ML093340025

Final Radiological Emergency Preparedness Program Exercise Report

ML093340025
Person / Time
Site:	Monticello
Issue date:	11/16/2009
From:	US Dept of Homeland Security, Federal Emergency Management Agency
To:	Office of Nuclear Reactor Regulation
References
Download: ML093340025 (104)

Text

Monticello Nuclear Generating Plant Exercise Report - 2009-08-18 Final Report - Radiological Emergency Preparedness (REP) Program 2009-11-03

Exercise Report Monticello Nuclear Generating Plant Exercise Date: 2009-08-18 Report Date: 2009-11-16 U.S. DEPARTMENT OF HOMELAND SECURITY Federal Emergency Management Agency REP Program 536 S. Clark St. 6th floor Chicago, IL 60605 Table of Contents Chapter 1 Executive Summary Chapter 2 Introduction Chapter 3 Exercise Overview Section 3.1 EPZ Description Section 3.2 Exercise Participants Section 3.3 Exercise Timeline Chapter 4 Exercise Evaluation and Results Section 4.1 Summary Results of Exercise Evaluation Section 4.2 Status of Jurisdictions Evaluated

4.2.1 Minnesota

Jurisdictions 4.2.1.1 Minnesota State Initial Warning Point (Bureau of Criminal Apprehension) 4.2.1.2 Minnesota State Emergency Operations Center 4.2.1.3 Minnesota State Emergency Operations Center (Ingestion Phase) 4.2.1.4 Intermediate Phase Task Force (IPTF) - Minnesota State EOC 4.2.1.5 Minnesota State Planning and Assessment Center 4.2.1.6 Minnesota State PIO at Joint Information Center 4.2.1.7 Public Inquiry Hotline (MN State Emergency Operations Center) 4.2.1.8 State Regional Program Coordinator - Sherburne County 4.2.1.9 State Regional Program Coordinator - Wright County 4.2.1.10 State Patrol Helicopter - Sherburne County Recreationalists 4.2.1.11 State RAD Field Team #1 (Monticello) 4.2.1.12 State RAD Field Team #2 (Monticello) 4.2.1.13 State RAD Team Command Van (Monticello) 4.2.1.14 State RAD Field Team #1 (Ingestion Phase) (Monticello) 4.2.1.15 State RAD Field Team #2 (Ingestion Phase) (Monticello) 4.2.1.16 State RAD Team Command Van (Ingestion Phase) (Monticello) 4.2.1.17 Minnesota Department of Agriculture Field Team 4.2.1.18 Minnesota Department of Natural Resources Field Team 4.2.1.19 Minnesota Department of Health State Public Health Laboratory 4.2.1.20 State Traffic and Access Control Point - Sherburne County 4.2.1.21 Evacuee Decontamination Rogers Reception Center 4.2.1.22 Evacuee Monitoring Rogers Reception Center 4.2.1.23 Evacuee Registration Rogers Reception Center 4.2.1.24 Evacuee Vehicle Decontamination Rogers Reception Center 4.2.1.25 Evacuee Vehicle Monitoring Rogers Reception Center 4.2.1.26 Medical Services (MS-1) Transportation North Memorial Medical Center 4.2.1.27 Medical Services (MS-1) Facility North Memorial Medical Center 4.2.2 Risk Jurisdictions 4.2.2.1 Sherburne County Initial Warning Point 4.2.2.2 Sherburne County Emergency Operations Center 4.2.2.3 Sherburne County Traffic and Access Control Point 4.2.2.4 Sherburne County Public Information Officer at the State JIC 4.2.2.5 EV-2 Big Lake School District 4.2.2.6 Emergency Worker Monitoring and Decontamination 4.2.2.7 Emergency Worker Vehicle Monitoring and Decontamination 4.2.2.8 Sherburne County Emergency Operations Center (Ingestion Phase) 4.2.2.9 Sherburne County Public Information Officer at the State JIC (Ingestion Phase) 4.2.2.10 Wright County Initial Warning Point 4.2.2.11 Wright County Emergency Operations Center 4.2.2.12 Wright County Traffic and Access Control Point 4.2.2.13 Wright County Public Information Officer at the State JIC 4.2.2.14 Wright County Emergency Operations Center (Ingestion Phase) 4.2.2.15 Wright County Public Information Officer at the State JIC (Ingestion Phase)4.2.2.16 EV-2 St. Michael - Albertville School District 4.2.2.17 EV-2 Buffalo School District Appendices Appendix 1 - Acronyms and Abbreviations Appendix 2 - Exercise Evaluators and Team Leaders Appendix 3 - Exercise Evaluation Areas and Extent of Play Agreement Appendix 4 - Exercise Scenario and Timeline

1. Executive Summary On August 18 and 19, 2009, a Radiological Emergency Preparedness (REP) Full Participation Plume and Ingestion Exposure Pathway Exercise was conducted for the 10-mile Emergency Planning Zone (EPZ) and 50-mile Ingestion Pathway Zone (IPZ) around the Monticello Nuclear Generating Plant (MNGP) by the U. S. Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA). The purpose of this exercise was to assess the level of State and local preparedness in responding to a radiological emergency. This exercise was held in accordance with DHS/FEMA policies and guidance concerning the exercise of State and local radiological emergency response plans (RERPs) and procedures.

The most recent Radiological Emergency Preparedness (REP) Full Participation Plume Exposure Pathway Exercise at this site was conducted on November 6, 2007. The most recent REP Full Participation Plume and Ingestion Exposure Pathway Exercise at this site was conducted on November 18 and 19, 2003. The qualifying emergency preparedness exercise was conducted on January 7, 1981.

DHS/FEMA wishes to acknowledge the efforts of the many individuals in the State of Minnesota and the Counties of Sherburne and Wright who participated in this exercise.

Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities. Cooperation and teamwork on the part of all participants was evident during this exercise.

This Final Report contains the evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities:

Registration, and Vehicle Monitoring and Decontamination were demonstrated at Rogers High School; Medical Services (MS-1) demonstration involving transporting and caring for a potentially contaminated and injured individual at North Memorial Hospital;

1 Monitoring and Decontamination Center; District (Big Lake High School);

School District (District Office);

School District (District Office).The State and local organizations except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them.

No Deficiencies were identified for any jurisdiction during this exercise.

