ML101950058

FEMA Ltr Dtd 6/28/10 Updated Final Exercise Report for IPEC Radiological EP Plume Pathway Exercise Conducted 12/3/08

ML101950058
Person / Time
Site:	Indian Point
Issue date:	06/28/2010
From:	Canton L US Dept of Homeland Security, Federal Emergency Management Agency
To:	Collins S Division of Nuclear Materials Safety I
References
Download: ML101950058 (136)

Text

U.S. Department of Homeland Seeurity Region II 1acob K. 1avits Federal Office Building 26 Federal Plaza, Room 1311 New York, NY 10278-0002 FEMA June 28, 2010 Mr. Samuel J. Collins U.S. Nuclear Regulatory Commission NRC Region I 475 Allendale Road King of Prussia, PA 19406-1415

Dear Mr. Collins:

Enclosed please find five copies of the Updated Final Exercise Report for the Indian Point Energy Center radiological emergency preparedness Plume Pathway Exercise conducted on December 3, 2008. This report, dated June 20, 2010, is being re-issued because a number of related out-of- out-of sequence drills and demonstrations were completed in the fall of 2009 and these are now included in the report. The previous report, dated September 18,2009, should be replaced with this version.

The State of New York and local emergency response organizations successfully demonstrated the capabilities to implement their off-site radiological emergency response plans and procedures, based on the evaluation of this exercise by the Regional Assistance Committee and a team of Federal evaluators. There were no deficiencies; nine Areas Requiring Corrective Actions were identified, 2 of which have been already corrected as noted in the report.

State and local preparedness is adequate to protect the health and safety of the public living in the vicinity of the Indian Point NPS and will provide reasonable assurance that appropriate measures can be taken offsite in the event of a radiological emergency.

If you have any questions regarding this matter, please contact Rebecca Thomson, Chair of the R. II Regional Assistance Committee at (212) 680-8509.

Sincerely yours, Lynn Canton Regional Administrator Enclosures www.ferna.gov*PH: (212)680-3600

REVISED FINAL EXERCISE REPORT INDIAN POINT ENERGY CENTER Licensee: Entergy Exercise Date: December 3, 2008 Report Date: Sept 18,2009 Revised Date: June 20, 2010 u.s. DEPARTMENT OF HOM:ELAND SECURITY FEDERAL EMERGENCY MANAGEMENT AGENCY REGION II 26 Federal Plaza New York. New York 10278

Table of Contents L EXECUTIVE

SUMMARY

II. INTRODUCTION ..................................................................... 2 III. EXERCISE OVERVIEW ................................................................ 5 A. Emergency Planning Zone Description ................................ 5 B. Exercise Participants ...................................................... 7 C. Exercise Timeline . . . . . . . . . . . . . . . . . . . ........... .. ...... . . . . .... . . . ..... 12 IV. EXERCISE EVALUATION AND RESULTS ..................................... 15 A. Summary Results of Exercise Evaluation ......................................... 15 B. Status of Jurisdictions Evaluated ................................................... 25 I. NEW YORK STATE .........................................................................

.........................................................................27 27 1.1 New York State Emergency Operations Center ..................................... 27 1.2 Licensee Emergency Operations Facility .............................................. 27 1.3 New York State Accident Assessment .......................................... ., ... 27 1.4 New York State Personnel Monitoring Center - Townline Sub Residence ...... 27 1.5 Indian Point Joint Information Center ..................................................... 28 1.6 Indian Point Joint Information Center Briefings ....................................... 28 1.7 Indian Point Joint Information Center Public Inquiry ................................ 29 1.8 Indian Point EAS Station WHUD .......................................................

.......................................................29 29 1.9 State of New York Call Center ........................................................ 29 2.0 New York State - Westchester County Joint Emergency Worked ...................... ......................29 29 Personnel Monitoring Center

2. RISK JURISDICTIONS 1 ORANGE COUNTy .....................................................................

.....................................................................30 30 2.1.1 Orange County Emergency Operations Center .................................... 30 2.1.2 Orange County Accident Assessment..

Assessment...............................................

............................................. 33 2.1.3 Orange County - Field Monitoring Team 1.......................................... 33 2.1.4 Orange County - Field Monitoring Team 2 ....................................... 33 2.1.5 Orange County - General Population Reception Center......................... 33 Middletown High School 2.1.6 Orange County - General Population Bus Company - West Point Tours ..... .3 3 2.1.7 Orange County School Bus Company - West Point Tours- Highland Falls.. 34

2. 1.8 Orange County - School Interview - Fort Montgomery Elementary School..34 2.1.9 Orange County - Congregate Care Center - Middletown High School... ........ 34

2.1.10 Orange County - Medical Services Transport - Cornwall... ........................ 34 Volunteer Ambulance Corps -2009 2.1.11 Orange County - Medical Services Hospital- St Lukes ............................ 35 Cornwall Hospital - 2009 2.1.12 Orange County - Medical Services Hospital- St Lukes ............................ 36 Cornwall Hospital - 2007 2.1.13 Orange County Medical Services Transport - 2007 .................................... 36 2.1.14 Orange County - Emergency Worker Personnel Monitoring Center.......... .37 Orange - Ulster Boces 2.1.15 Orange County Traffic Control Point ....................................................... .37 2.2 PUTNAM COUNTyCOUNTy..........................................................................

.......................................................................... 38 2.2.1 Putnam County - Warning Point ..................................................................... 38 2.2.2 Putnam County Emergency Operations Center .............................................. 38 2.2.3 Putnam County Accident Assessment.. .......................................................... 40 2.2.4 Putnam County - Field Monitoring Team Alpha ............................................ 41 2.2.5 Putnam County - Field Monitoring Team Bravo .............................................

.............................................42 42 2.2.6 Putnam County - School Reception Center - Kent Primary School... ............. 42 2.2.7 Putnam County - General Population Bus Company ..................................... 42 Haldane Central School District 2.2.8 Putnam County - School Interview - Haldanl~ Central School District.. ........ 43 2.2.9 Putnam County - School Bus Company - Haldane Central School District.. 43 2.2.10 Putnam County - School Interview - Noahs Ark Nursery School... ............... .43 2.2.11 Putnam County - School Interview - Putnam Valley Day Care ..................... .43 2.2.12 Putnam County - School Interview - St Phillips Nursery School... ................ .44 2.2.13 Putnam County - Medical Services TransporL .............................................. .44

...............................................44 Carmel Volunteer Ambulance Company 2.2.14 Putnam County - Medical Services Hospital - Putnam Hospital... ................. .44 2.2.15 Putnam County Traffic Control Point.. ............................................................ 45 2.2.16 Putnam County Reception Center Carmel High school... ............................... .46 2.3 ROCKLAND COUNTY ........................................................................

........................................................................48 48 2.3.1 Rockland County - Warning Point... ............................................................... .48 2.3.2 Rockland County Emergency Operations Center........................................... .48 2.3.3 Rockland County Accident Assessment.. ........................................................ 48 2.3.4 Rockland County - Field Monitoring Team 1................................................. .48 2.3.5 Rockland County - Field Monitoring Tt~am 2 2.................................................

................................................. .49 2.3.6 Rockland County - General Population Reception Center.............................. 49 Pearl River High School 2.3.7 Rockland County - General Population Bus Company ................................... 51

...................................51 Clarkstown Central School District 2.3.8 Rockland County - General Population Bus Company ...................................

...................................51 51 East Ramapo Central School District 2.3.9 Rockland County - School Bus Company ........................................................ 51

........................................................51 Clarkstown Central School District 2.3.10 Rockland County - School Bus Company ........................................................

........................................................52 52 East Ramapo Central School District ii

2.3.11 Rockland County - Medical Services Transport .............................................

.............................................52 52 Spring Hill Ambulance Corps 2.3.12 Rockland County - Medical Services Hospital- Good Samaritan HospitaL..52 2.3.15 Rockland County - Emergency Worker Personnel Monitoring ..................... 52 Center Rockland County Sewer District 2.3.14 Rockland County Traffic Control Point.. ........................................................ 53 2.4 WESTCHESTER COUNTy COUNTy....................................................................

.................................................................... 54 2.4.1 Westchester County - Warning Point... ........................................................... 54 2.4.2 Westchester County Emergency Operations Center....................................... 54 2.4.3 White Plains Control CeIL ............................................................................. 54 2.4.4 Westchester County Accident Assessment.. ................................................. 54 2.4.5 Westchester County - Field Monitoring Team HD-l.. ................................... 56 2.4.6 Westchester County - Field Monitoring Team HD-2 ..................................... 56 2.4.7 Westchester County Call Center. ....................................................................

....................................................................56 56 2.4.8 Westchester County - Traffic Control Point ,................................................. 56 2.4.9 Westchester County - General Population Chappaqua Bus Company ........... 57 2.4.10 Westchester County - School Bus Company Chappaqua Bus ........................ ........................5757 2.4.11 Westchester County - School Bus Company Briarcliff Manor....................... .......................5757 School District 2.4.12 Westchester County - Lakeland School Bus Company ................ ,................. 57 2.4.13 Westchester County - Todd Elementary School Interviews Interviews..........................

.......................... 58 2.4.14 Westchester County - Briarcliff High Schoon Interview ................................ .58 2.4.15 Westchester County - Briarcliff Middle School Interview ........................... 58 2.4.16 Westchester County - Anne M. Donner Middle School Interviews .............. 58 2.4.17 Westchester County - Roosevelt Education Center School Interview ......... .........59 59 2.4.18 Westchester County - Yorktown Heights Center School Interview ........ :...... 59 2.4.19 Westchester County - Brookside Elementary School Interview .................... .59 2.4.20 Westchester County - Carrie E. Thompkins Elementary Schoollnterview ... ...59 59 2.4.21 Westchester County - Clarement Elementary School Interview .................... ....................60 60 2.4.22 Westchester County - Croton Harmon High School Interview ...................... ......................60 60 2.4.23 Westchester County - Fox Meadow School Interview ...................................

...................................60 60 2.4.24 Westchester County - Hillcrest Elementary School Interview ....................... .......................6060 2.4.25 Westchester County - Oaks ide Elementary School Interview ........................ ........................61 61 2.4.26 Westchester County - Ossining High Schoollnterview .................................

.................................61 61 2.4.27 Westchester County - Park Early Childhood Center School Interview .......... ..........61 61 2.4.28 Westchester County - Peekskill High School Interview .................................

.................................61 61 2.4.29 Westchester County - Peekskill Middle School Interview .............................

.............................6262 2.4.30 Westchester County - Pierre Van Cortland Middle School Interview ............ ............62 62 2.4.31 Westchester County - Pines Bridge Schoollnterview ....................................

....................................62 62 2.4.32 Westchester County - Seven Bridges Middle Schoollnterview ..................... .....................62 62 2.4.33 Westchester County - West Orchard Elementary Schoollnterview ............... ...............63 63 2.4.34 Westchester County - Woodside Elementary School Interview ..................... .....................6363 2.4.35 Westchester County - Walden School Interview ............................................

............................................63 63 2.4.36 Westchester County - Medical Service Hospital Westchester Medical Center................................................................................................

................................................................................................63 63 2.4.37 Westchester County - Medical Service Transport Trans Care ....................... .......................6464 Ambulance Service 2.4.38 Westchester County - Hendrick Hudson School Bus Company Interview ..... .....64 64 11\

2.4.39 Westhester County - Hendrick Hudson District School Interviews ................... ...................65 65 2.4.40 Westchester County - Lakeland School District School Interviews .................. ..................65 65 2.4.41 Westchester County Croton Bus Company Interview .......................................

.......................................65 65 2.5 SUPPORT JURISDICTIONS 2.5.1 Bergen County Emergency Operations Cc:nter ............................................ 65

............................................65 APPENDIX 1. ACRONYMS AND ABBREVIATIONS .............................................

.............................................66 66 APPENDIX 2. EXERCISE EVALUATORS AND TEAM LEADERS ....................... .......................69 69 APPENDIX 3. EXERCISE OBJECTIVES & EXTENT OF PLAY ............................

