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Pilgrim Nuclear Power Station - Final After Action Report, Exercise Date: November 16, 2016, Radiological Emergency Preparedness Program
	ML17053A456
Person / Time
Site:	Pilgrim
Issue date:	02/13/2017
From:	Colman S; US Dept of Homeland Security, Federal Emergency Management Agency
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML17053A456 (111)
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{{#Wiki_filter:/ U.S. Nuclear Regulatory Commission Document Control Desk One White Flint North 11555 Rockville Pike, Rockville, MD 20852

Dear Sir/Madam:

U.S. Department of Homeland Security FEMA I . 99 High St., S'h Floor Boston, MA 02110-2320 FEMA February 13, 2017 Enclosed is the final After Action Report from the November 16, 2016 Pilgrim Nuclear Power Station evaluated exercise. The Commonwealth of Massachusetts and local emergency response organizations successfully demonstrated their capabilities to implement off-site radiological emergency response plans based on a federal team's evaluation of the exercise. There were no Level 1 or Level 2 Findings as a result of the November 16, 2016 evaluated exercise. State and local preparedness remains adequate to protect the health and safety of the public living in the.vicinity the Pilgrim Nuclear Power Station and provides reasonable assurance* that appropriate measures can be taken off-site in the event of a radiological emergency . . If you have apy questions regarding this matter, please feel free to contact me at ( 617) 832-4 731 or Taneeka Hollins of my staff, at (617) 956-7523. ]:)fL-£ Steve Colman RAC Chair, Region I Enclosure E-copy: NRC Region I Doug Tift, Regional Liaison, NRC Region I www.fema.gov -"'.""' -* --, **--*---*--.-*;:--- Pilgrim Nuclear Power Station Final After Action Report Exercise Date: November 16, 2016 Radiological Emergency Preparedness Program FEMA Published February 13, 2017 Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Table of Contents Page I Table of Contents ......................................................................................................

... , ...........

-....... 3 Executive Summary ........................................................................................................................ 4 Section 1: Exercise Overview ......................................................................................... , ......................... 6 1.1 Exercise Details ************************************************************************************"**************************:.6

1.2 Exercise

Planning Team Leadership ............................................................................. 6 1.3 Participating Organizations ............................................................................................ 7 Section 2: Exercise Design Summary ........................................................................................... 11 2.1 Exercise Purpose and.Design ........................................................................................... ! i' 2.2 FEMA Exercise Objectives and Core-Capabilities ...........................

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11 2.3 Scenario Summary .............................

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11 Section 3: Analysis of Capabilities ............................................................................................... 12 3.1 Exercise Evaluation and Results .................................................................................. 12 3.2 Summary Results of Exercise Evaluation .................................................................... 12

Table 3.2 -Summary of Exercise Evaluation

................................................................. 13 3.3 Jurisdictional Summary Results of Exercise Evaluation .............................................. 18 3.3.1 Commonwealth of Massachusetts ................................................................... 18 3 .3 .2 Risk Jurisdictions ............................................ . 3.3.3 Host Jurisdictions ............................................ . Section-4: Conclusion ................................................................................................................... 29 Appendix A: Exercise Timeline .................................................................................................... 30 Appendix B: Exercise Evaluators and Team Leaders ..................................................................... 31 Appendix C: Extent of Play Agreement ............................. ......................................................... 34 Appendix D: Exercise Scenario Summary **************************************************************:********************85 3 Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Executive Summary On November 16, 2016, a Plume Exercise was conducted in the 10-mile plume emergency planning zone (EPZ) around the Pilgrim Nuclear Power Station (PNPS) by the Federal Emergency Management Agency (FEMA), Region I personnel. Out-of-sequence demonstrations of schools and special facilities were also conducted per the new 8-year exercise cycle. The purpose of the exercise and the out-of-sequence demonstrations was to assess the level of State and local preparedness in responding to a radiological emergency. The exercise and out-of-sequence demonstrations were held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures. The most recent prior full-scale exercise at this site was conducted on April 30, 2014. The qualifying emergency preparedness exercise was conducted on March 3, 1982. FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Massachusetts; the Massachusetts risk jurisdictions of Carver, Duxbury, Kingston, Marshfield, and Plymouth; the host jurisdictions of Taunton, Bridgewater and Braintree. The.various agencies, organizations, and units of government from these State and local jurisdictions who participated in this exercise are listed in Section III of this report. Protecting the public health and safety is the full-time job of some of the exercise participants . and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities. Cooperation and teamwork of all the participants were evident during this exercise. This report contains the final evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities: Schools and Daycares Duxbury .. Duxbury High School Duxbury Middle School Chandler Elementary School Alden Elementary School Kinvston, Sacred Heart Early Childhood Center Sacred Heart Elementary School Sacred Heart High School 4 l<--***-Unclassified Radiological* Emergency Preparedness Program After Action Report P/ymo14.th W Elementary School Plymouth Community Intermediate School

Plymouth South Middle School Plymouth North High School Plymouth South High, School Special Facilities Duxbury Group Facility and North* Hill Group Facility and Cordwood Plymouth Chilton House Rest Home Host Schools Braintree High School 2016 Pilgrim Nuclear Power Station 5 Unclassified
Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Section 1: Exercise Overview 1.1 Exercise Details Exercise Name _ 2016 Pilgrim Nuclear Power Station Radiological Emergency Preparedness (REP) Program Evaluated Exercise Type of Exercise Plume Scale Functional Exercise Exercise Date(s) November 16, 2016 Locations See the Extent of Play Agreement in Appendix C for a complete listing of locations.

Sponsors Program Department of Homeland Security (DHS)/Federal Emergency-Management Agency (FEMA) REP Program Mission Response Scenario Type Plume Phase Full Participation JIBP Exercise 1.2 FEMA Exercise Planning Team Leadership Steve L. Colman RAC Chair FEMA Region I 99 High St, 5th Floor Boston, MA 02110 617-832-4731 Steve.Colman@fema.dhs.gov John Rice Senior Technological Hazards Specialist FEMA Region I 99 High St, 5th Floor Boston, MA 02110 6 . -. ---*-------*-----*-----*--- Unclassified Radiological Emergency Preparedness Program After Action Report 617-956-7509 John.Rice2@fema.dhs.gov Taneeka Hollins Site Specialist FEMA Region I 99 High St, 5th Floor Boston, MA 02110 617-956-7523

1.3 Participating

Organizations .* 2016 Pilgrim Nuclear Power Station Agencies and organizations of the followingjurisdictions participated in the 2016 Pilgrim Nuclear Power Station exercise. . State Jurisdictions: Comffionwealth of Massachusetts Massachusetts Department of Mental Health . Massachusetts Air National Guard Massachusetts pepartment Public Health Massachusetts Department of Corrections Massachusetts Department of Transportation Massachusetts Emergency Management Agency MEMA Region II Massachusetts State Police Massachusetts United Way-211 Call Center 7 U oclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Risk Jurisdictions: Town of Braintree Emergency Management Agency Town of Braintree Office of the Mayor Town of Braintree Police Department Town of Braintree School Department Town of Braintree Board of Health Town of Bridgewater School Department Town of Bridgewater Police Department Town of Bridgewater Highway Department Town of Bridgewater Fire Department Town of Bridgewater Emergency Management Agency Town of Bridgewater Building Department Town of Bridgewater Board of Health Town of Carver Transportation Coordinator Town of Carver Special Needs Coordinator Town of Carver Shelter Officer Town of Carver School Liaison \ Town of Carver Police Department

Town of Carver Fire Department Town of Carver EOC Staff Town of Carver Emergency Medical Services Town of Carver Emergency Management Agency Town of Carver Council on Aging Town of Carver Board of Selectmen Town of Duxbury Department of Public Works Town of Duxbury Emergency Management Agency Town of Duxbury Fire Department Town of Duxbury Police Department
Town of Duxbury Regional Communications Center Town of Duxbury School Department Town of Kingston Emergency Management Agency Town of Kingston Fire Department 8 ----. . ----

-! Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Town of Kingston Police Department Town of Kingston Streets, Trees, and Parks Department Town of Kingston Su.perintendent of Schools Office Town of Marshfield Board of Selectmen Town of Marshfield Dept. of Public Works Town of Marshfield Emergency Management Agency Town of Marshfield Fire Department Town of Marshfield Harbormaster Town of Marshfield Police Department Town of Marshfield School Dept. Town of Plymouth Community Services Town of Plymouth Council on Aging Plymouth County Sheriff's Dept. Town of Plymouth Department of Public Work Town of Plymouth Medical Service Town of Plymouth Finance Town of Plymouth Fire Department Town of Plymouth Human Resources Town of Plymouth Information Technology . . Town of Plymouth Inspectional Services Town of Plymouth Marine and Townr of Plymouth OEM-CERT Town of Plymouth Office of Emergency Management Town of Plymouth Planning and Development Town of Plymouth Police Town of Plymouth Public Health Town of Plymouth Schools Town of Plymouth Town Management 9 , . Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Power Nuclear Power Station --.:... __ -._:__ _____ Support.Jurisdictions: Town of Braintree Emergency Agency Town of Braintree Office of the Mayor Town of Braintree Police Department' Town of Braintree School Department Town of Braintree Board of Health Town of Bridgewater School Dept. Town of Bridgewater Police Dept. Town of Bridgewater Highway Dept. Town of Bridgewater Fire Department Town of Bridgewater Emergency Management Agency Town of Bridgewater Building Department Town of Bridgewater Board of Health City of Taunton Community Volunteers City of Taunton Emergency Management Agency City of Taunton Engineer* Department City of Taunton Mayor's Office City of Taunton Police Department City of Taunton Public Works Department City of Taunton School Department City of Taunton Veterans Department City of Taunton Water Department Private Organizations: Entergy Nuclear American Red Cross Federal Agencies: Federal Emergency Management Agency Nuclear Regulatory Commission United States Coast Guard 10 Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Section 2: Exercise Design Summary 2.1 Exercise Purpose and Design The purpose of this report is to present the results and findings on'the performance of the offsite response organizations (OROs) during a simulated radiological emergency. FEMA Region I evaluated a biennial exercise (Plume Phase) for Pilgrim Nuclear Power Station on November 16, 2016. The exercise was designed to assess the capabilities of state' and local emergency preparedness organizations in implementing their Radiological Emergency Response

Plans (RERPs) and procedures to protect the public health and safety during a radiological emergency involving Pilgrim Nuclear Power Station. 2.2 FEMA Exercise Objectives and Core Capabilities The exercise capabilities, and activities are noted in the extent of play agreement, included in Appendix C, Exercise Plan. 2.3
Scenario Summary The exercise scenario was developed to evaluate the exercise participants' response to a radiological emergency.

11 Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Section 3: Analysis of Capabilities

3.1 Exercise

Evaluation and Results This section contains the results and findings of the evaluation of all jurisdictions and functional entities that participated in the November 16 , 2016 plume exercise and sequence (OOS) interviews and demonstrations during the 2016 exercise cycle. Each jurisdiction and functional entity was evaluated based on their demonstration of Capabilities and their equivalent REP criteria as delineated in the FEMA REP Program Manual dated January 2016. Detailed information on the evaluation criteria and the extent of play agreement for this exercise are included as appendices in this report. 3.2 Summary Results of Exercise Evaluation The matrix presented in the table on the following pages presents the status of all exercise evaluation area criteria that were scheduled for demonstration during the exercise. Exercise criteria are listed by number, and the demonstration status of those criteria are indicated b y the use of the following letters:

M: Met (no level 1 or level 2 findings assessed and no unresolved findings from prior exercises)
Fl: Level 1 finding (formerly LEVEL 2 FINDINGS ) assessed
F2: Level 2 finding (formerly area requiring corrective action) assessed or unresolved from a prior exercise
P: Plan issue
N: Not demonstrated Note: Blank fields indicate criterion was not evaluated at that location.

12 Unclass ified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Po we r Station Table 3.2 -Summary of Exercise Eva luati on "" u D ATE: 2016-11-16 f-.'.. f-.'.. 0 u """ w SITE: Pilgrim Nuclear Power Station , MA u 0 u u < 0 0 w """ """ :::; u 0 w u w en en en en 0 w -0 0 --Q.. , C.. p.. z w c c: <; M: Met, 1: Level 1 Finding, 2: Level 2 Finding, w -C2 ;z ;z :z .. :::l .9 <.:: en "" Q., Q., Q., Q.. "' .J:J "' .<= P: Plan Issue N: Not Demon strated <( <( < < < < < C; x OD "' :::l c: "' u 0 Q Emergency Operations Management Mobilization !al M M M N N M M M M M Facilities Direction and Contro l l e i M M M M M M M M Communicatio n s Equipment ldl M M M M N N M M M M M Equi pm e nt and Supplies to Support Operations lei M M M M N N M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2a l M M Dose Assessment & P ARs & P ADs for the Eme r gency Event 2bl M M Dose Assessment & PARs & PAD s for the Eme r gency Event 2b2 M M PADs for the Protection of persons with disabilities and access/fu nc tio n al 2cl M M M ne e d s Radiological Assess ment and Decision-making fo r the Ingestion Expos ur e 2d l Pathway Radiological Assessment & Deci sio n-making Concerning Po st-Plume Phase 2el Re l ocation , Reentrv , and R eturn Protective Action Implementation lmo l ementation ofEmern:e nc v Worker Ex oosure Co ntrol 3al M M N N M M M M M Implementation ofKI Decision for Institutionalized Indi viduals and the Public 3bl M M M M Implementation of Protective Actions for persons with disab ili ties and 3c l M M M M M M access/functional n eeds Implementation of Protective Actions fo r persons with disabilities and 3c2 M M M M M access/functional ne e d s M Implementation ofTraffic and Access Co ntrol 3dl M M M M M M Imp l ementation ofTraffic and Access Control 3d 2 M M M M M M Implementation of Ingestion Pathway Decisions 3el Implementation of Ingestion Pathwa y Decisions 3e2 Im plement ation of Po st-Plume Phase Relocation , Reentry , and Return 3fl Decisions Field Measurement and Analysis RESE R VED 4al Plume Phase Field Measurement and Analyses 4a2 M Plume Phase Field Measurement and Analyses 4a3 N N Post Plum e Phase Fie ld Measurements and Samp lin g 4bl Laboratory Operations 4cl Eme r gency Notification and Public Info Activation of the Prompt Alert and Notification System 5al M RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System Sa4 Eme r ge nc y Information and Instructions for the Public and the Media Sb! M M M M M M M M 13 U ncl ass ifi ed Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Support Operations/Facilities Monitoring , Decontamination , and Registration ofEvacuee s 6al Monitoring and Decontamination . .ofEmergency Workers and their Equipment 6bl and Vehicles 14 Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Power Nuclear Power Station Table 3 .1 -Summar y of E x ercise Evaluation (Continued. page 2/3) I 0 c:: l 0 <JJ DATE: 2016-11-16 ..c:: c u E u <) c: 0 Cl'.l <JJ <JJ .".:l u <JJ SITE: Pilgrim Nuclear Power Station u u ..c:: =a E t.Ll 0 t.Ll u -0 c: 0 00 <JJ <JJ t:: t.Ll .... 0 :E E t.Ll 2 "' £ "' t.Ll .... <JJ <JJ <JJ M: Met, 1: Level 1 Finding , 2: Level 2 Finding , <JJ :: c: c c <JJ :c :c ::I 0 <JJ 8 ::I ::I =a c: 0 P: Plan Issue , N: Not Demonstrated E c: 00 c: ..c ..c c: <JJ e e ;>-. *;;; :2 ::I x x "' -0 <) <) .... i:!3 "' ::I ::I ..c:: "' "' 0::: co f-Ci Ci u Cl'.l Cl'.l Ooerat i ons Man;i.gem ent Mobilizat i on la! M M M M M M M M M M Facilities !bl M M M M *Direction and Control !cl M M M M I Communications Equipment Id! M M M M E quipment and Supplies to Support Operations lei M M M M P ro teal v e A c ti oo D eeisio n " *---* -*** Emergenc y Worker Exposure Control 2al 1 Dose Assessment & P ARs & P AD s for the Emergenc y Event 2bl Dose Assessment & P ARs & P ADs for the Emergency E v ent 2b2 P ADs for the Protection of persons with disabilities and acces s/functional needs 2cl ' Radiological A s ses s ment and Decision-making for the Inge s tion Exposure 2dl I Pathway Radiological Assessment & Decision-making Concerning Post-Plume Phase 2el Relocation , Reentry , and Return .. Protective Action ful pl em.¢ntatio n > ,,.,... Implementation ofEmergency Worker Exposure Control 3al M IM IM IM of.KI Decision for Institutionalized Individuals and the Public 3bl M M M M M M !Implementation of Protective Actions for persons with disabilities and 3cl M access/functional needs Implementation of Protective Actions for persons with disabilities and 3c2 M M M M M M M ! access/functional needs 'Implementation of Traffic and Access Control 3dl M M M M Implementation of Traffic and Access Control 3d2 M M M M I Implementation of Ingestion Pathway Decisions 3el . Implementation of Ingestion Pathway Decisions 3e2 ' Implement a tion of Post-Plume Phase Relocation, Reentry , and Return 3fl Decisions 'Ft eid Measurement anJi Aruil fs is "' >Ai "' "+ , , ;RESERVED 4al !Plume Phase Field Measurement and Anal y se s 4a2 Plume Phase Field Measurement and Analyses 4a3 i Post Plume Phase Field Measurements and Sampling 4bl I Laboratory Operations 4cl Em ergency No t fif cation and RU bilc lri:t'o ":'i,!'*<*if<W ,.__. I II' .. --;!.¥-. Activation of the Prompt Alert and Notification System 5al RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instructions for the Public and the Media 5bl IM 15 U ncla ss ifi e d Radio l ogica l Emerge n cy Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Table 3.1 -Summary of Exercise Evaluation (Contin u e d. page 3/3) 0 <U DATE: 2016-11-16 0 0 <U E -= 0 B =o 0 0 u -= -= -= :r:: SITE: Pilgrim Nuclear Power Station Cl'.l u "' :-g Oil Oil 0 -= Cl'.l :-0 :c i t; -= <U u Oil § Cl'.l :I: = = M: Met , 1: Level 1 Finding, 2: Level 2 Finding , "E B = t:: = <U -= t:: 0 0 0 en Oil <U ..= z = """ :c "' E Cl'.l Cl'.l 0 "O P: Plan Issue, N: Not Demonstrated <U -= -= -= -= :r:: :r:: <U :I: 0 <U g :; = = c: 0 "O 0 0 0 _g -= ;::: t; E E E E 'E c: t:: *e u . ,.?;> >. >. :.c 0 0 "' ;;::: ;;::: ;;::: Cl'.l """ u z u i:o Emergency Operations Management Mobilization J al M M M M M M N N N N Facilities lb! Direction and Control lei Communications Equipment !di Equipment and Supplies to Support Operations !el Protective Action Decision Making Emergency Worker Exposure Control 2al Dose Assessment & P ARs & P ADs for the Emergency Event 2bl Dose Assessment & P ARs & P ADs for the Emergency Event 2 b 2 P ADs fo r the Protection of persons with disabilities and access/functional 2cl needs Radiological Assessment and Dec i sion-making for the Ingestion Exposure 2dl Pathwav Radiological Assessment & Decision-making Concerning Post-Plume P h ase 2el Relocation , Reentrv , and Return Protective Action Implementation Implementation ofEmern:encv Worker Exoosure Control 3al M M M M M MN N N N Implementation of KI Decision for Institutionalized Individuals and the Public 3bl Implementation of Protective Actions fo r persons with disabi l ities and 3cl access/functional needs (other than sc h ools) Im pl e m entation of Protective Act i o n s fo r perso n s with disabilities and 3c2 M M M M M M N N N N access/fu n ctional needs( schoo l s) Imp l ementat i on of Traffic and Access Control 3dl Imp l ementation ofTraffic and Access Control 3d2 Implementation oflngestion Pathway Decisions 3el Implementation oflngestion Pathway Decisions 3e2 Implementation of Post-Plume Phase Relocation , Reentry , and Return 3fl Dec i sions Field Measurement and Analysis RESERVED 4al Plume Phase Field Measurement and Analyses 4a2 P l ume Phase Field Measurement and Analyses 4a3 Post Pl ume Phase Fie l d Measurements and Samp l ing 4bl Labo r atory Ope r ations 4c l Emerge n cy Notification and Public fnfo Activation of the Prompt Alert and Notification S y stem 5al RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instructions for the Pub l ic and the Media 5bl 16 Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Support Operations/Facilities Monitorin11:. Decontamination , and Re11:istration ofEvacuees 6al Monitoring and Decontamination ofErnergency Workers and their Equipment 6bl and Vehicles Temporary Care of Evacuees 6cl Transportation and Treatment of Contaminated Injured Indi v iduals 6dl 17 Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3 Criteria Evaluation Summaries

3.3.1 Commonwealth

of Massachusetts 3.3.1.1 MA State Emergency Operations Center In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET:* l.a.l, l.c.l, l.d.l, l.e.l, 2.a.l, 2.b.l, 2.b.2, 2.c.l, 3.b.l, 3.c.l, 3.d.l, 3.d.2, 5.a.l, 5.b.l b. LEVEL 1 FINDING: None c. LEVEL 2 FINDING: None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.1.2 MA 211 Call Center In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: l.d.l, l.e.l, 5.b.l. b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.1.3 MA Region II EOC In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: l.a.l,'l.b.l, l.c.l, l.d.l, l.e.l, 3.a.l, 3.b.l, 3.c.l, 3.c.2., 3.d.1, 3.d.2, 5.bl b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None 18 Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan Pilgrim Nuclear Power Station f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.1.1.4 MA (PNPS) Emergency Operations Facility In summary, the status ofDHSlFEMA criteria for this location is as follows: a. MET: I.a.I, 1.c.1, 1.d.1, 1.e.1, 2.a:l, 2.b.l, 2.b.2, 2.c.1, 4.a.2. b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f.

PRIOR ISSUES -RESOLVED:

None g. PRIOR ISSUES -UNRESOLVED: None 3.1.1.5 MA (PNPS) Field Monitoring Team-1 In. summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: 1.d.1 (All other criteria Observed only demonstrated during 2016 Seabrook Exercise)

b. LEVEL 1 FINDINGS : None . c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

None f. PRIOR ISSUES -RESOLVED: 1.d.l (2016 Seabrook)

g. PRIOR ISSUES -UNRESOLVED:

None 3.1.1.6 MA (PNPS) Field Monitoring Team-2 In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: Observed only (demonstrated during 2016 Seabrook Exercise)

b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 19 Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan. Pilgrim Nuclear Power Station 3.1.1.7 MA (fNPS) Joint Information Center In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: 1.a.1,1.c.l, l.d.1,.1.e.l, 3.b.l,. 5.b.l. b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None . f. PRIOR -ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2 Risk Jurisdictions 3.3.2.1 Carver Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: l.a.l, l.c.l, l.d.l, Le.I, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.b.l. b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.2 Duxbury Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: I.a.I, l.c.l, l.d.l, Le.I, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.b.l. b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 20 Unclassified Radiological Emergency Preparedness Progiam (REP) After Action Report/Improvement Plan 3.3.2.3 Duxbury High School In summary, the status ofDHS/FEMA criteria for this location is as follows: MET: l.a.1, 3.b.1, 3.c.2 b. LEVEL I FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES :. UNRESOLVED: None 3.3.2.4 Duxbury Middle School In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: I.a.I, 3.b.1, 3.c.2

b. LEVEL I FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: Norte 3.3.2.5 Chandler Elementary School . In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: l.a.1, 3.b.1, Jc.2 -b. LEVEL I FINDINGS : None c. LEVEL 2 FINDINGS.

