ML16053A238

FEMA, Limerick, Units 1 and 2 - Submittal of After Action Report/Improvement Plan, Exercise Date - November 17, 2015, Radiological Emergency Preparedness (REP) Program

ML16053A238
Person / Time
Site:	Limerick
Issue date:	02/12/2016
From:	Tierney M A US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML16053A238 (184)

Text

U.S. Department of Homeland Security One Independence Mall. Sixth Floor 615 Chestnut Street tAT Philadelphia, PA 19106-4404 FE MA FEB 1 2 2016 Nuclear Regulatory Commission Headquarters Office of Nuclear Security and Incident Response Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-000 1 To Whom It May Concern: Enclosed is the final After Action Report/Improvement Plan for the Limerick Generating Station Radiological Emergency Preparedness Plume Exercise that was held on November 1 7t, 2015.This report also includes the Mass Care Walk Downs on October 29th and 30h and Out of Sequence Exercise on November 1 7t and 18%h 2015.There were no Level 1 Findings or Plan Issues identified during the exercise.

There was one Level 2 Finding identified that was successfully re-demonstrated during the exercise.Based on the results of the exercise and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards of NUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.If you have any questions, please contact Thomas Scardino at (215) 931-5546.Sincerely MaryAnn Tierney Regional Administrator Enclosure Limerick Generating Station After Action Report!Improvement Plan Exercise Date -November 17, 2015 Radiological Emergency Preparedness (REP) Program~ E APublished February 1, 2016 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station This page is intentionally blank.2 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station*Limerick Generating Station After Action Report/Improvement Plan Published EXECUTIVE

SUMMARY

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5 SECTION 1: EXERCISE OVERVIEW .............................................................

6 1.1 Exercise Details...................................................................................

6 1.2 Exercise Planning Team Leadership

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6 1.3 Participating Organizations

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7 SECTION 2: EXERCISE DESIGN SUMMlVARY

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15 2.1 Exercise Purpose and Design .................................................................

15 2.2 Exercise Objectives, Capabilities and Activities............................................

18 2.3 Scenario Summary .............................................................................

18 SECTION 3: ANALYSIS OF CAPABILITIES

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20 3.1 Exercise Evaluation and Results..............................................................

20 3.2 Summary Results of Exercise Evaluation...................................................

20 3.3 Criteria Evaluation Summaries

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31 3.3.1 State Jurisdictions

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31 3.3.2 Risk Jurisdictions

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33 3.3.3 Support Jurisdictions........................................................................

61 3.3.4 Private Jurisdictions..........................................................................

71 SECTION 4: CONCLUSION.........................................................................

72 APPENDIX A: BEST PRACTICES

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73 APPENDIX B: EXEgRCISE TIMELINE ...........................................................

75 APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS........................

79 APPENDIX D: ACRONYMS AND ABBREVIATIONS.........................................

87 APPENDIX E: EXERCISE PLAN .................

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90 3 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station This page is intentionally blank.4 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station EXECUTIVE

SUMMARY

On November 17, 2015, a full-scale Plume Exercise was evaluated in the 10-mile plume exposure pathway, Emergency Planning Zone (EPZ) around the Limerick Generating Station (LGS) by the Federal Emergency Management Agency (FEMA) Region III. Out-of-sequence Mass Care Walkdowns were conducted the 29th and 3 0 th of October, 2015. The purpose of the exercise and the out-of-sequence demonstrations was to assess the State and local offsite response organization's 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 November 18, 2013.FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania; the risk jurisdictions of Berks, Chester, and Montgomery Counties; the support jurisdictions of Bucks and Lehigh Counties; and 16 participating municipalities who were evaluated during this exercise.Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility as volunteers providing vital emergency services twenty four (24) hours to the communities of which they live. Cooperation and teamwork of all the participants was observed during this exercise.This report contains the final evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities:

• Mass Care Walkdowns were conducted on October 29th and 30th 2015* Emergency Workers, Equipment and Vehicles -Monitoring and Decontamination were conducted November 18, 2015.* School Interviews were conducted on November 17, 2015.* Traffic/Access Control interviews with the Pennsylvania State Police Skippack Barracks 2047C, Bridge Road, Schwenksville in Montgomery County were conducted November 18, 2015.The Commonwealth of Pennsylvania and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Level 1 Findings or Plan Issues identified during the exercise.

There was one Level 2 Performance Issue identified which was successfully re-demonstrated during the exercise.5 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Limerick Generating Station Plume Exercise Type of Exercise Plume Exercise Date November 17, 2015 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Tina Lai Thomas Emergency Management Specialist Federal Emergency Management Agency 615 Chestnut Street Sixth Floor One Independence Mall Philadelphia, PA, 19106 (215) 931-5680 tina.thomas(~fema.dhs .gov Jeffery Dean Emergency Preparedness Coordinator Exelon Corporation 298 Longview Road Royersford, PA, 19468 (610) 718-2022 ieffrey.dean~iexeloncorp.com 6

Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Sandra Silva Emergency Management Specialist Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, PA, 17110 (717) 651-2235 sansilva(~ipa.gov

1.3 Participating

Organizations Agencies and organizations of the following jurisdictions participated in the Limerick Generating Station Exercise: Commonwealth of Pennsylvania State BOC* American Red Cross* Auxiliary Communication Services (ACS)* Bureau of Radiation Protection

• Department of Military and Veteran Affairs* Nuclear Regulatory Commission

• Pennsylvania Department Office of Administration

• Pennsylvania Department of Aging* Pennsylvania Department of Agriculture

• Pennsylvania Department of Conservation and Natural Resources* Pennsylvania Department of Corrections

• Pennsylvania Department of Education* Pennsylvania Department of Fish and Boat Commission

• Pennsylvania Department of General Services* Pennsylvania Department of Health* Pennsylvania Department of Transportation

• Pennsylvania Department of Human Services* Pennsylvania Emergency Management Agency* Pennsylvania Department of Labor and Industry-Pennsylvania Liquor Control Board* Pennsylvania Game Commission

• Pennsylvania State Police* Pennsylvania Turnpike Commission

• Pennsylvania Utility Commission

• U.S. Department of Agriculture 7

Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station PA Joint Information Center/Exelon Joint Information Center* Bureau of Radiation Protection

• Exelon Corporation

• Nuclear Regulatory Commission

• Pennsylvania Emergency Management Agency Accident Assessment Center* Bureau of Radiation Protection

• Pennsylvania Department of Environmental Protection Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Vehicle* Bureau of Radiation Protection and Emergency Response Team* Department of Environmental Protection

• State of Pennsylvania State Field Monitoring Team A* Department of Emergency Response, Norristown Regional Office* Pennsylvania Bureau of Radiation Protection, Harrisburg Office* Pennsylvania Bureau of Radiation Protection, Norristown Office* Pennsylvania Department of Environmental Protection State Field Monitoring Team B* Bureau of Radiation Protection

• Department of Environmental Protection Emergency Management Berks County Berks County EOC* American Red Cross* Berks County Agricultural Extension Office* Berks County Civil Air Patrol* Berks County Department of Emergency Services* Berks County Planning Commission

• Berks County Public Works Department

• Berks County Sheriffs Office* Pennsylvania Department of Transportation

• Pennsylvania Emergency Management Agency* Pennsylvania State Police* Radio Amateur Civil Emergency Service (RACES)8 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Douglass Township EOC Douglass Township Traffic & Access Control Washington Township BOG* Bally Community Ambulance* Berks County RACES* Eastern Berks Fire Department

• Washington Township Board of Supervisors

• Washington Township Roadmaster

• Washington Township Public Works* Washington Township Transportation Commission

• Washington Township Back-up Route Alerting* Bally Borough/Washington Township/Bechtelsville Borough emergency Management Agency Berks County Schools* Pennsylvania Emergency Management Agency* Berks County Department of Emergency Services* Boyertown Area School District* Boyertown Elementary School* Boyertown Junior High School West* Daniel Boone Area School District* Daniel Boone High School* Monocacy Elementary Center Berks County Mass Care Walkdowns* Conrad Weiser High School* Conrad Weiser Middle School* Twin Valley High School* Twin Valley Middle School* Wilson Middle School South* Muhlenberg Middle School Chester County* Chester County EOC* Pennsylvania Emergency Management Agency* Chester county Department of Emergency services (DES)* Chester County Department of Transportation

• Chester County Department of Environmental Protection

• Chester County Department of Public Health.* Chester County Medical Services* Chester County Department of Public Safety* Chester County Sheriff's Office* Chester County Department of Agriculture 9

Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station*Pennsylvania State Police Chester County 911 Call Center (Communications)

American Red Cross ARES/RACES Chester County School Districts Chester County Evacuation Support Officer (EFS #6)Chester County Fire and Emergency Medical Services Chester County Public Information Officer Chester County Housing and Human services Chester County Oil and Hazardous Material Response (ESF #10)East Vincent Township EGG* East Vincent Township Department of Public Works* East Vincent Township Emergency Management

• East Vincent Police Department

• East Vincent Public Safety and Security* East Vincent Township Fire Services* East Vincent Township Public Health and Medical Services* East Vincent Township Transportation Services* Radio Amateur Civil Emergency Service (RACES)South Coventry Township EGG* Exelon* South Coventry Township Emergency Management

• South Coventry Township Back-Up Route Alerting* CCAIR/Radio Amateur Civil Emergency Service (RACES)* Ridge Fire Company West Pikeland Township EGG* West Pikeland Township Police* West Pikeland Township Emergency Management

• West Pikeland Township Public Works* Cumberland County Department of Emergency Services* RACES Chester County Schools* Pennsylvania Emergency Management Agency* Chester County Department of Emergency Services* Downingtown Area School District* Shamona Creek Elementary

• Downingtown High School West* Great Valley Area School District* KD Markley Elementary School* Owen J. Roberts School District* Owen J. Roberts High School 10 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* Chester County Department of Emergency Services* Owen J. Roberts High School* Owen J. Roberts High School Safety and Security* East Coventry Elementary School* Phoenixville Area School District* Phoenixville High School* Kindergarten Center Chester County Mass Care Walkdowns* Avon Grove High School* Charles Patton Middle School* Fred Engle Middle School* Kennett High School* Mary Lang Elementary

• Unionville High School Montgomery County Montgomery County EOC* American Red Cross Southeast Pennsylvania Chapter* Montgomery County Animal Response Team* Montgomery County Critical Incident Stress Management Team* Montgomery County 911 Emergency Communications Center* Montgomery County Department of Public Safety Lower Providence Township EOC* Lower Providence Administration

• ,Lower Providence Emergency Management Agency* Lower Providence Emergency Medical Services* Lower Providence Fire Department

• Lower Providence Police Department

• Lower Providence Public Works* Radio Amateur Civil Emergency Service (RACES)Lower Salford Township EOC* Lower Salford Township Back-Up Route Alerting* Pottstown Borough EOC Upper Frederick Township EOC* Upper Frederick Township Board of Supervisors

• Upper Frederick Township Department of Public Works* Upper Frederick Township Emergency Management Organization

• Upper Frederick Township Town Constable* Upper Frederick Township Town Manager* Upper Frederick Township Volunteer Fire Department 11 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImiprovement Plan Limerick Generating Station Upper Pottsgrove Township BOG* Upper Pottsgrove Township Police Department

• Upper Pottsgrove Township Public Works* Upper Pottsgrove Township Volunteer Fire Company 79* Radio Amateur Civil Emergency Service (RACES)/Amateur Radio Emergency Services (ARES)Montgomery County Schools* Pennsylvania Emergency Management Agency* Montgomery County Department of Emergency Services* Methacton Area School District* Arcola Intermediate School* Skyview Elementary School* Perkiomen Valley School District* Perkiomen Valley High School* Schwenksville Elementary School* Pottsgrove School District* Lower Pottsgrove Elementary School* Pottstown Area School District* Franklin Elementary School* Pottstown Middle School* Souderton Area School District* Indian Valley Middle School* Spring Ford Area School District* Evans Elementary School* Limerick Elementary School* Royersford Elementary School* 9 th Grade Center* Upper Perkiomen School District Montgomery County Mass Care Walkdowns* Abington Junior High School* Abington Senior High School* Cheltenham High School Bucks County Bucks County EOC Bucks County Mass Care Walkdowns* Council Rock Newtown Middle School* Council Rock South High School* Edgewood Elementary

• Eleanor Roosevelt Elementary

• Franklin Roosevelt School 12 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* Holland Middle School* Lenape Middle School* Makefield Elementary

• Milford Township Fire Company* Milford Middle School* Morrisville Middle/Senior High School* Poquessing Middle School* Quakertown Community High School* Richboro Middle School* Springfield Elementary Lehigh County Lehigh County EOC* Lehigh County Emergency Management Agency* Lehigh County Health Network Office of Emergency Management

• Pennsylvania Department of Transportation

• American Red Cross* Emmaus Emergency Management Agency* Washington Township Emergency Management Agency* Weisenberg Emergency Management Agency* North Whitehall Emergency Management Agency Lehigh County Mass Care Walkdowns* DeSales University

• Eyer Junior High School* Orefield Middle School* South Mountain Middle School* Springhouse Junior High School State Traffic/Access Control Points* Pennsylvania State Police* Troop K, Skippack Barracks Reception Centers/Mass Care/Mon/Decon Berks County Mass Care/MoniDecon-Fleetwood High School* Fleetwood Volunteer Fire Company* Eastern Pennsylvania Region American Red Cross Mass Care-Wyomissing High, School* American Red Cross* Berks County Emergency Management Agency* Berks County Radio Amateur Civil Emergency Service (RACES)13 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station Mon/Decon-Wyomissing High School* Wyomissing Fire Department and Township of Spring Fire Rescue* Berks County Emergency Management Agency Reception Center-Morgantown Crossings* Berks County Department ofEmergency Services* Caernarvon Township Emergency Management Agency* Caernarvon Township Police* Twin Valley Fire Department Bucks County Reception/Mon/Decon-County Line Plaza* Souderton Fire Company* Bucks County Emergency Management Agency Chester County Reception/Mon/Decon-Downingtown High School West* Chester County HazMat Team Lehigh County Reception/Mass Care/Mon/Decon-Emmaus High School* American Red Cross* Emmaus Fire Department

• Emmaus Police Department

• Emmaus Emergency Management Agency* Lehigh County Emergency Management Agency Emergency Worker Monitoring and Decontamination station Chester County Lionville Middle School* Chester County HazMat Team Montgomery County Upper Perkiomen High School* Montgomery County Office of Emergency Management

• Pennsburg Fire Station Staff 14 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Gencrating Station SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise

Purpose and Design On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume the lead responsibility for all off-site nuclear planning and response.FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.44 CFR 350 establishes the policies and procedures for FEMA's initial and continued approval of State and local governments' radiological emergency planning and preparedness for commercial nuclear power plants. This approval is contingent, in part, on State and local government participation in joint exercises with licensees.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

A. Taking the lead in offsite emergency planning and in the review and evaluation of Radiological Emergency Response Plans (RERPs) and procedures developed by State and local governments; B. Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; C. Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993, Federal Register, Vol. 58, No. 176, September 14, 1993; and D. Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process:-U.S. Department of Commerce,-U.S. Nuclear Regulatory Commission,-U.S. Environmental Protection Agency,-U.S. Department of Energy,-U.S. Department of Health and Human Services,-U.S. Department of Transportation,-U.S. Department of Agriculture,-U.S. Department of the Interior, and-U.S. Food and Drug Administration.

15 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Gencrating Station Representatives of these agencies serve on the Region III Radiological Assistance Committee (RAC), which is chaired by FEMA.A Radiological Emergency Preparedness (REP) exercise was conducted on November 17, 2015, to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Limerick Generating Station (LGS). The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the FEMA Region III RAG Chairperson and approved by FEMA Headquarters.

These reports are provided to the NRC and participating States. State and local governments utilize the findings contained in these reports for the purposes ofplanning, training, and improving emergency response capabilities.

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

• NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980;* Radiological Emergency Preparedness Program Manual, July 2015 Section 1 of this report, entitled 'Exercise Overview", presents the "Exercise Planning Team" and the "Participating Organizations" Section 2 of this report, entitled "Exercise Design Summary", and includes the "Purpose and Design", "Exercise Objectives, Capabilities, and Activities", and the "Scenario Summary".Section 3 of this report, entitled "Analysis of Capabilities", presents detailed "Drill Evaluation and Results" information on the demonstration for each jurisdiction or functional entity evaluated in a jurisdiction-based, issue-only format (Criteria Evaluation Summaries).

Section 4, of this report, entitled "Conclusion", is a description ofthe Region's overall assessment of the capabilities of the participating organizations.

It also presents information on planning issues if any were identified.

Emergency Planning Zone

Description:

Limerick Generating Station (LGS) is located in southeastern Pennsylvania on the Schuylkill River about 1.7 miles southeast of Pottstown Borough. The river passes through the site, separating the western portion, which is in East Coventry Township in Chester County, from the eastern portion, which is in Limerick and Lower Pottsgrove Townships in Montgomery County.16 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportllmprovement Plan Limerick Generating Station The plant is owned and operated by Exelon Nuclear. Two boiling water reactors each generate an electrical output of 1,050 megawatts (MW). Unit 1 was issued a full-power license in August 1985; commercial operations began in February 1986. Unit 2 was issued a full-power license in August 1989 with commercial operations beginning in January 1990.The site encompasses 595 acres and is divided into three (3) parts. The principal portion, where the major operating equipment and buildings are located, is on the east bank of the Schuylkill River. This portion is separated from the second segment, where the cooling water intake is located, near the main line of the Reading Railroad.

The third portion lies on the west bank of the river, adjacent to Conrail railroad tracks. The site coordinates are approximately 4Q0°13 '27"N and 75O35, 1 5"W.The minimum exclusion distance for the LGS is 2,500 feet from the center of each reactor. The utility owns all the land within the exclusion area. No private residences are located within the exclusion area; however, some farming may be permitted.

There are 165 sirens installed to cover the 10-mile plume exposure pathway EPZ. These sirens are activated three (3) minutes before the Emergency Alert System (EAS) messages issued by the Commonwealth of Pennsylvania are broadcast.

Soils in this area are of the Reaville-Penn-Klinesville Association and are characteristic of rolling uplands. They are underlain by sedimentary rocks of the Brunswick Formation, consisting mostly of red shale with some fine-grained sandstone interbedding.

The normal pool elevation of the Schuylkill River in this area is 200 feet above mean sea level (msl). The topography of the area is hilly, with elevations ranging from 100-300 feet above msl within five (5) miles of the site. The plant is approximately 217 feet above msl.The climate in this area is dominated by prevailing westerly winds that produce humid, continental-type weather characterized by warm summers and moderately cold winters.Montgomery County is the warmest part of Pennsylvania, with an average annual temperature of 57°F. Annual precipitation is approximately 42 inches. The area in the immediate vicinity of the plant is made up mostly of agricultural and other open land. The Pottstown Borough in Montgomery County is the nearest community.

The nearest major population center (more than 25,000 people) is Philadelphia that lies 25 miles to the southeast of the site.Two major industries employ a total of 850 persons within two (2) miles of the plant. Two small airfields are also located nearby. A small private airfield is about one (1) mile to the northeast, but its runway is oriented so that the flight path does not pass over the plant. The Pottstown Municipal Airport is 4.3 miles northwest of the site. The LGS does not lie in the approach pattern for this airport. No major thoroughfares are located in the immediate vicinity of the plant. The main line of the Reading Railroad runs along the north bank of the Schuylkill River and traverses the site about 500 feet from the plant.17 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lInprovement Plan Limerick Generating Station 2.2 Exercise Objectives, Capabilities and Activities The objective of the 2015 Limerick Generating Stations (LGS) Plume Exercise was to demonstrate the capabilities of State and local emergency management agencies to mobilize emergency management and emergency response personnel, to activate emergency operations centers and support facilities, and to protect the health, lives, and property of the citizens residing within the 10 mile Emergency Planning Zone (EPZ).To demonstrate the ability to communicate between multiple levels of government and provide timely, accurate, and sufficiently detailed information to the public, the emergency management agencies use a variety of resources, including radios, telephones, the Internet, the media, the Emergency Alert System (EAS), and the utility Alert and Notification System (ANS) Sirens. All of these communication resources were employed and evaluated.

The EAS and ANS were simulated and media information was prepared but not actually released.An essential capability of the Radiological Emergency Preparedness Program (REPP) is to evacuate, monitor and decontaminate, if necessary, and provide temporary care and shelter to displaced residents from the EPZ. The ability of the risk/support counties to mobilize personnel and resources to establish reception, monitoring and decontamination, and mass care centers was demonstrated.

The protection of school children is also a vital mission of the REPP. School districts and selected schools demonstrated the capability to communicate and coordinate the collection, evacuation, transportation and shelter of students attending schools within the EPZ. Provisions for students who live within the EPZ, but attend school outside were also evaluated.

2.3 Scenario

Summary SCENARIO

SUMMARY

LIMERICK GENERATING STATION DUS-FEMA Region III, PLUME EXERCISE -November 17, 2015 NOTE: The times for the events are approximate as the NRC licensee's operations crew on the reactor training simulator will be provided opportunity for free play. All scenario events are simulated.

On November 17, 2015 at 1600, the Plume exercise started in the Limerick Generating Station (LGS) control room simulator.

LGS Unit 1 and Unit 2 are boiling water reactors operating at 100 percent power. Unit 1 was participating in the exercise.

At 1600, the wind direction was from the North East, 43 degrees, into the South West at 6 miles per hour (mph). The atmospheric stability class was E. The near term weather forecast was for the winds to trend towards the East, and then shift to the North East. Initial conditions on Unit 1 were that the containment spray system was out of service, and one of the two standby gas treatment systems was out of service. Repairs were expected to be completed within 24 to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. In the event 18 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station of a loss of cooling accident this would reduce the capability of the plant to mitigate the release of radioactive materials.

At 1630, the reactor was shut down successfully when there was a 90 gallons per minute (gpm)leak from the reactor coolant system into the reactor containment.

By 1647, an Alert was declared based on EAL FAl loss of the reactor coolant system barrier.There were no releases to the environment.

At 1700, maintenance reported that the second train of the standby gas treatment system was out of service.At 1738, a loss of cooling accident into the containment occurred.

The containment pressure was increasing and the reactor water level was falling to below the top of the fuel rods. The containment radiation level was 300 R/hour and rising. Some fuel clad damage occurred.By 1811, a Site Area Emergency was declared based on EAL FS1, loss of both the reactor coolant system and the fuel clad barriers.

There were no releases to the environment.

At 1850, radioactive releases to the environment commenced when the reactor containment pressure began decreasing owing to a leak into the reactor building through the personnel hatch seal. The stack effluent monitor reading increased significantly.

By 1905, a General Emergency was declared based on EAL FG1, loss of all three fission product barriers.

Limerick issued a Protective Action Recommendation (PAR), "Evacuate the 0 to 2 miles ring. Evacuate the 2 to 5 mile downwind sectors SSW/S W/WS W/W/WNW.Administer potassium iodide to the public, and advise the remainder of the EPZ to monitor and prepare".

Radioactive releases were in progress.

The wind direction was from 59 degrees ENE at 10 mph with a stability class of E. Limerick station dose projections indicated that the EPA Protective Action Guides were not exceeded beyond the site boundary.At 1950, the wind direction changed to be from 33 degrees NNE at 10 mph with a stability class of E. By 2005, Limerick station upgraded their Protective Action Recommendation

(?PAR),"Evacuate the 0 to 2 miles ring. Evacuate the 2 to 5 mile downwind sectors S/S SW/SW/WSW/WiWNW.

Administer potassium iodide KI to the public, and advise the remainder of the EPZ to monitor and prepare".Field monitoring teams would detect plume centerline gamma exposure rates (closed window) of about 7 mR/hr at the site boundary to 1 mR/hr at about 9 miles fr'om the site. Air sample iodine cartridge readings on the plume centerline would be as high as 50 net corrected counts per minute out to about 4 miles from the site.By 2100, the Evaluated Exercise will end if all objectives are met.19 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station SECTION 3: ANALYSIS OF CAPABILITIES

3.1 Exercise

Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the November 17, 2015, Plume Radiological Emergency Preparedness (REP) Exercise.

This report also includes the Mass Care Walk Downs on October 2 9 th and 30th, and Out of Sequence Exercise on November 17th and 18th 2015. The exercise was conducted to demonstrate the ability of State, County and local jurisdictional Offsite Response Organizations (ORO) to respond to a radiological release within the 10 mile Emergency Planning Zone (EPZ) associated with the Limerick Generating Station.Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the appropriate Exercise Evaluation Area Criteria contained in the REP Program Manual. Detailed information on the exercise evaluation area criteria and the Extent-of-Play agreement are found in Appendix E.The exercise was conducted and evaluated in accordance with the Radiological Emergency Preparedness Program Manual and NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Program Manual that was scheduled for demonstration during this exercise by all participating jurisdictions and functional entities.

Exercise evaluation area criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters: (Li) Level 1 Finding: an observed or identified inadequacy of organizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant (NPP).(L2) Level 2 Finding: an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.(P) Plan Issue: an observed or identified inadequacy in the offsite response organizations'(OROs) emergency plan/implementation procedures, rather than that of the ORO's performance.(N) Not Demonstrated:

term applied to the status of a REP exercise Evaluation Area Criterion indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area 20 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Criterion, as required in the Extent-of-Play agreement or at the two-year or eight-year interval required in the FEMA REP Program Manual.(M) Met: status of a REP exercise Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the Extent-of-Play agreement with no Findings assessed in the current exercise and no unresolved prior Findings.21 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Tables 3.1 -Summary of Exercise Evaluation Table 3.1a -Exercise Evaluation by Classification

-Criteria Met Date: 11/17/2015 Site: Limerick Generating Station Location Abbreviation Criteria Title BkCo EOC (5) Emergency Information

& Instructions for the Public/Media 5bl BkCo EOC (5) Equipment and Supplies to Support Operations lel BkCo EOC (5) ,Communications Equipment idl BkCo EOC (5) Direction and Control icl BkCo BOC (5) Mobilization 1lal BkCoMCCCRNMS Temporary Care of Evacuees 6c1 BkCoMCCCRSHS Temporary Care of Evacuees 6cl BkCoMCCEES Temporary Care of Evacuees 6cl BkCoMCCERES Temporary Care of Evacuees 6cl BkCoMCCFRMS Temporary Care of Evacuees 6c1 BkCoMCCHTMS Temporary Care of Evacuees 6cl BkCoMCCLMS Temporary Care of Evacuees 6cl BkCoMCCMES Temporary Care of Evacuees 6cl BkCoMCCMMS Temporary Care of Evacuees 6cl B kCoMCCMMSHrS Temporary Care of Evacuees 6cl BkCoMCCMTFC Temporary Care of Evacuees 6cl BkCoMCCPMS Temporary Care of Evacuees 6c1 BkCoMCCQCHS Temporary Care of Evacuees 6cl BkCoMCCRMS Temporary Care of Evacuees 6cl BkCoMCCSES Temporary Care of Evacuees 6cl BkCo MVDC CoLnPlza Monitoring, Decontamination, & Registration of Evacuees 6al BkCo MDC CoLnPlza Implementation of Emergency Worker Exposure Control 3al BkCo MDC CoLniPiza Equipment and Supplies to Support Operations lel BkCo RC CoLnPlza Monitoring, Decontamination, & Registration of Evacuees 6al BkCo RC CoLnPlza Equipment and Supplies to Support Operations lel BrCo BASD Implementation of PADs for Schools 3c2 BrCo BASD ByrtwnES Implementation of PADs for Schools 3c2 BrCo BASD Byrtwni}HSW Implementation of PADs for Schools 3c2 BrCo DBASD Implementation of PADs for Schools 3c2 BrCo DBASD MEC Implementation of PADs for Schools 3c2 BrCo DglsTwp BOC Impediments to Evacuation 3d2 BrCo DglsTwp EOC Implementation of Traffic & Access Control 3d1 BrCo DglsTwp EOC Equipment and Supplies to Support Operations le 1 BrCo DglsTwp EOC Implementation of PADs for Schools 3c2 BrCo DglsTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl BrCo DglsTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 22 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station BrCo DglsTwp EOC Direction and Control 1ici BrCo DglsTwp EOC Implementation of Emergency Worker Exposure Control 3a1 BrCo DglsTwp EOC Communications Equipment 1id1 BrCo DglsTwp EOC Mobilization 1 al BrCo DglsTwp TACP Implementation of Emergency Worker Exposure Control 3al BrCo DglsTwp TACP Equipment and Supplies to Support Operations lel BrCo DglsTwp TACP Implementation of Traffic & Access Control 3dl BrCo DglsTwp TACP Impediments to Evacuation 3 d2 BrCo DglsTwp TACP Communications Equipment 1 d 1 BrCo EOC Impediments to Evacuation 3d2 BrCo EOC Implementation of Traffic & Access Control 3d 1 BrCo EOC Implementation of PADs for Schools 3c2 BrCo EOC Implementation of PADs for disabilities

& access/functional needs people 3cd BrCo EOC Activation of the Back-up ANS 5a3 BrCo EOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl BrCo EOC Emergency Information

& Instructions for the Public/Media 5b 1 BrCo EOC Direction and Control lcl BrCo EOC Activation of the Prompt Alert & Notification System 5al BrCo EOC Implementation of Emergency Worker Exposure Control 3al BrCo EOC Equipment and Supplies to Support Operations lel BrCo EOC Communications Equipment 1id1 BrCo EOC Mobilization 1lal BrCoMCCCWHS Temporary Care of Evacuees 6cl B rCoMCCCWMS Temporary Care of Evacuees 6c 1 BrCoMCCFHS Temporary Care of Evacuees 6cl1 BrCoMCCMMS Temporary Care of Evacuees 6c1 BrCoMCCTVHS Temporary Care of Evacuees 6c 1 BrCoMCCTVMS Temporary Care of Evacuees 6cl BrCoMCCWHS Temporary Care of Evacuees 6c1 BrCoMCCWSMS Temporary Care of Evacuees 6c1 BrCoMDCFHS Monitoring, Decontamination, & Registration of Evacuees 6a1 BrCoMDCFHS Implementation of Emergency Worker Exposure Control 3a1 BrCoMDCFHS Equipment and Supplies to Support Operations lel BrCoMDCWHS Monitoring, Decontamination, & Registration of Evacuees 6al BrCoMDCWHS Implementation of Emergency Worker Exposure Control 3al BrCoMDCWHS Equipment and Supplies to Support Operations 1el BrCoMVDCWHS Monitoring, Decontamination, & Registration of Evacuees 6a1 BrCoMDCWHS Implementation of Emergency Worker Exposure Control 3a1 BrCoMDCWHS Equipment and Supplies to Support Operations le1 BrCo WshtnTwp EOC Communications Equipment 1id1 BrCo WshtnTwp EOC Impediments to Evacuation 3d2 BrCo WshtnTwp EOC Direction and Control lcl BrCo WshtnTwp EOC Implementation of Traffic & Access Control 3dl 23 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station B oWstwpECMobilization 1 al BrCo WshtnTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3cd BrCo WshtnTwp EOC Implementation of PADs for Schools 3c2 BrCo WshtnTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 Bro~puAActivation of the Back-up ANS 5a3 BrCoWTwpBuRA Implementation of Emergency Worker Exposure Control 3a1 BrCoWTwpBuRA Equipment and Supplies to Support Operations lel BrCoWTwpBuRA Mobilization 1 al BrCoWTwpBuRA Communications Equipment 1 dl1 BRP R3V Field Team Management 4a2 BRP R3V Implementation of Emergency Worker Exposure Control 3al BPRVEquipment and Supplies to Support Operations lel BPRVCommunications Equipment ldl BPRVDirection and Control icl BPRVMobilization lal CDADImplementation of PADs for Schools 3c2 CC DASD DHSW Implementation of PADs for Schools 3c2 CC DASD SCES Implementation of PADs for Schools 3c2 CC EOC Emergency Information

& Instructions for the Public/Media 5b 1 CC EOC Direction and Control ic 1 CC EOC Equipment and Supplies to Support Operations lel CC EOC Communications Equipment idi CC EOC Impediments to Evacuation 3d2 CC EOC Implementation of Traffic & Access Control 3d1 CC EOC Mobilization 1 al CC EOC Activation of the Prompt Alert & Notification System 5al CC EOC Activation of the Back-up ANS 5a3 CC EOC Implementation of PADs for Schools 3c2 CC EOC Implementation of PADs for disabilities

& access/functional needs people 3cl CC EOC Implementation of KIr PAD for Institutionalized Individuals/Public 3b 1 CC EOC Implementation of Emergency Worker Exposure Control 3al CCEVcntTwpEOC Impediments to Evacuation 3d2 CCEVcntTwpEOC Implementation of Traffic & Access Control 3dl CCEVcntTwpEOC Implementation of Emergency Worker Exposure Control 3a1 CCEVcntTwpEOC Equipment and Supplies to Support Operations lel CCEVcntTwpEOC Communications Equipment 1 dl1 CCEVcntTwpEOC Direction and Control lcl CCEVcntTwpEOC Mobilization 1 al CCEVcntTwpEOC Implementation of PADs for Schools 3c2 CCEVcntTwpEOC Implementation of PADs for disabilities

& access/functional needs people 3cl CCEVcntTwpEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl CCEVcntTwpTACP Impediments to Evacuation 3d2 CCEVcntTwpTACP Implementation of Traffic & Access Control 3dl 24 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lImprovement Plan Limerick Generating Station CCEVcntTwpTACP Implementation of Emergency Worker Exposure Control 3al CCEVcntTwpTACP Equipment and Supplies to Support Operations le1 CCEVcntTwpTACP Communications Equipment 1id1 CC EWMDS LMS Monitoring/Decontamination of Emergency Workers/Equipment/Vehicles 6b 1 CC EWMLDS LMS Equipment and Supplies to Support Operations lel CC EWMvDS LMS Implementation of Emergency Worker Exposure Control 3a1 CC EWMDS LMS Communications Equipment 1id1 CC EWMDS LMS Direction and Control lcl CC GVSD Implementation of PADs for Schools 3c2 CC GVSD KDMIES Implementation of PADs for Schools 3 c2 CCMCCAGHS Temporary Care of Evacuees 6c1 CC MCC CPMS Temporary Care of Evacuees 6cl CCMCCFEMS Temporary Care of Evacuees 6cl CCMCCKHS Temporary Care of Evacuees 6cl CCMCCMLES Temporary Care of Evacuees 6cl1 CCMCCUnHS Temporary Care of Evacuees 6c1 CC MDC DHS Equipment and Supplies to Support Operations lel CC MDC DHS Monitoring, Decontamination, & Registration of Evacuees 6a1 CC MDC DHS Implementation of Emergency Worker Exposure Control 3a1 CCOJRSD Implementation of PADs for Schools 3c2 CCOJRSDECES Implementation of PADs for Schools 3c2 CCOJRSDOJRHS Implementation of PADs for Schools 3c2 CC PASD Implementation of PADs for Schools 3c2 CC PASD KC Implementation of PADs for Schools 3c2 CC RC DHS Equipment and Supplies to Support Operations lel CC RC DHS Monitoring, Decontamination, & Registration of Evacuees 6a1 CCSCTwpBuRA Activation of the Back-up ANS 5a3 CCSCTwpBuRA Implementation of Emergency Worker Exposure Control 3a1 CCSCTwpBuRA Equipment and Supplies to Support Operations lel CS wp RACommunications Equipment ldl CS wpuAMobilization 1 al CC SCvntryTwp EOC Impediments to Evacuation 3d2 CC SCvntryTwp EOC Implementation of Traffic & Access Control 3d1 CC SCvntryTwp EOC Implementation of PADs for Schools 3c2 CC SCvntryTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl CC SCvntryTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 CC SCvntryTwp EOC Implementation of Emergency Worker Exposure Control 3a1 CC SCvntryTwp EOC Equipment and Supplies to Support Operations lel CC SCvntryTwp EOC Communications Equipment ldi CC SCvntryTwp EOC Direction and Control ici CC SCvntryTwp EOC Mobilization 1lal CC WPklndTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl CC WPklndTwp EOC Implementation of Traffic & Access Control 3dl 25 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station CC WiPklndTwp EOC Implementation of PADs for Schools 3c2 CC WPklndTwp EOC Impediments to Evacuation 3d2 CC WPklndTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b1 CC WPklndTwp EOC Implementation of Emergency Worker Exposure Control 3a1 CC WPklndTwp EOC Equipment and Supplies to Support Operations lel CC WPklndTwp EOC Communications Equipment I d1 CC WPklndTwp EOC Direction and Control 1ic1 CC WPklndTwp EOC Mobilization 1 al CC WPklndTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 CC WPklndTwp TACP Impediments to Evacuation 3d2 CC WPklndTwp TACP Implementation of Traffic & Access Control 3dl CC WPklndTwp TACP Implementation of Emergency Worker Exposure Control 3aI CC WPklndTwp TACP Equipment and Supplies to Support Operations lel CC WPklndTwp TACP Communications Equipment 1idl EJIC Communications Equipment 1idi EJIC Mobilization 1lal LhCo EOC (5) Emergency Information

& Instructions for the Public/Media 5b 1 LhCo EOC (5) Equipment and Supplies to Support Operations lel LhCo EOC (5) Communications Equipment 1ldl LhCo EOC (5) Direction and Control lc 1 LhCo EOC (5) Mobilization 1lal LhCo MCC DU Temporary Care of Evacuees 6cl LhCoMCCEHS Temporary Care of Evacuees 6c 1 LhCoMCCEJHS Temporary Care of Evacuees 6c1 LhCoMCCOMS

-Temporary Care of Evacuees 6cl LhCoMCCSMMvS Temporary Care of Evacuees 6cl LhCoMCCSphMS Temporary Care of Evacuees 6cl LhCoMiDCEHS Monitoring, Decontamination, & Registration of Evacuees 6a1 LhCoMDCEHS Implementation of Emergency Worker Exposure Control 3al LhCoMDCEHS Equipment and Supplies to Support Operations 1 el LhCo RC EHS Monitoring, Decontamination, & Registration of Evacuees 6al LhCo RC EHS Equipment and Supplies to Support Operations lel MC EOC Direction and Control lci MC EOC Impediments to Evacuation 3d2 MC EOC Implementation of Traffic & Access Control 3dl MC EOC Implementation of PADs for Schools 3c2 MC EOC Implementation of PADs for disabilities

& access/functional needs people 3cl MC EOC Activation of the Back-up ANS 5a3 MC EOC Mobilization 1lal MC EOC Communications Equipment 1id1 MC EOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MC EOC Implementation of Emergency Worker Exposure Control 3a1 MC EOC Emergency Information

& Instructions for the Public/Media 5b 1 26 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station MC EOC Equipment and Supplies to Support Operations 1le 1 MC EOC Activation of the Prompt Alert & Notification System 5al MC EWMDS UPHS Monitoring/Decontamination of Emergency Workers/Equipment/Vehicles 6bl1 MC EWMvIDS UPHS Implementation of Emergency Worker Exposure Control 3al MC EWMDS UIPHS Direction and Control lci MC EWMDS UPHS Equipment and Supplies to Support Operations lel MC EWMDS UPHS Communications Equipment Id1 MC LPTwp TACP Implementation of Traffic & Access Control 3dl MC LPTwp TACP Equipment and Supplies to Support Operations lel MC LPTwp TACP Implementation of Emergency Worker Exposure Control 3al MC LPTwp TACP Communications Equipment 1idi MCLrPrvTwpEOC Impediments to Evacuation 3d2 MCLrPrvTwpEOC Implementation of Traffic & Access Control 3d1 MCLrPrvTwpEOC Implementation of PADs for Schools 3c2 MCLrPrvTwpEOC Implementation of PADs for disabilities

& access/functional needs people 3cd MCLrPrvTwpEOC Direction and Control 1icl MCLrPrvTwpEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MCLrPrvTwpEOC Implementation of Emergency Worker Exposure Control 3al MCLrPrvTwpEOC Equipment and Supplies to Support Operations lel MCLrPrvTwpEOC .Communications Equipment 1idi MCLrPrvTwpEOC Mobilization 1 al MC LSlfirdTwp TACP Implementation of Emergency Worker Exposure Control 3al MC LSlfrdTwp TACP Impediments to Evacuation 3d2 MC LSlfrdTwp TACP Implementation of Traffic & Access Control 3d 1 MC LSlfrdTwp TACP Equipment and Supplies to Support Operations le1 MC LSlfrdTwp TACP Communications Equipment idl MCLSTBuRA Activation of the Back-up ANS 5a3 MCLSTBuRA Implementation of Emergency Worker Exposure Control 3a1 MCLSTBURA Equipment and Supplies to Support Operations lel MCLSTBuRA Communications Equipment 1id1 MCLSTBuRA Mobilization 1 al MC LwrSlfrdTwp EOC Implementation of Emergency Worker Exposure Control 3al MC LwrSlfrdTwp EOC Equipment and Supplies to Support Operations 1lel MC LwrSlfrdTwp EOC Communications Equipment 1id1 MC LwrSlfrdTwp EOC Direction and Control 1ici MC LwrSlfrdTwp EOC Mobilization 1lal MC LwrSlfrdTwp EOC Impediments to Evacuation 3d2 MC LwrSlfrdTwp EOC Implementation of Traffic & Access Control 3dl MC LwrSlfrdTwp EOC Implementation of PADs for Schools 3c2 MC LwrSlfrdTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl MC LwrSlfirdTwp EOC Implementation of KI PAD for Institutionalized Individuals!Public 3bl MCMCCAJHS Temporary Care of Evacuees 6cl MCMCCASHS Temporary Care of Evacuees 6c1 27 Unclassified Radiological Emergency Preparedness Program (REp)After Action Report/Improvement Plan Limerick Generating Station MCMCCCHS Temporary Care of Evacuees 6c1 MC MSD Implementation of PADs for Schools 3c2 MC MSD AIS Implementation of PADs for Schools 3c2 MCMSDSUES Implementation of PADs for Schools 3c2 MC PASD Implementation of PADs for Schools 3c2 MC PASD FES Implementation of PADs for Schools 3c2 MC PASD PMS Implementation of PADs for Schools 3c2 MC PSD Implementation of PADs for Schools 3c2 MC PSD LPES Implementation of PADs for Schools 3c2 MC PSVD SES Implementation of PADs for Schools 3c2 MC PtstwniBr EOC Implementation of Emergency Worker Exposure Control 3a1 MC Ptst'wnflr EOC Equipment and Supplies to Support Operations lel MC PtstwnBr BOC Implementation of Traffic & Access Control 3d1 MC PtstwnBr EOC Implementation of PADs for disabilities

& access/functional needs people 3cl MC PtstwnBr EOC Communications Equipment 1idi MC PtstwnBr EOC Direction and Control ici MC PtstwnBr BOC Mobilization lal MC PtstwnBr EOC Implementation of PADs for Schools 3c2 MC PtstwnBr EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b1 MC PtstwnBr BOC Impediments to Evacuation 3d2 MC PtstwnBr TACP Impediments to Evacuation

.3d2 MC Ptstwnt~r TACP Implementation of Traffic & Access Control 3d1 MC PtstwnBr TACP Implementation of Emergency Worker Exposure Control 3a1 MC PtstwnBr TACP Equipment and Supplies to Support Operations lel MC PtstwnBr TACP Communications Equipment idi MC PVSD Implementation of PADs for Schools 3e2 MC PVSD PVHS Implementation of PADs for Schools 3c2 MC SASD Implementation of PADs for Schools 3c2 MC SFASD Implementation of PADs for Schools 3c2 MCSFASD9GC Implementation of PADs for Schools 3c2 MC SFASD EvnsES Implementation of PADs for Schools 3c2 MC SFASD LES Implementation of PADs for Schools 3c2 MC SFASD RyrsfrdES Implementation of PADs for Schools 3c2 MC SVASD IVMS Implementation of PADs for Schools 3c2 MCUFTwpEOC Implementation of Emergency Worker Exposure Control 3al MCUFTwpEOC Direction and Control ici MCUFTwpEOC Implementation of Traffic & Access Control 3d1 MCUFTwpEOC Implementation of PADs for disabilities

& access/functional needs people 3cl MCUFTwpEOC Impediments to Evacuation 3d2 MCUFTwpEOC Equipment and Supplies to Support Operations lel MCUFTwpEOC Communications Equipment idi1 MCUFTwpEOC Mobilization 1 al MCUFTwpEOC Implementation of KIT PAD for Institutionalized Individuals/Public 3b1 28

• Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station MCUFTwpEOC Implementation of PADs for Schools 3c2 MCUpPtgrTTACP Impediments to Evacuation 3 d2 MCUpPtgrTTACP Implementation of Traffic & Access Control 3dl MCUpPtgrTTACP Implementation of Emergency Worker Exposure Control 3a1 MCUpPtgrTITACP Equipment and Supplies to Support Operations lel MCUpPtgrTTACP Communications Equipment idi1 MC UprPtsgrvTwp BOC Implementation of Emergency Worker Exposure Control 3al MC UprPtsgrvTwp EOC Equipment and Supplies to Support Operations 1lel MC UprPtsgrvTwp EOC Communications Equipment 1idl MC UprPtsgrvTwp EOC Direction and Control 1iel MC UprPtsgrvTwp EOC Mobilization 1 al MC UprPtsgrvTwp EOC Impediments to Evacuation 3d2 MC UprPtsgrvTwp EOC Implementation of Traffic & Access Control 3dl MC UprPtsgrvTwp EOC Implementation of PADs for Schools 3c2 MC UprPtsgrvTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl MC UprPtsgrvTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 MC UPSD Implementation of PADs for Schools 3c2 PAAACSEOCBRP PAD decision-making process and coordination for the General Public 2b2 PAAACSEOCBRP Accident Assessment and PARs for the Emergency Event 2b1 PAAACSEOCBRP Emergency Worker Exposure Control Decisions 2a1 PAAACSEOCBRP Equipment and Supplies to Support Operations lel PAAACSEOCBRP Communications Equipment 1id1 PAAACSEOCBRP Direction and Control lcl PAAACSEOCBRP Mobilization 1 al PA EOC Emergency Information

& Instructions for the Public/Media 5b 1 PA EOC Activation of the Prompt Alert & Notification System 5al PA EOC Equipment and Supplies to Support Operations 1el PA EOC Communications Equipment 1id1 PA EOC Mobilization 1lal PA EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 PA EOC PADs for disabilities

& access/functional needs people 2el PA EOC PAD decision-making process and coordination for the General Public 2b2 PA EOC Direction and Control icl PA JIC/RumCon Emergency Information

& Instructions for the Public/Media 5b 1 PA JIC/RumCon Communications Equipment 1id1 PA JIC/RumCon Mobilization 1 al PA TACP SPBSkpk Impediments to Evacuation 3d2 PA TACP SPBSkpk Implementation of Traffic & Access Control 3dl PA TACP SPBSkpk Implementation of Emergency Worker Exposure Control 3al PA TACP SPBSkpk Equipment and Supplies to Support Operations lel PA TACP SPB Skpk Communications Equipment 1id1 SFMT A SER Mobilization 1 al SFMT A SER Plume Phase Field Measurement, Handling, & Analyses 4a3 29 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station SFMT A SER Implementation of Emergency Worker Exposure Control 3al SFMT A SER Communications Equipment ldl SFMT A SER Equipment and Supplies to Support Operations 1 el SFMT B SER Plume Phase Field Measurement, Handling, & Analyses 4a3 SFMT B SER Implementation of Emergency Worker Exposure Control 3al SFMT B SER Equipment and Supplies to Support Operations le1 SFMT B SER Communications Equipment 1ldl SFMT B SER Mobilization 1 al 30 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 State Jurisdictions 3.3.1.1 PA State Field Monitoring Team A, South East Region In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, l.d.1, l.e.1, 3.a.1, 4.a.3 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.2 PA State Field Monitoring Team B, South East Region In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 4.a.3 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.3 Pennsylvania Accident Assessment Center, State EOC-Bureau of Radiation Protection In summary, the status of DHS/FEMA criteria for this location is as follows: a. OBSERVED ONLY: 1.a.1, 1.c.1, 1.d.1, 1.e.l, 2.a.1, 2.b.1, 2.b.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 31 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.4 Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Vehicle In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 4.a.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.5 Pennsylvania Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. OBSERVED ONLY: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.2, 2.c.1, 5.a.1, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN IS SUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.6 Pennsylvania Joint Information Center/Rumor Control In summary, the status of DHS/FEMA criteria for this location is as follows: a. OBSERVED ONLY: 1.a.1, 1.d.1, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE 32 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.7 Pennsylvania State Traffic and Access Control Points, State Police Barracks Skippack In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2 Risk Jurisdictions 3.3.2.1 Berks County Emergency Operation Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: l.a.1, Il.c., 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.2 Berks County Mass Care Center, Conrad Weiser High School In summary, the status of DHS/FEM\A criteria for this location is as follows: a. MET: 6.c.1 33 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.3 Berks County Mass Care Center, Conrad Weiser Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FTNDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.4 Berks County Mass Care Center, Fleetwood High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.5 Berks County Mass Care Center, Muhelenberg Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 34 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lImprovement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.6 Berks County Mass Care Center, Twin Valley High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.7 Berks County Mass Care Center, Twin Valley Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.8 Berks County Mass Care Center, Wilson Southern Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.l 35 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.9 Berks County Mass Care Center, Wyomissing High School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.10 Berks County Monitoring and Decontamination Center, Fleetwood High School In summary, the status of DHS/FEMVA criteria for this location is as follows: a. MET: 1.e.1, 3.a.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.11 Berks County Monitoring and Decontamination Center, Wyomissing High School 36 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 3.a.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FTNDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.12 Berks County Reception Center, Morgantown Crossing In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.e.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.13 Berks County, Boyertown Area District, Boyertown Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDJINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.14 Berks County, Boyertown Area School District 37 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DUS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDIINGS:

NONE c. LEVEL 2 FINDiNGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.15 Berks County, Boyertown Area School District, Boyertown Junior High School West In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.16 Berks County, Daniel Boone Area District, Monocacy Elementary Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.17 Berks County, Daniel Boone Area School District 38 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDTNGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.18 Berks County, Douglass Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.19 Berks County, Douglass Township Traffic and Access Control In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1 .d. 1, 1.e. 1, 3.a. 1, 3.d. 1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 39 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 3.3.2.20 Berks County, Washington Township Backup Route Alerting In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 5.a.3 b. LEVEL 1 FfNDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.21 Berks County, Washington Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MVET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.22 Bucks County Monitoring and Decontamination Center, County Line Plaza In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 3.a.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE 40 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.23 Chester County Emergency Operations Center In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.3, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.24 Chester County Emergency Worker Monitoring and Decontamination Station, Lionville Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.l, 6.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.25 Chester County Mass Care Center, Avon Grove High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE 41 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.26 Chester County Mass Care Center, Charles Patton Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.27 Chester County Mass Care Center, Fred Engle Middle School In summary, the status of DHSIFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.28 Chester County Mass Care Center, Kennett High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE 42 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.29 Chester County Mass Care Center, Mary Lang Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.30 Chester County Mass Care Center, Unionville High School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.31 Chester County Monitoring and Decontamination Center, Downingtown High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 3.a.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 43 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.32 Chester County Reception Center, Downingtown High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.33 Chester County, Downingtown Area School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.34 Chester County, Downingtown Area School District, Downingtown High School West In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 44 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportllImprovement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.35 Chester County, Downingtown Area School District, Shamona Creek Elementary School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.36 Chester County, East Vincent Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.l, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.37 Chester County, East Vincent Township Traffic and Access Control In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE 45 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: U-NRESOLVED:

NONE 3.3.2.38 Chester County, Great Valley School District, KD Markley Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.39 Chester County, Owen J. Roberts School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.40 Chester County, Owen J. Roberts School District, East Coventry Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE 46 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station c. LEVEL 2 FINDTNGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.41 Chester County, Owen J. Roberts School District, Owen J. Roberts High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 F1NDrNGS:

NONE c. LEVEL 2 FiNDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.42 Chester County, Phoenixville Area School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.43 Chester County, Phoenixville Area School District, Kindergarten Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE 47 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station c. LEVEL 2 FINDTNGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.44 Chester County, South Coventry Township Backup Route Alerting In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 5.a.3 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.45 Chester County, South Coventry Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

ONE LOCATION:

South Coventry Township Emergency Operation Center ISSUE NO: 35-15-3a1-L2-01 CRITERION:

Emergency Worker Exposure Control CONDITION:

The Radiological Briefing was not conducted in accordance with procedures and content required.POSSIBLE CAUSE: Radiological Officer (RO) not adequately trained.