There were four Areas Requiring Corrective Action (ARCAs) identified for the State of Minnesota, one of which was resolved after additional training was conducted, as documented in the Schedule of Corrective Actions letter from the State dated October 21, 2009, and one which was successfully re-demonstrated on October 19, 2009. There were two ARCAs identified for Wright County, one of which was successfully re-demonstrated during the exercise. No ARCAs were identified for Sherburne County.

There were no previous ARCAs for the State of Minnesota, Wright and Sherburne Counties that were resolved.

The first ARCA for the State of Minnesota was identified under Criterion 1.e.1 -

Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations, whereby the thermoluminescent dosimeters utilized at the North Memorial Medical Center did not have an exchange date and there were no instructions on when the dosimeters needed to be exchanged. This ARCA remains unresolved.

The second ARCA for the State of Minnesota was identified under Criterion 4.a.3 -

Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams must 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, whereby the teams exhibited a lack of contamination control by failing to wear proper 2

protective equipment ( gloves). This ARCA was resolved after additional training was conducted, as documented in the Schedule of Corrective Actions letter from the State dated October 21, 2009.

The third ARCA for the State of Minnesota was identified under Criterion 4.c.1 -

Laboratory is capable of performing required radiological analyses to support PADs, whereby results of laboratory isotopic analysis of samples counted in Marinelli beakers were not reliable, and there was no assurance in the quality and quantity of the isotopic concentrations. This ARCA was successfully re-demonstrated on October 19, 2009, which was completed within the 60 day timeframe requested by FEMA.

The fourth ARCA for the State of Minnesota was identified under Criterion 6.d.1 - The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals, whereby The Model 3 survey meters were checked for operability using a Cs-137 check source attached to the case. The instruments were not operability checked using a specified range of readings for a particular source. This ARCA remains unresolved.

The first ARCA for Wright County was identified under Criterion 1.c.1 - Key personnel with functional roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible, whereby the Operations Chief (Nuclear Director) and other key EOC staff were not informed by staff that a decision to evacuate the County Jail population had been made. This ARCA remains unresolved.

The second ARCA for Wright County was identified under Criterion 1.e.1 - Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations, whereby during the operations check, DRDs were zeroed at the top of the scale, 200 mR rather than 0 mR. This ARCA was successfully re-demonstrated during the exercise.

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2. Introduction On December 7, 1979, the President directed FEMA to assume the lead responsibility for all off-site nuclear planning and response. FEMA's activities are 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.

FEMA Rule 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 governments' participation in joint exercises with licensees.

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

RERPs and procedures developed by State and local governments;

the evaluation of the plans and procedures conducted by State and local governments;

to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, September 14, 1993); and

emergency planning process:

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Representatives of these agencies serve on the FEMA Region V Regional Assistance Committee (RAC), which is chaired by FEMA.

Formal submission of the RERPs for the MNGP to FEMA Region V by the State of Minnesota and involved local jurisdictions occurred on February 1, 1983. Formal approval of these RERPs was granted by FEMA on May 10, 1985, under 44 CFR 350.

A Radiological Emergency Preparedness (REP) Full Participation Plume and Ingestion Exposure Pathway Exercise was conducted on August 18 and 19, 2009, by DHS/FEMA Region V to assess the capabilities of State and local off-site emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the MNGP. The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (ORO's) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluation team, with final determinations made by the DHS/FEMA Region V RAC Chairperson and approved by DHS/FEMA Headquarters.

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

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980;

1991; and published in the Federal Register Notice/Vol. 67, No. 80, dated April 25, 2002.

Section III of this report, entitled "Exercise Overview," presents basic information and data relevant to the exercise. This section of the report contains a description of the plume pathway EPZ and an ingestion pathway IPZ, a listing of all participating jurisdictions and functional entities which were evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities.

5 Section IV of this report, entitled "Exercise Evaluation and Results," presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues only format. This section also contains: (1) descriptions of all Deficiencies and ARCAs assessed during this exercise, recommended corrective actions for each identified exercise issue; and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the ORO's efforts to resolve them.

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3. Exercise Overview Contained in this section are data and basic information relevant to the August 18 and 19, 2009, Radiological Emergency Preparedness (REP) Full Participation Plume and Ingestion Exposure Pathway Exercise to test the off-site emergency response capabilities in the area surrounding the Monticello Nuclear Generating Plant. This section of the exercise report includes a description of the 10-mile Emergency Planning Zone (EPZ) and a description of the 50-mile Ingestion Pathway Zone (IPZ), a listing of all participating jurisdictions and functional entities which were evaluated, and a tabular presentation of the time of the actual occurrence of key exercise events and activities.

3.1. EPZ Description The MNGP is located within the city limits of Monticello, Minnesota. The plant consists of approximately 1500 acres of land. The northwest and southwest sectors are mainly agricultural. The northeast and southeast sectors are urban and manufacturing. Part of this property is on the north bank of the Mississippi River in Sherburne County and part is on the south bank of Wright County. The northwestern suburbs of Minneapolis are about 30 miles southeast of the MNGP.

The 10-mile EPZ for the MNGP consists of a circle with the utility at the center point.

The EPZ extends 10-miles outward in all directions from the plant for the plume exposure pathway planning zone and 50 miles outward for the IPZ. In the event of a serious accident, the plume exposure-planning zone will be in the area in which intensive efforts will be made to notify and protect residents and transient populations from exposure to radiation. The population in the MNGP 10-mile EPZ is 64,184. This figure represents the permanent population in the municipalities and unincorporated areas located in the 10-mile EPZ.

There are numerous lakes in the 10-mile EPZ, which are used for recreational purposes. Parts of Lake Saint Marie Park, Sandune State Park, and Game Refuge are within the 10-mile EPZ. The Mississippi River flows from the northwest to southeast through the 10-mile EPZ. The three major highways passing through the area are Interstate 94, U.S. 10, and State Highways 25 and 55. Railroad access is available from the Burlington Northern. Major waterways are the Mississippi Scenic River and Crow River and the Elk River and Saint Francis River watersheds; however these waterways are not navigable. There are no major airports in the 10-mile EPZ.

7 The following Sub-Areas are included within the 10-mile EPZ: Sub-Areas 2, 5N, 5E, 5S, 5W, 10N, 10E, 10SE, 10S, 10SW, 10W and 10NW.