None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.6 Alden Elementary School . In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: I.a.I, 3.b.1, 3.c.2 b. LEVEL I FINDINGS : None 2I. Pilgrim Nuclear Power Station Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan Pilgrim Nuclear Power Station c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f.

PRIOR ISSUES -RESOLVED:

None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.6.1 North Hill Group Facility (Duxbury)

In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET:None b. LEVEL I FINDINGS:

None c. LEVEL2FINDINGS:None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED:

I.a.I, 3.b.l, 3.c.2 (will be demonstrated in20I 7) f. PRIOR ISSUES-RESOLVED: None , g. PRIOR ISSUES-UNRESOLVED: None 3.3.2.6.2 Cordwood Group Facilities (Duxbury) In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET:None b. LEVEL I FINDINGS: None c. LEVEL2FINDINGS:None

d. PLAN ISSUES: None e. NOT DEMONSTRATED:

I .a. I, 3 .b.1, 3 .c.2 (will be demonstrated in 20 I 7) f. PRIOR ISSUES-RESOLVED: None g. PRIOR ISSUES-UNRESOLVED: None 3.3.2. 7 Kingston MA Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: I.a.I, l.c.l, l.d.l, Le.I, 3.a.I, 3.c.1, 3.c.2, 3.d.l, 3.d.2, 5.b.l. b. LEVEL I FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 22 *--------------- Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.8 Sacred Heart Early Childhood Center In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 3.b.l, 3.c.2 b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None

3.3.2.9 Sacred Heart Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: . ** a. MET: 1.a.l, 3.b.l, J.c.2 b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.10 Sacred Heart High School In summary, the status of criteria for this location is as follows: a. MET: 1.a.l, 3.b.l, 3.c.2 b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES-UNRESOLVED: None 23

Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.11 Marshfield Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: l.a.1, l.c.l, l.d.l, l.e.l, 3.a.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.b.l. b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.12 Plymouth Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows: *a. MET: I.a.I, l.c.l, l.d.l, l.e.l, 3.a.l, 3.c.l, 3.c.2,'3.d.l, 3.d.2, 5.b.l. b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 24 U oclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan 3.3.2.13 West Elementary School In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: I.a.I, 3.b.l, 3.c.2 h. LEVEL I FINDINGS : None 1. LEVEL 2 FINDINGS : None J. PLAN ISSUES: None k. NOT DEMONSTRATED: None I. PRIOR ISSUES -RESOLVED: None m. PRIOR ISSUES -UNRESOLVED: None 3.3.2.14 Plymouth Community Intermediate School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: I.a.I, 3.b.l, 3.c.2. b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.15 Plymouth South Middle School Pilgrim Nuclear Power Station In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: I.a.I, 3.b.l, 3.c.2. b. LEVEL 1 FINDINGS :None c.

LEVEL 2 FINDINGS :None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 25 Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.16 Plymouth North High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: I.a.I, 3.c.2. b. LEVEL 1 FINDINGS :None c. LEVEL 2 FINDINGS :None d. *PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.17 Plymouth South High School In summary, the status ofDHS/FEMA criteria for this -location is as follows: a. MET: I.a.I, 3.b.l, 3.c.2. b. LEVEL 1 FINDINGS :None c. LEVEL 2 FINDINGS :None d. PLAN ISSUES:. None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.18 Chilton House Rest Home In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET:None b. LEVEL 1 FINDINGS: None c. LEVEL2 FINDINGS: None d. PLAN ISSUES: None e. NOT DEMONSTRATED: I.a.I, 3.b.l, 3.c.2 (will demonstrated in2017) f. PRIOR ISSUES-RESOLVED: None g. PRIOR ISSUES-UNRESOLVED: None 26 Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.3 Support Jurisdictions 3.3.3.1 Braintree Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: l.a.l, l.c.l, l.d.l, l.e.l, 3.d.1, 3.d.2, 5.b.1

b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

None f. PRIOR ISSUES -RESOLVED: Non 3.3.3.1.2 Braintree High School In summary, the status ofDHS/FEMA criteria for this location is as follows: a. MET: Non.e (Not Evaluated)

b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED:

l.a.l, 3.a.l, 3.c.2 (moved to next year) f. PRJOR ISSUES-RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 3.3.3.2 Bridgewater Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: l.a.l, l.b.l, l.c.l, 1.d.l, Le.I, 3.d.l, 3.d.2, b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None d. PLAN ISSUES: None e. NOT DEMONSTRATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 27 U oclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan " 3.3.3.3 Taunton Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: La.I, Lb.l, Le.I, Ld.l, Le.I, 3.a.l, 3.c.1, 3.d.1, 3.d.2, b. LEVEL 1 FINDINGS : None c. LEVEL 2 FINDINGS : None q. PLAN ISSUES: None e. NOT DEMONS1RATED: None f. PRIOR ISSUES -RESOLVED: None g. PRIOR ISSUES -UNRESOLVED: None 28 Pilgrim Nuclear Power Station *-*r -* * **---------

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Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/Improvement Plan _Pilgrim Nuclear Power Station Section 4: Conclusion The state and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures. All activities were implemented as they would be in an actual emergency unless specified otherwise in the extent of play agreement. There were no "Findings" identified during this exercise. One prior "Finding" from the 2016 Seabrook Station Plume Exercise was resolved. 29 U nclassi fi ed Ra d io l og i cal Emerge n cy P r e p are dn ess P rogram (RE P) After Actio n Report/Improve m e n t Plan P ilgrim Nuclear Power Statio n A ppendix A: Ex erci s e T imelin e EX E RCI S E TIMELIN E Date and Site: November 1 4-18 , 2016; Pilg ri m Nuclear Powet Plan t r-TWloliil ... T t*l.Ml -*EJlllt -.. IA llEll liWT liWT ea,,., r.,_ Dudllly l;nliiell ...,_.. T-sm,.-in..r... 1EOC 2:11 112 It a I UC Ell' EOC EOC EllC EOC EOC EOC EOC EllC Event 08 1 4 0825 0!!24 NA 0824 0824 0824 0824 0824 0824 0824 0824 0825 Alert 085 1 D90 1 0005 0008 0852 0900 0904 0002 QQll2 OIKl1 000 1 OIKl2 0008 Si.e hea Emergerey 1 027 1 033 1 005 1 028 1 D27 1 036 103 7 1 042 1034 1 033 1 046 1 033 1 037 General Emergency 11 3 1 11 38 11 43 1 133 11 3 1 1'1 40 1 1 42 11 38 1 145 113 8 1 1311 11 39 1 1 4 1 Sin wted RadioadM!y 1 043 1046 1 050 1 104 1 ()43 1D55 1052 1138 1 027 1 D55 1.05e 105 1 1 D5!i Release Began Sin wted RadioadM!y 1231 NA NA 1 303 t Z3 1 NA 1304 NA NA NA NA NA NA Release T erminaied F aciity Declared Opera1ionai 09 1 5 Oll08 H Xl3 0948 0900 0835 09 1 2 0927 0900 OQ32 0900 08!i7 Gov Dec!aratioo c:i state c:i Emergency 1000 1 008 1 000 1 006 1 006 10 1 2 1000 1 025 10 1 0 1 000 10 1 6 1 026 Oedaraiion a Local Emergency NA NA NA 0913 1000 0945 0055 ooro 1 0 1 4 112D 0008 Exen:ise Tenn i na.ied 1303 1303 1 303 1 306 1305 1 304 1307 1 305 1303 1 3D!i 1 303 1.:113 Pn!cautiooary Actions: Si1!n Soimed Area 4 (Plymoo1h NA NA NA NA NA NA NA NA NA Dll44 NA NA NA EOC) Close Parks DQ54 09!i7 1 008 1 000 0925 1004 1 026 1 107 Dll5ll 1 1D 7 NA 1010 Reslrid W* T raffic [)Q3!i 0944 1000 1 000 0925 1 004 1 D26 1 1 07 00311 Ol!48 0052 10 1 0 Rl!5iricl Ra il Traffic 1048 NA 12 40 1 000 0925 1 004 1 026 11 07 @39 Ol!48 0052 1010 Re5lrid Air5Dace 1 048 NA 1 2411 1 000 0925 1.004 1 026 1107 0039 004S Dll52 10 10 Shelll!r I M!slcc:t. s1Dr1!d feed , & water 1 027 1 057 1 008 1 026 111 3 1 11 4 1 026 1 107 11 08 1 107 1111 10 10 Sc:hoot Transfers 11944 NA OQ50 NA 09!i!i (Jg5ij NA NA NA 004S 09!i2 OQ44 1<< A&N OecisK>n '1 055 1 057 1 100 NA 111 3 1028 111 4 1100 11 00 '1111 5 NA NA 1* Sil!n Activation 11D7 1107 11 07 NA 1 1 07 1107 11 07 1107 1 1117 1107 1 106 1107 1<< EAS Messaoe 1 1 1 0 111 0 111 0 NA 1'1 1D m o m a 111 0 111 0 t11 0 11'1 D 111 0 pJ MN Decision 11 53 11 53 1 156 NA 1 205 1 204 1 2!17 1 200 11 56 1 157 11 56 NA pJ Si ren Activalil n 1 2!15 1 205 1 205 NA 1 205 '1 2D!i 1 205 1205 1205 1 2!15 1 205 NA pJ EAS Messaae 1 208 1208 1 208 NA 1208 1 208 1208 1 208 1 208 1 208 1 208 1238 Kl Decision: EWs advised tD t ake Kl 1 055 1D!i7 1 104 1 055 111 3 H 2tl 11 1 4 111 0 111 0 11D7 11 00 NA General Public advised to lake K l 1 055 1D!i7 1 104 1 055 11 13 111 4 111 4 111 0 111 0 '11 07 11 06 111 3 U ncla ss ified Radiological E mer gency Preparedn ess Program (REP) After Action Report/Improvement Plan Pilgrim Nuclear Power Station Location MA SEOC MA211 MEMAR2 nc EOF FMTl FMT2 CarverEOC inject) Kingston EOC DuxburyEOC Marshfield EOC Appendix B: Exercise Evaluators and Team Leaders 2016 Pilgrim Station Plume Evaluator Assignments Steve Colman-RAC Chair John Rice-Senior Site Specialist Taneeka Hollins-Pilgrim Site Specialist Evaluator Criteria Ingrid Pierce (TL) Barbara Thomas Helen Laforge Mike Howe Larry Broockerd Bill Webb (TL) Nick Buls Bill McDougall Linda Gee (TL) Ken Wierman (TL) Tim Pflieger Nan Calhoun Korky Dulgerian Mike Shuler (TL) Patti Gardner Lee Torres (TL) Tina Lai-Thomas Brian Hasemann (TL) Miriam Weston lcl, Sal lal, ldl , lel, 5.b.1 3bl , 3cl, 3dl, 3d2 2al, 2bl, 2b2, 2cl ldl, lel , 5bl lcl lal , ldl , lel , 5bl 3al,3bl,3cl,3c2,3dl,3d2 lal, lcl, ldl , lel, 5bl lal, lcl , ldl, lel , 4a2 2al, 2bl, 2b2 , 2cl OBSERVED ONLY OBSERVED ONLY lal , lcl, ldl , lel , 5bl 3al, 3cl , 3c2, 3dl, 3 d2 *(impediment lal, lcl, ldl , lel, 5bl 3al,3cl,3c2,3 dl ,3d2 lal , lcl , ldl , lel , 5bl 3al ,3 cl,3c2,3dl,3d2 Lauren DeMarco (TL) lal , lcl, ldl , lel , 5bl Pat Fos ter/ TJ Swenson (OJT) 3al,3cl, 3c2 , 3dl, 3d2 31 Unclassified Ra d io l ogica l E m e r ge n cy Preparedness Pr ogram (REP) Afte r Ac t io n Re p ort/I mp rove m e n t Pl an Plymouth EOC Taunton EOC Bridge w ater EOC Braintree EOC Joe Suders (TL) Lisa Rink R y an Jones (TL) Rufus Mobley Mark Dalton-IC F (TL) Kent Tosch -ICF Tom Hegele -ICF (TL) Bruce Swiren -ICF lal , lcl , ldl , lel , 5bl 3al , 3cl , 3c2 , 3dl , 3d2 lal , lcl , ldl , lel 3al , 3dl , 3d2 , 5bl lal , lcl , ldl , lel 3al , 3dl , 3d2 , 5bl lal , lcl , ldl , lel 3al , 3dl , 3d2 , 5bl P ilgrim Nu cle ar P owe r Sta t io n *Schools/Special Facilities-Evaluated Out of Sequence b y Taneeka Hollins (Site Specialist 32 U nclassified Radiological E m erge n cy P reparedness Pr ogram (RE P) After Ac t io n Report/Improvement P lan P ilgrim Nuclear P owe r Statio n This page is intentionall y blank 33 Appendix C: Extent of Play A1:reement PU,GBIM NI J CLEAB POWER STATION EXEBCJSE -Noyember 16 2016 MASSACHUSETTS EVALUATIONAREASANDEXTENTOFPLAY Overview The following organizations/locations will demonstrate in 2016: State Emerge ncv Operations Ce nter Massachusetts Emergency Management Agency Massachusetts Department of Pub li c Health Massachusetts State Police MassDOT Massachusetts National Guard Massachu s etts Department of Mental Health Office of the Secretary of the Commonwealth US Coast Guard American Red Cross Federal Emergency Management Agency Region l Pilgrim Nuclear Power Station Liaison MASS 211 Call Center Region D Emergency Operations Center Massachusetts Eme r gency ManagementAgency-Region II Massachusetts State Police Mass DOT Massachusetts National Guard Pilgrim Nuclear Power Station Liaison American Red Cross MBT ARepresentative Department of Corrections-Bridgewater Plymouth County SheriffEmergency Management Agency E mergency Operations Facility Massachusetts Emergency Management Agency Massachusetts Department of Public Health/Radiation Control Program Pilgrim Nuclear Power Station Radiological Field Monitoring and Samp ling Teams Mas s achusetts DepartmentofPublic Health/Radiation Control Program Pilgrim Nuclear Power Station Joint Information Center Massachusetts Emergency Management Agency Pi l grim Nuclear Power Station EAS Radio Station WBZ 1030AM RiskJuri s dictions CarverEOC DuxburyEOC Kingston EOC Marshfield EOC PlymouthEOC Pilgrim EOP Rev. 0 rage 1 01 so 01121116 PU,GBJM NI J Q.EAR POWER STATION EXERCJSE-November 16 2016 Sup portJu risdi ctions Braintree Command Center Bridgewater EOC TauntonEOC The following demonstrations were conducted out of se quence Summer 20 l6 Mass State Police Dosimetry Demonstration MS I Hospital-Good Samaritan Hospital September 29 , 2016 SchoolsandDaycares: Duxbury: Duxbury High School Duxbury Middle School Chan dler Ele mentary School Alden Elementary School Kingston: Sacred Heart Earl y Childhood Center Sacred Heart Elementary School Sacred Heart High School Plymouth: West Elementary School Plymouth Community Intermediate School Plymouth South Middle School Plymouth North High School Plymouth South High School Special Facilities Duxbury:

Gro up Facility and North Hill Group Facility and Cordwood Plymouth:

C hilton House Rest Home HostSchools: Braintree High School Per FEMA Region I Memorandum dated, February 27, 2012, "On the Spot" corrections as outlined in Rgcqmmgndqtiqn Tnjtiqtiyg 1 5 -Correct Issues fmny:diqtetv is approved for the following criterion: l.d.l, Le.I, 3.a.l, 3.b.l, 3.d.l, 3.d.2, 4.a.3, 4.b.J, 5.b.J, 6.a.1, and 6.b.J. Pilgrim EOP Rev. 0 Page 2 of 50 07/27/16 -. PU , GBIM MfCJ,EAB POWER STATION EXERCISE-Noyember 16, 2016 EVALUAUONAR£A T* Emergency Qnemtiqny Mqnqgemen( I Sub-element J.a-Mobilization Intent This sub-element is derived from ll/UREG-0654 /FEMA-REP-J , whic h requires that Oifsite Response O r ganizatio n s (ORO) have the capability to alert , notify, and mobilize e m erge n cy personnel and activate and staff e merg e n cy facilities. Criterion

1. a. I: 0 ROs use effective procedures to alert , notify , and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654/FEMA-REP-J, A.ia, e; Extent of Play Responsible OROs must demonstrate the capa bility to receive notification of an in cident.fro m the li ce n see, verify the notification , and co nta c t , alert , and mobilize key emergency personnel in a timely manner and demonstrate the ability to maintain and staif24-h our opera t io ns. Twenty-four hour operations can be demonstrated during the exercise via rosters or shift c han ges or o therwise in an actual activation.

Local responders must d emonstrate the abi lity to receive and/or ini tiat e notification to the licen s ees or o th er respective e mergency management organiza ti ons of an incident in a timely manner , when they receive information fro m the licensee or alternate source s. Responsible OROs must demonstrate the activation of facil iti es fo r i mme diate use by mobili:::ed personnel upon their arrival. Activation of facilities and staff, including those associated with the ICS, must be complete d in accordance with ORO plan s/proced u res. The location and c ontact informatio n for facilities includ e d in the incident command must be available to all appropriate responding agencies and the N P P after these facil iti es have been activated. Pre-positio nin g of e mergency personnel is appropriate , in ac c ordance wi th the Extent-of-Play A greement , at those facil iti es located beyond a normal commuting distance from the individual 's duty l ocatio n o r residence. This includes the staggered release of resources.from an assembly area. A dditionally , pre-positioning ofstajffo r out-of-sequence demonstrations may be used in accordance with the Exten t-of-Play A greement. The REP program does not evaluate Incident Command Post tactical opera 1 ions (e.g., Law Enforcement hostile action suppre s sion te c hniques), only coordination among the incident comma nd , th e utility , and all appropriate OROs, pursuant to plans/procedures. Initial law enforce m ent , fire service , HA Z: MAT, and e mergency medical response t o the NP P si t e may impact the ability to s taff REP functions. The ability to identify and request additional r e source s or identify compensato1y me asures must be de m onstrated. Exe r cises must also address the role of mutual a id in the incident , as appropriate. An integral part of the response to an HAB scenario at an NPP may also be withi n the auspices of the Federal Government (e.g., FBI, NRC , or DHS). Protocols for requesting Federal , State , local , and Tribal law enforcement s upport must be demonstrated. as appropria t e. Any resources must be on the ORO 's mobilization list so th e y c an be c ontac t ed during an incident , if needed. A ll activities mu st be based o n the ORO 's plans/proc e dures and c ompleted as they would be in an a c tual emergency , unless noted above or otherw i se specified in the Exte nt-of-Play A greement. Pilgrim EO P Rev. 0 Pagel of SO 07/27/16 W.GBIM NI!Q;EAB POWER STATION J;XEBCJSE-Nsiygmbcr 16 2016 Massachusetts Extent of Pla y State EOC-Massachusetts Emergency Management (MEMA) SEOC emerge n cy staff , including the Massachusetts Emergency ManagementTeamstaff(Massachusetts DepartmentofPublicHealth (MDPH), Massachusetts Department ofT ransportation (MassDOT), Massachusetts Department ofMental Health (MDMH), Massachusetts State Police (MSP), US Coast Guard , ;Massachusetts I Army National Guard (MANG), and American Red Cross (ARC), the State Public Information Line (Mass 211) staff , the Federal Emergency Management Agency (FEMA), *and the Pilgrim Nuclear Power Station Liaison will be pre-staged at TBD in the SEOC cafeteria, and upon notification , will r eport to the EOC , using a tenminute per hour travel time. The notification process will be comp l eted , and call down rosters will be shown to the FEMA Evaluator. The MASS 211 Call Center will be activated for an event at Pilgrim Station. Region II EOC-MEMA Region II EOC staff and emergency volunteer staff will pre-staged at TBD outside the Region II EOC , and upon notification , will report to the Region Il EOC, u sing a ten-minute per hour travel time (note: MEMA Region II staff who report prior to TBD will report at their normal reporting time). The notification proce ss will be com pl eted and call down rosters will be shown to the FEMAEval uat o r. the EOF, and upon notification , will report to the EOF using the I 0 minute to hour travel time. Joint Informatio n Cente r (JlC}--MEMA personnel will be pre-staged in tbe area of the JlC and upon notification , will report to the JlC using the 10 minute to hour travel time NIA T Field Monitori ng Team Personnel-Field Team personnel wi ll be pre-staged at the EOF and up on notification , will report to the EOF using the I 0 minute to ho ur travel time. Loca l EOCs--Local EOC emerge n cy response staff will be pre-staged at TBD o u tside the local EOC and upon notification , will report to the EOC , u si ng a ten-m inute per hour travel time. State Police Troo p D-Will dispatch representatives to the Region II EOC , b ut traffic and access control personnel will not be mobilized (s ee Eval u ation Area 3.d.). Plymouth Co un tv Sheriff's Eme r gency Management Age n cy CPCSEMA)-Wi ll d emo n strate com muni cations with emergency staff and obtain ETA; however , staff and vehicles wi U not be mobilized , except for the PCS EMA li aison who wi U report to the MEMA Region U EOC. Transportat i o n Providers-C alls will be made to a ll transportation providers to verify the contact information. FEMA will eval uat e the contact of the transportation provider s during the practice exercise. A Co ntr oller message will refer to the matrix to provide the number of vehicles and drivers available for exercise play. No vehicles or personnel will be mobilized. Level l or Level 2 Findings: NIA Pil&rim EO P R ev. 0 P age 4 of 50 07127116 I Commented [CK(1]: PU , GBIM NI J Cl,f;AB POWER STATION EXf:BQSE -Ngyemhcr 16 2016 I Sub-element I. b-Facilities Intent This sub-el e m e nt is de riv e d from NU REG-0654/FE MA-REP-I , which requir es thatO.ffsite Response Organi z ations (ORO) have facilitie s to s upport the e mergency r es ponse. Criterion