............................74 74 APPENDIX 4. EXERCISE SCENARIO ...................................................................... 107 APPENDIX 5. PLANNING ISSUES ............................................................................ 110 LIST OF TABLES TABLE I. EXERCISE TIME LINE ............................................................................... 12 TABLE 2.

SUMMARY

OF EXERCISE EVALUATIONS ........................................... 16 IV

I. Executive Summary The Federal Emergency Management Agency, Region 11 evaluated an exercise on December 3, 2008 and related out of sequence activities in the plume exposure pathway emergency planning zone (EPZ) around the Indian Point Energy Center (fPEC). The purpose of the exercise and out of sequence activities was to assess the level of State and local preparedness in responding to a radiological emergency. The exercise and out of sequence activities 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 previous exercise at this site was conducted on December 3, 2008.

The qualifying emergency preparedness exercise was conducted on March 3, 1982.

FEMA wishes to acknowledge the efforts of the many individuals in New York State; Westchester, Rockland, Orange, and Putnam Counties; and Bergen County, New Jersey 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. The cooperation and teamwork of all participants were evident during this exercise.

This report contains the draft evaluation of the biennial exercise and of the following out-out of-sequence activities in Orange, Putnam, Rockland and Westchester counties:

Reception Centers; Congregate Care Centers; Emergency Worker Personnel Monitoring Centers; General and Special Population Bus Companies; School Bus Companies; Traffic Control Points; School Interviews and Medical Drills.

The State and local organizations, except where noted in this report, satisfactorily demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiendes and nine Areas Requiring Corrective Actions (ARCAs) were identified. Two AReA's have been resolved.

Six of the eight ARCA's from the previous 2006 exercise were corrected.

Therefore there are eleven ARC As remaining.

II. Introduction On December 7, 1979, the President directed FEMA to assume the lead responsibility for all offsite 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 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 tor 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:

• Taking the lead in offsite emergency planning and in the review and evaluation of RERPs and procedures developed by State and local governments;

• Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises ofthe plans and procedures conducted by State and local governments;

• 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 I 1993); and 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 2

- U.S. Department of Agriculture,

- U.S. Department of Transportation

- U.S. Department of Health and Human Services,

- U.S. Department of the Interior,

- U.S. Food and Drug Administration, and

- US Department of Defense Representatives of these agencies serve on the FEMA Region II Regional Assistance Committee (RAC), which is chaired by FEMA.

Formal submission of the RERPs for the IPEC to FEMA Region II by the State of New York and involved local jurisdictions occurred on October 10, 1991. Formal approval of the RERP was granted by FEMA on May 3, 1996, under 44 CFR 350.

A fuJi-scale REP exercise was evaluated on December 3,2008 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 at the IPEC. The purpose of this exercise report is to present the exercise results and findings on the performance of the offsite response organizations (ORO) during a simulated radiological emergency.

The tindings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the DHS New York Field Office Branch Chief and RAC Chairperson, and approved by the Acting Director of the Chemical and Nuclear Planning and Protection Division, Office ofInfrastructure Protection, DHS.

The criteria utilized in the FEMA evaluation proce:ss are contained in:

• NUREG-0654/FEMA-REP-I, Rev. I, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980; and

• Radiological Emergency Preparedness: Exercise Evaluation Methodology," published in the Federal Register on September 12,2001. and revised April 25, 2002.

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

Section IV of this report, titled "Exercise Evaluation and Results," presents information on the demonstration of applicable exercise evaluation areas at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all Deficiencies and Areas Requiring Corrective Action (ARCAs) assessed during this exercise, recommendations for corrective actions, and the State and local governments' schedule of corrective actions for each identified exercise issue, and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the Off Site Response Organizations (OROs)' efforts to resolve them.

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II. Exercise Overview Contained in this section are data and basic information relevant to the December 3, 2008 exercise held to test the offsite emergency response capabilities in the area surrounding the lPEe. This section of the exercise report includes a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were eval uated, and a tabular presentation of the time of actual occurrence of key exercise events and activities.

A. Plume Emergency Planning Zone Description The IPEe's 10-mile plume pathway EPZ contains portions of four New York State counties: Orange, Putnam, Rockland, and Westchester.

The IPEC is located on the east bank of the Hudson River about 24 miles north of the New York City boundary line at Indian Point, Village of Buchanan in upper Westchester County, New York. The station is about 0.8 miles southwest of the city of Peekskill, 8.3 miles south of West Point, 1.5 miles northeast of the Lovett Generating Station site, 4.6 miles north of the Bowline Point Generating Station site, and 23 miles north of Montrose Point.

The IPEC is accessible by several roads in the Village of Buchanan. Broadway, a two- two lane paved road, borders the site to the east and is the primary access road to the site.

The Village roads of Bleakley Avenue and First Street enter Broadway across from the eastern site boundary. Additionally, a paved road links the eastern boundary of the site to the plants.

There are no residences within the site boundary. In addition, there are no public highways or railroads that traverse the site area.

The IPEC is surrounded on almost all sides by high ground ranging from 600 to 1,000 feet above sea level. The site is on the east bank of the Hudson River which runs northeast to southwest at this point but turns sharply northwest approximately two miles northeast of the site.

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The west bank of the Hudson is flanked by the steep, heavily wooded slopes of the Dunderberg Mountain and to then northwest (elevations 1,086 feet and 1,257 feet respectively) and Buckberg Mountain to the west-southwest (elevation 793 feet). These peaks extend to the west by other names and gradually rise to slightly higher peaks.

The general orientation of this mass of high ground is northeast to southwest One mile northwest of the site, Dunderberg Mountain bulges to the east; north of Dunderberg and the site, high ground reaching 800 feet forms the east bank of the Hudson as the river makes a sharp turn to the northwest To the east of the site, peaks are generally lower than those to the north and west The Spitzenberg and Blue Mountains average about 600 feet in height and there is a weak, poorly defined series of ridges that again run mainly in a north-northeast direction. The river south of the site makes another sharp bend to the southeast and then widens as it flows past Croton and Haverstraw.

The IPEC is approximately 239 acres in size and contains three pressurized water reactors: Unit 1 (615 MWt, 265 MWe, de-fueled), Unit 2 (2,758 MWt, 873 MWe), and Unit 3 (3,025 MWt, 965 MWe). Indian Point Unit 3 is adjacent to and south of Unit 1 and Unit 2 is to the north of Unit L The two operating units, #'s 2 and 3, were designed by the Westinghouse Electric Corporation. Indian Point Unit 1 was decommissioned and defueled in 1974.

IPEC's pressurized water nuclear power plants each contain a nuclear reactor and closed loops of pressurized water that remove the heat energy from the reactor core and transfer the energy to a secondary water system that generates steam. The steam, in turn, drives a turbine generator set which produces electric power.

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B. Exercise Participants The following agencies, organizations, and units of government participated in the Indian Point 3 exercise on December 3,2008.

Federal Agencies us Military Academy at West Point State Jurisdictions New York State Division of Military and Naval Affairs New York State Depaetment of Agriculture and Markets New York State Department of Environmental Conservation New York State Department of Health New York State Department of Highways New York State Department of Social Services New York State Department of Transportation New York State Emergency Management Office New York State Emergency Medical Services Coordinator New York State Office of Fire Prevention and Control New York State Park Police New York State Publice Service Commission New York State Police New York Thruway Authority New York State Office of General Services NYS Energy Research and Development Authority State University of New York New York State Office of the Aging New York State Office of Human Services New York State Education Department New York State Department of Labor New York State Office of Mental Health New York State Division of Criminal Justice Services 7

Risk Jurisdictions Orange County Orange County Commission on Aging Orange County Commissioner on Emergency Servi<:es Orange County Commissioner on Finance Orange County Commissioner on Fire Services Orange County Commissioner on Mental Health Orange County Commissioners on Health Orange County Commissioners on Social Services Orange County Department of Health Orange County Department of Public Works, Buildings and Grounds Orange County Department of Social Services Orange County District Attorney's Office Orange County Division Budget Orange County Division of Emergency Management Orange County Division of Environmental Health Orange County Division of Fire Services Orange County Executive Office Orange County Health Department Orange County Maintenance Orange County Sheriffs Office Putnam County Putnam County Bureau of Emergency Services Putnam County Department of Highways and Facilities Putnam County Department of Social Services Putnam County Deputy County Executive Putnam County Division of Mental Health Putnam County Office for Aging Putnam County Patient Services Putnam County Schools Putnam County Sheriffs Department Rockland County Rockland Board of Cooperative Education Services Rockland County Sheriffs Department Rockland County Community College Rockland County Clerk's Office 8

Rockland County Department of Finance and Administration Rockland Board of Cooperative Education Services Rockland County Sheriffs Department Rockland County Community College Rockland County Clerk's Office Rockland County Department of Finance and Administration Rockland County Department of Health Rockland County Purchasing Department Rockland County Department of Law Rockland County Department of Highways Rockland County Department of Hospitals Rockland County Department of Mental Health Rockland County Department of Planning Rockland County Department of Public Transportation Rockland County Department of Social Services Rockland County Division of Environmental Resources Rockland County Executive's Office Rockland County Facilities Management Rockland County Fire and Emergency Rockland County Fire Training Center Rockland County Legislature Rockland County Management Information Systems Rockland County Office of Consumer Protection, Weights, and Measures Rockland County Department of General Services Rockland County Planning Board Rockland County Sewer District, Sparkill Rockland County Sheriff Westchester County Westchester County Bureau of Labor Westchester County Commissioner Westchester County Department of Consumer Protection Westchester County Department of Emergency Services Westchester County Department of Health Westchester County Department of Information Technology Westchester County Department of Parks Westchester County Department of Planning Westchester County Department of Public Services Westchester County Department of Public Works Westchester County Department of Social Services 9

Westchester County Department of Transportation Westchester County Executive Office Westchester County Geographical Information Services Westchester County Office of Hispanic Affairs Westchester County Police Department Westchester County Senior Services Westchester County Office of Hispanic Affllirs Westchester County Police Department Westchester County Senior Services Support .Jurisdictions Clarkstown Police Department Connecticut Department of Emergency Management and Homeland Security Grassland Fire Brigade New Castle Police Department New Jersey Depa11ment of Environmental Protection, Bureau of Nuclear Energy New Jersey Office of Emergency Managment New Jersey State Police South Orangetown Volunteer Ambulance Stony Point Police Department Bergen County Bergen County Hazardous Materials Personnel Bergen County Office of Emergency Management Private IV olunteer Organizations American Red Cross Cornell Cooperative Extension Entergy Nuclear Northeast Gilbert H. Cosnett & Associates Peter Brega Bus Company Radio Amature Civil Emergency Services Student Bus Company, Inc.

Salvation Army Transcare Ambulance Service 10

United Water Agency Westchester Medical Center WHUD Radio Station staff Federal Jurisdictions US Military Academy at West Point Nuclear Regulatory Commission 11

<:. Exercise Timeline Table I, on the following page, presents the time at which key events and activities occurred during the Indian Point Exercise on December 3,2008. Also included are times notifications were made to the participating jurisdictions/functional entities.

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Table 1 - Exercise Timeline 12nd Protective Action Decision: Shelter 1220 1220 (fax N/A 1220 1220 2nd Protective Action Decision: Evacuate 1220 1220 1156 1220 1220 2nd Siren Activation 1222 1220 1222 (fax 1222 1222 1222 2nd EAS or EBS Message 1226 1220 1226 (fax 1226 1226 1226 teetive Action Decision: Shelter 1241 1249 (fax N/A 1225 1241 teetive Action Decision: Evacuate 1241 1242 1249 (fax 1241 1225 1241 1243 1242 1249 (fax 1243 1243 1243 1247 1242 1249 (fax 1247 1247 1247 13

Table 1 - Exercise Timeline DATE: 2008-12-03, SITE: Indian Point, NY 14

IV. Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the December 3, 2008 exercise and associated out of sequence demonstrations to test the offsite emergency response capabilities of State and local governments in the 10-mile EPZ surrounding the lPEC.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria contained in the September 12,2001, Federal Register Notice (revised 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.