The 50-mile IPZ for the MNGP has an estimated population of approximately 3,591,108 as of the year 2008. Approximately 90% reside in the Minneapolis-St. Paul metropolitan area. There are 22 counties in the 50-mile EPZ. They are: Anoka, Benton, Carver, Chisago, Dakota, Hennepin, Isanti, Kanabec, Kandiyohi, McLeod, Meeker, Mille Lacs, Morrison, Pine, Ramsey, Renville, Scott, Sherburne, Sibley, Stearns, Washington, and Wright. 3.2. Exercise Participants Agencies and organizations of the following jurisdictions participated in the Monticello Nuclear Generating Plant exercise:

State Jurisdictions State of Minnesota Governor's Office Department of Public Safety, Division of Homeland Security and Emergency Management Minnesota Department of Health Minnesota Department of Agriculture Emergency Medical Services Regulatory Board Minnesota Department of Natural Resources Minnesota Department of Education Minnesota Department of Human Services Minnesota Voluntary Organizations Active in Disasters Minnesota Department of Transportation Minnesota State Patrol Minnesota Department of Military Affairs University of Minnesota Bureau of Criminal Apprehension Office of Technical Support Services Minnesota Geospatial Information Office Department of Public Safety, Office of Communication School Safety Center (State of Minnesota)

Minnesota Department of Health, Public Health Laboratory State of Minnesota National Guard 8

55th Civil Support Team Risk Jurisdictions City of Monticello Civil Defense Director Sherburne County Emergency Management Agency Sherburne County Public Health Sherburne County Public Works Sherburne County Sheriff's Dispatch Center Sherburne County Sheriff's Office Sherburne County Social Services Wright County Board of Commissioners Wright County Civil Defense Director/Wright County Nuclear Director Wright County Emergency Management Agency Wright County Engineer Wright County Highway Department Wright County Human Services Wright County Public Information Officer Wright County Law Enforcement Explorers Wright County Radiological Officer Wright County Sheriff"s Office Wright County Sheriff's Dispatch Center Buffalo School District Rockford School District St. Michael Albertville - Albertville School District Big Lake School District Zimmerman Fire Department Livonia Fire Department Plymouth Fire Department Maple Grove Fire Department Hennepin County Emergency Management Ramsey County Emergency Management Rogers High School Reception Center Brooklyn Park Fire Department Support Jurisdictions State of Wisconsin Dakota County Emergency Management Goodhue County Emergency Management Steele County Emergency Management 9

Private Jurisdictions Amateur Radio Emergency Services American Red Cross Vision Big Lake Transportation Xcel Energy Heritage Montessori School Salvation Army Metro Transit Don's Bus Company American Student Transportation Robbinsdale Amatuer Radio Club North Memorial Medical Center West Metro North Memorial Ambulance Federal Jurisdictions Federal Emergency Management Agency Nuclear Regulatory Agency Environmental Protection Agency U.S. Department of Transportation Food and Drug Administration Center for Disease Control Department of Homeland Security United States Department of Agriculture Federal Radiological Monitoring and Assessment Center Department of Defense Civil Air Patrol

3.3. Exercise

Timeline Table 1, on the following page, presents the time at which key events and activities occurred during the Monticello Nuclear Generating Plant Radiological Emergency Preparedness (REP) Full Participation Plume and Ingestion Exposure Pathway Exercise held on August 18 and 19, 2009. Also included are times that notifications were made to the participating jurisdictions/functional entities.

10 Table 1 - Exercise Timeline DATE: 2009-08-18, SITE: Monticello Nuclear Generating Plant, MN Emergency Classification Level or Event Time Utility Declared MN State Initial Warning Point MN State EOC PAC (MN State EOC)

JIC (MN State EOC)

Sherburne County Initial Warning Point Sherburne County EOC Unusual Event NA NA NA NA NA NA NA Alert 0828 0838 0849 0851 0852 0839 0842 Site Area Emergency 0945 1008 1007 1008 1006 General Emergency 1049 1112 1112 1118 1111 Simulated Rad. Release Started 1045 1112 1056 NA 1111 Simulated Rad. Release Terminated 1915 1915 1915 NA 1915 Facility Declared Operational 0932 0932 0932 0900 Declaration of State of Emergency 1030 1030 NA 1025 Exercise Terminated NA NA NA NA 1st Precautionary Action: Place animals on stored feed and protected water out to 10-miles 1027 NA NA NA 2nd Precautionary Action: air, rail and water restriction-10-mile EPZ 1036 NA NA NA 3rd Early Precautionary Action: Park Evacuation 1028 NA NA NA Precautionary Action: Wright/Sherburne CO-Relocation/Evacuation Schools NA NA NA 1014 1st PAR: Evacuate Sub - Areas 2, 5E and 5S, 2 mile 360 and 5 mile downwind, general population directed to ingest KI NA 1112 NA NA 1st PAD: Evacuate Sub - Areas 2, 5E and 5S, 2 mile 360 and 5 mile downwind, general population directed to ingest KI 1119 NA 1119 1119 1st Siren Activation NA NA NA 1129 1st EAS Message 1132 NA NA NA 2nd PAR: Evacuate Sub - Areas 2, 5S, 5E, 10E and 10S, 2 mile 360, 10 mile downwind, general population directed to ingest KI NA 1221 NA NA 2nd PAD: Evacuate Sub - Areas 2, 5E, 5S, 10E and 10S, 2 mile 360, 10 mile downwind, general population directed to ingest KI 1228 NA 1228 1228 2nd Siren Activation NA NA NA 1238 2nd EAS Message 1241 NA NA NA KI Administration Decision(s): Emergency Workers 1102 1054 NA NA 11 Table 1 - Exercise Timeline DATE: 2009-08-18, SITE: Monticello Nuclear Generating Plant, MN Emergency Classification Level or Event Time Utility Declared Wright County Initial Warning Point Wright County EOC Unusual Event NA NA NA Alert 0828 0838 0846 Site Area Emergency 0945 NA 1003 General Emergency 1049 NA 1108 Simulated Rad. Release Started 1045 1108 Simulated Rad. Release Terminated 1915 1915 Facility Declared Operational 0917 Declaration of State of Emergency 1012 Exercise Terminated NA 1st Precautionary Action: Place animals on stored feed and protected water out to 10-miles NA 2nd Precautionary Action: air, rail and water restriction-10-mile EPZ NA 3rd Early Precautionary Action: Park Evacuation NA Precautionary Action: Wright/Sherburne CO-Relocation/Evacuation Schools 1015 1st PAR: Evacuate Sub - Areas 2, 5E and 5S, 2 mile 360 and 5 mile downwind, general population directed to ingest KI NA 1st PAD: Evacuate Sub - Areas 2, 5E and 5S, 2 mile 360 and 5 mile downwind, general population directed to ingest KI 1119 1st Siren Activation 1129 1st EAS Message NA 2nd PAR: Evacuate Sub - Areas 2, 5S, 5E, 10E and 10S, 2 mile 360, 10 mile downwind, general population directed to ingest KI NA 2nd PAD: Evacuate Sub - Areas 2, 5E, 5S, 10E and 10S, 2 mile 360, 10 mile downwind, general population directed to ingest KI 1228 2nd Siren Activation 1238 2nd EAS Message NA KI Administration Decision(s): Emergency Workers NA 12

4. Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities, which participated in the August 18 and 19, 2009, Radiological Emergency Preparedness (REP) Full Participation Plume and Ingestion Exposure Pathway Exercise to test the off-site emergency response capabilities of State and local governments in the 10-mile EPZ and 50-mile IPZ surrounding the MNGP.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria delineated in exercise criteria contained in Federal Register notice/Vol. 67, No.

80, dated April 25, 2002. Detailed information on the exercise criteria and the extent of play agreement used in this exercise are found in Appendix 3 of this report.

4.1. Summary

Results of Exercise Evaluation The matrix presented in Table 2, on the following page(s), presents the status of all exercise criteria from Federal Register notice/Vol. 67, No. 80, dated April 25, 2002, which were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise criteria are listed by number and the demonstration status of those criteria are indicated by the use of the following letters:

M - Met (No Deficiency or ARCAs assessed and no unresolved ARCAs from prior exercises)

D - Deficiency assessed A - ARCA(s) assessed or unresolved ARCA(s) from prior exercise(s)

N - Not Demonstrated (Reason explained in Subsection B) 13 Table 2 - Summary of Exercise Evaluation (4 pages)

DATE: 2009-08-18 SITE: Monticello Nuclear Generating Plant, MN A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated MN State Initial Warning Point MN State EOC MN State EOC Ingestion Phase IPTF-MN State EOC PAC (MN State EOC)

JIC (MN State EOC)

Public Inquiry Hotline (JIC)

State RPC (Sherburne County EOC)

State RPC (Wright County EOC)

State Helicopter - Sherburne County State RAD Team #1 Emergency Operations Management Mobilization 1a1 M MM MM MM Facilities 1b1 Direction and Control 1c1M MM MCommunications Equipment 1d1 M MM M MM M Equip & Supplies to support operations 1e1MM MM M Protective Action Decision Making Emergency Worker Exposure Control 2a1MMM MRadiological Assessment and PARs 2b1MMDecisions for the Plume Phase -PADs 2b2MMM MPADs for protection of special populations 2c1MM MRad Assessment and Decision making for the Ingestion Exposure Pathway 2d1M M MRad Assess/Decision making concerning Relocation, Reentry, and Return 2e1M M MProtective Action Implementation Implementation of emergency worker exposure control 3a1M M Implementation of KI decision 3b1M M Implementation of protective actions for special populations - EOCs 3c1Implementation of protective actions for Schools 3c2MImplementation of traffic and access control 3d1MImpediments to evacuation are identified and resolved 3d2MImplementation of ingestion pathway decisions - availability/use of info 3e1M M MMaterials for Ingestion Pathway PADs are available 3e2M M MImplementation of relocation, re-entry, and return decisions 3f1M M MField Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4a1M Field Teams obtain sufficient information 4a2MField Teams Manage Sample Collection Appropriately 4a3M Post plume phase field measurements and sampling 4b1MLaboratory operations 4c1MEmergency Notification and Public Info Activation of the prompt alert and notification system 5a1MM M MActivation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5b1M MM M M M MSupport Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6a1Mon / decon of emergency worker equipment 6b1Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d114

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15 Table 2 - Summary of Exercise Evaluation (Continued. page 2/4)

DATE: 2009-08-18 SITE: Monticello Nuclear Generating Plant, MN A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated State RAD Team #2 State RAD Command Van State RAD Team #1 Ingestion Phase State RAD Team #2 Ingestion Phase State RAD Command Van Ingestion Phase MDA Field Team DNR Field Team MDH Public Health Lab State TACP (Sherburne County)

Sherburne County Initial Warning Point Sherburne County EOC Emergency Operations Management Mobilization 1a1 MM M MM M Facilities 1b1 Direction and Control 1c1M Communications Equipment 1d1 M MM M M M M M Equip & Supplies to support operations 1e1 M M M M M M M M MProtective Action Decision Making Emergency Worker Exposure Control 2a1M Radiological Assessment and PARs 2b1MDecisions for the Plume Phase -PADs 2b2M PADs for protection of special populations 2c1M Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1Rad Assess/Decision making concerning Relocation, Reentry, and Return 2e1Protective Action Implementation Implementation of emergency worker exposure control 3a1 M M M M M M M M MM Implementation of KI decision 3b1 M MMM Implementation of protective actions for special populations - EOCs 3c1M Implementation of protective actions for Schools 3c2M Implementation of traffic and access control 3d1MM Impediments to evacuation are identified and resolved 3d2M Implementation of ingestion pathway decisions - availability/use of info 3e1Materials for Ingestion Pathway PADs are available 3e2Implementation of relocation, re-entry, and return decisions 3f1Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4a1 MField Teams obtain sufficient information 4a2MField Teams Manage Sample Collection Appropriately 4a3 MPost plume phase field measurements and sampling 4b1M M M M MLaboratory operations 4c1MEmergency Notification and Public Info Activation of the prompt alert and notification system 5a1M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5b1M Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6a1Mon / decon of emergency worker equipment 6b1Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d116

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17 Table 2 - Summary of Exercise Evaluation (Continued. page 3/4)