1. b.1: Facilities are sufficient to support the emergency response. (NUREG0654/FEMA-REP-1, G.3.a; H.3; J.10.h; J.12; K.5.b) Extent of Play Res p o nsible O R Os mu s t de m o n s tr a t e, n o l es s than o n ce eve t y 8 yea r s , th e av a ilabili ty of faci liti es to s upp o rt a cco mplishm e nt o f e mer gency o p e rati o n s. T hi s includ es all alt e rn a t e and ba c kup f a c ilitie s. Ev aluati o ns a r e ty pi ca lly pe r fo rm ed/or EOCs a ndJ!Cs , as we ll as o ther f a c il i t ies s u c h as r ece pt ion/r e l oca ti o n ce nt e r s. So m e oft he a r eas eva luat e d w ithin the f a c ilit ies a r e ad e quate s p ace , fu rni s hin gs , li g hting , r es tr oo m s , ve ntilat io n , access t o ba c kup p o w e r , and/o r a lt e rna te f a c ili ty, if r e qu i r e d to s upport o perati o ns. Radio s tati o n s , lab o rat o r ies, initial warnin g point s and h os pital s ar e not e valuat e d und er l.b.I. I n a d d iti o n.f a c iliti es wi ll b e ev alu a t e d/o r this c rit e ri o n d urin g th e firs t bi e nni a l exe r cise a ft e r a n y n ew or su b s tantial c hanges in st r u c t u r e , e quipm e nt , o r mi ss i o n that aff ec t key c apabiliti es, a s 0 111lin e d in r es pe c tive e mer g en cy plan s/p r o c e dur es . .4 s ub s tantial c han ge i s o n e t har ha s a dir ec t e ff ec t o r impa c t o n eme r ge n cy r e s po n se oper at io ns perfo rm e d in t h ose fac il i ti es. Exa mpl es o f s ub s t a nt i al c han ges i nclud e m o d ify i ng th e si=e o r config urat io n of a n e m erge n cy ope ra tions center , a dd in g m o r e function t o a ce nt er , o r c han g ing t he e qu ip m e nt av ailabl e/or u se in a ce nt e r. A ll ac tiviti es mu st b e ba se d o n th e O R O 's plan s/p r oce dur es and co mpl e t e d a s th ey wo uld be i n an a c tual e m e r ge n cy, unless n o t e d a b o ve o r o th e n vise s p ec ifi e d i n the Ex t e nt-of-P l ay Agree m e nt. Massachusetts Extent of Play There are no new or renovated facilities within the Pilgrim Massachusetts EPZ. The Bridgewater Reception Center facility at the Tin s ley Center w e re evaluated in 2015. There will not be a FEMA evaluation of alternate or backup facilities during this exercise Level 1 or Level 2 Findings:

N/A Pil&rim EOP Rev. 0 Page 5 of50 07n 7/16 PU.G RCM NJ I CI.EAR POWER STATJON EXERCISE-Noycmber 16, 2016 I Sub-element 1.c -Direction and Control Intent This sub-element is derived.from NUREG-065 4/FEMA-REP-l , which requires thatOifsite Response O r ganizatio n s (ORO) hav e th e capabi lity to control their overall response to an eme r gency. Criterio n 1.c.J: Key personnel with leadership roles for the ORO provide direction and control to t hat part of the overall response effort for which they are responsible. (NUREG-0654/FEMA-REP-1 , A.1.d; A.2.a, b; A.3; C4, 6) Extent of Play Leadership personnel must demonstrate the ability to carry out the essential managementfimctions of the response effort (e.g., keeping staff informed through periodic briefings and/or other means , coordina1ing with other OROs , and ensuring completion of requirements and requests.) Leadership mu st demonstrate the ability to prioritize resource tasking and replace/s uppl e m ent resources (e.g., through MO Us or other agreements) when faced wi th co mp eting demands for finite resources. Any resources identified through LOA/MO Us must be on the ORO 's mobili=ation list so they may be contacted during an incident , if needed. All activities must be pe1formed based o n the ORO 's plans/procedures and co mpl eted as they would be in an actual e m ergency , unless 01herwise noted above or otherwise specified in the extent of play agreement. Massac hu setts Extent of Play If a local EPZ community is directed to evacuate, key EOC personnel will simulate closing and relocation of the EOC through a discussion oflogistics with the FEMA Evaluator. Closing of the local EOC and relocation will be sim ula ted. Level 1 or Level 2 Findings: NIA Pilcrim EOP Rev. 0 Pace 6 of SO 07/27/16 P I T.GBCM NI J C J, t;A B PO W ER S T ATI O N E XEB C I SE-N oy e mh e r 16 2016 I S ub-e l eme n t l.d-Communicatio ns E qu i p me n t I nt ent This sub-element is derived from NUREG-0654/FEMA-REP-l. which requires that Offsite Response Organizations (ORO) establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the emergency planning =one (EPZ): Federal emergency response organizations , the licensee and its facilities , emergency operations centers (EOC), Incident Command Posts and field monitoring teams. Cri t erion 1.d.l: At l east two communicatio n systems are availab l e, at least o n e ope r ates pro p er l y, and co mmun icatio n li nks are esta b lis h ed an d maintainedwith a pp r op r iate l ocatio n s. Co mmu nicatio n s capabilities are managed i n s u ppo r t of eme r ge n cy op erations. (NUREG-0654/FEMA-RE P-l, F.J, 2) Extent of Play OROs must demonstrate that a primary system and at least one backup system are fully fimctional at all times. Communications systems are maintained and tested on a recu rr ing basis throughout the assessment period and system status is available to all operators. Periodic test results and corrective actions are maintained on a real time basis. If a communications system or systems are not functional, but exercise performance is not affected , no exercise issue will be assessed Communications equipment and procedures for facilities and field units are used as needed for transmission and receip t of exercise messages. Al/facilities, FMTs and incident command must h ave the capability to access at least one communication system that is independent of the commercial telephone system. Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. Exercise scenarios may require the failure of a communications system and use of an alternate system , as negotiated in the extent of play agreement. All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless othenvise noted above or othenvise specified in the extent of play agreement. Massac hu se tt s Ex tent o f Pl ay Contact with l ocatio n s not playing will be sim u lated. Level l o r Leve l 2 Fi ndin gs: N/A P l an n i n g Iss u es: Condition: NIAT Field Teams du r ing the April 5 , 2016 Graded Seabrook Exercise did not demonstrate to two different communicatio n s systems. Possib l e Ca u se: NIAT Field Teams used cell phones and laptops with air card that relied on cell service and therefore were not considered two different forms of communications. Effect: Al l communication means are vulnerable to failure or inoperability of a single , local cellu l ar tower network. p;1 g o i m ESP R u. 9 Pa,c 7 of59 97i'i7fl6 PU , GB IMNI J Q , f;AB POW E R S T ATI O N EXE BCJ SE-Nqy e mh e r 16, 2016 Recommendation

NIAT Field Teams will be equipped with portable radios as the alternate means of communications.

FEMA will evaluate this planning issue during the practice exercise. This activity will be eva l uated by FEMA at the EOF prior to the Field Teams leaving for the fie l d. Note: I f , during the exercise , a participant demonstrates this s ub-element unsatisfactorily , the FEMA Evaluator will inform the MEMA Controller. After an " on the s pot" training by the local or State representative , the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day. Pi l crim EOP Rev. 0 Page8 of SO 07n7/16 PU , QBIM Nl l CJ,EAB POWER STATION EXEBCJSE-N9yember 16. 2016 Sub-element

1. e-Equipment and Supplies to Support Operations Intent This su b-element is de rived from NUREG-0654

/FEMA-REP-l , which requires thatO.ffsite Respo n se Organizations (ORO) have emergency equipment and supplies adequate to support 1he e m ergency response. Criterion I.e./: Equipment , maps , displays , monitoring instruments dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654/FEMA-REP -l, H. 7, JO; L 7, 8 , 9; J.10.a, b, e; J.11, 12; K3.a; K5.b) Extent of Play A particular fac ility's equ ipm e nt and supplies mu s t be sufficie nt and cons i s t ent with tha t facility's assigned role in the ORO 's e m e rg ency operations plans. Use of map s and other displays is e nc o ura ged. For non-facility-based ope rati ons , the equipment and supplies must be sufficient and co n siste nt with the a ssigned opera tional r ole. A t lo ca ti o n s where traffic and a ccess co ntr o l personnel are deployed , appropriated eq uipment (e.g., vehicles , barri ers , traffic cones and signs) mu st be available , o r their ava ilabili ty desc r i b ed. Specific equ ipment and supplies that must be demonstrated under this cri t erio n include KI inventories , dosimetry , and monitoring equip m ent , as follows: KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficiemfor use by: (/) emerge n cy workers; (2) institutiona/i=ed individua l s , as indicated in capacity listsforfaci /i ties; and (3) w h ere s tipulat ed by 1he pl an s/procedures , memb ers of the genera l public (including transiems) wi thin 1he plume pathway EPZ. In addi ti o n , OROs must demo n strate p r ov i sions to make KI ava ilabl e to specialized respo n se teams (e.g., civil suppo rt team, Specia l Weapons a nd Tactics Teams , urban search and rescue , bomb squads , HAZMAT, or o th er ancillary groups) as ide ntifi ed in plans/procedures. The plans/p r ocedures mu st include t h e forms to be used for documeming eme r gency worker ingeslion of KI, as well as a mechanism fo r identifaing e m erge n cy workers that have declined KI in advance. Consider carefu ll y the placement of emerge n cy workers 1ha 1 have declined KI in advance. ORO quantilies of dosimet1y and KI avai lable a nd storage localions(s) w ill be c orifirmed by physica l inspeclion al t h e storage lo c ation(s) or through documentalion of curren t inven101y subm ill ed duri n g the exercise , provided in the AL C sub mi ssion , and/or verified during an S A V Available supplies of KI must be w ithin t he expiration date ind i ca 1 ed on KI bott l es or blister packs. As an alternative, the ORO m ay produce a /etterfro m a ce rt ified private o r Slate laboratory indicating that the KI supp l y remains potent, in accordance with US. Pharmacopoeia slanda rds .* , Dosimetry: Sufficient quanlities of appropria t e di r ect-r eading and per man ent record dosi m etry and dosimeter chargers must be avai labl e for issuance 10 a ll emergency worke r s who wi ll be dispatched to pe1form a n ORO mi ssio n. Jn addi t io n, OROs must demonstrate pr!lV i sio n s to make dosimetry ava ilabl e 10 special i=ed response teams (e.g., civil suppo r t team , Special Weapons and Tactics Teams , urban search and rescue , bomb sq uad s , HAZMA T, or other a n cillary groups) as iden t ified in plans/ procedures. Appropriate direct-reading dosimetry must allow an individua/(s) lo read the administrative reporting limits and m aximum exposure limits contained in the ORO 's plans/ pro c edures. Direct-reading dosimeters must be =eroed or operationa ll y checked prior lo issuance. The dosimelers must be inspected for electrical leakage at leas/ annually and replaced when necessmy. Civil Defense Vic t o r een Mo del J 38s (CD V-13 8s) (0-200 mR), due to /heir documented hi story of e l ectric a//eakage problems , mus/ be inspected for electrical leakage at least quarterly and replaced when necessmy. This leakage tes tin g will be verified during the exercise , through documentation submilled in 1he A LC and/or through an SA V Pilgrim EOP Rev. 0 P ag e 9 of SO 07/27/16 Pllt(IBJM NJI Q.EA B POWER STATIO N EXEBCJSE-November 16 2016 Opera 1 iona l c h ecks and 1esting of electronic dosimelers must be in accordance with the mamifacturer 's insn*uctions and be verified during 1he exercise, through documentation s ubmitt ed in the ALC and/or through an SA V Monitoring In st rum e nts: All instruments must be inspected , inventoried, and operationa lly checked before e a ch use. Instruments mu st be calibrated in accordance with the manufac1urer 's recom mendat ions. U nm odified CD V-700 series instruments and o ther instru ments without a manufa c tur er's recommendatio n must be calib rat ed annually. }v/od ified CD V-700 instruments must be ca libr ated in accordance with the recommenda1ion of the m odification manufacturer. A label indicating s u ch ca librat ion mu st be on each i nstrum e nt or cali brat ed.frequency ca n be verified by 0 1h er means. Jn addilion , i n stru m en t s being used 10 m easu re activity m usl have a sticker-affixed to their sides ind icatin g the effec tiv e range of the readings. The range of rea din gs documentation specifies the acceptable range of readings tha t th e meter s h o uld indicate when i t is response-c h ecked using a st andard test source. For F1v1Ts, the instruments must be cap able of measu r ing ga mma exposu r e rate s and detecting beta radiation. These instruments must be capable of measuring a range of activity and exposure , including radi o l ogica l protection / expos ur e co ntr o l of team members and detection of activity on ai r sa mple co lle ct ion media, consistent with t h e intended use of the ins trument and th e ORO 's p la ns/ pro cedures. An appropriate radioactive c h eck so ur c e mu s t be u sed to veri.fY proper operational response for each range radiation m eas ur e m ent instrumen t (less than I Rlh r.) and for high-r ange ins trum e nt s when availab l e. If a so ur ce is not available fo r a high-range instrument , a procedure must exis t 10 ope rationally test the instrument befo r e en t eri n g an area where o nly a hi gh-ran ge instrument ca n make u sefal readings. Jn areas where portal monitors a r e used , the OROs mu st set up and opera ti o nally c h eck the moni 10 r (s). The monitor (s) mu s t conform to th e standards se t forth in 1he Co ntamination Moni t o r ing S t andard for a Portal Monito r Usedfo r Emergency R esponse , FEMA-REP-21 (M ar c h 1 995) or in accordance w ith the manufactur e r 'sreco mmendations. M u t ual Aid Resources: fjthe i nc o ming re so urc es arrive w ith t h ei r ow n eq uipm e nt (i.e., monit o rs and/ or dosimet 1 y), they will b e evalua t ed by REP P ro gram s tand ards. FElvlA wi ll n o t i n ventory eq ui pment tha t is n o t pa r t of the REP Program. fjan ag ency ha s a defined role in the REP P lan , Ihe ya re subject to the planning pr ocess and standards , as well as the guidance of th i s Ma nual. A ll a c1ivi tie s mu s t be based o n the ORO 's plans/pr oced ur es and co mpl e ted as Ihey wo uld be in an actual e mergency , unless noted above or ot h erwise s p ecified in the Ex1ent-oj-Play Agree ment. Massac hu setts Extent of Play Participating facilities will demonstrate that e quipment, maps , display s , monitoring instruments , do s imetry , Kl and o ther s upplie s are adequate and s ufficient to s upport the e mer ge nc y response. FEMA will provide copies of the Annual Lett er of Ce rtification to evaluators as documentation of quarterl y inventory and operational c hecks. Two MA NIAT Field Teams will b e dispatched from the Pilgrim EOF in acco rdance with Section D.4 of the NIA T Handbook. Co ntroller messages w ill provide si mulat ed m o nitorin g data provided from the plant. Eval u atio n ofNIAT Fie ld Te am s were evaluated b y FEMA during Seabrook Graded Exerc i se o n A pril 5 , 2016. NIAT Field Teams will use Pilgrim exercises fo r practice. Pilgrim EO P Rev. 0 Pa ge 10 of 50 07/2 7116 PU ,G BTM NJJ<;J,EAB POWER STATION EXEBQSE-Noycmher 16. 2016 Note: If , during the exercise, a participant demonstrates this sub-element unsatisfactorily , the FEMA Evaluator wil l inform the MEMA Controller. After an " on the spot" training by the local or State representative , the FEMA Evaluator will provide another opportunity to re-d emonstrate the activity that day. Pilirim EOP Rev. 0 Page II of 50 0712 7/16 PU , GBIM NUCJ,EAB POWER STATION EXEBCJSE-Noyember 16. 2016 E VA Ll!A UO N A Rf:A 2

fre c quriqnqrv qn dl qr prqtem w: Actiqn D ed siqn-Mqkjno Sub-element 2.a -Emergency Worker Expo s ure Control Intent This sub-element isderivedjrom NUREG-0654

/FEMA-REP-I , wh i ch requires thatOjfsite Response Organizations (OROs) have the ca pability to assess and control the radiatio n exposure re ceive d by emergency workers and have a dec i sion cha in in place , as specified in the ORO 's plans/procedures, to authorize e mergency worker exposure li m its to be exceeded for specific mi ssions. Radiation exposu r e limits for e m e rg ency workers are the recomm e nd e d accumulated dose limits or exposure rates that emergency wo r kers may b e permilled to incur during an emerge n cy. These limits include any pre-established administrative repo r ting limits (t hat take into co nsideration T o tal Effective Dose Equivalent or organ-s pecific limit s) identified in the ORO 's plans/procedures. Criterion

2. a.1: OR Os use a decision-making process , considering relevant fadors and appropriate coo rdination , to ensure that an exposure co ntrol syste m, induding the us e of Kl , is in plac e for emergency workers, including provisions to authorize radiation expo s ure in excess of administrative limits or protective action guides. (NUREG-0654/FEMA-REP-l, C. 6.f; K.3.a;K.4) Extent of Play OROs authorized to se nd emergency workers into the plume exposure pathway EPZ must d e m onstrate a capability to comply w ith e m ergency wo r ker exposure limits based on their emergency plans/procedure s. Participating OROs must demonstrat e the capa bility to make decisions conce rnin g the authorization of expos ur e levels i n excess of pre-aut h o r ized levels and to t h e number of e mergency wo r kers rec eiv ing radiation dose above pre-authorized levels. This would include p r oviding Kl and do si metry in a timely manner to emergency wo r kers dispat che d o n site to s upp o rt plant incident assess m en t and mitigating actions, in accordance wit h respective plans/procedures. As appropria t e, OROs must demonstrate the capability to make decisions on the distribution and administration of Kl as a protective measure fo r e m erge n cy wo rkers , based o n their's plan/ procedures o r projected thy r oi d dose co mp aredwi th the es tablished Protective Ac tion Guides (PA Gs) for Kl administration.

A ll activities must be based o n t h e ORO 's plans/procedu r es and co mpl e t ed as t h ey would be in an actual e merg e n cy , unless noted above o r ot h e n vise specifie d i n th e exte nt of play agreement. Massachusetts Extent of Play P rotective actio n decisions are demonstrated at th e Massachusetts State EOC based up o n informatio n provided from the EOF. MDPH Radiation Co ntr o l Program EOF staff w ill analyze utili ty, field team and meteorolog i cal date provided at th e EOF to make a recommendation to the State EOC for their cons id e r atio n in making prote ctive action decision s. Level l or Level 2 Findings: NIA Pil g rim E OP R ev. 0 Pace 12 of SO 07/27116 PU , GBCM NJ J Q ,EA B POWER STATION EXEBQSE-Noyemher

16. 2016 Sub-element 2.b. -Radiological Assessment, Protective Action Recommendations and Precautionary and/or Protective Action Decisions (or the Plume Phase ofthe Emergency Intent This sub-element is derived from NUREG-0654

/FEMA-REP-l, which requires that Offsite Response Organizations (ORO) have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PA Gs. OROs must have t h e capability to choose , among a range of pro t ective actions, those most appropriate in a given emergency. OROs base these cho i ces on PA Gs from their plans/procedures or EPA 's Manua l of Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria , such as plant conditions, licensee P ARs , coordination of precautionary and/or protective action decisions with other political jurisdictions (e.g., other affected OROs and incident command), availability of in-place shelter , weather conditions , and situations, to include HAB incidents , the threat posed by the specific hostile action , the affiliated response and the effect of an evacuation on the threat response effort, that create higher than normal risk from general population evacuation. Criterion

2. b.1: Ap propriaJe protective action recommendations (P ARs) are based on available injormaJion on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NU REP-l, J.JOandSupplement

3) Extent of Play During the ini tial stage of the emergency response.following notification of plant conditions that may warrant ojfsite protective actions , the ORO must demonstrate the capability to use appropriate means , described in the plan/procedures to develop protective action recommendations (PAR) for makers based on available information and recommendations provided from the licensee , as well as.field monitoring data if available.

The ORO must also consider any release and meteorological data provided by the licensee. The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs mu st 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 PA G to which they will be compared. PARs must be promptly transmilted to decision-makers in a prearranged format. When the licensee and ORO projected doses differ by more than a factor of I 0 , 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 PAR if timely and appropriate. The ORO must demonstrate the capability to use any additional data to re.fine projected doses and exposure rates and revise the associated PARs. All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency , unless noted above or otherwise specified in the extent of play agreement. Massachusetts Extent of Play Demonstration will be in accordance with the NlA T Handbook. The MDPH Dose Assess m en t Coordinator at the EOF will independently verify dose projections performed by the Utility. Pilgrim EOP Rev. 0 Page 13 of SO 07/27116 PIT , GBIM NUCJ , EAR POWER STATION EXEBCJSE -Nnye mb er I 6. 2016 The State EOC decision-making team will evaluate the protective action recommendations of the NIA T Accident Assessment Team and develop appropriate protective action decisions. Protective action recommendations will be made in accordance with the MARERP and NlAT Handbook. Leve l land Level 2 Findi ng s: NIA Criterion

2. b. 2: A decision-ma king process involving consideration of appropriaJe factors and necessary coordination is used to make precautionary and/or protective action decisions (PA.DJ for the general public (including the recommendation for the use of Kl, if ORO policy). (NU REG-0654/FEMA-REP-l , A-3; C-4, 6; D-4; J.9, 10.e,f, m) Extent of Play Ojfsite Response Organizations (ORO) must have 1he capability to make bolh initial and su b sequent precautionary and/or protective action decisions.