A. Summary Results of Exercise Evaluation The matrix presented in Table 2, on the following pages, presents the status of the exercise evaluation area criteria from the FEMA REP Exercise Evaluation Methodology that were 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:

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

D - Deficiency assessed A ARCA(s) assessed N - Not Demonstrated (Reason explained in Subsection B)

U Unresolved ARCA(s) from prior exercises 15

Table 2 - Summary of Exercise Evaluation DATE: December 3, 2008 SITE: Indian Point Energy Center, NY M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated 16

Table 2 - Summary of Exercise Evaluation DA TE: December 3, 2008 SITE: Indian Point Energy Center, NY M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated 17

Table 2 - Summary of Exercise Evaluation DATE:

DA TE: December 3, 2008 SITE: Indian Point Energy Center, NY M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated 18

Table 2 - Summary of Exercise Evaluation u

DATE: December 3, 2008 <

SITE: Indian Point Energy Center, NY M: Met, A: ARCA, D: Deficiency, P: Plan Issue. N: Not Demonstrated 19

Table 2 - Summary of Exercise Evaluation DATE: December 3, 2008 SITE: Indian Point Energy Center, NY M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated 20

Table 2 - Summary of Exercise Evaluation DA TE: December 3, 2008 SITE: Indian Point Energy Center, NY M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated 21

Table 2 - Summary of Exercise Evaluation DATE: December 3. 2008 SITE: Indian Point Energy Center, NY M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated 22

Table 2 - Summary of Exercise Evaluation DA TE: December 3, 2008 SITE: Indian Point Energy Center, NY M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated 23

Table 2 - Summary of Exercise Evaluation DATE: December 3, 2008 SITE: Indian Point Energy Center, NY M: Met, A: ARCA. D: Deficiency, P: Plan Issue, N: Not Demonstrated 24

B. Status of Jurisdictions Evaluated This subsection provides information on the evaluation of each participating jurisdiction and functional entity, in ajurisdiction~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 evaluation criteria under which no Deficiencies or AReAs were assessed during this exercise and under which no AReAs assessed during prior exercises remain unresolved.

Deficiency ~ Listing of the demonstrated exercise evaluation criteria 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 Actions - Listing of the demonstrated exercise evaluation criteria under which one or more AReAs were assessed during the current exercise or AReA's assessed during prior exercises remain unresolved. Included is a description of the AReAs 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 evaluation criteria which were not demonstrated as scheduled during this exercise and the reason they were not demonstrated.

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

Prior AReAs - Unresolved - Description of AReA's assessed during prior exercises which were not resolved in this exercise. Included is tht! reason the AReA remains 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.

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

An AReA is defined in FEMA-REP-14 as "... ...an an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself to have adverse impact public health and safety."

FEMA has developed a standardized system for numbering exercise issues (Deficiencies and AReAs). This system is used to achieve consistency in numbering exercise issues among FEMA Regions and site-spl;:cific 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 AReAs includes the following elements, with each element separated by a hyphen (-).

Plant Site Identifier Codes - A two-digit number com:sponding to the Utility Billable Plant Site.

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

Evaluation Area Criterion - A letter and number corresponding to the criteria in the FEMA REP Exercise Evaluation Methodology.

Issue Classification Identifier - (D = Deficiency, A = AReA). Only Deficiencies and AReAs are included in exercise reports.

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

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1. New York State 1.1 New York State - Emergency Operations Center

a. MET: l.a.!, I.b.l, I.e.!, J.d.l, I.e.!, 2.b.2, 2.e.l, 3.e.l. 5.a.l, S.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 1.2 Licensee Emergency Operations Facility

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

h. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE (PRIORISSUES-UNRESOLVED:NONE 1.3 New York State - Accident Assessment

a. MET: 2.a.l, 2.b.!

h. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES RESOLVED: NONE

f. PRIOR ISSUES UNRESOLVED: NONE 1.4 New York State - (Personnel Monitoring Center Townline Sub-Residence October 8,2009)

a. MET: I.d.1, 3.a.1, 3.b.I, 6.a.1, 6.b.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 27

1.5 Indian Point - Joint Information Center

a. MET: l.a.l, l.c.I. l.d.l, I.e.t, 5.a.I, 5,b.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES: - RESOLVED: ONE ISSUE NO: 32-06-1.d.I-A-OI ISSUE: During the media briefings held at 0934 and 120 I, spokespersons from the State, Westchester County, the Moderator and Representatives from Putnam, Orange and Rockland counties experienced audio transmission drop - out and static which interfered with the transmission of spoken information from the Media Briefing Room at the Joint Information Center and the Media Briefing areas in Putnam, Orange and Rockland Counties.

A back-up communication bridge was available but not used.

CORRECTIVE ACTION DEMONSTRATED: During the December 3,2008 exercise no transmission failures wen~ note:d and this ARCA has been corrected.

f. PRIOR ISSUES - UNRESOLVED: NONE 1.6 Indian Point - Joint Information Center Briefings

a. MET: 5.b.I

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 28

1.7 Indian Point - Joint Information Public Inquiry

a. MET: S.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED:NONE 1.8 Indian Point - EAS Station - WHUD

a. MET: I.d.l,5.a.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 1.9 State of New York - Call Center

a. MET: 1.a:l, I.e.], J.d. I , I.e. J, S.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.0 State of New York - Westchester County Emergency Worker Personnel Monitoring Center (~ruly 9, 2009)

a. MET: l.b.l, 3.a.1, 3.b.l, 6.a.l, 6.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 29

2. Risk Jurisdictions 2.1 ORANGE COUNTY 2.1.1 Orange County - Emergency Operations Center

a. MET: La. 1, 1.b 1, 1.c.l, 1.d. J, l.e.l, 2.b.2, 5.b.1 2.c.l, 3.c.I, 3.c.2, 3.d.l, 3.d.2, 5.a.3

h. AREAS REQUIRING CORRECTIVE ACTION: TWO ISSUE NO: 32-08-5.a.l-A-Ol CONDITION: During the preparatiton of the third EAS message, there was confusion between Orange County and the State EOC. The OCEOC listed specific instructions and areas to be evacuated and announced in the EAS.

These areas are mentioned in OC's Evacuation Plans. The State EOC was more general in the writing of the EAS. For example, instead of writing "Town of Cornwall East of Rt. 32 is to be evacuated" the State EOC wrote "Town of Cornwall is to be evacuat,ed. " This would have the effect of directing members of the of the public outside the 10-mile EPZ to evacuate.

The State mentioned there was an issue with their pre-scripted EAS messages.

The OCEOC advised the State EOC to review the county's Radiological Emergency Response Plans for spec:ific localities and area descriptions in the Orange County portion of the 10-mile EPZ. The discussions between the OCEOC and the State to correct the EAS message delayed its release and also delayed the sounding of the sirens, possibly putting members of the public at risk.

30

POSSIBLE CAUSE: The State did not review the locations and boundary limits for all localities within the lO-mile EPZ for Orange Country prior to drafting EAS messages. They may not have the updated and correct pre-scripted EAS messages.

REFERENCE:

NUREG-0654, E.5.6.7.

EFFECT: If the State's original EAS message had been broadcast, some of the public outside the 10 - mile EPZ would have been been incorrectly advised to evacuate and incorrectly advised to take KI (which they do not have).

This could have led to general confusion as to who should evacuate and who should stay behind. The delay of the sirens while the text of the EAS message was corrected could have put people in the EPZ at risk.

RECOMMENDATION: The NY State Emergency Management Agency should work with Orange County personnel to be sure that the EPZ area information is accurate, and that pre-scripted EAS messages are clear.

SCHEDULE OF CORRECTIVE ACTIONS: The corrective action for this issue will be demonstrated at the next federally evaluated, biennial exercise.

ISSUE NO: 32-08-5.a.l-A-02 CONDITION: The Joint Information Center's web page on New York Alert posted two Information Alerts for the general public at 1222 and 1243.

In each case the counties and the specific localities evacuated were listed, with areas to be evacuated shown in bold-face type. However, unlike the other three counties, the Orange County list was divided into two sections.

Some areas were listed in the bolded sc~ction under Orange County.

Other towns/villages where listed in plain text in a paragraph format within the text of the document.

Example - in bolded text:

Orange County:

Bear Mountain State Park West Point Highlands 31

Example in unbolded text/paragraph format:

"Orange County orders additional evacuation of these areas; Village of Harriman East of the NYS Thruway, Village of Woodbury East ofNYS Thruway ......""

If this had been an actual emergency, members of the public may not have seen the "additional areas" to be t:vacuated if they did not completely read, and understand the on-line buHetins.

POSSIBLE CAUSE: The JIC and NY Alert did not clearly list all areas to be evacuated in a single list.

REFERENCE:

NUREG-0654, E.5, 6, 7 EFFECT: If this had been an actual emergency, members of the public may not have seen the additional areas that were to be evacuated, but which were not presented in boldface type in the Information Alert message posted on NY Alert like the other areas indicated. This would have placed members of the public at risk if they did not see the complete areas to be evacuated because some members of the public who should have evacuated might have stayed within the lO-mile EPZ RECOMMENDATION: Ensure that all information regarding areas to be evacuated is presented clearly in printed and posted materials, including the JIC website.

SCHEDULE OF CORRECTIVE ACTIONS: The corrective action for this issue will be demonstrated at the next federally evaluated, biennial exercise.

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOl UNRESOl..VED:

.. VED: NONE 32

2.1.2 Orange County - Accident Assessment

a. MET: 2.a.1, 2.b.I, 3.a.I, 3.b,I, 4.a.2

b. AREAS REQUIRING CORRlCCTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.3. Orange County - Field Monitoring Team 1

a. MET: l.a.I, l.d.I, 3.a.l, 3.b.I" 4.a.l, 4.a.3

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.4 Orange County - Field Monitoring Team 2

a. MET: l.a.I, l.d.1, 3.a.1, 3.b.l, 4.a.1, 4.a.3

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.5 Orange County - (General Population Reception Center Middletown High School- September 10,2008)

a. MET: 3.a.l, 3.b.I, 6.a.I, 6.b.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.6. Orange County - (General Population Bus Company West Point Tours Highland Falls - Feb. 7, 2008)

a. MET: 3.a.I,3.b.1

b. AREAS REQUIRING: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. RIOR ISSUES - UNRESOLVED: NONE 33

2.1.7 Orange County - School Bus Company - (West Point Tours Highland Falls - February 7, 2008)

a. MET: 3.a.I,3.b.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.8 Orange County - School Interview (Fort Montgomery Elemlmtary School - January 23, 2008)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.9 Orange County - Congregate Care Center (Middletown High Sc::hool- September 23, 2008)

a. MET: 6.c.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.10 Orange County - Medical ServicesTransport (Mobile Life Support Services - May 28, 2009)

a. MET: 3.a.l, 3.b.l, 6.c1.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 34

2.1.11 Orange County - Medical Services Hospital (St Lukes Cornwall Hospital - May 28, 2009)

a. MET: 6.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: ONE ISSUE NO: 32-08-3.a.l-A**03 CONDITION: The procedure for St. Luke's Cornwall Hospital does not adequately address exposure control for emergency workers.

Radiology Policy and Procedure Number IP 1018 does not include procedures for using dosimetry, administrative reporting limits, or a decision chain for replacing emergency workers. During the event, workers were questioned regarding their dose limits. Workers reported that the dose limit was 5 R, with a reporting level of 1 R. If increasing levels of exposure were noted on the OROs, then the Radiological Safety Officer (RSO) would be consulted and would be responsible for replacing workers if necessary.

This information was covered in the training session, but is not included in the procedures. Additionally, since they used a 200 mR ORO, the ORO would have to be re-zeroed four times before reaching the administrative reporting level of 1 R.