DATE: 2009-08-18 SITE: Monticello Nuclear Generating Plant, MN A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated Sherburne County TACP Sherburne County PIO EV-2 Big Lake EM Worker Monit & Decon ZFD EM Worker Veh Monit & Decon ZFD Sherburne County EOC Ingestion Phase Sherburne County PIO Ingestion Phase Wright County Initial Warning Point Wright County EOC Wright County TACP Wright County PIO Emergency Operations Management Mobilization 1a1M MFacilities 1b1 Direction and Control 1c1ACommunications Equipment 1d1 MM M MM M MEquip & Supplies to support operations 1e1 MM M MM MProtective Action Decision Making Emergency Worker Exposure Control 2a1MRadiological Assessment and PARs 2b1Decisions for the Plume Phase -PADs 2b2MPADs for protection of special populations 2c1MRad Assessment and Decision making for the Ingestion Exposure Pathway 2d1MRad Assess/Decision making concerning Relocation, Reentry, and Return 2e1MProtective Action Implementation Implementation of emergency worker exposure control 3a1 MM MM M MImplementation of KI decision 3b1 MM M MImplementation of protective actions for special populations - EOCs 3c1MImplementation of protective actions for Schools 3c2MMImplementation of traffic and access control 3d1 MM MImpediments to evacuation are identified and resolved 3d2MImplementation of ingestion pathway decisions - availability/use of info 3e1MMaterials for Ingestion Pathway PADs are available 3e2MImplementation of relocation, re-entry, and return decisions 3f1MField Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4a1Field Teams obtain sufficient information 4a2Field Teams Manage Sample Collection Appropriately 4a3Post plume phase field measurements and sampling 4b1Laboratory operations 4c1Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1MActivation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5b1MM MMM Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6a1MMon / decon of emergency worker equipment 6b1MTemporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d118

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19 Table 2 - Summary of Exercise Evaluation (Continued. page 4/4)

DATE: 2009-08-18 SITE: Monticello Nuclear Generating Plant, MN A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated Wright County EOC Ingestion Phase Wright County PIO Ingestion Phase EV-2 St. Michael - Albertville School EV-2 Buffalo School District Evacuee Decon Rogers HS Evacuee Monit Rogers HS Evacuee Regis Rogers HS Evacuee Veh Decon Vision Trans Evacuee Veh Monit Rogers HS MS-1 Transportation NMMC MS-1 Facility NMMC Emergency Operations Management Mobilization 1a1Facilities 1b1 Direction and Control 1c1Communications Equipment 1d1M M MM M M M Equip & Supplies to support operations 1e1M M M M M M M M A Protective Action Decision Making Emergency Worker Exposure Control 2a1Radiological Assessment and PARs 2b1Decisions for the Plume Phase -PADs 2b2PADs for protection of special populations 2c1Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 MRad Assess/Decision making concerning Relocation, Reentry, and Return 2e1 MProtective Action Implementation Implementation of emergency worker exposure control 3a1M M M M M N M Implementation of KI decision 3b1MImplementation of protective actions for special populations - EOCs 3c1Implementation of protective actions for Schools 3c2M MImplementation of traffic and access control 3d1Impediments to evacuation are identified and resolved 3d2Implementation of ingestion pathway decisions - availability/use of info 3e1 MMaterials for Ingestion Pathway PADs are available 3e2 MImplementation of relocation, re-entry, and return decisions 3f1 MField Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4a1Field Teams obtain sufficient information 4a2Field Teams Manage Sample Collection Appropriately 4a3Post plume phase field measurements and sampling 4b1Laboratory operations 4c1Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5b1 M MSupport Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6a1M M M M MMon / decon of emergency worker equipment 6b1Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d1M A 20

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4.2. Status

of Jurisdictions Evaluated This subsection provides information on the evaluation of each participating jurisdiction and functional entity, in a jurisdiction based, issues only format. Presented below is a definition of the terms used in this subsection relative to objective demonstration status.

• Met - Listing of the demonstrated exercise objectives under which no Deficiencies or ARCAs were assessed during this exercise and under which no ARCAs assessed during prior exercises remain unresolved.

• Deficiency - Listing of the demonstrated exercise objectives under which one or more Deficiencies were assessed during this exercise. Included is a description of each Deficiency and recommended corrective actions.

• Area Requiring Corrective Action - Listing of the demonstrated exercise criterion under which one or more ARCAs was assessed during the current exercise or ARCAs assessed during prior exercises remain unresolved. Included is a description of the ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise.

• Not Demonstrated - Listing of the exercise objectives which were not demonstrated as scheduled during this exercise and the reason they were not demonstrated.

• Prior ARCAs - Resolved - Description of ARCAs assessed during previous exercises which were resolved in this exercise and the corrective actions demonstrated.

• Prior ARCAs - Unresolved - Description of ARCAs assessed during prior exercises, which were not resolved in this exercise. Included is the reason the ARCAs remain unresolved and recommended corrective actions to be demonstrated before or during the next biennial exercise.

The following are definitions of the two types of exercise issues, which are discussed in this report.

• A Deficiency is defined in FEMA-REP-14 as "...an observed or identified inadequacy of organizational performance in an exercise that could cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that 22 appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant."

• An ARCA is defined in FEMA-REP-14 as "...an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety." The DHS/FEMA has developed a standardized system for numbering exercise issues (Deficiencies and ARCAs). This system is used to achieve consistency in numbering exercise issues among DHS/FEMA Regions and site-specific exercise reports within each Region. It is also used to expedite tracking of exercise issues on a nationwide basis. The identifying number for Deficiencies and ARCAs includes the following elements, with each element separated by a hyphen (-).

• Plant Site Identifier - A two-digit number corresponding to the Utility Billable Plant Site Code.

• Exercise Year - The last two digits of the year the exercise was conducted.

• Criterion Number - A two-digit number corresponding to the criteria numbers in the six Exercise Evaluation Areas described in Federal Register Notice/Vol. 67, No. 80 dated April 25, 2002, which amends FEMA-REP 14, Radiological Emergency Preparedness Exercise Manual.

• Issue Classification Identifier - (D = Deficiency, A = ARCA). Only Deficiencies and ARCAs are included in exercise reports. Plan Issues are reported to the State via a letter from the Regional Administrator. Therefore, standardized issue numbers are not assigned to Plan Issues.

• Exercise Issue Identification Number - A separate two (or three) digit indexing number assigned to each issue identified in the exercise.