OROs must demonstrate the capability to make initial precautionary and/ or protective action decisions ina timely manner appropriate to the incident , based on informa1ionfrom the licensee , assessment of plant s1a1US and potential or ac/Ual releases, other available iriformation rela1ed10 t h e incident , input fro m appropriate OROau1 hor ities (e.g. JncidentCommand), and P ARsfrom the utility and ORO staff Jn addi1ion, a subsequent or alternate precautionary and/or protective action decision may be appropria1e if various cond iti ons (e.g. an HAB incident , weather , release timing and magnitude) pose undue risk to an evacuation, or if evacuation may disrupt the efforts to respond to a hostile action. OROs must demonstrate the ability to ob tain supplemental resources (e.g. mutual aid) necessary to imp l ement a precauiionary and/or protective action decision if local Jaw enforcement , fire service, HAZMAT, and emergency medical resources are u sed lo augment response 10 1he NP P site o r other key infrastructure. Dose assessment personnel may provide additional PARs ba sed on the s ubsequ ent dose p r ojections , fie Id m onito rin g data , or iriformalion on pl ant cond ilion s. Jn addition , incidenl co mmand must provide input regarding conside ralion sfo r subsequent PARs based on the magnitud e oflhe ongo ing 1hreat , the response, and/or si l e condi 1i ons. The decision-makers must demonstrale lhe capabi lity to change prolective actions based on the co mbinati on of al/ 1hese facto r s. If 1he ORO has determined that KI wi/J be used as a protective measure for the genera l public under ojfsite plans/procedures, then it must demonstrate the capabi lity to make decisions on the distribUlion and administration of KI lo s uppl emen t s heltering and evacuation. This decision must be based on the ORO 's plans/procedures o r projected thyroid dose compared with the established PAGfor KI administration. The KI decision-makingprocess must involv e close coo rdinati on with appropriate assessment and decisionmaking staff If more than one ORO is involved in decision-making, al/ appropriate OROs must communicale and coo rdinat e precautionary and/or protective action decisions with each other. Jn addi1ion , decisions must be coord inat ed! communicated with incident co mmand. OROs mus/ demonstrate the c apability to communicale the resu lt s of decisions to al/ the affected locations. Al/ a ctiv ities must *be based on the ORO 's plans/procedures and co mpleted as they would b e in an actual emergency , unless noted above or otherwise specified in the extent of play agr ee ment. Pilgrim EOP R ev. 0 Page 14 of 50 07n7/16 PD , GBIM NJT CU:A B POWER STATION EXERCISE-Noyemher 16. 2016 Massachusetts Extent of Play Protective action decisions are demonstrated at the Massachusetts State EOC based upon information provided by the EOF. MEMA and MDPH Radiation Contro l Program staff will analyze the Util ity , field monitoring and meteorological data provided at the EOF to make a recommendation to the State EOC for their consideration in making protective action decisions. Level I or Leve l 2 Findings: /A Pilgrim EOP Rev. 0 Page 15 of 50 0712 71 16 PO , GRIM NUQR<\B POWER STATION FXERCJSE-November 16. 2016 Sub-element 2.c-P r ecautionary and/or Protective Action Decision Consideration for the Protection of Persons with Disabilities and Access/Functional Needs Intent This sub-element is derived.from NUREG-0 654/FEMA-REP-1 , which requires that Offs ite Response Organizations (ORO) have the capability to determine precautionary and/or protective action decisions , including evacuatio n, sheltering and use of potassium iodide (Kl), if applicable,for groups of persons with disabilities and acces slfi mctional needs(e.g., hospitals, nursing homes, correctiona l facilities , schools , licensed day care , mobility impair ed individuals , and transportation-dependent individuals). The focus is on those groups of persons with disabilities and acces s/fu n c tional ne e ds that are or potentia//ywi// be affected by a radiological release from a nuclear power plant. Criterion 2.c.l: Precautionary and/or Protective action decisions are made, as appropriate , for groups of persons with disabilities and access/functional needs. (NUREG-0654/FEMA-REP-1, D.4; J.9; J.10.d, e) Extent of Play Us ually it is appropriate to implement evacuation in a r eas where dos es are proj ec ted to exceed the lower end o f the range of P A Gs, e x ce pt for incidents where there is a high-risk e nvironmental co ndition or where high-risk group s (e.g., th e immobile o r infirm) are involved. In th ese cases.f actors must be considered include weather co nditions , shelter availability , availability of transportation assets , risk of evacua tion vs. risk.from the avoided dose , and precautionary school evacuations. Jn addition , decisions must b e coordinated/ communicated with the incident co mmand. In situations where an insritutionalized population c annor be e vacuared , th e ORO mus/ co nsider use of Kl. App li ca bl e OROs mu st d e m o n s trate the ca pability to alert and notify a ll publi c schoo l sys tems/districts of e mergen cy co nditions that ar e ex pe c ted to or may ne cess itate prot ec tive actions for s tud e nts. Demonstration requires that the OROs a c tually co ntact public sc h ool sys tems/districts during The exercise. The O R Os musr demonstrate how the decision-making process takes those with disabilitie s and access/functional needs (e.g., nursing homes , correctional facilities , licensed day c ar e s , mobilityimpa ir e d individuals, and transp o rtarion-dependent individuals) i nto account. In accordance with plans/pr oce dur es , OROs and/or officials of public school systems/districts must demonsn*ate the capability ro make prompt decisions on protective actions for students. The makin gp r ocess , including any preplannedstrategiesjor prot ec riv e actions for that ECL , must co nsid er the locarion of students at the tim e (e.g., whether th e students are still at home , e nr o ute to sc hool , o r at school). S in ce o ther ag encies place r eq uir e m e nts on h osp itals ro pr e pare f or co ntaminat ed patients. th e REP Program has no n ee d to eva luate h os pitals in the EPZ That ne e d to ev a c uat e , or the facilities that are r ece iving These evacuees , n o r does the O RO have The responsibility to provide training or dosimetry 10 these h osp ital s/fac iliti es. A ddirionally , hosp ital e vacuation plans do not n ee d to be r ev i ewed o r tested b y the REP program. A ll activities associated must be based on the ORO 's plans/procedure s and co mpleted as they would be in an actual e m e rg e ncy, unl ess not e d above or o th e rwise s pecified in the extent of play agreement. Pilgrim EOP Rev. 0 Page 16 of 50 07/27/16 PIT.GRIM NI J CJ .EAR POWER STATION EXERCISE -Ngyember 16. 2016 MassachusettsExtentofPlay Protective action decisions , including those for groups of persons with disabilities and access/functional needs , are demonstrated at the Massach u setts State EOC based upon informat i on prov id ed by MEMA and MDPH Radiation Contro l Program staff at the EOF. MEMA and MDPH Radiation Control Program staff will analyze Uti li ty , fie ld team and meteorological data provided at the EOF to make a recommendation to the State EOC fo r their consideratio n in making protection action decisions. Level I or Level 2 Findings: N/A Pi l grim EOP R ev. 0 Page 1 7 of SO 0 7/2 71 16 PU,GBIM NI T CJ,EA B POWER STATION EXEBCJSE -Noyemher 16. 2016 Sub-element 2d -Radiolo 'c a/Assessment and Decision-Makin Intent This sub-element is derived from NUREG-0654/FEMA-REP-J , which requires that Ojfsite Response Organizations (ORO) have the means to assess the radiological consequences for the ingestion exposu re pathway , relate them to the appropriate PA Gs, and make timely , appropriate protective action decisions to mitigate exposure from the pathway. During an accident at a nuclear power plant, a release of radioactive material may contaminate water supplies and agricultural products in the surrounding areas. Any such contamination would likely occur during the plume phase of the accident and, depending on the nature of the release, could impact the ingestion pathway for weeks or years. Criterion 2.dl: R adiological conseq u ences for the ingestion pat h way are assessed and appropriate protective action decisions are made based on the ORO's planning criteria. (NUREG-0654/FEMA-REP-1, A.3; Cl, 4; D.4; J.9, 11) Extent of Play Ojfsite Response Organizations (ORO) are expected to rake precautionary actions to protect food and water supplies, or to minimize exposure to potentially contaminated water and food , in accordance with their respective plans/ procedures. Often OROs initiate such actions based o n c riteria related to the facility's Emergency Classifica tion Levels (ECL). Such actions may include recommendations to place milk animals on stored.feed and to use protected water supplies. The ORO must use its procedures to assess the radiological consequences of a release on the food and water supplies, such as the development of a sampling plan. The ORO 's assessment must include the evaluation of the radiological analyses of representative samples ofwa ter,food , and other ingestible substances of local interestfrom potentially impacted areas; characterization of the releases.from the facility; and th e exte nt of areas potentially impa cte d by the release. During this assessment, OROs must consider the use of agricultural and watershed data within the 50-mile EPZ. The radiological impacts on the food and water must rhen be compared to the appr o priate ingestion PA Gs contained in the ORO's plan/procedur es. The plans/procedures contain PA Gs based on specific dose commitment c riteria or on crite r ia as recommended by curr e nt Food and Drug A dministration guidance. Timely and appropriate recommendations must be provided to the ORO decision-makers group for implementation decisions. OR Os may also include a co mparison of taking or not taking a given action on the resultant ingestion pathway dose co mm i tments. The ORO must demonstrate timely decisions to minimize radiological i mpacts from the ingestion pathway , based on the given assessments and other information. Any such decisions must be communicated and, to the extent practical , coordinatedwith neighboring and local OROs. These decisions include tracking agricultural products entering and leaving the EPZ. Demonstration of plans and procedures which u se traffic access control points to track agricultural products enteringand leaving the EP Z may be conducted through interview. OROs will use Federal resources , as identified in the N uclear/Radiological Incident An nex of the NRF and other resources (e.g., compacts, nuclear insurers), as necessary. Evaluation of this c riterion will take into conside ration the level of Federa/and other resources participating. A ll activities must be based on the ORO 's plans/procedures and completed as they would be in an actual e mer ge ncy , unless noted above or otherwise specified in the extent of play agre e ment. Massachusetts Extent of P l ay This sub-element will not be demonstrated during this exercise. Leve l 1 or Leve l 2 Findings: N/A Pi l gnm EOP Rev. 0 Page 18 ol 50 07727116 fU , QBIM NJJ Q ,EA R POWER STATION EXERCJSE-Noyemher 16 2016 Concernin Post-Plume Phase elocation Re-en Intent This sub-element is derived.from NU REG-0654/FE MA-REP-I, which requir e s thatOffsite Response Organizations (ORO) have th e capability to make decisions on post-plume r e location , re-entry , and return of the general public. These decisions are essential for the protection of the public.from the dire c t long-term exposure to deposited radioactive materials from a severe accident at a nuclear power plant. Criterion

2. e. I: Timely po st-plume phase relocation, re-entry , and return decisions are mJJde and coordinated as appropriate , based on assessments of the radiological conditions and criteria in the OR O's plan and/or procedure s. (NURE G-0654/FEMA-REP-1 , LIO; J.9; K.3.a; M.l) Extent of Play Relocation:

OR Os must demonstrate the capability to es timate integrated dose in c ontaminated areas and compare th e s e estimates with P A Gs; apply de c ision c rit e ria f or r e location of those individuals in the general publi c who have not been evacuated , buiwhere actual o r projected doses are in excess of relocationPAGs

and control access to evacuated and restricted areas. OROs will make decisions for relocating members of the evacuated public who lived in areas that now have residua l radiation levels in excess of the PA Gs. Determination of areas to be restr i cted must be based on factors such as the mix of radionuclides in deposi ted mate rials , calculated exposure rates vs. the P A Gs , and analyses of vegetation and soil.field samples. Re-entry

Decision s must be made on the lo c ation of c ontrol points and policies regarding access and exposu r e control for emergency wo rker s and members of th e general public who need to temporarily enter the evacuated area to perform specific tasks or missions. Examples of control procedures are the assignment of, or checking/or , direct-reading and permanent record dosimetry for emergency workers; questions r e garding an individual 's o bjectives , locations expected to be visited and associated time frames; availability of maps and plots of radiation exposur e rates; and advice on areas to avoid. C ontrol procedures also include monit oring of individuals , vehicles , and equipment; the implementation of deci s ion criteria regarding decontamination; and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records. Responsible OROs must demonstrate the capability to develop a strategy fo r authorized re-entry of individuals into the restricted zone(s), based on established decision criteria. OROs must demonstrate the c apability to modify those poli c ie s for security purposes (e.g., police patrols), maintenance of essential services (e.g., fire protection and utilities), and o t her critical.functions. They must demonstrate the capability to use decision-ma king c riteria in allowing access to the restricted zone by the public for various reas o ns , such as to maintain property (e.g., to care for farm animals or secur e machinery for storage), or retrieve important possessions. Coordinated policies for access and exposure control must be developed among all agencies with roles to perform in the restricted zone (s). OROs must demonstrate the c apability to establish policies for provision of dosimetry to all individuals allowed to re-enter the restricted zone(s). The extent that OROs need to develop policies on re-ent1y will be determined by scenario events. Pilgrim E:OP Rev. 0 Page 19 of 50 07/27/16 PU , GRIM NJ J Q,EAB fOWEB SIAJION EXERCISE-N9yemher 16 2016 Return: OROs must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis). OROs must base their decisions on environmental data and political boundaries or physical/geological features , which allow identification of the boundaries of areas to which members of the general public may return. Return is permiued to the boundary of the restricted area(s) that is based on the relocation PAG. Other factors that the ORO must consider in decision-making include conditions that permit the cancellation of the Emergency Classification Level and the relaxation of associated restrictive measures. OROs must base return recommendations on measurements of radiation.from ground deposition. OROs must have the capabil ity to identify services and facilities that require restoration within a few days and to identify the procedures and resources/or their restoration. Examples of these services and facilities are medical and social services, utilities, roads, schools , and intermediate-term hou s in g/or relocated persons. All activities must be based on the ORO 's plans/procedures and completed as r h ey would be in an actual emergency , unless noted above or otherwise specified in the extent of play agreement. Massachusetts Extent of Play Th i s sub-element will not be demonstrated during this exercise. Level 1 or Level 2 Findings: /A Pllgtlm t!6P ltev. 6 Page %6 of36 PU , GBIM NI T CJ,EAB POWER STATION EXEBCJSE-Noyember 16. 2016 EVA/ I TA TTO N A REA 1* P,qtgctive A ctiqn Tmplemenmtiqn Sub-element 3.a-Jmplementation of Emergency Worker Exposure Control Intent This sub-element is derived from NUREG-0654 /FElvfA-REP-I, which requires thatOROs have the capability to provide for the following: distribution, use, collection, and processing of direct-read in g dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies

maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides , and t h e capability to provide Kl/or emergency workers , always applying the A LARA (As Low As is Reasonably Achievable) principle as appropriate.

Criterion 3.a.J: The OR Os issue appropriate dosimetry , Kl, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart OR Os maintain appropriate recordkeeping of the administration of Kl to emergency work ers. (NUREG-0654/FEMA-REP-1, K.3.a, b; K. 4) Extent of Play OROs must demonstrate t h e capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry , dosimeter chargers, Kl, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosi m etry that allows individu al (s) to read the administrative reporting limits that are established at a level low enough to consider subsequent calculation of Tota l Effective Dose Equivalent and maximum exposure limits,for those e m erge n cy workers involved in life saving activities contained in the ORO 's plans/procedures. Each emergency worker must have the basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures. If supplementa l resources are used , they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. During a plume phase exercise , emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker must report accumulated exposures during the exercise as indicated in the plans/procedures. OROs must demonstrate the actions described in the plans/procedures by determiningwhether to replace the worker , authorize the worker to incur additional exposures, or to take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure , evaluato r s must interview at least two emergency workers to determine their knowledge of whom to contact in case authorization is needed, and at wha t exposure levels. Workers may use any available resources (e.g., written procedures and/or co-workers) in providing responses. A lthough it is desirable for all emergency workers to each have a direct-reading dosimeter , there may be situations where team members will be in close proximity to each other during the entire mission. In such cases , adequate control of exposure can be affected achieved for all team members using one dosimeter worn by the team leader. Emergency workers who are assigned to low exposure rate fixed facilities , (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) Pilgrim EOP Rev. 0 Page 21of50 07127116 PU , GRIM NUCJ,EA B POWER STATTON f.XEBCJSE-Noyemher 16. 2016 may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry. Individuals authorized by the ORO to r e enter an evacuated area during the plume (emergency) phase , must be limited to the lowest radiological exposure commensurate with completing their missions. OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency wo rkers performing various services (e.g., lifesaving, p r otection of valuable property , all activities). ORO must ensure that the process used to seek autho r izations for exceed in g dose limits does nor negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable p r operty may require an urgent response. OROs must demonstrate the capability to accompl i sh distribution of Kl to e mer gency wo rkers consis tent with decisions made. OROs must have the capability to develop and maintain lists of emergency wo r kers w h o have ingested Kl , incl udin g documentation of the date(s) and time(s) they did so. Ingestion of Kl recommended by the designated ORO health official is vo lunta ry. For eval uati on purposes, the actual inges ti on of Kl shall not be performed. OROs must demonstrate t h e capability to fo rmula te and disseminate instructions o n using Kl fo r those advised to take it. Eme r gency wo r ke r s must demonstrate basic knowledge of procedures for using Kl whether or not 1he scenario drives the implementation of Kl use. Th i s can be accomplished by an interview wi1 h an evaluator. All activities must be based o n the ORO 's plans/p r ocedu r es and completed as they wo uld be in an actual emergency , unl ess noted above or otherwise specified in t h e extent of play agreement. Massachusetts Extent of Play EPZ EOCs: Dosimetry packets will be issued to two emergency workers in each EPZ EOC. Actual distribution and ingestion of Kl will not occur. Empty Kl tablet containers (s mall zip-lock bags) will be included in the dosimetry packets for emergency workers. Knowledge of the u se of dosimetry and Kl will be demonstrated throusJI an interview of these two individuals by the FEMA Ev aluator. Region II EOC: Extra Dosunetry packets and Kl are stored at this facility. No staff from this facility responds to the E PZ. Massachusetts State Police are u sed for co mpen sa tory response not R eg ion II personnel. T here will not be a d osi metry briefing at this location. Level l or Level 2 Findings: NIA Note: If, during the exercise , a participant demonstrates this su b-elem ent unsatisfactorily , the FEMA Eval uator will inform the MEMA Co ntroller. Afte r an " o n the s p ot" training by th e local or State representative , the FEMA Evaluator will provide anotheropportunity to re-demonstrate the activity that da y. Pilgrim EOP Rev. 0 Page 22 of 50 07/27116 PU , GR IM Nl!CJiE A B PO WE R STA TIO N EXERCISE-N oyember 16. 20 1 6 S ub-e l eme n t 3. b-lmel eme nt aJio n o(KI D ecisio n (or In stitutio n alized Ind ivi dua ls a nd t h e G e n e r al Pub lic Intent This sub-element isderivedfrom NU REG-0654/FEMA-REP-l , which r eq uires rhat Ojfs it e R es pons e O rganizations (ORO) have the c apability to provide Kl institutionaliz e d individuals , and , if in the plans/procedures , to the ge n e ral public for whom immediate evacua ti o n may nor be feasible , ve1y difficult, or significantly delayed. While ii is neces s ary for OROs 10 have rhe capability to pr ov ide Kl to institutionalized individuals , providing Kl to the general public is an ORO opt i on and mu s t be reflected in ORO 's plan s/procedures. Provisions should include the availability of adequate quantities , storag e , and means of the distributi o n of Kl. C r ite r io n 3. b. l: KI a nd a ppr o p riate i n str u ctio ns a r e av ail a bl e if a decisio n to reco mmen d u se o f KI i s mad e. A ppr o pr i aJ e r eco rd kee ping o f t he a dmin is tr atio n o f KI f o r i n stitutio n alized indi v idual s is maintain e d (NU REG-065 4/FEMA-REP-1 , J. 1 0.e , j) Exten t of Pl ay Ojfs ite R espo nse Organizations (O R O) must dem o nstrate the c apability to make Kl available to institutionalized individuals , and , where provided for in the ORO plans/procedures , t o members of th e genera/public. OROs must demonstrate the capability to accomplish distribution of Kl consistentwith decisions made. OROs must have the capability t o develop and mai nt ain lists of institutionalized individuals who have ingest e d Kl , including documentation of the date (s) and t i m e(s) they were instructed to ingest Kl. Ingestion of Kl recommended by the designated ORO health official is voluntary. F o r evaluation purposes , the actual ingestion of Kl shall not be performed. OROs must demonstrate the c apability to formulate and disseminate instructions o n using Kl for thos e advised 10 take it. If a rec o mmendation i s made for the general public to take Kl, app r opriate iefo r mation must be provided 10 the public by the means ofnotificarion s pe c ified in the ORO 's plan s/procedu r es. A ll activities must be ba se d on the O RO 's pla ns/proc e dur es and co mpl e ted as they would be in an actual e m e r ge n cy , unl ess noted ab ove or otherwise specified in the extent of play agreement. Massac hu settsExte n tof Pl ay Schoo l s , day cares , an d special fac i lity staff who administer Kl will be interviewed o u t-of-seq u ence by the FEMA Eval u ator (see page 2 ofEOP). The FEMA Eval u ator will check the availability of a d eq u ate quantities , s torage , and means ofKJ distribution. R eg i o n II E O C: Extra Dosimetry packets and Kl are stored at this facility. No staff from this facility responds to the EPZ. Massachusetts State Police are used fo r co m pensatory response not Region II personnel. There will not be a Kl briefmg at this location. Leve l l o r Leve l 2 F indin gs: N/A Note: If, during the exercise , a parti c ipant demonstrate s this sub-element unsatisfactoril y , the FEMA Eval u ator will inform the MEMA Controller. After an " on the spot" training by the local or State representative , the FEMAEval u atorwill provide another opportunity to re-demo n strate the activity that day. Pilg ri m EOP Rev. 0 Page 23 of SO 07/27/16 PU,GRIM NJJQ,EAB POWER SJ , UJON EXERCJSE-Noyember 16. 2016 Sub-element 3.c--lmplementation of Precautionary and/or Protective Actions for Persons with Disabilities andAccess/Functional Needs Intent This s ub-el e ment is derived.from NUREG-0654 /FEMA-REP-1, which req uir es that Ojfsite Response Org an iza tions (ORO) hav e the ca pability to implement precautionary and/or p rote ctive acti o n decisions , incl uding evacuation and/or shelte rin g,fo r all persons w ith disabilities and a ccess/func ti onal needs. The focus is o n those persons wi th disabilities and access/functional needs that are (or potentially will be) aff ec ted by a radiological release from a nuclear power plant. Criterion

3. c.1: Precautionary and/or protective action decisions are implemented for persons with disabilities and access/functional needs other than sc hools within areas subject to protective actions. (NVREG-0654/FEMA-REP-l, J.10. c, d, e, g) Extent of Play A pplicable OROs mu s t de mon stra t e the capab ili ty to alert and notify (i.e., provide protective action recommendations and e mer ge n cy iriformarion and inst ructi o ns to) persons with disabilities and access/functional needs , including h osp ital s/m e di ca l facilities, li cense d day ca res , nur s ing home s, co rr ectio nal facilitie s, m o bility impaired a nd transportation dep e nd e nt i ndividuals. OROs mu s t demonstrate the capab ility to provide for p e rsons wit h disabilities and access/functional n eeds in a cco rdanc e with plan s/procedures. Co ntact wi th persons with disabilities and access/functional needs and reception faci liti es may be actual or s imulat ed , as agreed t o in the Ex tent of Play. Some co ntact s with transportation providers must be actually co nta cted. as n ego tiated in the exte nt of play. A ll actual and s imulat e d co ntact s s hould be logged Si nce o ther agencie s place r eq uir e ments on h os pitals to prepare for co ntaminated patients , t h e REP Program has no n eed t o ev aluat e ho sp itals in the EPZ t hat n eed to evacua te , o r the facilities that are r ece iving thes e evacuees, nor do es th e ORO have the responsibility to pr o vide trainin g or dosim etry to th ese hospitals/f a c ilities. A dditi o nally, ho sp ital evac uation plans do not need to be r ev ie we d o r te ste d by th e REP prog r am. A ll a c tivities must be based o n th e ORO 's plans/pro ced ur es and co mplet e d as they would be in an actual emerg e n cy , unl ess no t ed above o r o th erwise specified in th e exte nt of play agreement. Massachusetts Extent of Play SEOC: The U.S. Coast Guard representative will e s tabl i sh co ntact with the District Command Center and communicate with them throughout the exercise. No Broadcasting over the U rgent Marine Information Broadcast will occur onl y simu l ation. Only initial c ommunication with the Captain of the Port will be established thereafter contact w i ll be s imulat e d. Region II: Initial calls to all Transportation Providers will be made to ve rify telephone number and co ntact per so n. A Co ntroller me ssage will refer to matrix to provide the number of vehicles and driver s available for exercise play. No vehicles or personnel will be mobilized. A list of the Transportation Providers will be provided to the FEMA Evaluator.