POSSIBLE CAUSE: St. Luke's Cornwall Hospital Radiology Policy and Procedure Number IP 1018 does not provide guidance to continually monitor and control emergency worker exposure, and the dosimetry provided would be awkward to use as the dose level approached the administrative level of 1R because of its low reading value (200 mR).

REFERENCE:

NUREG-0654 K 3.a.,b.

EFFECT: Without a procedure to continually monitor and control emergency worker exposure, which includes setting administrative dose limits, a worker may potentially receive unwarranted radiation exposure that is potentially harmful to human health. Additionally, having to re-zero a 200 mR dosimeter 4 times before reaching the administrative reporting level of 1 mR would cause further delay and exposure.

35

RECOMMENDATION: The procedure needs revision to include guidance on use of dosimetry, administrative dose limits, and designate an individual who is responsibile for managing worker exposure control. Also, provision of higher-reading (0-20 R) self reading dosimeters in addition to the 200 mR's should be considered. Personnel should be trained on the revised procedure.

SCHEDULE OF CORRECTI'V"'E ACTIONS: The corrective action for this issue will be demonstrated at the next federally evaluated, biennial exercise.

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE (PRIORISSUES-UNRESOLVED:NONE 2.1.12 Orange County - Medical Services Hospital (St Lukes Cornwall Hospital- Oct. 17,2007)

a. MET: 3.a.l. 3.b.l, 3.d.]

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.13 Orange County - Medical Services Transport (Cornwall Volunteer Ambulance Corps. - Oct. 17,2007)

a. MET: 3.a.l, 3.b.l, 6.d.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 36

2.1.14 Orange County - (Emergency Worker Personnel Monitoring Center - Orange-Ulster Boces - Nov. 13,2008)

a. MET: 3.a.l, 3.b.l, 6.a..l, 6.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. PRIOR ISSUES - RESOLVED: NONE

e. PRIOR ISSUES - UNRESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.1.15 Orange County - Traffic Control Point

a. MET: 3.a.1, 3.b.l, 3.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 37

2.2 PUTNAM COUNTY 2.2.1 Putnam County - Warning Point

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

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.2.2 Putnam County - Emergency Operations Center

a. MET: La.l, l.c.l, Ld.l, Le.l, 2.b.2, 2.c.1 3.c.l, 3.c.2, 3.d.l, 3.d.2, S.a.l,S.a.3

b. AREAS REQUIRING CORRECTIVE ACTION: ONE ISSUE NO: 32-08-S.b.l-A-04 CONDITION: Several Emergency Alert System (EAS) Follow-On messages that had been approved for publication by the Putnam County leadership were not published in the NY -Alert system.

POSSIBLE CAUSE: The Putnam County public information supervisory statf apparently did not verify directly in the NY -Alert system and the EASlNews Release Log Book ifEAS Follow-On messages approved by the Putnam County leadership had in fact been published in the system and documented in the log. This was possibly because of insufficient and/or inadequate training from the New York State Emergency Management Office (NYSEMO) in the use of the NY-Alert system.

REFERENCE:

NUREG-0654, E.S and E.7.; Putnam County Radiological Emergency Response Plan, Putnam Public Information Procedure, August 1,2008.

EFFECT: Lack of updated emergency information for the public in the NY-Alert system.

38

RECOMMENDATION: Putnam County should coordinate with NYSEMO to provide additional training in the use of the NY-Alert system, and to provide additional training to its emergency management leadership and lIC Workroom staff regarding the county Public Information Procedure:. In particular, the training should address the need to verify directly in the NY -Alert system that messages that have been approved for distribution are in fact published. The training should also address the need to review the content of EAS follow-on messages to ensure consistency with the associated EAS message.

NYSEMO should coordinate with Putnam County and other users to review its NY-Alert system to identify opportunities to streamline the process of drafting, publishing, and archiving messages.

SCHEDULE OF CORRECTIVE ACTIONS: The corrective action for this issue will be demonstrated at the next federally evaluated, biennial exercise.

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOL VEn: TWO ISSUE NO: 75-06-S.a.3-A-02 ISSUE: The Putnam County Sheriffs Department EOC representative did not follow up on the time it took to complete backup route alerting that was performed (simulated) following a report of siren failures when the Emergency Classification Level was at Alert. The requirement for backup route alerting is that it be completed within 45 minutes from when a siren failure is detected by the ORO (per NUREG-0654, E.6, Appendix 3.B.2.c).

CORRECTIVE ACTION DEMONSTRATED: Putnam County currently uses a high speed telephone emergency notification system known as Code RED to provide ba(;k-up to the new siren system to alert and notify residents located within the Indian Point Energy Center (lPEC)

Emergency Planning Zone (EPZ). During the exercise Putnam County successfully demonstrated the ability to provide timely back-up alert and notification by delivering a prerecorded test message using its new Code RED system. For the purposes of the exercise, the Code RED system was demonstrated concurrently with the first siren activation.

39

ISSUE NO: 75-06-5.b.l-A-03 ISSUE: The Putnam County Public Information Officer (PIO)/loint Information Center (lIC) Work room did not receive operations information of significant public Ire Irelevance levance in a timely manner. As a result, in some cases, inaccurate information was presented during media briefings and, in other case:s, there were delays in making up-to-date information available to the media and the public. Because the lead PIO for the county was also the EOC Operations Officer, some public and media inquires that were successfully handled by the EOC Operations Officer did not get relayed to the EOC Emergency Information Coordinator and the PIO/HC Work room was not made aware of these inquiries.

CORRECTIVE ACTION DEMONSTRATED: Putnam County demonstrated effective and timely flow of critical information between the EOC operations staff and the HC Workroom. During the exercise, the Public Information Administrator located in the HC Work room maintained frequent communication via telephone with the Emergency Information Coordinator/Public Information lead located in the EOC. Additionally, the Publi(: Information Administrator periodically reviewed new information posted by EOC staff on the Putnam County EOC information management system (EOC Commander) and proactively engaged the Emergency Information Coordinator/Public Information lead regarding new and evolving activities to ensure that, as appropriate, the current status of Putnam County's actions could be promptly addressed in press releases and conveyed to the spokesperson, who participated in the Virtual lIC.

f. PRIOR ISSUES - UNru:SOLVED: NONE 2.2.3 Putnam County - Accident Assessment

a. MET: 2.a.I, 2.b.l, 3.a.1, J.b.1, 4.a.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - UNRESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 40

2.2.4 Putnam County - Field Monitoring Team Alpha

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

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: TWO ISSUE NO: 75-06-3.a.l-A-04 ISSUE: The Putnam County Field Monitoring Teams (FMTs) were directed, at 11 :35 a.m., to take KI in response to the declaration of a General Emergency at Indian Point. The FMTs were never informed that a radioactive release had occurred and were not directed to don protective clothing (to be simulated). This is in direct contradiction to the requirements in the Putnam County Radiological Emergency Response Plan, Section 3.4 (p. 4-41), which states, "team members will be directed to don protective clothing when the following three conditions are met: (I) A General Emergency has been declared, (2) there has been a release of radioactive material from the site and (3) the wind is blowing from the site toward Putnam County."

Since these conditions were met in the scenario, the direction to the FMTs to dress in Anti-Contamination clothing should have been given concurrent with the notice to ingest KI, but was omitted from the radio -

communicated notice.

CORRECTIVE ACTION DEMONSTRATED: Putnam County Field Monitoring Teams were informed that a radiological release had occured and were directed to don protective clothing (simulated) as required per the Putnam County Radiological Emergency Response Plan. Putnam County Field Monitoring Teams did successfully demonstrate this criterion, with no additional issues identified.

ISSUE NO: 75-06-4.a.3-A-05 ISSUE: Putnam County Field Team Alpha did not take radiation exposure rate readings at the 5 minute mark and at the completion of the air sampling. These additional exposure rate surveys are called for in Step 1.6 of the Airborne Survey Techniques method (Putnam County Radiological Emergency Response Plan, Procedure 4, Radiological Officer, p. 4-68).

41

CORRECTIVE ACTION DEMONSTRATED: This ARC A was successfully demonstrated during the 2008 exercise by Putnam County Field Teams. Putnam County Field Teams did take radiation exposure readings at the beginning, 5 minute mark and at the completion of the air sampling as required per the Putnam County Radiological Emergency Response Plan during the exercise.

f. PRIOR ISSUES - UNRESOLVED: NONE 2.2.5 Putnam County - Field Monitoring Team Bravo a.MET: 1.a.l, l.d.l, 3.a.l, 3.b.!, 4.a.l, 4.a.3 b.AREAS REQUIRING CORRECTIVE ACTION: NONE c.DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVE:D: NONE

f. PRIOR ISSUES -UNRESOl.J VED: NONE 2.2.6 Putnam County - School Reception Center (Kent Primary School - April 25, 2008)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED:: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES ~ UNRESOl.J VED: NONE 2.2.7 Putnam County - General Population Bus Company (Haldane Central School District - November 16,2008)

a. MET: 3.a.l, 3.b.l, 3.e.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOL VED: NONE

f. PRIOR ISSUES - UNRESOL VED: NONE 42

2.2.8 Putnam County School Interview M

(Haldane Central School District - November 16,2008)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.2.9 Putnam County School Bus Company M

(Haldane Central School District - November 13,2008)

a. MET: 3.a.1, 3.b.l, 3.c.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOL V~::D: NONE

r. PRIOR ISSUES - UNRI:SOLVED: NONE 2.2.10 Putnam County - School Interview (Noahs Ark Nursery School- November 13,2008)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOL RESOLV);:D:

V);:D: NONE

f. PRIOR ISSUES - UNRESOl, VED: NONE 2.2.11 Putnam County - School Interview (Putnam Valley Day Care - November 6, 2008)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 43

2.2.12 Putnam County - School Interview (St. Phillips Nursery School- November 8, 2008)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.2.13 Putnam County - Medical Services Transport (Carmel Volunteer Ambulance Company - May 16,2008)

a. MET: 3.a.l, 3.b.1, 6.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATE]): NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.2.14 Putnam County - Medical Services Hospital (Putnam Hospital Center - May 16,2008)

a. MET: 3.a.l, 6.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATEI>: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 44

2.2.15 Putnam County - Trafti(: Control Point

a. MET: 3.a.l, 3.b.1, 3.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: TWO ISSUE NO: 75-06**3.d.l-A-08 ISSUE: During the Indian Point Energy Center (IPEC) radiological emergency response exercise on November 14,2006, the Putnam County Emergency Management Agency provided two Putnam County Sheriff s Department management personnel for interviews to demonstrate the extent of play with regard to the ability to provide staffing at traffic and access control points (TCP/ACP). The intent of the extent of play interviews was to determine if personnel who normally would staff TCP/ACPs had adequate knowledge and training to fulfill these functions. The management personnel provided, who were both sergeants and playing as the Sheriffs Department represe:ntatives at the EOC, did not meet the intent of the extent of play.

CORRECTIVE ACTION DEMONSTRATED: The Putnam County Sheriffs Department furnished two line level officers for interview to demonstrate: this criterion. These officers were separate and apart from the management level officers representing the PCSD in the EOC. These were officers who would be assigned to TCPs in an actual event. They were interviewed separately and demonstrated a commendable knowledge of the mission asignment, all policies and procedures and were very familiar with operation of all issued equipment.

f. PRIOR ISSUES - UNRESOLVED: NONE 45

2.2.16 Putnam County- General Population Reception Center (Carmel High School - April 4, 2009)

a. MET: 3.a.l, 3.b.l, 6.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: TWO ISSUE NO: 32-08-6.a.l-A-05 CONDITION: At both male and female decontamination areas, although they appear in tht~ Rec,eption Center Schematics (Putnam County Radiological Response~ Plan Appendix V, Rev 8/08, page V-6), step-off pads were not utilized. At the male decontamination area, the post-decontamination survey was conducted in the middle of the room and not at a clear egress point. The evacuee was then allowed to walk out through a potentially contaminated area. Also in the male decontamination area the personnel monitors were not initially aware of the release criteria and (0.1 mR above background) and had to be prompted by the controller. At the female decontamination area, the bottoms of the evacuee s shoes were not checked and the Personnel Decontamination Specialists were admittedly not familiar with the procedure. In both areas, contamination controls must be improved to prevent the potential spread of contamination to non-contaminated areas of the facility.