4.2.1. Minnesota

Jurisdictions 23 a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.4.2.1.1. Minnesota State Initial Warning Point (Bureau of Criminal Apprehension)

MET: 1.a.1, 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.2. Minnesota State Emergency Operations Center MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 2.b.2, 2.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.3. Minnesota State Emergency Operations Center (Ingestion Phase)

MET: 1.c.1, 2.d.1, 2.e.1, 3.e.1, 3.e.2, 3.f.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.4. Intermediate Phase Task Force (IPTF) -

Minnesota State EOC 24 a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.MET: 2.d.1, 2.e.1, 3.e.1, 3.e.2, 3.f.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.5. Minnesota State Planning and Assessment Center MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 2.b.2, 2.d.1, 2.e.1, 3.e.1, 3.e.2, 3.f.1, 4.a.2, 4.b.1, 4.c.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.6. Minnesota State PIO at Joint Information Center MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.7. Public Inquiry Hotline (MN State Emergency Operations Center)

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

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None 25 d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.8. State Regional Program Coordinator -

Sherburne County MET: 1.a.1, 2.a.1, 2.b.2, 2.c.1, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.9. State Regional Program Coordinator -

Wright County MET: 1.a.1, 2.a.1, 2.b.2, 2.c.1, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.10.

State Patrol Helicopter - Sherburne County Recreationalists MET: 1.d.1, 1.e.1, 3.a.1, 3.b.1, 5.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 26 a.b. 4.2.1.11.

State RAD Field Team #1 (Monticello)

MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.3.

AREAS REQUIRING CORRECTIVE ACTION: 4.a.3.

ISSUE NO.: 39-09-4a3-A-03 CRITERION: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected.

Teams must 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, I.8., 9., 11)

CONDITION: During the plume phase and the ingestion phase, there was a lack of contamination control. In the assembly and disassembly of the air monitoring sample head, no gloves were worn. This can lead to cross contamination between the particulate filter, the gaseous collection cartridge, and the environment around the vehicle, which had been in the plume as well. During the plume phase, the air monitoring collection head was disassembled and bagged with bare hands. During the ingestion phase, all the samples were collected without wearing gloves. Grass samples were held by the bare hands while being cut and put into the bag. The person collecting soil samples kneeled on the ground without using a plastic sheet or wearing gloves. At no time was State RAD Field Team #1 observed surveying themselves with the Canberra Model MCB-2 contamination survey meter.

POSSIBLE CAUSE: Lack of adequate training or understanding by Field Team members of the importance of wearing gloves to limit potential contamination.

REFERENCE:

NUREG 0654 H.12, I.8, J.10,and J.11 EFFECT: Lack of proper contamination control in obtaining air samples as well as ingestion pathway samples can lead to invalid sample results and/or contamination of equipment.

27 c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f. CORRECTIVE ACTION DEMONSTRATED: Additional training has been provided to field team members as to the importance of contamination control and the importance of wearing the proper personal protective equipment.

Also during subsequent training held annually this issue will be stressed as to its importance.

DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.12.

State RAD Field Team #2 (Monticello)

MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.3.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.13.

State RAD Team Command Van (Monticello)

MET: 1.d.1, 1.e.1, 2.b.1, 3.a.1, 3.b.1, 4.a.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.14.

State RAD Field Team #1 (Ingestion Phase) (Monticello) 28 a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.MET: 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.15.

State RAD Field Team #2 (Ingestion Phase) (Monticello)

MET: 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.16.

State RAD Team Command Van (Ingestion Phase) (Monticello)

MET: 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.17.

Minnesota Department of Agriculture Field Team MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None 29 e.f.a.b.c.d.e.f.a.b.PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.18.

Minnesota Department of Natural Resources Field Team MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.19.

Minnesota Department of Health State Public Health Laboratory MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 4.c.1.

AREAS REQUIRING CORRECTIVE ACTION: 4.c.1.

ISSUE NO.: 39-09-4c1-A-06 CRITERION: Laboratory is capable of performing required radiological analyses to support PADs CONDITION: Results of laboratory isotopic analysis of samples counted in Marinelli beakers were not reliable, and there was no assurance in the quality and quantity of the isotopic concentrations.

POSSIBLE CAUSE: Bagged samples were simply placed in the Marinelli beaker without regard to placement around the detector well within the Marinelli for efficiency or configuration. Additionally, the bagged cubic container sitting on top of the detector well in the Marinelli is not consistent with the geometry of the calibration source.

REFERENCE:

NUREG-0654 C.3, J.11 30 c.d.e.f.a.b.c.d.e.f. EFFECT: Since there is no reproducible geometry and the sample geometry was not consistent with the calibration source, there can be no assurance in the quality and quantity of the analysis. In the configuration used, the concentration of the various isotopes would have been under estimated. This in turn would have underestimated the dose rates for determination of the Relocation Protective Action Guides and would have underestimated the concentrations for comparison to the Derived Intervention Levels for determining where food embargos should be placed.

CORRECTIVE ACTION DEMONSTRATED: On October 19, 2009, the Minnesota Department of Health, Public Health Laboratory successfully re-demonstrated the preparation and analysis of environmental samples in a reproducible geometry consistent with calibration standards. Procedures have been modified to prepare and analyze samples consistent with calibration standards. Three Laboratory technicians have been trained in the corrected procedure.

DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.20.

State Traffic and Access Control Point -

Sherburne County MET: 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.21.

Evacuee Decontamination Rogers Reception Center 31 a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.MET: 1.d.1, 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.22.

Evacuee Monitoring Rogers Reception Center MET: 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.23.

Evacuee Registration Rogers Reception Center MET: 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.24.

Evacuee Vehicle Decontamination Rogers Reception Center MET: 1.d.1, 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None 32 e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.25.

Evacuee Vehicle Monitoring Rogers Reception Center MET: 1.d.1, 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.26.

Medical Services (MS-1) Transportation North Memorial Medical Center MET: 1.d.1, 1.e.1, 3.b.1, 6.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: 3.a.1.

PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.27.

Medical Services (MS-1) Facility North Memorial Medical Center MET: 1.d.1, 3.a.1.

AREAS REQUIRING CORRECTIVE ACTION: 1.e.1, 6.d.1.

ISSUE NO.: 39-09-1e1-A-04 CRITERION: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations.

CONDITION: The Landauer TLD cards did not have an exchange date 33 specified and the Emergency Management Director did not know when they were last changed or when the next exchange date was due. Also there was not any reference available to specify when to exchange the TLDs.

POSSIBLE CAUSE: There was no exchange date on the TLDs and there were no instructions or indications on when the TLDs needed to be exchanged.

REFERENCE:

NUREG-654 H.7, 10: J.10.a, b, e: J.11; K.3.a EFFECT: The dose assigned to an emergency work from reading one of the TLDs may not be accurate.