REFERENCE:

NUREG-0654/FEMA-REP-1:

J. 10.e, K.3.a & b, K.4 48 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EFFECT: The briefing was not done correctly to prepare Emergency Workers (EW) for deployment with the correct understanding of what the risks were and what proper monitoring and KI procedures to follow. As a result the EWs were not able to successfully answer the required interview questions.

CORRECTIVE ACTION DEMONSTRATED:

The Exelon representative provided training for the substitute Radiation Officer on the proper briefing content, risks, and proper monitoring and KI procedures.

The Radiation Officer was then able to conduct a proper Radiation Briefing to the personnel in the EOC and for the TCP staff. Two staff were interviewed and able to answer the questions correctly on monitoring and KI procedures.

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.46 Chester County, West Pikeland Emergency Operations Center In sunmmary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.47 Chester County, West Pikeland Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 49 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.48 Montgomery County Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.49 Montgomery County Emergency Worker Monitoring

& Decontamination Station, Upper Perkiomen High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 6.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN IS SUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.50 Montgomery County Mass Care Center, Abington Jr High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 50 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.51 Montgomery County Mass Care Center, Abington Sr. High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUIES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.52 Montgomery County Mass Care Center, Cheltenham High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2,FINDTNGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.53 Montgomery County, Lower Providence Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.l, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE 51 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR IS SUES: UNRESOLVED:

NONE 3.3.2.54 Montgomery County, Lower Providence Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FTNDTNGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.55 Montgomery County, Lower Salford Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.l, l.d.1, 1.e.l, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.l, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.56 Montgomery County, Lower Salford Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.l, 3.d.2 b. LEVEL 1 FINDINGS:

NONE 52 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lImprovement Plan Limerick Generating Station c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.57 Montgomery County, Lower Salford Township Backup Route Alerting In summary, the status of DHS/FEMA criteria for this location is as follows: a. MVET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 5.a.3 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.58 Montgomery County, Methacton School District, In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.59 Montgomery County, Methacton School District, Arcola Intermediate School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE 53 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.60 Montgomery County, Methacton School District, Skyview Upper Elementary School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.61 Montgomery County, Perkiomen Valley School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.62 Montgomery County, Perkiomen Valley School District, Perkiomen Valley High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 54 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.63 Montgomery County, Perkiomen Valley School District, Schwenksville Elementary School In summary, the status of DHS/FEIVA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.64 Montgomery County, Pottsgrove School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.65 Montgomery County, Pottsgrove School District, Lower Pottsgrove Elementary School 55 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.66 Montgomery County, Pottstown Area School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.67 Montgomery County, Pottstown Area School District, Franklin Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 56 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 3.3.2.68 Montgomery County, Pottstown Area School District, Pottstown Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDIINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.69 Montgomery County, Pottstown Borough Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.70 Montgomery County, Pottstown Borough Traffic and Access Control In summary, the status of DUS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.i, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 57 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plani Limerick Generating Station 3.3.2.71 Montgomery County, Souderton Area School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FTNDTNGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.72 Montgomery County, Souderton Valley Area School District, Indian Valley Mid. School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.73 Montgomery County, Spring-Ford Area School District In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE 58 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick tenerating Station f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.74 Montgomery County, Spring-Ford Area School District, 9th Grade Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDhINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.75 Montgomery County, Spring-Ford Area School District, Evans Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.76 Montgomery County, Spring-Ford Area School District, Limerick Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:i NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 59 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.77 Montgomery County, Spring-Ford Area School District, Royersford Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.78 Montgomery County, Upper Frederick Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.79 Montgomery County, Upper Perkiomen School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE 60 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.80 Montgomery County, Upper Pottsgrove Township Emergency Operation Center In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.l, l.d.1, l.e.l, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDTNGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.81 Montgomery County, Upper Pottsgrove Township Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3 Support Jurisdictions 3.3.3.1 Bucks County Mass Care Center, Lenape Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 61 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportf/Improvcment Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.2 Bucks County Emergency Operations Center In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.3 Bucks County Mass Care Center Franklin Roosevelt Middle School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.4 Bucks County Mass Care Center, Council Rock Newtown Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 62 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN IS SUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.5 Bucks County Mass Care Center, Council Rock South High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.6 Bucks County Mass Care Center, Edgewood Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.7 Bucks County Mass Care Center, Eleanor Roosevelt Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 63 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.8 Bucks County Mass Care Center, Holland Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.9 Bucks County Mass Care Center, Makefield Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.10 Bucks County Mass Care Center, Milford Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 64 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.11 Bucks County Mass Care Center, Milford Township Fire Company In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS" NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.12 Bucks County Mass Care Center, Morrisville Middle/Senior High School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.13 Bucks County Mass Care Center, Poquessing Middle School In summary, the status of DUS/FEMA criteria for this location is as follows: a. MET: 6.c.1 65 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDTNGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.14 Bucks County Mass Care Center, Quakertown Community High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.l b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.15 Bucks County Mass Care Center, Richboro Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

N'ONE d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.16 Bucks County Mass Care Center, Springfield Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 66 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.17 Bucks County Reception Center, County Line Plaza In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.18 Chester County, Great Valley School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.19 Lehigh County Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 5.b.1 67 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.20 Lehigh County Mass Care Center, DeSales University In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN IS SUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.21 Lehigh County Mass Care Center, Emmaus High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.22 Lehigh County Mass Care Center, Eyer Jr. High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 68 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.23 Lehigh County Mass Care Center, Orefield Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.24 Lehigh County Mass Care Center, South Mountain Middle School In summary, the status of DHS/FEIVA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.25 Lehigh County Mass Care Center, Springhouse Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 69 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FTNDTNGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.26 Lehigh County Monitoring and Decontamination Center, Emmaus High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.27 Lehigh County Reception Center, Emmaus High School In summary, the status of DHS/FEMA criteria for this location is as follows: b. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 70 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 3.3.4 Private Jurisdictions 3.3.4.1 Exelon Joint Information Center In summary, the status of DHS/FEMA criteria for this location is as follows: c. MET: 1.a.1, 1.d.1, 5.b.l b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDIN4GS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 71 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and local jurisdictions, except where noted in this report demonstrated knowledge of their Radiological Emergency Response Plans (RERP) and procedures were adequately implemented during the Limerick Generating Station Plume exercise evaluated on November 17, 2015.Federal Emergency Management Agency (FEMA) evaluators provided analyses of over 300 evaluation criteria.

These analyses resulted in a determination of no Level 1 Findings, (1) One Level 2 Finding, successfully re-demonstrated during the exercise and no New Plan Issues, and no unresolved Plan Issues."Based on the results of the exercise and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards of NUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CER 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise."~

An After Action Implementation Plan (IP) will not be developed as part of this report.72 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station APPENDIX A: BEST PRACTICES 1. IPAWS Pilot Implementation Summary: The Chester County Department of Emergency Services, working with support from the FEMA Region III Technological Hazards Branch, and the FEMA IPAWS lab located at the Joint Interoperability Test Command (JITC) in Indian Head, Maryland, conducted the Nation's first pilot demonstration of the IPAWS Nuclear Power Plant Warning (NUW) alert code during a scheduled Radiological Emergency Preparedness (REP) exercise.

The demonstration was not an evaluated component of the REP exercise, but it was executed in sequence with exercise play using real-time scenario information.

As a result, the capabilities of both the hardware components of the system and the training of the responders who would potentially use it were realistically tested.Description:

The Integrated Public Alert and Warning System (IPAWS) is an important modernization and integration of the nation's alert and warning infrastructure that will save time for Federal, State, territorial, Tribal, and local alerting authorities who choose to use the system.The ability to pre-script messages for each Emergency Classification Level (ECL) and to choose which routes the alert may take to reach the affected population from a single interface represents a key evolutionary step in the timely notification of the public of an incident at a Nuclear Power Plant.Alerting authorities who are designated as REP risk and/or ingestion pathway counties may choose to use IPAWS and may also integrate local systems that use Common Alerting Protocol (CAP) standards with the IPAWS infrastructure.

Examples of CAP-compliant Emergency Alerting systems available for use in Chester County which are commonly found throughout other REP jurisdictions include terrestrial radio, television, cable, broadcast, satellite, and wireline providers.

Additional notification tools demonstrated in Chester County included Wireless Emergency Alerts (WEAs), which were transmitted to local cellular towers and have the capability to effectively reach transient populations as well as residents with actionable emergency information.

The Chester County Department of Emergency Services (DES) chose to demonstrate initial public alert and warning at the Site Area Emergency (SAE) ECL at 1833 hours0.0212 days <br />0.509 hours <br />0.00303 weeks <br />6.974565e-4 months <br /> by sending a simulated SAE NUW message to the IPAWS Lab at JITC. DES chose to simulate the use of WEAs, as well as to integrate the test with their-existing CAP-compliant EAS message outlets.A test report from JITC was returned in real-time which demonstrated the success or failure of each component.

All components tested were successful.

Tests of NUTW messages using the IPAWS lab during scheduled REP exercise play or as a component of a regular preparedness testing program are available to any REP jurisdiction who has completed the requirements to become an IPAWS alerting authority.

73 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station At 1834 hours0.0212 days <br />0.509 hours <br />0.00303 weeks <br />6.97837e-4 months <br />, the Chester County DES simulated a real-time expansion of the flexibility of their IPAWS platform by incorporating a simulated siren failure event from the scenario into their demonstration.

In the Chester County plans, the failure of this particular siren requires the activation of a backup route alerting protocol for the population affected by the failure. Route 6C2 was chosen both in real-time evaluated exercise play and for the non-evaluated IPAWS component of the exercise.

Typically, this route requires the notification of a municipal EOC (South Coventry Township) and the subsequent dispatch of a volunteer fire department to report to the Fire Station, confirm instructions, and drive the complete length of the route--to include side roads and long driveways--which would not have received notification due to the failure of the siren. The completion time goal for backup route alerting tasks across the REP program nationwide is 45 minutes.In real-time exercise play, the backup route alerting team needed all of the available 45 minutes to complete the task in addition to a seven minute response time for the volunteers to report to the fire station. During the simulated backup route alert notification initiated in the Chester County EOC, the Watch Officer opened a map on his computer screen using a Google Chrome browser, highlighted a map area to create a polygon which directly matched Route 6C2, and pushed out the backup route alert via IPAWS using the Wireless Emergency Alert tools to ping local cell phone towers. The test met the FEMA requirement to notify "essentially 100% of the population" and was completed in three minutes. Through their whole-of-community collaborative planning process, Chester County is working with response partners to validate best practices for ensuring that previously-identified Special Needs residents are notified during initial notifications as well as any potential backup route alerting processes using the IPAWS platform.Using Chester County as a model going forward, FEMA strongly encourages the integration of IPAWS with existing REP offsite alert and notification plans. As IPAWS is adopted continues to expand throughout FEMA Region III and nationwide, technical and planning assistance is available for any interested REP jurisdiction by contacting their respective partners at the FEMA Regional Office Technological Hazards/REP Branch. The local REP Site Specialist and/or REP Regional Assistance Committee Chairperson can facilitate the process with the IPAWS Program Management Office and testing lab.74 Unclassified Radiological Emergency Preparedness Program (REP)Limerick Generating Station After Action Report/Improvement Plan APPENDIX B: EXERCISE TIMELINE DATE: 11/17/2015, SITE: Limerick Generating Station I Time That Notification Was Received at the Listed Location Classification DelaedEast Vincent South Coventry Level or Event DelrdPA AAC Exelon JIC Berks County Douglass Township Washington Township Chester County_________IA SEOC {Township Township Unusual Event N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 1634 1652 1652 1732 1703 1703 1654 1703 1734 1653 SAE 1750 1809 1805 1811 1815 1825 1811 1818 1814 1838 GE 1854 1914 1914 1916 1914 1931 1926 1914 1914 1914 Start of Simulated N/A 1923 1910 1916 1914 1931 1938 1914 1914 1914 Radiation Release Termination of Simulated N/A Ongoing N/A NA N/A N/A N/A N/A N/A .N/A Radiation Release Facility Declared Operational 1705 1630 1805 1655 1741 1745 1715 1830 1728 Governor's Declaration of 1815 1814 1834 1829 1853 1850 1814 1914 1809 State of Emergency Exercise Terminated 2045 1920 2100 2038 2058 2057 2050 1953 2030 First Preca utiona ry/Protective 1819 1819 1816 1819 1823 1825 1819 1821 1831 Actions: Describe: Airspace Restrictions Boating and fishing restriction Air, Rail and Restrictions Shelter and place livestock or stored feed and water 75 Unclassified Radiological Emergency Preparedness Program (REP)Limerick Generating Station After Action Report/Improvement Plan Siren Sounding 1829 [ 1829 [ 1829 [ 1829 1829 ] 1829 1829 1829 J 1829 EAS Broadcast time 1832 [ 1832 [ 1832 [ 1832 1832 ] 1832 ] 1832 1832 J 1832 Second Precautionary/Protective Actions. Describe: Recommend population within 10 miles to evacuate.

Special Population shelter in place and prepared KI for general public and 1937 1937 1946 1937 1951 1944 1937 1946 1945 Emergency Workers Air Restriction, 10 miles, 10K feet Access limited disable Siren Sounding 1947 1947 ( 1947 ( 1947 1947 1947 1947 1947 ] 1947 EAS Message Broadcast 1950 1950 [ 1950 [ 1950 J 1950 J 1950 1950 1950 1 1950 KI Decision (YES) EWs 1939 J 1934 [ 1946 [ 1934 J 1951 1 1934 1941 1953 1945 KI Decision (YES) General Public ]1939 1934 [ 1946 [ 1934 J 2003 1934 1941 1953 1945 KI Decision (YES) Persons withTI Disabilities or Access Functional 1939 1934 1946 1934 2003 1934 194119394 needs __ _ _ __ __ I __ _ _76 Unclassified Radiological Emergency Preparedness Program (REP)Limerick Generating Station After Action Report/Improvement Plan__________-

_________

-__________ -Time That Notification Was Received at the Listed Location Emergency Tif tiit Classification Delae Motoey LwrPoieI Lower Salford Pottstown Upper Frederick Lower Pottsgrove Level or Event Delrd est Pike land Bucks County Lehigh County______FCounty Township Township Borough Township.

Township Unusual Event N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 1634 1709 1703 1650 1650 1650 1648 1704 1704 1703 SAE 1750 1813 1815 1810 1810 1810 1810 1810 1809 1807 GE 1854 1924 1910 1921 1924 1922 1919 1922 1924 1917 Start of Simulated19012194121999113794 Radiation Release N/A 200819092194921999213794 Termination of Simulated N/A N/A N/A NA N/A N/A N/A N/A N/A N/A Radiation Release Facility Declared Operational 1709 1652 1702 1901 1706 1809 1722 1645 1720 GvrosDcaainoStt 1891814 1834 1946 1945 1834 1834 1834 1814 of Emergency Exercise Terminated 2018 2048 2052 2045 2052 2045 2052 2035 2038 First Precautionary/Protective 1831 1819 1829 1829 1832 1825 1829 1819 1819 Actions: Describe: Water/rail, 10 miles Air 3000 feet, 3 miles Sheltering livestock stored feed Siren Sounding 1919 ( 1829 1825 j 1829 j 1829 1829 1829 -1829 1829 ]EAS Broadcast time 1832 [ 1832 1832 J 1829 1832 1832 [1832 1832 1832 ]77 Unclassified Radiological Emergency Preparedness Program (REP)Limerick Generating Station After Action Report/Improvement Plan Second Precautionary/Protective Actions. Describe: Air, 10 miles, 10,000 feet 1945 1937 1945 1946 1945 1946 1947 1945 1945 Evac Shelter, KI and TCP KI/Shelter in Place Siren Sounding 1947 1947 J 1947 J 1947 [ 1947 1947 J1947 J1947 ] 1947 EAS Message Broadcast 1950 1950 J 1950 J 1950 [ 1950 [ 1950 J1950 1950 ] 1950 KI Decision (YES) EWs ] 1934 1934 J 1945 J 1946 [ *945 1946 J1947 ]N/A ] N/A KI Decision (YES) General Public, 1 1934 T 1934 1945 1 1946 [ 1945 F 1946 11947 1N/A 1 N/A spciyifrstiteiofecosy

__i____f _restricted______

________ ______to_

______sectors_____

_______KI Decisions (YES) Persons with Disabilities or Access/Functional 1934 1934 1945 1946 1945 1946 1947 N/A N/A needs __________

______ _______ _______ _______ ________ ________ ________ _______78 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leaders for the Limerick Generating Station 2015 Radiological Emergency Preparedness Plume Exercise evaluated on November 17, 2015.The following constitutes the managing staff for the Exercise Evaluation:

• Thomas Scardino, DHS/FEMA, Regional Assistance Committee (RAG) Chairman* Tina Thomas, DHSiFEMA, Project Officer and Site Specialist DATE: 11/17/2015, SITE: Limerick Generating Station LOCATION .. .....TEAM LEALEER AGENCY Berks County Emergency Operation Center Barton Freeman FEMA Region 3 Berks County Mass Care Center, Conrad Weiser High School Robert Neff FEMA Region 3 Berks County Mass Care Center, Fleetwood High School Joseph Suders FEMA Region 3 Berks County Mass Care Center, Muhelenberg Middle School Tina Lai-Thomas FEMA Region 3 Berks County Mass Care Center, Twin Valley High School Tina Lai-Thomas FEMA Region 3 Berks County Mass Care Center, Twin Valley Middle School Tina Lai-Thomas FEMA Region 3 Berks County Mass Care Center, Wilson Southern Middle School Tina Lai-Thomas FEMA Region 3 Berks County Mass Care Center, Wyomissing High School Robert Neff FEMA Region 3 Berks County Monitoring and Decontamination Center, Fleetwood Joseph Suders FEMA Region 3 High School Berks County Monitoring and Decontamination Center, Wyomissing Robert Neff FEMA Region 3 High School Berks County Reception Center, Morgantown Crossing Joseph Suders FEMA Region 3 Berks County, Boyertown Area District, Boyertown Elementary Michael Shuler FEMA Region 3 School Berks County, Boyertown Area School District Michael Shuler FEMA Region 3 Berks County, Boyertown Area School District, Boyertown Junior Michael Shuler FEMA Region 3 High School West Berks County, Daniel Boone Area District, Monocacy Elementary Michael Shuler FEMA Region 3 Center Berks County, Daniel Boone Area School District Michael Shuler FEMA Region 3 Berks County, Douglass Township Emergency Operations Center Barton Freeman FEMA Region 3 Berks County, Douglass Township Traffic and Access Control Barton Freeman FEMA Region 3 Berks County, Washington Township Backup Route Alerting Barton Freeman FEMA Region 3 Berks County, Washington Township Emergency Operations Center Barton Freeman FEMA Region 3 Bucks County Mass Care Center, Lenape Middle School Tina Lai-Thomas FEMA Region 3 Bucks County Emergency Operations Center Bridget Ahlgrim FEMA HQ Bucks County Mass Care Center Franklin Roosevelt Middle School Tina Lai-Thomas FEMA Region 3 79 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Bucks County Mass Care Center, Council Rock Newtown Middle Tina Lai-Thomas FEMA Region 3 School Bucks County Mass Care Center, Council Rock South High School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Edgewood Elementary School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Eleanor Roosevelt Elementary Tina Lai-Thomas FEMA Region 3 School_______________________

Bucks County Mass Care Center, Holland Middle Schiool Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Makefield Elementary School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Milford Middle School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Milford Township Fire Company Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Morrisville Middle/Senior High Tina Lai-Thomas FEMA Region 3 School __________

Bucks County Mass Care Center, Poquessing Middle School Tina Lai-Thomas FEMVA Region 3 Bucks County Mass Care Center, Quakertown Community High Tina Lai-Thomas FEMA Region 3 School __________

Bucks County Mass Care Center, Richboro Middle School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Springfield Elementary School Tina Lai-Thomas FEMA Region 3 Bucks County Monitoring and Decontamination Center, County Line Joseph Suders FEMA Region 3 Plaza Bucks County Reception Center, County Line Plaza Joseph Suders FEMA Region 3 Chester County Emergency Operations Center John Price FEMA Region 3 Chester County Emergency Worker Monitoring and Decontamination Joseph Suders FEMA Region 3 Station, Lionville Middle School Chester County Mass Care Center, Avon Grove High School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Charles Patton Middle School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Fred Engle Middle School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Kennett High School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Mary Lang Elementary School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Unionville High School Tina Lai-Thomas FEMA Region 3 Chester County Monitoring and Decontamination Center, Joseph Suders FEMA Region 3 Downingtown High School Chester County Reception Center, Downingtown High School Joseph Suders FEMA Region 3 Chester County, Downingtown Area School District Michael Shuler FEM\A Region 3 Chester County, Downingtown Area School District, Downingtown Michael Shuler FEMA Region 3 High School West Chester County, Downingtown Area School District, Shamona Creek Michael Shuler FEMA Region 3 Elementary School Chester County, East Vincent Township Emergency Operations John Price FEMA Region 3 Center Chester County, East Vincent Township Traffic and Access Control John Price FEMA Region 3 Chester County, Great Valley School District Michael Shuler FEMA Region 3 Chester County, Great Valley School District, KD Markley Michael Shuler FEMA Region 3 Elementary School___________

Chester County, Owen J. Roherts School District Michael Shuler FEMA Region 3 80 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lImprovement Plan Limerick Generating Station Chester County, Owen J. Roberts School District, East Coventry Michael Shuler FEMA Region 3 Elementary School ___________

Chester County, Owen J. Roberts School District, Owen J. Roberts Michael Shuler FEMA Region 3 High School Chester County, Phoenixville Area School District Michael Shuler FEMA Region 3 Chester County, Phoenixville Area School District, Kindergarten Michael Shuler FEMA Region 3 Center Chester County, South Coventry Township Backup Route Alerting John Price FEMA Region 3 Chester County, South Coventry Township Emergency Operations John Price FEMA Region 3 Center Chester County, West Pikeland Emergency Operations Center John Price FEMA Region 3 Chester County, West Pikeland Township Traffic and Access Control John Price FEMA Region 3 Exelon Joint Information Center Joseph Suders FEMA Region 3 Lehigh County Emergency Operations Center Bridget Ahlgrim FEMA HQ Lehigh County Mass Care Center, DeSales University Tina Lai-Thomas FEMA Region 3 Lehigh County Mass Care Center, Emmaus High School Joseph Suders FEMA Region 3 Lehigh County Mass Care Center, Eyer Jr. High School Tina Lai-Thomas FEMA Region 3 Lehigh County Mass Care Center, Orefield Middle School Tina Lai-Thomas FEMA Region 3 Lehigh County Mass Care Center, South Mountain Middle School Tina Lai-Thomas FEMA Region 3 Lehigh County Mass Care Center, Springhouse Middle School Tina Lai-Thomas FEMA Region 3 Lehigh County Monitoring and Decontamination Center, Emmaus Joseph Suders FEMA Region 3 High School Lehigh County Reception Center, Emmaus High School Joseph Suders FEMA Region 3 Montgomery County Emergency Operations Center Lee Torres FEMA Region 3 Montgomery County Emergency Worker Monitoring

& Joseph Suders FEMA Region 3 Decontamination Station, Upper Perkiomen HS ___________

_________Montgomery County Mass Care Center, Abington Jr. High School Tina Lai-Thomas FEMA Region 3 Montgomery County Mass Care Center, Abington Sr. High School Tina Lai-Thomas FEMA Region 3 Montgomery County Mass Care Center, Cheltenham High School Tina Lai-Thomas FEMA Region 3 Montgomery County, Lower Providence Township Emergency Lee Torres FEMA Region 3 Operations Center Montgomery County, Lower Providence Township Traffic and Lee Torres FEMA Region 3 Access Control Montgomery County, Lower Salford Township Emergency Lee Tortes FEMA Region 3 Operations Center Montgomery County, Lower Salford Township Traffic and Access Lee Torres FEMA Region 3 Control Montgomery County, Lower Salford Township Backup Route Lee Torres FEMA Region 3 Alerting Montgomery County, Methacton School District, Michael Shuler FEMA Region 3 Montgomery County, Methacton School District, Arcola Intermediate Michael Shuler FEMA Region 3 School Montgomery County, Methacton School District, Skyview Upper Michael Shuler FEMA Region 3 Elementary School Montgomery County, Perkiomen Valley School District Michael Shuler FEMA Region 3 81 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Gencrating Station Montgomery County, Perkiomen Valley School District, Perkiomen Michael Shuler FEMA Region 3 Valley High School Montgomery County, Perkiomen Valley School District, Michael Shuler FEMA Region 3 Schwenksville Elementary School Montgomery County, Pottsgrove School District Michael Shuler FEMA Region 3 Montgomery County, Pottsgrove School District, Lower Pottsgrove Michael Shuler FEMA Region 3 Elementary School Montgomery County, Pottstown Area School District Michael Shuler FEMA Region 3 Montgomery County, Pottstown Area School District, Franklin Michael Shuler FEMA Region 3 Elementary School Montgomery County, Pottstown Area School District, Pottstown Michael Shuler FEMA Region 3 Middle School Montgomery County, Pottstown Borough Emergency Operations Lee Torres FEMA Region 3 Center Montgomery County, Pottstown Borough Traffic and Access Control Lee Torres FEMA Region 3 Montgomery County, Souderton Area School District Michael Shuler FEMA Region 3 Montgomery County, Souderton Valley Area School District, Indian Michael Shuler FEMA Region 3 Valley Mid. School Montgomery County, Spring-Ford Area School District Michael Shuler FEMA Region 3 Montgomery County, Spring-Ford Area School District, 9th Grade Michael Shuler FEMA Region 3 Center Montgomery County, Spring-Ford Area School District, Evans Michael Shuler FEMA Region 3 Elementary School Montgomery County, Spring-Ford Area School District, Limerick Michael Shuler FEMA Region 3 Elementary School Montgomery County, Spring-Ford Area School District, Royersford Michael Shuler FEMA Region 3 Elementary School Montgomery County, Upper Frederick Township Emergency Lee Torres FEMA Region 3 Operations Center ___________

Montgomery County, Upper Perkiomen School District Michael Shuler FEMA Region 3 Montgomery County, Upper Pottsgrove Township Emergency Lee Torres FEMA Region 3 Operation Center Montgomery County, Upper Pottsgrove Township Traffic and Access Lee Torres FEMA Region 3 Control Point PA State Field Monitoring Team A, South East Region Martin Vyenielo FEMA Region 3 PA State Field Monitoring Team B, South East Region Martin Vyenielo FEMA Region 3 Pennsylvania Accident Assessment Center, State EOC-Bureau of Martin Vyenielo FEMA Region 3 Radiation Protection Pennsylvania Bureau of Radiation Protection, Radiological Rapid Martin Vyenielo FEMA Region 3 Response Vehicle Pennsylvania Emergency Operations Center Joseph Suders FEMA Region 3 Pennsylvania Joint Information Center/Rumor Control Joseph Suders FEMA Region 3 IPennsylvania State Traffic and Access Control Points, State Police Barracks Skippack Joseph Suders FEMA Region 3 82 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station LOCATION EVALUATOR AGENCY Berks County Emergency Operation Center Miriam Weston FEMA Region 2 Berks County Emergency Operation Center Barton Freeman FEMA Region 3 Berks County Emergency Operation Center Frank Cordaro JCF Berks County Emergency Operation Center Robert Neff FEMA Region 3 Berks County Mass Care Center, Conrad Weiser High School Robert Neff FEMA Region 3 Berks County Mass Care Center, Fleetwood High School Gary Goldberg ICF Berks County Mass Care Center, Muhelenberg Middle School Robert Neff FEMA Region 3 Berks County Mass Care Center, Twin Valley High School Robert Neff FEMA Region 3 Berks County Mass Care Center, Twin Valley Middle School Robert Neff FEMA Region 3 Berks County Mass Care Center, Wilson Southern Middle School Robert Neff FEMA Region 3 Berks County Mass Care Center, Wyomissing High School Robert Neff FEMA Region 3 Berks County Monitoring and Decontamination Center, Fleetwood High Gary Goldberg ICF School Berks County Monitoring and Decontamination Center, Wyomissing High Robert Neff FEMA Region 3 School Berks County Reception Center, Morgantown Crossing Thomas Essig ICF Berks County, Boyertown Area District, Boyertown Elementary School Frank Cordaro ICF Berks County, Boyertown Area School District Roger Kowieski ICF Berks County, Boyertown Area School District, Boyertown Junior High Bill Webb FEMA Region 10 School West Berks County, Daniel Boone Area District, Monocacy Elementary Center Ronald Bonner ICF Berks County, Daniel Boone Area School District Laurel Ryan FEMA Region 9 Berks County, Douglass Township Emergency Operations Center Paul Anderson FEMA Region 9 Berks County, Douglass Township Emergency Operations Center Ronald Bonner ICF Berks County, Douglass Township Traffic and Access Control Lenora Borchardt ICF Berks County, Washington Township Backup Route Alerting Brian Hasemann FEMA Region 2 Berks County, Washington Township Emergency Operations Center Andrew Chancellor FEMA R7 Berks County, Washington Township Emergency Operations Center Gregg Dawkins ICF Bucks County Mass Care Center, Lenape Middle School Lee Torres FEMA Region 3 Bucks County Emergency Operations Center Kerry Holmes FEMA Region 3 Bucks County Mass Care Center Franklin Roosevelt Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Council Rock Newtown Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Council Rock South High School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Edgewood Elementary School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Eleanor Roosevelt Elementary School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Holland Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Makefield Elementary School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Milford Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Milford Township Fire Company Lee Torres FEMA Region 3 Bucks County Mass Care Center, Morrisville Middle/Senior High School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Poquessing Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Quakertown Community High School Lee Torres FEMA Region 3 83 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Gcncrating Station Bucks County Mass Care Center, Riehboro Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Springfield Elementary School Lee Torres FEMA Region 3 Bucks County Monitoring and Decontamination Center, County Line Plaza John Zeidler ICF Bucks County~Reception Center, County Line Plaza Brad McRee ICF Chester County Emergency Operations Center Christopher Roe FEMA Region 5 Chester County Emergency Operations Center John Price FEMA Region 3 Chester County Emergency Operations Center Michael Shuler FEMA Region 3 Chester County Emergency Operations Center Steve Ward FEMA Region 3 Chester County Emergency Worker Monitoring and Decontamination Reggie Rodgers ICF Station, Lionville MS Chester County Mass Care Center, Avon Grove High School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Charles Patton Middle School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Fred Engle Middle School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Kennett High School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Mary Lang Elementary School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Unionville High School Tina Lai-Thomas FEMA Region 3 Chester County Monitoring and Decontamination Center, Downingtown Richard Smith ICF High School Chester County Reception Center, Downingtown High School Richard Smith JCF Chester County, Downingtown Area School District Lenora Borchardt ICF Chester County, Downing-town Area School District, Downingtown High Robert Duggleby ICF School West Chester County, Downing-town Area School District, Shamona Creek Gregg Dawkins ICF Elementary School Chester County, East Vincent Township Emergency Operations Center Marynctte Herndon ICF Chester County, East Vincent Township Emergency Operations Center Robert Duggleby ICF Chester County, East Vincent Township Traffic and Access Control James Hickey ICF Chester County, Great Valley School District Marynette Herndon ICF Chester County, Great Valley School District, KD Markley Elementary James Hickey ICF School Chester County, Owen J. Roberts School District Roger Jobe ICF Chester County, Owen J. Roberts School District, East Coventry Elementary David Kayen ICF School Chester County, Owen J. Roberts School District, Owen J. Roberts High Roger Jobe ICF School __________

Chester County, Phoenixville Area School District Robert Lemeshka ICF Chester County, Phoenixville Area School District, Kindergarten Center Carl Wentzell ICF Chester County, South Coventry Township Backup Route Alerting Roger Jobe ICF Chester County, South Coventry Township Emergency Operations Center Laura Forrest FEMA Region 2 Chester County, South Coventry Township Emergency Operations Center Bill Webb FEMA Region 10 Chester County, West Pikeland Emergency Operations Center David Kayen ICF Chester County, West Pikeland Emergency Operations Center Lisa Hamilton FEMA Region HQ Chester County, West Pikeland Township Traffic and Access Control Robert Lemeshka ICF Exelon Joint Information Center Roger Kowieski ICF Lehigh County Emergency Operations Center Paul Nied ICF 84 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Lehigh County Mass Care Center, DeSales University Lee Torres FEMA Region 3 Lehigh County Mass Care Center, Emmaus High School Kent Tosch ICF Lehigh County Mass Care Center, Eyer Jr. High School Lee Torres FEMA Region 3 Lehigh County Mass Care Center, Orefield Middle School Lee Torres FEMA Region 3 Lehigh County Mass Care Center, South Mountain Middle School Lee Torres FEMA Region 3 Lehigh County Mass Care Center, Springhouse Middle School Lee Torres FEMA Region 3 Lehigh County Monitoring and Decontamination Center, Emmaus High Robert Walker ICF School Lehigh County Reception Center, Emmaus High School Kent Tosch ICF Montgomery County Emergency Operations Center Bridget Ahlgrim FEMA HQ Montgomery County Emergency Operations Center Lee Torres FEMA Region 3 Montgomery County Emergency Operations Center Matthew Wiedemer FEMA Region 3 Montgomery County Emergency Operations Center Peter Herrick, Jr. FEMA Region 3 Montgomery County Emergency Worker Monitoring

& Decontamination Mario Vigliani ICF Station, Upper Perkiomen HS Montgomery County Mass Care Center, Abington Jr. High School Robert Neff FEMA Region 3 Montgomery County Mass Care Center, Abington Sr. High School Robert Neff FEMA Region 3 Montgomery County Mass Care Center, Cheltenham High School Robert Neff FEMA Region 3 Montgomery County, Lower Providence Township Emergency Operations Jon Christiansen ICF Center Montgomery County, Lower Providence Township Emergency Operations Rufus Mobley FEMA Region HQ Center Montgomery County, Lower Providence Township Traffic and Access Carl Wentzell ICF Control Montgomery County, Lower Salford Township Emergency Operations Cristina Schulingkamp EPA Center Montgomery County, Lower Salford Township Emergency Operations Kathy Duran FEMA Region 3 Center Montgomery County, Lower Salford Township Traffic and Access Control Brenda Rembert ICF Mo~ntgomery County, Lower Salford Township Backup Route Alerting Thomas Reynolds ICF Montgomery County, Methacton School District, Brenda Rembert ICF Montgomery County, Methacton School District, Arcola Intermediate Thomas Reynolds JCF School Montgomery County, Methacton School District, Skyview Upper Wes Ryals ICF Elementary School Montgomery County, Perkiomen Valley School District Clayton Spangenberg ICF Montgomery County, Perkiomen Valley School District, Perkiomen Valley Lynn Steffensen ICF High School Montgomery County, Perkiomen Valley School District, Schwenksville Bruce Swiren ICF Elementary School Montgomery County, Pottsgrove School District Rebecca Thomson ICF Montgomery County, Pottsgrove School District, Lower Pottsgrove Rebecca Thomson ICF Elementary School Montgomery County, Pottstown Area School District Robert Walker ICF Montgomery County, Pottstown Area School District, Franklin Elementary Robert Walker ICF School_________________________

85 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Montgomery County, Pottstown Area School District, Pottstown Middle Paul Nied ICF School Montgomery County, Pottstown Borough Emergency Operations Center LaShawn Halsey FEMA HQ Montgomery County, Pottstown Borough Emergency Operations Center Taneeka Hollins FEMA Region 1 Montgomery County, Pottstown Borough Emergency Operations Center Lee Torres FEMA Region 3 Montgomery County, Pottstown Borough Traffic and Access Control Wes Ryals ICF Montgomery County, Souderton Area School District John Zeidler ICF Montgomery County, Souderton Valley Area School District, Indian Valley John Zeidler ICF Mid. School Montgomery County, Spring-Ford Area School District Thomas Essig ICF Montgomery County, Spring-Ford Area School District, 9th Grade Center Gary Goldberg ICF Montgomery County, Spring-Ford Area School District, Evans Elementary Brad McRee ICF School Montgomery County, Spring-Ford Area School District, Limerick Richard Smith ICF Elementary School Montgomery County, Spring-Ford Area School District, Royersford Kent Tosch ICF Elementary School Montgomery County, Upper Frederick Township Emergency Operations Clayton Spangenberg ICF Center Montgomery County, Upper Frederick Township Emergency Operations Ryan Jones FEMA Region 1 Center Montgomery County, Upper Perkiomen School District Mario Vigliani ICF Montgomery County, Upper Pottsgrove Township Emergency Operation Lee Torres FEMA Region 3 Center Montgomery County, Upper Pottsgrove Township Emergency Operation Bruce Swiren ICF Center Montgomery County, Upper Pottsgrove Township Emergency Operation Lynn Steffensen ICF Center Montgomery County, Upper Pottsgrove Township Traffic and Access Rebecca Thomson ICF Control Point PA State Field Monitoring Team A, South East Region Deborah Blunt JCF PA State Field Monitoring Team B, South East Region Johanna Berkey FEMA Region 9 Pennsylvania Accident Assessment Center, State EOC-Bureau of Radiation Martin Vyenielo FEMA Region 3 Protection Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Reggie Rodgers ICF Vehicle Pennsylvania Emergency Operations Center Joseph Suders FEMA Region 3 Pennsylvania Emergency Operations Center Thomas Murray FEMA Region 3 Pennsylvania Joint Information Center/Rumor Control Laurel Ryan FEMA Region 3 Pennsylvania State Traffic and Access Control Points, Station Police Jon Christiansen ICE Barracks Skippack____________

___________

86 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station APPENDIX D: ACRONYMS AND ABBREVIATIONS ACP Access Control Points ACS Auxiliary Communications Service AO Agriculture Officer AP Assistant Principal ARC American Red Cross ARRA Area Requiring Corrective Action ARES Amateur Radio Emergency Services ATEOC Amity Township Emergency Operations Center BASD Boyertown Area School District BCEOC Berks County Emergency Operations Center CART County Animal Response Team CCEOC Chester County Emergency Operations Center CCEPRS Chester County Emergency Preparedness Radio System CERT Crisis Emergency Response Team DASD Downingtown Area School District DRD Direct Reading Dosimeter DT Douglass Township EAL Emergency Action Level EAS Emergency Alert System ECC Emergency Communications Center ECL Emergency Classification Level EDO Emergency Duty Officer EMA Emergency Management Agency EMC Emergency Management Coordinator EMD Emergency Management Director EMS Emergency Medical Services ENEOC East Nantmeal Emergency Operations Center EOC Emergency Operations Center EOCD Emergency Operations Center Director EPLO Emergency Preparedness Liaison Officer EPT Emergency Preparedness Team EPZ Emergency Planning Zone ERP Emergency Response Procedure ERT Emergency Response Team ESF Emergency Support Function EW Emergency Workers FAA Federal Aviation Authority FCP Forward Command Post FEMA Federal Emergency Management Agency FRT Facility Response Team GE General Emergency GES Gilbertsville Elementary School 87 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station GIS Geospatial Information System HAB Hostile Action Base JIC Joint Information Center LGS Limerick Generating Station LNGA Limerick Nuclear Generating Station LSC Logistic Section Chief LVFD Lionville Volunteer Fire Department MC Montgomery County MCCEOC Montgomery County Emergency Operations Center MCT Mobile Cornputer Terminal MDC Mobile Data Computer MDT Mobile Data Terminal MERT Medical Emergency Response Team MPS Municipal Planner Specialist MSD Methacton School District MTFD Montgomery Township Fire Department NARS Nuclear Accident Reporting System ORO Offsite Response Organization PAD Protective Action Decision PBEMA Phoenixville Borough Emergency Management Agency PBEOC Phoenixville Borough Emergency Operations Center PBPD Phoenixville Borough Police Department PCS Personal Communications Services PEIRS Pennsylvania Emergency Incident Reporting System PEMA Pennsylvania Emergency Management Agency PFES Pine Forge Elementary School PIO Public Information Officer PM Portal Monitor PRD Permanent Radiation Dosimeter PSP Pennsylvania State Police PVES Pickering Valley Elementary School PVSD Perkiomen Valley School District PWD Public Works Department RACES Radio Amateur Civil Emergency Services RAT Route Alerting Teams REOP Radiological Emergency Operations Plan REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RO Radiological Officer RSAN Roam Secure Alert Network RSO Radiation Safety Officer SAC Staging Area Commander SAE Site Area Emergency 88 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportllmprovement Plan Limerick Generating Station SASD Souderton Area School District SEOC State Emergency Operations Center SES Schuylkill Elementary School SEVAN Statewide Emergency Voice Activation Network SSL School Services Liaison TCP Traffic Control Points TEDE Total Effective Dose Equivalent TLD Thermo Luminescent Dosimeter TOC Tactical Operations Center USVFC Upper Salford Volunteer Fire Company UUT Upper Uwchlan Township WT Warwick Township 89 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station APPENDIX E: EXERCISE PLAN The enclosed Exercise Plan was created as an overall tool for facilitation and implementation of the Limerick Generating Station (LGS) Radiological Emergency Preparedness Exercise and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program Exercise Methodology.

The Exercise Plan was originally drafted by the Pennsylvania Emergency Management Agency (PEMA) and published by the Federal Emergency Management Agency as an independent document and is annexed here. The Limerick Generating Station Extent-of-Play (EOP) was negotiated and agreed upon by FEMA Region III, and PEMA. The Extent-of-Play is included as an Appendix of the Exercise Plan.90 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportl/Improvcment Plan Limerick Generating Station Preface The 2015 Limerick Generating Station Evaluated Full Scale Exercise (FSE) is sponsored by the Federal Emergency Management Agency (FEMA) and the Pennsylvania Emergency Management Agency (PEMA). This Exercise Plan (ExPlan) was produced with input, advice, and assistance from the Exercise Planning Team (EPT), which followed the guidance set forth in the Federal Emergency Management Agency (FEMA), Homeland Security Exercise and Evaluation Program (HSEEP).The ExPlan gives officials, observers, media personnel, and players from participating organizations the information necessary to observe or participate in a nuclear power plant accident response exercise focusing on participants' emergency response plans, policies, and procedures as they pertain to this type of event. The information in this document is current as of the date of publication and is subject to change as dictated by the EPT.The 2015 Limerick Generating Station Evaluated Full Scale Exercise is an unclassified exercise.The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, Controllers, and Evaluators, but Players may view other materials deemed necessary to their performance.

The ExPlan may be viewed by all exercise participants, but the Controller and Evaluator (C/E) Handbook is a restricted document intended for Controllers and Evaluators only.All exercise participants should use appropriate guidelines to ensure the proper control of information within their areas of expertise and to protect this material in accordance with current jurisdictional directives.

Public release of exercise materials to third parties is at the discretion of DHS and the EPT.91 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generatring Station This page is intentionally left blank.92 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Handling Instructions

1. The title of this document is 2015 Limerick Generating Station Evaluated Full Scale Exercise Plan (ExPlan).2. The information gathered in this ExPlan should be handled as sensitive information not to be disclosed.

This document should be safeguarded, handled, transmitted, and stored in accordance with appropriate security directives.

Reproduction of this document, in whole or in part, without prior approval from Exercise Planning Director is prohibited.

3. At a minimum, the attached materials will be disseminated only on a need-to-know basis and when unattended, stored in an area offering sufficient protection against theft, compromise, inadvertent access, and unauthorized disclosure.

4. For more information, please consult the following points of contact (POCs): Federal POC(s): Tina Lai Thomas, Technological Hazards Program Specialist Department of Homeland Security (DHS)Federal Emergency Management Agency (FEMA) Region III 615 Chestnut Street, Sixth Floor One Independence Mall Philadelphia, Pennsylvania 19106-4404 215.931.5680 Tina.Thomas(~fema.dhs .gov State POC(s): Sandra B. Silva, Radiological Planner Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, Pennsylvania 17110 717.561.2235 sans ilva(~pa.

gov 93 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station TABLE OF CONTENTS Exercise Plan ...........................................................................................

90 Limerick Generating Station FEMA Evaluated REP Exercise .................................

90 U.S. DEPARTMENT OF HOMELAND SECURITY ............................................

90 Preface ...................................................................................................

91 Handling Instructions

.................................................................................

93 Chapter 1: General Information

....................................................................

96 Introduction..........................................................................................

96 Confidentiality.......................................................................................

96 Purpose ...............................................................................................

96 Core Capabilities

....................................................................................

97 Exercise Objectives

.................................................................................

97 Outstanding Issues ..................................................................................

98 Chapter 2: Exercise Logistics

........................................................................

99 Exercise Summary...................................................................................

99 General ..............................................................................................

99 Assumptions........................................................................................

99 Constructs and Constraints.......................................................................

100 Exercise Participants..............................................................................

100 Exercise Tools ....................................................................................

101 Controller Handbook.............................................................................

101 Master Scenario Events List .....................................................................

101 Exercise Implementation

.........................................................................

102 Exercise Play......................................................................................

102 Exercise Rules ....................................................................................

102 Safety Requirements................................................................................

102 General .................

............................................................................