POSSIBLE CAUSE: Because the reception center demonstration was conducted in conjunction with a mass casualty incident involving school children, more volunteers arrived to help at the school than were originally expected. While the falet that many volunteers showed up and were eager to help should b{~ viewed as positive, many of these volunteers had received little or no training.

REFERENCE:

NUREG - 0654 1.12; Putnam County Radiological Emergency Response Plan, Appendix V- Reception Center Schematics (Rev 8/08), pageV-6 EFFECT: The failure to properly monitor evacuees at egress points could result in tht~ reception center becoming contaminated.

SCHEDULE OF CORRECTIVE ACTIONS: The corrective action for this issue will be demonstrated at the next federally evaluated biennial exercise.

46

ISSUE NO: 32-08-6.a.l-A-06 CONDITION: At the personnel monitoring point, after an alarm was received on the portal monitor, the Personnel Monitor proceeded to frisk the evacuee. This unnecessary step took several minutes to complete and is contrary to the Putnam County Radiological Response Plan, Procedure 3, step 4.5.7,which directs the Monitor, in the event of an alarm to, "note the area of the alarm indication and to direct the evacuee to step back and proceed to the decontamination area."

POSSIBLE CAUSE: The most likely cause is unfamiliarity with the content of the procedure.

REFERENCE:

NUREG - 06541.12; Putnam County Radiological EmergencyResponse Plan, Procedure 3, step 4.5.7 (Rev 7/08).

EFFECT: When contamination is detected on an individual, it should be removed as soon as possible to maintain exposure as low as possible.

This is true for not only emergency workers, but also the general public.

The unnecessary frisking of evacuees could also lead to long lines, long wait times and negatively impact the productivity rate for this facility.

RECOMMENDATION: Provide additional training on the content of Procedure 3 for Personnel Monitors.

SCHEDULE OF CORRECTIVE ACTIONS: The corrective action for this issue will be demonstrated at the next federally evaluated, biennial exercIse.

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 47

2.3 Rockland County 2.3.1 Rockland County - Warning Point

a. MET: l.a.l

h. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - ru::SOL VED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.2 Rockland County - Emergency Operations Center

a. MET: 1.a.l, I.c.l, l.d.L l.e.I, 2.b.2, 2.c.l, 5.b.1 3.c.I, 3.c.2, 3.d.l 3.d.2, 5.a.l,5.a.3

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRA DEMONSTRATEn: TEn: NONE

e. PRIOR ISSUES - RESOI~ VED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.3 Rockland County - Accident Assessment

a. MET: 2.a.l, 2.b.I, 3.a.l, 3.b.l, 4.a.2

h. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.4 Rockland County - Field Monitoring Team 1

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

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 48

2.3.5 Rock1and County - Field Monitoring Team 2

a. MET: La. I , I.d.l, 3.a.l, 3.b.l, 4.a.l, 4.a.3

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.6 Rockland County - General Population Reception Center (Pearl River High School - June 12, 2008)

a. MET: I.e.l, 3.b.1, 6.a.1

b. AREAS REQUIRING CORRECTIVE ACTION: TWO ISSUE NO: 32-08-I.e.l-A**07 CONDITION: The Pearl River (PR) Personnel Monitoring Center (PMC) mission included issuance of KI to general public evacuees, at their request, upon their arrival at the PMC. As part of the PMC setting-up process, a large cardboard box, containing an estimated 2,000 packets of KI was taken to the two-person team assigned to handle KI issues to the gent:ral public. Some, if not all, packets had passed an expiration date of over one year.

Each KI packet consisted of 14 - 130 mg IOSA T tablets. Examination of the labels of approximatdy 50 packets revealed that the expiration date of each (3/20/07) had passed. The PR Fire Chief (PMC Director) and the KI issue team stated that there was no other supply of KI at the PMC and that they were not aware of any letter extending the use of the expired KI. The observer from RC added that adequate supplies of new KI were available at the County, but the delivery of them to the PR PMC was in advertently overlooked in preparing for this evaluation. Both the Rockland County observer and the State Controller concurred that no letter extending the shelf-life ofthe expired KI had been promulgated.

49

POSSIBLE CAUSE: The apparent cause ofthe condition described above was the failure to distribute cum~nt KI stocks from the RC Emergency Management Office to the PR PMC and to dispose of the expired stocks of KI.

REFERENCE:

NUREG-0654 1.1 O.e.

EFFECT: Issuing KI beyond its expiration date. unless the expiration date is extended and justified in writing by competent authority, could result in the user receiving reduc:ed, no, andlor adverse benefit from the properties of the expired KI.

CORRECTIVE ACTION DEMONSTRATED: There were stocks of KI with a proper date of 2120 14 at the Pearl River Personnel Monitoring Center; however, the old stock had not yet been removed. Rockland County Emergency Management Office has removed the expired KI.

This issue is resolved.

ISSUE NO: 32-08-3.a.l-A-08 CONDITION: It was observed that the dosimetry issuance for all the emergency workers (EW s) was not documented on a single record/log.

The name and Self-Reading Dosimeters/Permanent Record Dosimetry (SRD/PRD) serial numbers were documented on the Radiation Exposure Record (Individual) card by each EW. This card was issued with the dosimetry and was taken by the EW to document their periodic SRD readings. At the end of the exercise, the Radiation Exposure Record (Individual) cards were turned in by all the EWs along with the dosimetry. By interview it was determined that the only documentation at the PMC would be the Radiation Exposure Record (Individual) cards.

EFFECT: Without a combined (master list) record of what dosimetry was issued to each EW at the dosimetry issue point the Radiation Exposure Record (Individual) card becomes essential. Problems of lost cards or improperly documented cards could lead to not knowing which EW had what dosimetry, and therefore not know their exposure.

50

CORRECTIVE ACTION D]~MONSTRATED: The Rockland County Office of Emergency Management has created an Emergency Worker Dosimetry Issuance Log. This log is part of DOH-2 attachment 8 and will be part of the 2009 plan changes.This issue is resolved.

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.7 Rockland County - General Population Bus Company (Clarkstown Central School District - November 4, 2008)

a. MET: 3.a.l, 3.b.I, 3.c.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.8 Rockland County - General Population Bus Company (East Ramapo Central School District - November 4, 2008)

a. MET: 3.a.l, 3.b.L 3.c.]

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.9 Rockland County - School Bus Company (Clarkstown Central School District - November 4, 2008)

a. MET: 3.a.l, 3.b.I., 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 51

2.3.10 Rockland County - School Bus Company (East Ramapo Central School District - November 4, 2008)

a. MET: 3.a.l, 3.b.l, 3.c.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.11 Rockland County - Medical Services Transport (Spring Hill Ambulance Corps - May 20, 2009)

a. MET: 3.a.l, 6.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.12 Rockland County - Medical Services Hospital (Good Samaritan Hospital - May 20, 2008)

a. MET: 3.a.I,6.d.I

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES -RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.3.13 Rockland County - Emergency Worker Personnel Monitoring Center (Rockland County Sewer District September 25, 2008)

a. MET: 3.b. L 6.a.l. 6.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: 3.a.I.

52

ISSUE NO: 75-06-3.a.l-A-09 ISSUE: The South" Orangetown Ambulance Emergency Medical Technicians (EMT) were issued a high range 0 to 200 R direct reading dosimeter but were not issued a low range dosimeter.

REASON UNRESOLVED: South Orangetown Ambulance EMTs were not demonstrated (or evaluated) during this exercise. This AReA will be reevaluated in 2010 during a Staff Assistance Visit.

2.3.14 Rockland County - Traffic Control Point

a. MET: 3.a.1, 3.b.!, 3.d.!

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 53

2.4 WESTCHESTER COUNTY 2.4.1 Westchester County - Warning Point

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

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.2 Westchester County - Emergency Operations Center

a. MET: 1.a.I, I.c.I, I.d.I, I.e.1, 2.b.2, 2.c.!,

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

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.3 White Plains Control Cell

a. MET: 5.b.1

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.4 Westchester County - Accident Assessment

a. MET: 2.a.l, 2.b.I, 3.a.l, 3.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: ONE 54

ISSUE NO: 32-08-4.a.2-A-09 CONDITION: In order to characterize the plume, both exposure rate data and radioiodine concentration measurements are needed.

The licensee uses one of two default noble gas to iodine ratios for*

two types of release scenarios. For a Loss of Coolant Accident the assumed noble gas to iodine ratio is 10000 and for a steam generator accident the ratio is 100. The field monitoring data is one method verifying the validity of th*ese assumptions. The licensee failed to provide any radioiodine concentration data to the offsite jurisdictions.

POSSIBLE CAUSE: Dependency on the default noble gas to iodine ratios without any verification of the accuracy of the value.

REFERENCE:

NUREG-0654 1.10; WCERP Procedure 3-1 Attachment 3, Step 1 EFFECT: A relatively minor error in the 10000 to 1 ratio which was assumed in this exercise, has the potential to impact the accuracy of the thyroid dose projection and therefore the appropriate distance that would require evacuation and does not allow the otfsite jurisdiction to characterize the release.

RECOMMENDATION: Retrain all staff both onsite and offsite to impress upon them the importance of getting radioiodine data to verify or modify the assumed ratios in the release. Add steps in the procedures to assure that responders follow through with verifying the assumed ratios.

SCHEDULE OF CORRECTIVE ACTIONS: The corrective action for this issue will be demonstrated at the next federally evaluated biennial exercise.

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 55

2.4.5 Westchester County** Field Monitoring Team HD-l

a. MET: l.a.I, l.d.I, 3.a.l, 3.b.I, 4.a.I, 4.a.3

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RE:SOL VED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.6 Westchester County .. Field MonitoringTeam HD-2

a. MET: l.a.I, l.d.I, 3.a.I, 3.b.I, 4.a.l, 4.a.3

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES .. UNRESOLVED: NONE 2.4.7 Westchester County- Call Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES* RESOLVED: NONE

f. PRIOR ISSUES .. UNRESOLVED: NONE 2.4.8 Westchester County** Traffic Control Point

a. MET: 3.a.l, 3.b.I, 3.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES ,. RESOLVED: NONE

f. PRIOR ISSUES .. UNRESOLVED: NONE 56

2.4.9 Westchester County - (General Population Bus Company Chappaqua Bus October 22, 2009)

a. MET: 3.a.l, 3.b.l, 3.d.l

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.4.10 Westchester County - (School Bus Company Chappaqua Bus October 22, 2009)

a. MET: 3.a.l, 3.b.l, 3.d.l

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRI~SOL VED: NONE 2.4.11 Westchester County - (School Bus Company Briarcliff Manor School District May 2, 2009)

a. MET: 3.a.1, 3.bJ, 3.d.l

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.4.12 Westchester County - (Lakeland School Bus Company Interview August 4, 2009)

a. MET: 3.a.l, 3.b.I, 3.d.!

b. DEFICIENCY: NONE

c. AREAS REQUIRI~G CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 57

2.4.13 Westchester County - (Todd Elementary School Interview Aug. 28, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.14 Westchester County - (Briarcliff High School Interview Aug. 25, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE LPRIORISSUES-UNRESOLVED:NONE 2.4.15 Westchester County - (Briarcliff Middle School Interview Aug. 25, 20(9)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRA.TED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.16 Westchester County - Anne M. Dorner Middle School Interview December 8, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 58

2.4.17 Westchester - (Roosevelt Education Center School Interview December 8l . 2009)

a. MET: 3.a.l, 3.b.!, 3.d.l

h. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.18 Westchester County - (Yorktown Heights Center School Interview December 21,2009)

a. MET: 3.c.2

h. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.19 Westchester County - (Brookside Elementary School Interview December 8, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.20 Westchester County - (Carrie E. Tompkins Elementary School Interview December 21, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRE:SOL VED: NONE 59