RECOMMENDATION: Contact Landauer to find out when they were last exchanged, exchange the TLDs when due, formalize the exchange process in procedures, and track exchange dates.

SCHEDULE OF CORRECTIVE ACTIONS: North Memorial Hospital will be updating procedures to ensure the proper thermoluminescent dosimeters have current exchange dates and instructions will be on hand at the hospital as to how to properly use and exchange the thermoluminescent dosimeters.

ISSUE NO.: 39-09-6d1-A-05 CRITERION: Facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654, F.2., H.10., K.5.a.b., L.1., 4)

CONDITION: The Model 3 survey meters were checked for operability using a Cs-137 source attached to the case. They were only checked to see if they got a response - a response check. The instruments were not operability checked using a specified range of readings for a particular source.

POSSIBLE CAUSE: Procedures only call for a response check - not an operability check with a specified source with a specific range of readings.

34 c.d.e.f.a.b.c.d.e.f.

REFERENCE:

F.2: H.10: K.5.a, b: L.1; L.4.

EFFECT: An instrument range of readings from a response to a specified source is typically provided to ensure proper operation of the instrument. If the instrument reads above or below the range, the instrument is not responding properly and is considered inoperable. Without a specified range of reading there can be no assurance the instrument is operating properly.

RECOMMENDATION: All instruments should have a specified response range for a particular source to ensure proper operability of the instrument.

Plans and procedures should be changed, and all personnel trained in the changes. SCHEDULE OF CORRECTIVE ACTIONS: The Model 3 survey meters will have a range of reading sticker attached and training will be provided to the users of the Model 3 survey meters on how to properly do operational checks. DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2. Risk Jurisdictions 4.2.2.1. Sherburne County Initial Warning Point MET: 1.a.1, 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 35 a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.4.2.2.2. Sherburne County Emergency Operations Center MET: 1.a.1, 1.c.1, 1.d.1, 2.a.1, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.3. Sherburne County Traffic and Access Control Point MET: 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.4. Sherburne County Public Information Officer at the State JIC MET: 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.5. EV-2 Big Lake School District 36 a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.MET: 1.d.1, 1.e.1, 3.c.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.6. Emergency Worker Monitoring and Decontamination MET: 1.d.1, 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.7. Emergency Worker Vehicle Monitoring and Decontamination MET: 1.d.1, 1.e.1, 3.a.1, 6.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.8. Sherburne County Emergency Operations Center (Ingestion Phase)

MET: 2.d.1, 2.e.1, 3.e.1, 3.e.2, 3.f.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None 37 e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.9. Sherburne County Public Information Officer at the State JIC (Ingestion Phase)

MET: 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.10.

Wright County Initial Warning Point MET: 1.a.1, 1.d.1, 3.a.1, 3.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.11.

Wright County Emergency Operations Center MET: 1.a.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: 1.c.1, 1.e.1.

ISSUE NO.: 39-09-1c1-A-01 CRITERION: Key personnel with functional roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

CONDITION: The decision by the Jail Captain at 1246 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.74103e-4 months <br /> to evacuate the 38 jail population was not coordinated with the EOC, and the Nuclear Director/Operations Chief did not become aware of the action until about 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> near the end of the exercise. Options for sheltering-in-place or evacuating were not considered, and the RADEF staff and Operations Chief were not consulted regarding appropriate actions.

POSSIBLE CAUSE: Key players, including the Operations Chief and RADEF staff, were not included in decision-making for evacuation of the jailed population.

REFERENCE:

NUREG-0654: A.1.d; A.2.a, b EFFECT: EOC leadership was neither included in nor aware of protective actions being made regarding the jailed population.

RECOMMENDATION: The EOC staff should receive training and procedures should be improved relative to decision-making and operations involving protective actions.

SCHEDULE OF CORRECTIVE ACTIONS: Wright County has conducted additional training with its staff on the proper coordination and decision-making process on how to implement protective actions for the County Jail, which included a possible evacuation decision. This will be a point of emphasis during subsequent years of training within the county.

ISSUE NO.: 39-09-1e1-A-02 CRITERION: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations.

CONDITION: During the operations check of dosimetry equipment, the Radiological Officer (RO) incorrectly zeroed the 0-200mR Model 622 Direct-Reading Dosimeters (DRDs) manufactured by Arrow-Tech INC. The DRDs were zeroed at the top of the scale vice the bottom of the scale; specifically 200mR. POSSIBLE CAUSE: The RO's lack of attention to detail resulted in the 39 c.d.e.f.a.b.c.d.e.f.a.b.c.d.equipment being zeroed incorrectly.

REFERENCE:

NUREG-0654, H.7, 10; J.10 A, B, E; J.11; K.3.Q.

EFFECT: Radiation levels may not have been properly indicated, possibly resulting in contamination to emergency workers without their knowledge.

CORRECTIVE ACTION DEMONSTRATED: The controller was immediately notified of the inadequacy and play was stopped to conduct re-training to the RO from the controller. Upon completion of the retraining the RO was re-evaluated. He successfully demonstrated to the evaluator how to zero the DRDs. DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.12.

Wright County Traffic and Access Control Point MET: 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.13.

Wright County Public Information Officer at the State JIC MET: 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None 40 e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.14.

Wright County Emergency Operations Center (Ingestion Phase)

MET: 2.d.1, 2.e.1, 3.e.1, 3.e.2, 3.f.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.15.

Wright County Public Information Officer at the State JIC (Ingestion Phase)

MET: 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.16.

EV-2 St. Michael - Albertville School District MET: 1.d.1, 1.e.1, 3.c.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 41 a.b.c.d.e.f.4.2.2.17.