R egio n II Special Nee d s Coordinator and s taff (CME D) will demon s trate all a ppropriate communications with E PZ co mmunity EOC staff and s imulate coo rdination of bed s pace ass i g nment for evacuating PIJ , GBIM NJTCLEAR POWER STATION EXEBCJSE-N oyember 16 2016 nursing home patients and hospital patie n ts , although actual evacuation of special facilities will not occur. A Controller me ssage will provide the default number of estimated bed s paces in host hospital s. All contact with hospitals will be s imulated. EPZ EOCs: All special facilities will receive initial contact. Follow-up calls will be s imulated and logged. Participating special facilities will be interviewed out of se quence by a FEMA Evalua t or (see page 2 of the EOP). EPZ EOCs: The l ist of persons with disabilities and access/functional needs will be shown to the FEMA evaluato r; however , the info rmat ion is confidential and copies will not be provided to the eval u ator. Staff wi ll s imulate and l og cal l s to the individuals on the li s t that have identified themse l ves as needing assistance dur i n g an eme r ge n cy. Level l or Level 2 Findings: /A Criterio n 3.c.2: OR O s/Sc hool officials implement precautionary/protective actions for schools. (NU REG-0654/F E MA-REP-1 , J.10.c, d, e, g) Extent of Pla y School systems/districts (these include public and private schools , kindergartens , and preschools) must demonstrate the ability to implement precau t ionary and/o r p r otective action decisions for students. The demonstration mu s t be made as follows: Each school sys te m/d i s trict within the 10 mil e EPZ mu s t demonstrate implementation of protective actions. A I least one school per affected sys t em/d i s tr ict mu st par1icipa1e in the demonstration. C anc el ing the schoo l day , dis mi ssing ea r ly , or she lt e ring in place must be simulated by describi n g to eva l ua1ors the procedures /hat would be fo llowed If ev acuati o n is t h e i m plemen1edp r otective act i on. all activities to coo r dinate and co mplete /he evac uation of students to reception ce nter s , co n grega t e care cente rs , or h os t sc h ools may actually be demonstrated o r accomplished through an interview pr ocess. If accomplished through an interview , appropriate school pe r sonnel including decision-making officials (e.g., sc ho o ls' s up eri nt endenJ/pri ncipals and transpor1ation 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 evacu ation of school c hildr en. C om muni cations capabilities between school officials and lhe buses , if required by 1h e plans/procedures , must b e verified Offic ials of the schoo l system(s) must demonstrate the capab ili ty to develop and provide timely information to OROsfo r use in m essages 10 pa r ents , Jhe general public , and the media on the s tatu s of pro1ec1ive aclionsfor schools. If a sc h oo l faci lity has e m e rgen cy plans as a condition of licensing, those plans m ay be submitted to FEMA r eview in place of demonstration or inlerview p ursuanl to the ORO 's p l ans/procedures as negotiated in the Exten t of Play Agreement. All activities must be based on the ORO 's plans/pro c edures and comp l eted , as they wo uld be i n an actual e m ergency , unless noted above or otherwise specified in the extent of play agreement. Massac hu setts Exte nt of Play Pilgrim EOP Rev. 0 Page 25 o f 50 07/2 7/16 PU,GBTMNI I Q.EAB POWER STATION f:XEBCISE-Noyemher

16. 2016 Region 0 EOC: The MEMA Region II Special Needs Coordinator , in an interview with the FEMA Evaluator , will provide a list of schools located outside the EPZ with students who reside within the EPZ. Calls to schools outside the EPZ will be simulated and logged. EPZ EOCs: Initial notification will be made to all schools and day care centers. EPZ Schools: Participating facilities were visited out of sequence by a FEMA Evaluator in 2016 , who interviewed key players (and if the site's plan calls for KI , responsible staff). See page 2 of Extent of Play for list Day Care Centers: Participating facilities were visited out of sequence by a FEMA Evaluator , who interviewed key players (and if the site's plan calls for KI , responsible staff). See page 2 of Extent of Play for list. Level 1 or Level 2 Findings:

/A Pil&rim EOP Rev. 0 Page 26 of SO 07/27/16 PU , GRJM NJJCJ.EAB POWER STATION EXERCJSE-Noyemher 16. 2016 Sub-element 3.d -Im lementation o Tra 1c and Access Control Intent This sub-element isderivedfromNUREG*0654 /FEJvfA-REP-l , which requires thatOffsite Response Organizations (ORO) have the capability to implement protective action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This sub-element focuses on selecting , establishing, and staffing of traffic and access co ntr o l points and removal of impediments to the flow of evacua tion traffic. Criterion 3.dl: Appropriate traffic and access control is established Accurate instructions are provided to traffic and access control personnel (NUREG-0654/FEMA-REP-l, A.3; C.J , 4; J.10.g,j) Extent of Play OROs mu st demonstrate the capability to selec t , establis h , and staff appropriate traffic and access control points consistent with current conditions and protective action decisions (e.g., evacuating, sheltering , and relocation), in a timely manner. OROs must demonstrate the capability 10 provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled. Traffic and access con trol staff must demonstrate accurate knowledge of their roles and responsibilities , including verifying e m ergency worker identification and access authorization to the affected areas , as per the exte nt of play agreement. These capa bilities may be demonstrated by actual deployment or by interview, in accordance wi th the extent of play agreement. In instances where OROs lack authority necessary 10 control access by certain types of traffic (e.g., rail , water , and air traffic), they must de m onstrate the capability to contact the S tat e or Federal agencies that have the needed authority , as agreed upon by the extent of play agreement. All activities must be based on the ORO 's plans/procedures and c omp l eted as they would be in an actual emergency , unless noted above or otherwise specified in the extent of play agreement. Massachusetts Extent of Play State EOCs: Contact with water , rail and air authorities are demonstrated at the State EOC. EPZ EOCs: EOCs will demon s trate the ability to direct and monitor traffic control operations within their jurisdictions through discu ssions with the evaluator. The local EOC highway and/or Law Enforce ment representative will participate in a discussion of procedures and resour ces available for traffic control. No personnel or equipment will be deployed to field locations. Level I or Level 2 Findings: NIA Note: If , during the exercise , a participant demonstrates this sub-element unsatisfactorily , the FEMA Evalua t or will inform the MEMA Controller. After an " on the spot" training by the local or State representative , the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day. Pil&rim EOP Rev. 0 Page 27 of 50 07/27/16 PU , QBJM NI!CJ ,EA B POWER STATION EXERCISE-Noyemher 16 2016 Criterion 3.d2: Impediments to evac uation are identified and resolved (NUREG-0654/FEMA-REP-1, J.10.k) Extent of Play 0 ROs must demonstrate the capability to identify and take appropriate actions co nc ern ing impediments t o evacuations. In demonstrating this c apability , th e impediment must r e main in place during the e vacuation long enough that re-r o uting of traffic is requi r ed and must al so r es ult in demonstration of de c isi o n-making and coo rdination wi th the JIC t o co mmunicate the alterna t e route to ev acue es. When, due to specifics of th e scenario or jurisdict i o n , the impediment c annot be located on an evacua ti on route , it must be located so as to impact th e evacuation. Whe n not po ssi ble , actual di s pat c h of resource s n ee d not be physically demonstrat e d; how eve r , all contacts , actual or simu lat ed , s hould be lo gge d. A ll a c tivities must be based o n th e ORO 's plans/procedures and co mpl e t ed as they would be in an actual e merg e ncy , unless noted ab ove or othenvise s pe c ifi ed in the extent of play agreemenL Massachusetts Extent of Play Eac h E PZ Local EOC will demonstrate rerouting of traffic following a traffic impediment through an interview with the FEMA Eval uator. No per so nn e l o r equipment will be dispatched to the sim ulated acc id e nt sce ne. One EPZ co mmuni ty will be have an impediment that is likely to cause length y rerouting of traffic along the evacuation route , this Local EOC will communicate this information to MEMA Region II in order for this information to be passed to the State EOC and the JlC. MA will demonstrate only one Local EOC will dem onstrate the coo rdination with the JIC to comm unicate the alternate route to evac uee s. Note: If , during the exe rcis e , a participant demonstrate s this sub-element un s atisfactorily , the FEMA Evaluator will inform the MEMA Co ntroller. After an " o n the spot" training b y the local or State representative , the FEMA Eval u ator will provide another o pportunity to re-demon s trate the activity that day. Pilgrim EO P R ev. 0 28 o f 50 07/2 71 1 6 Pil , GRIM NT T CJ,f;AR POWER STATION EXERCJSE-Noyember 16 2016 Sub-element3.e-l lementation o Jnnestion Decisions Intent This sub-element isderivedfrom N U REG-0654/FEMA-REP-l , which require s thatOROs have the capability to implement protective actions , based on criteria recommended by current Food and Drug Admi n istration guidance.for the ingestion exposure pathway EPZ (i.e., the area wit hin an approximate 50-mile radius of the nuclear power plant). This sub-elementfocuses on those actions required for impl ementation of protective actions. Criterion 3.e.1: The ORO demonstraJes the availability and appropriaJe use of adequaJe information regarding waJer, food supplies, milk, and agricultural production within the ingestion exposure paJ/1way emergency planning zone for implementaJion of protective actions. (NUREG-0654/FEMA-REP-1,A.3; Cl, 4; J.11) Extent of Play Applicable OROs must demonstra t e the capability to secure and use current information on the locations of dairy farms, meat and poultry producers.fisheries.fruit growers, vegetable growers , grain producers.food processing plants , andwater supply intake points to implement protective actions wi thin the EPZ OROs use Federal resources as identified i n the NRF Nuclear/Rad iologi cal Incident Annex , and o th er resources (e.g., co mpa cts , nuclear insurers) if available. Eva luation of t hi s criterion will take into conside rat ion the level of Federal and other resources participating in the exe r cise. A ll a ctivities mu st be based o n the ORO 's plans/procedures and co mpl eted as they wo uld be in an actual emergency, unless noted above or o then vise specified in the ex t ent of play agreement Massachusetts Extent of Play This criterion will not be demonstrated during this exercise. Level I or Level 2 Findings: N/A Criterion

3. e.2: AppropriaJe measures , straJegies, and pre-printed instructional material are developed for implementing protective action decisiotlS for contaminaJedwaJer,foodproducts, milk, and agricultural productiotL (NUREG-0654/FEMA-REP-1, G.1; J.9 , 11) Extent of Play OROs must demonstrate the dev elop m ent of mea s ur es and strateg ie s fo r implementation of i nge s tion exposure pathway EPZ protective actions by for mulating protective action information for the general publi c and food producers and processors.

Demonstration of this criterion includes either distributed public information material in the ingestion exposure pathway EPZ o r the c apab i lity for the rap id reproduction and distribution of appropriate reproduction-ready infor mati on and instructions to pre-determined individuals and businesses. OROs must also demonstrate the c apability to control , restrict or prevent distribution of contaminated food by co mm ercial sectors. Exercise play must include demonstration ef communications and coordi nati on among o r ganizations to implement protective actions. Fie ld play of implementation activities may be si mul ated. For e xample , c ommunications and coord inati on with agencies responsible fo r enforci n gfood controls within the ingestion exposure pathway EPZ must be demonstrated, but actual co mmuni catio n s with food producers and processors may b e simulated. Pilgoim E9P lk<. 9 Psgd9 oFS9 9?127116 PO , GBIM NJ J CJ ,E AB POWER STATION f:XEBCJSE-Ngyemher

16. 2016 All activities must be based on the ORO 's plans/procedur es and comp l e ted as they would be in an actual e m ergency, unless noted above or otherwise specified in the extent of play agreement. Massac hu setts Extent of Play This c rit erion will n ot be demonstrated during this exerc i se. Level I or Level 2 Findings:

N/A Pilgrim EOP R ev. 0 07/271 16 PU,GBIM NJTCJ,EAB POWER STATION EXEBQSE Noyemher 16. 2016 Sub-element

3. -l lementation o Post-Plume Phase Relocatiot Re-ent and Return Decision s Intent This sub-element isderivedfromNUREG-0654

/FEMA-REP-l , which requires thatOffsite Response Organizations (ORO) have the capability to implement plans , procedures , and decisions for post-plume phase relocation, re-entry, and return. implementation of these decisions is essential/or protecting the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a commercial nuclear power plant. Crite r ion 3.f.l: Decisions regarding controlled re-entry, r elocation, and return of individuals during the post-plume phase are coo rdinat ed with appropriate organizations and implemented (NUREG-0654/FEMA-REP-1, E. 7; J.10.j; J.12; K.5.b; M.1, 3) Exte11t of Play Relocatio11: OR Os must demonstrate the capabil i ty to coordinate and implement decisions concerning relocation of individuals located in radiologically contaminated areas who were not previously evacuated Such individuals must be relocated to an area(s) where radiological contamination will not expose the general public to doses that exceed the relocationPAGs. OROs must also demonstrate the capability to provide for short-or long-term relocation of evacuees who lived in area(s) that have residual radiation levels above the (first-, second-, and 50-year) PA Gs. Areas of consideration must include the capability ofOROs to com municat e with o ther OROs regard ing timing of actions, notification of the population of procedures/or relocation , and the notification of, and advice for , evacuated individuals who will be converted to relocation status in situations where they will not be able to return to their homes due to high levels of contaminatio

n. OROs must also demonstrate the capabi lity to co mmunicat e instructions to the public regarding relocation decisions and intermediate-t erm housing/or relocated persons. Re-entry:

OR Os must demonstrate the capability to control re-entry and exit of individuals who are authorized by the ORO to temporarily re-enter the restricted area during the post-plume (i.e., intermediate or late) phase to protect them from unnecessary radiation exposure. OROs must also demonstrate the capability to con tr ol exit of vehicles and equipment to control the spread of contamination outside the restrictedarea(s). individuals without specific radiological response mi ss i ons, such a s farmers for animal care , essential utility service personnel, or o ther members of the public who must reenter an evacuated area during the post-emergency phase must be limited to the lowest radiological exposure commensurate with completi n g their missions. Mo nit o rin g and de contamination faci liti es will be established as appropriate. Examples of control procedure subjects are: (1) the assignment of, or checking/or , direct-reading and permanent record dosimetry for emergency workers: (2) questions regarding the individuals' objective(s), location(s) expected to be visited. and associated timeframes

(3) maps and plots of radiation exposure rates; (4) advice on areas to avoid; (5) procedures for exit , including monitoring of individuals , vehicles , and equipment; (6) decision criteria regarding contamination; (7) proper disposition of emergency worker dosimetry; and (8)maintenance of emergencyworker radiation exposure records. Return: OR Os must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. OROs must demonstrate the capability to identify and prioritize services and facilities that require restorption w ithin a few days, and to identify the procedures and reso ur ces for their restoration.

Examples of these services and facilities are medical and social services , utilities , roads , and schools. Pilgrim EO P Re v. 0 Page 3 1 of SO 07/27/16 Pil , GRIM Nl!CJ,f;AR POWER STATION EXERCJSE-Noyember 16. 2016 Co mmunications among OROsjo r r e lo c ation , re-entry , and return may be simulated. A ll s imulat e d o r actual co ntact s must be documented. These discussions may be a cco mpli s h e d ina group setting. O R Os s h o uld use Federal resou r ces a s identified i n 1he NRF Nucle a r/Radi o l ogi cal Incidenl An n ex, and o ther re so ur ces (e.g., co mpa c t s, nu clea r insurers), as n ecessary , if available. Evalualion oj1h is c riter io n wil/ 1ake into co n s ideration the l eve l of Federal and o th er r eso ur ces participating i n the exercise. A ll activities must be based on 1he ORO 's plans/p r ocedures and co mpleted as the y would be in an actual emergency , unless not e d ab o ve o r o therwi s e specified in th e extenl of play agr ee ment. Massachusetts Extent of Pla y This s ub-element wi ll not be demonstrated durin g this exercise. Level l or Level 2 Findings: N/A Piigrim £Of RC\1. 0 Patt 32 Ui 30 0 7J 2 7Jld PU , GBW NJJ CJ,E A R POW E R ST A TIO N E X E BCJ SE-N oyember 16 2016 EVA T CTA UO NA R£A 4* Fie ld Me qwcgment A nd A nq ly 5j5 S u b-eleme nt 4.a-P l u me Ph ase Fiel d M eas uc ements a nd A n alvses latent This sub-element is derived.from NUREG-0654 /FEMA-REP-l , which requi r es rhatOjfsite Response Organizations (ORO) have the capabiliry to deploy fie l d teams with rhe equipment , methods , and experrise necessary to determine the location of airborne radiation and particu l are deposition on the ground from an airborne pl u me. In addirion , NUREG-0654 /FEMA-REP-l indica t es t hatOROs must have the capabiliry to use.field monitoring teams within the p l ume exposure pathway EPZ to detect airborne radioiodine i n the presence of noble gases and radioactive particulate material in the airborne pl u me. In an i n cident at a nuclear power p l ant , the possible release of radioactive material may pose a risk to the nearby population and environment. Although incident assessment methods are available to project the extent and magnitude of a release , these methods are subject to large uncertainties. During an incident , ii is important to collect.field radiological data to help characterize any radiological release. Adequate equipment and procedures are essential to such.field measurement efforts. C ri te r io n 4.a.1: R eserved C r ite ri o n 4.a.2: Fie ld t e ams (2 or m o r e) ac e mana ged to o btain s uffi cie nt i nf o r mation t o h e lp c h a ra cte ri ze th e r e l ease an d t o co ntr o l radiati o n ex p os ur e. (NU RE G-0654/F E MA-REP-1, C 1; H.12; 1. 7, 8, 11; J.10.a) E xte nt o f Pla y Responsible Ojfsite Response Organiza t ions (ORO) must demo n strate rhe capabiliry to brief.field monitoring teams on predicted plume location and direction , plume travel speed , and exposure control procedures before deployment. During an HAE incident, the.field team management must keep t h e incident command informed of.field monitoring teams' activities and location. Coordination with.field monitoring teams and.field monitoring may be demonstrated as out-of-sequence demonstrations , as negotiated in the extent of play agreement. Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions , or to be a factor in modifying protective actions. Teams must be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize t h e pl um e and its impacts. If the responsibi l ity for obtaining peak measurements in the plume has been accepted by licensee Judd monito r ing teams , with concurrence from OROs , there is no requirement/or these measurements to be repeated by OROs monitoring teams. If the licensee field monitoring teams do not obtain peak measurements in the plume , it is the ORO 's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coo r dination of plume measurement information among all.field monitoring teams (licensee , Federal , and ORO) is essential. OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee) as necessmy. Evaluation of this criterion will take into considerarion the level of Federal and other resources participating in the exercise. All activities must be based on the ORO 's plans/procedu r es and comp l eted as they would be in an actual eme r gency , unless noted above or otherwise specified in the extent of play agreement. Pi l g ri m EOP R ev. 0 Page 33 of SO 07/27/1 6 *' PU , GRIM NJJCIJ:AR POWER STATION EXERCISE-Noyemher 16. 2016 Massachusetts Extent of Play NIA T Field Teams aie man aged by the Field Team Coordinator who a re located at the utility EOF. He/she will brief and in conjunction with the utility and other state agencie s, dispatch two. team s to s ampling locations in accordance with the NIAT Handbook, Section D.4 , as dictated by scenario play. The NIAT Field Teams have been e valua ted by FEMA during the Seabrook Exercise April 5 , 2016. Both NIAT Field Teams will practice preparing one sample media and the report survey results on the appropriate survey forms to the Field Team Coordinator. Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG.:()654/FEMA-REP-1, Cl; H.12; L 8 , 9; J.10.a) ' Extent of Play Two or more field monitoring te a ms mu st demonstrate the capability to m ake and report measurements ambient radiati o n to t he field team coo rdinat or, dose assessment team , o r o th e r appropriate authority. Field monitoring teams mu st also demonstrate the capability to o btain an air sa mpl e for measurement of airborne radioiodine and particulat es, and to provide the appropriate authority with.field data perta ining to m eas ur e m en t. If sa mpl es hav e radi oac tivity s ignificantly above background, the auth o rity must co n sider the need for exped ited laboratory analyses of these samples. Coo rdination concerning transfer of samples, including a c hain-of-custody form(s), to a radiological laboratory{ies) must b e dem o nstrated. OROs mu s t s har e data in a timel y mann er with all other appropriate OROs. A ll m e thodolo gy, including contamination co ntrol , instrumentation , preparation of sa mples, and a c hain-of-custody form(s)for transfer to a /ab o ratory(i es), will be in ac co rdance with th e ORO 's plan s/p roc ed ure s. OR Os will use F edera/ re so ur ces as identified in the NRF N uclear/Radiological Incident A nnex and other resources (e.g., co mpa c ts o r the licensee), as needed. Evaluation of this cri teri o n will take into co nsideration the level of Federal and o ther resource s parti c ipating in th e exercise. A ll activities must be must be based on the ORO 's plans/p rocedures and completed as they would be in an actual e mergency , unless noted above or otherwise specified in the e xtent of play agreement. Massachusetts Extent of Play Two MA NIAT Field Teams will be dispatched from the EOF in accordance with theNIAT Handbook. The NIAT Field Teams have been evaluated by FEMA during the Seabrook Exercise April 5, 2016. The NIAT Field Teams will be practicing during the Pilgrim Exercise. Once , dispatched , only disposable gloves will be used for actual exercise play. Charcoal cartridges will be used instead of silver zeolite. Both NIAT F ield Teams will practice collecting one complete sample (monitoring and air sample) as s pecified b y the in Section D. 4 of the NIA T Handbook. Note: If , during the exe rcise , a participant demon s trates this s ub-element unsatisfactoril y , the FEMA Evaluator will inf o rm the MEMA Controller. After an " on the s pot" training by the local or State representative , the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that da y. Pilgrim EOP Rev. 0 Paee 34 of SO 07n7/16 PU , GBIM NITCJ,f:AB fOWEB STATTON FXEBCJSE -Noyember 16. 2016 Sub-element

4. b-Post Plume Phase Field Measurements and Sa fin Intent This sub-ele m ent is derived from NUREG*0654

/FEMA-REP-l , w hi ch requires thatOROs should have the capability to assess the actual or potential magnitude and locations of radiological hazards in the ingestion exposure pathway EPZ and to support relocation , re-entry and re turn decisions. This sub-elementfocuses on the co ll ecting envi r onmental samples for laboratory analyses that are essential for decisions on protection of the public from conta minat ed food and water and direct radiation from deposited materials. C rit erion 4. b. l: The field teams (2 or more) demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g.,jood crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making. (NUREG-0654/FEMA-REP-l CJ; L8; J.11) Extent of Play The ORO 'sjield monitoring teams must demonstrate the capability to take measurements and samples , at such limes and loca ti ons as dire c ted to e nable an adequate assessment of the ingestion exposu r e pathway and to s upport re-entry, relocation, and return decisions. When r e sources are available , use of aerial surveys and in-situ ga mma m easure m ent is appropriate. All meth odology , including conta minati on con tr o l , instrumentation , preparation of samples , and cha in-of-cus t odyfo rm (s)fo r transfer to a lab oratory(ies), w ill be in accordance with th e ORO 's plans/procedures. The field monitoring teams and/or other sa mplin g personnel must secure ingestion exposu r e pathway samp l es from a gric ultural products and wa ter. Samples in s upp o rt of relocation and return mu s t be s ecured from soil , vegetation , and other s ur faces in areas that received radio a ctive gro und deposition. OROs will use Federal resour c es as identified in the NRF Nuclea r/Radiologica l Incident Annex and other reso ur ces (e.g., co mpa cts , the licensee , or nuclear insurers) as needed. Evaluation of this c rit e r ion will take into consideration t h e level of Federal and other resources participating in the exe r cise. All activities must be must be based on the ORO 's plans/procedures and completed as they wou ld be in an actual emergency , unless noted above o r othenvise specified in the extent of play agreement. Massachusetts Extent of Play This s ub-element will not be dem onstrate d during this exercise. Level l or Level 2 Fi nding s: NIA Note: If , during the exercise , a participant demonstrates this su b-elem en t unsatisfactorily , the FEMA Eval u ato r will info rm the MEMA Co ntr o ll er. After an " on the spot" training by the l ocal or State representative , the FEMA Eval u ator wi ll provide another opportunity to re-demonstrate t h e activity that day. Pilgrim EOP Rev. 0 Page 35 of 50 07127116 pu ,G RIM NI T CJ,EAR POWER STATTON f,XERCJSE -Noyember 16. 2016 I Sub-element

4. c -laboratory Oeerations Intent This sub-element isderivedfromNUREG-0654

/FEMA-REP-l , which requires thatOffsite Response Organizatio n s (ORO) have the capability to perform laboratory analyse s of radioactivity in air , liquid , and envi r onmental samples to support protective action decision-makin g. Criterion

4. c. J: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NU REG-0654/FEMA-REP-J, CJ, 3; J.11) Extent of Play The laboratory staff must demonstrate the capability to follow appropriate procedures for receiving samples , including logging of info rma tion, preventing contamination of the laboratory(ies), preventing buildup of background radiation due to sto r ed samples , preventing cross contamination of samples , preserving s amples t hat may spoil (e.g., milk), and keeping track of sample identity. In addition , the laboratory staff must demonstrate t h e capability to prepare samples for conducting measurements.