2.4.21 Westchester County - (Claremont Elementary School Interview December 21, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.22 Westchester County - (Croton Harmon High School Interview December 21, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.23 Westchester County - (Fox Meadow School Interview December 21, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.24 Westchester County - (Hillcrest Elementary School Interview January 7,2010)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNru:SOLVED: NONE 60

2.4.25 Westchester County - (Oakside Elementary School Interview January 7, 2010)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.26 Westchester County - (Ossining High School Interview December 8, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.27 Westchester County - (Park Early Childhood Center School Interview December 8, 2009)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.28 Westchester County - (Peekskill High School Interview January 7, 2010)

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRI~SOLVED: NONE 61

2.4.29 Westchester County - (Peekskill Middle School Interview January 7, 2010)

a. MET: 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.4.30 Westchester County - (Pierre Van Cortland Middle School Interview December 21,2009)

a. MET: 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - lUNRESOL VED: NONE 2.4.31 Westchester County - (Pines Bridge School Interview December 21, 2009)

a. MET: 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARC ARCAS AS - UNRESOLVED: NONE 2.4.32 Westchester County - (Seven Bridges Middle School Interview December 14, 2009)

a. MET: 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 62

2.4.33 Westchester County - (West Orchard Elementary School Interview December 14, 2009)

a. MET: 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.4.34 Westchester County - (Woodside Elementary School Interview January 7, 2010)

a. MET: 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS .. UNRESOLVED: NONE 2.4.35 Westchester County - (Walden School Interview December 21, 2009)

a. MET: 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS* RESOLVED: NONE

f. PRIORARCAS - UNRESOLVED: NONE 2.4.36 Westchester County .. (Medical Service Hospital Westchester Center November 5, 2009)

a. MET 3.a.l, 3.b.l, 6.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 63

2.4.37 Westchester County - (Medical Services Transport Trans Care Ambulance Service November 5, 2009)

a. MET: 3.b. L 6.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRA DEMONSTRATEn: TEn: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNru:SOL UNru:SOLVED: VED: ONE ISSUE NO: 75-06-3al-A-12 ISSUE: The ambulance crew (Transcare Ambulance Service) who responded to the Emergency Worker Personnel Monitoring Center (PMC) to transport the injured emergency worker did not have any dosimetry. While the PMC was located outside the emergency planning zone, handling and transporting a contaminated emergency worker requires the use of dosimetry by the ambulance crew in accordance with Wt:stchester County Procedure IP-3.3, Section 3.5.

REASON UNRESOL YEn: This issue was not corrected because, once again, dosimeters were not issued to Transcare EMS.

SCHEDULE OF CORRECTIVE ACTIONS: The corrective action for this issue will be demonstrated at the next federally evaluatud biennial exercise.

2.4.38 Westchester County - (Hendrick Hudson School Bus Company Interview Aug. 25, 2009)

a. MET: 3.a.l ;3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 64

2.4.39 Westchester County - School Interviews Hendrick Hudson School District - (Frank G. Lindsey Elementary Schoo),

Blue Mountain Middle School, Buchanan Verplank Elementary School, Furnace Woods Elementary School, Hendrick Hudson High School, Sep. 16,2009)

a. MET: 3,c,2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.40 Westchester County - School Interviews Lakeland School District Interviews - (Benjamin Franklin Elementary School, Thomas Jefferson Elementary Schoo), Lake Alternative High School, Van Cortland Elementary School, Lincoln - Titus Elementary School, Lakeland High School, Walter Panas High School, Cooper Beech Middle School,

a. MET: 3.c.2

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 2.4.41 Westchester County** (Croton Bus Company Interview Oct. 21,2009)

a. MET: 3,a.l;3.b.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

c. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 65

3.0 Support Jurisdictions 3.1 Bergen County Emergency Operations Center

a. MET: l.a.!, I.c.l, l.d.l, I.!!. 1, 3.c.2, 3.d.l

b. AREAS REQUIRING CORRECTIVE ACTION: NONE

c. DEFICIENCY: NONE

d. NOT DEMONSTRATED: NONE

c. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 66

APPENDIX 1 ACRONYMS AND ABBREVIATIONS AA Accident Assessment ACP Access Control Point AlS Advanced Life Support ARCA Area Requiring Corrective Action

!ATl Assessment Team leader J?C Bergen County BCPD Berqen County Police Department

~lS Basic Life Support BOCES Board of Cooperative Education SI::I VI~~~

CC Call Center CCC Congregate Care Center CCSD Clarkstown Central School District CD Compact Disk CDE Committed Dose Equivalent CEMD County Emergency Management Director CENS Community Emerqency Notification System CEOM County Emergencv Operations Manaqer CERT Community Emergencv Response Team g9VAC Cornwall Volunteer Ambulance Corps.

CRO County RadioloQical Officer CVAC Carmel Volunteer Ambulance Corps.

DAl Dose Assessment lead IDAR Dose Assessment Room DEP Department of Environmental n. m::vLII.

DOH Department of Health DOT DeQartment of Trans~ortation ORO Direct Reading Dosimeter EAl Emergency Action level EAS Emergency Alert System ECl Emergency Classification level ED Emergency Director EM Emergency Manager EMT Emergency Medical Technician

• ENS Emergency Notification System

~9C Emergency Operations Center EOF Emergency Operations Facility EPA Environmental Protection Agency EPZ Emergency Planning Zone I

~R Emergency Room I

ERCSD East Ramapo Central School District ERO Emergency ResQonse Organization ERPA Emergency Response Plannina Area cE:.'fV Emeraencv Worker 67

EWDC Emergency Worker Decontamination Genter EWPMC Emergency Worker Personnel Monitoring Center

£.GC Federal Communications Commission FMES Fort MontQomery Elementary School FMT Field Monitorinq Team FTC Field Team Coordinator FTS Field Team Suoervisor GE General Emergencv SM Geiger Muller GPBC General Population Bus Company GPRC General Population Reception Center

~~SH Good Samaritan Hospital JjCSD Haldane Central School District HF Highland Falls HI Hearinq Impaired ICS Incident Command System IPEC Indian Point Enerqv Center JIC Joint Information Center JNC Joint News Center KI Potassium Iodide KPS Kent Primary School MHS Middletown HiQh School MMC Media ManaQement Coordinator MSH Medical Services Hospital MST Medical Services Transport NANS Noah's Ark Nursery School NJSP New Jersev State Police NRC Nuclear Requlatory Commission  !

NYS New York State

~.YSEMO New York State Emeroency Manaoement Office NYSP New York State Police lac Oranqe County aCE Oranqe County Executive OCEOC OranQe County Emerqency Operations Center lOLL Offsite Lead Liaison OUB Orange-Ulster BOCES PAD Protective Action Decision PC Putnam County PCC Public Call Center PCSD Putnam County Sheriffs Department PHC Putnam Hospital Center PI Public Inquiry PIO Public Information Officer PM Portal Monitor

~]\I1C Personal Monitorinq Center PR Pearl River PRD Permanent Record Dosimeter PRHS Pearl River Hiah School PRVFD Pearl River Volunteer Fire District 68

PVDC Putnam Valley Day Care RAC Regional Assistance Committee RACES Radio Amateur Civil EmerQency Service

$9 Rockland County ReEOC Rockland County Emergency Operations Center REA Radiological Emergency Area

$!=CS Radiological Emergency Communication System REP Radiological Emergency Preparedness REPP Radiological Emergency Preparedness Plan RERP Radiological Emergency Response Plan RSO Radiological Safety Officer SAE r--

r---

Site Area EmerQency SSC School Bus Company

~!=MO State EmerQency ManaQement Office SEOC State EmerQency Operations Center SFC Special Facilities Coordinator SHAC Spring Hill Ambulance Corps_

SI School Interview

~~CH St Luke's Cornwall Hospital SO Safety Officer

~NS St Philips Nursery School SRD Self Readinq Dosimeters SWP State Warning Point TeAS TransCare Ambulance Service TCP Traffic Control Points TEDE Total Effective Dose Equivalent TSR Townline Sub-Residency VHF VelyHigh Frequency VOIP Voice Over Internet Protocol WC Westchester County WCEOC Westchester County Emergency Operations Center WCREP Westchester County Radiological Emerqency Plan WMC Westchester Medical Center WP Warning Point WPCC White Plains Control Cell WPT West Point Tours WWP Westchester Warning Point 69

APPENDIX 2 EXERCISE EVALUATORS AND TEAM LEADERS 70

DATE: December 2008 SITE: Indian Point Energy Center, NY ICF FEMA Mabel Santiago FEMA

• William Cullen FEMA 71

Putnam County - General Population Bus Company - Haldane Central *Korky Dulgerian FEMA School District Putnam County - School Bus Company - Haldane Central S(:hool *Korky Dulgerian FEMA District Putnam County - School Interview - Haldane Central School District *William Cullen FEMA Putnam County - School Interview - Noahs Ark Nursery School Mabel Santiago FEMA Putnam County - School Interview - Putnam Valley Day Care Mabel Santiago FEMA Putnam County - School Interview - St Phillips Nursery School Chris Cammarata FEMA Putnam County - Medical Services Transport - Carmel Volunteer Gary Goldberg rCF Company Ambulance Comoany Hospital - Putnam HosQital Center Putnam County - Medical Services Hosoital Deborah Blunt rCF Putnam County Traffic Control Point Mark Dalton ICF Rockland County - Warning Point *Korky Dulgerian FEMA Rockland County Emergency Operations Center Korky Dulgerian FEMA Dave Petta ICF Kim Wood ICF Rockland County Accident Assessment Daryl Thome ICF Rockland County - Field Monitoring Team I Mke Hammond ICF Rockland County - Field Monitoring Team 2 Michael Leal FDA Rockland County General Population Reception Center - Pearl River Alan Bevan High School Dave Petta rCF Ro,kl.nd County G,n,,,1 Popul.tion Bu, Comp"'y - CI","',o~ilHam Cull,n FEMA

..Q~ntral School District Rockland County - General Population Bus Company - East Ram orky Dulgerian FEMA Central School District Rockland County - School Bus Company - Clarkstown Central School *William Cullen FEMA IDistrict Rockland County - School Bus Company - East Ramapo Central *Korky Dulgerian FEMA I School District Rockland County - Medical Services Transport - Spring Hill Bart Ray ICF A.mbulance Corps Rockland County - Medical Services Hospital- Good Samaritan Ronald Biernacki rCF Hospital

~9ckland County Traffic Control Point Kim Wood ICF Rockland County - Emergency Worker Personnel Monitoring Cemer Center Ronald Biernacki ICF 1---

Dave Petta ICF Westchester County - Warning Point John Flynn ICF White Plains Control Cell Richard McPeak ICF West{:hester County Emergency Operations Center Michael Burriss ICF

• WilJiam Cullen FEMA Sonia Eischen ICF Terry Sheehan DOT Westchester County Accident Assessment Joe Keller ICF Westchester County - Field Monitoring Team HD-l Jeanette Eng EPA Westchester County - Field Monitoring Team HD-2 Ronald Biernacki ICF Westchester County Call Center Rosemary Samsel ICF Westchester County - General Population Bus Company - Chappaqua *Korky Dulgerian FEMA Bus IWestchester County - School Bus Company - Briarcliff Manor School Mabel Santiago FEMA District Westchester County - School Bus Company - Chappaqua Bus *Korkv Dulgerian FEMA 72

Westchester County - School Bus Company - Hendrick Hudson Bus Chris Cammarata FEMA Westchester County - School Bus Company - Lakeland Bus Mabel Santiago FEMA Westchester County - School Interview - Anne M Domer Middle *Patricia Mason FEMA Schoo)

Westchester County - School Interview - Roosevent Education Center

• Patricia Mason FEMA Westchester County - School Interview - Yorktown Heights Center *Korky Dulgerian FEMA Westchester County - School Interview - Briarcliff High School *Chris Cammarata FEMA Westchester County - School Interview - Briarcliff Middle School *Chris Cammarata FEMA Westchester County - School Interview - Brookside Elementary *Patricia Mason FEMA School Ossining Westchester County - School Interview - Carrie E Tompkins *Korky Dulgerian FEl'vlA Elementary School Westchester County - School Interview - Claremont Elementary *Patricia Mason FEMA School Westchester County - School Interview - Croton Harmon High School *Korky Dulgerian FEMA Westchester County - School Interview - Fox Meadow School *Korky Dulgerian FEMA

.F.estchester County - School Interview - Hillcrest Elementarv School *Patricia Mason FEMA Westchester County -School Interview - Oakside Elementary School *Patricia Mason FEMA Westchester County - School Interview - Ossining High School *Patricia Mason FEMA

.F.estchester County - School Interview - Park Early Childhood Center *Patricia Mason FEMA Westchester County - School Interview - Peekskill High School *Patricia Mason FEMA Westchester County - School Interview - Peekskill Middle School *Patricia Mason FEMA Westchester County - School Interview - Pierre Van Cortlandt Middle *Korky Dulgerian FEMA School Westchester County - School Interview - Pines Bridge School *Korky Dulgerian FEMA Westchester County - School Interview - Seven Bridges Middle *Korky Dulgerian FEMA School I Westchester County - School Interview - Todd Elementary School *Chris Cammarata FEMA Westchester Co un!}: - School Interview - Walden School *Korkv Dulgerian FEMA Westchester County - School Interview - West Orchard Elementary *Korky Dulgerian FEMA School .