102 Exercise Setup ....................................................................................

103 Accident Reporting and Real Emergencies

....................................................

103 Site Access...........................................................................................

103 Observer Coordination...........................................................................

103 Exercise Identification......................

.....................................................

104 Communications Plan .............................................................................

104 Exercise Start, Suspension, and Termination Instructions

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104 Player Communication...........................................................................

104 Player Briefing ....................................................................................

105 Public Affairs .....................................................................................

105 94 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Chapter 3: Player Guidelines

.........................................................................

106 Exercise Staff .........................................................................................

106 Exercise Director..................................................................................

1-6 Lead Controller....................................................................................

106 Controllers.........................................................................................

107 Lead Evaluator

....................................................................................

107 Evaluators

......................

...................................................................

107 Player Instructions

...................................................................................

107 Before the Exercise.........................................

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107 During the Exercise...............................................................................

108 Following the Exercise ...........................................................................

108 Simulation Guidelines

...............................................................................

109 Chapter 4: Evaluation and Post-Exercise Activities

..............................................

110 Exercise Documentation

............................................................................

11 0 Exercise Evaluation Guides ......................................................................

110 Players Critique.......................................................................................110 Hotwash ................................................................................................

110 Participants and Public/Media Briefings.........................................................

11 After Action Report..................................................................................

11 After Action Conference and Improvement Plan ..............................................

11 After Action Conference..........................................................................

111 Improvement Plan .................................................................................

111 Annex A: Exercise Schedules

.........................................................................

112 Annex B: Method of Operations and Extent of Play..............................................

114 Annex C: Participating Agencies and Site Maps ..................................................

115 Annex D: Directions

....................................................................................

116 Annex E: Open Issues ..................................................................................

117 Extent of Play............................................................................................

118 95 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Chapter 1: General Information Introduction The 2015 Limerick Generating Station Exercise is a full-scale exercise (FSE) designed to establish a learning environment for players to exercise emergency response plans, policies, and procedures as they pertain to Nuclear Power Plant accidents.

An FSE is a complex event that requires detailed planning.

To conduct an effective exercise, subject matter experts (SMEs) and local representatives from numerous agencies have taken part in the planning process and will take part in exercise conduct and evaluation.

This Exercise Plan (ExiPlan) was produced at the direction of the Federal Emergency Management Agency (FEMA) and the Pennsylvania Emergency Management Agency (PEMA)with the input, advice, and assistance of the EPT. The 2015 Limerick Generating Station Evaluated Full Scale Exercise is evidence of the growing partnership between State and local jurisdictions for response to the threats our nation and communities face.Confidentiality The 2015 Limerick Generating Station Evaluated Full Scale Exercise is an unclassifed exercise.The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, controllers, and evaluators, but players may view other materials deemed necessary to their performance.

This ExPlan may be viewed by all exercise participants, but the Controller and Evaluator (C/E) Handbook is a restricted document intended for controllers and evaluators only.All exercise participants should use appropriate guidelines to ensure the proper control of information within their areas of expertise and protect this material in accordance with current Federal Emergency Management Agency (FEMA) directives.

Public release of exercise materials to third parties is at the discretion of the Federal Emergency Management Agency (FEMA) and the EPT.Purpose The purpose of this exercise is to evaluate player actions against current response plans and capabilities for a nuclear power plant-related incident, and to comply with the requirements of 44 CFR 350 and the guidelines of NUREG 0654/FEMA-REP-1.

Exercise planners utilized the elements described in the Radiological Emergency Preparedness (REP) Program Manual (July 2015) to develop this exercise.The objective of the Federal Emergency Management Agency (FEMA) and the Pennsylvania Emergency Management Agency (PEMA) is to demonstrate reasonable assurance that the public can be protected during a nuclear power plant emergency.

95 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Core Capabilities The establishment of the National Preparedness Priorities have steered the focus of homeland security toward a capabilities-based planning approach.

Capabilities-based planning focuses on planning under uncertainty, since the next danger or disaster can never be forecast with complete accuracy.

Therefore, capabilities-based planning takes an all-hazards approach to planning and preparation which builds capabilities that can be applied to a wide variety of incidents.

States and Urban Areas use capabilities-based planning to identify a baseline assessment of their homeland security efforts by comparing their current capabilities against the Core Capabilities List (CCL)and the critical tasks of the Universal Task List (UTL). This approach identifies gaps in current capabilities and focuses efforts on identifying and developing priority capabilities and tasks for the jurisdiction.

These priority capabilities are articulated in the jurisdiction's homeland security strategy and Multi-Year Training and Exercise Plan (TEP), of which this exercise is a component.

The capabilities listed below have been selected by the EPT planning team from the priority capabilities identified in Pennsylvania Multi-Year TEP. These capabilities provide the foundation for development of the exercise objectives and scenario, as the purpose of this exercise is to measure and validate performance of these capabilities and their associated critical tasks.* Operational Communications

• Public Health and Medical Services* Critical Transportation

• Public and Private Services and Resources* Operational Coordination

• Public Information and Warning* On-scene Security and Protection

• Environmental Response/Health and Safety* Mass Care Services* Supply Chain Integrity and Security* Economic Recovery Exercise Objectives The EPT selected objectives that focus on evaluating emergency response procedures, identifying areas for improvement, and achieving a collaborative attitude.

This exercise will focus on the following objectives:

• The objective of this exercise is to demonstrate reasonable assurance that the health and safety of the public can be protected, through successful demonstration of tasks identified in Appendix B, Extent-of-Play.

97 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* The players in this exercise will satisfactorily demonstrate negotiated competency on key Demonstration Criteria as defined in Radiological Emergency Preparedness (REP)Program Manual (July 2015) as negotiated and defined in Appendix B, Extent-of-Play.

Outstanding Issues There are no (0) Issues remaining as a result of the FEMA-evaluated plume-phase exercise at Limerick Generating Station in 2013.98 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportllmprovenment Plan Limerick Generating Station Chapter 2: Exercise Logistics Exercise Summary General The 2015 Limerick Generating Station Evaluated Full Scale Exercise is designed to establish a learning environment for players to exercise their plans and procedures for responding to an incident at a Nuclear Power Plant. The 2015 Limerick Generating Station Evaluated Full Scale Exercise will be conducted on November 17, 2015. Exercise play is scheduled for eight (8)hours or until the Lead Controller in consultation with FEMA and the Utility determines that the exercise objectives have been met at each venue. Out-of-Sequence Evaluations will be conducted as follows:* The MS-i hospital demonstration was federally evaluated at Brandywine Hospital, Chester County, on August 11, 2015.* The exercise window for school demonstrations will be between 9:00 -11:00 a.m. on November 17, 2015.* The demonstration of reception centers, mass care centers (as indicated), monitoring/decontamination centers and emergency worker stations will be conducted between 7:00 p.m. -9:30 p.m. on November 18, 2015.o Thirty six mass care centers (6 in Berks, 15 in Bucks, 6 in Chester, 5 in Lehigh, and 4 in Montgomery) will receive "walkdown" baseline evaluations on October 29 and 30, 2015. These 36 mass care centers will not be evaluated during the evening of November 18. There are two co-located Mass Care/Monitoring and Decontamination Centers in Berks and one in Lehigh that will be evaluated on the evening of November 18.* The interview of Pennsylvania State Police traffic control/access control points will be from 10:00 a.m. -12:00 noon November 18, 2015.Assumptions Assumptions constitute the implied factual foundation for the exercise and, hence, are assumed to be present before the start of the exercise.

The following general assumptions apply to the 2015 Limerick Generating Station Evaluated Full Scale Exercise:*The exercise will be graded against the REP criteria.

Elements outside the scope of the REP criteria will not be graded.*This exercise will be conducted in a no-fault learning environment wherein systems and processes, not individuals, will be evaluated.

• Exercise simulation will be realistic and plausible, containing sufficient detail from which to respond.99 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* Exercise players will react to the information and situations as they are presented, in the same manner as if this had been a real event.Constructs and Constraints Constructs are exercise devices designed to enhance or improve exercise realism. Alternatively, constraints are exercise limitations that may detract from exercise realism. Constraints may be the inadvertent result of a faulty construct or may pertain to financial and staffing issues.Although there are a number of constructs and constraints (also known as exercise artificialities) for any exercise, the EPT recognizes and accepts the following as necessary:

• Exercise communication and coordination will be limited to the participating exercise venues and the Simulation Cell (SimCell).

• Only those communication methods listed in the Communication Directory will be available for players to use during the exercise.* Out-of-Sequence play is allowed.* Certain simulations are allowed.The participating agencies may need to balance exercise play with real-world emergencies.

It is understood that real-world emergencies will take priority.Exercise Participants The following are the categories of participants involved in this exercise; note that the term"participant" refers to all categories listed below, not just those playing in the exercise:*Players.

Players are agency personnel who have an active role in responding to the simulated emergency and perform their regular roles and responsibilities during the exercise.

Players initiate actions that will respond to and mitigate the simulated emergency.

• Controllers.

Controllers set up and operate the exercise site; plan and manage exercise play; act in the roles of response individuals and agencies not playing in the exercise.Controllers direct the pace of exercise play and routinely include members from the exercise planning team. They provide key data to players and may or initiate certain player actions to ensure exercise continuity.

• Simulators.

Simulators are control staff personnel who role-play as nonparticipating organizations or individuals.

They most often operate out of the SimCell, but may occasionally have face-to-face contact with players. Simulators function semi-independently under the supervision of SimCell controllers, enacting roles (e.g., as media reporters or next of kin) in accordance with instructions provided in the Master Scenario Events List (MSEL). All simulators are ultimately accountable to the Exercise Director and/or the Senior Controller.

• Evaluators.

Evaluators are chosen to evaluate and provide feedback on a designated functional area of the exercise.

They are chosen based on their expertise in the functional 100 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station area(s) they have been assigned to review during the exercise and their familiarity with local emergency response procedures.

Evaluators assess and document participants' performance against established emergency plans and exercise evaluation criteria, in accordance with HSEEP standards and within the bounds of REP Program guidance and regulations.

They are typically chosen from amongst planning committee members or the agencies/organizations that are participating in the exercise.

FEMA Evaluators will not serve as Controllers.

• Actors. Actors are exercise participants who act or simulate specific roles during exercise play. They are typically volunteers who have been recruited to play the role of victims or other bystanders.

• Observers.

Observers visit or view selected segments of the exercise.

Observers do not play in the exercise, and do not perform any control or evaluation functions.

Observers will view the exercise from a designated observation area and will be asked to remain within the observation area during the exercise.

VIPs are a type of observer, but are frequently grouped separately.

A dedicated group of exercise Controllers should be assigned to manage these groups. PEMA will provide observers to risk municipalities to observe and document activity at evaluated and non-evaluated OROs.*Media Personnel.

Some media personnel may be present as observers pending approval by the Exercise Director in coordination with the PEMA Press Office. Media interaction may also be simulated by the SimCell to enhance realism and meet related exercise objectives.

A dedicated group of exercise controllers should be assigned to manage these groups.*Support Staff. Exercise support staff includes individuals who are assigned administrative and logistical support tasks during the exercise (i.e. registration, catering, etc.)Exercise Tools Controller Handbook The 2015 Limerick Generating Station Evaluated Full Scale Exercise CiE Handbook is designed to help exercise Controllers and evaluators conduct and evaluate an effective exercise.

This Handbook also enables Controllers and Evaluators to understand their roles and responsibilities in exercise execution and evaluation.

Should a Player, Observer, or media representative find an unattended Handbook, it should be provided to the nearest Controller or Evaluator.

PEMA determine if a Controller Handbook will be used.Master Scenario Events List The MSEL outlines benchmarks, as well as injects that drive exercise play. It also details realistic input to the exercise players, as well as information expected to emanate from simulated organizations (i.e., those nonparticipating organizations, agencies, and individuals who would usually respond to the situation).

An inject will include several items of information, such as 101 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station inject time, intended recipient, responsible controller, inject type, a short description of the event, and the expected player action.Exercise hnplementation Exercise Play Exercise play will begin at approximately 4:00 p.m. on November 17, 2015 with a situation update going to each participating venue. Play will proceed according to the events outlined in the MSEL, in accordance with established plans and procedures.

The exercise will conclude upon the completion of operations and attainment of the exercise objectives, as determined by FEMA and the Utility.Exercise Rules The following are the general rules that govern exercise play:* Real-world emergency actions take priority over exercise actions.* Exercise participants will comply with real-world response procedures, unless otherwise directed by control staff.* All communications (written, radio, telephone, etc.) made during the exercise will begin and end with the phrase, "This is an exercise.

" Exercise participants placing telephone calls or initiating radio communication with the SimCell must identify the organization, agency, office, and/or individual with whom they wish to speak.Safety Requirements General Exercise participant safety takes priority over exercise events. Although the organizations involved in the 2015 Limerick Generating Station Evaluated Full Scale Exercise come from various response agencies, they share the basic responsibility for ensuring a safe environment for all personnel involved in the exercise.

In addition, aspects of an emergency response are dangerous.

Professional health and safety ethics should guide all participants to operate in their assigned roles in the safest manner possible.

The following general requirements apply to the exercise:* All exercise controllers, evaluators, and staff will serve as safety observers while the exercise activities are underway.

Any safety concerns must be immediately reported to the Lead Controller.

• Participants will be responsible for their own and each other's safety during the exercise.It is the responsibility of all persons associated with the exercise to stop play if, in their 102 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station opinion, a real safety problem exists. Once the problem is corrected, exercise play can be restarted.

• All organizations will comply with their respective environmental, health, and safety plans and procedures, as well as the appropriate Federal, State, and local environmental health and safety regulations.

Exercise Setup Exercise setup involves the pre-staging and dispersal of exercise materials; including registration materials, documentation, signage, and other equipment as appropriate.

Accident Reporting and Real Emergencies

• Anyone observing a participant who is seriously ill or injured will first advise the nearest controller, then if possible, render aid, provided the aid does not exceed his or her training.*The controller who is made aware of a real emergency will initiate the broadcast"Real- World Emergency" on the controller radio network, providing the following information to the Senior Controller and Exercise Director: o Venue/function o Location within the venue/function o Condition o Requirements

• The SimCell will be notified as soon as possible if a real emergency occurs.* If the nature of the emergency requires a suspension of the exercise at the venue/function, all exercise activities at that facility will immediately cease. Exercise play may resume at that venue/function once the "Real-World Emergency" situation has been addressed.

• Exercise play at other venue/functions should not cease if one venue/function has declared a "Real-World Emergency" unless they are reliant on the affected venue.*If a real emergency occurs that affects the entire exercise, the exercise may be suspended or terminated at the discretion of the Exercise Director and Senior Controller.

The notification will be made from the SimCell.Site Access Observer Coordination Each organization with observers will coordinate with the PEMA and the Utility for access to the exercise site. Observers will be escorted to an observation area for orientation and conduct of the exercise.

All observers will be asked to remain within the designated observation area during the exercise.

Designated PEMA or Utility representatives and/or the Observer Controller will be 103 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station present to explain the exercise program and answer questions for the observers during the exercise.PEMA Observers and Liaison Officers PEMA will assign Observers and Liaison Officers to each County and Municipal Emergency Operations Center that is being evaluated in the 2015 Limerick Generating Station Evaluated Full Scale Exercise.

The Lead Controller will provide a list of Observers and Liaison Officers to the appropriate Off-Site Response Organizations prior to the day of the exercise.

All Observers and Liaison Officers will receive a pre-exercise briefing.PEMA Observers are not intended to be players and should excuse themselves from any active participation in the exercise.

If an Observer is engaged in any way by one of the exercise players he/she should refer the player to the PEMA Liaison Officer.PEMA Liaison Officers ar___e players and are assigned specific responsibilities for the exercise.Liaison Officers are instructed to call into the State Emergency Operations Center (SEOC) upon arrival at the exercise venue. They are required to confirm their arrival and provide to the SEOC Watch Officer phone numbers at which they can be reached during the exercise.

Liaison Officers are allowed to interact in the exercise as a PEMA representative and are sometimes required to provide injects to facilitate exercise play.Exercise Identification Identification badges may be issued to exercise staff. All exercise personnel and observers will be identified by badges distributed by the staff from each participating agency.Communications Plan Exercise Start, Suspension, and Termination Instructions The exercise is scheduled to run for eight (8) hours or until the Lead Controller in coordination with FEMA and the Utility determines that the exercise objectives have been met. The Lead Controller will announce the exercise suspension or termination through the State Emergency Operations Center (SEOC).Player Communication Players will use routine, in-place agency communication systems. Additional communication assets may be made available as the exercise progresses.

The need to maintain capability for a real-world response may preclude the use of certain communication channels or systems that would usually be available for an actual emergency incident.

In no instance will exercise.104 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station communication interfere with real-world emergency communications.

Each venue will coordinate its own internal communication networks and channels.The primary means of communication among the SimCell, Controllers, and the venues will be telephone.

A list of key telephone and fax numbers, and radio call signs will be available as a Communication Directory before the start of the exercise.Player Briefing Controllers/Evaluators may be required to read specific scenario details to the participants to begin exercise play. They may also have technical handouts or other materials to give to players in order to better orient them to the exercise environment.

Public Affairs Joint Information Centers will be established at both the Utility Emergency Operations Facility and the State Emergency Operations Centers. Actors will play the role of reporters "public briefings will be given as they would for a real incident." These "public briefings will be simulated and not broadcast for the public." The briefings will be available for viewing at the County EOCs.Any participation by the actual media will be coordinated through the Exercise Director in conjunction with the PEMA Public Information Office.This exercise enables Players to demonstrate an increased readiness to deal with a nuclear power plant incident.

Any nuclear power plant exercise may be a newsworthy event. Special attention must be given to the needs of the media, allowing them to get as complete and accurate a story as possible while ensuring their activities do not compromise the exercise realism, safety, or objectives.

Exelon, FEMA, PEMA, and involved counties are responsible for disseminating public information in advance of the exercise.105 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Chapter 3: Player Guidelines Exercise Staff Exercise Director The Exercise Director has the overall responsibility for planning, coordinating, and overseeing all exercise functions.

The Exercise Director for the 2015 Limerick Generating Station Evaluated Full Scale Exercise is the Regional Assistance Committee (RAC) Chair. He/she manages the exercise activities and maintains a close dialogue with the Controllers regarding the status of play and the achievement of the exercise design objectives.

The FEMA Region III RAC Chair for the Limerick Generating Station has authority to make determinations concerning evaluation issues and re-demonstrations.

The PEMA Limerick Generating Station Planner has responsibility to organize and lead the Exercise Planning Team.Trusted Agents Trusted agents are exercise planners and participants who are responsible for developing the Scenario and the Master Scenario Events List (MVSEL). These documents are restricted and are not available to the rest of the Exercise Planning Team, Players, or other Participants.

The trusted agents for the 2015 Limerick Generating Station Evaluated Full Scale Exercise include the Exercise Director, Lead Controller, Bureau of Radiation Protection (BRP) Representative, FEMA Emergency Management Program Specialist, and the Radiological Emergency Preparedness Regional Assistance Committee (RAC) Chair.Lead Controller The Lead Controller also functions as a Trusted Agent. As such he is involved in developing the Master Scenario Events List and is privy to the scenario used at the utility to generate exercise play. The Lead Controller is responsible for scheduling controllers at the "Out-of-Sequence" components of the exercise and the 2015 Limerick Generating Station Evaluated Full Scale Exercise.

The Lead Controller monitors exercise progress and coordinates decisions regarding deviations or significant changes to the scenario caused by unexpected developments during play. The Lead Controller monitors actions by individual Controllers and ensures they implement all designated and modified actions at the appropriate time. The Lead Controller will be the PEMA REP Staff designee and is stationed in the State BOC during the Exercise.The Lead Controller is responsible for the overall organization of the 2015 Limerick Generating Station Evaluated Full Scale Exercise.

The Lead Controller monitors exercise progress and coordinates decisions regarding deviations or significant changes to the scenario caused by unexpected developments during play. The Lead Controller monitors actions by individual Controllers and ensures they implement all designated and modified actions at the appropriate 106 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station time. The Lead Controller debriefs the Controllers after the exercise and oversees the setup and takedown of the exercise.Controllers At least one observer, liaison, or controller will be onsite with every facility and field team participating in the exercise, and at each out-of-sequence interview.

The Lead Facility Controller at each location will coordinate any changes that impact the scenario or affect other areas of play through the Lead Controller.

The individual controllers issue exercise materials to players as required and monitor the exercise.

Controllers or liaison also provide injects to the players as described in the MSEL.Lead Evaluator The Lead Evaluator is responsible for the overall evaluation of the 2015 Limerick Generating Station Evaluated Full Scale Exercise.

The Lead Evaluator monitors exercise progress and stays in contact with the Lead Controller regarding changes to the exercise during play. The Lead Evaluator monitors actions of individual Evaluators and ensures they are tracking progress of the players in accordance with the Extent-of-Play.

The Lead Evaluator debriefs the evaluators after the exercise and oversees the entire evaluation and After Action process.Evaluators Evaluators work under the direction of the Lead Evaluator, and as a team with Controllers.

Evaluators are SMEs who record events that take place during the exercise and assess/submit documentation for review and inclusion in the After Action Report (AAR).Before the Exercise* Review the appropriate emergency plans, procedures, and exercise support documents.

• Be at the appropriate site at least 30 minutes before the start of the exercise.

Wear appropriate uniform/identification badge.* If you gain knowledge of the scenario before the exercise, notify a controller so that appropriate actions can be taken to ensure a valid evaluation.

• Read your Player Information Handout, which includes information on exercise safety.* Please sign in.107 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station During the Exercise*Respond to the exercise events and information as if the emergency were real, unless otherwise directed by an exercise controller.

• Controllers will only give you information they are specifically directed to disseminate.

You are expected to obtain other necessary information through existing emergency information channels.*Do not engage in personal conversations with controllers, evaluators, observers, or media personnel while the exercise is in progress.

If you are asked an exercise-related question, give a short, concise answer. If you are busy and cannot immediately respond, indicate so, but report back with an answer at the earliest time possible.* If you do not understand the scope of the exercise or if you are uncertain about an organization's or agency's participation in an exercise, ask a controller.

• Parts of the scenario may seem implausible.

Recognize that the exercise has objectives to satisfy and may require the incorporation of unrealistic aspects. Note that every effort has been made by the trusted agents to balance realism with safety and the creation of an effective learning and evaluation environment.

• All exercise communication will begin and end with the phrase "This is an exercise." This is a precaution taken so anyone overhearing the conversation will not mistake the exercise play for a real-world emergency.

• When communicating with the SimCell, identify the organization, agency, office, and/or individual with which you want to speak.*Verbalize out loud when taking an action. This will ensure that evaluators are made aware of critical actions as they occur.*Maintain a log of your activities.

Many times, this log may include documentation of activities missed by a controller or evaluator.

Following the Exercise*At the end of the exercise at your facility, participate in the brief critique with the controllers and evaluators.

• Complete the Participant Feedback Form. This form allows you to comment candidly on emergency response activities and effectiveness of the exercise.

Please provide the completed form to a controller or evaluator.

• Provide any notes or materials generated from the exercise to your controller or evaluator for review and inclusion in the AAR.108 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Simulation Guidelines Because the 2015 Limerick Generating Station Exercise is of limited duration and scope, the physical description of what would fully occur at the incident sites and surrounding areas will be relayed to the Players by Simulators or Controllers.

If a real emergency occurs during the exercise, the exercise at your respective venue may be suspended or terminated at the discretion of the controller(s) at each venue. If a real emergency occurs, say "Real-World Emergency" and notify the nearest Controller and Evaluator.

109 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Chapter 4: Evaluation and Post-Exercise Activities Exercise Documentation The goal of the 2015 Limerick Generating Station Evaluated Full Scale Exercise is to comprehensively exercise and evaluate the OROs' plans and capabilities as they pertain to a potential nuclear power plant incident.

After the exercise, data collected by Controllers, Evaluators, the SimCell, and Players will be used to identify strengths and areas for improvement in the context of the exercise design objectives.

Exercise Evaluation Guides DHS has developed Exercise Evaluation Guides (EEGs) that identify expected activities for evaluation, provide consistency across exercises, and link individual tasks to disciplines and expected outcomes.The Federal Emergency Management Agency (FEMA) Region III has decided not to use EEG's as part of Exercise Documentation process.Players Critique Immediately following the completion of exercise play, Controllers will facilitate a critique with Players from their assigned location.

The critique is an opportunity for Players to voice their opinions on the exercise and their own performance.

At this time, Controllers can also seek clarification on certain actions and what prompted Players to take them. The critique should not last more than 30 minutes. Controllers should take notes during the critique and include these observations in their analysis.Hotwash Prior to the Participants and Public/Media Briefing, The Federal Emergency Management Agency (FEMA) will facilitate a Hotwash with the State, Risk and Support Counties, local jurisdictions and agencies participating in the exercise.

The Hotwash is an opportunity for evaluators and participants to voice preliminary performance concerns, demonstrated strengths, and thank those who played. At this time,. Evaluators can also seek clarification on certain actions and what prompted Players to take them. Evaluators should take notes during the Hotwash and include these observations in their analysis, if necessary.

The Hotwash will be held at 3:00 p.m. on Thursday, November 19, 2015 at the Courtyard Valley Forge/Collegeville, 600 Campus Drive, Collegeville, Pennsylvania 19426.110 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Participants and Public/Media Briefings The Participants Briefing will be conducted on Friday November 20, 2015 at 10:00 a.m. at Courtyard Valley Forge/Collegeville, 600 Campus Drive, Collegeville, Pennsylvania 19426.The Public/Media Briefing will also be conducted on Friday November 20, 2015 at 11:00 a.m. at the same location mentioned above.After Action Report The AAR is the culmination of the exercise.

It is a written report outlining the strengths and areas for improvement identified during the exercise.

The AAR will include the timeline, executive summary, scenario description, performance issues, planning issues, deficiencies, and capability analysis.

The AAR will be drafted by a core group of individuals from the exercise planning team.After Action Conference and Improvement Plan The improvement process represents the comprehensive, continuing preparedness effort of which the 2015 Limerick Generating Station Evaluated Full Scale Exercise is a part. The lessons learned and recommendations from the AAR will be incorporated into the Improvement Plan (IP).After Action Conference The After Action Conference (AAC) will be scheduled for approximately 90 days following the exercise, is a forum for jurisdiction officials to hear the results of the evaluation analysis, validate the findings and recommendations in the draft AAR, and begin development of the IP.Improvement Plan The IP identifies how recommendations will be addressed, including what actions will be taken, who is responsible, and the timeline for completion.

It is created by key stakeholders from the 2015 Limerick Generating Station Evaluated Full Scale Exercise participating agency officials during the AAC.Iii Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Annex A: Exercise Schedule Table A.1 2015 Limerick Generating Station Exercise Schedule TCF, DEP/BRP Field Monitoring Teams 112 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Table A.2 2015 Limerick Generating Station Exercise Out-of-Sequence Schedule A u g u st 1 1 ,,2 0 1 5 .. .. ..,:.. ... ...: : .... .. ..... ... : : .. Completed Brandywine Hospital, Chester MS-i Hospital Federal___________jCounty Evaluation Various times Mass Care Facilities in Berks, Mass Care Walkdown Bucks, Chester, Montgomery, Inspections by PEMA, FEMA, and Lehigh Counties American Red Cross and County Personnel N ovem ber 17, 2015 ... ....." .... :.. .. ... .:: : -: :. ...9:00 -11:00 a.m. 23 Pennsylvania Schools will be School Demonstrations evaluated in 13 school districts in Berks, Chester, and Montgomery Counties.Noeber 18, 2015 10:00 -12:00 noon PSP Skippack Barracks, in TCP/ACP Deployment and Schwenksville, Montgomery manning Interview and County Briefing of concepts to Evaluators 7:00 p.m. -9:30 p.m. Selected Reception, Mon/Decon Mass Care, Reception Center, Centers/Stations and Mass Care and Decontamination Station Facilities in Berks, Bucks, Demonstration Evaluations Chester, Lehigh and Montgomery Counties 113 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Annex B: Method of Operation and Extent-of-Play See PEMA Extent-of-Play 114 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Annex C: Participating Agencies and Site Maps Not Used 115 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Annex D: Addresses of Locations to be Evaluated Not Used 116 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Annex E: Open Issues No Open Issues 117 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION EXTENT-OF-PLAY 2015 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE 118 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportflImprovement Plan Limerick Generating Station THIS PA GE IS INTENTIONALL Y LEFT BLANK 119 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportllmprovement Plan Limerick Generating Station Table of Contents METHOD OF OPERATION

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121 I. Limerick Generating Station (LGS).......................................................

121 II. Bureau of Radiation Protection (BRP)....................................................

121 III. PEMA Operations at State EOC........................................................

121 IV. PEMA Area Office Operations..........................................................

122 V. Counties Designated to Participate........................................................

122 VI. PEMA Liaison Officers ...................................................................

122 VII. Controllers..................................................................................

122 VIII. PEMA Observers

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123 IX. FEMA Evaluators.........................................................................

123 X. Demonstration Windows....................................................................

123 XI. Stand-down.................................................................................

125 XII. General Concepts..........................................................................

125 XIII. Re-demonstrations

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125 EXTENT-OF-PLAY AGREEMENT

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127 EVALUATION AREA 1 .........................................................................

127 EVALUATION AREA 2.........................................................................

137 EVALUATION AREA 3........................................................................

.144 EVALUATION AREA 4.........................................................................

154 EVALUATION AREA 5.........................................................................

159 EVALUATION AREA 6.........................................................................

166 AMERICAN RED CROSS RISK AND SUPPORT COUNTY CHAPTERS:

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173 ATTACHMENT A...............................................................................

176 I. Plume Phase Exercise .......................................................................

176 II. Mass Care Center Walkdowns.............................................................

181 ATTACHMENT B...............................................................................

183 120 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION 2015 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE METHOD OF OPERATION I. Limerick Generating Station (LGS)The facility normally uses off-watch section personnel to participate in the exercise.

The plant's simulated events, radiation readings, and emergency classifications will trigger offsite exercise actions. A pre-approved exercise scenario will be used. LGS will notify the State BOC, the Bureau of Radiation Protection and Risk Counties of emergency classifications.

II. Bureau of Radiation Protection (BRP)BRP personnel will be present at the State BOC, the nuclear facility BOF, Branch and field locations; BRP field teams WILL be evaluated during this exercise.

BRP field teams will perform air sampling out-of-sequence, preferably before they deploy to the plume area.III. PEMA Operations at State BOC This "Method of Operation" Document includes activities for the Full-Scale Plume Exercise (November 17, 2015), and the "Out-of-sequence" Activities (November 18, 2015).A. Plume Exercise -November 17, 2015 PEMA staff, augmented by designated PEMA personnel from the Fire Commissioner's Office, the Bureau of Administration, Technical Services, Planning and Preparedness, plus Emergency Preparedness Liaison Officers (EPLOs) with accompanying response team members from designated state departments/agencies, including representatives from the USDA State Emergency Board will comprise initial operations at the State Emergency Operations Center (EOC). The State EOC will not be evaluated during this exercise.B. Plume Exercise -"Out-of-Sequence" Activities

-November 17, 2015 PEMA staff, augmented by designated PEMA personnel will disseminate exercise related messages to the participating Counties for dissemination to the participating School Districts during the morning of November 17, 2015. The State Emergency Operations Center (EOC) and County EOCs will NOT be 121 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station evaluated during the "Out-of-Sequence" component.

PEMA personnel will serve as "Observers" at the identified School Districts.

C. "Out-of-Sequence" Activities

-November 18, 2015 PEMA personnel will serve as "Observers" at the various field exercise locations during the evening "Out-of-Sequence" component November 18, 2015. An exercise coordinator will remain in the State BOG. The State Emergency Operations Center (BOC) and Counties will NOT be evaluated during the evening"Out-of-Sequence" component.

The Pennsylvania State Police (PSP) demonstration will take place at PSP Skippack Barracks, 2047 C Bridge Road, Schwenksville, Montgomery County.The PSP briefing will be performed out-of-sequence in a demonstration window of 10:00 a.m. to 12:00 noon on November 18, 2015.IV. PEMA Area Office Operations The PEMA Area Office (Hamburg -Eastern Area) will not be activated nor evaluated during this exercise.

Selected staff of the Area Office will serve as Liaison Officers to Risk and Support Counties as assigned.

Liaison Officers are exercise participants.

V. Counties Designated to Participate The three risk counties (Berks, Chester, and Montgomery), in coordination with PEMA, will demonstrate the capability to mobilize appropriate staff, activate their respective Emergency Operations Centers and implement emergency response operations to include sheltering and/or evacuation.

County government will provide direction and coordination to risk municipalities.

The two support counties (Bucks and Lehigh) will participate in their assigned support roles. Actual sheltering or evacuation of the general public will be simulated.

VI. PEMA Liaison Officers Liaison officers will be present at the participating risk and support county EOCs, the LGS Emergency Operations Facility (EOF), and LGS Joint Information Center (JIG) to provide assistance, guidance, and support. These liaison officers will participate as players in the exercise.VII. Controllers A lead controller will be present in the State BOG on November 17, 2015. Controllers will be present at the emergency worker monitoring/decontaminating stations and the mass care monitoring/decontamination centers (November 18, 2015). Controllers are not players. Controllers will provide pre-approved injects and information to the players, as 122 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station appropriate, regarding radiological readings during the monitoring of personnel.

Live radioactive sources will not be used. Exception:

individuals tasked with the setup of portal monitoring equipment will use a standard 1 micro curie Cesium 137 source for the purpose of conducting operational tests. Additionally, appropriate test sources will be available and used to verify' the operation of the monitoring/survey instruments per manufacturer's recommendations.

VIII. PEMA Observers PEMA staff, qualified county emergency management personnel, and/or nuclear power plant personnel will be assigned, if required, to key locations for the purpose of observing, noting response actions and conditions, and recording observations for future use. Observers will not take an active part in the proceedings, but will interact with staff members to the extent necessary to fulfill their observer responsibilities.

Coaching of players by observers is not permitted except to provide training to participants awaiting a re-demonstration. (Refer to paragraph XIII)IX. FEMA Evaluators Federal evaluators will be present at the risk and support county BOCs, identified risk municipal EOCs, and at appropriate field locations to evaluate player response to the actual and simulated events in the exercise scenario.

FEM\A will evaluate approximately one-third of the risk municipalities in B erks, Chester, and Montgomery Counties.Out-of-Sequence Period (November 17 and 18, 2015): On November 17, Federal evaluators will be present at the identified "out-of-sequence" demonstration sites per Attachment A, Section 1. 1. These include the identified Public School Districts and participating school buildings.

On November 18, Federal evaluators will also be present at identified Reception Centers, Emergency Worker Monitoring and Decontamination Stations, Mass Care Centers and Mass Care Monitoring and Decontamination Centers, as identified in Attachment A, Section J.B.l1, I.B.2 and I.B.3.Plume Phase Exercise (November 17, 2015): Federal evaluators will be present at the identified risk and support county EOCs to evaluate player response to the actual and simulated events in the exercise scenario.

Additionally, approximately one-third of the risk municipalities will be federally evaluated.

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

The "demonstration windows" for this exercise are: 123 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limecrick Generating Station A. Plume Phase Exercise The out-of-sequence MS-i hospital demonstration will be federally evaluated at Brandywine Hospital, Chester County on August 11, 2015.The out-of-sequence exercise window for school demonstrations will be between 9:00- 11:00 a.m. on November 17, 2015.The out-of-sequence demonstration of reception centers, mass care centers (as indicated), monitoring/decontamination centers and emergency worker stations will be conducted between 7:00 p.m. -9:30 p.m. on November 18, 2015.Locations are specified within Attachment A,Section I.Thirty six mass care centers (6 in Berks, 15 in Bucks, 6 in Chester, 5 in Lehigh, and 4 in Montgomery) will receive "walkdown" baseline evaluations on October 29th and 3 0 th, 2015. These 36 mass care centers will not be evaluated during the evening of November 18. There are two co-located Mass Care/Monitoring and Decontamination Centers in Berks and one in Lehigh that will be evaluated on the evening of November 18. (Please refer to the Extent-of-Play Demonstfration Tables, Attachment A)124 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station The out-of-sequence interview of Pennsylvania State Police traffic control/access control points will be from 10:00 a.m. -12:00 noon November 18, 2015.All demonstrations will commence promptly and, barring any complications, not continue beyond the time of the designated demonstration window.County and municipal EOC operations will be conducted on November 17, 2015 with exercise period from approximately 4:00 -10:00 p.m. unless terminated by the Lead Controller in coordination with the Utility and PEMA. (Please refer to the Extent-of-Play Demonstration Tables, Attachment A)B. Post Plume Exercise No post-plume phase exercise is scheduled during this evaluation.

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

Upon completion of all requirements and after having informed the FEMA evaluator that all evaluation areas have been demonstrated and/or completed, the risk municipality EOCs may request approval from their county BOC to stand-down their portion of the exercise.A. Support counties may request approval to stand-down upon completion of all evaluated objectives from the state EOC.B. The risk county EOC will remain operational until the exercise is officially terminated by the State Lead Controller.

The State EOC will issue an Exercise Termination Message.XII. General Concepts An emergency plan is drafted to address the generally expected conditions of an emergency.

Not everything in the emergency plan may be applicable for a given scenario.

The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a plan that they cannot take actions that are more protective of the public.Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so that the plan can be modified and the appropriate negative assessment applied.XIII. Re-demonstrations During the exercise, any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants provided it does not negatively interfere with the 125 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station exercise.

Refresher training may be provided by the players, observers, and/or controllers.

Evaluators are not permitted to provide refresher training.

Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators.

PEMA may advise the RAG Chair prior to initiating any re-demonstrations.

It is permissible to extend the demonstration window, within reason, to accommodate the re-demonstration.

Activities corrected from a re-demonstration will be so noted.126 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION 2015 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE EXTENT-OF-PLAY AGREEMENT EVALUATION AREA 1 Emergency Operations Management Sub-element l.a -Mobilization INTENT This Sub-element is derived from NUJREG-0654/FEMA-REP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

Criterion 1.a.l: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner.(NUREG-0654/FEMA-REP-1, A.1.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; 11.3, 4)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, out-of-sequence evaluation or by means of drills conducted at any time.Responsible OROs must demonstrate the capability to receive notification of an incident from the licensee; verify the notification; and contact, alert, and mobilize key emergency personnel in a timely manner and demonstrate the ability to maintain and staff 24-hour operations.

Twenty-four-hour operations can be demonstrated during the exercise via rosters or shift changes or otherwise in an actual activation.

Local responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner, when they receive information from the licensee or alternate sources. Responsible OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. Activation of facilities and staff, including those associated with the Incident Command System, must be completed in accordance with ORO plans/procedures.

The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP after these facilities have been activated.

Pre-positioning of emergency personnel is appropriate, in accordance with the Extent-of-Play Agreement, at those facilities located beyond a normal commuting distance from the individual's duty location or residence.

This includes the staggered release of resources from an assembly 127 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station area. Additionally, pre-positioning of staff for out-of-sequence demonstrations may be used in accordance with the Extent-of-Play Agreement.

The REP program does not evaluate Incident Command System tactical operations, only coordination among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

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

The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

Exercises must also address the role of mutual aid in the incident, as appropriate.

An integral part of the response to an HAD scenario at an NPP may also be within the auspices of the Federal Government (e.g., FBI, NRC, or DHS). Protocols for requesting Federal, State, local, and Tribal law enforcement support must be demonstrated, as appropriate.

Any resources must be on the ORO's mobilization list so they can be contacted during an incident, if needed.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

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

Risk counties/municipalities will conduct call-outs to demonstrate the mobilization of key personnel.

The utility JIC will be evaluated for this drill.* Actual calls (or pager notifcations) will be made to the county/municipal EOC personnel for the Plume Phase exercise per plans and procedures.

• In all instances, the demonstration of a shift change is NOT required.

Twenty-four hour staffing will be demonstrated by means of a roster or staffing chart.* All out-of-sequence players will be pre-positioned and equipment will be demonstrated or shown to be inventory (School District personnel, PSP TCP/ACP, Reception Centers, Emergency Worker Monitoring and Decontamination Stations Mass Care/Sheltering Centers and Monitoring and Decontamination Centers).* Individuals working in state facilities and county EOCs may be pre-positioned for the plume phase.* Other locations, including Municipal EOCs, will NOT pre-stage but will wait for notifi cation of emergency before staffing their duty location.Sub-element 1.b -Facilities INTENT 128 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have facilities to support the emergency response.Criterion 1.b.1: Facilities are sufficient to support the emergency response.(NUREG-0654/FEMA-REP-1, 11.3; G.3.a; J.10.h; J.12; K.5.b)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, SAVs, or by out-of-sequence evaluations.

Responsible OROs must demonstrate, no less than once every 8 years, the availability of facilities to support accomplishment of emergency operations (this includes all alternate and backup facilities).

Evaluations are typically performed for EOCs and JI~s, as well as other facilities such as reception/relocation centers. Some of the areas evaluated within the facilities are adequate space, furnishings, lighting, restrooms, ventilation, access to backup power, and/or alternate facility, if required to support operations.

Radio stations, laboratories, initial warning points and hospitals are not evaluated under 1 .b. 1.In addition, facilities will be evaluated for this criterion during the first biennial exercise after any new or substantial changes in structure, equipment, or mission that affect key capabilities, as outlined in respective emergency plans/procedures.

A substantial change is one that has a direct effect or impact on emergency response operations performed in those facilities.

Examples of substantial changes include modifying the size or configuration of an emergency operations center, adding more function to a center, or changing the equipment available for use in a center.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.

PEMA Negotiated Extent-of-Play:

None Sub-element 1.c -Direction and Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to control their overall response to an emergency.

Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.(NUREG-0654/IFEMA-REP-1, A.1.d; A.2.a, b; A.3; C.4, 6)Assessment!Extent-of-Play 129 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Assessment of this Demonstration Criterion may be accomplished in a biennial or tabletop exercise.Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through periodic briefings and/or other means, coordinating with other 0R~s, and ensuring completion of requirements and requests.)

Leadership must demonstrate the ability to prioritize resource tasking and place/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources.

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

PEMA Negotiated Extent-of-Play None 130 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Sub-element 1.d -Communications Equipment INTENT This Sub-element is derived from NUREG-0654iFEMA-REP-1, which requires that OROs establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the EPZ, Federal emergency response organizations, the licensee and its facilities, BOCs, Incident Command Posts, and FMTs.Criterion 1.d.l: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations.(NUREG-0654/FEMA-REP-1, F.1, 2)Assessment/Extent-of-Play Assessment of this Demonstration Criterion is accomplished initially in a baseline evaluation and subsequently in periodic testing and drills. System familiarity and use must be demonstrated as applicable in biennial or tabletop exercise, or if their use would be required, during an actual event.OROs must demonstrate that a primary system, and at least one backup system for fixed facilities, is fully functional at all times. Communications systems are maintained and tested on a recurring basis throughout the assessment period and system status is available to all operators.

Periodic test results and corrective actions are maintained on a real time basis. If a communications system or systems are not functional, but exercise performance is not affected, no exercise issue will be assessed.Communications equipment and procedures for facilities and field units are used as needed for transmission and receipt of exercise messages.

All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations.

OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. Exercise scenarios may require the failure of a communication system and use of an alternate system, as negotiated in the Extent-of-Play Agreement.

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.

PEMA Negotiated Extent-of-Play:

131 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Risk and Support Counties will communicate with the State EOC via SE VAN (primary) and e-mail (secondary.)

PASTAR, State 800 MHz Radio System, and commercial telephone are available for back-up. The State EOC may communicate with the utility and the risk counties via dedicated telephone circuits, commercial "dial-up" lines, or other available means.Risk Counties will communicate with their risk municipalities via public safety radio frequencies (EM4 Radio), Commercial Telephone, Fax, or Amateur Radio Communications (ARES/RACES) or other available means.132 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Sub-element i.e -Equipment and Supplies to Support Operations INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.Criterion 1.e.1: Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (KI1) and other supplies are sufficient to support emergency operations.(NUREG-0654/FEMA-REP-1, 11.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b)Assessment/Extent-of-Play Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation and subsequent periodic inspections.

A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is encouraged.

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.

Specific equipment and supplies that .must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows: KI1: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transients) within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures).

The plans/procedures must include the forms to be used for documenting emergency worker ingestion of RI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined RI in advance.ORG quantities of dosimetry and RI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV.Available supplies of RI must be within the expiration date indicated on RI bottles or blister packs. As an alternative, the ORG may produce a letter from a certified private or State laboratory indicating that the RI supply remains potent, in accordance with U.S. Pharmacopoeia standards.

133 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Dosimetry:

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

Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures.

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

The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary.

Civil Defense Victoreen Model 138s (CD V-138s) (0-200 mnR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary.

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

All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation must be calibrated annually.

Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer.

A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings.

The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source.For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta radiation.

These instruments must be capable of measuring a range of activity and exposure, including radiological protection

/ exposure control of team members and detection of activity on air sample collection media, consistent with the intended use of the instrument and the ORO's plans/procedures.

An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than 1R/hr) and for high-range instruments when available.

If a source is not available for a high-range instrument, a procedure must exist to operationally test the instrument before entering an area where only a high-range instrument can make useful readings.In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s).

The monitor(s) must conform to the standards set forth in the Contamination 134 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-2 1 (March 1995) or in accordance with the manufacturer's recommendations.

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.

Mutual Aid Resources:

If the incoming resources arrive with their own equipment (i.e., monitors and/or dosimetry), they will be evaluated by REP Program standards.

FEMA will not inventory equipment that is not part of the REP Program. If an agency has a defined role in the REP Plan, they are subject to the planning process and standards, as well as the guidance of this Manual.135 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station PEMA Negotiated Extent-of-Play:

In Pennsylvania support counties do not have DRDs, or KI, but those responsible for reception centers and/or monitoring and decontamination centers will have PRDs.Evaluation of DRD and KI quantities will be verified using inventory sheets. DRDs and KI will not be removed from storage locations and boxes/packages will not be opened. K! questions will be addressed through interviews.

Leakage testing verifi cation and K! extension letters (as appropriate) will be available to the evaluator.

All DRDs "read" in units of Roentgens.

The commonwealth, counties and municipalities do not use direct reading dosimeters which "read" in units of milli-Roentgens.

136 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 2 Protective Action Decision Making Sub-element 2.a -Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans/procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates that emergency workers may be permitted to incur during an emergency.

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

Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers, including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.(NUREG-0654/FEMA-REP-1, C.6; f; K.3.a; K.4)Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be assessed concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures.

Participating OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. This would include providing 1(I and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

As appropriate, OROs must demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for emergency workers, based on their plans/procedures or projected thyroid dose compared with the established PAGs for KI administration.

137 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

None 138 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Sub-element 2.b. -Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PAGs.OROs must have the capability to choose, among a range of protective actions, those most appropriate in a given emergency.

OROs base these choices on PAGs from their plans/procedures or EPA' s Manual of Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria, such as plant conditions, licensee PARs, 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.l: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions.(NUREG-0654/FEMA-REP-1, 1.10 and Supplement 3)Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORG must demonstrate the capability to use appropriate means, described in the plans/procedures, to develop PARs for decision-makers based on available information and recommendations provided by the licensee as well as field monitoring data, if available.

The ORG must also consider any release and meteorological data provided by the licensee.The ORG must demonstrate a reliable capability to independently validate dose projections.

The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs must be appropriate to the scenario.

In all cases, calculation of projected dose must be demonstrated.

Projected doses must be related to quantities and units of the PAG to which they will be compared.

PARs must be promptly transmitted to decision-makers in a prearranged format.When the licensee and ORG projected doses differ by more than a factor of 10, the ORG and licensee must determine the source of the difference by discussing input data and assumptions, 139 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the PARs if timely and appropriate.

The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

140 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station PEMA Negotiated Extent-of-Play:

This sub-element will not be evaluated during this exercise.Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PAIDs) for the general public (including the recommendation for the use of KIt, if ORO policy).(NUREG-0654/FEMA-REP-1,A.3; C.4, 6; D.4; J.9; J.10.e, f; m)Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions.

OROs must demonstrate the capability to make initial precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAD incident, weather, release timing and magnitude) pose undue risk to an evacuation, or if evacuation may disrupt the efforts to respond to a hostile action.OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure.

Dose assessment personnel may provide additional PARs based on the subsequent dose projections, field monitoring data, or information on plant conditions.

In addition, incident command must provide input regarding considerations for subsequent PARs based on the magnitude of the ongoing threat, the response, and/or site conditions.

The decision-makers must demonstrate the capability to change protective actions based on the combination of all these factors.If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation.

This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established PAG for KI administration.