The laboratory(ies) must be appropriately equipped to provide , upon request , timely analyses of media of sufficient quality and sensitivity to support assess m ents and decisions as anticipated by the ORO 's plans/p r oced ur es. The laboratory instrument ca librat ions must be traceable to standards provided by the Nationa l Institute of S tandards and Technology. laboratory methods used to analyze typica l radionuclides released in a r e actor incident should be as described in the plans/procedures. New or revised methods may be used to analyze atypical radionuclide releases (e.g., transuranics o r as a.result of a terrorist event) or if warranted by incident c ircumstance

s. Analys i s may require resources beyond those of the ORO. The laboratory staff must be qualified in radioanalytical techniques and contami nati on co ntr ol procedures. OROs wi ll use Federal resources as identified in the NRF N uclea r/Radiological Incident A nnex and other r esou r ces (e.g., co mpacts , the licensee , nuclear insurers) as needed. Evaluation of this criterion will take int o cons id eration the level of Federal and other r esources participating in t he exe r cise. A ll activities must be based on t h e O R O 's plans/procedures and comp l eted as they would be in an actual emergency, unless noted above or otherwise specified in the extent of play agreement.

Massachusetts Extent of Play This sub-element will not demonstrated during this exercise Level 1 or Level 2 Findings: N/A Pilgiim £6P Ru. 8 Pagd6 of58 PU , QRIM NJTCJ,EAR POWER STATION EX}i;RCJSE Ngyember 16. 2016 EVA L C IA TTON A BRA 5

Rnzerggncy Nqtjficqtiqn qnd Public lnfnrmatian Sub-element 5.a-Activation ofthe Prompt Alert and Notification Svstem Intent This sub-element is derived from NU REG-0654/FEMA-REP-l , which requires that 0 ROs have the capability to provide prompt instructions to lhe public within the plume palhway EP Z. Specific provisions addressed in this sub-e/emenl are farther discussed in Section V. Part A of the REP manual , Alert and Notification Syste ms. Exhibil W-4: Eva luali on Standards for Alert and Notificalion Svs1ems Demonstration JnaTunely W'uhin 45Minutes Within a CriJeria:

Manner Reasonable Ti me Prin111T1J Alert and Notification 5.a.J: ... covering essentially 100% of x the I 0-mi/e EPZ 5.a.4: .. .for FEMA-approved exception x areas Backup Alert and Notification for Alllncidents 5.a.3: ... coveri n g the x 10-mileEPZ Criterion

5. a.I: Activities associated with p r imary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

The initial instructional message to the public must include as a minimum the elements required by current REP guidance. (NUREG-0654/F EMA-REP-l, E.5, 6, 7) Extetlt of Play Responsible Ojfsile Response Organizations (ORO) mus/ demonslrale the capability to sequen tially provide an a/er/ signal followed by an initial ins/ructional message Jo populated areas (permanent residen/ and Jransienl) throughou/ the 10-mile plume pathway EPZ. Following Jhe decision Joactivale Jhe a/er/ and notification sys t em, OR Os must co mpl ete syste m activation fa r primary alert/notification and disseminate Jhe information/ins/ructions in a lime/y manner. Fo r exe r c is e pwposes , timely is de.fined as " with a sense of urgency andwithow undue delay. "If me ssage dissemination is identified as not having been accomplished in a limely manner , t h e evaluator(s) will document a specific delay o r cause as to why a me ssage was not cons ider e d tim ely. Proced ur es to broadcast the message mus/ be folly demons/rated as they wo uld in an actual e m ergency up to t h e point of1ransmission. Broadcast of the message(s) or test messag e s is not required. The proced ur es mus/ be demons/rated up to t h e poin t of actua l activation. The alert signal activation should be simu lat ed , not performed. Evaluations of EAS broadcast s tat ions may also be accomplished t hr ough SA V s. The capability of/h e primary notification system to broadca s t an instructional m essage on a 24-h our basis must be verified during an interview with appropriate personnel fro m the pr im a ry no tifi cat i on system, including verification of provisions fo r backup power or an alt e rnate sta t ion. Pilgrim EOP Rev. 0 Page 37 of 50 07n 7/16 PU,GBIM NI J Q,YAB fOWEB STATTON EXEBQSE-November 16. 2016 The initial message must include at a minimum the following elements: Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message; Identification of the commercial Nuclear Power Plant and a statement that an emergency exists there; Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in te l ephone books) for use by the general public during an emergency; and A closing statement asking that the affected and potentially affected populations stay tuned for additional information , or that the population tune to another station for additiOna/ information. If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the OROs plans/procedures and the extent of play agreement. OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subjec t to specific time requirements). At leas t one route needs to be demonstrated and evaluated. The selected route(s) must vary fro m exercise to exe r cise. However , the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (i.e., the message that would actually be used is read for th e evaluator , but not actually broadcast) as negotiated in the ex t ent of play. Actual testing of the mobile public address system wi/J be conducted at an upon location. OROs must demonstrate any means of primary alert and notification included in their plans/procedures as negotiated in the extent of play agreement. All activities must be based on the ORO 's plans/procedures and comp l eted as they would be in an actual emergency , except as noted above or otherwise specified in the extent of play agreement. Massachusetts Extent of Play The sounding of the sirens and broadcastofEAS/News Releases will be simulated. EAS/News Releases will be formulated and distributed by the Massachusetts State EOC. Actions to demonstrate performance of initial notification of the public will be performed up to the point ofactual transmission of the E mergenc y Alert System (EAS) message. The EAS message will be prepared/ encoded by MEMA. EAS radio statio n WBZ (1030 AM) will be initially contacted and faxed a copy of a standard test me ssage. Siren activation and broadcast ofEAS messages/News Releases will be simulated. Level 1 or Level 2 Findings: NIA Criterion5.a.2: {RESERVED] Criterion

5. a.3: Backup alert and notification of the public is completed within a reasonable time following the detection by the ORO of a failure of the primary alert and notification system (NU REG0654/FEMA-REP-1, E. 6; Appendix 3.B.2.c) Extent of Play Jftlze exercise scenario calls for failure of any portion of the primary system(s) or if any portion of the primary system(s) actually fails to function during the exercise , OROs must demonstrate backup means of alert and notification.

Backup.means of alert and notification will differ from facility to facility. Pilgrim EOP Rev. 0 Page 38 or SO 07127116 PU.GRIM NI T Q.EA R POWER STATION EXERCISE-Noyember 16 2016 Backup alert and notificarion procedures that wo uld be impl e m e nt ed in multipl e stages mus/ be structured such that the population closest to the plant (e.g., wirhin 2 miles) is alerted and norifiedjirst. The pop ulari o n sfart h er away and downwind of any poremial radiological release would be covered se qu en tiall y (e.g., 2 10 5 mil es.fo ll owe d by d ownw ind 5 t o 10 mil es , and finally the r e mainin g population as direcred by aurhoriries). Topography , population density, existing ORO resources, and timing will be considered in jud gi ng th e ac ce ptability of backup means of alert and n o tification. Al th o ugh ci r c um s ranc es may nor allow t hi s fo r all siruations, FEMA and rhe N R C rec o mmend rhar OROs and o p e rat ors a/tempt to es tablish backup m ea ns thar w ill reach those in the plume expos ur e EPZ within a reas o nable lim e of fa ilure of rh e prima ry al e rt and norification system, wirh a recommended goal of 45 minut es. The ba cku p alert m ess a ge mu s e , at a minimum , include: (1) a s tat eme nt chat an emergency exists at the plant; and (2) i n s tructi o ns rega rding where to o btain a dditional information. Whe n backup r o ut e alerting i s dem ons trat ed , only one route needs to be selected and demonstrated. A ll alert and notification activities along the route(s) must be s imulat ed (i.e., the m essage that would actually be us ed is read for th e eva luaror , but not acrually br oadcast), as n ego tiat ed in t h e ex t en t of play. Ac tual testin g of t h e m obi l e public address sys tem will be co ndu cted a t a n agreed-upon lo catio n. O R Os ma y demon st rate a ny m ea n s of backup alert and notification included in their p lan s/procedures as n egotiated i n the Extent-of-Play Agree m e nt. A ll activities mu s t be based o n t h e ORO 's plans/p r oced ur es and co mpl eted as they wo uld be in an actual e mer ge n cy, unless not ed above or otherwise spec ifi e d in t he Extent-of-Play Ag r ee m en t. Massachusetts Extent of Play This sub-element will not be demonstrated this iteration. Level l or Level 2 Findings: N/A Criterion

5. a. 4: Activities assodatedwitli FEMA-approved exception areas (wliere applicable) are completedwitliin 45 minutes following tlie initial decision by autliorized offsite emergency officials to notify tlie public of an emergency situation. (NUREG-0654/FEMA-REP-J , E. 6; Appendix3.B.2.c)

Extent of Play Offs ite Response Organizations (ORO) with FEM4-appr ovedexceptionareas (i dentified in the appr o ved A lert and Notifica ti on System Design Report), 5to10 mile s from the nuclear power plant , must demonstrate the c apability to ac co mplish primary ale rtin g and notification of the exceptionarea(s). FEMA and the NRC recommend thatOROs and operators es tablish means that will reach those in approv ed exception ar e a s within 45 minutes once the initial decision i s mad e by authoriz e d offs it e emergency officials to notify the public of an incident. The exception area alert messa ge must , at a minimum , include (1) a stateme nt that an emergency exists at the plant and (2) instructions regarding where to obtain additional information. For excep tion area alerting, at l e ast o ne route needs to be demonstrated and ev aluat e d. The se le cte d route (s) s hould vary from exe r c ise to exercise. Howev e r , the most difficult rout e(s) must be demonstrated no less than o nce e very 8 ye ar s. A ll alert and notification activiti es along th e rout e(s) must be si mulat e d (i.e., the me ss age that w o uld a c tually be us e d is read for the e valuaror , but not actually br o adcasted) as n ego tiated in th e ex tent of play. Ac tual testing of the m ob ile public address sys tem will be co ndu c ted at 8'Hl!'1116 PU , GRIM Nlf CJ,EAB POWER STATION EXEBQSE-N oyemher 16 2016 an agreed-upon location. For exception areas alerted by air/w ater craft, actual routes will be negotiated in the ex tent of play , but must be demonstrated no less than once every 8 years. A ll activities mu st be based on the ORO 's plans/procedures and completed as they would be in an actual emergency , except as noted above or otherwise s pecified in the extent of play agreement. Massac hu setts Extent of Play This criterion is not required b y the Massachusetts Radiological Eme r ge ncy Response Plan. Level 1 or Level 2 Findings: NIA rugnm tor Rev. o rage 40 ot so 0 11211 16 pU , GRIM NI T CJ,EAR fOWER STATION EXERCISE-Noyember 16. 2016 Sub-element 5.b-Subse uent Emer en In ormation and Instructions or the Public andthe Media Intent This sub-element isderivedfrom NUREG-0654/FEMA-REP-l, which requires thatOffsite Response Organizations (ORO) have the capability to disseminate appropriate emergency information and instructions , including any recommended protective actions , to the public. In addition , NU REG-0654/FEMA-REP-I requires OROs to ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency. NUREG-0 654/FEA1A-REP-l also provides that a system should be available for dealing wi th rumors. This system will hereafter be known as the '*public inquiry hotline. " Criterion

5. b. l: OR Os provid e accurate subsequent emergency information and instructions to the public and the news media in a timely nwnner. (NURE G-0654/FEMA-REP-1 , E. 5, 7; G. 3. a, G.4. a, c) Extent of Play The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions 10 the public and media in a timely manner following the initial alert and notification (not subject to specific time requirements

). For exercise purposes , timely is defined as " with a sense of urgency and without undue delay. " If message dissemination is identified as not having been accomplished in a timely manner , the eva luator (s) will document a specific delay or cause as to why a message was not considered timely. Message elements: The ORO must ensure that emergency info rma tion and instructions are consistent with protective action decisions made by appropriate officials. The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions , evacuation routes , reception center locations , what to take when evacuating , shelter-in-place instructions , information c oncerning protective actions fo r school s and persons with disabilities and acces s/functional needs , and public inquiry hotline telephone number) to assist the publi c in carrying o ut prot ec tive action decisions provided. The ORO must also be prepared to disclose and explain the Em e rgency C lassification level (E C L) of the incident. At a minimum , this information must be included in media briefings and/or media releases. OROs must demonstrate the c apability to use language that is clear and understandable 10 the public within both the plume and ingestion exposu r e pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries 10 describe prote c tiv e action areas. The e mergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a. land previously identified protective action areas that are still valid , as well as new areas. Information about any rerouting of evacuation routes due to impediments should also be included. The OROs must demonstrate the c apability to ensure that em e rgency information that is no longer valid is rescinded and not repeated by broadcast media. In addition , the OROs must demonstrate the capability to ensure that curr e nt emergency information is repeated at pre-established intervals in accordance with the plan s/procedures. OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures. If ingestion pathway measures are exercised , OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to pr e-d etermined individuals and businesses in accordance with the 0 RO 's plans/procedures. Pilgrim EOP Rev. 0 Page41 of SO 07/27/16 PU,GBJM NJT CJ ,EA B POWER STATTON f:XERCJSE-Noye mber 16 2016 Media information: OROs must demonstrate the capability to provide timely , accurate , concise , and coordi nat ed information to the news media/or subsequent dissemination to the public. This would include demonstration of the capability to c onduct timely and pertinent media briefings and distribute media releases as the incident warrants. The OROs must demonstrate 1he capability to respond appropriately to inquirie s from the news media. All information presented in media briefings and releases must be consistent with protective action decisions and other emergency info rmation provided to the public. Copies of pertinent eme r gency information (e.g., EAS me ssages and media releases) and media information kits must be available for dissemination to th e media. Public inquiry: OROs must demonstrate t hat an effective system is in place for dealing with ca lls received via the public inquiry hotline. Hotline s taff must demonstrate the capability to provide or ob tain accurate information for callers or refer 1hem to an appropriate informalion source. Information from Ihe hotline s taff. including information Iha/ co rr ects false o r inaccurate information when trends are noted , must be included , as appropria/e , in e mer gency information provided to the public , media briefings , and/or media releases. HAB co n sideratio n s: The dissemination of information dealing with specific aspecls of NP P security c apabili1ies , actual or perceived adversarial (1errorist)fo r ce o r Ihreat , and Jactica/ law enforce ment response mu st be coordina1edl communica1edwith appropriale security authorities , e.g .. law enfo r cement and NP P security agencies, in accordance with ORO plans/procedures. All acJivities must be based on Ihe ORO 's plans/procedures and comple1ed, as /hey would be in an actual emergency , unless noted above or 01herwise specified in the extent of play agreement. Massachusetts Extent of Play Joint Information Center: Information generated as a result of incoming calls to the SEOC Public Information Line/MASS 211 Call Center will be included in news briefings. At least two rumor trends will be handled. State EOC: Control ce ll personnel will make calls simulating members of the public. The MASS 2!! Call Center will demonstrate the ability to handle public inquiry calls. Handling at least two rumor trends (three or more calls of the same nature) will be demonstrated. Two MASS 211 public information line operato r s each will respond to calls once the Public Alert and Notification System has been activated at Site Area Emergency or General Emergency at the State EOC. Each local EOC w ill demonstrate the community's emergency response and refer all other questions to MASS 211 Cal l Center. Level I or Leve l 2 Findings: N/A Note: If , during the exercise, a participant demonstrates this s ub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Co ntroller. After an " on the spot" training b y the lo cal or State representative , the FEMAEvaluatorwill provide another opportunity to re-demonstrate the activity that da y. Pilgrim EOP Rev. 0 Page 42 of 50 07/27/16 PU , GBIM Nl!CJ.EAB POWER STATION f:XEBCISE-Noyemher

16. 2016 t:VALCIAUoNAREA 6* Sunnqrt Opgrqtiqnffqdlitigs Sub-element6.a-Monitoring.

Decontamination and Registration o(Evacuees Intent Thissub-ele m en ti sde riv e dfr omNUREG-065 4/FEMA-REP-l , w hi chreq uir est hat Offsi te Response Organizations (ORO) have the ca pability to implement radiologi c al m o nitorin g and decontamination of evacuees , wh il e minimizing co ntaminati o n of the facility. OROs mu s t also hav e rh e capability to identify and regisrer evacuees at reception center s. Criterion 6.a.J: The reception center facility has appropriate space , adequate resources , and trained personnel to provide monitoring, decontamination, and registration of evacuees. (NURE G-0654/FEMA-REP-1 , A.3; C4; J.10.h; J.12) Extent of Play Radiological m o nitorin g , d eco nraminati o n , and r egisr ration f a ci liti esfo r evac u ees mu s t be se r up and demonstrated as they wo uld be in an actual emerge n cy or as indicated in t h e exten t of play a gree m ent. OROs co nducring this demonstration must hav e 1 1 3 of the resources (e.g., m o nit o rin g t e am s/in s trum e ntario nl portal m o nitors) availabl e at the f acility (ies) as n ecess ary to monitor 20% of the population within a 12-hour p e ri od. This would include adequate sp a ce fo r ev a c uee s' vehicles. Av ailability of re source s can b e demonstrated wi th valid documentation (e.g., MOU/LOA , e tc.) reflecting how nec ess ary equipment would b e pr oc ured fo r th e location. Pla n s/pro ce dur es must indicate provi s ions for service animals. Befo r e u si ng monitorin g in s trument (s), the m o nit o r (s) must demon s trat e th e process of chec king the instrument(s) fo r proper oper ati on. St aff responsible fo r the radiological m o nit o r i n g of e vacuees must demonstrate the c apabili ty to a/lain and s u stai n , within ab o ut 12 hours , a monitoring productivity rate per h o ur needed t o m o nitor the 20% emergency planning zone (EPZ) population planning base. The monitoring producrivity rar e per h ou r is rhe number of ev a cuees thar can be m o nitor ed , per hour, by rhe r ota/ co mpl e m e nt of m o nitor s using a n app r op riar e procedure. Fo r demonstration of monitoring, d eco ntaminati o n , a nd r egis tration ca pabiliti es, a minimum of six individuals per monitorin g station must b e monit o r e d per station using e quipment and procedures s pecified i n rh e plans/procedures. The m o nitorin g seq uen ces for th efi r s r six s imulat ed evac u ees per m o nit o rin g team wi ll b e timed by th e eva luar ors in o rder to determin e whether the tw e lv e-h o ur requirement can b e m e t. OROs mu st demonstration the cap ability to register ev acu ees up o n co mpleti o n of the monit ori ng and decontamination a c tiviti es. Th e activiti es fo r recording radiological m o nitor i n g and , if n ecess ary , decontamination must include estab li s hin g a registration record cons isting of th e evacuee's name , address , r e sults of m on i tor in g , and time of de co ntaminati o n (if any), or as ot h en11 i se designated in the plan and/o r procedures. Audio recorders , ca m corders or writte n re c ords are all acc ep table m eans fo r registration. Mo nit or in g activities s hall nor be si mulat ed. Mon itor ingpe r so nn e lmu stexplain u se of trigger/a c tion levels fo r determining the n eed for decontamination. They must al so expl ain the proc e dures for referring any evacuees who c annot b e adequately decontaminated for assessment and fo ll ow-up in accordance w ith the O R O 's plans/procedures. A ll activities mu st b e based on th e O R O 's p lans/p ro cedu r es and co mpl e ted as they wou ld b e in an actual emergency , unless n o t ed above or othen11ise s p ecified in the ex t e nt of play agreement. Pilgrim EOP Rev. 0 Page 43 of 50 071271 1 6 PU ,G RIM NI!CJ,EAR POWER STATTON EXERCISE-Noyemher 16 20J6 Decontamination of evacuees may be simulated and conducted by interview. Provisions for separate showering and same-sex decontamination must be demonstrated or explained The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coveri ng s, signs , and appropriate means (e.g., partitions , roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees , provide changes of clothing/or those with contaminated clothing; and store contaminated clothing and personal belongings to preventfarther contamination of evacuees or facilities. In addition.for any evacuee found to be contaminated, procedures must be discussed concerning the handling of potential contamination of vehicles and personal belongings. Waste water from decontamination operations does not need to be collected. Individuals who have co mpl eted monitoring and decontamination, if needed must have means (e.g., hand stamp , s ticker , bracelet,form, etc.) indicating that they , and their service animals and vehicles, where applicable , have been monitored, cleared, and found to have no conta m ination or contamination below the trigger/action level or have been placed in a secure area until they can be monitored and decontaminated, if necessary. In acco rdan ce with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored These individuals do not requ ir e c onfirmation that their ve hicl e is free from contamination prior to entering the co n gregate care areas. However , those individuals who are found to be co ntaminat ed and are then decontaminatedwill have their vehicles held in a secure area or monitored and decontaminated (if applicable) and do require confirmation that their vehicle is being held in a secure area or free from contamination prior to entering the congregate care areas. Massachusetts Extent of Play This sub-element will not be demonstrated during this exercise. Level l or Level 2 Findings: NIA Note: If , during the exercise , a participant demon s trate s this sub-element unsatisfactoril y, the FEMA Eval uator will inform the MEMA Controller. After an " on the spot" training by the local o r State representative , the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day. Pilgrim EOP Rev. 0 Page 44 of SO 07127/16 PU.GR IM NJ J CJ ,EA R POWER S T AT IO N EXE BQS E-N oyember 16 2016 a n d D eco n taminatio n o Eme r<>e n Wo r kers a n d thei r E u i me nt a n d Inte n t This sub-elem e nl is derived from NUREG-0654/FEMA-REP-I, which r eq uires that Offs ire Response Organizations (ORO) have the capability to implement radiological monitoringandde co nlamination of emergencyworkers and their equipment , inclusive of vehicles. C rit e ri o n 6. b. l: T/1 e faci l ity/ORO h as ad equate pr oce dur es and r eso ur ces to a cco mpli s h m o nit o r i n g and d eco n ta minati o n o f e me rge n cy wo rk ers a nd t h e ir e qu i p me n t and ve h icles. (NU REG-06 5 4/F E MA-RE P-l,K.5.a, b) Exte nt o f Pl ay The monitoring staff must demonstrate the capability lo monitor emergency worker personnel and Jheir equipment andvehiclesfor conlamination in accordance with the Offsite Re s ponse Organizations (ORO) plans/procedures. Specific a/lention must be given to equipment, including any vehicles that were in co ntact with contamination. The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, e quipment, and vehicles based on trigger/action levels and procedures stated in the OROs plans/procedures. Monito r ing of e m ergency wo r ker> does not have to meet the 12-hour requiremen

t. However , appropriate monitoring procedur es must be demonst r ated fo r a minimum of 2 emergency workers and t h ei r e quipment and vehicles. Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrumenl(s)for proper operation.