Westchester County - School Interview - Woodside Elementary

• Patricia Mason FEMA School Westchester County - School Interview - Yorktown Central High *Korky Dulgerian FEMA School West(:hester County - Medical Services Transport - Trans Care Ronald Biernacki ICF Ambulance Service West(:hester County - Medical Services Hospital- Westchester Korky Dulgerian FEMA

\1edical Center West,:hester Coun!}' Traffic Control Point Terrv Sheehan DOT

~

nty Emergency Operations Center "'Chris Cammarata FEMA Glenn Kinnear ICF H 'I'~;;:f" :.'<'~~~~'\\i~

• TeamL  :~~/:, .};~ \  ;,.,~;4>?~;

• 73

Appendix 3 Putnam Orange Westchester FINAL OFFSITE EXTENT-OF-PLAY FOR THE DECEMBER 3, 2008 INDIAN POINT ENERGY CENTER - UNIT 3 FULL-PARTICIPATION EXERCISE 74

TABLE OF CONTENTS Table ot Contents ............................................................................................................. i Extent-ot-Play Ground Rules .......................................................................................... 1 Extent-Ot-Play ................................................................................................................. 3 EXTENT-OF-PLAY GROUND RULES 75

EXTENT-OF-PLAY GROUND RULES

• REAL LIFE EMERGENCIES TAKE PRIORITY OVER EXERCISE PLAY.

• The Scenario Development Team will develop the "Exercise" free play messages.

The State Controller will inject these messages for action as agreed upon.

• "Optional" messages will be developed and inserted to facilitate EOC participation.

• The Scenario Development Team will develop "Exercise" free play messages for Public Inquiry conducted at the New York State Tax and Finance Call Center in Albany, NY and at the Westchester County Alternate Emergency Operations Center/MOB in White Plains, NY. Public Inquiry messages will be injected to the two call centers by a control cell(s).

• The Scenario Development Team will develop "Exercise" free play messages for Media Inquiry. Media Inquiry messages will be injected to the State and county EOCs by a control cell(s).

• The State Controller will provide radiological data for any radiological field activities (e.g., Field Teams, Emergency Worker Personnel Monitoring Centers, Reception Centers, etc.).

• According to REP Program Strategic Review Initiative 1.5, "During tabletop exercises, drills and other demonstrations conducted out-ot-sequence from an integrated exercise, if FEMA and the offsite response organizations (ORO) agree, the FEMA Evaluator may have the partiCipants re-demonstrate an activity that is determined to be not satisfactorily demonstrated. Immediate correction of issues in an integrated exercise is authorized only if it would not be disruptive and interrupt the flow of the exercise and affect other Evaluation Areas." This initiative is not applicable to EOC/JIC/EOF demonstrations during the December 3, 2008 exercise.

• The following criteria, which deal with ingestion pathway, relocation, re-entry and return, post-plume phase and lab operations, will not be demonstrated:

2.d.1 2.e.1 3.e.1 3.e.2 3.f.1 4.b.1 4.c.1

• Additionally, criterion 5.a.2 for the activation of the prompt alert and notification system will not be demonstrated.

76

EXTENT OF PLAY 77

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.a - Mobilization Criterion 1.a.1: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654, A.4; D.3, 4; E.1, 2; H.4)

WARNING POINTS Extent-ot-Play Agreement:

• The latest quarterly revised call lists will be provided at the Federal/State evaluators briefing session the day before the exercise, if requested by FEMA. The lists will contain the business telephone numbers only.

EOCs Extent-ot-Play Agreement:

• State liaisons will be pre-positioned in the area and will arrive at County EOCs 30 minutes after receiving notification to activate via pager or other means.

• Licensee Technical Liaisons will be pre-positioned in the area and will arrive at the State and county EOCs 30 minutes after receiving notification to activate via pager or other means.

Extent-ot-Play Agreement:

• State liaisons will be pre-positioned in the area and will arrive at the EOF 30 minutes after receiving notification to activate via pager or other means.

78

JIC Extent-ot-Play Agreement:

• State ~IIC Staff will be pre-positioned in the area and will arrive at the JIC no sooner than 30 minutes after receiving notification to activate via pager or other means.

79

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub*element 1.b - Facilities Criterion 1.b.1: Facilities are sufficient to support the emergency response.

(NUREG-0654, H.3)

Extent*of*Play Agreement:

• This criterion will be evaluated for the following facilities only:

o Orange County EOC, Wells Farrn Rd., Goshen, NY o NYS EOC, Bldg. 22, Albany, NY 80

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.c - Direction and Control 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, A.1.d; A.2.a., b.)

Extent-at-Play Agreement:

• The State Controller will inject "Exercise" messages for action as agreed upon.

81

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.d - Communications Equipment Criterion 1.d.1: 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, F.1! 2).

Extent-ot-Play Agreement:

• The use of RACES as a back up to commercial telephones or radios will be demonstrated between the State and four Risk County EOCs only.

• An alternate to the Executive Hotline may be used to coordinate protective action decisions (PADs) among the Risk Counties and State if needed.

82

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.e - Equipment and Supplies to Support Operations Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI),

and other supplies are sufficient to support emergency operations. (NUREG-(NUREG 0654, H.7, 10; J.10.a, b, e, J.11; K.3.a)

Extent-of.Play Agreement:

• Maps and displays will vary with each facility and may include hard copy printouts and listings and electronic displays.

• The instruments that are used for field monitoring are the RO-20 or RO-2A (Gamma and Beta-mR/hr or R/hr) or equivalent and RM-14 (Gamma and Beta- Beta CPM) or equivalent.

• Field team equipment is calibrated by IPEC's RP Department. An internallPEC requirement provides for calibration of this equipment every six months.

Therefore, the calibration sticker for this equipment shows a "calibration due date" which reflects the six month calibration schedule. The instruments are considered calibrated as long as the current date is within one year of the calibration date.

• No equipment (e.g., barriers, traffic cones, signs, etc.) will be deployed to the field with the exception of Reception Centers and EWPMCs.

83

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.a - Emergency Worker Exposure Control Criterion 2.a.1: OROs use a decision-makilng process, considering relevant factors and appropriate coordination, to insure 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-D654, J.1 D.e, f; KA)

Extent-ot-Play Agreement:

• All activities will be based on the OROs' plans and procedures as they would in an actual emergency.

84

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.b. Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions. (NUREG-0654, 1.8, 10 and Supplement 3).

Extent-ot-Play Agreement:

• In the event of a simulated radiological release, the licensee field teams will obtain plume centerline data.

85

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.b. Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PADs) for the general public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654, J,g, 10.f, m).

Extent-of-Play Agreement:

• All activities will be based on the OROs' plans and procedures as they would in an actual emergency.

86

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Special Populations Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups. (NUREG-0654, J.9, J.10.d, e)

Extent-of-Play Agreement:

• All activities will be based on the OROs' plans and procedures as they would in an actual emergency.

87

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation ot Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and 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. (NUREG-0654, K.3.a, b)

Extent-ot-Plav Agreement:

• All activities will be based on the OROs' plans and procedures as they would in an actual emergency.

88

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.b - Implementation of KI Decision Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals is maintained.

(NUREG-0654, J.10. e)

Extent-of.Play Agreement:

• All activities will be based on the OROs' plans and procedures as they would in an actual emergency.

• The post distribution of KI to the public will also be discussed at reception centers when demonstrated as per the Offsite Extent-at-Play Activities Schedule.

89

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub..element 3.c - Implementation of Protective Actions for Special Populations Criterion 3.c.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions.

(NUREG-0654, J.10.c, d, g).

EOC ACTIVITIES:

TRANSPORTATION DEPENDENT POPULATION Extent-of-Play Agreement:

• During the December 3,2008 exercise, there will be initial contact with the transportation providers (telephone call) by the Transportation Coordinator.

Initial contacts will be actual and some follow-up contacts may be simulated. All calls will be logged at each EOC.

NOTIFICATION OF HEARING IMPAIRED Extent-of-Play Agreement:

Jurisdiction Extent-ot-Play In Out of Out of Comments Sequence Sequence; Sequence; With Day of NOT Day of Exercise Exercise Exercise Westchester The hearing-impaired County list will be available for review at the county EOC. This list will be reviewed but not copied or retained by the Federal evaluator. (X)

The procedure to contact hearing-impaired individuals will be discussed with the federal evaluator at the EOC.

90

Jurisdiction I xten t-ot-Play In Out of Out of Comments Sequence Sequence; Sequence; With Day of NOT Day of Exercise Exercise Exercise Rockland The hearing-impaired County list will be available for review at the county EOC. This list will be reviewed but not copied or retained by the Federal evaluator. (X)

The procedure to contact hearing-impaired individuals will be discussed with the federal evaluator at the EOC.

Orange The hearing-impaired County list will be available for review at the county EOC. This list will be reviewed but not copied or retained by the Federal evaluator. (X)

The procedure to contact hearing-impaired individuals will be discussed with the federal evaluator at the EOC.

Putnam The hearing-impaired County list will be available for review at the county EOC. This list will be reviewed but not copied or retained by the Federal evaluator. (X) i The procedure to contact hearing-impaired individuals will be discussed with the federal evaluator at the EOC. I 91

NON-INSTITUTIONALIZED MOBILITY IMPAIRED INDIVIDUALS Extent-of-Play Agreement:

'JUrisdiction Extent-of-Play In Out of Out of Comments Sequence Sequence; Sequence; With Day of NOT Day of Exercise Exercise Exercise Westchester The list of non-County institutionalized mobility-impaired will be available for review at the county EOC. This list will be reviewed but not copied or retained by the Federal evaluator.

(X)

The procedure to contact non-institutionalized mobility-impaired individuals will be discussed with the federal evaluator at the EOC.

Rockland The list of non-County institutionalized mobility-impaired will be available for review at the county EOC. This list will be reviewed but not copied or retained by the Federal evaluator.

(X)

The procedure to contact non-institutional ized mobility-impaired individuals will be discussed with the federal evaluator at the EOC.

92

Jurisdiction I xten t-of-Play In Out of Out of Gomments Sequence Sequence; Sequence; With Oayof NOT Day of Exercise Exercise Exercise Orange The list of non-County institutionalized mobility-impaired will be available for review at the county EOG. This list will be reviewed but not copied or retained by the Federal evaluator.

(X)

The procedure to contact non-institutionalized mobility-impaired individuals will be discussed with the federal evaluator at

. the EOG.

Putnam The list of non-County institutionalized mobility-impaired will be available for review at the county EOG. This list will be reviewed but not copied or retained by the Federal evaluator.