The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff.If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or protective action decisions with each other. In addition, 141 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

None Sub-element 2.c -PAD Consideration for the Protection of Persons with Disabilities and Access/Functional Needs INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to determine precautionary and/or protective action decisions, including evacuation, sheltering, and use of RI, if applicable, for groups of persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals).

The focus is on those groups of persons with disabilities and access/functional needs that are, or potentially will be, affected by a radiological release from an NPP.Criterion 2.c.1: Precautionary and/or protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs.(NUREG-0654/FEMA-REP-1, D.4; J.9; J.10.d, e)Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise that would include the use of plant conditions transmitted from the licensee.Usually it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range of PAGs, except for incidents where there is a high-risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved.In these cases, factors that must be considered include weather conditions, shelter availability, availability of transportation assets, risk of evacuation versus' risk from the avoided dose, and precautionary school evacuations.

In addition, decisions must be coordinated/communicated with the incident command. In situations where an institutionalized population cannot be evacuated, the ORG must consider use of RI.Applicable OROs must demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective 142 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station actions for students.

Demonstration requires that the OROs actually contact public school systems/districts during the exercise.The OROs must demonstrate how the decision-making process takes those with disabilities and access/functional needs (e.g., nursing homes, correctional facilities, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals) into account.In accordance with plans/procedures, OROs and/or officials of public school systems/districts must demonstrate the capability to make prompt decisions on protective actions for students.The decision-making process, including any preplanned strategies for protective actions for that ECL, must consider the location of students at the time (e.g., whether the students are still at home, en route to school, or at school).Since other agencies place requirements on hospitals to prepare for contaminated patients, the REP Program has no need to evaluate host hospitals, nor does the ORO have the responsibility to provide training or dosimetry.

Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

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

Sub-element 2.d. -Radiological Assessment and Decision Making for the Ingestion Exposure Pathway This sub-element will not be evaluated during this exercise.Sub-element 2.e. -Radiological Assessment and Decision-Making Concerning Post-Plume Phase Re~location, Reentry, and Return This sub-element will not be evaluated during this exercise.143 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 3 Protective Action Implementation Sub-element 3.a -Implementation of Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide for the following:

distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KI for emergency workers, always applying the "as low as is reasonably achievable" principle as appropriate.

Criterion 3.a.1: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to emergency workers.(NUREG-0654/FEMA-REP-1, K.3.a, b; K.4)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise.

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

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures.

If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.144 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 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 determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge of whom to contact in case authorization is needed, and at what exposure levels.Workers may use any available resources (e.g., written procedures and/or coworkers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. In such cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimeter worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry.

Individuals authorized by the ORG to reenter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with completing their missions.OROs may have administrative limits lower than EPA-400-R-92-00 1 dose limits for emergency workers performing various services (e.g., lifesaving, protection of valuable property, all activities).

OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response.OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s)they did so. Ingestion of KI recommended by the designated ORG health official is voluntary.

For evaluation purposes, the actual ingestion of KI shall not be performed.

OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. Emergency workers must demonstrate basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.

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

PEMA Negotiated Extent-of-Play:

145 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station Radiological briefings will be provided to address exposure limits and procedures to replace those approaching limits and how permission to exceed limits is obtained from the municipality and county. Emergency workers will also be briefed on when to take K! and on whose authority.

Distribution of K! will be simulated.

A maximum of six (6) Dosimetry-KJ report forms will be demonstrated.

OROs should also demonstrate the use of all applicable dosimetry forms to emergency workers.At any time, players may ask other players or supervisors to clarify radiological information.

In Pennsylvania, emergency workers outside of the EPZ do not have turn-back values.Emergency workers who are assigned to low exposure rate areas, (e.g., at reception centers, counting laboratories, emergency operations centers, and communications centers) may have individual direct reading dosimeters or they may be monitored by dosimeters strategically placed in the work area. In Pennsylvania this will be accomplished through the use of an area kit. The area kit process is explained in State, County and Municipal Plans.Standard issue of dosimetry and potassium iodide for each category of emergency worker is as follows: Category A: 1 PRD, 1 DRD, and 1 unit of K!Cate gory B: 1 PRD and 1 unit of K!Category C.. 1 PPD All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP), will make the dosimetry equipment (and KI) available for inspection by the Federal Evaluator.

Simulation PRDs with mock serial numbers will be used.Personnel assigned to operate monitoring/decontamination centers and stations are not issued DRDs or K! since the centers/stations are located outside the EPZ. Each will be issued a simulated PRD with mock serial numbers. For purposes of demonstration, a maximum of six PRDs will be issued.Sub-element 3.b -Implementation of KI Decision for Institutionalized Individuals and the General Public INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide K(1 for institutionalized individuals, and, if in the plans/procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide RI to institutionalized individuals, providing RI to the general public is an ORO option and must be 146 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station reflected as such in ORO plans/procedures.

Provisions must include the availability of adequate quantities, storage, and means of distributing KI.Criterion 3.b.1: KI1 and appropriate instructions are available if a decision to recommend use of KIt is made. Appropriate record-keeping of the administration of KI for institutionalized individuals is maintained. (NUREG-0654/FEMA-REP-1, J.10.e, f)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise.

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

OROs must demonstrate the capability to make 1(1 available to institutionalized individuals, and, where provided for in their plans/procedures, to members of the general public. OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made.OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. Ingestion of KI recommended by the designated ORG health official is voluntary.

For evaluation purposes, the actual ingestion of KI shall not be performed.

OROs must demonstrate the capability to formulate and disseminate instructions on using RI for those advised to take it.147 Unclassified Radiological Emergency Preparedness Program (REP)After Actiont Report/Improvement Plan Limerick Generating Station If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/procedures.

All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

Within Pennsylvania, the Pennsylvania Department of Health is responsible for distribution of K[ to the general public located within the EPZ. Pre-distribution is accomplished on an annual basis. KI is not distributed to the general public at the time of an emergency.

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

Personnel assigned to operate monitoring/decontamination centers and stations are not issued DRDs or K! since the centers/stations are located outside the EPZ. Each will be issued a simulated PRD with mock serial numbers. For purposes of demonstration, a maximum of six PRDs will be issued.Sub-element 3.c -Implementation of precautionary and/or protective action decisions for Persons with Disabilities and Access/Functional Needs INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement precautionary and/or protective action decisions, including evacuation and/or sheltering, for all persons with disabilities and access/functional needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological release from an NPP.Criterion 3.c.1: Precautionary and/or protective action decisions are implemented for persons with disabilities and access/functional needs other than schools within areas subject to protective actions.(NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a~biennial exercise, an actual event, or by means of drills conducted at any time.Applicable 0ROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency information and instructions to) persons with disabilities and access/functional needs, including hospitals/medical facilities, nursing homes, correctional facilities, and mobility-148 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station impaired and transportation-dependent individuals.

OROs must demonstrate the capability to provide for persons with disabilities and access/functional needs in accordance with plans/procedures.

Contact with persons with disabilities and access/functional needs and reception facilities may be actual or simulated, as agreed to in the Extent-of-Play.

Some contacts with transportation providers must be actually contacted, as negotiated in the Extent-of-Play.

All actual and simulated contacts must be logged.Since other agencies place requirements on hospitals to prepare for contaminated patients, the REP Program has no need to evaluate host hospitals, nor does the ORO have the responsibility to provide training or dosimetry.

Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

The names, locations and contact information of identified individuals with identifed special needs are maintained on a list at their respective municipal EOC (based upon residential jurisdiction).

Copies of these lists will not be provided to the evaluators," however, evaluators will be allowed to inspect the lists during the exercise.NOTE: Berks County maintains a countywide special needs list for individuals requiring assistance.

This list may be viewed at the county as it will not be disseminated for exercise purposes.Initial contact, by the County, with special populations (hospitals, nursing homes and county correctional facilities) will be actual. All subsequent calls will be simulated.

Actual contacts (up to two per risk county) will be made with transportation providers per their plan. All actual and simulated contacts should be logged.Criterion 3.c.2: OROs/School officials implement precautionary and/or protective action decisions for schools. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial, or tabletop exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.School systems/districts (these include public and private schools, kindergartens, preschools, and licensed day cares) must demonstrate the ability to implement precautionary and/or protective action decisions for students.

The demonstration must be made as follows: each school systenm/district within the 10 mile EPZ must demonstrate implementation of protective actions.149 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station At least one school per affected system/district must participate in the demonstration.

Canceling the school day, dismissing early, or sheltering in place must be simulated by describing to evaluators the procedures that would be followed.

If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process.If accomplished through an interview, appropriate school personnel including decision-making officials (e.g., schools' superintendent/principals and transportation director/bus dispatchers), and at least one bus driver (and the bus driver's escort, if applicable) must be available to demonstrate knowledge of their role(s) in the evacuation of school children.

Communications capabilities between school officials and the buses, if required by the plans/procedures, must be verified.150 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Officials of the school system(s) must demonstrate the capability to develop and provide timely information to OROs for use in messages to parents, the general public, and the media on the status of protective actions for schools.If a school facility has emergency plans as a condition of licensing, those plans may be submitted to FEMA review in place of demonstration or interview pursuant to the ORO's plans/procedures as negotiated in the Extent-of-Play Agreement.

Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

School students will not be involved during the exercise.

Actions and activities associated with the demonstration of Criterion

3. c.2 will be limited to the School District Administration key personnel and the County. Evacuation of students will be conducted through an interview process with School District personnel or the building principal.

The role of the bus driver may be conducted through an interview with school or transportation officials (or designee) if a bus driver is not available.

Actual demonstration of the bus route is not required and will not be demonstrated.

Maps or route descriptions will be available for illustration purposes.Risk County school plans do not require communications between the school and vehicles.

Bus drivers are not considered emergency workers and therefore do not require dosimetry.

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

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

Any simulated contacts should be logged.Sub-element 3.d. -Implementation of Traffic and Access Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic and access control points, and removal of impediments to the flow of evacuation traffic.151 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Criterion 3.d.1: Appropriate traffic and access control is established.

Accurate instructions are provided to traffic and access control personnel.(NUREG-0654/FEMA-REP-1, A.3; C.1, 4; J.10.g, j)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and PADs (e.g., evacuating, sheltering, and relocation) in a timely manner. OROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas, as per the Extent-of-Play Agreement.

These capabilities may be demonstrated by actual deployment or by interview, in accordance with the Extent-of-Play Agreement.

In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic), they must demonstrate the capability to contact the State or Federal agencies that have the needed authority, as agreed upon in the Extent-of-Play Agreement.

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

Municipal Traffic and Access control will be demonstrated by interview at the applicable EOC of jurisdiction.

The traffic/access control personnel will not be deployed to the traffic/access control point(s).

lIfthe designated assignment is a location within the EPZ, a radiological briefing will be provided to the assigned individuals.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.(NUREG0654/FEMA-REP-1, J.10.k)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.152 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations.

In demonstrating this capability, the impediment must remain in place during the evacuation long enough that re-routing of traffic is required and must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

When, due to specifics of the scenario or jurisdiction, the impediment cannot be located on an evacuation route, it must be located so as to impact the evacuation.

When not possible, actual dispatch of resources need not be physically demonstrated; however, all contacts, actual or simulated, must be logged.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.

PEMA Negotiated Extent-of-Play:

OROs should demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation.

Actual dispatch of resources to deal with impediments, such as tow trucks, need not be demonstrated," however, simulated contacts will be logged If the scenario does not lead to evacuation the criteria shall be deemed complete if the ORO can describe to the evaluator through controller inject or interview the actions they would take to overcome a major traffic impediment during an evacuation and how such actions would be communicated to the public and affected OR Os. (Risk counties only)Sub-element 3.e -Implementation of Ingestion Pathway Decisions This sub-element will not be evaluated during this exercise.Sub-element 3.f -Implementation of Post-Plume Phase Relocation, Reentry, and Return Decisions This sub-element will not be evaluated during this exercise.153 Unclassified Radiological Emergency Preparedness Program (REP)Afttr Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 4 Field Measurement and Analyses Sub-element 4.a -Plume Phase Field Measurements and Analyses INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to deploy FMTs with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUJREG-0654/FEMA-REP-1 indicates that OROs must have the capability to use FMTs within the plume exposure pathway EPZ to detect airborne radioiodine in the presence of noble gases and radioactive particulate material in the airborne plume. In an incident at an NPP, the possible release of radioactive material may pose a risk to-the nearby population and environment.

Although incident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties.

During an incident, it is important to collect field radiological data to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.Criterion 4.a.1: [RESERVED]

Criterion 4.a.2: Field teams (2 or more) are managed to obtain sufficient information to help characterize the release and to control radiation exposure.(NUREG-0654/FEMA-REP-1, C.1; 11.12; 1.7, 8, 11; J.10.a)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise.Other means may include drills that would fully demonstrate technical proficiency.

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

During an H-AB incident, the Field Team management must keep the incident command informed of field monitoring teams' activities and location.

Coordination with FMTs and field monitoring may be demonstrated as out-of-sequence demonstrations, as negotiated in the Extent-of-Play Agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions, or to be a factor in modifying protective actions.Teams must be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts.154 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station If the responsibility for obtaining peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by ORG monitoring teams. If the licensee FMTs do not obtain peak measurements in the plume, it is the ORG's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all FMTs (licensee, Federal, and ORO) is essential.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as necessary.

Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

Department of Environmental Protection (DEP), Bureau of Radiation Protection (BRP) field teams are equipped with the necessary instrumentation and supplies.

FEMA observers will meet the field teams at the R3 V staging area at Wilson Farm Park, 500 Lee Road in Chesterbrook, Pennsylvania at 1:30p.m. on November 17, 2015 to observe instrumentation checks and equipment inventory verification.

Field Team Control will be performed within or near the 10 mile EPZ using the DEP Radiological Rapid Response Vehicle (R3 V). Field Team control is expected to initially be out-of-sequence with the plume timeline.

During the exercise the field teams will be directed to take measurements in locations to provide information sufficient to characterize the plume and impacts. In addition to field team measurements, remote detectors will be located by the field teams near the expected plume pathway, these detectors will automatically transmit data to the R3 V. These detectors will be used to keep field team dose ALARA.Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected.

Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654/IFEMA-REP-1, C.1; 11.12: 1.8, 9; J.10.a)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise.Other means may include drills that would fully demonstrate technical proficiency.

Two or more FMTs must demonstrate the capability to make and report measurements of ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority.

FMTs must also demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and to provide the appropriate authority with field data 155 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station pertaining to measurement.

If samples have radioactivity significantly above background, the authority must consider the need for expedited laboratory analyses of these samples.Coordination concerning transfer of samples, including a chain-of-custody form(s), to a radiological laboratory(ies) must be demonstrated.

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

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Measurements will be made by Department of Environmental Protection (DEP), Bureau of Radiation Protection (BRI), in accordance with the State Annex E, Appendix 6, and BRP Standard Implementing Procedures (1Ps). Two mobile monitoring teams from BRP DEP South East Regional Office will demonstrate ambient radiation monitoring and radioiodine and particulate sampling.

Field teams will be equipped with appropriate dosimetry and K1. Field teams WILL be evaluated by FEMA. Each team will be directed to monitoring locations and perform actual radiation measurements at each location.

Measurements may consist of truck installed radiation monitor or hand-held radiation instruments.

An actual air sample will be taken at the R3 V staging area prior to field team departure to LGS. Field teams will discuss air sample counting procedures via an interview process. Teams will then take additional simulated air samples, as directed, at additional locations, if conditions are appropriate for radioiodine sampling and relay information to the Radiological Rapid Response Vehicle (R3 V). In place of silver zeolite cartridges, charcoal cartridges will be used for the exercise.

All measurements will be forwarded to theR3 V immediately upon obtaining data.FEMA/ observers will meet the field teams at the R3 V staging area at Wilson Farm Park, 500 Lee Road in Chesterbrook, Pa. at 1:30p.m., November 17, 2015.Sub-element 4.b -Post-Plume Phase Field Measurements and Sampling INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess the actual or potential magnitude and locations of radiological hazards to determine the ingestion exposure pathway EPZ and to support relocation, reentry, and return decisions.

This Sub-element focuses on collecting environmental samples for laboratory 156 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station analyses that are essential for decisions on protecting the public from contaminated food and water and direct radiation from deposited materials.

Criterion 4.b.1: The field teams (2 or more) demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision making. (NUREG-0654fFEMA-REP-1, C.1; 1.8; J.11)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise.

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

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

When resources are available, use of aerial surveys and in-situ gamma measurement is appropriate.

All methodology, including contamination control, instrumentation, preparation of samples, and chain-of-custody form(s) for transfer to a laboratory(ies), will be in accordance with the ORO's plans/procedures.

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

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

This sub-element will not be demonstrated during this exercise.Sub-element 4.c -Laboratory Operations INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision making.157 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654/FEMA-REP-1, C.1, 3; J.11)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial, tabletop exercise, or an actual event. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

The laboratory staff must demonstrate the capability to follow appropriate procedures for receiving samples, including logging information, preventing contamination of the laboratory(ies), preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil (e.g., milk), and keeping track of sample identity.

In addition, the laboratory staff must demonstrate the capability to prepare samples for conducting measurements.

The laboratory (ies) must be appropriately equipped to provide, upon request, timely analyses of media of sufficient quality and sensitivity to support assessments and decisions anticipated in the ORO's plans/procedures.

The laboratory instrument calibrations must be traceable to standards provided by the National Institute of Standards and Technology.

Laboratory methods used to analyze typical radionuclides released in a reactor incident must be as described in the plans/procedures.

New or revised methods may be used to analyze atypical radionuclide releases (e.g., transuranics or as a result of a terrorist incident) or if warranted by incident circumstances.

Analysis may require resources beyond those of the ORO.The laboratory staff must be qualified in radioanalytical techniques and contamination control procedures.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

This sub-element will not be evaluated during this exercise.158 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 5 Emergency Notification and Public Information Sub-element 5.a -Activation of the Prompt Alert and Notification System INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide prompt instructions to the public within the plume exposure pathway EPZ. Specific provisions addressed in this Sub-element are further discussed in Section V, Part A of this Manual, Alert and Notification Systems.Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

The initial instructional message to the public must include as a minimum the elements required by current REP guidance. (NUREG-0654/FEMA-REP-1, E.5, 6, 7)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

Responsible OROs must demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas (permanent resident and transient) throughout the 10-mile plume EPZ. Following the decision to activate the alert and notification system, OROs must complete system activation for primary alert/notification and disseminate the information

/ instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of transmission.

Broadcast of the message(s) or test message(s) is not required.

The procedures must be demonstrated up to the point of actual activation.

The alert signal activation should be simulated, not performed.

Evaluations of EAS broadcast stations may also be accomplished through SAVs.The capability of the primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview with appropriate personnel from the primary notification system, including verification of provisions for backup power or an alternate station.The initial message must include at a minimum the following elements: 159 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* Identification of the ORG responsible and the official with authority for providing the alert signal and instructional message;* Identification of the commercial NPP and a statement that an emergency exists there;* Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and* A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the ORG's plans/procedures and the Extent-of-Play Agreement.

OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time requirements).

At least one route needs to be demonstrated and evaluated.

The selected route(s) must vary from exercise to exercise.

However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as negotiated in the Extent-of-Play.

Actual testing of the mobile public address system will be conducted at an agreed-upon location.OROs may demonstrate any means of primary alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

The Commonwealth of Pennsylvania has implemented a Statewide EAS Control system in cooperation with the Pennsylvania Association of Broadcasters per the State Emergency Communications Committee and Pennsylvania Emergency Alert System State EAS Plan (April]1, 2004). The State EOC (PEMAvL) is the initiating point for the activation of the EAS. Risk Counties have the control equipment for activation of sirens. Coordination will occur between the State EOC and the affected counties with respect to the Alert and Notifcation System (AN[S)process. Sirens will be coordinated and the sounding simulated at the appropriate time with the simulated activation of EAS taking place approximately 3 minutes following the simulated activation of the sirens. Regular Broadcasting will not be interrupted on the EAS Stations.Broadcast of the message (s) or test message(s) is NOT required and NOT requested Counties may elect to simulate county specific supplemental messages to their electronic local media.Following the decision to activate the alert and notification system, in accordance with the ORO 's plan and/or procedures, ANS activation should be accomplished in a timely manner for primary alerting/notification.

This action will be per formed in a responsible time and without delay.160 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station All actions to broadcast stations will be simulated.

Systems that use automatic sending technology may be demonstrated by explanation during an interview.

Each evaluated municipality per risk county will demonstrate, by interview, route alerting of the hearing impaired residents within theirljurisdiction.

Hearing impaired notification teams will not be deployed.Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Backup alert and notification of the public is completed within a reasonable time following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654/FEMA-REP-1, E.6, Appendix 3.B.2.c)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

If the exercise scenario calls for failure of any portion of the primary system(s) or if any portion of the primary system(s) actually fails to function during the exercise, OROs must demonstrate backup means of alert and notification.

Backup means of alert and notification will differ from facility to facility.Backup alert and notification procedures that would be implemented in multiple stages must be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The populations farther away and downwind of any potential radiological release would be covered sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the remaining population as directed by authorities).

Topography, population density, existing ORO resources, and timing will be considered in judging the acceptability of backup means of alert and notification.

Although circumstances may not allow this for all situations, FEMA and the NRC recommend that OROs and operators attempt to establish backup means that will reach those in the plume exposure EPZ within a reasonable time of failure of the primary alert and notification system, with a recommended goal of 45 minutes. The backup alert message must, at a minimum, include: (1) a statement that an emergency exists at the plant; and (2) instructions regarding where to obtain additional information.

When backup route alerting is demonstrated, only one route needs to be selected and demonstrated.

All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast), as negotiated in the Extent-of-Play.

Actual testing of the mobile public address system will be conducted at an agreed-upon location.161 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station OROs may demonstrate any means of backup alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

Back-up alert notifi cation of the public due to a simulated siren failure will be demonstrated.(Refer to Attachment A, Section 1. 4.) County liaisons will give an inject to the county siren dispatcher, upon confirmation that sirens were sounded, that a particular siren has failed in the municipalities scheduled to demonstrate back-up route alerting.

Notice of the siren failure will then be communicated to the appropriate municipalities/locations so they can demonstrate their recommended goal of 45 minute per-identified back-up route alert run as per Attachment A, Section 1.A. 4. Pennsylvania does not have any "exception areas." The 45-minute clock starts when the siren dispatcher receives the notification that a siren has failed.IPA WS may be used, as long as it does not interfere with the required demonstrated and evaluated notifications.

Alternate methods of route alerting will NOT be evaluated.

Criterion 5,a.4: Activities associated with FEMA-approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.(NUREG-0654/FEMA-REP-1, E.6; Appendix 3.B.2.c)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

OROs with FEMA-approved exception areas (identified in the approved Alert and Notification System Design Report), 5 to 10 miles from the NPP, must demonstrate the capability to accomplish primary alerting and notification of the exception area(s). FEMA and the NRC recommend that OROs and operators establish means that will reach those in approved exception areas within 45 minutes once the initial decision is made by authorized offsite emergency officials to notify the public of an incident.

The exception area alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain additional information.

For exception area alerting, at least one route must be demonstrated and evaluated.

The selected route(s) must vary from exercise to exercise.

However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcasted) as negotiated in the Extent-of-Play.

Actual testing of the mobile public address system will be conducted at an agreed-upon location.

For exception areas 162 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station alerted by air / water craft, actual routes will be negotiated in the Extent-of-Play, but must be demonstrated no less than once every 8 years.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.

PEMA Negotiated Extent-of-Play:

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

Pennsylvania has no exception areas.Sub-element 5.b -Subsequent Emergency Information and Instructions for the Public and the Media INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUJREG-0654/FEMA-REP-1 requires OROs to ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency.

NUREG-0654/FEMA-REP-1 also provides that a system must be available for dealing with rumors. This system will hereafter be known as the "public inquiry hotline." Criterion 5.b.1: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner.(NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, or drills.The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in a timely manner following the initial alert and notification (not subject to specific time requirements).

For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.Message elements:

The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials.

The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and 163 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided.

The ORG must also be prepared to disclose and explain the ECL of the incident.

At a minimum, this information must be included in media briefings and/or media releases.

OROs must demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion exposure pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a. 1 and previously identified protective action areas that are still valid, as well as new areas. Information about any rerouting of evacuation routes due to impediments should also be included.

The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media.In addition, the OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures.

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

If ingestion pathway measures are exercised, OROs must demonstrate that a system exists for rapid dissemination of ingestion pathway information to predetermined individuals and businesses in accordance with the ORG's plans/procedures.

Media information:

OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants.

The GROs must demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and releases must be consistent with PADs and other emergency information provided to the public. Copies of pertinent emergency information (e.g., EAS messages and media releases) and media information kits must be available for dissemination to the media.Public inquiry: OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. Hotline staff must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, must be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

164 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Subsequent emergency information and instructions should be provided to the public and the media in a timely manner. This will NOT be sub/ect to specific time requirements.

One media briefing will be demonstrated in each risk county.Risk and Support Counties will receive and handle "Public Inquiry" messages via their individual "Public Inquiry "processes (in compliance with NIMS terminology, Rumor Control is now considered to be "Public Inquiry "). Counties will receive approximately ten (10) public inquiry calls from the State Exercise cell assigned this responsibility.

Counties will be expected to receive and log the calls, identify any trends and take appropriate actions to include follow-up message development, distributions and/or briefings.

165 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 6 Support Operations/Facilities Sub-element 6.a -Monitoring, Decontamination, and Registration of Evacuees INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of evacuees, while minimizing contamination of the facility.

OROs must also have the capability to identify and register evacuees at reception centers.Criterion 6.a.1: The reception center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees. (NUJREG-0654/FEMA-REP-1, A.3; C.4; J.10.h; J.12)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, drills, or SAy.Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency or as indicated in the Extent-of-Play Agreement.

OROs conducting this demonstration must have one-third of the resources (e.g., monitoring teams/instrumentation/portal monitors) available at the facility (ies) as necessary to monitor 20 percent of the population within a 12-hour period. This would include adequate space for evacuees' vehicles.

Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location.

Plans/procedures must indicate provisions for service animals.Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

Staff responsible for the radiological monitoring of evacuees must demonstrate the capability to attain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. The monitoring productivity rate per hour is the number of evacuees that can be monitored, per hour, by the total complement of monitors using an appropriate procedure.

For demonstration of monitoring, decontamination, and registration capabilities, a minimum of six evacuees must be monitored per station using equipment and procedures specified in the plans/procedures.

The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met.OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities.

The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the 166 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station evacuee's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the plan and/or procedures.

Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated.

Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination.

They must also explain the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures.

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

Decontamination of evacuees may be simulated and conducted by interview.

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

The staff must demonstrate provisions for limiting the spread of contamination.

Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees, provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities.

In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal belongings.

Waste water from decontamination operations does not need to be collected.

Individuals who have completed monitoring (and decontamination, if needed) must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level or have been placed in a secure area until they can be monitored and decontaminated, if necessary.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored.

These individuals do not require confirmation that their vehicle is free from contamination prior to entering the congregate care areas.However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles held in a secure area or monitored and decontaminated (if applicable) 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.PEMA Negotiated Extent-of-Play:

Radiological monitoring demons tration sites should possess a roster of the monitoring personnel required to process the population allocated to the facility within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period.167 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Water from decontamination activities may go directly to a storm drain or other sewer or drain system or area normally designated for wastewater that has been used for bathing or washing of vehicles and or equipment.

Radiological monitoring of the public may be co-located at either reception centers or mass care centers depending on the county plan.At each reception center (stand alone -non-mon/decon activity sites) a minimum of three volunteer evacuees will be processed, briefed, issued the appropriate strip map or directions, and instructed to proceed to a mass care center designated for demonstration of monitoring, decontamination, and registration.

A sample of the appropriate strip maps or directions will be made available for the demonstration.

Note. Co-located facilities do not require strip maps or written directions.

Mass care centers and mass care monitorinjg/decontamination centers will be demonstrated per Attachment A during the out-of-sequence window. The counties will provide space at designated mass care centers for ope ration of monitoring/decontamination centers. Schematics of these monitoring/decontamination centers will be available to show the organization and layout within the facility and space management for monitoring and decontamination.

Procedures will be demonstrated to show the separation of contaminated and non-contaminated (clean) individuals to minimize cross contamination.

At the evacuee monitoring/decontamination centers (if using~ hand-held meters), a minimum of six (6) volunteer evacuees will be monitored (or one volunteer evacuee may be monitored six times). Centers using portal monitors are only required to demonstrate three (3) volunteer evacuees.

Suitable radiological monitoring instruments will be issued to and demonstrated by the initial monitoring team(s). A monitoring team consists of one monitor and one recorder equipped with one survey instrument.

Those individuals found to be free of "contamination

", based upon scenario injects, will be directed to the mass care registration point for further processing.

Note: Actual radiological sources will not be attached to or hidden upon the volunteer evacuees.One of the simulated evacuees, based upon controller injects, will not be able to be decontaminated.

Discussions concerning the processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. Showering will be simulated, water will not be used. Note: If portal monitors are used, see below.At the emergency worker monitorinig/decontamination stations, two (2) emergency workers will be monitored.

Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. Showering will be simulated, water will'not be used. Suitable radiological monitoring instruments will be issued to the initial monitoring team. Note: If portal monitors are used, the Portal Monitor Extent-of-Play described below shall be used.168 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Portal Monitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees and/or emergency workers. The monitoring/decontamination team requirements will be based on the portal monitor capabilities as applicable based on the procedure/guidelines, and the recommendations of the manufacturer.

Note: PEMA Interim Annex E letter, April 2009 or superseding document shall apply.Monitoring/decontamination centers and Emergency Worker monitoring and decontamination station personnel are not issued DRDs or KI since the centers and stations are outside the EPZ.Category "C" Dosimetry applies. Simulated permanent record dosimeters (PRDs) will be worn.Radiation readings/contamination data for the evacuees and vehicle will be provided by the controller as appropriate based upon information contained in the scenario package. Set-up of the facility will be performed the same as for an actual emergency with all route markings and contamination control measures in place including step-off pad (if used). Long runs of plastic covered with paper will not be demonstrated, but the materials may be available and explained (as appropriate).

Positioning of a fire apparatus on-site may be simulated ifotherwise required.Note: Re-demonstrations may be performed as appropriate and time permitting.

Sub-element 6.b -Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles INTENT This Sub-element is derived from NUJREG0654iFEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of emergency workers and their equipment, inclusive of vehicles.Criterion 6.b.1: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles.(NUREG-0654/FEMA-REP-1, K.5.a, b)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, an actual event, or SAy.The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in accordance with the ORG's plans/procedures.

Specific attention must be given to equipment, including any vehicles that were in contact with contamination.

The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and vehicles based on trigger/action levels and procedures stated in the ORG plans/procedures.

Monitoring of emergency workers does not 169 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station have to meet the 12-hour requirement.

However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency workers and their equipment and vehicles.*Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

The area to be used for monitoring and decontamination must be set up as it would be in an actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles.

However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated.

Interior surfaces of vehicles that were in contact with contaminated individuals must also be checked.Decontamination of emergency workers may be 'simulated and conducted via interview.

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

The staff must demonstrate provisions for limiting the spread of contamination.

Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated individuals where applicable; provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of emergency workers or facilities.

OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and decontamination activities.

The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the emergency worker's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the plan and/or procedures.

Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated.

Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination.

They must also explain the procedures for referring any emergency workers who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures.

Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by interview.

Waste water from decontamination operations does not need to be collected.

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.

PEMA Negotiated Extent-of-Play:

Emergency worker station personnel will consist of a minimum of one monitor and one recorder and sufficient personnel to demonstrate monitoring of at least one vehicle. Schematics of these 170 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station monitoring/decontamination stations will be available to show organization and space management within the facility.

The evaluator will request that decontamination procedures be explained after the vehicle which has simulated contamination has been monitored One radiological survey meter will be issued to each monitoring/decontamination team. One vehicle and/or piece of equipment will not be able to be decontaminated.

Simulated radiation contamination data will be included in the scenario package, and injected by a con/roller.

Set-up of the facility will be performed as closely as possible to that for an actual emergency with all route markings in place including clearly defined exit areas, per contamination control procedures and/or step-off pads (if used); with the exception of long runs of plastic covered with paper which will not be demonstrated, but the materials may be available and explained (as appropriate.).

Decontamination capabilities, and provisions for vehicles and equipment that cannot be decontaminated, will be simulated and conducted by interview.

NVote: Re-demons/rations may be performed as appropriate and time permitting.

Sub-element 6.c -Temporary Care of Evacuees INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires OROs to have the capability to establish relocation centers in host/support jurisdictions.

The American Red Cross normally provides congregate care in support of OROs under existing letters of agreement.

Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines.

Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654/FEMA-REP-1, J.10.h, J.12)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, an actual event, or SAy.The evaluator must conduct a walk-through of the center to determine, through observation and inquiries, that the services and accommodations are consistent with applicable guidance.For planning purposes, OROs must plan for a sufficient number of congregate care centers in host/support jurisdictions based on their all-hazard sheltering experience and what is historically relevant for that particular area. In this simulation, it is not necessary to set up operations as they would be in an actual emergency.

Alternatively, capabilities may be demonstrated by setting up stations for various services and providing those services to simulated evacuees.

Given the 171 Unclassified

• Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station substantial differences between demonstration and simulation of this criterion, exercise demonstration expectations must be clearly specified in Extent-of-Play Agreements.

Congregate care staff must also demonstrate the capability to ensure that evacuees, service animals, and vehicles have been monitored for contamination, decontaminated as appropriate, and registered before entering the facility.Individuals arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been placed in a secured area or monitored, cleared, and found to have no contamination or contamination below the trigger/action level.In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored.

These individuals do not need confirmation that their vehicle is free from contamination prior to entering the congregate care areas.However, t~hose individuals who are found to be contaminated and are then decontaminated will have their vehicles held in a secure area until they can be monitored and decontaminated (if applicable) and do need confirmation that their 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, sundries, and large-scale food supplies) need not be physically available at the facility(ies).

However, availability of such items must be verified by providing the evaluator a list of sources with locations and estimates of quantities.

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.

PEMA Negotiated Extent-of-Play:

Counties demonstrating the operation of mass care centers during the out-of-sequence window (Berks and Lehigh Counties) will provide floor plans of the mass care centers to show organization within the facility and space management during a real emergency..

Mass care center locations are listed in the demonstration tables "Demonstration of Mass Care Centers (Attachment A, Section B.3).Personnel, at a minimum, will consist of one manager and one assistant for each mass care center opened during the out-of-sequence window. The responsible American Red Cross chapter will show the source and quantities, by job functional description, to be provided to mass care centers to support the 24-hour operation.

The responsible Red Cross Chapter(s) will be visited, or telephonically contacted during business hours on November 18, 2015, by an exercise evaluator, or interviewed at the mass care center (as appropriate) during the out-of-sequence evaluation to provide information regarding the 24-hour operation.

Schematics of these mass 172 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Inmprovement Plan Limerick Generating Station care centers will be available, during the demonstration window, to show organization within the facility and space allocation for the registration and sheltering the evacuating public.Necessary signs, directional arrows and forms will be available and used to demonstrate registration, at a minimum, of three evacuees requiring emergency housing. Evacuees will be shown the location where they would be housed in an actual situation.

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

This out-of-sequence demonstration window will be from 7:00 PM- 9.'30 PM on November 18, 2015.Those facilities identified for the FEMA walk-down evaluations will be supported by a participating representative from the appropriate Red Cross Chapter(s).

An interview process will be conducted to determine facility compliance of the above stated requirements.

AMERICAN RED CROSS RISK AND SUPPORT COUNTY CHAPTERS: Tri County Chapter (Serving Berks and Chester Counties)701 Centre Avenue Reading, Pennsylvania 19601 Brittany Rivera (484) 894-8754 Greater Lehigh Valley Chapter (Serving Bucks and Lehigh Counties)3939 Broadway Allentown, Pennsylvania 18104 Nina Johnson (484) 403-4715 Southeastern Pennsylvania Chapter (Serving Montgomery County)2221 Chestnut Street Philadelphia Pennsylvania 19103 Kevin Bone (267) 246-4309 Sub-element 6.d -Transportation and Treatment of Contaminated Injured Individuals INTENT This Sub-element is derived from NUREG0654/FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.Criterion 6.d.l: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services 173 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportf/Improvement Plan Limerick Generating Station to contaminated injured individuals.(NUJREG-0654/FEMA-REP-1, F.2; 11.10; K.5.a, b; L.1, 4)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, or drills. FEMA has determined that these capabilities have been enhanced and consistently demonstrated as adequate; therefore, offsite medical services drills need only be evaluated biennially.

FEMA will, at the request of the involved ORO, continue to evaluate the drills on an annual basis. All hospitals listed in the plan as medical services hospitals must be evaluated, with a transportation provider, every 2 years. Additional transportation providers will be rotated through the drills in the 8-year exercise cycle. For ambulance providers who do not participate in an evaluated drill during the two year cycle, training will be provided.

This training will be documented in the ALC.Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the victim.OROs must demonstrate the capability to monitor/decontaminate and transport contaminated injured individuals to medical facilities.

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility.

It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "victim(s)" to the medical facility.

This option is used in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests of the community.

Normal communications between the ambulance/dispatcher and the receiving medical facility must be demonstrated.

If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available.

In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

Monitoring of the victim may be performed before transport or en route, or may be deferred to the medical facility.

Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s).

However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored.

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

All monitoring activities must be completed as 174 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/improvement Plan Limerick Generating Station they would be in an actual emergency.

Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility.The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment.

Medical facilities are expected to have at least one trained physician and one trained nurse to perform and supervise treatment of contaminated injured individuals.

Equipment and supplies must be available for treatment of contaminated injured individuals.

The medical facility must demonstrate the capability to make decisions on the need for decontamination of the individual, follow appropriate decontamination procedures, and maintain records of all survey measurements and samples taken. All procedures for collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator.

Waste water from decontamination operations must be handled according to facility plans/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.

PEMA Negotiated Extent-of-Play:

This sub-element will be evaluated at Brandywine Hospital, Chester County, on August 1], 2015.NOTE: Responding EMS crew does not monitor nor decontaminate the inlured patient. The in]jured patient will be monitored at the hospital.

If found contaminated, the patient will be decontaminated at the hospital as well.175 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station ATTACHMENT A LIMERICK GENERATING STATION EXTENT-OF-PLAY DEMONSTRATION TABLES I. Plume Phase Exercise A. Activities -November 17, 2015 1. School Districts

-Out-of-Sequence Exercise Risk Public School Districts with schools located within the EPZ and those districts situated outside the EPZ, but with students living within the EPZ, will participate and be evaluated by FEMA. Each identified District Administration Office will be evaluated.

When a school system is comprised of multiple buildings (High School, Middle School, Elementary School), the affected buildings (those with students from the EPZ) will be evaluated on a rotational basis to coincide with the eight-year exercise cycle.Time: Out-of-sequence

-9:00 -11:00 AM Asterisks

(*) items indicate buildings not in EPZ -students may live in the EPZ"Bold" indicated those facilities that are scheduled for Federal evaluation.

COUNTY ISCHOOL DISTRICTTSCOL 1 I (approx. 1/4 th evaluated)

Berks Boyertown Area 1. Boyertown Elementary

____________________2.

Boyertown ilHS West Daniel Boone Area 1. Daniel Boone HS 2.Mncc*lmnayCne Chester Downingtown Area 1. Shamona Creek Elementary*

Great Valley 1. KD Markley Elementary

• Owen J. Roberts 1. Owen J Roberts HS Phoenixville Area 1. Phoenixville Senior HS 2. Kindergarten Center Montgomery TMethacton Area ]1. Arcola Intermediate

_______________I J2. Skyview Elementary 176 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station Perkiomen Valley 1. Perkiomen Valley HS 2. Schwenksville Elementary Pottsgrove

1. Lower Pottsgrove Elementary Pottstown Area 1. Franklin Elementary

2. Pottstown MS Souderton Area 1. Indian Valley MS *Montgomery (cont'd) Spring-Ford Area 1. Evans Elementary

2. Limerick Elementary

3. Royersford Elementary

4. 9 th Grade Center Upper Perkiomen Only the school district will be evaluated.

2. County Emergency Operations Center (EOCs)Time: Per Exercise Scenario DEMONSTRATION FOR EOC MOBILIZATION FOR COUNTIES ______________

___ _____COUNTY DATE [Time Berks November 17, 2015 Exercise Scenario Bucks November 17, 2015 Exercise Scenario Chester November 17, 2015 Exercise Scenario Montgomery November 17, 2015 Exercise Scenario Lehigh November 17, 2015 Exercise Scenario 3. BRP field teams will be evaluated at the R3V staging area located at Wilson Farm Park, 500 Lee Road, Chesterbrook, Pennsylvania on November 17, 2015 at 1:30 p.m.4. Municipal Emergency Operations Center (EOCs)Time: Per Exercise Scenario Asterisks

(*) items indicate joint EOCs."Bold" indicates those facilities that are scheduled for Federal evaluation.

Non-bold indicates those facilities being observed by PEMA.177 Unclassified Radiological Emergency Preparedness Program (REP)Aftcr Action Report/Improvcment Plan Limerick Generating Station DEMONSTRATION FOR EOC MOBILIZATION FOR MUNICIPALITIES RISKI COUNTY MUNICIPALITY I DATE Berks (6) Amity Twp November 17, 2015* Boyertown Borough/Colebrookdale Twp November 17, 2015 Douglass Twp November 17, 2015 Earl Twp November 17, 2015 Union Twp November 17, 2015 Washington Twp -RA November 17, 2015 Chester (15) Charlestown Twp November 17, 2015 East Coventry Twp November 17, 2015 East Nantmeal Twp November 17, 2015 East Pikeland Twp November 17, 2015 East Vincent Twp November 17, 2015 North Coventry Twp November 17, 2015 Chester (cont'd) Phoenixville Borough November 17, 2015 Schuylkill Twp November 17, 2015 South Coventry Twp -RA November 17, 2015 Spring City Borough November 17, 2015 Upper Uwchlan Twp November 17, 2015__________Uwchlan Twp November 17, 2015___________Warwick Twp November 17, 2015 West Pikeland Twp November 17, 2015 West Vincent Tw November 17, 2015 Montgomery (20) Collegeville Borough November 17, 2015_________Douglass Twp November 17, 2015*Greenlane Borough/Marborough Twp November 17, 2015 Limerick Twp November 17, 2015 Lower Frederick Twp November 17, 2015 Lower Pottsgrove Twp November 17, 2015 Lower Providence Twp November 17, 2015 Lower Salford Twp -RA November 17, 2015 New Hanover Twp November 17, 2015 Perkiomen Twp November 17, 2015___________Pottstown Borough November 17, 2015__________Royersford Borough November 17, 2015___________Schwenksville Borough November 17, 2015___________Skippack Twp November 17, 2015___________Trappe Borough November 17, 2015 178 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station___________Upper Frederick Twp November 17, 2015__________Upper Pottsgrove Twp November 17, 2015__________Upper Providence Twp November 17, 2015___________Upper Salford Twp November 17, 2015___________West Pottsgrove Twp November 17, 2015 5. One back-up one route alerting demonstration by one municipality in each risk county. (During Scenario Exercise)BACK-UP ROUTE ALERTING COUNTY ]MUNICIPALITY

/ ROUTE I SIREN DATE Berks Washington Twp -22A / #1 (2 teams) November 17, 2015 Chester South Coventry Twp -62C / #154 (2 teams) INovember 17, 2015 Montgomery Lower Salford Tw -61A / #43 (2 teams) November 17, 2015 6. Traffic and Access Control Points a. The Pennsylvania State Police will brief at the PSP Skippack Barracks, 2047C Bridge Road, Schwenksville, Montgomery County. Members attending the briefing will NOT actually deploy to the TCP/ACPs.b. The PSP briefing will be performed out-of-sequence in a demonstration window of 10:00 a.m. -12:00 a.m. on November 18, 2015.c. Each municipal/regional police force with a TCP assigned in its plan will demonstrate all preparation duties including TCP responsibilities and radiological briefing.

Dispatch of persons to the TCP site will not occur during the exercise.d. Municipal and county staffs will be prepared to brief the FEMA evaluator on actions to be taken should there be an impediment to evacuation on a designated route. This will be demonstrated between 4:00 p.m. -10:00 p.m. on November 17, 2015.These municipal/regional police forces are (by county) being federally evaluated through an interview process at their respective municipality:

179 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Berks IChester 1Montgomery Douglass Township East Vincent Township Upper Pottsgrove Township______________West Pikeland Township Lower Providence Township__________________

_______________________Lower Salford Township_________________________________________Pottstown Borough B. Activities

-November 18, 2015 1. Reception Centers Time: Out-of-sequence

-7:00 p.m. -9:30 p.m.The asterisks

(*) indicate monitoring/decontamination center activities at the respective reception centers.RECEPTION CENTERS LOCATIONS COUNTY LOCATION ]Quantity Berks Morgantown Crossings 1*Bucks County Line Plaza 1__________________(alt.

Souderton Fire Company)*Chester Dowington West High School1 (alt. Chester County Government Services_________________Building; EOC location)*Lehigh Emmaus High School1 2. Emergency worker monitoring/decontamination stations for each risk county.EMERGENCY WORKER MOMITORING/DECONTAMINATION STATION COUNTY ]LOCATION IDATE Chester Lionville Middle School November 18, 2015 (alt. Chester County Government Services Building;EOC location)Montgomery Upper Perkiomen High School November 18, 2015_____________(alt.

Pennsburg Fire Department)__________

3. Evacuee monitoring/decontamination station for each risk and support counties.EVACUEE MONITORING/DECONTAMINATION STATION_______

COUNTY JLOCATION

]DATE Berks Fleetwood High School ]November 18, 2015________Wyomissing High School JNovember 18, 2015 180 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Bucks County Line Plaza November 18, 2015_____________(alt.

Souderton Fire Company) __________

Chester Dowington West High School November 18, 2015_____________(alt.

Chester County Government Services Building)

__________

Lehigh Emmaus High School November 18, 2015 II. Mass Care Center Walkdowns Berks and Lehigh Counties (*) conduct monitoring/decontamination center activities at their mass care centers.DEMONSTRATION OF MASS CARE CENTERS / HOST SCHOOL COUNTY [DATE TIME*Berks (22/6)Bucks (61/15) Thirty five walkdowns are scheduled for October 29-30, 2015 Chester (12/6) See schedule below Lehigh (15/5)Monitgomery_(13/3)

________________________________

MASS CARE CENTER LOCATIONS COUNTY [LOCATION

[Quantity*Berks 1. Conrad Weiser High School 6 2. Conrad Weiser Middle School 3. Twin Valley High School Blue Team 4. Twin Valley Middle School October 29, 2015 5. Wilson Middle School South 9:00 A.M. 6. Muhlenberg Middle School Bucks 1. Franklin Roosevelt School 15 2. Holland Middle School 3. Morrisville Middle / Senior High School 4. Poquessing Middle School 5. Richboro Middle School 6. Milford Township Fire Company Red Team 7. Milford Middle School October 29, 2015 8. Quakertown Community High School 9:00 A.M. 9. Council Rock South High School 10. Council Rock Newtown Middle School 11. Lenape Middle School___________________12.

Eleanor Roosevelt Elementary_________

181 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station MASS CARE CENTER LOCATIONS COUNTY [LOCATION JQuantity Bucks continued

13. Makefield Elementary

14. Edgewood Elementary

15. Springfield Elementary Chester 1. Avon Grove High School 6 2. Fred Engle Middle School 3. Charles Patton Middle School Blue Team 4. Unionville High School October 30, 2015 5. Kennett High School 9:00 A.M. 6. Mary Lang Elementary

• Lehigh 1. Eyer Junior High School5 2. Orefield Middle School Red Team 3. South Mountain Middle School October 30,2015 4. Springhouse Junior High School 9:00 A.M. 5. DeSales University Montgomery

1. Abington Junior High School3 2. Abington Senior High School Blue Team 3. Cheltenham High School October 29, 2015 1:00 P.M.182 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station ATTACHMENT B LIMERICK GENERATING STATION PREVIOUS ISSUES WE DID NOT HAVE ANY ISSUES FROM THE LGS HAB EXERCISE HELD ON NOVEMBER 18, 2013.183 U.S. Department of Homeland Security One Independence Mall. Sixth Floor 615 Chestnut Street tAT Philadelphia, PA 19106-4404 FE MA FEB 1 2 2016 Nuclear Regulatory Commission Headquarters Office of Nuclear Security and Incident Response Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-000 1 To Whom It May Concern: Enclosed is the final After Action Report/Improvement Plan for the Limerick Generating Station Radiological Emergency Preparedness Plume Exercise that was held on November 1 7t, 2015.This report also includes the Mass Care Walk Downs on October 29th and 30h and Out of Sequence Exercise on November 1 7t and 18%h 2015.There were no Level 1 Findings or Plan Issues identified during the exercise.