The area to be used for monitoring and deconlaminalion must be set up as it would be in an aclual emergency, with all route ma r kings , instrumenlalion , record keeping and co ntamination co ntrol measures in place. Monitoring pro ce dures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. However , the capability to monitor areas such as radiator grills , bumpers , wheel wells , I ires , and door handles must be demonstrated. Interior surfaces of v e hicles tha l we r e in contaclwilh con1amina1ed individuals must also* be checked. Decontaminalion of emergency workers may be simulated and conducted via interview. Provisions for separate showering and same-sex decontamination must be demonstrated or exp l ained. The staff must demonstrate provisions for limiting the spread of contamina t ion. Provisio n s cou ld i n clude floor cove r ings , signs and app r opriate means (e.g., partitions , roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated individuals where applicable, provide changes of clothing/or those with contaminated clothing and s lore contaminated clo1hing and personal belongings to prevent.further contaminalion of emergencyworkers or facilities. OROs must demonstrate the capability to regisler e m erge n cywo rker supo n co mpl e tion of the monitoring and decontamination activities. The activiliesfor recording radiological moniloring and if necessG!y , decontamination must include establishing a registration record consisting of the emergency worker's name , address , results of mon i toring , and time of decontamination (if any), or as o t herwise designated in the plans/ procedures. Audio recorders, camcorders , orwritlen records are all acceptable means for registration. Monitoringaclivities shall not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. Th ey musl also explain the procedures for referring any Pi l grim EOP Rev. 0 Page 45 of 50 07/27/16 PU , GBIM NlICiiEAB POWER STATTON EXEBQSE -Noyemher 16. 2016 emergencyworkerswho cannot be adequately decontaminated fo r assessment and follow-up in accordance with the ORO 'splans/procedures. Decontamination capabil iti es and provisions for vehicles and equ ipment that cannot be succesifully decontaminated may be si mul ated and conducted by interview. Waste wa ter from decontamination operations does not need to be collected All activities must be based o n the ORO 's plans/procedures and comp l eted as they wou ld be in an actual emergency , unless noted above or otherwise specified in the extent of play agreement. Massachusetts Extent of Play This s ub-element will not be demonstrated during this exercise. Level I or Level 2 Findings: NIA Note: I f , during the exercise , a participant demonstrate s this s ub-elem e nt unsatisfactorily , the FEMA Eval uator will inform the MEMA Co ntroller. After an " on the spot" training by the local or State representative , the FEMA Eval uator will provide another o pportuni ty to re-demonstrate the activity th a t da y. Pilgrim EOP Rev. 0 Page 46 o r.So 07/27/16 PU ,G B!M NJTQ,EAB POWER STATION EXEBCJSE-Noyember 16 2016 I Sub-element

6. c-Temporary Care o(Evacuees Intent This sub-element is derived from NU REG-0654/FEMA-REP-l , which requires 1hat Offsile Response Organiza/ions (ORO) to have the capability toe stabl i sh relocation centers in host/support jurisdictions.

The American Red Cross normally provides congregate care in supporl ofOROs under existing letters of agreement. Criterion 6.c.1: Managers of congregate care facilities demonstraJe thaJ the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. Managers demonstrate the procedures to assure thaJ evacuees have been monitored for contamination and have been decontaminaJed as appropriate prior to entering congregaJecarefacilities. (NUREG-0654/FEMA-REP-1, J.10.h, J.12) Extent of Play The evalua t or must c onduct a walk-through of the c enter to determine , through observation and inquiries ,

that the services and accommoda1ions are consis t entwi th applicable guidance.

For planning purposes , OROs mus/ plan fora sufficient number of congregate care centers in host/support jurisdictions based on their a//-hazardshelteringexperience and what is historically relevantfor that particular area. In this si mulation , it is not necessary to set up operations as they would be in an actual emergency. A lterna1ively , capabilities may be demonstrated by setting up stations for various services and providing those services to sim ulat ed evacuees. Given 1he substantial differences be/Ween de monstration and simulation of this c rit erion, exercise demonstration expectations must be clearly specified in extent-of-play agreements. Congrega t e care s1aff mus/ also demonstrate lhe capabi lity to ensure that evacuees , service animals, and vehicles have been monitored for contamination , decontaminated as appropriale , and registered before entering the facility. Individuals arriving at congregate c are facilities must have means (e.g., hand stamp , sticker , bracelet.form , etc.) indicating that they , and their service animal and vehicles , where applicable , have been placed in a secured area or monitored, cleared, and found to have no contamination or con tamination below the trigger/a ction/eve/. Jn accordance with plans/procedures , individuals found to be clean after monitoring do not need to have their vehicle monitored These individuals do not need corifi rmation 1hat their vehicle is free from contamination prior to entering the congregate care areas. However , those individuals who are found to be co ntaminat ed and are then deconta minat ed will have 1heir vehicles held in a secure area until 1hey can be monitor e d o r decontaminated (if applicable) and do need corifirmation 1hat their 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 , blankets, s undries , and large-scale food supplies) need not be physically available at thefacility(ies). However , availability of such items must be verified by providing the eval uator a /isl of sources with locations and eslimates of quantities. Pilgrim EOP R ev. 0 Page 47 of 50 07127/16 PU , GBIM NJ J CJ ,EA B POW E R STATION EXEBCJS E-Npyemher 16. 2016 A ll activ i ties must be based on the ORO 's plans/procedures and co mpl e ted as they would be in an actual emergency , unl ess n o ted above or otherwise specified in the exte nt of play agreement. Massachusetts Ex tent of Play This sub-e l e m ent will not be demonstrated during this exercise. Levell or Level 2 Findings: N/A Ht gnm EOP K ev. 0 rage 48 at so O ff Z fl i6 PU , GR JM NJJ CU;AB POWER S TA TTO N EXERCJS E-Ngyemher 16 2016 Sub-e/eme nt 6.d-Trans o rtati o n and Tr e atment o Co n t aminat e d I n 'ur e d Individual s In te nt This sub-element is derived from NUREG-0654 /FEMA-REP-l , which requires thatOffsile Response Organizations (ORO) have the capability to transport contaminated injured individuals to medica/facilities with the capability to provide medical services. C rit e ri o n 6. d I: T h e faci li ty/ORO h as th e appr o priate s pa ce, ad e quat e re s our ces, and trained p e r s onnel t o pro vi de tr a n s port , nwn ito r i n g, dec o nt a mination , and medi c a l se rvi ces to c ontaminat e dinjur e d i ndi v idual s. (NU REG-0 654/FEMA-REP-I, F.2; H.I O; K.5.a, b; LI , 4) Ext e nt o f Pl ay Monitoring , decontamination, and contamination control effo r ts must not delay urgent medical care fo r the victim. Offsite Response Organizations (ORO) must demonstrate the capability to monitor/decontaminate and transport contaminated , injured individuals to medical facilities. An ambulance must be used for the 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 medica l facility. It is allowable fo r an a m bu l ance to de m onstrate up to the point of departu r e for the m ed i ca l faci l ity and then have a non-specia l ized vehicle transport t h e " victi m (s) " to t h e m edica l facility. This option is used in areas where removing an ambulance from service to drive a great distance (over an hou r) for a drill wou l d not be in the best i n terests of the com mu nity. No r mal com m unications between the ambulance/dispatcher and the receiv i ng medical facil i ty m ust be demonstrated. Jfa substitute vehicle is used for t r ansport to the medical facility , this communication must occur before releasing the a m b ul ance from the dril l. This communication would include reporting radiation monitoring results , if available. Jn addition , the ambulance crew must demonstrate , by interview , know l edge of where the ambulance and crew would be monitored and decontaminated, if required , or whom to contact for such information. Monitoring of the victim may be performed before tra n sport or enroute , or may be deferred to the medical facility. Con t a m inated i n j u red individua l s t r ansported to medica l facilities are monito r ed as soon as possible to assure tha t everyone (amb ul ance and medica!jacility) is aware of the medic a l a n d radiological status of the indtvidual(s). However , if an ambulance defe r s monitoring to the medica l facility , then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored. Before using monitoring instru m ents , the monito r (s) must de m onstrate the p r ocess of checking the instrument(s)for prope r operation. All monitoring activities must be c omp l eted as they would be in an actual emergency. Approp r iate contamination control measu r es mus.I be demonstrated before and duri n g transpo r t and at the receiving medical facility. The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment. Medical facilities are e xpected to have at least one trained physician and one trained nurse to perform and supervise treatment of contaminated injured individuals. Equipment and supplies must be available for the treatment of co n taminated injured individuals. Pi l grim EOP Rev. 0 Page 49 of 5-0 07127116 PILGR IM Nl l CJ,E A R PO W ER S T A TIO N f:XERCJSE N oyember 16. 2016 The medical facility must demonstrate the capability to make decisions on the need for decontamination of the individual.follow appropriate decontamination procedures , and maintain records of all survey measurements and samples taken. A ll procedures for the collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator. Waste water from decontamination operations must be handled according to facility plans/procedures. All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency , unless noted above or otherwise specified in the extent of play agreement. Massa chu se tts Ex t e nt o f Pla y Good Samaritan Hospital wi ll be demonstrated o u t of seq u ence September 2016 Level l o r Leve l 2 F inding s: NIA Pilgrim E OF ReV. 0 r age so 0 1 so 0 112111 6 Unclassified Radiological Emergency Preparedness Program (REP) After Action Report/lmprovement Plan Pilgrim Nuclear Power Station Appendix D: Pilerim Exerdse Scenario Summary* Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise SCHEDULE OF EVENTS* 34 pre-Exercjse Event: Date: Time: Location: Attendees: Event: Date: Time: Location: Attendees: Event: Date: Time: Location: Attendees: Event:. Date: Time:

Location:

Attendees: Event: Date: Time: Location: Attendees: Event: Date: Time: Location: Attendees: SCHEDULE OF ACTIVITIES TSC/OSC Player Briefing* Monday, November 7 2016 1000-1130 . TSC/OSC TSC/OSC Players EOE Player Brjefing* Monday, November 7, 2016 1400-1530 EOF EOF Players

JIC Player Briefing*

Tuesday, November 8, 2016 0730-0900 Industrial Park -Classroom 4 JIC Players

Controller Briefing Wednesday, November 9, 2016 1300 -1500 ESB Conference Room 2A/B All Controllers NBC Entrance Monday November 14, 2016 1300 TBD Lead Facility Controllers, Leadership Team EEMA Evaluator Briefing Tuesday, November 15, 2016 1000 Hampton Inn, Plymouth selected individuals for scenario review Exercise Event: Date: . Time: Location:

Attendees: Post-Exercjse Event: Date:' Time: Location: Attendees: Event: Date: *Time: Location: Attendees: Event: Date: Time: Location: Attendees: Event: Date: Time: Location:. Attendees: NRC/FEMA Evaluated Exercise .. Wednesday, November 16, 2016 0800 to Drill Termination Simulator, TSC, OSC, EOF, JIC All Players and All Controllers Lead Controller Debrjef Wednesday, November 16, 2016 1600 -1800 CR 2A/B Drill Coordinator, Lead Facility Controllers and Players and EP Exercise Results -Persentation to Management Team/NBC* Thursday, November 17, 2016 1600 -1700 (tentative) CR3A Senior Team, Lead Facility Controllers and Lead Drill Players, EP NRC Exjt* Friday,November18,2016 0830 (tentative) CR3A Senior Team, Lead Facility Controllers and Lead Drill Players, EP EEMA Public meeting* Friday,November18,2016 1100 Hampton lrin, Plymouth EP, RAPID.members pf Senior Team, * *Presentation to Management and NRC Exit are dependent on drill and inspection results Pilgrim Nuclear Power Station November 16, 201616-04 NRC/FEMA Evaluated Exercise

PartiCipating Agencies:

Commonwealth of Massachusetts .

Massachusetts Emergency Management Agency (MEMA) Massachusetts Department of Public Health (MDPH) EPZ Communities Town of Plymouth Town of Carver Town of Kingston Town of Duxbury Town of Marshfield Reception Communities
Taunton , Bridgewater Braintree Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise Plant and Player Safety Considerations:
Do NOT operate any plant equipment
Personnel are required to maintain safe operation (i.e., on-shift operators) of the plant will be exempt from drill activities.

Do not interact with the sh ift operating crew

Never violate Industrial Safety, Radiation Protections, Operations or Security procedures/regulations
Drill communications over radios and telephones are to be prefaced and followed by "THIS IS A DRILL." Face-to-face communications do not require this statement
Use 3 part communication especially with numbers, units of measure, etc.
If a plant issue/actual emergency arises you will be informed by the facility controllers to suspend the drill. *
Participants must respond to simulated events as if they are real. This includes but is not limited to the following:

[As amended by extent of play or controllers] (a) Wearing of dosimetry and protective clothing. (b) good radiation protection practices (c) Minimizing exposures (d) Responding to failed instruments in the field (e) Reporting hazards to the correct personnel (f) Proper contamination control

All normal site procedures and rules are to be followed when entering the protected area and actual radiological controlled or radiation areas. NO ONE, including controllers, and observers, are exempt from normal station radiological or safety practices
Read/review your procedures/position books. A drill is an infrequently performed task. . ... --* --***--

*---------------------------------*------.

Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES . A.1 Command and Control Demonstrate the ability of the Emergency Director or Facility Lead/Manager to provide overall direction (command and control) by initiating, coordinating and implementing timely and effective actions during the event. . Demonstrate the ability of the Emergency Director to provide overall direction (command and control) by initiating, coordinating and implementing timely and effective actions during the event. A.2 . Operatjonal Agreements Demonstrate the coordination of the implementation of emergency and the exchange of information between the utility and Federal, State and local agencies and other support organizations having an emergency response role within the EPZ. A.3 Contjnyous Operatjons Demonstrate the capability to establish and maintain continuous (24 hour) operations for a protracted period.

B.1 Shjft Staff Response Demonstrate the ability of the normal staff complement to perform the functions of the on-shift ERO. B.2 On-shjft Emergency Djrectjon Demonstrate the Shift Manager's ability to immediately and unilaterally initiate any emergency response action, including providing protective action recommendations to authorities responsible for implementing offsite emergency measures.

B.3 Line of Syccessjon Demonstrate the ability to transfer overall command and control of the emergency response. B.4 Non-Pelegable Responsjbi!itjes Demonstrate the performance of authority of the non-delegable responsibilities. B.5 Mjnjmym ERO Staffjng Demonstrate the ability to augment the on-shift response capabilities within a short period of time. B.6 Fyl! ERO Staffjng Aygmentatjon Demonstrate the ability of management, administrative and technical support personnel to augment the plant staff in the areas of logistics support, technical support, government interface, and public information. B.7 ERO Sypportbraanjzatjons. Demonstrate the ability of specified contractor and private support organizations to provide technical assistance.to or augmentthe ERO. B.10 24 Hoyr per day Emeraency Response Capabilitjes Demonstrate planning for 24-hour per day emergency response capabilities. C.2 Commynjty Representatjye Demonstrate the ability to provide a liaison at each participating offsite governmental Emergency Operations Center (EOC). D.1 Classificatjon

Demonstrate the ability to recogniz!=

the initiating conditions for EALs and to properly classify emergencies. E.1 Off-sjte Notificatjon Demonstrate the ability to notify the offsite Emergency Response Organizations (ORO) consistent with the classification scheme including the verification of messages in a timely manner. . Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES (cont) E.2 ERO Notificatjon Demonstrate the ability to alert, notify and mobilize ERO personnel. E.3 lnjtjal Notificatjon Message Content Demonstrate the ability to provide the required content for the initial notification messages accurately within the required time limit. E.4 Eollow*yp Message Content Demonstrate the ability to provide the required content for the follow-up notification messages timely and accurately. F.1 State/Local Commynjcajjons System Demonstrate the ability to operate the communications systems used by the ERO to provide information to the State and local agencies. E.2 Federal Commynjcatjons System Demonstrate the ability to operate the communications systems used by the ERO to provide information to federal agency(s). ," F.3 Emeraency Response pata System lERDSl

Demonstrate the ability to activate EROS as soon as possible but no later than one hour after declaration of an emergency of an Alert or higher emergency classification.

F.4 Utility Commynjcatjons System Demonstrate the ability to operate the communications systems used by the ERO to exchange information with other emergency response facilities. G.1 JIC Sypport of Emeraency Demonstrate the adequacy of the JIC to. support emergency response activities. G.2 Medja Brjefinqs-Demonstrate the ability of the Spokesperson to brief the media in a clear, accurate and timely manner. G.3 Exchange of Public lntormatjon Demonstrate the timely exchange of public information among designated agency spokespersons.

G.4 pyblic lngyjrv <Rymor Control) Demonstrate the ability to establish and operate an effective system for dealing with calls to the public inquiry hotline.
G.5 Release of lntocmatjon Demonstrate the ability to develop and release information to the media/public for a declared emergency.

H.1 !SC Sypport of Emeraency Operatjons Demonstrate the adequacy of the TSC to support emergency response activities. H.2 EOE Sypport of Emergency Operatjons Demonstrate the adequacy of the EOF to support emergency response activities: H.3 OSC Sypport of Emeraency Operatjons Demonstrate the adequacy of the OSC to support emergency response activities. H.4 Tjmely Facility Actjyatjon Demonstrate the ability to activate the emergency response facilities in a timely manner. H.10 Control Room pjrectjon and Control Demonstrate effective direction and control for onsite resources to support assessment and mitigation of the event. Pilgrim Nuclear Power Station *November 16, 201616-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES <cont) H.11 !SC Pirection and Control Demonstrate effective direction and control for facility resources to support assessment and mitigation of the event. H.1ZEOE pjrectjon and Control Demonstrate effective direction and control for facility resources to support facility priorities. H.14 EOE pjsplay Capabjljtjes Demonstrate the capability for obtaining and displaying plant data and radiological information for each reactor at the station and each station supported by the facility. H.15 EOE Technical Capabi!itjes Demonstrate the capability to analyze plart technical information and provide technical briefings on event prognosis to station and off-site response organizations for each reactor at the station and each station supported by the facility. H.17 Meterologjcal Pata 1.1 1.2 1.3 1.5 1.6 1.7 1.8 J.1 J.4 Demonstrate the ability tci obtain current and forecasted meteorological information from primary as well.as backup and alternate sources. Accjdent Recognjtjon and Assessment Demonstrate the ability to provide initial values and continuing assessment throughout the course of an accident as well as the parameter values that correspond to the initiating conditions for EALs and PARs. Core carnage Assessment Demonstrate the ability to determine the extent of core failure based on specific assessment strategies and sampling, Release and Pose Assessment Demonstrate the ability to determine the magnitude of radioactive releases or perform dose assessments based on plant parameters, effluent monitors, field data and meteorological conditions. Health physjcs -In Plant Monjtorjnq Demonstrate response and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment.. Health Physjcs -Enyjronmental Release Monjtorjng Demonstrate response and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment. OM! Support of Emeraency OperatjOns . Demonstrate the adequacy of the OMTs to support emergency response activities. Plyme phase Monjtorjnq Demonstrate the ability to monitor radiological releases to the environment in the field. Warnjng On-Sjte personnel Demonstrate the means to alert individuals at the site and persons who may be in the public access areas within the owner controlled area. Assembly and Accoyntability Demonstrate the ability to perform accountability for all individuals in the Protected Area within 30 minutes -., . , ... -* **------*---- Pilgrim Nuc.lear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES (cont> J.5 Personnel protectjon Equioment Demonstrate the availability and use of respiratory protections and protective clothing for onsite emergency response personnel. J.6 potassjym lodjde tK1l Demonstrate the availability and use* of potassium iodide (Kl) for utility emergency response personnel.

J. 7 Protective Action Recommendations

(.PABl.

Demonstrate the ability to recommend protective actions to appropriate offsite authorities.

K.2 Exposyre Monjtorjnq Demonstrate the ability to control and track emergency 'worker radiation exposure. K.3 personnel Qecontaminitjon Controls Demonstrate the use of action levels for determining the need for decontamination, perform decontamination and provide for waste disposal. K.4 Area Contamjnatjon Controls

Demonstrate contamination control practices.

K.5 Habjtability Controls Demonstrate the capability to minimize ERO internal contamination through ERF habitability controls and controlling the intake of drinking water and food supplies. N.1 Exercjse and prms . Demonstrate the ability to conduct drills and exercises which evaluate *key skills, overall emergency response capabilities and formal critiques identifying weaknesses or deficiencies requiring action. N.2 Plans. procedyres. Facilitjes and .Eqyjpment Personnel, plans, procedures, facilities and equipment are tested and maintained ready to respond to emergencies, from minor events to severe acddents. Page 1-1 Pilgrim Nuclear Power Station November 16 111 2016 NRC/FEMA Evaluated Exercise Scenario Timeline and Messages. /-Updated 9/13/16 08:00 hrs Pilgrim Nuclear Power Station _ November 16 111 2016 NRC/FEMA Evaluated Exercise 1 Narrative Initial Conditions It is November 16th, 2016. At the start of the exercise, the plant is at 100% power and has been on line for 63 days. A nor'easter impacted the site yesterday. Local communities have experienced some beach erosion however all major roads are passible and impact from the storm has been minimal. The site is continuing to experience astronomically high tides from the storm and the full moon. High tide is expected around 1000 hrs. The wind is from the North East at 8-10 mph at 45°. Travelling screens are running fast and being monitored locally. It is a cloudy day with temperatures in the 50's F. The weather forecast predicts the winds to remain relatively constant from the North East at 8-10 mph. Skies are expected to remain cloudy throughout the day. Sequence of Eyents (0805) The Exercise is initiated when Control Rod 26-27 drifts out. The operators are expected to respond to the rod drift per ARP-C905L & PNPS 2.4.11 and return 26-27 to its required position. However the rod will continue to drift out, forcing the operators to insert the rod to 00 and disable it. This rod drift will be the start of some minor (<3%) fuel clad failure (not visible to crew at this time). PNPS procedure 2.4.40, "Rapid Increase in Main Steam Line or Offgas Activity" requires a reactor coolant sample be analyzed for evidence of fuel failure. (0820) Crew recognizes increased sea water level. Crew recognizes sea water bay level has exceeded 13' 6". Shift Manager will declare an UNUSUAL EVENT based on EAL HU1.5:

Sea water bay water level> +13' 6" MSL (Ll-3831A/B)

OR Sea water bay water level < -13' 9" MSL (Ll-3831 A/B) Operations reports that sea water bay level is upscale high and requests field operator to report local sea water level readings. An operator is dispatched per 5.3.8, Att 2 or 3. Main Steam and Off-gas radiation levels are trending upward due to minor fuel cladding failure resulting from the rod drift. Emergency Plant Information Computer (EPIC) alarms are received. (0850) Field operator reports that sea water intake levels are +16'4" and continuing to rise slowly. Crew recognizes rising sea level and Shift Manager declares an ALERT based on EAL HA 1.6

Sea water bay water level > +16' O" MSL OR Sea water bay water level < -16' O" MSL Page 1-2 Updated 9/13/16 08:00 hrs Pilgrim Nuclea.r Power Station November 16th 2016 NRC/FEMA Evaluated Exercise When the Alert is declared, the emergency response organization (ERO) is notified by activation of the Emergency Response Organization Notification system. When sufficient numbers of the ERO arrive at the Technical Support Center (TSC), the Operations Support Center (OSC), the Emergency Operations Facility (EOF), and the Joint Information Genter (JIC), each facility will become operational.