EV-2 Buffalo School District MET: 1.d.1, 1.e.1, 3.c.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 42 APPENDIX 1 ACRONYMS AND ABBREVIATIONS AMS Aerial Measuring System ARC American Red Cross ARES Amateur Radio Emergency Services CAD Computer Aided Dispatch CCC Congregate Care Center CDD Civil Defense Director CDE Committed Dose Equivalent CR County Road DCO Dosimetry Control Officer DOC Department Operations Center DRD Direct Reading Dosimeter EAS Emergency Alert System ECL Emergency Classification Level ED Emergency Department EMD Emergency Management Director EMT Emergency Medical Technicians EOC Emergency Operations Center EOF Emergency Operations Facility EPA Environmental Protection Agency EPZ Emergency Planning Zone ERDS Emergency Radiological Data System EW Emergency Worker FAA Federal Aviation Administration FEMA Federal Emergency Management Agency GE General Emergency GIS Global Information System HS Human Services HSD Human Services Department HSIP Homeland Security Information Program HSO Human Services Officer IPTF Intermediate Phase Task Force IPZ Ingestion Planning Zone ISD Independent School District IWP Initial Warning Point JIC Joint Information Center MDC Mobile Data Computers MENRF Monticello Emergency Notification Report Form MNGP Monticello Nuclear Generating Plant MRCC Medical Resources Control Center MRF Minnesota Road Facility MSP Minnesota State Patrol NARAC National Atmospheric Release Advisory Center NARS Nuclear Accident Reporting System 43 ND Nuclear Director NMMC North Memorial Medical Center NPR National Public Radio NRC Nuclear Regulatory Commission OC Operations Chief OSD Optically Stimulated Dosimeter OSL Optically Stimulated Luminescence PAC Planning Assessment Center PAD Protective Action Decision PAG Protective Action Guide PAR Protective Action Recommendations PC Planning Chief PHLD Public Health Laboratory Division PIO Public Information Officer RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Services RAD Radiological Accident Deployment RDO Radiation Defense Officer REA Radiation Emergency Area REP Radiological Emergency Preparedness RMCC Resource Medical Control Center RO Radiological Officer RPT Radiation Protection Technologists RRC Rogers Reception Center RTC Rad Team Captain SAE Site Area Emergency SC Sherburne County SCEOC Sherburne County Emergency Operations Center SEOC State Emergency Operations Center SIM Site Incident Manager SNB Special News Bulletins SOG Standard Operating Guidelines SOP Standard Operating Procedure TACP Traffic Access Control Points TCP Traffic Control Points TEDE Total Effective Dose Equivalent TLD Thermo Luminescent Dosimeter TSC Technical Support Center VHF Very High Frequency WC Wright County WCND Wright County Nuclear Director 44 APPENDIX 2 EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel who evaluated the Monticello Nuclear Generating Plant Radiological Emergency Preparedness (REP) Full Participation Plume and Ingestion Exposure Pathway Exercise on August 18 and 19, 2009.

Evaluator Team Leaders are indicated by an asterisk "(*)" before their names. The organization which each evaluator represents is indicated by the following abbreviations:

Agency

45 DATE: 2009-08-18, SITE: Monticello Nuclear Generating Plant, MN LOCATION EVALUATOR AGENCY Minnesota State Initial Warning Point (Bureau of Criminal Apprehension)

Nick Lowe ICF Minnesota State Emergency Operations Center Wes Ryals Debra Schneck Louis Sosler ICF ICF ICF Minnesota State Emergency Operations Center (Ingestion Phase)Debra Schneck Louis Sosler ICF ICF Intermediate Phase Task Force (IPTF) - Minnesota State EOC Nick Lowe ICF Minnesota State Planning and Assessment Center Stephen Chambers David Stuenkel ICF ICF Minnesota State PIO at Joint Information Center Michael Meshenberg ICF Public Inquiry Hotline (MN State Emergency Operations Center)

George R MacDonald ICF State Regional Program Coordinator - Sherburne County

• Clinton Crackel DHS/FEMA State Regional Program Coordinator - Wright County

• Delwyn Kinsley DHS/FEMA State Patrol Helicopter - Sherburne County Recreationalists Todd Sniffin ICF State RAD Field Team #1 (Monticello)

Bernis Hannah ICF State RAD Field Team #2 (Monticello)

Thomas Essig ICF State RAD Team Command Van (Monticello)

Richard Watts ICF State RAD Field Team #1 (Ingestion Phase) (Monticello)

Bernis Hannah ICF State RAD Field Team #2 (Ingestion Phase) (Monticello)

Thomas Essig ICF State RAD Team Command Van (Ingestion Phase) (Monticello)

Richard Watts ICF Minnesota Department of Agriculture Field Team John Zeidler ICF Minnesota Department of Natural Resources Field Team Paul Cormier ICF Minnesota Department of Health State Public Health Laboratory Richard Grundstrom ICF State Traffic and Access Control Point - Sherburne County Kara Scott DHS/FEMA Evacuee Decontamination Rogers Reception Center Wes Ryals ICF Evacuee Monitoring Rogers Reception Center Deborah Fulk DHS/FEMA Evacuee Registration Rogers Reception Center Carl Bebrich DHS/FEMA Evacuee Vehicle Decontamination Rogers Reception Center Donald Greene ICF Evacuee Vehicle Monitoring Rogers Reception Center James King DHS/FEMA Medical Services (MS-1) Transportation North Memorial Medical Center Clark Duffy ICF Medical Services (MS-1) Facility North Memorial Medical Center Richard Grundstrom ICF Sherburne County Initial Warning Point Kara Scott DHS/FEMA Sherburne County Emergency Operations Center Deborah Fulk Donald Greene Jeffry McSpaden DHS/FEMA ICF U.S. DOT Sherburne County Traffic and Access Control Point Clayton Spangenberg ICF Sherburne County Public Information Officer at the State JIC George R MacDonald ICF EV-2 Big Lake School District Clark Duffy ICF Emergency Worker Monitoring and Decontamination Jeffry McSpaden U.S. DOT Emergency Worker Vehicle Monitoring and Decontamination Clayton Spangenberg ICF Sherburne County Emergency Operations Center (Ingestion Phase)Paul Cormier John Zeidler ICF ICF Sherburne County Public Information Officer at the State JIC (Ingestion Phase)

George R MacDonald ICF Wright County Initial Warning Point Bridget Ahlgrim DHS/FEMA Wright County Emergency Operations Center Carl Bebrich Edward Golinski David Ortman DHS/FEMA DHS/FEMA DHS/FEMA 46 Wright County Traffic and Access Control Point James King DHS/FEMA Wright County Public Information Officer at the State JIC George R MacDonald ICF Wright County Emergency Operations Center (Ingestion Phase)

Bridget Ahlgrim Tracey Green DHS/FEMA ICF Wright County Public Information Officer at the State JIC (Ingestion Phase)

George R MacDonald ICF EV-2 St. Michael - Albertville School District Edward Golinski DHS/FEMA EV-2 Buffalo School District Edward Golinski DHS/FEMA* Team Leader 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100