There was one Level 2 Finding identified that was successfully re-demonstrated during the exercise.Based on the results of the exercise and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards of NUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.If you have any questions, please contact Thomas Scardino at (215) 931-5546.Sincerely MaryAnn Tierney Regional Administrator Enclosure Limerick Generating Station After Action Report!Improvement Plan Exercise Date -November 17, 2015 Radiological Emergency Preparedness (REP) Program~ E APublished February 1, 2016 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station This page is intentionally blank.2 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station*Limerick Generating Station After Action Report/Improvement Plan Published EXECUTIVE

SUMMARY

.............................................................................

5 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 SUMMlVARY

.................................................

15 2.1 Exercise Purpose and Design .................................................................

15 2.2 Exercise Objectives, Capabilities and Activities............................................

18 2.3 Scenario Summary .............................................................................

18 SECTION 3: ANALYSIS OF CAPABILITIES

...................................................

20 3.1 Exercise Evaluation and Results..............................................................

20 3.2 Summary Results of Exercise Evaluation...................................................

20 3.3 Criteria Evaluation Summaries

..............................................................

31 3.3.1 State Jurisdictions

...........................................................................

31 3.3.2 Risk Jurisdictions

...........................................................

33 3.3.3 Support Jurisdictions........................................................................

61 3.3.4 Private Jurisdictions..........................................................................

71 SECTION 4: CONCLUSION.........................................................................

72 APPENDIX A: BEST PRACTICES

................................................................

73 APPENDIX B: EXEgRCISE TIMELINE ...........................................................

75 APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS........................

79 APPENDIX D: ACRONYMS AND ABBREVIATIONS.........................................

87 APPENDIX E: EXERCISE PLAN .................

.................................................

90 3 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station This page is intentionally blank.4 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station EXECUTIVE

SUMMARY

On November 17, 2015, a full-scale Plume Exercise was evaluated in the 10-mile plume exposure pathway, Emergency Planning Zone (EPZ) around the Limerick Generating Station (LGS) by the Federal Emergency Management Agency (FEMA) Region III. Out-of-sequence Mass Care Walkdowns were conducted the 29th and 3 0 th of October, 2015. The purpose of the exercise and the out-of-sequence demonstrations was to assess the State and local offsite response organization's 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 November 18, 2013.FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania; the risk jurisdictions of Berks, Chester, and Montgomery Counties; the support jurisdictions of Bucks and Lehigh Counties; and 16 participating municipalities who were evaluated during this exercise.Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility as volunteers providing vital emergency services twenty four (24) hours to the communities of which they live. Cooperation and teamwork of all the participants was observed during this exercise.This report contains the final evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities:

• Mass Care Walkdowns were conducted on October 29th and 30th 2015* Emergency Workers, Equipment and Vehicles -Monitoring and Decontamination were conducted November 18, 2015.* School Interviews were conducted on November 17, 2015.* Traffic/Access Control interviews with the Pennsylvania State Police Skippack Barracks 2047C, Bridge Road, Schwenksville in Montgomery County were conducted November 18, 2015.The Commonwealth of Pennsylvania and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Level 1 Findings or Plan Issues identified during the exercise.

There was one Level 2 Performance Issue identified which was successfully re-demonstrated during the exercise.5 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Limerick Generating Station Plume Exercise Type of Exercise Plume Exercise Date November 17, 2015 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Tina Lai Thomas Emergency Management Specialist Federal Emergency Management Agency 615 Chestnut Street Sixth Floor One Independence Mall Philadelphia, PA, 19106 (215) 931-5680 tina.thomas(~fema.dhs .gov Jeffery Dean Emergency Preparedness Coordinator Exelon Corporation 298 Longview Road Royersford, PA, 19468 (610) 718-2022 ieffrey.dean~iexeloncorp.com 6

Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Sandra Silva Emergency Management Specialist Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, PA, 17110 (717) 651-2235 sansilva(~ipa.gov

1.3 Participating

Organizations Agencies and organizations of the following jurisdictions participated in the Limerick Generating Station Exercise: Commonwealth of Pennsylvania State BOC* American Red Cross* Auxiliary Communication Services (ACS)* Bureau of Radiation Protection

• Department of Military and Veteran Affairs* Nuclear Regulatory Commission

• Pennsylvania Department Office of Administration

• Pennsylvania Department of Aging* Pennsylvania Department of Agriculture

• Pennsylvania Department of Conservation and Natural Resources* Pennsylvania Department of Corrections

• Pennsylvania Department of Education* Pennsylvania Department of Fish and Boat Commission

• Pennsylvania Department of General Services* Pennsylvania Department of Health* Pennsylvania Department of Transportation

• Pennsylvania Department of Human Services* Pennsylvania Emergency Management Agency* Pennsylvania Department of Labor and Industry-Pennsylvania Liquor Control Board* Pennsylvania Game Commission

• Pennsylvania State Police* Pennsylvania Turnpike Commission

• Pennsylvania Utility Commission

• U.S. Department of Agriculture 7

Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station PA Joint Information Center/Exelon Joint Information Center* Bureau of Radiation Protection

• Exelon Corporation

• Nuclear Regulatory Commission

• Pennsylvania Emergency Management Agency Accident Assessment Center* Bureau of Radiation Protection

• Pennsylvania Department of Environmental Protection Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Vehicle* Bureau of Radiation Protection and Emergency Response Team* Department of Environmental Protection

• State of Pennsylvania State Field Monitoring Team A* Department of Emergency Response, Norristown Regional Office* Pennsylvania Bureau of Radiation Protection, Harrisburg Office* Pennsylvania Bureau of Radiation Protection, Norristown Office* Pennsylvania Department of Environmental Protection State Field Monitoring Team B* Bureau of Radiation Protection

• Department of Environmental Protection Emergency Management Berks County Berks County EOC* American Red Cross* Berks County Agricultural Extension Office* Berks County Civil Air Patrol* Berks County Department of Emergency Services* Berks County Planning Commission

• Berks County Public Works Department

• Berks County Sheriffs Office* Pennsylvania Department of Transportation

• Pennsylvania Emergency Management Agency* Pennsylvania State Police* Radio Amateur Civil Emergency Service (RACES)8 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Douglass Township EOC Douglass Township Traffic & Access Control Washington Township BOG* Bally Community Ambulance* Berks County RACES* Eastern Berks Fire Department

• Washington Township Board of Supervisors

• Washington Township Roadmaster

• Washington Township Public Works* Washington Township Transportation Commission

• Washington Township Back-up Route Alerting* Bally Borough/Washington Township/Bechtelsville Borough emergency Management Agency Berks County Schools* Pennsylvania Emergency Management Agency* Berks County Department of Emergency Services* Boyertown Area School District* Boyertown Elementary School* Boyertown Junior High School West* Daniel Boone Area School District* Daniel Boone High School* Monocacy Elementary Center Berks County Mass Care Walkdowns* Conrad Weiser High School* Conrad Weiser Middle School* Twin Valley High School* Twin Valley Middle School* Wilson Middle School South* Muhlenberg Middle School Chester County* Chester County EOC* Pennsylvania Emergency Management Agency* Chester county Department of Emergency services (DES)* Chester County Department of Transportation

• Chester County Department of Environmental Protection

• Chester County Department of Public Health.* Chester County Medical Services* Chester County Department of Public Safety* Chester County Sheriff's Office* Chester County Department of Agriculture 9

Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station*Pennsylvania State Police Chester County 911 Call Center (Communications)

American Red Cross ARES/RACES Chester County School Districts Chester County Evacuation Support Officer (EFS #6)Chester County Fire and Emergency Medical Services Chester County Public Information Officer Chester County Housing and Human services Chester County Oil and Hazardous Material Response (ESF #10)East Vincent Township EGG* East Vincent Township Department of Public Works* East Vincent Township Emergency Management

• East Vincent Police Department

• East Vincent Public Safety and Security* East Vincent Township Fire Services* East Vincent Township Public Health and Medical Services* East Vincent Township Transportation Services* Radio Amateur Civil Emergency Service (RACES)South Coventry Township EGG* Exelon* South Coventry Township Emergency Management

• South Coventry Township Back-Up Route Alerting* CCAIR/Radio Amateur Civil Emergency Service (RACES)* Ridge Fire Company West Pikeland Township EGG* West Pikeland Township Police* West Pikeland Township Emergency Management

• West Pikeland Township Public Works* Cumberland County Department of Emergency Services* RACES Chester County Schools* Pennsylvania Emergency Management Agency* Chester County Department of Emergency Services* Downingtown Area School District* Shamona Creek Elementary

• Downingtown High School West* Great Valley Area School District* KD Markley Elementary School* Owen J. Roberts School District* Owen J. Roberts High School 10 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* Chester County Department of Emergency Services* Owen J. Roberts High School* Owen J. Roberts High School Safety and Security* East Coventry Elementary School* Phoenixville Area School District* Phoenixville High School* Kindergarten Center Chester County Mass Care Walkdowns* Avon Grove High School* Charles Patton Middle School* Fred Engle Middle School* Kennett High School* Mary Lang Elementary

• Unionville High School Montgomery County Montgomery County EOC* American Red Cross Southeast Pennsylvania Chapter* Montgomery County Animal Response Team* Montgomery County Critical Incident Stress Management Team* Montgomery County 911 Emergency Communications Center* Montgomery County Department of Public Safety Lower Providence Township EOC* Lower Providence Administration

• ,Lower Providence Emergency Management Agency* Lower Providence Emergency Medical Services* Lower Providence Fire Department

• Lower Providence Police Department

• Lower Providence Public Works* Radio Amateur Civil Emergency Service (RACES)Lower Salford Township EOC* Lower Salford Township Back-Up Route Alerting* Pottstown Borough EOC Upper Frederick Township EOC* Upper Frederick Township Board of Supervisors

• Upper Frederick Township Department of Public Works* Upper Frederick Township Emergency Management Organization

• Upper Frederick Township Town Constable* Upper Frederick Township Town Manager* Upper Frederick Township Volunteer Fire Department 11 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImiprovement Plan Limerick Generating Station Upper Pottsgrove Township BOG* Upper Pottsgrove Township Police Department

• Upper Pottsgrove Township Public Works* Upper Pottsgrove Township Volunteer Fire Company 79* Radio Amateur Civil Emergency Service (RACES)/Amateur Radio Emergency Services (ARES)Montgomery County Schools* Pennsylvania Emergency Management Agency* Montgomery County Department of Emergency Services* Methacton Area School District* Arcola Intermediate School* Skyview Elementary School* Perkiomen Valley School District* Perkiomen Valley High School* Schwenksville Elementary School* Pottsgrove School District* Lower Pottsgrove Elementary School* Pottstown Area School District* Franklin Elementary School* Pottstown Middle School* Souderton Area School District* Indian Valley Middle School* Spring Ford Area School District* Evans Elementary School* Limerick Elementary School* Royersford Elementary School* 9 th Grade Center* Upper Perkiomen School District Montgomery County Mass Care Walkdowns* Abington Junior High School* Abington Senior High School* Cheltenham High School Bucks County Bucks County EOC Bucks County Mass Care Walkdowns* Council Rock Newtown Middle School* Council Rock South High School* Edgewood Elementary

• Eleanor Roosevelt Elementary

• Franklin Roosevelt School 12 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* Holland Middle School* Lenape Middle School* Makefield Elementary

• Milford Township Fire Company* Milford Middle School* Morrisville Middle/Senior High School* Poquessing Middle School* Quakertown Community High School* Richboro Middle School* Springfield Elementary Lehigh County Lehigh County EOC* Lehigh County Emergency Management Agency* Lehigh County Health Network Office of Emergency Management

• Pennsylvania Department of Transportation

• American Red Cross* Emmaus Emergency Management Agency* Washington Township Emergency Management Agency* Weisenberg Emergency Management Agency* North Whitehall Emergency Management Agency Lehigh County Mass Care Walkdowns* DeSales University

• Eyer Junior High School* Orefield Middle School* South Mountain Middle School* Springhouse Junior High School State Traffic/Access Control Points* Pennsylvania State Police* Troop K, Skippack Barracks Reception Centers/Mass Care/Mon/Decon Berks County Mass Care/MoniDecon-Fleetwood High School* Fleetwood Volunteer Fire Company* Eastern Pennsylvania Region American Red Cross Mass Care-Wyomissing High, School* American Red Cross* Berks County Emergency Management Agency* Berks County Radio Amateur Civil Emergency Service (RACES)13 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station Mon/Decon-Wyomissing High School* Wyomissing Fire Department and Township of Spring Fire Rescue* Berks County Emergency Management Agency Reception Center-Morgantown Crossings* Berks County Department ofEmergency Services* Caernarvon Township Emergency Management Agency* Caernarvon Township Police* Twin Valley Fire Department Bucks County Reception/Mon/Decon-County Line Plaza* Souderton Fire Company* Bucks County Emergency Management Agency Chester County Reception/Mon/Decon-Downingtown High School West* Chester County HazMat Team Lehigh County Reception/Mass Care/Mon/Decon-Emmaus High School* American Red Cross* Emmaus Fire Department

• Emmaus Police Department

• Emmaus Emergency Management Agency* Lehigh County Emergency Management Agency Emergency Worker Monitoring and Decontamination station Chester County Lionville Middle School* Chester County HazMat Team Montgomery County Upper Perkiomen High School* Montgomery County Office of Emergency Management

• Pennsburg Fire Station Staff 14 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Gencrating Station SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise

Purpose and Design On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume the lead responsibility for all off-site nuclear planning and response.FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.44 CFR 350 establishes the policies and procedures for FEMA's initial and continued approval of State and local governments' radiological emergency planning and preparedness for commercial nuclear power plants. This approval is contingent, in part, on State and local government participation in joint exercises with licensees.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

A. Taking the lead in offsite emergency planning and in the review and evaluation of Radiological Emergency Response Plans (RERPs) and procedures developed by State and local governments; B. Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; C. Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993, Federal Register, Vol. 58, No. 176, September 14, 1993; and D. Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process:-U.S. Department of Commerce,-U.S. Nuclear Regulatory Commission,-U.S. Environmental Protection Agency,-U.S. Department of Energy,-U.S. Department of Health and Human Services,-U.S. Department of Transportation,-U.S. Department of Agriculture,-U.S. Department of the Interior, and-U.S. Food and Drug Administration.

15 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Gencrating Station Representatives of these agencies serve on the Region III Radiological Assistance Committee (RAC), which is chaired by FEMA.A Radiological Emergency Preparedness (REP) exercise was conducted on November 17, 2015, to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Limerick Generating Station (LGS). The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the FEMA Region III RAG Chairperson and approved by FEMA Headquarters.

These reports are provided to the NRC and participating States. State and local governments utilize the findings contained in these reports for the purposes ofplanning, training, and improving emergency response capabilities.

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

• NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980;* Radiological Emergency Preparedness Program Manual, July 2015 Section 1 of this report, entitled 'Exercise Overview", presents the "Exercise Planning Team" and the "Participating Organizations" Section 2 of this report, entitled "Exercise Design Summary", and includes the "Purpose and Design", "Exercise Objectives, Capabilities, and Activities", and the "Scenario Summary".Section 3 of this report, entitled "Analysis of Capabilities", presents detailed "Drill Evaluation and Results" information on the demonstration for each jurisdiction or functional entity evaluated in a jurisdiction-based, issue-only format (Criteria Evaluation Summaries).

Section 4, of this report, entitled "Conclusion", is a description ofthe Region's overall assessment of the capabilities of the participating organizations.

It also presents information on planning issues if any were identified.

Emergency Planning Zone

Description:

Limerick Generating Station (LGS) is located in southeastern Pennsylvania on the Schuylkill River about 1.7 miles southeast of Pottstown Borough. The river passes through the site, separating the western portion, which is in East Coventry Township in Chester County, from the eastern portion, which is in Limerick and Lower Pottsgrove Townships in Montgomery County.16 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportllmprovement Plan Limerick Generating Station The plant is owned and operated by Exelon Nuclear. Two boiling water reactors each generate an electrical output of 1,050 megawatts (MW). Unit 1 was issued a full-power license in August 1985; commercial operations began in February 1986. Unit 2 was issued a full-power license in August 1989 with commercial operations beginning in January 1990.The site encompasses 595 acres and is divided into three (3) parts. The principal portion, where the major operating equipment and buildings are located, is on the east bank of the Schuylkill River. This portion is separated from the second segment, where the cooling water intake is located, near the main line of the Reading Railroad.

The third portion lies on the west bank of the river, adjacent to Conrail railroad tracks. The site coordinates are approximately 4Q0°13 '27"N and 75O35, 1 5"W.The minimum exclusion distance for the LGS is 2,500 feet from the center of each reactor. The utility owns all the land within the exclusion area. No private residences are located within the exclusion area; however, some farming may be permitted.

There are 165 sirens installed to cover the 10-mile plume exposure pathway EPZ. These sirens are activated three (3) minutes before the Emergency Alert System (EAS) messages issued by the Commonwealth of Pennsylvania are broadcast.

Soils in this area are of the Reaville-Penn-Klinesville Association and are characteristic of rolling uplands. They are underlain by sedimentary rocks of the Brunswick Formation, consisting mostly of red shale with some fine-grained sandstone interbedding.

The normal pool elevation of the Schuylkill River in this area is 200 feet above mean sea level (msl). The topography of the area is hilly, with elevations ranging from 100-300 feet above msl within five (5) miles of the site. The plant is approximately 217 feet above msl.The climate in this area is dominated by prevailing westerly winds that produce humid, continental-type weather characterized by warm summers and moderately cold winters.Montgomery County is the warmest part of Pennsylvania, with an average annual temperature of 57°F. Annual precipitation is approximately 42 inches. The area in the immediate vicinity of the plant is made up mostly of agricultural and other open land. The Pottstown Borough in Montgomery County is the nearest community.

The nearest major population center (more than 25,000 people) is Philadelphia that lies 25 miles to the southeast of the site.Two major industries employ a total of 850 persons within two (2) miles of the plant. Two small airfields are also located nearby. A small private airfield is about one (1) mile to the northeast, but its runway is oriented so that the flight path does not pass over the plant. The Pottstown Municipal Airport is 4.3 miles northwest of the site. The LGS does not lie in the approach pattern for this airport. No major thoroughfares are located in the immediate vicinity of the plant. The main line of the Reading Railroad runs along the north bank of the Schuylkill River and traverses the site about 500 feet from the plant.17 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lInprovement Plan Limerick Generating Station 2.2 Exercise Objectives, Capabilities and Activities The objective of the 2015 Limerick Generating Stations (LGS) Plume Exercise was to demonstrate the capabilities of State and local emergency management agencies to mobilize emergency management and emergency response personnel, to activate emergency operations centers and support facilities, and to protect the health, lives, and property of the citizens residing within the 10 mile Emergency Planning Zone (EPZ).To demonstrate the ability to communicate between multiple levels of government and provide timely, accurate, and sufficiently detailed information to the public, the emergency management agencies use a variety of resources, including radios, telephones, the Internet, the media, the Emergency Alert System (EAS), and the utility Alert and Notification System (ANS) Sirens. All of these communication resources were employed and evaluated.

The EAS and ANS were simulated and media information was prepared but not actually released.An essential capability of the Radiological Emergency Preparedness Program (REPP) is to evacuate, monitor and decontaminate, if necessary, and provide temporary care and shelter to displaced residents from the EPZ. The ability of the risk/support counties to mobilize personnel and resources to establish reception, monitoring and decontamination, and mass care centers was demonstrated.

The protection of school children is also a vital mission of the REPP. School districts and selected schools demonstrated the capability to communicate and coordinate the collection, evacuation, transportation and shelter of students attending schools within the EPZ. Provisions for students who live within the EPZ, but attend school outside were also evaluated.

2.3 Scenario

Summary SCENARIO

SUMMARY

LIMERICK GENERATING STATION DUS-FEMA Region III, PLUME EXERCISE -November 17, 2015 NOTE: The times for the events are approximate as the NRC licensee's operations crew on the reactor training simulator will be provided opportunity for free play. All scenario events are simulated.

On November 17, 2015 at 1600, the Plume exercise started in the Limerick Generating Station (LGS) control room simulator.

LGS Unit 1 and Unit 2 are boiling water reactors operating at 100 percent power. Unit 1 was participating in the exercise.

At 1600, the wind direction was from the North East, 43 degrees, into the South West at 6 miles per hour (mph). The atmospheric stability class was E. The near term weather forecast was for the winds to trend towards the East, and then shift to the North East. Initial conditions on Unit 1 were that the containment spray system was out of service, and one of the two standby gas treatment systems was out of service. Repairs were expected to be completed within 24 to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. In the event 18 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station of a loss of cooling accident this would reduce the capability of the plant to mitigate the release of radioactive materials.

At 1630, the reactor was shut down successfully when there was a 90 gallons per minute (gpm)leak from the reactor coolant system into the reactor containment.

By 1647, an Alert was declared based on EAL FAl loss of the reactor coolant system barrier.There were no releases to the environment.

At 1700, maintenance reported that the second train of the standby gas treatment system was out of service.At 1738, a loss of cooling accident into the containment occurred.

The containment pressure was increasing and the reactor water level was falling to below the top of the fuel rods. The containment radiation level was 300 R/hour and rising. Some fuel clad damage occurred.By 1811, a Site Area Emergency was declared based on EAL FS1, loss of both the reactor coolant system and the fuel clad barriers.

There were no releases to the environment.

At 1850, radioactive releases to the environment commenced when the reactor containment pressure began decreasing owing to a leak into the reactor building through the personnel hatch seal. The stack effluent monitor reading increased significantly.

By 1905, a General Emergency was declared based on EAL FG1, loss of all three fission product barriers.

Limerick issued a Protective Action Recommendation (PAR), "Evacuate the 0 to 2 miles ring. Evacuate the 2 to 5 mile downwind sectors SSW/S W/WS W/W/WNW.Administer potassium iodide to the public, and advise the remainder of the EPZ to monitor and prepare".

Radioactive releases were in progress.

The wind direction was from 59 degrees ENE at 10 mph with a stability class of E. Limerick station dose projections indicated that the EPA Protective Action Guides were not exceeded beyond the site boundary.At 1950, the wind direction changed to be from 33 degrees NNE at 10 mph with a stability class of E. By 2005, Limerick station upgraded their Protective Action Recommendation

(?PAR),"Evacuate the 0 to 2 miles ring. Evacuate the 2 to 5 mile downwind sectors S/S SW/SW/WSW/WiWNW.

Administer potassium iodide KI to the public, and advise the remainder of the EPZ to monitor and prepare".Field monitoring teams would detect plume centerline gamma exposure rates (closed window) of about 7 mR/hr at the site boundary to 1 mR/hr at about 9 miles fr'om the site. Air sample iodine cartridge readings on the plume centerline would be as high as 50 net corrected counts per minute out to about 4 miles from the site.By 2100, the Evaluated Exercise will end if all objectives are met.19 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station SECTION 3: ANALYSIS OF CAPABILITIES

3.1 Exercise

Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the November 17, 2015, Plume Radiological Emergency Preparedness (REP) Exercise.

This report also includes the Mass Care Walk Downs on October 2 9 th and 30th, and Out of Sequence Exercise on November 17th and 18th 2015. The exercise was conducted to demonstrate the ability of State, County and local jurisdictional Offsite Response Organizations (ORO) to respond to a radiological release within the 10 mile Emergency Planning Zone (EPZ) associated with the Limerick Generating Station.Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the appropriate Exercise Evaluation Area Criteria contained in the REP Program Manual. Detailed information on the exercise evaluation area criteria and the Extent-of-Play agreement are found in Appendix E.The exercise was conducted and evaluated in accordance with the Radiological Emergency Preparedness Program Manual and NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Program Manual that was scheduled for demonstration during this exercise by all participating jurisdictions and functional entities.

Exercise evaluation area criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters: (Li) Level 1 Finding: an observed or identified inadequacy of organizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant (NPP).(L2) Level 2 Finding: an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.(P) Plan Issue: an observed or identified inadequacy in the offsite response organizations'(OROs) emergency plan/implementation procedures, rather than that of the ORO's performance.(N) Not Demonstrated:

term applied to the status of a REP exercise Evaluation Area Criterion indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area 20 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Criterion, as required in the Extent-of-Play agreement or at the two-year or eight-year interval required in the FEMA REP Program Manual.(M) Met: status of a REP exercise Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the Extent-of-Play agreement with no Findings assessed in the current exercise and no unresolved prior Findings.21 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Tables 3.1 -Summary of Exercise Evaluation Table 3.1a -Exercise Evaluation by Classification

-Criteria Met Date: 11/17/2015 Site: Limerick Generating Station Location Abbreviation Criteria Title BkCo EOC (5) Emergency Information

& Instructions for the Public/Media 5bl BkCo EOC (5) Equipment and Supplies to Support Operations lel BkCo EOC (5) ,Communications Equipment idl BkCo EOC (5) Direction and Control icl BkCo BOC (5) Mobilization 1lal BkCoMCCCRNMS Temporary Care of Evacuees 6c1 BkCoMCCCRSHS Temporary Care of Evacuees 6cl BkCoMCCEES Temporary Care of Evacuees 6cl BkCoMCCERES Temporary Care of Evacuees 6cl BkCoMCCFRMS Temporary Care of Evacuees 6c1 BkCoMCCHTMS Temporary Care of Evacuees 6cl BkCoMCCLMS Temporary Care of Evacuees 6cl BkCoMCCMES Temporary Care of Evacuees 6cl BkCoMCCMMS Temporary Care of Evacuees 6cl B kCoMCCMMSHrS Temporary Care of Evacuees 6cl BkCoMCCMTFC Temporary Care of Evacuees 6cl BkCoMCCPMS Temporary Care of Evacuees 6c1 BkCoMCCQCHS Temporary Care of Evacuees 6cl BkCoMCCRMS Temporary Care of Evacuees 6cl BkCoMCCSES Temporary Care of Evacuees 6cl BkCo MVDC CoLnPlza Monitoring, Decontamination, & Registration of Evacuees 6al BkCo MDC CoLnPlza Implementation of Emergency Worker Exposure Control 3al BkCo MDC CoLniPiza Equipment and Supplies to Support Operations lel BkCo RC CoLnPlza Monitoring, Decontamination, & Registration of Evacuees 6al BkCo RC CoLnPlza Equipment and Supplies to Support Operations lel BrCo BASD Implementation of PADs for Schools 3c2 BrCo BASD ByrtwnES Implementation of PADs for Schools 3c2 BrCo BASD Byrtwni}HSW Implementation of PADs for Schools 3c2 BrCo DBASD Implementation of PADs for Schools 3c2 BrCo DBASD MEC Implementation of PADs for Schools 3c2 BrCo DglsTwp BOC Impediments to Evacuation 3d2 BrCo DglsTwp EOC Implementation of Traffic & Access Control 3d1 BrCo DglsTwp EOC Equipment and Supplies to Support Operations le 1 BrCo DglsTwp EOC Implementation of PADs for Schools 3c2 BrCo DglsTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl BrCo DglsTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 22 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station BrCo DglsTwp EOC Direction and Control 1ici BrCo DglsTwp EOC Implementation of Emergency Worker Exposure Control 3a1 BrCo DglsTwp EOC Communications Equipment 1id1 BrCo DglsTwp EOC Mobilization 1 al BrCo DglsTwp TACP Implementation of Emergency Worker Exposure Control 3al BrCo DglsTwp TACP Equipment and Supplies to Support Operations lel BrCo DglsTwp TACP Implementation of Traffic & Access Control 3dl BrCo DglsTwp TACP Impediments to Evacuation 3 d2 BrCo DglsTwp TACP Communications Equipment 1 d 1 BrCo EOC Impediments to Evacuation 3d2 BrCo EOC Implementation of Traffic & Access Control 3d 1 BrCo EOC Implementation of PADs for Schools 3c2 BrCo EOC Implementation of PADs for disabilities

& access/functional needs people 3cd BrCo EOC Activation of the Back-up ANS 5a3 BrCo EOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl BrCo EOC Emergency Information

& Instructions for the Public/Media 5b 1 BrCo EOC Direction and Control lcl BrCo EOC Activation of the Prompt Alert & Notification System 5al BrCo EOC Implementation of Emergency Worker Exposure Control 3al BrCo EOC Equipment and Supplies to Support Operations lel BrCo EOC Communications Equipment 1id1 BrCo EOC Mobilization 1lal BrCoMCCCWHS Temporary Care of Evacuees 6cl B rCoMCCCWMS Temporary Care of Evacuees 6c 1 BrCoMCCFHS Temporary Care of Evacuees 6cl1 BrCoMCCMMS Temporary Care of Evacuees 6c1 BrCoMCCTVHS Temporary Care of Evacuees 6c 1 BrCoMCCTVMS Temporary Care of Evacuees 6cl BrCoMCCWHS Temporary Care of Evacuees 6c1 BrCoMCCWSMS Temporary Care of Evacuees 6c1 BrCoMDCFHS Monitoring, Decontamination, & Registration of Evacuees 6a1 BrCoMDCFHS Implementation of Emergency Worker Exposure Control 3a1 BrCoMDCFHS Equipment and Supplies to Support Operations lel BrCoMDCWHS Monitoring, Decontamination, & Registration of Evacuees 6al BrCoMDCWHS Implementation of Emergency Worker Exposure Control 3al BrCoMDCWHS Equipment and Supplies to Support Operations 1el BrCoMVDCWHS Monitoring, Decontamination, & Registration of Evacuees 6a1 BrCoMDCWHS Implementation of Emergency Worker Exposure Control 3a1 BrCoMDCWHS Equipment and Supplies to Support Operations le1 BrCo WshtnTwp EOC Communications Equipment 1id1 BrCo WshtnTwp EOC Impediments to Evacuation 3d2 BrCo WshtnTwp EOC Direction and Control lcl BrCo WshtnTwp EOC Implementation of Traffic & Access Control 3dl 23 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station B oWstwpECMobilization 1 al BrCo WshtnTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3cd BrCo WshtnTwp EOC Implementation of PADs for Schools 3c2 BrCo WshtnTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 Bro~puAActivation of the Back-up ANS 5a3 BrCoWTwpBuRA Implementation of Emergency Worker Exposure Control 3a1 BrCoWTwpBuRA Equipment and Supplies to Support Operations lel BrCoWTwpBuRA Mobilization 1 al BrCoWTwpBuRA Communications Equipment 1 dl1 BRP R3V Field Team Management 4a2 BRP R3V Implementation of Emergency Worker Exposure Control 3al BPRVEquipment and Supplies to Support Operations lel BPRVCommunications Equipment ldl BPRVDirection and Control icl BPRVMobilization lal CDADImplementation of PADs for Schools 3c2 CC DASD DHSW Implementation of PADs for Schools 3c2 CC DASD SCES Implementation of PADs for Schools 3c2 CC EOC Emergency Information

& Instructions for the Public/Media 5b 1 CC EOC Direction and Control ic 1 CC EOC Equipment and Supplies to Support Operations lel CC EOC Communications Equipment idi CC EOC Impediments to Evacuation 3d2 CC EOC Implementation of Traffic & Access Control 3d1 CC EOC Mobilization 1 al CC EOC Activation of the Prompt Alert & Notification System 5al CC EOC Activation of the Back-up ANS 5a3 CC EOC Implementation of PADs for Schools 3c2 CC EOC Implementation of PADs for disabilities

& access/functional needs people 3cl CC EOC Implementation of KIr PAD for Institutionalized Individuals/Public 3b 1 CC EOC Implementation of Emergency Worker Exposure Control 3al CCEVcntTwpEOC Impediments to Evacuation 3d2 CCEVcntTwpEOC Implementation of Traffic & Access Control 3dl CCEVcntTwpEOC Implementation of Emergency Worker Exposure Control 3a1 CCEVcntTwpEOC Equipment and Supplies to Support Operations lel CCEVcntTwpEOC Communications Equipment 1 dl1 CCEVcntTwpEOC Direction and Control lcl CCEVcntTwpEOC Mobilization 1 al CCEVcntTwpEOC Implementation of PADs for Schools 3c2 CCEVcntTwpEOC Implementation of PADs for disabilities

& access/functional needs people 3cl CCEVcntTwpEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl CCEVcntTwpTACP Impediments to Evacuation 3d2 CCEVcntTwpTACP Implementation of Traffic & Access Control 3dl 24 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lImprovement Plan Limerick Generating Station CCEVcntTwpTACP Implementation of Emergency Worker Exposure Control 3al CCEVcntTwpTACP Equipment and Supplies to Support Operations le1 CCEVcntTwpTACP Communications Equipment 1id1 CC EWMDS LMS Monitoring/Decontamination of Emergency Workers/Equipment/Vehicles 6b 1 CC EWMLDS LMS Equipment and Supplies to Support Operations lel CC EWMvDS LMS Implementation of Emergency Worker Exposure Control 3a1 CC EWMDS LMS Communications Equipment 1id1 CC EWMDS LMS Direction and Control lcl CC GVSD Implementation of PADs for Schools 3c2 CC GVSD KDMIES Implementation of PADs for Schools 3 c2 CCMCCAGHS Temporary Care of Evacuees 6c1 CC MCC CPMS Temporary Care of Evacuees 6cl CCMCCFEMS Temporary Care of Evacuees 6cl CCMCCKHS Temporary Care of Evacuees 6cl CCMCCMLES Temporary Care of Evacuees 6cl1 CCMCCUnHS Temporary Care of Evacuees 6c1 CC MDC DHS Equipment and Supplies to Support Operations lel CC MDC DHS Monitoring, Decontamination, & Registration of Evacuees 6a1 CC MDC DHS Implementation of Emergency Worker Exposure Control 3a1 CCOJRSD Implementation of PADs for Schools 3c2 CCOJRSDECES Implementation of PADs for Schools 3c2 CCOJRSDOJRHS Implementation of PADs for Schools 3c2 CC PASD Implementation of PADs for Schools 3c2 CC PASD KC Implementation of PADs for Schools 3c2 CC RC DHS Equipment and Supplies to Support Operations lel CC RC DHS Monitoring, Decontamination, & Registration of Evacuees 6a1 CCSCTwpBuRA Activation of the Back-up ANS 5a3 CCSCTwpBuRA Implementation of Emergency Worker Exposure Control 3a1 CCSCTwpBuRA Equipment and Supplies to Support Operations lel CS wp RACommunications Equipment ldl CS wpuAMobilization 1 al CC SCvntryTwp EOC Impediments to Evacuation 3d2 CC SCvntryTwp EOC Implementation of Traffic & Access Control 3d1 CC SCvntryTwp EOC Implementation of PADs for Schools 3c2 CC SCvntryTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl CC SCvntryTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 CC SCvntryTwp EOC Implementation of Emergency Worker Exposure Control 3a1 CC SCvntryTwp EOC Equipment and Supplies to Support Operations lel CC SCvntryTwp EOC Communications Equipment ldi CC SCvntryTwp EOC Direction and Control ici CC SCvntryTwp EOC Mobilization 1lal CC WPklndTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl CC WPklndTwp EOC Implementation of Traffic & Access Control 3dl 25 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station CC WiPklndTwp EOC Implementation of PADs for Schools 3c2 CC WPklndTwp EOC Impediments to Evacuation 3d2 CC WPklndTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b1 CC WPklndTwp EOC Implementation of Emergency Worker Exposure Control 3a1 CC WPklndTwp EOC Equipment and Supplies to Support Operations lel CC WPklndTwp EOC Communications Equipment I d1 CC WPklndTwp EOC Direction and Control 1ic1 CC WPklndTwp EOC Mobilization 1 al CC WPklndTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 CC WPklndTwp TACP Impediments to Evacuation 3d2 CC WPklndTwp TACP Implementation of Traffic & Access Control 3dl CC WPklndTwp TACP Implementation of Emergency Worker Exposure Control 3aI CC WPklndTwp TACP Equipment and Supplies to Support Operations lel CC WPklndTwp TACP Communications Equipment 1idl EJIC Communications Equipment 1idi EJIC Mobilization 1lal LhCo EOC (5) Emergency Information

& Instructions for the Public/Media 5b 1 LhCo EOC (5) Equipment and Supplies to Support Operations lel LhCo EOC (5) Communications Equipment 1ldl LhCo EOC (5) Direction and Control lc 1 LhCo EOC (5) Mobilization 1lal LhCo MCC DU Temporary Care of Evacuees 6cl LhCoMCCEHS Temporary Care of Evacuees 6c 1 LhCoMCCEJHS Temporary Care of Evacuees 6c1 LhCoMCCOMS

-Temporary Care of Evacuees 6cl LhCoMCCSMMvS Temporary Care of Evacuees 6cl LhCoMCCSphMS Temporary Care of Evacuees 6cl LhCoMiDCEHS Monitoring, Decontamination, & Registration of Evacuees 6a1 LhCoMDCEHS Implementation of Emergency Worker Exposure Control 3al LhCoMDCEHS Equipment and Supplies to Support Operations 1 el LhCo RC EHS Monitoring, Decontamination, & Registration of Evacuees 6al LhCo RC EHS Equipment and Supplies to Support Operations lel MC EOC Direction and Control lci MC EOC Impediments to Evacuation 3d2 MC EOC Implementation of Traffic & Access Control 3dl MC EOC Implementation of PADs for Schools 3c2 MC EOC Implementation of PADs for disabilities

& access/functional needs people 3cl MC EOC Activation of the Back-up ANS 5a3 MC EOC Mobilization 1lal MC EOC Communications Equipment 1id1 MC EOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MC EOC Implementation of Emergency Worker Exposure Control 3a1 MC EOC Emergency Information

& Instructions for the Public/Media 5b 1 26 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station MC EOC Equipment and Supplies to Support Operations 1le 1 MC EOC Activation of the Prompt Alert & Notification System 5al MC EWMDS UPHS Monitoring/Decontamination of Emergency Workers/Equipment/Vehicles 6bl1 MC EWMvIDS UPHS Implementation of Emergency Worker Exposure Control 3al MC EWMDS UIPHS Direction and Control lci MC EWMDS UPHS Equipment and Supplies to Support Operations lel MC EWMDS UPHS Communications Equipment Id1 MC LPTwp TACP Implementation of Traffic & Access Control 3dl MC LPTwp TACP Equipment and Supplies to Support Operations lel MC LPTwp TACP Implementation of Emergency Worker Exposure Control 3al MC LPTwp TACP Communications Equipment 1idi MCLrPrvTwpEOC Impediments to Evacuation 3d2 MCLrPrvTwpEOC Implementation of Traffic & Access Control 3d1 MCLrPrvTwpEOC Implementation of PADs for Schools 3c2 MCLrPrvTwpEOC Implementation of PADs for disabilities

& access/functional needs people 3cd MCLrPrvTwpEOC Direction and Control 1icl MCLrPrvTwpEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MCLrPrvTwpEOC Implementation of Emergency Worker Exposure Control 3al MCLrPrvTwpEOC Equipment and Supplies to Support Operations lel MCLrPrvTwpEOC .Communications Equipment 1idi MCLrPrvTwpEOC Mobilization 1 al MC LSlfirdTwp TACP Implementation of Emergency Worker Exposure Control 3al MC LSlfrdTwp TACP Impediments to Evacuation 3d2 MC LSlfrdTwp TACP Implementation of Traffic & Access Control 3d 1 MC LSlfrdTwp TACP Equipment and Supplies to Support Operations le1 MC LSlfrdTwp TACP Communications Equipment idl MCLSTBuRA Activation of the Back-up ANS 5a3 MCLSTBuRA Implementation of Emergency Worker Exposure Control 3a1 MCLSTBURA Equipment and Supplies to Support Operations lel MCLSTBuRA Communications Equipment 1id1 MCLSTBuRA Mobilization 1 al MC LwrSlfrdTwp EOC Implementation of Emergency Worker Exposure Control 3al MC LwrSlfrdTwp EOC Equipment and Supplies to Support Operations 1lel MC LwrSlfrdTwp EOC Communications Equipment 1id1 MC LwrSlfrdTwp EOC Direction and Control 1ici MC LwrSlfrdTwp EOC Mobilization 1lal MC LwrSlfrdTwp EOC Impediments to Evacuation 3d2 MC LwrSlfrdTwp EOC Implementation of Traffic & Access Control 3dl MC LwrSlfrdTwp EOC Implementation of PADs for Schools 3c2 MC LwrSlfrdTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl MC LwrSlfirdTwp EOC Implementation of KI PAD for Institutionalized Individuals!Public 3bl MCMCCAJHS Temporary Care of Evacuees 6cl MCMCCASHS Temporary Care of Evacuees 6c1 27 Unclassified Radiological Emergency Preparedness Program (REp)After Action Report/Improvement Plan Limerick Generating Station MCMCCCHS Temporary Care of Evacuees 6c1 MC MSD Implementation of PADs for Schools 3c2 MC MSD AIS Implementation of PADs for Schools 3c2 MCMSDSUES Implementation of PADs for Schools 3c2 MC PASD Implementation of PADs for Schools 3c2 MC PASD FES Implementation of PADs for Schools 3c2 MC PASD PMS Implementation of PADs for Schools 3c2 MC PSD Implementation of PADs for Schools 3c2 MC PSD LPES Implementation of PADs for Schools 3c2 MC PSVD SES Implementation of PADs for Schools 3c2 MC PtstwniBr EOC Implementation of Emergency Worker Exposure Control 3a1 MC Ptst'wnflr EOC Equipment and Supplies to Support Operations lel MC PtstwnBr BOC Implementation of Traffic & Access Control 3d1 MC PtstwnBr EOC Implementation of PADs for disabilities

& access/functional needs people 3cl MC PtstwnBr EOC Communications Equipment 1idi MC PtstwnBr EOC Direction and Control ici MC PtstwnBr BOC Mobilization lal MC PtstwnBr EOC Implementation of PADs for Schools 3c2 MC PtstwnBr EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b1 MC PtstwnBr BOC Impediments to Evacuation 3d2 MC PtstwnBr TACP Impediments to Evacuation

.3d2 MC Ptstwnt~r TACP Implementation of Traffic & Access Control 3d1 MC PtstwnBr TACP Implementation of Emergency Worker Exposure Control 3a1 MC PtstwnBr TACP Equipment and Supplies to Support Operations lel MC PtstwnBr TACP Communications Equipment idi MC PVSD Implementation of PADs for Schools 3e2 MC PVSD PVHS Implementation of PADs for Schools 3c2 MC SASD Implementation of PADs for Schools 3c2 MC SFASD Implementation of PADs for Schools 3c2 MCSFASD9GC Implementation of PADs for Schools 3c2 MC SFASD EvnsES Implementation of PADs for Schools 3c2 MC SFASD LES Implementation of PADs for Schools 3c2 MC SFASD RyrsfrdES Implementation of PADs for Schools 3c2 MC SVASD IVMS Implementation of PADs for Schools 3c2 MCUFTwpEOC Implementation of Emergency Worker Exposure Control 3al MCUFTwpEOC Direction and Control ici MCUFTwpEOC Implementation of Traffic & Access Control 3d1 MCUFTwpEOC Implementation of PADs for disabilities

& access/functional needs people 3cl MCUFTwpEOC Impediments to Evacuation 3d2 MCUFTwpEOC Equipment and Supplies to Support Operations lel MCUFTwpEOC Communications Equipment idi1 MCUFTwpEOC Mobilization 1 al MCUFTwpEOC Implementation of KIT PAD for Institutionalized Individuals/Public 3b1 28

• Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station MCUFTwpEOC Implementation of PADs for Schools 3c2 MCUpPtgrTTACP Impediments to Evacuation 3 d2 MCUpPtgrTTACP Implementation of Traffic & Access Control 3dl MCUpPtgrTTACP Implementation of Emergency Worker Exposure Control 3a1 MCUpPtgrTITACP Equipment and Supplies to Support Operations lel MCUpPtgrTTACP Communications Equipment idi1 MC UprPtsgrvTwp BOC Implementation of Emergency Worker Exposure Control 3al MC UprPtsgrvTwp EOC Equipment and Supplies to Support Operations 1lel MC UprPtsgrvTwp EOC Communications Equipment 1idl MC UprPtsgrvTwp EOC Direction and Control 1iel MC UprPtsgrvTwp EOC Mobilization 1 al MC UprPtsgrvTwp EOC Impediments to Evacuation 3d2 MC UprPtsgrvTwp EOC Implementation of Traffic & Access Control 3dl MC UprPtsgrvTwp EOC Implementation of PADs for Schools 3c2 MC UprPtsgrvTwp EOC Implementation of PADs for disabilities

& access/functional needs people 3dl MC UprPtsgrvTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 MC UPSD Implementation of PADs for Schools 3c2 PAAACSEOCBRP PAD decision-making process and coordination for the General Public 2b2 PAAACSEOCBRP Accident Assessment and PARs for the Emergency Event 2b1 PAAACSEOCBRP Emergency Worker Exposure Control Decisions 2a1 PAAACSEOCBRP Equipment and Supplies to Support Operations lel PAAACSEOCBRP Communications Equipment 1id1 PAAACSEOCBRP Direction and Control lcl PAAACSEOCBRP Mobilization 1 al PA EOC Emergency Information

& Instructions for the Public/Media 5b 1 PA EOC Activation of the Prompt Alert & Notification System 5al PA EOC Equipment and Supplies to Support Operations 1el PA EOC Communications Equipment 1id1 PA EOC Mobilization 1lal PA EOC Implementation of KI PAD for Institutionalized Individuals/Public 3b 1 PA EOC PADs for disabilities

& access/functional needs people 2el PA EOC PAD decision-making process and coordination for the General Public 2b2 PA EOC Direction and Control icl PA JIC/RumCon Emergency Information

& Instructions for the Public/Media 5b 1 PA JIC/RumCon Communications Equipment 1id1 PA JIC/RumCon Mobilization 1 al PA TACP SPBSkpk Impediments to Evacuation 3d2 PA TACP SPBSkpk Implementation of Traffic & Access Control 3dl PA TACP SPBSkpk Implementation of Emergency Worker Exposure Control 3al PA TACP SPBSkpk Equipment and Supplies to Support Operations lel PA TACP SPB Skpk Communications Equipment 1id1 SFMT A SER Mobilization 1 al SFMT A SER Plume Phase Field Measurement, Handling, & Analyses 4a3 29 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station SFMT A SER Implementation of Emergency Worker Exposure Control 3al SFMT A SER Communications Equipment ldl SFMT A SER Equipment and Supplies to Support Operations 1 el SFMT B SER Plume Phase Field Measurement, Handling, & Analyses 4a3 SFMT B SER Implementation of Emergency Worker Exposure Control 3al SFMT B SER Equipment and Supplies to Support Operations le1 SFMT B SER Communications Equipment 1ldl SFMT B SER Mobilization 1 al 30 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 State Jurisdictions 3.3.1.1 PA State Field Monitoring Team A, South East Region In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, l.d.1, l.e.1, 3.a.1, 4.a.3 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.2 PA State Field Monitoring Team B, South East Region In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 4.a.3 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.3 Pennsylvania Accident Assessment Center, State EOC-Bureau of Radiation Protection In summary, the status of DHS/FEMA criteria for this location is as follows: a. OBSERVED ONLY: 1.a.1, 1.c.1, 1.d.1, 1.e.l, 2.a.1, 2.b.1, 2.b.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 31 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.4 Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Vehicle In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 4.a.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.5 Pennsylvania Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. OBSERVED ONLY: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.2, 2.c.1, 5.a.1, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN IS SUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.6 Pennsylvania Joint Information Center/Rumor Control In summary, the status of DHS/FEMA criteria for this location is as follows: a. OBSERVED ONLY: 1.a.1, 1.d.1, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE 32 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.1.7 Pennsylvania State Traffic and Access Control Points, State Police Barracks Skippack In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2 Risk Jurisdictions 3.3.2.1 Berks County Emergency Operation Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: l.a.1, Il.c., 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.2 Berks County Mass Care Center, Conrad Weiser High School In summary, the status of DHS/FEM\A criteria for this location is as follows: a. MET: 6.c.1 33 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.3 Berks County Mass Care Center, Conrad Weiser Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FTNDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.4 Berks County Mass Care Center, Fleetwood High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.5 Berks County Mass Care Center, Muhelenberg Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 34 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lImprovement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.6 Berks County Mass Care Center, Twin Valley High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.7 Berks County Mass Care Center, Twin Valley Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.8 Berks County Mass Care Center, Wilson Southern Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.l 35 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.9 Berks County Mass Care Center, Wyomissing High School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.10 Berks County Monitoring and Decontamination Center, Fleetwood High School In summary, the status of DHS/FEMVA criteria for this location is as follows: a. MET: 1.e.1, 3.a.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.11 Berks County Monitoring and Decontamination Center, Wyomissing High School 36 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 3.a.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FTNDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.12 Berks County Reception Center, Morgantown Crossing In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.e.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.13 Berks County, Boyertown Area District, Boyertown Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDJINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.14 Berks County, Boyertown Area School District 37 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DUS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDIINGS:

NONE c. LEVEL 2 FINDiNGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.15 Berks County, Boyertown Area School District, Boyertown Junior High School West In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.16 Berks County, Daniel Boone Area District, Monocacy Elementary Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.17 Berks County, Daniel Boone Area School District 38 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDTNGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.18 Berks County, Douglass Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.19 Berks County, Douglass Township Traffic and Access Control In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1 .d. 1, 1.e. 1, 3.a. 1, 3.d. 1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 39 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 3.3.2.20 Berks County, Washington Township Backup Route Alerting In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 5.a.3 b. LEVEL 1 FfNDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.21 Berks County, Washington Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MVET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.22 Bucks County Monitoring and Decontamination Center, County Line Plaza In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 3.a.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE 40 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.23 Chester County Emergency Operations Center In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.3, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.24 Chester County Emergency Worker Monitoring and Decontamination Station, Lionville Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.l, 6.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.25 Chester County Mass Care Center, Avon Grove High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE 41 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.26 Chester County Mass Care Center, Charles Patton Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.27 Chester County Mass Care Center, Fred Engle Middle School In summary, the status of DHSIFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.28 Chester County Mass Care Center, Kennett High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE 42 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.29 Chester County Mass Care Center, Mary Lang Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.30 Chester County Mass Care Center, Unionville High School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.31 Chester County Monitoring and Decontamination Center, Downingtown High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 3.a.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 43 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.32 Chester County Reception Center, Downingtown High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.33 Chester County, Downingtown Area School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.34 Chester County, Downingtown Area School District, Downingtown High School West In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 44 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportllImprovement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.35 Chester County, Downingtown Area School District, Shamona Creek Elementary School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.36 Chester County, East Vincent Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.l, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.37 Chester County, East Vincent Township Traffic and Access Control In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE 45 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: U-NRESOLVED:

NONE 3.3.2.38 Chester County, Great Valley School District, KD Markley Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.39 Chester County, Owen J. Roberts School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.40 Chester County, Owen J. Roberts School District, East Coventry Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE 46 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station c. LEVEL 2 FINDTNGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.41 Chester County, Owen J. Roberts School District, Owen J. Roberts High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 F1NDrNGS:

NONE c. LEVEL 2 FiNDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.42 Chester County, Phoenixville Area School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.43 Chester County, Phoenixville Area School District, Kindergarten Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE 47 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station c. LEVEL 2 FINDTNGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.44 Chester County, South Coventry Township Backup Route Alerting In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 5.a.3 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.45 Chester County, South Coventry Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

ONE LOCATION:

South Coventry Township Emergency Operation Center ISSUE NO: 35-15-3a1-L2-01 CRITERION:

Emergency Worker Exposure Control CONDITION:

The Radiological Briefing was not conducted in accordance with procedures and content required.POSSIBLE CAUSE: Radiological Officer (RO) not adequately trained.