Shortly following the Alert, EOG "A" trouble alarm comes in due to low start air pressure. NLO will be sent to investigate cause. A review of the Annunciator Response Procedure (ARP) indicates the air pressure is below the set point for the valve. The valve Is lifting and is not reseating. After the ALERT and when all facilities are declared operational, the Main Steam Line (MSL) B Flow Indicator, Fl-640-23B, fails downscale resulting in a small transient observed by the Control Room Operators which results in slightly lower reactor vessel level. Feedwater level control is affected and crew may take manual control of feed -regulating valves. Operations should ask for a team to troubleshoot and repair the indicator.* Approximately one hour and fifteen minutes after the ALERT has been declared, a leak develops on the Reactor Water Clean Up (RWCU) at E-208C head, discharging primary coolant i,nto the Reactor Building (-20 gpm) which will not isolate (Supply valves M0-1201-02 and M0-1201-05 will not close). Secondary Containment temperature and radiation levels increase to Max Normal values. Operators enter EOP-04 based on the rising Secondary Containment temperatures. The reactor is scrammed per EOP-04 when max normal values are reached with primary system discharging into secondary containment. Operators should determine that a leak has occurred in the RWCU HX Room and RWCU failed to isolate. Attempts to isolate M0-1201-02 and M0-1201-05 from the simulator control room are unsuccessful. Conditions are met for a SAE based on EAL FS1 .1 "Loss of any two barriers" Criteria C.9 or C.14 and C.18. The Emergency Director in the EOF should make the determination that an unisolable primary system is discharging outside primary containment. This requires an upgrade to SITE AREA EMERGENCY based on EAL FS1 .1 "Loss or Potential Loss of two Fission Product Barriers".

*The two fission product barriers are Loss of RCS (criterion

9) or Potential Loss of RCS (criteria

14) and Loss of Primary Containment Barrier (criterion 18). The transient from the reactor scram causes additional fuel to fail. Fission products have entered into the Reactor Coolant system and also into the Reactor Building via *the RWCU system leak from which they are collected by the Standby Gas Treatment System and flow through the Main Stack for monitoring and discharge.

Main Steam and Off-gas radiation levels are trending upward due to fuel failure from the rod drift ana the scram transient. PNPS procedure 2.4.40, "Rapid Increase in Main Steam Line or Offgas Activity. directs Main Steam Isolation Valve (MSIV) closure upon reaching Main Steam Line Radiation High-High set point. Crew may isolate MSIVs before reaching set point. The MSIV closure will force more fission products to escape via the RWCU leak. Chemistry personnel should be directed to obtain a reactor

coolant sample. Operations would be expected to aggressively pursue cool down and Page 1-3 Updated 9/13/16 08:00 hrs Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise reducing reactor vessel pressure per EOP-04 in order to minimize or stop the leak. The opening of the SRVs to maintain reactor pressure will also raise the activity in containment.
., About one hour after Site Area Emergency, a Torus High Range Monitor exceeds SOR/hr. Staff should recognize this as an indication of failed fuel clad barrier and combined with the SAE conditions, this meets GE criteria.

The Emergency Director in the EOF is expected to upgrade the event to a GENERAL EMERGENCY (GE) based on EAL FG1 .1: Loss of two barriers and loss or potential loss of third barrier.

The three fission product barriers are Loss of Fuel Clad (criteria 2), Loss of RCS (criterion

9) or Potential Loss of RCS (criteria

14) and Loss of Primary* Containment Barrier (criterion 18). At the time of declaring the General Emergency, the ERO will formulate and issue Protective Action Recommendations.(PAR) with the initial General Emergency declaration.

The PAR should include evacuating the 2 mile ring surrounding the plant and 5 miles downwind of the affected sub-areas in the Emergency Planning Zone (EPZ); and sheltering all remaining sub-areas in the EPZ. This should include evacuating sub-areas 1,2,3, 12 and sheltering sub areas 4,5,6,7,8,9and

10. This PAR is based on postulated wind direction from the North East (45 degrees) at 8-10 mph. If chemistry sample was requested following the reactor scram, the reported sample results are 350 uCi/gm 1-131 dose equivalents. (This value meets fission product barrier Loss of Fuel Clad (criteria 3)).

After an additional.

hour (1215 -1230) and repairs have been made, RWCU valve' M0-1201-02 may be closed to stop the release: Termination The exercise will be terminated when sufficient time has elapsed to allow appropriate objectives to be demonstrated or evaluated and concurrence from the Commonwealth: '* Page 1-4 Updated 9/13/1 08:00 hrs Pilgrim Nuclear Power Station 1; November 16th 2016 NRC/FEMA Evaluated Exercise 2 Tjme Line *: Initial Conditions: " ,, i I* ' ,. !: i .,, I' Event # 1. 2. 3. 4. 5. 6. 7.

100% Power
EOOS Risk XXXX Integrated Risk XXXX Events: Elapsed Est Actual Event Details/Expected Actions Time* Time* Time* Hr:min -00:30 0730 All Controllers in position at their Emergency Response Facility (ERF) -00:30 0730 Initial conditions Established.

Simulator operating crew is briefed on the initial conditions. Controllers to provide this {Message All-001} information to the lead facility players when they arrive. -00:15 0745 Lead Controller Conference line check Conference line check with lead controllers. Phone: 508-830-7701 pass code 999999 -00:05 0755 Control Room Exercise Announcement Control Room (CR) annour:icer makes. {Message CR-002} announcement over the plant Public Address l(PA) svstem. -00:05 0755 ESB Exercise Announcement Security Personnel or designated controller {Message SEC-003} makes announcement over the Engineering Support Building Public Address (PA) system. 00:00 0800 Drill/Exercise Commences Controllers and Simulator operating crew players are in position. Scenario begins. 00:02 0802 "A" Travelling Screen Hi D/P intermittent Alarms Operations is monitoring travelling screens at {Task-001 Operator} start of exercise. Page 2-1 **All times are *approximate** Expected Procedures ' Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected # Time* Time* Time* Procedures Hr:min 8. 00:05 0805 Control Rod 26-27 drifts out. Crew will enter ARP-C905LA3 & 2.4.11 & reduce ARP-(This event provides justification for initial > power to -75% (43Mlbs/hr) C905L, indications of fuel damage.) . 2.4.11, Crew calls Rx Engineer to control room. . 2.2.87.2 {Task-002 Operator} SM may contact WWM to investigate 26-27 {Message-004 -WWM} drifting. {Message -005 -Rx Engineering}

9. 00:20 0820 Operator reports that the sea water bay level has Crew recognizes rising sea level and makes the EP-IP-exceeded 13' 6". This will require declaration of an appropriate classifications HU1 .5. Expect 100 DEP Unusual Event per EAL HU1 .5 Operator dispatched to confirm and monitor Pl {Task 003 Operator}

water level and travelling screens. UNUSUAL EVENT DECLARED 10. 00:25 0825 UE Announcement CR announcer announces UE over plant PA EP-IP-system. ERO is notified via the E-Plan 100 Att {Message CR-006} system. 9.2 SM may elect to activate any of the Emergency Response Facilities (ERFs) at this time. Announcement from Simulator will provide info. 11. 00:25 0825 Engineering Support Bldg (ESB) UE Announcement Security Personnel announces UE over plant {Message SEC-007} .. ESB PA svstem. 12. 0835 -0835-Unusual Event EAL HU1 .5 Off-site notification State and local off-site notifications will be 0850 initiated and transmitted. SIMULA TOR CONTROLLER LOG TIME DEP NOTIFICATION TRANSMITTED Pl ... Page 2-2 **All times are approximate** ' ,. 1' i I ,. " I ,. Event # 13. 14. 15. 16. 17. 18. Elapsed Time* Hr:min 00:40 0050 0100 0102 0105-0120 Page 2-3 Est Actual Time* Time* 0840 At least 20 minutes after indication s -0850 DEP Pl 0900 0902 -0905-0920 DEP Pl Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Details/Expected Actions Expected Procedures If requested, Chemistry to obtain coolant sample. Main Steam and Off-gas radiation levels are 2.4.40 {Task 004} trending upward due to fuel failure occurring from 7.4.64 Att the rod drift. First MSL Rad Alarm on EPIC. 29 All Rad readinQs will be Normal. Contingency UE message. Controllers will issue this message only if the UE {Message SIM-OOSX} has not been declared by this time and have approval from Lead Drill Coordinator. Alert per EAL HA 1.6 Crew recognizes rising sea level and Operator at sea water bay reports back reading. SM should EP-IP-. Field reports that sea water intake levels are +16'4" declare upgrade to Alert per EAL HA1.6 -Sea 100 and continuing to rise slowly. (Visual measurement) water bay water level > +16' O" MSL (LI-5.3.8 {see Task-003 -. Ops} 3831A/B) ---Operator may be sent to screen house with portable device to perform 5.3.8 Attachment 3 Alert Announcement CR announcer announces Alert over plant PA (Message CR-009} system. ERO is notified via the ERO notification system. Engineering Support Bldg (ESB) Alert Security Personnel announces ALERT over plant Announcement ESB PA system. (Message SEC-010} Alert EAL HA1.6 Off-site notification State and local off-site notifications will be initiated and transmitted for upgrade to Alert. -**All times are approximate** I , Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected # Time* Time* Time* Procedures Hr: min 19. At least Contingency Alert message. Controllers will issue this rnessage only if the 20 Alert has not been declared by this time and minutes {Message SIM-011 X} have approval from Lead Drill Coordinator.. after indication s 20. 01:00 0900 Main Steam Line (MSL} "B Flow indicator fails Crew may request l&C Techs to investigate. Fl-downscale due to transmitter failure. 640-238. {Task 004 -l&C Techs} 21. 0105 0905 Emergency Response Organization (ERO) The ERO should be mobilizing and activating EP-IP-Mobilization Emergency Response Facilities. 100 (unless activated at Unusual Event) '. 22. 0140 0940 Chemistry reports results from coolant sample if _ Chemistry Technician reports results from taken. sample {Task 005 -Chem Techs} Isotope micro curies/cc 1-131 3.65E-0.3 1-132 3.69E-03 1-133 2.35E-03 1-134 O.OOE+OO 1-135 9.30E-04 .. Dose Equivalent (DE) iodine 4.09E-03 23. 0132 0942 EOG "A" trouble alarms comes in due to low system Operator to investigate. air pressure.' (Upon investigation will hear air blowing, relief ' {Task-006 -Ops/Mech} valve liftina and not reseatina) . 24. 0145 0945-TSC/OSC and EOF operational (approximately 60 TSC, OSC and EOF should be made EP-IP-1005 minutes maximum after ERO activation operational. On-call EOF Emergency Director 100 announcement) should take over command and control from the Shift Manager (SM) . . Page 2-4 **All times are approximate** I I_ j* '\ I ,, i. " ,i I ,, " " i* " I' .,. Event # 25. Elapsed Est Time* Time* Hr:min 0150 0950 Page 2-5 Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Actual Event Details/Expected Actions Expected Time* Procedures OSC!TSC assign team to replace relief valve on After Operator reports that relief valve is lifting EDG"A" and notreseating, -osc Team to replace valve. {Task 007 -Mechanical}

- All times are approximate**

Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected # Time* Time* Time* Procedures Hr:min 26. 0215 -1015 A steam leak develops on the RWCU line (-20 Operators enter EOP-04 based on the rising EOP-04 gpm) and will not isolate (Supply valves M01201-02 Secondary Containment Temperatures and and M0-1201-05 will not close). Secondary Radiation levels in the RWCU area, The reactor Containment Temperature and radiation INCREASE is scrammed per EOP-04 when max normal TO Max Normal values. vah.,ies are reached with a primary system Conditions are met for a SAE based on: discharging into secondary containment. EAL FS1 .1 "Loss of two barriers" Criteria 9 or 14 & 18. Crew will request an operator to go to the RWCU to investigate for steam leak. Operators should RAD readings: Continuous Air Monitors outside of determine that a steam leak has occurred in the RWCU Hx start to alarm at 4 DAC. RWCU HX Room and RWCU fails to isolate. ,.) The RWCU supply isolations will not close. Contamination levels from steam coming out is 12K Attempts from the simulator control room are dpm/100 cm2; Rad Levels in outer hallway 50 unsuccessful mrem/hr'. If personnel get near RWCU Hx Room door then General area around MOV-5 is 1500 mrem/hr with they will_ be contaminated and will not pass the high contamination 150K dpm/100cm2. 6 DAC in exit monitors unless they are wearing proper room. PC's. If contaminated, they will follow decontamination process. Operator sent out to determine steam leak per EOP-4. Initial attempts to close these valves from their breakers will also be unsuccessful. (480 V MCC ;;,. {Task-:-008 Ops } B-20 & 125 voe D-7) {Task -009 Electrical} {Task -010 Mechanical} The following alarms/indications are received: RWCU Temp Alarm comes in. A radioactive steam leak is occurring in the Reactor Building. (Area Temperature, Fire Alarm and Area Radiation Monitor on Rx Bldg Elevation .. 51' are alarming). Operators should enter EOP-04 (Secondary ... Containment Control) . I -::::i--**All are approximate** il I' *' ' ,, ,, 1: *' Event # 27. 28. 29. 30. 31. 32. Elapsed Est Actual Time* Time* Time* Hr: min 0215 1015-1030 DEP Pl 0220 1020 0220 1020 0225 1025 0228 1028 0230 1030 Page 2-1 Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Details/Expected Actions Expected Procedures Site Area Emergency (SAE) Declared per The Emergency Director in the EOF is expected EP-IP-EAL FS1.1 ' to upgrade the event to a SITE AREA 100 EMERGENCY (SAE) per EAL FS1 .1 Loss or potential loss of any two barriers: Criteria 9 or 14 and 18 Time starts when crew recognizes they cannot isolate the leak. Main Steam and Off-gas Rad Monitors alarm. Main Steam and Off-gas radiation levels are , ARP-trending upward due to fuel failure from the rod C904LC drift and SCRAM. PNPS procedure 2.4.40, A6 & 86, "Rapid Increase.in Main Steam Line or Offgas 2.4.40 Activity" directs Main Steam Isolation Valve (MSIV) closure upon reaching High-High set point. Crew may isolate MS IVs *before reaching set point. Reactor Scram Scram transient causes more fuel damage Reactor Scram CR announces SCRAM over plant PA system. {Message CR-012} Reactor Scram Security Personnel or designated controller {Message ESB-013} announces SCRAM over plant PA system_. SAE Announcement CR announcer announces SAE over plant PA {Message CR-014} system. State and local off-site notifications will be initiated and transmitted of upgrade to SAE. **All times are approximate** Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected # Time* Time* Time* Procedures Hr:min 33. 0233 1033 Engineering Support Bldg (ESB) SAE Security announces SAE over plant ESB PA Announcement system. * {Message SEC-015} ; 34. 0230 10:30 Post Scram actions tp be performed by: Rad conditions: Scram Surveys are taken. 2.1.6 Piping in overtiead of scram header is now 7.4.64 {Task -011 RP} reading 250 mrem/hr 6.1-220 contamination level: west bank of HCUs 90K dpm/100cm2 {Task -012 Ops} Operators sent to close CRD 25 valve and remove condensate demineralizers from service. {Task -013 Chemistry} Chemistry to obtain sample. RP's will perform Post Scram surveys per PNPS 6.1-220; "Radiological Controls for High Risk Evolutions" 35. 0230 -1030-SAE EAL FS1 .1 Off-site Notification State and local off-site notifications will be 1045 ** initiated and transmitted of upgrade to Site Area DEP Emergency. Pl 36. At least 20 Contingency SAE message. Controllers will issue this message only if the minutes SAE has not been declared by this time and after {Message EOF-01 SX} have approval from Lead Drill Coordinator. indications ' 37. 0240 1040 JIC activated JIC should be activated -may be sooner but have 2 hr response Page 2-8 **All times are approximate** I' 1* I ., '* Event # 38. Elapsed Est Actual Time* Time* Time* Hr:min 0330 -1130 Page 2-9 Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Details/Expected Actions Expected Procedures

Torus High Range Monitor exceeds 50R/hr Staff should recognize the Torus High Range EP-IP-Conditions are met for a GE based on: Monitor exceeds 50R/hr as an indication of failed 100 Att fuel clad barrier and combined with the SAE 9.5 EAL FG1 .1 "Loss of two barriers and loss or conditions, this meets GE criteria.

EP-IP-potential loss of third barrier". Criteria: 2, 9 or 14 Radiation level: 20-50 mrem/hr General area in 400 and 18. 23' RB Crew requests starting all available turbine roof exhaust fans.(Control Room High Efficiency Air Filtration System -CRHEAFS) The Emergency Director in the EOF is expected 'to* upgrade to a GENERAL EMERGENCY (GE) per EAL FG1.1 Loss of two barriers and loss or potential loss of third barrier Criteria: 2, 9 or 14 and 18. **All times are approximate** Pilgrim Nu.clear Power Station November 16 111 2016 NRC/FEMA Evaluated Exer.cise Event Elapsed Est Actual Event Details/Expected Actions Expected # Time** Time* Time* Procedures Hr: min 39. 0330 -1130 General Emergency (GE) Declared* Upon confirmation of the status of the Fuel Clad EP-IP-EAL FG1.1 Barrier, RCS Barrier and Primary Containment 100 Att DEP Barrier, the EOF Emergency Director should 9.5 Pl Loss of any two Fission Product Barriers and Loss peclare a General Emergency per EAL FG1 .1. EP-IP-or Potential Loss of the Third Barrier (Table F-1 ) .. 400 This should include declaring the loss of the EOF CONTROLLER LOG TIME GE DECLARED Fission Product Barriers based on the following

and PAR determination time. EAL conditions contained in EP-IP-100.1 Table F-1.
Fuel Clad Barrjer Loss of Fuel Clad 2-Torus High Range Rad Monitor >50R/hr RCS Barrjer Loss of the RCS Barrier 9 -Release pathway exists outside Primary Containment resulting from is<;>lation failure in any of the following (excluding normal process system flow paths from an unisolable system): -Main steam line -HPCI steam line -RCIC steam line -RWCU -Feedwate.r QB Page 2-10 **All times are approximate**

. I Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected # Time* Time* Time* Procedures Hr: min (Potential Loss) 14-Unisolable primary system discharge outside primary containment AND A valid entry condition into EOP-04 exists due to

Secondary Containment area radiation or temperature above any* Maximum Normal Operating Value. (EOP-04 Table H) Atll2 Prjmarv Contajnment tPCl Barrjer: Loss of PC 18 -Failure*of any valve in any one line to close AND Direct downstream pathway to the
environment exists after PC isolation signal. At the time of declaring the General Emergency, the EOF Director will formulate and . issue Protective Action Recommendations (PARs) with the initial Genl:lral Emergency declaration to the State EOF representatives.

!' 40. 0336 1130 GE Announcement CR announces GE over plant PA system. -{Message CR-017} -41. 0338 1132 Engineering Support Bldg (ESB) GE Announcement Security GE over plant ESB PA system. {Message SEC-018} i: I !" 42. 0340 -1145 GE EAL FG1.1 NOTIFICATION State and local off-site notifications will be DEP initiated and transmitted of upgrade to GE. Pl :, -Page 2-11 **All times are approximate** II Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected # Time* Time* Time* Procedures Hr: min 43. 0340 -1130-PAR Offsite Notification The PAR should include evacuating the 2 mile 1145 ring surrounding the plant and 5 miles downwind DEP of the affected .sub-areas in the Emergency Planning Zone (EPZ); and sheltering all Pl remaining sub-areas in the EPZ. This should include evacuating 1,2,3 and 12 and; sheltering sub areas 4,5,6,7,8,9 and 10, This PAR is based on postulated wind from the East (45 degrees) at 8-10 MPH. 44. At least 20 Contingency GE message. Controllers will issue this message only if a GE .minutes has not been declared by this time and have after {Message EOF-019X}

approval from Lead Drill Coordinator.

indications

45. '0420 -1220 If taken and when completed (simulated), If sample is taken post scram, Chemistry reports coolant sample results of 350 RP tech is to take a dose rate of sample 600 uCi/gm 1-131 dose equivalent.

mr/hr on the sample .. Isotope micro curies/cc 1-131 2.51E+02 1-132 3.54E+02 ' 1-133 5.02E+02 1-134 5.61E+02 1-135 4.43E+02 DE iodine 350 This meets Criteria 3 loss of fuel clad. 46. 0415 -1215-OSC team is successful in closing M0-1201-02. OSC team is successful in isolating the leak. 1230 Page 2-12 **All times are approximate** ., : :. i ' I ,I ' I; Event # 49 Elapsed Est Time* Time* Hr:min 0500 -1300 Page 2-13 Pilgrim Nuclear Power Station November 16 111 2016 NRC/FEMA Evaluated Exercise Actual Event Details/Expected Actions Expected Time* Procedures Exercise Termination ll'tbmannounced by Lead The exercise will be terminated when sufficient Drill Coordinator. time has elapsed to allow appropriate objectives to be demonstrated or evaluated on site and off {Message CR-020, SEC-021, EOF-022 and All-023} site. ' Validate Commonwealth has met extent of play criteria for their portion of the exercise requiring Pilgrim support (and FEMA evaluators concur). Exercise termination will not be announced until objective demonstration has been confirmed_ as needed per the Lead Drill Coordinator.

- All times are approximate**

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ML17053A456: Difference between revisions

Revision as of 06:10, 9 October 2018

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Dear Sir/Madam:

1.2 Exercise

1.3 Participating

3.1 Exercise

3.3.1 Commonwealth

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ML17053A456: Difference between revisions

Revision as of 06:10, 9 October 2018

Text

Dear Sir/Madam:

1.2 Exercise

1.3 Participating

3.1 Exercise

3.3.1 Commonwealth

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