REFERENCE:

NUREG-0654/FEMA-REP-1:

J. 10.e, K.3.a & b, K.4 48 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EFFECT: The briefing was not done correctly to prepare Emergency Workers (EW) for deployment with the correct understanding of what the risks were and what proper monitoring and KI procedures to follow. As a result the EWs were not able to successfully answer the required interview questions.

CORRECTIVE ACTION DEMONSTRATED:

The Exelon representative provided training for the substitute Radiation Officer on the proper briefing content, risks, and proper monitoring and KI procedures.

The Radiation Officer was then able to conduct a proper Radiation Briefing to the personnel in the EOC and for the TCP staff. Two staff were interviewed and able to answer the questions correctly on monitoring and KI procedures.

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.46 Chester County, West Pikeland Emergency Operations Center In sunmmary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.47 Chester County, West Pikeland Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 49 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.48 Montgomery County Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.49 Montgomery County Emergency Worker Monitoring

& Decontamination Station, Upper Perkiomen High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 6.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN IS SUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.50 Montgomery County Mass Care Center, Abington Jr High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 50 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.51 Montgomery County Mass Care Center, Abington Sr. High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUIES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.52 Montgomery County Mass Care Center, Cheltenham High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2,FINDTNGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.53 Montgomery County, Lower Providence Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.l, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE 51 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR IS SUES: UNRESOLVED:

NONE 3.3.2.54 Montgomery County, Lower Providence Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FTNDTNGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.55 Montgomery County, Lower Salford Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.l, l.d.1, 1.e.l, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.l, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.56 Montgomery County, Lower Salford Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.l, 3.d.2 b. LEVEL 1 FINDINGS:

NONE 52 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lImprovement Plan Limerick Generating Station c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.57 Montgomery County, Lower Salford Township Backup Route Alerting In summary, the status of DHS/FEMA criteria for this location is as follows: a. MVET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 5.a.3 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.58 Montgomery County, Methacton School District, In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.59 Montgomery County, Methacton School District, Arcola Intermediate School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE 53 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.60 Montgomery County, Methacton School District, Skyview Upper Elementary School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.61 Montgomery County, Perkiomen Valley School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.62 Montgomery County, Perkiomen Valley School District, Perkiomen Valley High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 54 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.63 Montgomery County, Perkiomen Valley School District, Schwenksville Elementary School In summary, the status of DHS/FEIVA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.64 Montgomery County, Pottsgrove School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.65 Montgomery County, Pottsgrove School District, Lower Pottsgrove Elementary School 55 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.66 Montgomery County, Pottstown Area School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.67 Montgomery County, Pottstown Area School District, Franklin Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 56 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 3.3.2.68 Montgomery County, Pottstown Area School District, Pottstown Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDIINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.69 Montgomery County, Pottstown Borough Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.70 Montgomery County, Pottstown Borough Traffic and Access Control In summary, the status of DUS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.i, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 57 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plani Limerick Generating Station 3.3.2.71 Montgomery County, Souderton Area School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FTNDTNGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.72 Montgomery County, Souderton Valley Area School District, Indian Valley Mid. School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.73 Montgomery County, Spring-Ford Area School District In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE 58 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick tenerating Station f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.74 Montgomery County, Spring-Ford Area School District, 9th Grade Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDhINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.75 Montgomery County, Spring-Ford Area School District, Evans Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.76 Montgomery County, Spring-Ford Area School District, Limerick Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:i NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE 59 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.77 Montgomery County, Spring-Ford Area School District, Royersford Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.78 Montgomery County, Upper Frederick Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.79 Montgomery County, Upper Perkiomen School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE 60 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.80 Montgomery County, Upper Pottsgrove Township Emergency Operation Center In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.l, l.d.1, l.e.l, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2 b. LEVEL 1 FINDTNGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.2.81 Montgomery County, Upper Pottsgrove Township Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1, 3.d.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3 Support Jurisdictions 3.3.3.1 Bucks County Mass Care Center, Lenape Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 61 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportf/Improvcment Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.2 Bucks County Emergency Operations Center In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 5.b.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.3 Bucks County Mass Care Center Franklin Roosevelt Middle School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.4 Bucks County Mass Care Center, Council Rock Newtown Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 62 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN IS SUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.5 Bucks County Mass Care Center, Council Rock South High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.6 Bucks County Mass Care Center, Edgewood Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.7 Bucks County Mass Care Center, Eleanor Roosevelt Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 63 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.8 Bucks County Mass Care Center, Holland Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.9 Bucks County Mass Care Center, Makefield Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.10 Bucks County Mass Care Center, Milford Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 64 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.11 Bucks County Mass Care Center, Milford Township Fire Company In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS" NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.12 Bucks County Mass Care Center, Morrisville Middle/Senior High School In summary, the status of DHSiFEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.13 Bucks County Mass Care Center, Poquessing Middle School In summary, the status of DUS/FEMA criteria for this location is as follows: a. MET: 6.c.1 65 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDTNGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.14 Bucks County Mass Care Center, Quakertown Community High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.l b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.15 Bucks County Mass Care Center, Richboro Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

N'ONE d. PLAN ISSUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.16 Bucks County Mass Care Center, Springfield Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 66 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.17 Bucks County Reception Center, County Line Plaza In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.e.1, 6.a.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.18 Chester County, Great Valley School District In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 3.c.2 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.19 Lehigh County Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 5.b.1 67 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.20 Lehigh County Mass Care Center, DeSales University In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN IS SUES: NONE e. PRIOR ISSUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.21 Lehigh County Mass Care Center, Emmaus High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.22 Lehigh County Mass Care Center, Eyer Jr. High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 68 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.23 Lehigh County Mass Care Center, Orefield Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.24 Lehigh County Mass Care Center, South Mountain Middle School In summary, the status of DHS/FEIVA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.25 Lehigh County Mass Care Center, Springhouse Middle School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 69 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station b. LEVEL 1 FTNDTNGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.26 Lehigh County Monitoring and Decontamination Center, Emmaus High School In summary, the status of DHS/FEMA criteria for this location is as follows: a. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR IS SUES: RESOLVED:

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 3.3.3.27 Lehigh County Reception Center, Emmaus High School In summary, the status of DHS/FEMA criteria for this location is as follows: b. MET: 6.c.1 b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 70 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 3.3.4 Private Jurisdictions 3.3.4.1 Exelon Joint Information Center In summary, the status of DHS/FEMA criteria for this location is as follows: c. MET: 1.a.1, 1.d.1, 5.b.l b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDIN4GS:

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

NONE f. PRIOR ISSUES: UNRESOLVED:

NONE 71 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and local jurisdictions, except where noted in this report demonstrated knowledge of their Radiological Emergency Response Plans (RERP) and procedures were adequately implemented during the Limerick Generating Station Plume exercise evaluated on November 17, 2015.Federal Emergency Management Agency (FEMA) evaluators provided analyses of over 300 evaluation criteria.

These analyses resulted in a determination of no Level 1 Findings, (1) One Level 2 Finding, successfully re-demonstrated during the exercise and no New Plan Issues, and no unresolved Plan Issues."Based on the results of the exercise and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards of NUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CER 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise."~

An After Action Implementation Plan (IP) will not be developed as part of this report.72 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station APPENDIX A: BEST PRACTICES 1. IPAWS Pilot Implementation Summary: The Chester County Department of Emergency Services, working with support from the FEMA Region III Technological Hazards Branch, and the FEMA IPAWS lab located at the Joint Interoperability Test Command (JITC) in Indian Head, Maryland, conducted the Nation's first pilot demonstration of the IPAWS Nuclear Power Plant Warning (NUW) alert code during a scheduled Radiological Emergency Preparedness (REP) exercise.

The demonstration was not an evaluated component of the REP exercise, but it was executed in sequence with exercise play using real-time scenario information.

As a result, the capabilities of both the hardware components of the system and the training of the responders who would potentially use it were realistically tested.Description:

The Integrated Public Alert and Warning System (IPAWS) is an important modernization and integration of the nation's alert and warning infrastructure that will save time for Federal, State, territorial, Tribal, and local alerting authorities who choose to use the system.The ability to pre-script messages for each Emergency Classification Level (ECL) and to choose which routes the alert may take to reach the affected population from a single interface represents a key evolutionary step in the timely notification of the public of an incident at a Nuclear Power Plant.Alerting authorities who are designated as REP risk and/or ingestion pathway counties may choose to use IPAWS and may also integrate local systems that use Common Alerting Protocol (CAP) standards with the IPAWS infrastructure.

Examples of CAP-compliant Emergency Alerting systems available for use in Chester County which are commonly found throughout other REP jurisdictions include terrestrial radio, television, cable, broadcast, satellite, and wireline providers.

Additional notification tools demonstrated in Chester County included Wireless Emergency Alerts (WEAs), which were transmitted to local cellular towers and have the capability to effectively reach transient populations as well as residents with actionable emergency information.

The Chester County Department of Emergency Services (DES) chose to demonstrate initial public alert and warning at the Site Area Emergency (SAE) ECL at 1833 hours0.0212 days <br />0.509 hours <br />0.00303 weeks <br />6.974565e-4 months <br /> by sending a simulated SAE NUW message to the IPAWS Lab at JITC. DES chose to simulate the use of WEAs, as well as to integrate the test with their-existing CAP-compliant EAS message outlets.A test report from JITC was returned in real-time which demonstrated the success or failure of each component.

All components tested were successful.

Tests of NUTW messages using the IPAWS lab during scheduled REP exercise play or as a component of a regular preparedness testing program are available to any REP jurisdiction who has completed the requirements to become an IPAWS alerting authority.

73 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station At 1834 hours0.0212 days <br />0.509 hours <br />0.00303 weeks <br />6.97837e-4 months <br />, the Chester County DES simulated a real-time expansion of the flexibility of their IPAWS platform by incorporating a simulated siren failure event from the scenario into their demonstration.

In the Chester County plans, the failure of this particular siren requires the activation of a backup route alerting protocol for the population affected by the failure. Route 6C2 was chosen both in real-time evaluated exercise play and for the non-evaluated IPAWS component of the exercise.

Typically, this route requires the notification of a municipal EOC (South Coventry Township) and the subsequent dispatch of a volunteer fire department to report to the Fire Station, confirm instructions, and drive the complete length of the route--to include side roads and long driveways--which would not have received notification due to the failure of the siren. The completion time goal for backup route alerting tasks across the REP program nationwide is 45 minutes.In real-time exercise play, the backup route alerting team needed all of the available 45 minutes to complete the task in addition to a seven minute response time for the volunteers to report to the fire station. During the simulated backup route alert notification initiated in the Chester County EOC, the Watch Officer opened a map on his computer screen using a Google Chrome browser, highlighted a map area to create a polygon which directly matched Route 6C2, and pushed out the backup route alert via IPAWS using the Wireless Emergency Alert tools to ping local cell phone towers. The test met the FEMA requirement to notify "essentially 100% of the population" and was completed in three minutes. Through their whole-of-community collaborative planning process, Chester County is working with response partners to validate best practices for ensuring that previously-identified Special Needs residents are notified during initial notifications as well as any potential backup route alerting processes using the IPAWS platform.Using Chester County as a model going forward, FEMA strongly encourages the integration of IPAWS with existing REP offsite alert and notification plans. As IPAWS is adopted continues to expand throughout FEMA Region III and nationwide, technical and planning assistance is available for any interested REP jurisdiction by contacting their respective partners at the FEMA Regional Office Technological Hazards/REP Branch. The local REP Site Specialist and/or REP Regional Assistance Committee Chairperson can facilitate the process with the IPAWS Program Management Office and testing lab.74 Unclassified Radiological Emergency Preparedness Program (REP)Limerick Generating Station After Action Report/Improvement Plan APPENDIX B: EXERCISE TIMELINE DATE: 11/17/2015, SITE: Limerick Generating Station I Time That Notification Was Received at the Listed Location Classification DelaedEast Vincent South Coventry Level or Event DelrdPA AAC Exelon JIC Berks County Douglass Township Washington Township Chester County_________IA SEOC {Township Township Unusual Event N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 1634 1652 1652 1732 1703 1703 1654 1703 1734 1653 SAE 1750 1809 1805 1811 1815 1825 1811 1818 1814 1838 GE 1854 1914 1914 1916 1914 1931 1926 1914 1914 1914 Start of Simulated N/A 1923 1910 1916 1914 1931 1938 1914 1914 1914 Radiation Release Termination of Simulated N/A Ongoing N/A NA N/A N/A N/A N/A N/A .N/A Radiation Release Facility Declared Operational 1705 1630 1805 1655 1741 1745 1715 1830 1728 Governor's Declaration of 1815 1814 1834 1829 1853 1850 1814 1914 1809 State of Emergency Exercise Terminated 2045 1920 2100 2038 2058 2057 2050 1953 2030 First Preca utiona ry/Protective 1819 1819 1816 1819 1823 1825 1819 1821 1831 Actions: Describe: Airspace Restrictions Boating and fishing restriction Air, Rail and Restrictions Shelter and place livestock or stored feed and water 75 Unclassified Radiological Emergency Preparedness Program (REP)Limerick Generating Station After Action Report/Improvement Plan Siren Sounding 1829 [ 1829 [ 1829 [ 1829 1829 ] 1829 1829 1829 J 1829 EAS Broadcast time 1832 [ 1832 [ 1832 [ 1832 1832 ] 1832 ] 1832 1832 J 1832 Second Precautionary/Protective Actions. Describe: Recommend population within 10 miles to evacuate.

Special Population shelter in place and prepared KI for general public and 1937 1937 1946 1937 1951 1944 1937 1946 1945 Emergency Workers Air Restriction, 10 miles, 10K feet Access limited disable Siren Sounding 1947 1947 ( 1947 ( 1947 1947 1947 1947 1947 ] 1947 EAS Message Broadcast 1950 1950 [ 1950 [ 1950 J 1950 J 1950 1950 1950 1 1950 KI Decision (YES) EWs 1939 J 1934 [ 1946 [ 1934 J 1951 1 1934 1941 1953 1945 KI Decision (YES) General Public ]1939 1934 [ 1946 [ 1934 J 2003 1934 1941 1953 1945 KI Decision (YES) Persons withTI Disabilities or Access Functional 1939 1934 1946 1934 2003 1934 194119394 needs __ _ _ __ __ I __ _ _76 Unclassified Radiological Emergency Preparedness Program (REP)Limerick Generating Station After Action Report/Improvement Plan__________-

_________

-__________ -Time That Notification Was Received at the Listed Location Emergency Tif tiit Classification Delae Motoey LwrPoieI Lower Salford Pottstown Upper Frederick Lower Pottsgrove Level or Event Delrd est Pike land Bucks County Lehigh County______FCounty Township Township Borough Township.

Township Unusual Event N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 1634 1709 1703 1650 1650 1650 1648 1704 1704 1703 SAE 1750 1813 1815 1810 1810 1810 1810 1810 1809 1807 GE 1854 1924 1910 1921 1924 1922 1919 1922 1924 1917 Start of Simulated19012194121999113794 Radiation Release N/A 200819092194921999213794 Termination of Simulated N/A N/A N/A NA N/A N/A N/A N/A N/A N/A Radiation Release Facility Declared Operational 1709 1652 1702 1901 1706 1809 1722 1645 1720 GvrosDcaainoStt 1891814 1834 1946 1945 1834 1834 1834 1814 of Emergency Exercise Terminated 2018 2048 2052 2045 2052 2045 2052 2035 2038 First Precautionary/Protective 1831 1819 1829 1829 1832 1825 1829 1819 1819 Actions: Describe: Water/rail, 10 miles Air 3000 feet, 3 miles Sheltering livestock stored feed Siren Sounding 1919 ( 1829 1825 j 1829 j 1829 1829 1829 -1829 1829 ]EAS Broadcast time 1832 [ 1832 1832 J 1829 1832 1832 [1832 1832 1832 ]77 Unclassified Radiological Emergency Preparedness Program (REP)Limerick Generating Station After Action Report/Improvement Plan Second Precautionary/Protective Actions. Describe: Air, 10 miles, 10,000 feet 1945 1937 1945 1946 1945 1946 1947 1945 1945 Evac Shelter, KI and TCP KI/Shelter in Place Siren Sounding 1947 1947 J 1947 J 1947 [ 1947 1947 J1947 J1947 ] 1947 EAS Message Broadcast 1950 1950 J 1950 J 1950 [ 1950 [ 1950 J1950 1950 ] 1950 KI Decision (YES) EWs ] 1934 1934 J 1945 J 1946 [ *945 1946 J1947 ]N/A ] N/A KI Decision (YES) General Public, 1 1934 T 1934 1945 1 1946 [ 1945 F 1946 11947 1N/A 1 N/A spciyifrstiteiofecosy

__i____f _restricted______

________ ______to_

______sectors_____

_______KI Decisions (YES) Persons with Disabilities or Access/Functional 1934 1934 1945 1946 1945 1946 1947 N/A N/A needs __________

______ _______ _______ _______ ________ ________ ________ _______78 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leaders for the Limerick Generating Station 2015 Radiological Emergency Preparedness Plume Exercise evaluated on November 17, 2015.The following constitutes the managing staff for the Exercise Evaluation:

• Thomas Scardino, DHS/FEMA, Regional Assistance Committee (RAG) Chairman* Tina Thomas, DHSiFEMA, Project Officer and Site Specialist DATE: 11/17/2015, SITE: Limerick Generating Station LOCATION .. .....TEAM LEALEER AGENCY Berks County Emergency Operation Center Barton Freeman FEMA Region 3 Berks County Mass Care Center, Conrad Weiser High School Robert Neff FEMA Region 3 Berks County Mass Care Center, Fleetwood High School Joseph Suders FEMA Region 3 Berks County Mass Care Center, Muhelenberg Middle School Tina Lai-Thomas FEMA Region 3 Berks County Mass Care Center, Twin Valley High School Tina Lai-Thomas FEMA Region 3 Berks County Mass Care Center, Twin Valley Middle School Tina Lai-Thomas FEMA Region 3 Berks County Mass Care Center, Wilson Southern Middle School Tina Lai-Thomas FEMA Region 3 Berks County Mass Care Center, Wyomissing High School Robert Neff FEMA Region 3 Berks County Monitoring and Decontamination Center, Fleetwood Joseph Suders FEMA Region 3 High School Berks County Monitoring and Decontamination Center, Wyomissing Robert Neff FEMA Region 3 High School Berks County Reception Center, Morgantown Crossing Joseph Suders FEMA Region 3 Berks County, Boyertown Area District, Boyertown Elementary Michael Shuler FEMA Region 3 School Berks County, Boyertown Area School District Michael Shuler FEMA Region 3 Berks County, Boyertown Area School District, Boyertown Junior Michael Shuler FEMA Region 3 High School West Berks County, Daniel Boone Area District, Monocacy Elementary Michael Shuler FEMA Region 3 Center Berks County, Daniel Boone Area School District Michael Shuler FEMA Region 3 Berks County, Douglass Township Emergency Operations Center Barton Freeman FEMA Region 3 Berks County, Douglass Township Traffic and Access Control Barton Freeman FEMA Region 3 Berks County, Washington Township Backup Route Alerting Barton Freeman FEMA Region 3 Berks County, Washington Township Emergency Operations Center Barton Freeman FEMA Region 3 Bucks County Mass Care Center, Lenape Middle School Tina Lai-Thomas FEMA Region 3 Bucks County Emergency Operations Center Bridget Ahlgrim FEMA HQ Bucks County Mass Care Center Franklin Roosevelt Middle School Tina Lai-Thomas FEMA Region 3 79 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Bucks County Mass Care Center, Council Rock Newtown Middle Tina Lai-Thomas FEMA Region 3 School Bucks County Mass Care Center, Council Rock South High School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Edgewood Elementary School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Eleanor Roosevelt Elementary Tina Lai-Thomas FEMA Region 3 School_______________________

Bucks County Mass Care Center, Holland Middle Schiool Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Makefield Elementary School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Milford Middle School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Milford Township Fire Company Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Morrisville Middle/Senior High Tina Lai-Thomas FEMA Region 3 School __________

Bucks County Mass Care Center, Poquessing Middle School Tina Lai-Thomas FEMVA Region 3 Bucks County Mass Care Center, Quakertown Community High Tina Lai-Thomas FEMA Region 3 School __________

Bucks County Mass Care Center, Richboro Middle School Tina Lai-Thomas FEMA Region 3 Bucks County Mass Care Center, Springfield Elementary School Tina Lai-Thomas FEMA Region 3 Bucks County Monitoring and Decontamination Center, County Line Joseph Suders FEMA Region 3 Plaza Bucks County Reception Center, County Line Plaza Joseph Suders FEMA Region 3 Chester County Emergency Operations Center John Price FEMA Region 3 Chester County Emergency Worker Monitoring and Decontamination Joseph Suders FEMA Region 3 Station, Lionville Middle School Chester County Mass Care Center, Avon Grove High School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Charles Patton Middle School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Fred Engle Middle School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Kennett High School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Mary Lang Elementary School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Unionville High School Tina Lai-Thomas FEMA Region 3 Chester County Monitoring and Decontamination Center, Joseph Suders FEMA Region 3 Downingtown High School Chester County Reception Center, Downingtown High School Joseph Suders FEMA Region 3 Chester County, Downingtown Area School District Michael Shuler FEM\A Region 3 Chester County, Downingtown Area School District, Downingtown Michael Shuler FEMA Region 3 High School West Chester County, Downingtown Area School District, Shamona Creek Michael Shuler FEMA Region 3 Elementary School Chester County, East Vincent Township Emergency Operations John Price FEMA Region 3 Center Chester County, East Vincent Township Traffic and Access Control John Price FEMA Region 3 Chester County, Great Valley School District Michael Shuler FEMA Region 3 Chester County, Great Valley School District, KD Markley Michael Shuler FEMA Region 3 Elementary School___________

Chester County, Owen J. Roherts School District Michael Shuler FEMA Region 3 80 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/lImprovement Plan Limerick Generating Station Chester County, Owen J. Roberts School District, East Coventry Michael Shuler FEMA Region 3 Elementary School ___________

Chester County, Owen J. Roberts School District, Owen J. Roberts Michael Shuler FEMA Region 3 High School Chester County, Phoenixville Area School District Michael Shuler FEMA Region 3 Chester County, Phoenixville Area School District, Kindergarten Michael Shuler FEMA Region 3 Center Chester County, South Coventry Township Backup Route Alerting John Price FEMA Region 3 Chester County, South Coventry Township Emergency Operations John Price FEMA Region 3 Center Chester County, West Pikeland Emergency Operations Center John Price FEMA Region 3 Chester County, West Pikeland Township Traffic and Access Control John Price FEMA Region 3 Exelon Joint Information Center Joseph Suders FEMA Region 3 Lehigh County Emergency Operations Center Bridget Ahlgrim FEMA HQ Lehigh County Mass Care Center, DeSales University Tina Lai-Thomas FEMA Region 3 Lehigh County Mass Care Center, Emmaus High School Joseph Suders FEMA Region 3 Lehigh County Mass Care Center, Eyer Jr. High School Tina Lai-Thomas FEMA Region 3 Lehigh County Mass Care Center, Orefield Middle School Tina Lai-Thomas FEMA Region 3 Lehigh County Mass Care Center, South Mountain Middle School Tina Lai-Thomas FEMA Region 3 Lehigh County Mass Care Center, Springhouse Middle School Tina Lai-Thomas FEMA Region 3 Lehigh County Monitoring and Decontamination Center, Emmaus Joseph Suders FEMA Region 3 High School Lehigh County Reception Center, Emmaus High School Joseph Suders FEMA Region 3 Montgomery County Emergency Operations Center Lee Torres FEMA Region 3 Montgomery County Emergency Worker Monitoring

& Joseph Suders FEMA Region 3 Decontamination Station, Upper Perkiomen HS ___________

_________Montgomery County Mass Care Center, Abington Jr. High School Tina Lai-Thomas FEMA Region 3 Montgomery County Mass Care Center, Abington Sr. High School Tina Lai-Thomas FEMA Region 3 Montgomery County Mass Care Center, Cheltenham High School Tina Lai-Thomas FEMA Region 3 Montgomery County, Lower Providence Township Emergency Lee Torres FEMA Region 3 Operations Center Montgomery County, Lower Providence Township Traffic and Lee Torres FEMA Region 3 Access Control Montgomery County, Lower Salford Township Emergency Lee Tortes FEMA Region 3 Operations Center Montgomery County, Lower Salford Township Traffic and Access Lee Torres FEMA Region 3 Control Montgomery County, Lower Salford Township Backup Route Lee Torres FEMA Region 3 Alerting Montgomery County, Methacton School District, Michael Shuler FEMA Region 3 Montgomery County, Methacton School District, Arcola Intermediate Michael Shuler FEMA Region 3 School Montgomery County, Methacton School District, Skyview Upper Michael Shuler FEMA Region 3 Elementary School Montgomery County, Perkiomen Valley School District Michael Shuler FEMA Region 3 81 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Gencrating Station Montgomery County, Perkiomen Valley School District, Perkiomen Michael Shuler FEMA Region 3 Valley High School Montgomery County, Perkiomen Valley School District, Michael Shuler FEMA Region 3 Schwenksville Elementary School Montgomery County, Pottsgrove School District Michael Shuler FEMA Region 3 Montgomery County, Pottsgrove School District, Lower Pottsgrove Michael Shuler FEMA Region 3 Elementary School Montgomery County, Pottstown Area School District Michael Shuler FEMA Region 3 Montgomery County, Pottstown Area School District, Franklin Michael Shuler FEMA Region 3 Elementary School Montgomery County, Pottstown Area School District, Pottstown Michael Shuler FEMA Region 3 Middle School Montgomery County, Pottstown Borough Emergency Operations Lee Torres FEMA Region 3 Center Montgomery County, Pottstown Borough Traffic and Access Control Lee Torres FEMA Region 3 Montgomery County, Souderton Area School District Michael Shuler FEMA Region 3 Montgomery County, Souderton Valley Area School District, Indian Michael Shuler FEMA Region 3 Valley Mid. School Montgomery County, Spring-Ford Area School District Michael Shuler FEMA Region 3 Montgomery County, Spring-Ford Area School District, 9th Grade Michael Shuler FEMA Region 3 Center Montgomery County, Spring-Ford Area School District, Evans Michael Shuler FEMA Region 3 Elementary School Montgomery County, Spring-Ford Area School District, Limerick Michael Shuler FEMA Region 3 Elementary School Montgomery County, Spring-Ford Area School District, Royersford Michael Shuler FEMA Region 3 Elementary School Montgomery County, Upper Frederick Township Emergency Lee Torres FEMA Region 3 Operations Center ___________

Montgomery County, Upper Perkiomen School District Michael Shuler FEMA Region 3 Montgomery County, Upper Pottsgrove Township Emergency Lee Torres FEMA Region 3 Operation Center Montgomery County, Upper Pottsgrove Township Traffic and Access Lee Torres FEMA Region 3 Control Point PA State Field Monitoring Team A, South East Region Martin Vyenielo FEMA Region 3 PA State Field Monitoring Team B, South East Region Martin Vyenielo FEMA Region 3 Pennsylvania Accident Assessment Center, State EOC-Bureau of Martin Vyenielo FEMA Region 3 Radiation Protection Pennsylvania Bureau of Radiation Protection, Radiological Rapid Martin Vyenielo FEMA Region 3 Response Vehicle Pennsylvania Emergency Operations Center Joseph Suders FEMA Region 3 Pennsylvania Joint Information Center/Rumor Control Joseph Suders FEMA Region 3 IPennsylvania State Traffic and Access Control Points, State Police Barracks Skippack Joseph Suders FEMA Region 3 82 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station LOCATION EVALUATOR AGENCY Berks County Emergency Operation Center Miriam Weston FEMA Region 2 Berks County Emergency Operation Center Barton Freeman FEMA Region 3 Berks County Emergency Operation Center Frank Cordaro JCF Berks County Emergency Operation Center Robert Neff FEMA Region 3 Berks County Mass Care Center, Conrad Weiser High School Robert Neff FEMA Region 3 Berks County Mass Care Center, Fleetwood High School Gary Goldberg ICF Berks County Mass Care Center, Muhelenberg Middle School Robert Neff FEMA Region 3 Berks County Mass Care Center, Twin Valley High School Robert Neff FEMA Region 3 Berks County Mass Care Center, Twin Valley Middle School Robert Neff FEMA Region 3 Berks County Mass Care Center, Wilson Southern Middle School Robert Neff FEMA Region 3 Berks County Mass Care Center, Wyomissing High School Robert Neff FEMA Region 3 Berks County Monitoring and Decontamination Center, Fleetwood High Gary Goldberg ICF School Berks County Monitoring and Decontamination Center, Wyomissing High Robert Neff FEMA Region 3 School Berks County Reception Center, Morgantown Crossing Thomas Essig ICF Berks County, Boyertown Area District, Boyertown Elementary School Frank Cordaro ICF Berks County, Boyertown Area School District Roger Kowieski ICF Berks County, Boyertown Area School District, Boyertown Junior High Bill Webb FEMA Region 10 School West Berks County, Daniel Boone Area District, Monocacy Elementary Center Ronald Bonner ICF Berks County, Daniel Boone Area School District Laurel Ryan FEMA Region 9 Berks County, Douglass Township Emergency Operations Center Paul Anderson FEMA Region 9 Berks County, Douglass Township Emergency Operations Center Ronald Bonner ICF Berks County, Douglass Township Traffic and Access Control Lenora Borchardt ICF Berks County, Washington Township Backup Route Alerting Brian Hasemann FEMA Region 2 Berks County, Washington Township Emergency Operations Center Andrew Chancellor FEMA R7 Berks County, Washington Township Emergency Operations Center Gregg Dawkins ICF Bucks County Mass Care Center, Lenape Middle School Lee Torres FEMA Region 3 Bucks County Emergency Operations Center Kerry Holmes FEMA Region 3 Bucks County Mass Care Center Franklin Roosevelt Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Council Rock Newtown Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Council Rock South High School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Edgewood Elementary School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Eleanor Roosevelt Elementary School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Holland Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Makefield Elementary School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Milford Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Milford Township Fire Company Lee Torres FEMA Region 3 Bucks County Mass Care Center, Morrisville Middle/Senior High School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Poquessing Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Quakertown Community High School Lee Torres FEMA Region 3 83 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Gcncrating Station Bucks County Mass Care Center, Riehboro Middle School Lee Torres FEMA Region 3 Bucks County Mass Care Center, Springfield Elementary School Lee Torres FEMA Region 3 Bucks County Monitoring and Decontamination Center, County Line Plaza John Zeidler ICF Bucks County~Reception Center, County Line Plaza Brad McRee ICF Chester County Emergency Operations Center Christopher Roe FEMA Region 5 Chester County Emergency Operations Center John Price FEMA Region 3 Chester County Emergency Operations Center Michael Shuler FEMA Region 3 Chester County Emergency Operations Center Steve Ward FEMA Region 3 Chester County Emergency Worker Monitoring and Decontamination Reggie Rodgers ICF Station, Lionville MS Chester County Mass Care Center, Avon Grove High School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Charles Patton Middle School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Fred Engle Middle School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Kennett High School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Mary Lang Elementary School Tina Lai-Thomas FEMA Region 3 Chester County Mass Care Center, Unionville High School Tina Lai-Thomas FEMA Region 3 Chester County Monitoring and Decontamination Center, Downingtown Richard Smith ICF High School Chester County Reception Center, Downingtown High School Richard Smith JCF Chester County, Downingtown Area School District Lenora Borchardt ICF Chester County, Downing-town Area School District, Downingtown High Robert Duggleby ICF School West Chester County, Downing-town Area School District, Shamona Creek Gregg Dawkins ICF Elementary School Chester County, East Vincent Township Emergency Operations Center Marynctte Herndon ICF Chester County, East Vincent Township Emergency Operations Center Robert Duggleby ICF Chester County, East Vincent Township Traffic and Access Control James Hickey ICF Chester County, Great Valley School District Marynette Herndon ICF Chester County, Great Valley School District, KD Markley Elementary James Hickey ICF School Chester County, Owen J. Roberts School District Roger Jobe ICF Chester County, Owen J. Roberts School District, East Coventry Elementary David Kayen ICF School Chester County, Owen J. Roberts School District, Owen J. Roberts High Roger Jobe ICF School __________

Chester County, Phoenixville Area School District Robert Lemeshka ICF Chester County, Phoenixville Area School District, Kindergarten Center Carl Wentzell ICF Chester County, South Coventry Township Backup Route Alerting Roger Jobe ICF Chester County, South Coventry Township Emergency Operations Center Laura Forrest FEMA Region 2 Chester County, South Coventry Township Emergency Operations Center Bill Webb FEMA Region 10 Chester County, West Pikeland Emergency Operations Center David Kayen ICF Chester County, West Pikeland Emergency Operations Center Lisa Hamilton FEMA Region HQ Chester County, West Pikeland Township Traffic and Access Control Robert Lemeshka ICF Exelon Joint Information Center Roger Kowieski ICF Lehigh County Emergency Operations Center Paul Nied ICF 84 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Lehigh County Mass Care Center, DeSales University Lee Torres FEMA Region 3 Lehigh County Mass Care Center, Emmaus High School Kent Tosch ICF Lehigh County Mass Care Center, Eyer Jr. High School Lee Torres FEMA Region 3 Lehigh County Mass Care Center, Orefield Middle School Lee Torres FEMA Region 3 Lehigh County Mass Care Center, South Mountain Middle School Lee Torres FEMA Region 3 Lehigh County Mass Care Center, Springhouse Middle School Lee Torres FEMA Region 3 Lehigh County Monitoring and Decontamination Center, Emmaus High Robert Walker ICF School Lehigh County Reception Center, Emmaus High School Kent Tosch ICF Montgomery County Emergency Operations Center Bridget Ahlgrim FEMA HQ Montgomery County Emergency Operations Center Lee Torres FEMA Region 3 Montgomery County Emergency Operations Center Matthew Wiedemer FEMA Region 3 Montgomery County Emergency Operations Center Peter Herrick, Jr. FEMA Region 3 Montgomery County Emergency Worker Monitoring

& Decontamination Mario Vigliani ICF Station, Upper Perkiomen HS Montgomery County Mass Care Center, Abington Jr. High School Robert Neff FEMA Region 3 Montgomery County Mass Care Center, Abington Sr. High School Robert Neff FEMA Region 3 Montgomery County Mass Care Center, Cheltenham High School Robert Neff FEMA Region 3 Montgomery County, Lower Providence Township Emergency Operations Jon Christiansen ICF Center Montgomery County, Lower Providence Township Emergency Operations Rufus Mobley FEMA Region HQ Center Montgomery County, Lower Providence Township Traffic and Access Carl Wentzell ICF Control Montgomery County, Lower Salford Township Emergency Operations Cristina Schulingkamp EPA Center Montgomery County, Lower Salford Township Emergency Operations Kathy Duran FEMA Region 3 Center Montgomery County, Lower Salford Township Traffic and Access Control Brenda Rembert ICF Mo~ntgomery County, Lower Salford Township Backup Route Alerting Thomas Reynolds ICF Montgomery County, Methacton School District, Brenda Rembert ICF Montgomery County, Methacton School District, Arcola Intermediate Thomas Reynolds JCF School Montgomery County, Methacton School District, Skyview Upper Wes Ryals ICF Elementary School Montgomery County, Perkiomen Valley School District Clayton Spangenberg ICF Montgomery County, Perkiomen Valley School District, Perkiomen Valley Lynn Steffensen ICF High School Montgomery County, Perkiomen Valley School District, Schwenksville Bruce Swiren ICF Elementary School Montgomery County, Pottsgrove School District Rebecca Thomson ICF Montgomery County, Pottsgrove School District, Lower Pottsgrove Rebecca Thomson ICF Elementary School Montgomery County, Pottstown Area School District Robert Walker ICF Montgomery County, Pottstown Area School District, Franklin Elementary Robert Walker ICF School_________________________

85 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Montgomery County, Pottstown Area School District, Pottstown Middle Paul Nied ICF School Montgomery County, Pottstown Borough Emergency Operations Center LaShawn Halsey FEMA HQ Montgomery County, Pottstown Borough Emergency Operations Center Taneeka Hollins FEMA Region 1 Montgomery County, Pottstown Borough Emergency Operations Center Lee Torres FEMA Region 3 Montgomery County, Pottstown Borough Traffic and Access Control Wes Ryals ICF Montgomery County, Souderton Area School District John Zeidler ICF Montgomery County, Souderton Valley Area School District, Indian Valley John Zeidler ICF Mid. School Montgomery County, Spring-Ford Area School District Thomas Essig ICF Montgomery County, Spring-Ford Area School District, 9th Grade Center Gary Goldberg ICF Montgomery County, Spring-Ford Area School District, Evans Elementary Brad McRee ICF School Montgomery County, Spring-Ford Area School District, Limerick Richard Smith ICF Elementary School Montgomery County, Spring-Ford Area School District, Royersford Kent Tosch ICF Elementary School Montgomery County, Upper Frederick Township Emergency Operations Clayton Spangenberg ICF Center Montgomery County, Upper Frederick Township Emergency Operations Ryan Jones FEMA Region 1 Center Montgomery County, Upper Perkiomen School District Mario Vigliani ICF Montgomery County, Upper Pottsgrove Township Emergency Operation Lee Torres FEMA Region 3 Center Montgomery County, Upper Pottsgrove Township Emergency Operation Bruce Swiren ICF Center Montgomery County, Upper Pottsgrove Township Emergency Operation Lynn Steffensen ICF Center Montgomery County, Upper Pottsgrove Township Traffic and Access Rebecca Thomson ICF Control Point PA State Field Monitoring Team A, South East Region Deborah Blunt JCF PA State Field Monitoring Team B, South East Region Johanna Berkey FEMA Region 9 Pennsylvania Accident Assessment Center, State EOC-Bureau of Radiation Martin Vyenielo FEMA Region 3 Protection Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Reggie Rodgers ICF Vehicle Pennsylvania Emergency Operations Center Joseph Suders FEMA Region 3 Pennsylvania Emergency Operations Center Thomas Murray FEMA Region 3 Pennsylvania Joint Information Center/Rumor Control Laurel Ryan FEMA Region 3 Pennsylvania State Traffic and Access Control Points, Station Police Jon Christiansen ICE Barracks Skippack____________

___________

86 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station APPENDIX D: ACRONYMS AND ABBREVIATIONS ACP Access Control Points ACS Auxiliary Communications Service AO Agriculture Officer AP Assistant Principal ARC American Red Cross ARRA Area Requiring Corrective Action ARES Amateur Radio Emergency Services ATEOC Amity Township Emergency Operations Center BASD Boyertown Area School District BCEOC Berks County Emergency Operations Center CART County Animal Response Team CCEOC Chester County Emergency Operations Center CCEPRS Chester County Emergency Preparedness Radio System CERT Crisis Emergency Response Team DASD Downingtown Area School District DRD Direct Reading Dosimeter DT Douglass Township EAL Emergency Action Level EAS Emergency Alert System ECC Emergency Communications Center ECL Emergency Classification Level EDO Emergency Duty Officer EMA Emergency Management Agency EMC Emergency Management Coordinator EMD Emergency Management Director EMS Emergency Medical Services ENEOC East Nantmeal Emergency Operations Center EOC Emergency Operations Center EOCD Emergency Operations Center Director EPLO Emergency Preparedness Liaison Officer EPT Emergency Preparedness Team EPZ Emergency Planning Zone ERP Emergency Response Procedure ERT Emergency Response Team ESF Emergency Support Function EW Emergency Workers FAA Federal Aviation Authority FCP Forward Command Post FEMA Federal Emergency Management Agency FRT Facility Response Team GE General Emergency GES Gilbertsville Elementary School 87 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station GIS Geospatial Information System HAB Hostile Action Base JIC Joint Information Center LGS Limerick Generating Station LNGA Limerick Nuclear Generating Station LSC Logistic Section Chief LVFD Lionville Volunteer Fire Department MC Montgomery County MCCEOC Montgomery County Emergency Operations Center MCT Mobile Cornputer Terminal MDC Mobile Data Computer MDT Mobile Data Terminal MERT Medical Emergency Response Team MPS Municipal Planner Specialist MSD Methacton School District MTFD Montgomery Township Fire Department NARS Nuclear Accident Reporting System ORO Offsite Response Organization PAD Protective Action Decision PBEMA Phoenixville Borough Emergency Management Agency PBEOC Phoenixville Borough Emergency Operations Center PBPD Phoenixville Borough Police Department PCS Personal Communications Services PEIRS Pennsylvania Emergency Incident Reporting System PEMA Pennsylvania Emergency Management Agency PFES Pine Forge Elementary School PIO Public Information Officer PM Portal Monitor PRD Permanent Radiation Dosimeter PSP Pennsylvania State Police PVES Pickering Valley Elementary School PVSD Perkiomen Valley School District PWD Public Works Department RACES Radio Amateur Civil Emergency Services RAT Route Alerting Teams REOP Radiological Emergency Operations Plan REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RO Radiological Officer RSAN Roam Secure Alert Network RSO Radiation Safety Officer SAC Staging Area Commander SAE Site Area Emergency 88 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportllmprovement Plan Limerick Generating Station SASD Souderton Area School District SEOC State Emergency Operations Center SES Schuylkill Elementary School SEVAN Statewide Emergency Voice Activation Network SSL School Services Liaison TCP Traffic Control Points TEDE Total Effective Dose Equivalent TLD Thermo Luminescent Dosimeter TOC Tactical Operations Center USVFC Upper Salford Volunteer Fire Company UUT Upper Uwchlan Township WT Warwick Township 89 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station APPENDIX E: EXERCISE PLAN The enclosed Exercise Plan was created as an overall tool for facilitation and implementation of the Limerick Generating Station (LGS) Radiological Emergency Preparedness Exercise and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program Exercise Methodology.

The Exercise Plan was originally drafted by the Pennsylvania Emergency Management Agency (PEMA) and published by the Federal Emergency Management Agency as an independent document and is annexed here. The Limerick Generating Station Extent-of-Play (EOP) was negotiated and agreed upon by FEMA Region III, and PEMA. The Extent-of-Play is included as an Appendix of the Exercise Plan.90 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportl/Improvcment Plan Limerick Generating Station Preface The 2015 Limerick Generating Station Evaluated Full Scale Exercise (FSE) is sponsored by the Federal Emergency Management Agency (FEMA) and the Pennsylvania Emergency Management Agency (PEMA). This Exercise Plan (ExPlan) was produced with input, advice, and assistance from the Exercise Planning Team (EPT), which followed the guidance set forth in the Federal Emergency Management Agency (FEMA), Homeland Security Exercise and Evaluation Program (HSEEP).The ExPlan gives officials, observers, media personnel, and players from participating organizations the information necessary to observe or participate in a nuclear power plant accident response exercise focusing on participants' emergency response plans, policies, and procedures as they pertain to this type of event. The information in this document is current as of the date of publication and is subject to change as dictated by the EPT.The 2015 Limerick Generating Station Evaluated Full Scale Exercise is an unclassified exercise.The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, Controllers, and Evaluators, but Players may view other materials deemed necessary to their performance.

The ExPlan may be viewed by all exercise participants, but the Controller and Evaluator (C/E) Handbook is a restricted document intended for Controllers and Evaluators only.All exercise participants should use appropriate guidelines to ensure the proper control of information within their areas of expertise and to protect this material in accordance with current jurisdictional directives.

Public release of exercise materials to third parties is at the discretion of DHS and the EPT.91 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generatring Station This page is intentionally left blank.92 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Handling Instructions

1. The title of this document is 2015 Limerick Generating Station Evaluated Full Scale Exercise Plan (ExPlan).2. The information gathered in this ExPlan should be handled as sensitive information not to be disclosed.

This document should be safeguarded, handled, transmitted, and stored in accordance with appropriate security directives.

Reproduction of this document, in whole or in part, without prior approval from Exercise Planning Director is prohibited.

3. At a minimum, the attached materials will be disseminated only on a need-to-know basis and when unattended, stored in an area offering sufficient protection against theft, compromise, inadvertent access, and unauthorized disclosure.

4. For more information, please consult the following points of contact (POCs): Federal POC(s): Tina Lai Thomas, Technological Hazards Program Specialist Department of Homeland Security (DHS)Federal Emergency Management Agency (FEMA) Region III 615 Chestnut Street, Sixth Floor One Independence Mall Philadelphia, Pennsylvania 19106-4404 215.931.5680 Tina.Thomas(~fema.dhs .gov State POC(s): Sandra B. Silva, Radiological Planner Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, Pennsylvania 17110 717.561.2235 sans ilva(~pa.

gov 93 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station TABLE OF CONTENTS Exercise Plan ...........................................................................................

90 Limerick Generating Station FEMA Evaluated REP Exercise .................................

90 U.S. DEPARTMENT OF HOMELAND SECURITY ............................................

90 Preface ...................................................................................................

91 Handling Instructions

.................................................................................

93 Chapter 1: General Information

....................................................................

96 Introduction..........................................................................................

96 Confidentiality.......................................................................................

96 Purpose ...............................................................................................

96 Core Capabilities

....................................................................................

97 Exercise Objectives

.................................................................................

97 Outstanding Issues ..................................................................................

98 Chapter 2: Exercise Logistics

........................................................................

99 Exercise Summary...................................................................................

99 General ..............................................................................................

99 Assumptions........................................................................................

99 Constructs and Constraints.......................................................................

100 Exercise Participants..............................................................................

100 Exercise Tools ....................................................................................

101 Controller Handbook.............................................................................

101 Master Scenario Events List .....................................................................

101 Exercise Implementation

.........................................................................

102 Exercise Play......................................................................................

102 Exercise Rules ....................................................................................

102 Safety Requirements................................................................................

102 General .................

............................................................................

102 Exercise Setup ....................................................................................

103 Accident Reporting and Real Emergencies

....................................................

103 Site Access...........................................................................................

103 Observer Coordination...........................................................................

103 Exercise Identification......................

.....................................................

104 Communications Plan .............................................................................

104 Exercise Start, Suspension, and Termination Instructions

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104 Player Communication...........................................................................

104 Player Briefing ....................................................................................

105 Public Affairs .....................................................................................

105 94 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Chapter 3: Player Guidelines

.........................................................................

106 Exercise Staff .........................................................................................

106 Exercise Director..................................................................................

1-6 Lead Controller....................................................................................

106 Controllers.........................................................................................

107 Lead Evaluator

....................................................................................

107 Evaluators

......................

...................................................................

107 Player Instructions

...................................................................................

107 Before the Exercise.........................................

......................................

107 During the Exercise...............................................................................

108 Following the Exercise ...........................................................................

108 Simulation Guidelines

...............................................................................

109 Chapter 4: Evaluation and Post-Exercise Activities

..............................................

110 Exercise Documentation

............................................................................

11 0 Exercise Evaluation Guides ......................................................................

110 Players Critique.......................................................................................110 Hotwash ................................................................................................

110 Participants and Public/Media Briefings.........................................................

11 After Action Report..................................................................................

11 After Action Conference and Improvement Plan ..............................................

11 After Action Conference..........................................................................

111 Improvement Plan .................................................................................

111 Annex A: Exercise Schedules

.........................................................................

112 Annex B: Method of Operations and Extent of Play..............................................

114 Annex C: Participating Agencies and Site Maps ..................................................

115 Annex D: Directions

....................................................................................

116 Annex E: Open Issues ..................................................................................

117 Extent of Play............................................................................................

118 95 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Chapter 1: General Information Introduction The 2015 Limerick Generating Station Exercise is a full-scale exercise (FSE) designed to establish a learning environment for players to exercise emergency response plans, policies, and procedures as they pertain to Nuclear Power Plant accidents.

An FSE is a complex event that requires detailed planning.

To conduct an effective exercise, subject matter experts (SMEs) and local representatives from numerous agencies have taken part in the planning process and will take part in exercise conduct and evaluation.

This Exercise Plan (ExiPlan) was produced at the direction of the Federal Emergency Management Agency (FEMA) and the Pennsylvania Emergency Management Agency (PEMA)with the input, advice, and assistance of the EPT. The 2015 Limerick Generating Station Evaluated Full Scale Exercise is evidence of the growing partnership between State and local jurisdictions for response to the threats our nation and communities face.Confidentiality The 2015 Limerick Generating Station Evaluated Full Scale Exercise is an unclassifed exercise.The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, controllers, and evaluators, but players may view other materials deemed necessary to their performance.

This ExPlan may be viewed by all exercise participants, but the Controller and Evaluator (C/E) Handbook is a restricted document intended for controllers and evaluators only.All exercise participants should use appropriate guidelines to ensure the proper control of information within their areas of expertise and protect this material in accordance with current Federal Emergency Management Agency (FEMA) directives.

Public release of exercise materials to third parties is at the discretion of the Federal Emergency Management Agency (FEMA) and the EPT.Purpose The purpose of this exercise is to evaluate player actions against current response plans and capabilities for a nuclear power plant-related incident, and to comply with the requirements of 44 CFR 350 and the guidelines of NUREG 0654/FEMA-REP-1.

Exercise planners utilized the elements described in the Radiological Emergency Preparedness (REP) Program Manual (July 2015) to develop this exercise.The objective of the Federal Emergency Management Agency (FEMA) and the Pennsylvania Emergency Management Agency (PEMA) is to demonstrate reasonable assurance that the public can be protected during a nuclear power plant emergency.

95 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Core Capabilities The establishment of the National Preparedness Priorities have steered the focus of homeland security toward a capabilities-based planning approach.

Capabilities-based planning focuses on planning under uncertainty, since the next danger or disaster can never be forecast with complete accuracy.

Therefore, capabilities-based planning takes an all-hazards approach to planning and preparation which builds capabilities that can be applied to a wide variety of incidents.

States and Urban Areas use capabilities-based planning to identify a baseline assessment of their homeland security efforts by comparing their current capabilities against the Core Capabilities List (CCL)and the critical tasks of the Universal Task List (UTL). This approach identifies gaps in current capabilities and focuses efforts on identifying and developing priority capabilities and tasks for the jurisdiction.

These priority capabilities are articulated in the jurisdiction's homeland security strategy and Multi-Year Training and Exercise Plan (TEP), of which this exercise is a component.

The capabilities listed below have been selected by the EPT planning team from the priority capabilities identified in Pennsylvania Multi-Year TEP. These capabilities provide the foundation for development of the exercise objectives and scenario, as the purpose of this exercise is to measure and validate performance of these capabilities and their associated critical tasks.* Operational Communications

• Public Health and Medical Services* Critical Transportation

• Public and Private Services and Resources* Operational Coordination

• Public Information and Warning* On-scene Security and Protection

• Environmental Response/Health and Safety* Mass Care Services* Supply Chain Integrity and Security* Economic Recovery Exercise Objectives The EPT selected objectives that focus on evaluating emergency response procedures, identifying areas for improvement, and achieving a collaborative attitude.

This exercise will focus on the following objectives:

• The objective of this exercise is to demonstrate reasonable assurance that the health and safety of the public can be protected, through successful demonstration of tasks identified in Appendix B, Extent-of-Play.

97 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* The players in this exercise will satisfactorily demonstrate negotiated competency on key Demonstration Criteria as defined in Radiological Emergency Preparedness (REP)Program Manual (July 2015) as negotiated and defined in Appendix B, Extent-of-Play.

Outstanding Issues There are no (0) Issues remaining as a result of the FEMA-evaluated plume-phase exercise at Limerick Generating Station in 2013.98 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportllmprovenment Plan Limerick Generating Station Chapter 2: Exercise Logistics Exercise Summary General The 2015 Limerick Generating Station Evaluated Full Scale Exercise is designed to establish a learning environment for players to exercise their plans and procedures for responding to an incident at a Nuclear Power Plant. The 2015 Limerick Generating Station Evaluated Full Scale Exercise will be conducted on November 17, 2015. Exercise play is scheduled for eight (8)hours or until the Lead Controller in consultation with FEMA and the Utility determines that the exercise objectives have been met at each venue. Out-of-Sequence Evaluations will be conducted as follows:* The MS-i hospital demonstration was federally evaluated at Brandywine Hospital, Chester County, on August 11, 2015.* The exercise window for school demonstrations will be between 9:00 -11:00 a.m. on November 17, 2015.* The demonstration of reception centers, mass care centers (as indicated), monitoring/decontamination centers and emergency worker stations will be conducted between 7:00 p.m. -9:30 p.m. on November 18, 2015.o Thirty six mass care centers (6 in Berks, 15 in Bucks, 6 in Chester, 5 in Lehigh, and 4 in Montgomery) will receive "walkdown" baseline evaluations on October 29 and 30, 2015. These 36 mass care centers will not be evaluated during the evening of November 18. There are two co-located Mass Care/Monitoring and Decontamination Centers in Berks and one in Lehigh that will be evaluated on the evening of November 18.* The interview of Pennsylvania State Police traffic control/access control points will be from 10:00 a.m. -12:00 noon November 18, 2015.Assumptions Assumptions constitute the implied factual foundation for the exercise and, hence, are assumed to be present before the start of the exercise.

The following general assumptions apply to the 2015 Limerick Generating Station Evaluated Full Scale Exercise:*The exercise will be graded against the REP criteria.

Elements outside the scope of the REP criteria will not be graded.*This exercise will be conducted in a no-fault learning environment wherein systems and processes, not individuals, will be evaluated.

• Exercise simulation will be realistic and plausible, containing sufficient detail from which to respond.99 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* Exercise players will react to the information and situations as they are presented, in the same manner as if this had been a real event.Constructs and Constraints Constructs are exercise devices designed to enhance or improve exercise realism. Alternatively, constraints are exercise limitations that may detract from exercise realism. Constraints may be the inadvertent result of a faulty construct or may pertain to financial and staffing issues.Although there are a number of constructs and constraints (also known as exercise artificialities) for any exercise, the EPT recognizes and accepts the following as necessary:

• Exercise communication and coordination will be limited to the participating exercise venues and the Simulation Cell (SimCell).

• Only those communication methods listed in the Communication Directory will be available for players to use during the exercise.* Out-of-Sequence play is allowed.* Certain simulations are allowed.The participating agencies may need to balance exercise play with real-world emergencies.

It is understood that real-world emergencies will take priority.Exercise Participants The following are the categories of participants involved in this exercise; note that the term"participant" refers to all categories listed below, not just those playing in the exercise:*Players.

Players are agency personnel who have an active role in responding to the simulated emergency and perform their regular roles and responsibilities during the exercise.

Players initiate actions that will respond to and mitigate the simulated emergency.

• Controllers.

Controllers set up and operate the exercise site; plan and manage exercise play; act in the roles of response individuals and agencies not playing in the exercise.Controllers direct the pace of exercise play and routinely include members from the exercise planning team. They provide key data to players and may or initiate certain player actions to ensure exercise continuity.

• Simulators.

Simulators are control staff personnel who role-play as nonparticipating organizations or individuals.

They most often operate out of the SimCell, but may occasionally have face-to-face contact with players. Simulators function semi-independently under the supervision of SimCell controllers, enacting roles (e.g., as media reporters or next of kin) in accordance with instructions provided in the Master Scenario Events List (MSEL). All simulators are ultimately accountable to the Exercise Director and/or the Senior Controller.

• Evaluators.

Evaluators are chosen to evaluate and provide feedback on a designated functional area of the exercise.

They are chosen based on their expertise in the functional 100 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station area(s) they have been assigned to review during the exercise and their familiarity with local emergency response procedures.

Evaluators assess and document participants' performance against established emergency plans and exercise evaluation criteria, in accordance with HSEEP standards and within the bounds of REP Program guidance and regulations.

They are typically chosen from amongst planning committee members or the agencies/organizations that are participating in the exercise.

FEMA Evaluators will not serve as Controllers.

• Actors. Actors are exercise participants who act or simulate specific roles during exercise play. They are typically volunteers who have been recruited to play the role of victims or other bystanders.

• Observers.

Observers visit or view selected segments of the exercise.

Observers do not play in the exercise, and do not perform any control or evaluation functions.

Observers will view the exercise from a designated observation area and will be asked to remain within the observation area during the exercise.

VIPs are a type of observer, but are frequently grouped separately.

A dedicated group of exercise Controllers should be assigned to manage these groups. PEMA will provide observers to risk municipalities to observe and document activity at evaluated and non-evaluated OROs.*Media Personnel.

Some media personnel may be present as observers pending approval by the Exercise Director in coordination with the PEMA Press Office. Media interaction may also be simulated by the SimCell to enhance realism and meet related exercise objectives.

A dedicated group of exercise controllers should be assigned to manage these groups.*Support Staff. Exercise support staff includes individuals who are assigned administrative and logistical support tasks during the exercise (i.e. registration, catering, etc.)Exercise Tools Controller Handbook The 2015 Limerick Generating Station Evaluated Full Scale Exercise CiE Handbook is designed to help exercise Controllers and evaluators conduct and evaluate an effective exercise.

This Handbook also enables Controllers and Evaluators to understand their roles and responsibilities in exercise execution and evaluation.

Should a Player, Observer, or media representative find an unattended Handbook, it should be provided to the nearest Controller or Evaluator.

PEMA determine if a Controller Handbook will be used.Master Scenario Events List The MSEL outlines benchmarks, as well as injects that drive exercise play. It also details realistic input to the exercise players, as well as information expected to emanate from simulated organizations (i.e., those nonparticipating organizations, agencies, and individuals who would usually respond to the situation).

An inject will include several items of information, such as 101 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station inject time, intended recipient, responsible controller, inject type, a short description of the event, and the expected player action.Exercise hnplementation Exercise Play Exercise play will begin at approximately 4:00 p.m. on November 17, 2015 with a situation update going to each participating venue. Play will proceed according to the events outlined in the MSEL, in accordance with established plans and procedures.

The exercise will conclude upon the completion of operations and attainment of the exercise objectives, as determined by FEMA and the Utility.Exercise Rules The following are the general rules that govern exercise play:* Real-world emergency actions take priority over exercise actions.* Exercise participants will comply with real-world response procedures, unless otherwise directed by control staff.* All communications (written, radio, telephone, etc.) made during the exercise will begin and end with the phrase, "This is an exercise.

" Exercise participants placing telephone calls or initiating radio communication with the SimCell must identify the organization, agency, office, and/or individual with whom they wish to speak.Safety Requirements General Exercise participant safety takes priority over exercise events. Although the organizations involved in the 2015 Limerick Generating Station Evaluated Full Scale Exercise come from various response agencies, they share the basic responsibility for ensuring a safe environment for all personnel involved in the exercise.

In addition, aspects of an emergency response are dangerous.

Professional health and safety ethics should guide all participants to operate in their assigned roles in the safest manner possible.

The following general requirements apply to the exercise:* All exercise controllers, evaluators, and staff will serve as safety observers while the exercise activities are underway.

Any safety concerns must be immediately reported to the Lead Controller.

• Participants will be responsible for their own and each other's safety during the exercise.It is the responsibility of all persons associated with the exercise to stop play if, in their 102 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station opinion, a real safety problem exists. Once the problem is corrected, exercise play can be restarted.

• All organizations will comply with their respective environmental, health, and safety plans and procedures, as well as the appropriate Federal, State, and local environmental health and safety regulations.

Exercise Setup Exercise setup involves the pre-staging and dispersal of exercise materials; including registration materials, documentation, signage, and other equipment as appropriate.

Accident Reporting and Real Emergencies

• Anyone observing a participant who is seriously ill or injured will first advise the nearest controller, then if possible, render aid, provided the aid does not exceed his or her training.*The controller who is made aware of a real emergency will initiate the broadcast"Real- World Emergency" on the controller radio network, providing the following information to the Senior Controller and Exercise Director: o Venue/function o Location within the venue/function o Condition o Requirements

• The SimCell will be notified as soon as possible if a real emergency occurs.* If the nature of the emergency requires a suspension of the exercise at the venue/function, all exercise activities at that facility will immediately cease. Exercise play may resume at that venue/function once the "Real-World Emergency" situation has been addressed.

• Exercise play at other venue/functions should not cease if one venue/function has declared a "Real-World Emergency" unless they are reliant on the affected venue.*If a real emergency occurs that affects the entire exercise, the exercise may be suspended or terminated at the discretion of the Exercise Director and Senior Controller.

The notification will be made from the SimCell.Site Access Observer Coordination Each organization with observers will coordinate with the PEMA and the Utility for access to the exercise site. Observers will be escorted to an observation area for orientation and conduct of the exercise.

All observers will be asked to remain within the designated observation area during the exercise.

Designated PEMA or Utility representatives and/or the Observer Controller will be 103 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station present to explain the exercise program and answer questions for the observers during the exercise.PEMA Observers and Liaison Officers PEMA will assign Observers and Liaison Officers to each County and Municipal Emergency Operations Center that is being evaluated in the 2015 Limerick Generating Station Evaluated Full Scale Exercise.

The Lead Controller will provide a list of Observers and Liaison Officers to the appropriate Off-Site Response Organizations prior to the day of the exercise.

All Observers and Liaison Officers will receive a pre-exercise briefing.PEMA Observers are not intended to be players and should excuse themselves from any active participation in the exercise.

If an Observer is engaged in any way by one of the exercise players he/she should refer the player to the PEMA Liaison Officer.PEMA Liaison Officers ar___e players and are assigned specific responsibilities for the exercise.Liaison Officers are instructed to call into the State Emergency Operations Center (SEOC) upon arrival at the exercise venue. They are required to confirm their arrival and provide to the SEOC Watch Officer phone numbers at which they can be reached during the exercise.

Liaison Officers are allowed to interact in the exercise as a PEMA representative and are sometimes required to provide injects to facilitate exercise play.Exercise Identification Identification badges may be issued to exercise staff. All exercise personnel and observers will be identified by badges distributed by the staff from each participating agency.Communications Plan Exercise Start, Suspension, and Termination Instructions The exercise is scheduled to run for eight (8) hours or until the Lead Controller in coordination with FEMA and the Utility determines that the exercise objectives have been met. The Lead Controller will announce the exercise suspension or termination through the State Emergency Operations Center (SEOC).Player Communication Players will use routine, in-place agency communication systems. Additional communication assets may be made available as the exercise progresses.

The need to maintain capability for a real-world response may preclude the use of certain communication channels or systems that would usually be available for an actual emergency incident.

In no instance will exercise.104 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station communication interfere with real-world emergency communications.

Each venue will coordinate its own internal communication networks and channels.The primary means of communication among the SimCell, Controllers, and the venues will be telephone.

A list of key telephone and fax numbers, and radio call signs will be available as a Communication Directory before the start of the exercise.Player Briefing Controllers/Evaluators may be required to read specific scenario details to the participants to begin exercise play. They may also have technical handouts or other materials to give to players in order to better orient them to the exercise environment.

Public Affairs Joint Information Centers will be established at both the Utility Emergency Operations Facility and the State Emergency Operations Centers. Actors will play the role of reporters "public briefings will be given as they would for a real incident." These "public briefings will be simulated and not broadcast for the public." The briefings will be available for viewing at the County EOCs.Any participation by the actual media will be coordinated through the Exercise Director in conjunction with the PEMA Public Information Office.This exercise enables Players to demonstrate an increased readiness to deal with a nuclear power plant incident.

Any nuclear power plant exercise may be a newsworthy event. Special attention must be given to the needs of the media, allowing them to get as complete and accurate a story as possible while ensuring their activities do not compromise the exercise realism, safety, or objectives.

Exelon, FEMA, PEMA, and involved counties are responsible for disseminating public information in advance of the exercise.105 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Chapter 3: Player Guidelines Exercise Staff Exercise Director The Exercise Director has the overall responsibility for planning, coordinating, and overseeing all exercise functions.

The Exercise Director for the 2015 Limerick Generating Station Evaluated Full Scale Exercise is the Regional Assistance Committee (RAC) Chair. He/she manages the exercise activities and maintains a close dialogue with the Controllers regarding the status of play and the achievement of the exercise design objectives.

The FEMA Region III RAC Chair for the Limerick Generating Station has authority to make determinations concerning evaluation issues and re-demonstrations.

The PEMA Limerick Generating Station Planner has responsibility to organize and lead the Exercise Planning Team.Trusted Agents Trusted agents are exercise planners and participants who are responsible for developing the Scenario and the Master Scenario Events List (MVSEL). These documents are restricted and are not available to the rest of the Exercise Planning Team, Players, or other Participants.

The trusted agents for the 2015 Limerick Generating Station Evaluated Full Scale Exercise include the Exercise Director, Lead Controller, Bureau of Radiation Protection (BRP) Representative, FEMA Emergency Management Program Specialist, and the Radiological Emergency Preparedness Regional Assistance Committee (RAC) Chair.Lead Controller The Lead Controller also functions as a Trusted Agent. As such he is involved in developing the Master Scenario Events List and is privy to the scenario used at the utility to generate exercise play. The Lead Controller is responsible for scheduling controllers at the "Out-of-Sequence" components of the exercise and the 2015 Limerick Generating Station Evaluated Full Scale Exercise.

The Lead Controller monitors exercise progress and coordinates decisions regarding deviations or significant changes to the scenario caused by unexpected developments during play. The Lead Controller monitors actions by individual Controllers and ensures they implement all designated and modified actions at the appropriate time. The Lead Controller will be the PEMA REP Staff designee and is stationed in the State BOC during the Exercise.The Lead Controller is responsible for the overall organization of the 2015 Limerick Generating Station Evaluated Full Scale Exercise.

The Lead Controller monitors exercise progress and coordinates decisions regarding deviations or significant changes to the scenario caused by unexpected developments during play. The Lead Controller monitors actions by individual Controllers and ensures they implement all designated and modified actions at the appropriate 106 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station time. The Lead Controller debriefs the Controllers after the exercise and oversees the setup and takedown of the exercise.Controllers At least one observer, liaison, or controller will be onsite with every facility and field team participating in the exercise, and at each out-of-sequence interview.

The Lead Facility Controller at each location will coordinate any changes that impact the scenario or affect other areas of play through the Lead Controller.

The individual controllers issue exercise materials to players as required and monitor the exercise.

Controllers or liaison also provide injects to the players as described in the MSEL.Lead Evaluator The Lead Evaluator is responsible for the overall evaluation of the 2015 Limerick Generating Station Evaluated Full Scale Exercise.

The Lead Evaluator monitors exercise progress and stays in contact with the Lead Controller regarding changes to the exercise during play. The Lead Evaluator monitors actions of individual Evaluators and ensures they are tracking progress of the players in accordance with the Extent-of-Play.

The Lead Evaluator debriefs the evaluators after the exercise and oversees the entire evaluation and After Action process.Evaluators Evaluators work under the direction of the Lead Evaluator, and as a team with Controllers.

Evaluators are SMEs who record events that take place during the exercise and assess/submit documentation for review and inclusion in the After Action Report (AAR).Before the Exercise* Review the appropriate emergency plans, procedures, and exercise support documents.

• Be at the appropriate site at least 30 minutes before the start of the exercise.

Wear appropriate uniform/identification badge.* If you gain knowledge of the scenario before the exercise, notify a controller so that appropriate actions can be taken to ensure a valid evaluation.

• Read your Player Information Handout, which includes information on exercise safety.* Please sign in.107 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station During the Exercise*Respond to the exercise events and information as if the emergency were real, unless otherwise directed by an exercise controller.

• Controllers will only give you information they are specifically directed to disseminate.

You are expected to obtain other necessary information through existing emergency information channels.*Do not engage in personal conversations with controllers, evaluators, observers, or media personnel while the exercise is in progress.

If you are asked an exercise-related question, give a short, concise answer. If you are busy and cannot immediately respond, indicate so, but report back with an answer at the earliest time possible.* If you do not understand the scope of the exercise or if you are uncertain about an organization's or agency's participation in an exercise, ask a controller.

• Parts of the scenario may seem implausible.

Recognize that the exercise has objectives to satisfy and may require the incorporation of unrealistic aspects. Note that every effort has been made by the trusted agents to balance realism with safety and the creation of an effective learning and evaluation environment.

• All exercise communication will begin and end with the phrase "This is an exercise." This is a precaution taken so anyone overhearing the conversation will not mistake the exercise play for a real-world emergency.

• When communicating with the SimCell, identify the organization, agency, office, and/or individual with which you want to speak.*Verbalize out loud when taking an action. This will ensure that evaluators are made aware of critical actions as they occur.*Maintain a log of your activities.

Many times, this log may include documentation of activities missed by a controller or evaluator.

Following the Exercise*At the end of the exercise at your facility, participate in the brief critique with the controllers and evaluators.

• Complete the Participant Feedback Form. This form allows you to comment candidly on emergency response activities and effectiveness of the exercise.

Please provide the completed form to a controller or evaluator.

• Provide any notes or materials generated from the exercise to your controller or evaluator for review and inclusion in the AAR.108 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Simulation Guidelines Because the 2015 Limerick Generating Station Exercise is of limited duration and scope, the physical description of what would fully occur at the incident sites and surrounding areas will be relayed to the Players by Simulators or Controllers.

If a real emergency occurs during the exercise, the exercise at your respective venue may be suspended or terminated at the discretion of the controller(s) at each venue. If a real emergency occurs, say "Real-World Emergency" and notify the nearest Controller and Evaluator.

109 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Chapter 4: Evaluation and Post-Exercise Activities Exercise Documentation The goal of the 2015 Limerick Generating Station Evaluated Full Scale Exercise is to comprehensively exercise and evaluate the OROs' plans and capabilities as they pertain to a potential nuclear power plant incident.

After the exercise, data collected by Controllers, Evaluators, the SimCell, and Players will be used to identify strengths and areas for improvement in the context of the exercise design objectives.

Exercise Evaluation Guides DHS has developed Exercise Evaluation Guides (EEGs) that identify expected activities for evaluation, provide consistency across exercises, and link individual tasks to disciplines and expected outcomes.The Federal Emergency Management Agency (FEMA) Region III has decided not to use EEG's as part of Exercise Documentation process.Players Critique Immediately following the completion of exercise play, Controllers will facilitate a critique with Players from their assigned location.

The critique is an opportunity for Players to voice their opinions on the exercise and their own performance.

At this time, Controllers can also seek clarification on certain actions and what prompted Players to take them. The critique should not last more than 30 minutes. Controllers should take notes during the critique and include these observations in their analysis.Hotwash Prior to the Participants and Public/Media Briefing, The Federal Emergency Management Agency (FEMA) will facilitate a Hotwash with the State, Risk and Support Counties, local jurisdictions and agencies participating in the exercise.

The Hotwash is an opportunity for evaluators and participants to voice preliminary performance concerns, demonstrated strengths, and thank those who played. At this time,. Evaluators can also seek clarification on certain actions and what prompted Players to take them. Evaluators should take notes during the Hotwash and include these observations in their analysis, if necessary.

The Hotwash will be held at 3:00 p.m. on Thursday, November 19, 2015 at the Courtyard Valley Forge/Collegeville, 600 Campus Drive, Collegeville, Pennsylvania 19426.110 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Participants and Public/Media Briefings The Participants Briefing will be conducted on Friday November 20, 2015 at 10:00 a.m. at Courtyard Valley Forge/Collegeville, 600 Campus Drive, Collegeville, Pennsylvania 19426.The Public/Media Briefing will also be conducted on Friday November 20, 2015 at 11:00 a.m. at the same location mentioned above.After Action Report The AAR is the culmination of the exercise.

It is a written report outlining the strengths and areas for improvement identified during the exercise.

The AAR will include the timeline, executive summary, scenario description, performance issues, planning issues, deficiencies, and capability analysis.

The AAR will be drafted by a core group of individuals from the exercise planning team.After Action Conference and Improvement Plan The improvement process represents the comprehensive, continuing preparedness effort of which the 2015 Limerick Generating Station Evaluated Full Scale Exercise is a part. The lessons learned and recommendations from the AAR will be incorporated into the Improvement Plan (IP).After Action Conference The After Action Conference (AAC) will be scheduled for approximately 90 days following the exercise, is a forum for jurisdiction officials to hear the results of the evaluation analysis, validate the findings and recommendations in the draft AAR, and begin development of the IP.Improvement Plan The IP identifies how recommendations will be addressed, including what actions will be taken, who is responsible, and the timeline for completion.

It is created by key stakeholders from the 2015 Limerick Generating Station Evaluated Full Scale Exercise participating agency officials during the AAC.Iii Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Annex A: Exercise Schedule Table A.1 2015 Limerick Generating Station Exercise Schedule TCF, DEP/BRP Field Monitoring Teams 112 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Table A.2 2015 Limerick Generating Station Exercise Out-of-Sequence Schedule A u g u st 1 1 ,,2 0 1 5 .. .. ..,:.. ... ...: : .... .. ..... ... : : .. Completed Brandywine Hospital, Chester MS-i Hospital Federal___________jCounty Evaluation Various times Mass Care Facilities in Berks, Mass Care Walkdown Bucks, Chester, Montgomery, Inspections by PEMA, FEMA, and Lehigh Counties American Red Cross and County Personnel N ovem ber 17, 2015 ... ....." .... :.. .. ... .:: : -: :. ...9:00 -11:00 a.m. 23 Pennsylvania Schools will be School Demonstrations evaluated in 13 school districts in Berks, Chester, and Montgomery Counties.Noeber 18, 2015 10:00 -12:00 noon PSP Skippack Barracks, in TCP/ACP Deployment and Schwenksville, Montgomery manning Interview and County Briefing of concepts to Evaluators 7:00 p.m. -9:30 p.m. Selected Reception, Mon/Decon Mass Care, Reception Center, Centers/Stations and Mass Care and Decontamination Station Facilities in Berks, Bucks, Demonstration Evaluations Chester, Lehigh and Montgomery Counties 113 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Annex B: Method of Operation and Extent-of-Play See PEMA Extent-of-Play 114 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Annex C: Participating Agencies and Site Maps Not Used 115 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Annex D: Addresses of Locations to be Evaluated Not Used 116 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Annex E: Open Issues No Open Issues 117 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION EXTENT-OF-PLAY 2015 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE 118 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportflImprovement Plan Limerick Generating Station THIS PA GE IS INTENTIONALL Y LEFT BLANK 119 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportllmprovement Plan Limerick Generating Station Table of Contents METHOD OF OPERATION

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121 I. Limerick Generating Station (LGS).......................................................

121 II. Bureau of Radiation Protection (BRP)....................................................

121 III. PEMA Operations at State EOC........................................................

121 IV. PEMA Area Office Operations..........................................................

122 V. Counties Designated to Participate........................................................

122 VI. PEMA Liaison Officers ...................................................................

122 VII. Controllers..................................................................................

122 VIII. PEMA Observers

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123 IX. FEMA Evaluators.........................................................................

123 X. Demonstration Windows....................................................................

123 XI. Stand-down.................................................................................

125 XII. General Concepts..........................................................................

125 XIII. Re-demonstrations

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125 EXTENT-OF-PLAY AGREEMENT

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127 EVALUATION AREA 1 .........................................................................

127 EVALUATION AREA 2.........................................................................

137 EVALUATION AREA 3........................................................................

.144 EVALUATION AREA 4.........................................................................

154 EVALUATION AREA 5.........................................................................

159 EVALUATION AREA 6.........................................................................

166 AMERICAN RED CROSS RISK AND SUPPORT COUNTY CHAPTERS:

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173 ATTACHMENT A...............................................................................

176 I. Plume Phase Exercise .......................................................................

176 II. Mass Care Center Walkdowns.............................................................

181 ATTACHMENT B...............................................................................

183 120 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION 2015 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE METHOD OF OPERATION I. Limerick Generating Station (LGS)The facility normally uses off-watch section personnel to participate in the exercise.

The plant's simulated events, radiation readings, and emergency classifications will trigger offsite exercise actions. A pre-approved exercise scenario will be used. LGS will notify the State BOC, the Bureau of Radiation Protection and Risk Counties of emergency classifications.

II. Bureau of Radiation Protection (BRP)BRP personnel will be present at the State BOC, the nuclear facility BOF, Branch and field locations; BRP field teams WILL be evaluated during this exercise.

BRP field teams will perform air sampling out-of-sequence, preferably before they deploy to the plume area.III. PEMA Operations at State BOC This "Method of Operation" Document includes activities for the Full-Scale Plume Exercise (November 17, 2015), and the "Out-of-sequence" Activities (November 18, 2015).A. Plume Exercise -November 17, 2015 PEMA staff, augmented by designated PEMA personnel from the Fire Commissioner's Office, the Bureau of Administration, Technical Services, Planning and Preparedness, plus Emergency Preparedness Liaison Officers (EPLOs) with accompanying response team members from designated state departments/agencies, including representatives from the USDA State Emergency Board will comprise initial operations at the State Emergency Operations Center (EOC). The State EOC will not be evaluated during this exercise.B. Plume Exercise -"Out-of-Sequence" Activities

-November 17, 2015 PEMA staff, augmented by designated PEMA personnel will disseminate exercise related messages to the participating Counties for dissemination to the participating School Districts during the morning of November 17, 2015. The State Emergency Operations Center (EOC) and County EOCs will NOT be 121 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station evaluated during the "Out-of-Sequence" component.

PEMA personnel will serve as "Observers" at the identified School Districts.

C. "Out-of-Sequence" Activities

-November 18, 2015 PEMA personnel will serve as "Observers" at the various field exercise locations during the evening "Out-of-Sequence" component November 18, 2015. An exercise coordinator will remain in the State BOG. The State Emergency Operations Center (BOC) and Counties will NOT be evaluated during the evening"Out-of-Sequence" component.

The Pennsylvania State Police (PSP) demonstration will take place at PSP Skippack Barracks, 2047 C Bridge Road, Schwenksville, Montgomery County.The PSP briefing will be performed out-of-sequence in a demonstration window of 10:00 a.m. to 12:00 noon on November 18, 2015.IV. PEMA Area Office Operations The PEMA Area Office (Hamburg -Eastern Area) will not be activated nor evaluated during this exercise.

Selected staff of the Area Office will serve as Liaison Officers to Risk and Support Counties as assigned.

Liaison Officers are exercise participants.

V. Counties Designated to Participate The three risk counties (Berks, Chester, and Montgomery), in coordination with PEMA, will demonstrate the capability to mobilize appropriate staff, activate their respective Emergency Operations Centers and implement emergency response operations to include sheltering and/or evacuation.

County government will provide direction and coordination to risk municipalities.

The two support counties (Bucks and Lehigh) will participate in their assigned support roles. Actual sheltering or evacuation of the general public will be simulated.

VI. PEMA Liaison Officers Liaison officers will be present at the participating risk and support county EOCs, the LGS Emergency Operations Facility (EOF), and LGS Joint Information Center (JIG) to provide assistance, guidance, and support. These liaison officers will participate as players in the exercise.VII. Controllers A lead controller will be present in the State BOG on November 17, 2015. Controllers will be present at the emergency worker monitoring/decontaminating stations and the mass care monitoring/decontamination centers (November 18, 2015). Controllers are not players. Controllers will provide pre-approved injects and information to the players, as 122 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station appropriate, regarding radiological readings during the monitoring of personnel.

Live radioactive sources will not be used. Exception:

individuals tasked with the setup of portal monitoring equipment will use a standard 1 micro curie Cesium 137 source for the purpose of conducting operational tests. Additionally, appropriate test sources will be available and used to verify' the operation of the monitoring/survey instruments per manufacturer's recommendations.

VIII. PEMA Observers PEMA staff, qualified county emergency management personnel, and/or nuclear power plant personnel will be assigned, if required, to key locations for the purpose of observing, noting response actions and conditions, and recording observations for future use. Observers will not take an active part in the proceedings, but will interact with staff members to the extent necessary to fulfill their observer responsibilities.

Coaching of players by observers is not permitted except to provide training to participants awaiting a re-demonstration. (Refer to paragraph XIII)IX. FEMA Evaluators Federal evaluators will be present at the risk and support county BOCs, identified risk municipal EOCs, and at appropriate field locations to evaluate player response to the actual and simulated events in the exercise scenario.

FEM\A will evaluate approximately one-third of the risk municipalities in B erks, Chester, and Montgomery Counties.Out-of-Sequence Period (November 17 and 18, 2015): On November 17, Federal evaluators will be present at the identified "out-of-sequence" demonstration sites per Attachment A, Section 1. 1. These include the identified Public School Districts and participating school buildings.

On November 18, Federal evaluators will also be present at identified Reception Centers, Emergency Worker Monitoring and Decontamination Stations, Mass Care Centers and Mass Care Monitoring and Decontamination Centers, as identified in Attachment A, Section J.B.l1, I.B.2 and I.B.3.Plume Phase Exercise (November 17, 2015): Federal evaluators will be present at the identified risk and support county EOCs to evaluate player response to the actual and simulated events in the exercise scenario.

Additionally, approximately one-third of the risk municipalities will be federally evaluated.

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

The "demonstration windows" for this exercise are: 123 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limecrick Generating Station A. Plume Phase Exercise The out-of-sequence MS-i hospital demonstration will be federally evaluated at Brandywine Hospital, Chester County on August 11, 2015.The out-of-sequence exercise window for school demonstrations will be between 9:00- 11:00 a.m. on November 17, 2015.The out-of-sequence demonstration of reception centers, mass care centers (as indicated), monitoring/decontamination centers and emergency worker stations will be conducted between 7:00 p.m. -9:30 p.m. on November 18, 2015.Locations are specified within Attachment A,Section I.Thirty six mass care centers (6 in Berks, 15 in Bucks, 6 in Chester, 5 in Lehigh, and 4 in Montgomery) will receive "walkdown" baseline evaluations on October 29th and 3 0 th, 2015. These 36 mass care centers will not be evaluated during the evening of November 18. There are two co-located Mass Care/Monitoring and Decontamination Centers in Berks and one in Lehigh that will be evaluated on the evening of November 18. (Please refer to the Extent-of-Play Demonstfration Tables, Attachment A)124 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station The out-of-sequence interview of Pennsylvania State Police traffic control/access control points will be from 10:00 a.m. -12:00 noon November 18, 2015.All demonstrations will commence promptly and, barring any complications, not continue beyond the time of the designated demonstration window.County and municipal EOC operations will be conducted on November 17, 2015 with exercise period from approximately 4:00 -10:00 p.m. unless terminated by the Lead Controller in coordination with the Utility and PEMA. (Please refer to the Extent-of-Play Demonstration Tables, Attachment A)B. Post Plume Exercise No post-plume phase exercise is scheduled during this evaluation.

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

Upon completion of all requirements and after having informed the FEMA evaluator that all evaluation areas have been demonstrated and/or completed, the risk municipality EOCs may request approval from their county BOC to stand-down their portion of the exercise.A. Support counties may request approval to stand-down upon completion of all evaluated objectives from the state EOC.B. The risk county EOC will remain operational until the exercise is officially terminated by the State Lead Controller.

The State EOC will issue an Exercise Termination Message.XII. General Concepts An emergency plan is drafted to address the generally expected conditions of an emergency.

Not everything in the emergency plan may be applicable for a given scenario.

The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a plan that they cannot take actions that are more protective of the public.Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so that the plan can be modified and the appropriate negative assessment applied.XIII. Re-demonstrations During the exercise, any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants provided it does not negatively interfere with the 125 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station exercise.

Refresher training may be provided by the players, observers, and/or controllers.

Evaluators are not permitted to provide refresher training.

Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators.

PEMA may advise the RAG Chair prior to initiating any re-demonstrations.

It is permissible to extend the demonstration window, within reason, to accommodate the re-demonstration.

Activities corrected from a re-demonstration will be so noted.126 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION 2015 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE EXTENT-OF-PLAY AGREEMENT EVALUATION AREA 1 Emergency Operations Management Sub-element l.a -Mobilization INTENT This Sub-element is derived from NUJREG-0654/FEMA-REP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

Criterion 1.a.l: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner.(NUREG-0654/FEMA-REP-1, A.1.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; 11.3, 4)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, out-of-sequence evaluation or by means of drills conducted at any time.Responsible OROs must demonstrate the capability to receive notification of an incident from the licensee; verify the notification; and contact, alert, and mobilize key emergency personnel in a timely manner and demonstrate the ability to maintain and staff 24-hour operations.

Twenty-four-hour operations can be demonstrated during the exercise via rosters or shift changes or otherwise in an actual activation.

Local responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner, when they receive information from the licensee or alternate sources. Responsible OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. Activation of facilities and staff, including those associated with the Incident Command System, must be completed in accordance with ORO plans/procedures.

The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP after these facilities have been activated.

Pre-positioning of emergency personnel is appropriate, in accordance with the Extent-of-Play Agreement, at those facilities located beyond a normal commuting distance from the individual's duty location or residence.

This includes the staggered release of resources from an assembly 127 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station area. Additionally, pre-positioning of staff for out-of-sequence demonstrations may be used in accordance with the Extent-of-Play Agreement.

The REP program does not evaluate Incident Command System tactical operations, only coordination among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

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

The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

Exercises must also address the role of mutual aid in the incident, as appropriate.

An integral part of the response to an HAD scenario at an NPP may also be within the auspices of the Federal Government (e.g., FBI, NRC, or DHS). Protocols for requesting Federal, State, local, and Tribal law enforcement support must be demonstrated, as appropriate.

Any resources must be on the ORO's mobilization list so they can be contacted during an incident, if needed.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

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

Risk counties/municipalities will conduct call-outs to demonstrate the mobilization of key personnel.

The utility JIC will be evaluated for this drill.* Actual calls (or pager notifcations) will be made to the county/municipal EOC personnel for the Plume Phase exercise per plans and procedures.

• In all instances, the demonstration of a shift change is NOT required.

Twenty-four hour staffing will be demonstrated by means of a roster or staffing chart.* All out-of-sequence players will be pre-positioned and equipment will be demonstrated or shown to be inventory (School District personnel, PSP TCP/ACP, Reception Centers, Emergency Worker Monitoring and Decontamination Stations Mass Care/Sheltering Centers and Monitoring and Decontamination Centers).* Individuals working in state facilities and county EOCs may be pre-positioned for the plume phase.* Other locations, including Municipal EOCs, will NOT pre-stage but will wait for notifi cation of emergency before staffing their duty location.Sub-element 1.b -Facilities INTENT 128 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have facilities to support the emergency response.Criterion 1.b.1: Facilities are sufficient to support the emergency response.(NUREG-0654/FEMA-REP-1, 11.3; G.3.a; J.10.h; J.12; K.5.b)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, SAVs, or by out-of-sequence evaluations.

Responsible OROs must demonstrate, no less than once every 8 years, the availability of facilities to support accomplishment of emergency operations (this includes all alternate and backup facilities).

Evaluations are typically performed for EOCs and JI~s, as well as other facilities such as reception/relocation centers. Some of the areas evaluated within the facilities are adequate space, furnishings, lighting, restrooms, ventilation, access to backup power, and/or alternate facility, if required to support operations.

Radio stations, laboratories, initial warning points and hospitals are not evaluated under 1 .b. 1.In addition, facilities will be evaluated for this criterion during the first biennial exercise after any new or substantial changes in structure, equipment, or mission that affect key capabilities, as outlined in respective emergency plans/procedures.

A substantial change is one that has a direct effect or impact on emergency response operations performed in those facilities.

Examples of substantial changes include modifying the size or configuration of an emergency operations center, adding more function to a center, or changing the equipment available for use in a center.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.

PEMA Negotiated Extent-of-Play:

None Sub-element 1.c -Direction and Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to control their overall response to an emergency.

Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.(NUREG-0654/IFEMA-REP-1, A.1.d; A.2.a, b; A.3; C.4, 6)Assessment!Extent-of-Play 129 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Assessment of this Demonstration Criterion may be accomplished in a biennial or tabletop exercise.Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through periodic briefings and/or other means, coordinating with other 0R~s, and ensuring completion of requirements and requests.)

Leadership must demonstrate the ability to prioritize resource tasking and place/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources.

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

PEMA Negotiated Extent-of-Play None 130 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Sub-element 1.d -Communications Equipment INTENT This Sub-element is derived from NUREG-0654iFEMA-REP-1, which requires that OROs establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the EPZ, Federal emergency response organizations, the licensee and its facilities, BOCs, Incident Command Posts, and FMTs.Criterion 1.d.l: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations.(NUREG-0654/FEMA-REP-1, F.1, 2)Assessment/Extent-of-Play Assessment of this Demonstration Criterion is accomplished initially in a baseline evaluation and subsequently in periodic testing and drills. System familiarity and use must be demonstrated as applicable in biennial or tabletop exercise, or if their use would be required, during an actual event.OROs must demonstrate that a primary system, and at least one backup system for fixed facilities, is fully functional at all times. Communications systems are maintained and tested on a recurring basis throughout the assessment period and system status is available to all operators.

Periodic test results and corrective actions are maintained on a real time basis. If a communications system or systems are not functional, but exercise performance is not affected, no exercise issue will be assessed.Communications equipment and procedures for facilities and field units are used as needed for transmission and receipt of exercise messages.

All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations.

OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. Exercise scenarios may require the failure of a communication system and use of an alternate system, as negotiated in the Extent-of-Play Agreement.

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.

PEMA Negotiated Extent-of-Play:

131 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Risk and Support Counties will communicate with the State EOC via SE VAN (primary) and e-mail (secondary.)

PASTAR, State 800 MHz Radio System, and commercial telephone are available for back-up. The State EOC may communicate with the utility and the risk counties via dedicated telephone circuits, commercial "dial-up" lines, or other available means.Risk Counties will communicate with their risk municipalities via public safety radio frequencies (EM4 Radio), Commercial Telephone, Fax, or Amateur Radio Communications (ARES/RACES) or other available means.132 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Sub-element i.e -Equipment and Supplies to Support Operations INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.Criterion 1.e.1: Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (KI1) and other supplies are sufficient to support emergency operations.(NUREG-0654/FEMA-REP-1, 11.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b)Assessment/Extent-of-Play Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation and subsequent periodic inspections.

A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is encouraged.

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.

Specific equipment and supplies that .must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows: KI1: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transients) within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures).

The plans/procedures must include the forms to be used for documenting emergency worker ingestion of RI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined RI in advance.ORG quantities of dosimetry and RI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV.Available supplies of RI must be within the expiration date indicated on RI bottles or blister packs. As an alternative, the ORG may produce a letter from a certified private or State laboratory indicating that the RI supply remains potent, in accordance with U.S. Pharmacopoeia standards.

133 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Dosimetry:

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

Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures.

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

The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary.

Civil Defense Victoreen Model 138s (CD V-138s) (0-200 mnR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary.

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

All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation must be calibrated annually.

Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer.

A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings.

The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source.For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta radiation.

These instruments must be capable of measuring a range of activity and exposure, including radiological protection

/ exposure control of team members and detection of activity on air sample collection media, consistent with the intended use of the instrument and the ORO's plans/procedures.

An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than 1R/hr) and for high-range instruments when available.

If a source is not available for a high-range instrument, a procedure must exist to operationally test the instrument before entering an area where only a high-range instrument can make useful readings.In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s).

The monitor(s) must conform to the standards set forth in the Contamination 134 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-2 1 (March 1995) or in accordance with the manufacturer's recommendations.

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.

Mutual Aid Resources:

If the incoming resources arrive with their own equipment (i.e., monitors and/or dosimetry), they will be evaluated by REP Program standards.

FEMA will not inventory equipment that is not part of the REP Program. If an agency has a defined role in the REP Plan, they are subject to the planning process and standards, as well as the guidance of this Manual.135 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station PEMA Negotiated Extent-of-Play:

In Pennsylvania support counties do not have DRDs, or KI, but those responsible for reception centers and/or monitoring and decontamination centers will have PRDs.Evaluation of DRD and KI quantities will be verified using inventory sheets. DRDs and KI will not be removed from storage locations and boxes/packages will not be opened. K! questions will be addressed through interviews.

Leakage testing verifi cation and K! extension letters (as appropriate) will be available to the evaluator.

All DRDs "read" in units of Roentgens.

The commonwealth, counties and municipalities do not use direct reading dosimeters which "read" in units of milli-Roentgens.

136 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 2 Protective Action Decision Making Sub-element 2.a -Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans/procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates that emergency workers may be permitted to incur during an emergency.

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

Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers, including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.(NUREG-0654/FEMA-REP-1, C.6; f; K.3.a; K.4)Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be assessed concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures.

Participating OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. This would include providing 1(I and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

As appropriate, OROs must demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for emergency workers, based on their plans/procedures or projected thyroid dose compared with the established PAGs for KI administration.

137 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

None 138 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Sub-element 2.b. -Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PAGs.OROs must have the capability to choose, among a range of protective actions, those most appropriate in a given emergency.

OROs base these choices on PAGs from their plans/procedures or EPA' s Manual of Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria, such as plant conditions, licensee PARs, 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.l: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions.(NUREG-0654/FEMA-REP-1, 1.10 and Supplement 3)Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORG must demonstrate the capability to use appropriate means, described in the plans/procedures, to develop PARs for decision-makers based on available information and recommendations provided by the licensee as well as field monitoring data, if available.

The ORG must also consider any release and meteorological data provided by the licensee.The ORG must demonstrate a reliable capability to independently validate dose projections.

The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs must be appropriate to the scenario.

In all cases, calculation of projected dose must be demonstrated.

Projected doses must be related to quantities and units of the PAG to which they will be compared.

PARs must be promptly transmitted to decision-makers in a prearranged format.When the licensee and ORG projected doses differ by more than a factor of 10, the ORG and licensee must determine the source of the difference by discussing input data and assumptions, 139 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportfImprovement Plan Limerick Generating Station using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the PARs if timely and appropriate.

The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

140 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station PEMA Negotiated Extent-of-Play:

This sub-element will not be evaluated during this exercise.Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PAIDs) for the general public (including the recommendation for the use of KIt, if ORO policy).(NUREG-0654/FEMA-REP-1,A.3; C.4, 6; D.4; J.9; J.10.e, f; m)Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions.

OROs must demonstrate the capability to make initial precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAD incident, weather, release timing and magnitude) pose undue risk to an evacuation, or if evacuation may disrupt the efforts to respond to a hostile action.OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure.

Dose assessment personnel may provide additional PARs based on the subsequent dose projections, field monitoring data, or information on plant conditions.

In addition, incident command must provide input regarding considerations for subsequent PARs based on the magnitude of the ongoing threat, the response, and/or site conditions.

The decision-makers must demonstrate the capability to change protective actions based on the combination of all these factors.If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation.

This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established PAG for KI administration.

The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff.If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or protective action decisions with each other. In addition, 141 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

None Sub-element 2.c -PAD Consideration for the Protection of Persons with Disabilities and Access/Functional Needs INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to determine precautionary and/or protective action decisions, including evacuation, sheltering, and use of RI, if applicable, for groups of persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals).

The focus is on those groups of persons with disabilities and access/functional needs that are, or potentially will be, affected by a radiological release from an NPP.Criterion 2.c.1: Precautionary and/or protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs.(NUREG-0654/FEMA-REP-1, D.4; J.9; J.10.d, e)Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise that would include the use of plant conditions transmitted from the licensee.Usually it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range of PAGs, except for incidents where there is a high-risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved.In these cases, factors that must be considered include weather conditions, shelter availability, availability of transportation assets, risk of evacuation versus' risk from the avoided dose, and precautionary school evacuations.

In addition, decisions must be coordinated/communicated with the incident command. In situations where an institutionalized population cannot be evacuated, the ORG must consider use of RI.Applicable OROs must demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective 142 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station actions for students.

Demonstration requires that the OROs actually contact public school systems/districts during the exercise.The OROs must demonstrate how the decision-making process takes those with disabilities and access/functional needs (e.g., nursing homes, correctional facilities, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals) into account.In accordance with plans/procedures, OROs and/or officials of public school systems/districts must demonstrate the capability to make prompt decisions on protective actions for students.The decision-making process, including any preplanned strategies for protective actions for that ECL, must consider the location of students at the time (e.g., whether the students are still at home, en route to school, or at school).Since other agencies place requirements on hospitals to prepare for contaminated patients, the REP Program has no need to evaluate host hospitals, nor does the ORO have the responsibility to provide training or dosimetry.

Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

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

Sub-element 2.d. -Radiological Assessment and Decision Making for the Ingestion Exposure Pathway This sub-element will not be evaluated during this exercise.Sub-element 2.e. -Radiological Assessment and Decision-Making Concerning Post-Plume Phase Re~location, Reentry, and Return This sub-element will not be evaluated during this exercise.143 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 3 Protective Action Implementation Sub-element 3.a -Implementation of Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide for the following:

distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KI for emergency workers, always applying the "as low as is reasonably achievable" principle as appropriate.

Criterion 3.a.1: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to emergency workers.(NUREG-0654/FEMA-REP-1, K.3.a, b; K.4)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise.

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

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures.

If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.144 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station 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 determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge of whom to contact in case authorization is needed, and at what exposure levels.Workers may use any available resources (e.g., written procedures and/or coworkers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. In such cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimeter worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry.

Individuals authorized by the ORG to reenter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with completing their missions.OROs may have administrative limits lower than EPA-400-R-92-00 1 dose limits for emergency workers performing various services (e.g., lifesaving, protection of valuable property, all activities).

OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response.OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s)they did so. Ingestion of KI recommended by the designated ORG health official is voluntary.

For evaluation purposes, the actual ingestion of KI shall not be performed.

OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. Emergency workers must demonstrate basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.

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

PEMA Negotiated Extent-of-Play:

145 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station Radiological briefings will be provided to address exposure limits and procedures to replace those approaching limits and how permission to exceed limits is obtained from the municipality and county. Emergency workers will also be briefed on when to take K! and on whose authority.

Distribution of K! will be simulated.

A maximum of six (6) Dosimetry-KJ report forms will be demonstrated.

OROs should also demonstrate the use of all applicable dosimetry forms to emergency workers.At any time, players may ask other players or supervisors to clarify radiological information.

In Pennsylvania, emergency workers outside of the EPZ do not have turn-back values.Emergency workers who are assigned to low exposure rate areas, (e.g., at reception centers, counting laboratories, emergency operations centers, and communications centers) may have individual direct reading dosimeters or they may be monitored by dosimeters strategically placed in the work area. In Pennsylvania this will be accomplished through the use of an area kit. The area kit process is explained in State, County and Municipal Plans.Standard issue of dosimetry and potassium iodide for each category of emergency worker is as follows: Category A: 1 PRD, 1 DRD, and 1 unit of K!Cate gory B: 1 PRD and 1 unit of K!Category C.. 1 PPD All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP), will make the dosimetry equipment (and KI) available for inspection by the Federal Evaluator.

Simulation PRDs with mock serial numbers will be used.Personnel assigned to operate monitoring/decontamination centers and stations are not issued DRDs or K! since the centers/stations are located outside the EPZ. Each will be issued a simulated PRD with mock serial numbers. For purposes of demonstration, a maximum of six PRDs will be issued.Sub-element 3.b -Implementation of KI Decision for Institutionalized Individuals and the General Public INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide K(1 for institutionalized individuals, and, if in the plans/procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide RI to institutionalized individuals, providing RI to the general public is an ORO option and must be 146 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station reflected as such in ORO plans/procedures.

Provisions must include the availability of adequate quantities, storage, and means of distributing KI.Criterion 3.b.1: KI1 and appropriate instructions are available if a decision to recommend use of KIt is made. Appropriate record-keeping of the administration of KI for institutionalized individuals is maintained. (NUREG-0654/FEMA-REP-1, J.10.e, f)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise.

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

OROs must demonstrate the capability to make 1(1 available to institutionalized individuals, and, where provided for in their plans/procedures, to members of the general public. OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made.OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. Ingestion of KI recommended by the designated ORG health official is voluntary.

For evaluation purposes, the actual ingestion of KI shall not be performed.

OROs must demonstrate the capability to formulate and disseminate instructions on using RI for those advised to take it.147 Unclassified Radiological Emergency Preparedness Program (REP)After Actiont Report/Improvement Plan Limerick Generating Station If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/procedures.

All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

Within Pennsylvania, the Pennsylvania Department of Health is responsible for distribution of K[ to the general public located within the EPZ. Pre-distribution is accomplished on an annual basis. KI is not distributed to the general public at the time of an emergency.

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

Personnel assigned to operate monitoring/decontamination centers and stations are not issued DRDs or K! since the centers/stations are located outside the EPZ. Each will be issued a simulated PRD with mock serial numbers. For purposes of demonstration, a maximum of six PRDs will be issued.Sub-element 3.c -Implementation of precautionary and/or protective action decisions for Persons with Disabilities and Access/Functional Needs INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement precautionary and/or protective action decisions, including evacuation and/or sheltering, for all persons with disabilities and access/functional needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological release from an NPP.Criterion 3.c.1: Precautionary and/or protective action decisions are implemented for persons with disabilities and access/functional needs other than schools within areas subject to protective actions.(NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a~biennial exercise, an actual event, or by means of drills conducted at any time.Applicable 0ROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency information and instructions to) persons with disabilities and access/functional needs, including hospitals/medical facilities, nursing homes, correctional facilities, and mobility-148 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station impaired and transportation-dependent individuals.

OROs must demonstrate the capability to provide for persons with disabilities and access/functional needs in accordance with plans/procedures.

Contact with persons with disabilities and access/functional needs and reception facilities may be actual or simulated, as agreed to in the Extent-of-Play.

Some contacts with transportation providers must be actually contacted, as negotiated in the Extent-of-Play.

All actual and simulated contacts must be logged.Since other agencies place requirements on hospitals to prepare for contaminated patients, the REP Program has no need to evaluate host hospitals, nor does the ORO have the responsibility to provide training or dosimetry.

Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

The names, locations and contact information of identified individuals with identifed special needs are maintained on a list at their respective municipal EOC (based upon residential jurisdiction).

Copies of these lists will not be provided to the evaluators," however, evaluators will be allowed to inspect the lists during the exercise.NOTE: Berks County maintains a countywide special needs list for individuals requiring assistance.

This list may be viewed at the county as it will not be disseminated for exercise purposes.Initial contact, by the County, with special populations (hospitals, nursing homes and county correctional facilities) will be actual. All subsequent calls will be simulated.

Actual contacts (up to two per risk county) will be made with transportation providers per their plan. All actual and simulated contacts should be logged.Criterion 3.c.2: OROs/School officials implement precautionary and/or protective action decisions for schools. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial, or tabletop exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.School systems/districts (these include public and private schools, kindergartens, preschools, and licensed day cares) must demonstrate the ability to implement precautionary and/or protective action decisions for students.

The demonstration must be made as follows: each school systenm/district within the 10 mile EPZ must demonstrate implementation of protective actions.149 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station At least one school per affected system/district must participate in the demonstration.

Canceling the school day, dismissing early, or sheltering in place must be simulated by describing to evaluators the procedures that would be followed.

If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process.If accomplished through an interview, appropriate school personnel including decision-making officials (e.g., schools' superintendent/principals and transportation director/bus dispatchers), and at least one bus driver (and the bus driver's escort, if applicable) must be available to demonstrate knowledge of their role(s) in the evacuation of school children.

Communications capabilities between school officials and the buses, if required by the plans/procedures, must be verified.150 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Officials of the school system(s) must demonstrate the capability to develop and provide timely information to OROs for use in messages to parents, the general public, and the media on the status of protective actions for schools.If a school facility has emergency plans as a condition of licensing, those plans may be submitted to FEMA review in place of demonstration or interview pursuant to the ORO's plans/procedures as negotiated in the Extent-of-Play Agreement.

Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

School students will not be involved during the exercise.

Actions and activities associated with the demonstration of Criterion

3. c.2 will be limited to the School District Administration key personnel and the County. Evacuation of students will be conducted through an interview process with School District personnel or the building principal.

The role of the bus driver may be conducted through an interview with school or transportation officials (or designee) if a bus driver is not available.

Actual demonstration of the bus route is not required and will not be demonstrated.

Maps or route descriptions will be available for illustration purposes.Risk County school plans do not require communications between the school and vehicles.

Bus drivers are not considered emergency workers and therefore do not require dosimetry.

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

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

Any simulated contacts should be logged.Sub-element 3.d. -Implementation of Traffic and Access Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic and access control points, and removal of impediments to the flow of evacuation traffic.151 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Criterion 3.d.1: Appropriate traffic and access control is established.

Accurate instructions are provided to traffic and access control personnel.(NUREG-0654/FEMA-REP-1, A.3; C.1, 4; J.10.g, j)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and PADs (e.g., evacuating, sheltering, and relocation) in a timely manner. OROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas, as per the Extent-of-Play Agreement.

These capabilities may be demonstrated by actual deployment or by interview, in accordance with the Extent-of-Play Agreement.

In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic), they must demonstrate the capability to contact the State or Federal agencies that have the needed authority, as agreed upon in the Extent-of-Play Agreement.

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

Municipal Traffic and Access control will be demonstrated by interview at the applicable EOC of jurisdiction.

The traffic/access control personnel will not be deployed to the traffic/access control point(s).

lIfthe designated assignment is a location within the EPZ, a radiological briefing will be provided to the assigned individuals.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.(NUREG0654/FEMA-REP-1, J.10.k)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.152 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations.

In demonstrating this capability, the impediment must remain in place during the evacuation long enough that re-routing of traffic is required and must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

When, due to specifics of the scenario or jurisdiction, the impediment cannot be located on an evacuation route, it must be located so as to impact the evacuation.

When not possible, actual dispatch of resources need not be physically demonstrated; however, all contacts, actual or simulated, must be logged.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.

PEMA Negotiated Extent-of-Play:

OROs should demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation.

Actual dispatch of resources to deal with impediments, such as tow trucks, need not be demonstrated," however, simulated contacts will be logged If the scenario does not lead to evacuation the criteria shall be deemed complete if the ORO can describe to the evaluator through controller inject or interview the actions they would take to overcome a major traffic impediment during an evacuation and how such actions would be communicated to the public and affected OR Os. (Risk counties only)Sub-element 3.e -Implementation of Ingestion Pathway Decisions This sub-element will not be evaluated during this exercise.Sub-element 3.f -Implementation of Post-Plume Phase Relocation, Reentry, and Return Decisions This sub-element will not be evaluated during this exercise.153 Unclassified Radiological Emergency Preparedness Program (REP)Afttr Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 4 Field Measurement and Analyses Sub-element 4.a -Plume Phase Field Measurements and Analyses INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to deploy FMTs with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUJREG-0654/FEMA-REP-1 indicates that OROs must have the capability to use FMTs within the plume exposure pathway EPZ to detect airborne radioiodine in the presence of noble gases and radioactive particulate material in the airborne plume. In an incident at an NPP, the possible release of radioactive material may pose a risk to-the nearby population and environment.

Although incident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties.

During an incident, it is important to collect field radiological data to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.Criterion 4.a.1: [RESERVED]

Criterion 4.a.2: Field teams (2 or more) are managed to obtain sufficient information to help characterize the release and to control radiation exposure.(NUREG-0654/FEMA-REP-1, C.1; 11.12; 1.7, 8, 11; J.10.a)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise.Other means may include drills that would fully demonstrate technical proficiency.

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

During an H-AB incident, the Field Team management must keep the incident command informed of field monitoring teams' activities and location.

Coordination with FMTs and field monitoring may be demonstrated as out-of-sequence demonstrations, as negotiated in the Extent-of-Play Agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions, or to be a factor in modifying protective actions.Teams must be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts.154 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station If the responsibility for obtaining peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by ORG monitoring teams. If the licensee FMTs do not obtain peak measurements in the plume, it is the ORG's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all FMTs (licensee, Federal, and ORO) is essential.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as necessary.

Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

Department of Environmental Protection (DEP), Bureau of Radiation Protection (BRP) field teams are equipped with the necessary instrumentation and supplies.

FEMA observers will meet the field teams at the R3 V staging area at Wilson Farm Park, 500 Lee Road in Chesterbrook, Pennsylvania at 1:30p.m. on November 17, 2015 to observe instrumentation checks and equipment inventory verification.

Field Team Control will be performed within or near the 10 mile EPZ using the DEP Radiological Rapid Response Vehicle (R3 V). Field Team control is expected to initially be out-of-sequence with the plume timeline.

During the exercise the field teams will be directed to take measurements in locations to provide information sufficient to characterize the plume and impacts. In addition to field team measurements, remote detectors will be located by the field teams near the expected plume pathway, these detectors will automatically transmit data to the R3 V. These detectors will be used to keep field team dose ALARA.Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected.

Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654/IFEMA-REP-1, C.1; 11.12: 1.8, 9; J.10.a)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise.Other means may include drills that would fully demonstrate technical proficiency.

Two or more FMTs must demonstrate the capability to make and report measurements of ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority.

FMTs must also demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and to provide the appropriate authority with field data 155 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station pertaining to measurement.

If samples have radioactivity significantly above background, the authority must consider the need for expedited laboratory analyses of these samples.Coordination concerning transfer of samples, including a chain-of-custody form(s), to a radiological laboratory(ies) must be demonstrated.

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

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Measurements will be made by Department of Environmental Protection (DEP), Bureau of Radiation Protection (BRI), in accordance with the State Annex E, Appendix 6, and BRP Standard Implementing Procedures (1Ps). Two mobile monitoring teams from BRP DEP South East Regional Office will demonstrate ambient radiation monitoring and radioiodine and particulate sampling.

Field teams will be equipped with appropriate dosimetry and K1. Field teams WILL be evaluated by FEMA. Each team will be directed to monitoring locations and perform actual radiation measurements at each location.

Measurements may consist of truck installed radiation monitor or hand-held radiation instruments.

An actual air sample will be taken at the R3 V staging area prior to field team departure to LGS. Field teams will discuss air sample counting procedures via an interview process. Teams will then take additional simulated air samples, as directed, at additional locations, if conditions are appropriate for radioiodine sampling and relay information to the Radiological Rapid Response Vehicle (R3 V). In place of silver zeolite cartridges, charcoal cartridges will be used for the exercise.

All measurements will be forwarded to theR3 V immediately upon obtaining data.FEMA/ observers will meet the field teams at the R3 V staging area at Wilson Farm Park, 500 Lee Road in Chesterbrook, Pa. at 1:30p.m., November 17, 2015.Sub-element 4.b -Post-Plume Phase Field Measurements and Sampling INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess the actual or potential magnitude and locations of radiological hazards to determine the ingestion exposure pathway EPZ and to support relocation, reentry, and return decisions.

This Sub-element focuses on collecting environmental samples for laboratory 156 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station analyses that are essential for decisions on protecting the public from contaminated food and water and direct radiation from deposited materials.

Criterion 4.b.1: The field teams (2 or more) demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision making. (NUREG-0654fFEMA-REP-1, C.1; 1.8; J.11)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise.

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

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

When resources are available, use of aerial surveys and in-situ gamma measurement is appropriate.

All methodology, including contamination control, instrumentation, preparation of samples, and chain-of-custody form(s) for transfer to a laboratory(ies), will be in accordance with the ORO's plans/procedures.

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

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

This sub-element will not be demonstrated during this exercise.Sub-element 4.c -Laboratory Operations INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision making.157 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654/FEMA-REP-1, C.1, 3; J.11)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial, tabletop exercise, or an actual event. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

The laboratory staff must demonstrate the capability to follow appropriate procedures for receiving samples, including logging information, preventing contamination of the laboratory(ies), preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil (e.g., milk), and keeping track of sample identity.

In addition, the laboratory staff must demonstrate the capability to prepare samples for conducting measurements.

The laboratory (ies) must be appropriately equipped to provide, upon request, timely analyses of media of sufficient quality and sensitivity to support assessments and decisions anticipated in the ORO's plans/procedures.

The laboratory instrument calibrations must be traceable to standards provided by the National Institute of Standards and Technology.

Laboratory methods used to analyze typical radionuclides released in a reactor incident must be as described in the plans/procedures.

New or revised methods may be used to analyze atypical radionuclide releases (e.g., transuranics or as a result of a terrorist incident) or if warranted by incident circumstances.

Analysis may require resources beyond those of the ORO.The laboratory staff must be qualified in radioanalytical techniques and contamination control procedures.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

This sub-element will not be evaluated during this exercise.158 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 5 Emergency Notification and Public Information Sub-element 5.a -Activation of the Prompt Alert and Notification System INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide prompt instructions to the public within the plume exposure pathway EPZ. Specific provisions addressed in this Sub-element are further discussed in Section V, Part A of this Manual, Alert and Notification Systems.Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

The initial instructional message to the public must include as a minimum the elements required by current REP guidance. (NUREG-0654/FEMA-REP-1, E.5, 6, 7)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

Responsible OROs must demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas (permanent resident and transient) throughout the 10-mile plume EPZ. Following the decision to activate the alert and notification system, OROs must complete system activation for primary alert/notification and disseminate the information

/ instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of transmission.

Broadcast of the message(s) or test message(s) is not required.

The procedures must be demonstrated up to the point of actual activation.

The alert signal activation should be simulated, not performed.

Evaluations of EAS broadcast stations may also be accomplished through SAVs.The capability of the primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview with appropriate personnel from the primary notification system, including verification of provisions for backup power or an alternate station.The initial message must include at a minimum the following elements: 159 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station* Identification of the ORG responsible and the official with authority for providing the alert signal and instructional message;* Identification of the commercial NPP and a statement that an emergency exists there;* Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and* A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the ORG's plans/procedures and the Extent-of-Play Agreement.

OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time requirements).

At least one route needs to be demonstrated and evaluated.

The selected route(s) must vary from exercise to exercise.

However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as negotiated in the Extent-of-Play.

Actual testing of the mobile public address system will be conducted at an agreed-upon location.OROs may demonstrate any means of primary alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

The Commonwealth of Pennsylvania has implemented a Statewide EAS Control system in cooperation with the Pennsylvania Association of Broadcasters per the State Emergency Communications Committee and Pennsylvania Emergency Alert System State EAS Plan (April]1, 2004). The State EOC (PEMAvL) is the initiating point for the activation of the EAS. Risk Counties have the control equipment for activation of sirens. Coordination will occur between the State EOC and the affected counties with respect to the Alert and Notifcation System (AN[S)process. Sirens will be coordinated and the sounding simulated at the appropriate time with the simulated activation of EAS taking place approximately 3 minutes following the simulated activation of the sirens. Regular Broadcasting will not be interrupted on the EAS Stations.Broadcast of the message (s) or test message(s) is NOT required and NOT requested Counties may elect to simulate county specific supplemental messages to their electronic local media.Following the decision to activate the alert and notification system, in accordance with the ORO 's plan and/or procedures, ANS activation should be accomplished in a timely manner for primary alerting/notification.

This action will be per formed in a responsible time and without delay.160 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station All actions to broadcast stations will be simulated.

Systems that use automatic sending technology may be demonstrated by explanation during an interview.

Each evaluated municipality per risk county will demonstrate, by interview, route alerting of the hearing impaired residents within theirljurisdiction.

Hearing impaired notification teams will not be deployed.Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Backup alert and notification of the public is completed within a reasonable time following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654/FEMA-REP-1, E.6, Appendix 3.B.2.c)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

If the exercise scenario calls for failure of any portion of the primary system(s) or if any portion of the primary system(s) actually fails to function during the exercise, OROs must demonstrate backup means of alert and notification.

Backup means of alert and notification will differ from facility to facility.Backup alert and notification procedures that would be implemented in multiple stages must be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The populations farther away and downwind of any potential radiological release would be covered sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the remaining population as directed by authorities).

Topography, population density, existing ORO resources, and timing will be considered in judging the acceptability of backup means of alert and notification.

Although circumstances may not allow this for all situations, FEMA and the NRC recommend that OROs and operators attempt to establish backup means that will reach those in the plume exposure EPZ within a reasonable time of failure of the primary alert and notification system, with a recommended goal of 45 minutes. The backup alert message must, at a minimum, include: (1) a statement that an emergency exists at the plant; and (2) instructions regarding where to obtain additional information.

When backup route alerting is demonstrated, only one route needs to be selected and demonstrated.

All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast), as negotiated in the Extent-of-Play.

Actual testing of the mobile public address system will be conducted at an agreed-upon location.161 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station OROs may demonstrate any means of backup alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

Back-up alert notifi cation of the public due to a simulated siren failure will be demonstrated.(Refer to Attachment A, Section 1. 4.) County liaisons will give an inject to the county siren dispatcher, upon confirmation that sirens were sounded, that a particular siren has failed in the municipalities scheduled to demonstrate back-up route alerting.

Notice of the siren failure will then be communicated to the appropriate municipalities/locations so they can demonstrate their recommended goal of 45 minute per-identified back-up route alert run as per Attachment A, Section 1.A. 4. Pennsylvania does not have any "exception areas." The 45-minute clock starts when the siren dispatcher receives the notification that a siren has failed.IPA WS may be used, as long as it does not interfere with the required demonstrated and evaluated notifications.

Alternate methods of route alerting will NOT be evaluated.

Criterion 5,a.4: Activities associated with FEMA-approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.(NUREG-0654/FEMA-REP-1, E.6; Appendix 3.B.2.c)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

OROs with FEMA-approved exception areas (identified in the approved Alert and Notification System Design Report), 5 to 10 miles from the NPP, must demonstrate the capability to accomplish primary alerting and notification of the exception area(s). FEMA and the NRC recommend that OROs and operators establish means that will reach those in approved exception areas within 45 minutes once the initial decision is made by authorized offsite emergency officials to notify the public of an incident.

The exception area alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain additional information.

For exception area alerting, at least one route must be demonstrated and evaluated.

The selected route(s) must vary from exercise to exercise.

However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcasted) as negotiated in the Extent-of-Play.

Actual testing of the mobile public address system will be conducted at an agreed-upon location.

For exception areas 162 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station alerted by air / water craft, actual routes will be negotiated in the Extent-of-Play, but must be demonstrated no less than once every 8 years.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.

PEMA Negotiated Extent-of-Play:

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

Pennsylvania has no exception areas.Sub-element 5.b -Subsequent Emergency Information and Instructions for the Public and the Media INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUJREG-0654/FEMA-REP-1 requires OROs to ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency.

NUREG-0654/FEMA-REP-1 also provides that a system must be available for dealing with rumors. This system will hereafter be known as the "public inquiry hotline." Criterion 5.b.1: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner.(NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, or drills.The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in a timely manner following the initial alert and notification (not subject to specific time requirements).

For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.Message elements:

The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials.

The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and 163 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided.

The ORG must also be prepared to disclose and explain the ECL of the incident.

At a minimum, this information must be included in media briefings and/or media releases.

OROs must demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion exposure pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a. 1 and previously identified protective action areas that are still valid, as well as new areas. Information about any rerouting of evacuation routes due to impediments should also be included.

The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media.In addition, the OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures.

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

If ingestion pathway measures are exercised, OROs must demonstrate that a system exists for rapid dissemination of ingestion pathway information to predetermined individuals and businesses in accordance with the ORG's plans/procedures.

Media information:

OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants.

The GROs must demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and releases must be consistent with PADs and other emergency information provided to the public. Copies of pertinent emergency information (e.g., EAS messages and media releases) and media information kits must be available for dissemination to the media.Public inquiry: OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. Hotline staff must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, must be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.All activities must be based on the ORG'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.

PEMA Negotiated Extent-of-Play:

164 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Subsequent emergency information and instructions should be provided to the public and the media in a timely manner. This will NOT be sub/ect to specific time requirements.

One media briefing will be demonstrated in each risk county.Risk and Support Counties will receive and handle "Public Inquiry" messages via their individual "Public Inquiry "processes (in compliance with NIMS terminology, Rumor Control is now considered to be "Public Inquiry "). Counties will receive approximately ten (10) public inquiry calls from the State Exercise cell assigned this responsibility.

Counties will be expected to receive and log the calls, identify any trends and take appropriate actions to include follow-up message development, distributions and/or briefings.

165 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 6 Support Operations/Facilities Sub-element 6.a -Monitoring, Decontamination, and Registration of Evacuees INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of evacuees, while minimizing contamination of the facility.

OROs must also have the capability to identify and register evacuees at reception centers.Criterion 6.a.1: The reception center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees. (NUJREG-0654/FEMA-REP-1, A.3; C.4; J.10.h; J.12)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, drills, or SAy.Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency or as indicated in the Extent-of-Play Agreement.

OROs conducting this demonstration must have one-third of the resources (e.g., monitoring teams/instrumentation/portal monitors) available at the facility (ies) as necessary to monitor 20 percent of the population within a 12-hour period. This would include adequate space for evacuees' vehicles.

Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location.

Plans/procedures must indicate provisions for service animals.Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

Staff responsible for the radiological monitoring of evacuees must demonstrate the capability to attain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. The monitoring productivity rate per hour is the number of evacuees that can be monitored, per hour, by the total complement of monitors using an appropriate procedure.

For demonstration of monitoring, decontamination, and registration capabilities, a minimum of six evacuees must be monitored per station using equipment and procedures specified in the plans/procedures.

The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met.OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities.

The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the 166 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station evacuee's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the plan and/or procedures.

Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated.

Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination.

They must also explain the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures.

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

Decontamination of evacuees may be simulated and conducted by interview.

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

The staff must demonstrate provisions for limiting the spread of contamination.

Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees, provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities.

In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal belongings.

Waste water from decontamination operations does not need to be collected.

Individuals who have completed monitoring (and decontamination, if needed) must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level or have been placed in a secure area until they can be monitored and decontaminated, if necessary.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored.

These individuals do not require confirmation that their vehicle is free from contamination prior to entering the congregate care areas.However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles held in a secure area or monitored and decontaminated (if applicable) 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.PEMA Negotiated Extent-of-Play:

Radiological monitoring demons tration sites should possess a roster of the monitoring personnel required to process the population allocated to the facility within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period.167 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Water from decontamination activities may go directly to a storm drain or other sewer or drain system or area normally designated for wastewater that has been used for bathing or washing of vehicles and or equipment.

Radiological monitoring of the public may be co-located at either reception centers or mass care centers depending on the county plan.At each reception center (stand alone -non-mon/decon activity sites) a minimum of three volunteer evacuees will be processed, briefed, issued the appropriate strip map or directions, and instructed to proceed to a mass care center designated for demonstration of monitoring, decontamination, and registration.

A sample of the appropriate strip maps or directions will be made available for the demonstration.

Note. Co-located facilities do not require strip maps or written directions.

Mass care centers and mass care monitorinjg/decontamination centers will be demonstrated per Attachment A during the out-of-sequence window. The counties will provide space at designated mass care centers for ope ration of monitoring/decontamination centers. Schematics of these monitoring/decontamination centers will be available to show the organization and layout within the facility and space management for monitoring and decontamination.

Procedures will be demonstrated to show the separation of contaminated and non-contaminated (clean) individuals to minimize cross contamination.

At the evacuee monitoring/decontamination centers (if using~ hand-held meters), a minimum of six (6) volunteer evacuees will be monitored (or one volunteer evacuee may be monitored six times). Centers using portal monitors are only required to demonstrate three (3) volunteer evacuees.

Suitable radiological monitoring instruments will be issued to and demonstrated by the initial monitoring team(s). A monitoring team consists of one monitor and one recorder equipped with one survey instrument.

Those individuals found to be free of "contamination

", based upon scenario injects, will be directed to the mass care registration point for further processing.

Note: Actual radiological sources will not be attached to or hidden upon the volunteer evacuees.One of the simulated evacuees, based upon controller injects, will not be able to be decontaminated.

Discussions concerning the processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. Showering will be simulated, water will not be used. Note: If portal monitors are used, see below.At the emergency worker monitorinig/decontamination stations, two (2) emergency workers will be monitored.

Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. Showering will be simulated, water will'not be used. Suitable radiological monitoring instruments will be issued to the initial monitoring team. Note: If portal monitors are used, the Portal Monitor Extent-of-Play described below shall be used.168 Unclassified Radiological Emergency Preparedness Program (REP)After Action ReportlImprovement Plan Limerick Generating Station Portal Monitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees and/or emergency workers. The monitoring/decontamination team requirements will be based on the portal monitor capabilities as applicable based on the procedure/guidelines, and the recommendations of the manufacturer.

Note: PEMA Interim Annex E letter, April 2009 or superseding document shall apply.Monitoring/decontamination centers and Emergency Worker monitoring and decontamination station personnel are not issued DRDs or KI since the centers and stations are outside the EPZ.Category "C" Dosimetry applies. Simulated permanent record dosimeters (PRDs) will be worn.Radiation readings/contamination data for the evacuees and vehicle will be provided by the controller as appropriate based upon information contained in the scenario package. Set-up of the facility will be performed the same as for an actual emergency with all route markings and contamination control measures in place including step-off pad (if used). Long runs of plastic covered with paper will not be demonstrated, but the materials may be available and explained (as appropriate).

Positioning of a fire apparatus on-site may be simulated ifotherwise required.Note: Re-demonstrations may be performed as appropriate and time permitting.

Sub-element 6.b -Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles INTENT This Sub-element is derived from NUJREG0654iFEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of emergency workers and their equipment, inclusive of vehicles.Criterion 6.b.1: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles.(NUREG-0654/FEMA-REP-1, K.5.a, b)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, an actual event, or SAy.The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in accordance with the ORG's plans/procedures.

Specific attention must be given to equipment, including any vehicles that were in contact with contamination.

The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and vehicles based on trigger/action levels and procedures stated in the ORG plans/procedures.

Monitoring of emergency workers does not 169 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station have to meet the 12-hour requirement.

However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency workers and their equipment and vehicles.*Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

The area to be used for monitoring and decontamination must be set up as it would be in an actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles.

However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated.

Interior surfaces of vehicles that were in contact with contaminated individuals must also be checked.Decontamination of emergency workers may be 'simulated and conducted via interview.

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

The staff must demonstrate provisions for limiting the spread of contamination.

Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated individuals where applicable; provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of emergency workers or facilities.

OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and decontamination activities.

The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the emergency worker's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the plan and/or procedures.

Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated.

Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination.

They must also explain the procedures for referring any emergency workers who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures.

Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by interview.

Waste water from decontamination operations does not need to be collected.

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.

PEMA Negotiated Extent-of-Play:

Emergency worker station personnel will consist of a minimum of one monitor and one recorder and sufficient personnel to demonstrate monitoring of at least one vehicle. Schematics of these 170 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station monitoring/decontamination stations will be available to show organization and space management within the facility.

The evaluator will request that decontamination procedures be explained after the vehicle which has simulated contamination has been monitored One radiological survey meter will be issued to each monitoring/decontamination team. One vehicle and/or piece of equipment will not be able to be decontaminated.

Simulated radiation contamination data will be included in the scenario package, and injected by a con/roller.

Set-up of the facility will be performed as closely as possible to that for an actual emergency with all route markings in place including clearly defined exit areas, per contamination control procedures and/or step-off pads (if used); with the exception of long runs of plastic covered with paper which will not be demonstrated, but the materials may be available and explained (as appropriate.).

Decontamination capabilities, and provisions for vehicles and equipment that cannot be decontaminated, will be simulated and conducted by interview.

NVote: Re-demons/rations may be performed as appropriate and time permitting.

Sub-element 6.c -Temporary Care of Evacuees INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires OROs to have the capability to establish relocation centers in host/support jurisdictions.

The American Red Cross normally provides congregate care in support of OROs under existing letters of agreement.

Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines.

Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654/FEMA-REP-1, J.10.h, J.12)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, an actual event, or SAy.The evaluator must conduct a walk-through of the center to determine, through observation and inquiries, that the services and accommodations are consistent with applicable guidance.For planning purposes, OROs must plan for a sufficient number of congregate care centers in host/support jurisdictions based on their all-hazard sheltering experience and what is historically relevant for that particular area. In this simulation, it is not necessary to set up operations as they would be in an actual emergency.

Alternatively, capabilities may be demonstrated by setting up stations for various services and providing those services to simulated evacuees.

Given the 171 Unclassified

• Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station substantial differences between demonstration and simulation of this criterion, exercise demonstration expectations must be clearly specified in Extent-of-Play Agreements.

Congregate care staff must also demonstrate the capability to ensure that evacuees, service animals, and vehicles have been monitored for contamination, decontaminated as appropriate, and registered before entering the facility.Individuals arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been placed in a secured area or monitored, cleared, and found to have no contamination or contamination below the trigger/action level.In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored.

These individuals do not need confirmation that their vehicle is free from contamination prior to entering the congregate care areas.However, t~hose individuals who are found to be contaminated and are then decontaminated will have their vehicles held in a secure area until they can be monitored and decontaminated (if applicable) and do need confirmation that their 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, sundries, and large-scale food supplies) need not be physically available at the facility(ies).

However, availability of such items must be verified by providing the evaluator a list of sources with locations and estimates of quantities.

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.

PEMA Negotiated Extent-of-Play:

Counties demonstrating the operation of mass care centers during the out-of-sequence window (Berks and Lehigh Counties) will provide floor plans of the mass care centers to show organization within the facility and space management during a real emergency..

Mass care center locations are listed in the demonstration tables "Demonstration of Mass Care Centers (Attachment A, Section B.3).Personnel, at a minimum, will consist of one manager and one assistant for each mass care center opened during the out-of-sequence window. The responsible American Red Cross chapter will show the source and quantities, by job functional description, to be provided to mass care centers to support the 24-hour operation.

The responsible Red Cross Chapter(s) will be visited, or telephonically contacted during business hours on November 18, 2015, by an exercise evaluator, or interviewed at the mass care center (as appropriate) during the out-of-sequence evaluation to provide information regarding the 24-hour operation.

Schematics of these mass 172 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Inmprovement Plan Limerick Generating Station care centers will be available, during the demonstration window, to show organization within the facility and space allocation for the registration and sheltering the evacuating public.Necessary signs, directional arrows and forms will be available and used to demonstrate registration, at a minimum, of three evacuees requiring emergency housing. Evacuees will be shown the location where they would be housed in an actual situation.

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

This out-of-sequence demonstration window will be from 7:00 PM- 9.'30 PM on November 18, 2015.Those facilities identified for the FEMA walk-down evaluations will be supported by a participating representative from the appropriate Red Cross Chapter(s).

An interview process will be conducted to determine facility compliance of the above stated requirements.

AMERICAN RED CROSS RISK AND SUPPORT COUNTY CHAPTERS: Tri County Chapter (Serving Berks and Chester Counties)701 Centre Avenue Reading, Pennsylvania 19601 Brittany Rivera (484) 894-8754 Greater Lehigh Valley Chapter (Serving Bucks and Lehigh Counties)3939 Broadway Allentown, Pennsylvania 18104 Nina Johnson (484) 403-4715 Southeastern Pennsylvania Chapter (Serving Montgomery County)2221 Chestnut Street Philadelphia Pennsylvania 19103 Kevin Bone (267) 246-4309 Sub-element 6.d -Transportation and Treatment of Contaminated Injured Individuals INTENT This Sub-element is derived from NUREG0654/FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.Criterion 6.d.l: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services 173 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportf/Improvement Plan Limerick Generating Station to contaminated injured individuals.(NUJREG-0654/FEMA-REP-1, F.2; 11.10; K.5.a, b; L.1, 4)Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, or drills. FEMA has determined that these capabilities have been enhanced and consistently demonstrated as adequate; therefore, offsite medical services drills need only be evaluated biennially.

FEMA will, at the request of the involved ORO, continue to evaluate the drills on an annual basis. All hospitals listed in the plan as medical services hospitals must be evaluated, with a transportation provider, every 2 years. Additional transportation providers will be rotated through the drills in the 8-year exercise cycle. For ambulance providers who do not participate in an evaluated drill during the two year cycle, training will be provided.

This training will be documented in the ALC.Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the victim.OROs must demonstrate the capability to monitor/decontaminate and transport contaminated injured individuals to medical facilities.

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility.

It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "victim(s)" to the medical facility.

This option is used in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests of the community.

Normal communications between the ambulance/dispatcher and the receiving medical facility must be demonstrated.

If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available.

In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

Monitoring of the victim may be performed before transport or en route, or may be deferred to the medical facility.

Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s).

However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored.

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

All monitoring activities must be completed as 174 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/improvement Plan Limerick Generating Station they would be in an actual emergency.

Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility.The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment.

Medical facilities are expected to have at least one trained physician and one trained nurse to perform and supervise treatment of contaminated injured individuals.

Equipment and supplies must be available for treatment of contaminated injured individuals.

The medical facility must demonstrate the capability to make decisions on the need for decontamination of the individual, follow appropriate decontamination procedures, and maintain records of all survey measurements and samples taken. All procedures for collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator.

Waste water from decontamination operations must be handled according to facility plans/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.

PEMA Negotiated Extent-of-Play:

This sub-element will be evaluated at Brandywine Hospital, Chester County, on August 1], 2015.NOTE: Responding EMS crew does not monitor nor decontaminate the inlured patient. The in]jured patient will be monitored at the hospital.

If found contaminated, the patient will be decontaminated at the hospital as well.175 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station ATTACHMENT A LIMERICK GENERATING STATION EXTENT-OF-PLAY DEMONSTRATION TABLES I. Plume Phase Exercise A. Activities -November 17, 2015 1. School Districts

-Out-of-Sequence Exercise Risk Public School Districts with schools located within the EPZ and those districts situated outside the EPZ, but with students living within the EPZ, will participate and be evaluated by FEMA. Each identified District Administration Office will be evaluated.

When a school system is comprised of multiple buildings (High School, Middle School, Elementary School), the affected buildings (those with students from the EPZ) will be evaluated on a rotational basis to coincide with the eight-year exercise cycle.Time: Out-of-sequence

-9:00 -11:00 AM Asterisks

(*) items indicate buildings not in EPZ -students may live in the EPZ"Bold" indicated those facilities that are scheduled for Federal evaluation.

COUNTY ISCHOOL DISTRICTTSCOL 1 I (approx. 1/4 th evaluated)

Berks Boyertown Area 1. Boyertown Elementary

____________________2.

Boyertown ilHS West Daniel Boone Area 1. Daniel Boone HS 2.Mncc*lmnayCne Chester Downingtown Area 1. Shamona Creek Elementary*

Great Valley 1. KD Markley Elementary

• Owen J. Roberts 1. Owen J Roberts HS Phoenixville Area 1. Phoenixville Senior HS 2. Kindergarten Center Montgomery TMethacton Area ]1. Arcola Intermediate

_______________I J2. Skyview Elementary 176 Unclassified Radiological Emergency Preparedness Program (REP)After Action Reportflmprovement Plan Limerick Generating Station Perkiomen Valley 1. Perkiomen Valley HS 2. Schwenksville Elementary Pottsgrove

1. Lower Pottsgrove Elementary Pottstown Area 1. Franklin Elementary

2. Pottstown MS Souderton Area 1. Indian Valley MS *Montgomery (cont'd) Spring-Ford Area 1. Evans Elementary

2. Limerick Elementary

3. Royersford Elementary

4. 9 th Grade Center Upper Perkiomen Only the school district will be evaluated.

2. County Emergency Operations Center (EOCs)Time: Per Exercise Scenario DEMONSTRATION FOR EOC MOBILIZATION FOR COUNTIES ______________

___ _____COUNTY DATE [Time Berks November 17, 2015 Exercise Scenario Bucks November 17, 2015 Exercise Scenario Chester November 17, 2015 Exercise Scenario Montgomery November 17, 2015 Exercise Scenario Lehigh November 17, 2015 Exercise Scenario 3. BRP field teams will be evaluated at the R3V staging area located at Wilson Farm Park, 500 Lee Road, Chesterbrook, Pennsylvania on November 17, 2015 at 1:30 p.m.4. Municipal Emergency Operations Center (EOCs)Time: Per Exercise Scenario Asterisks

(*) items indicate joint EOCs."Bold" indicates those facilities that are scheduled for Federal evaluation.

Non-bold indicates those facilities being observed by PEMA.177 Unclassified Radiological Emergency Preparedness Program (REP)Aftcr Action Report/Improvcment Plan Limerick Generating Station DEMONSTRATION FOR EOC MOBILIZATION FOR MUNICIPALITIES RISKI COUNTY MUNICIPALITY I DATE Berks (6) Amity Twp November 17, 2015* Boyertown Borough/Colebrookdale Twp November 17, 2015 Douglass Twp November 17, 2015 Earl Twp November 17, 2015 Union Twp November 17, 2015 Washington Twp -RA November 17, 2015 Chester (15) Charlestown Twp November 17, 2015 East Coventry Twp November 17, 2015 East Nantmeal Twp November 17, 2015 East Pikeland Twp November 17, 2015 East Vincent Twp November 17, 2015 North Coventry Twp November 17, 2015 Chester (cont'd) Phoenixville Borough November 17, 2015 Schuylkill Twp November 17, 2015 South Coventry Twp -RA November 17, 2015 Spring City Borough November 17, 2015 Upper Uwchlan Twp November 17, 2015__________Uwchlan Twp November 17, 2015___________Warwick Twp November 17, 2015 West Pikeland Twp November 17, 2015 West Vincent Tw November 17, 2015 Montgomery (20) Collegeville Borough November 17, 2015_________Douglass Twp November 17, 2015*Greenlane Borough/Marborough Twp November 17, 2015 Limerick Twp November 17, 2015 Lower Frederick Twp November 17, 2015 Lower Pottsgrove Twp November 17, 2015 Lower Providence Twp November 17, 2015 Lower Salford Twp -RA November 17, 2015 New Hanover Twp November 17, 2015 Perkiomen Twp November 17, 2015___________Pottstown Borough November 17, 2015__________Royersford Borough November 17, 2015___________Schwenksville Borough November 17, 2015___________Skippack Twp November 17, 2015___________Trappe Borough November 17, 2015 178 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station___________Upper Frederick Twp November 17, 2015__________Upper Pottsgrove Twp November 17, 2015__________Upper Providence Twp November 17, 2015___________Upper Salford Twp November 17, 2015___________West Pottsgrove Twp November 17, 2015 5. One back-up one route alerting demonstration by one municipality in each risk county. (During Scenario Exercise)BACK-UP ROUTE ALERTING COUNTY ]MUNICIPALITY

/ ROUTE I SIREN DATE Berks Washington Twp -22A / #1 (2 teams) November 17, 2015 Chester South Coventry Twp -62C / #154 (2 teams) INovember 17, 2015 Montgomery Lower Salford Tw -61A / #43 (2 teams) November 17, 2015 6. Traffic and Access Control Points a. The Pennsylvania State Police will brief at the PSP Skippack Barracks, 2047C Bridge Road, Schwenksville, Montgomery County. Members attending the briefing will NOT actually deploy to the TCP/ACPs.b. The PSP briefing will be performed out-of-sequence in a demonstration window of 10:00 a.m. -12:00 a.m. on November 18, 2015.c. Each municipal/regional police force with a TCP assigned in its plan will demonstrate all preparation duties including TCP responsibilities and radiological briefing.

Dispatch of persons to the TCP site will not occur during the exercise.d. Municipal and county staffs will be prepared to brief the FEMA evaluator on actions to be taken should there be an impediment to evacuation on a designated route. This will be demonstrated between 4:00 p.m. -10:00 p.m. on November 17, 2015.These municipal/regional police forces are (by county) being federally evaluated through an interview process at their respective municipality:

179 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Berks IChester 1Montgomery Douglass Township East Vincent Township Upper Pottsgrove Township______________West Pikeland Township Lower Providence Township__________________

_______________________Lower Salford Township_________________________________________Pottstown Borough B. Activities

-November 18, 2015 1. Reception Centers Time: Out-of-sequence

-7:00 p.m. -9:30 p.m.The asterisks

(*) indicate monitoring/decontamination center activities at the respective reception centers.RECEPTION CENTERS LOCATIONS COUNTY LOCATION ]Quantity Berks Morgantown Crossings 1*Bucks County Line Plaza 1__________________(alt.

Souderton Fire Company)*Chester Dowington West High School1 (alt. Chester County Government Services_________________Building; EOC location)*Lehigh Emmaus High School1 2. Emergency worker monitoring/decontamination stations for each risk county.EMERGENCY WORKER MOMITORING/DECONTAMINATION STATION COUNTY ]LOCATION IDATE Chester Lionville Middle School November 18, 2015 (alt. Chester County Government Services Building;EOC location)Montgomery Upper Perkiomen High School November 18, 2015_____________(alt.

Pennsburg Fire Department)__________

3. Evacuee monitoring/decontamination station for each risk and support counties.EVACUEE MONITORING/DECONTAMINATION STATION_______

COUNTY JLOCATION

]DATE Berks Fleetwood High School ]November 18, 2015________Wyomissing High School JNovember 18, 2015 180 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station Bucks County Line Plaza November 18, 2015_____________(alt.

Souderton Fire Company) __________

Chester Dowington West High School November 18, 2015_____________(alt.

Chester County Government Services Building)

__________

Lehigh Emmaus High School November 18, 2015 II. Mass Care Center Walkdowns Berks and Lehigh Counties (*) conduct monitoring/decontamination center activities at their mass care centers.DEMONSTRATION OF MASS CARE CENTERS / HOST SCHOOL COUNTY [DATE TIME*Berks (22/6)Bucks (61/15) Thirty five walkdowns are scheduled for October 29-30, 2015 Chester (12/6) See schedule below Lehigh (15/5)Monitgomery_(13/3)

________________________________

MASS CARE CENTER LOCATIONS COUNTY [LOCATION

[Quantity*Berks 1. Conrad Weiser High School 6 2. Conrad Weiser Middle School 3. Twin Valley High School Blue Team 4. Twin Valley Middle School October 29, 2015 5. Wilson Middle School South 9:00 A.M. 6. Muhlenberg Middle School Bucks 1. Franklin Roosevelt School 15 2. Holland Middle School 3. Morrisville Middle / Senior High School 4. Poquessing Middle School 5. Richboro Middle School 6. Milford Township Fire Company Red Team 7. Milford Middle School October 29, 2015 8. Quakertown Community High School 9:00 A.M. 9. Council Rock South High School 10. Council Rock Newtown Middle School 11. Lenape Middle School___________________12.

Eleanor Roosevelt Elementary_________

181 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station MASS CARE CENTER LOCATIONS COUNTY [LOCATION JQuantity Bucks continued

13. Makefield Elementary

14. Edgewood Elementary

15. Springfield Elementary Chester 1. Avon Grove High School 6 2. Fred Engle Middle School 3. Charles Patton Middle School Blue Team 4. Unionville High School October 30, 2015 5. Kennett High School 9:00 A.M. 6. Mary Lang Elementary

• Lehigh 1. Eyer Junior High School5 2. Orefield Middle School Red Team 3. South Mountain Middle School October 30,2015 4. Springhouse Junior High School 9:00 A.M. 5. DeSales University Montgomery

1. Abington Junior High School3 2. Abington Senior High School Blue Team 3. Cheltenham High School October 29, 2015 1:00 P.M.182 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement Plan Limerick Generating Station ATTACHMENT B LIMERICK GENERATING STATION PREVIOUS ISSUES WE DID NOT HAVE ANY ISSUES FROM THE LGS HAB EXERCISE HELD ON NOVEMBER 18, 2013.183