(X)

The procedure to contact non-institutionalized mobility-impaired individuals will be discussed with the federal evaluator at the EOG. I 93

SPECIAL FACILITIES Extent-of-Play Agreement:

• During the exercise, there will be initial contact with the special facilities (telephone call). Initial contacts will be actual and some follow-up contacts may be simulated. All calls will be logged alt each EOC.

FIELD ACTIVITIES:

EVACUATION OF TRANSPORTATION DEPENDENT POPULATION Extent-of-Play Agreement:

Jurisdiction Extent-ot-Play In Out of Out of Sequence Seq uence ;

Sequence Sequence; Comments With Day of NOT Day of Exercise Exercise Exercise Exercise Westchester Bus companies will County be interviewed as per the Offsite Extent-of-Play Activities Schedule. Each company will provide a dispatcher and 5 -

10% (minimum of 2) of that company's (X) drivers for interviews.

A State Controller will provide the bus routes to be discussed to the dispatcher for the briefing of drivers.

Rockland Bus companies will Group interviews County be interviewed as per requested the Offsite Extent-of-Play Activities Schedule. Each company will provide a dispatcher and 5 -

10% (minimum of 2) of that company's (X) drivers for interviews.

A State Controller will provide the bus routes to be discussed to the dispatcher for the briefing of drivers.

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

94

Jurisdiction I xten t-ot-Play In Out of Out of Sequence Sequence: Sequence; Comments With Oayof NOT Oay of Exercise Exercise Exercise Orange Bus companies will West Point Tours (Vails County be interviewed, Gate and Highland procedures will be Falls) interviews reviewed and completed 217108.

equipment will be inspected. Each company will provide a dispatcher and at least 5-10% (X)

(minimum of 2) of that company's drivers for interview. A State Controller will provide the bus routes to be discussed to the dispatcher for the briefing of drivers.

Putnam Bus companies will Putnam County County be interviewed, proposes to procedures will be demonstrate with school reviewed and administrator, equipment will be dispatcher and driver(s).

inspected. Each company will provide Also proposes a dispatcher and 5- 5 interviews of General 10% (minimum of 2) (X) Population and School of that company's Bus concurrently.

drivers for interview.

A State Controller will provide the bus routes to be discussed to the dispatcher for the briefing of drivers.

NOTIFICATION OF HEARING IMPAIRED Extent-ot-Play Agreement:

• There will be no actual notification of hearing-impaired individuals during the exercise.

EVACUATION OF NON-INSTITU,.IONALIZED MOBILITY IMPAIRED INDIVIDUALS Extent-ot-Play Agreement:

95

• There will be no actual dispatch of vehicles for transport of non-institutionalized mobility-impaired individuals.

• There will be no actual contact of non-institutionalized mobility-impaired individuals identified on the list.

96

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.c -Implementation of Protective Actions for Special Populations Criterion 3.c.2: OROs/School officials implement protective actions for schools.

(NUREG-0654, J.1 O.c, d, g).

EOC ACTIVITIES:

Extent-of.Play Agreement:

• During the December 3, 2008 exercise, there will be initial contact with the schools and transportation providers (telephone call) by the School and Transportation Coordinators. Initial contacts will be actual and some follow-up contacts may be simulated. All calls will be logged at each EOC.

FIELD ACTIVITIES:

EVACUATION OF SCHOOL POPULATION~

Extent-of-Play Agreement:

• Bus companies will be interviewed as per the Offsite Extent-Of-Play Activities Schedule.

• Each company will provide a dispatcher and 5-10% (minimum of 2) of that company's drivers for interview.

• A State Controller will provide the bus routes to be discussed to the bus dispatcher for the briefing of drivers.

SCHOOL INTERVIEWS Extent-of-Play Agreement:

• The minimum number of schools/licensed day care providers/private schools (one school per district) to be interviewed per the Offsite Extent-Of-Play Activities Schedule is as follows:

• Westchester County - 10 schools

• Rockland County - 5 schools

• Orange County - 1 school

• Putnam County - 3 schools 97

• Additional interviews of schools and school reception centers (baseline evaluations 2008-2013) will be conducted as agreed to by FEMA, NYSEMO and each county EMO.

• Interviews for schools within the same district may be conducted with school administrators at a scheduled district meeting.

98

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.d. - Implementation of Traffic and Access Control Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.g, j)

TRAFFIC AND ACCESS CONTROL POINTS (TCPs and ACPs)

Extent-of-Play Agreement:

Jurisdiction Extent-ot-Play In Out of Out of Sequence Sequence; Sequence; Comments With Day of NOT Day of Exercise Exercise Exercise Westchester There will be two (2)

County interviews of law enforcement officials to discuss how to activate TCPs/ACPs.

Each designated law enforcement agency will provide one (1) officer. The State (X)

Controller will provide a free play message to select the TCPI ACP assigned to that agency to be discussed. The interviews will take place at the EOC.

Rockland There will be two (2)

County interviews of law enforcement officials to discuss how to activate TCPs/ACPs.

Each designated law enforcement agency will provide one (1) officer. The State (X)

Controller will provide a free play message to select the TCPI ACP assigned to that agency to be discussed. The interviews will take place at the EOC.

99

-Jurisdiction Exten t-of-Play In Out of Out of Sequence Sequence: Sequence: Comments With Day of NOT Day of Exercise Exercise Exercise Orange There will be two (2)

County interviews of law enforcement officials to discuss how to activate TCPs/ACPs.

Each designated law enforcement agency will provide one (1) officer. The State (X)

Controller will provide a free play message to select the TCPI ACP assigned to that agency to be discussed. The interviews will take place at the EOC.

Putnam There will be two (2)

County interviews of law enforcement officials to discuss how to activate TCPs/ACPs.

Each designated law enforcement agency will provide one (1) officer. The State (X)

Controller will provide a free play message to select the TCPI ACP assigned to that agency to be discussed. The interviews will take place at the EOC.

100

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.d. - Implementation of Traffic and Access Control Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-(NUREG 0654, J.1 O.k).

IMPEDIMENTS TO EVACUATION Extent-of-Play Ag reement:

• Each of the four 10-mile plume exposure pathway EPZ counties is to demonstrate the organizational ability to deal with at least two (2) impediments to evacuation.

• The State Controller will inject "Exercise" messages for action as agreed upon.

• No equipment (Barriers, Traffic cones, Signs, etc.) will be deployed to the field.

• This demonstration will not involve the dispatch of a police or other emergency vehicle to the scene of a simulated impediment. Initial contact of resource providers will be actual and some follow-up contacts may be simulated. All calls will be logged at each EOC.

101

EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.a - Plume Phase Field Measurements and Analyses Criterion 4.a.1: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates. (NUREG-0654, H.10; 1.7, 8, 9)

FIELD MONITORING TEAMS Extent-ot-Play Agreement:

• The monitoring teams will not be suited up in anti-contamination clothing.

However, the clothing will be available for inspection. The initial use of gloves will be demonstrated.

• Field team equipment is calibrated by IPEC's RP Department. An internallPEC requirement provides for calibration of this equipment every six months.

Therefore, the calibration sticker for this equipment shows a "calibration due date" which reflects the six month calibration schedule. The instruments are considered calibrated as long as the current date is within one year of the calibration date.

102

EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS SubMelement 4.a - Plume Phase Field Measurements and Analyses Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, H.12; 1.8, 11; J.10.a)

• In the event of a simulated radiological release, the licensee field teams will obtain plume centerline data.

103

EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.a - Plume Phase Field Measurements and Analyses 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, 1.9).

FIELD MONITORING TEAMS Extent-of-Play Agreement:

• Each EPZ County will dispatch two (2) radiological monitoring teams. Each team will be supplied with a State Controller and FEMA evaluator.

• The monitoring teams will not be suited up in anti-contamination clothing.

However, the clothing will be available for inspection. The initial use of gloves will be demonstrated.

• Each team will take at least six (6) ambient radiation measurements (including background measurements) and at least two (2) air samples. All teams must take the air samples as though they were in the presence of the plume including County teams that may not be impacted by the plume. If necessary, an inject message from the State Controller may be used to complete the taking of all six measurements prior to the end of the exercise.

• The use of silver zeolite cartridges will be simulated and charcoal cartridges will be used. However, the silver zeolite cartrid!~es will be available at dispatch point of kit.

• There will be no actual packaging or transport of samples to the laboratory. EOC staff will be questioned only regarding means of transportation of air samples to a central point and the location of the laboratory. Field teams will demonstrate how to obtain air samples during the exercise and will be questioned only regarding the procedures for the pick-up point of air samples and chain of custody.

• Eating, drinking, and smoking will be allowed after concurrence of the FEMA evaluator.

104

EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.a - Activation of the Prompt Alert and Notification System 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 FEMA REP guidance. (10 CFR Part 50, Appendix E.IV.D & NUREG-0654, 1::.5, B, 7)

Extent-of.Play Agreement:

• There will be no actual sounding of sirens and no actual broadcasting of EAS messages. The Indian Point siren system will be tested during 2008. FEMA will be invited to observe the tests at those times.

• To demonstrate the procedures for siren activation, all counties will conduct an actual "Silent" test (no siren sounding) in conjunction with an EAS message broadcast (simulated) during the exercise.

• One (1) complete alerting and notification sequence will be evaluated. This sequence will include simulation of siren activation, preparation and transmission of a simulated EAS message to the LP-1 radio station, and preparation and transmission of a simulated EAS Follow-On News Bulletin or Release to the LP-1 radio station, both of which contain protective actions. Therefore, there will be actual telephone contact with the radio station for one (1) simulated EAS message which contains protective actions. Contact with the radio station for all other EAS messages may be simulated.

• Airing of the all EAS messages will be simulated.

• Regular programming responsibilities of the radio station may preclude participation at the time of the issuance of the simulated EAS message.

• All simulated EAS messages will be available via the JIC website.

105

EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.a - Activation of the Prompt Alert and Notification System Criterion 5.a.3: Backup alert and notification of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654, E. 6, A.ppendix 3.B.2.c).

Extent-of-Play Agreement:

• To demonstrate the procedures for siren activation, all counties will conduct an actual "Silent" test (no siren sounding) in conjunction with an EAS message broadcast (simulated) during the exercise.

• The results of the initial "Silent" test will be Llsed to discuss backup alerting by the telephone call-out system for sirens that have been simulated to fail.

Subsequent silent tests if conducted by the counties will not be evaluated.

• An inject message(s) to simulate siren failures will be used if no sirens appear to have failed on the "Silent" test.

• Demonstration of this criterion will be limited to two (2) actual "Silent" test failures or two (2) simulated siren failures per coun~{.

Jurisdiction Extent-ot-Play In Out of Out of Sequence Sequence; Sequence; Comments With Day of NOT Day of Exercise Exercise Exercise Westchester EOC discussion only, County after "Silent" test. (X)

The county's A small test group Will telephone call-out be used for system will be demonstration.

demonstrated to notify an area (X) impacted by a I

simulated siren L--.

failure.

---

--------1---

---

1-- J 106

Jurisdiction I xten t-of-Play In Out of Out of Sequence Sequence; Sequence; Comments With Day of NOT Day of r - - -_______-4~------~------_r=Ex~e~~~is~e~~E=x=e~~~is~e~~Ex~e~~=is~e~__~--~~------~~_1 The county's A small test group will telephone call-out be used for system will be demonstration.

demonstrated to notify an area (X) impacted by a simulated siren failure.

Orange EOC discussion after County "Silent" test. (X)

---

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

The county's A small test group will telephone call-out be used for system will be demonstration.

demonstrated to notify an area (X) impacted by a simulated siren failure.

Putnam EOC discussion after (X)

County

-fhe-countls------------ -----------

"Silent" test.

---

--------------- -A smaii test group wii(---

wii(--

telephone call-out be used for system will be demonstration.

demonstrated to notify an area (X) impacted by a simulated siren failure.

107

EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.b - Emergency Information and Instructions for the Public and the Media Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E. 5, 7; G.3.a, GA.c).

PUBLIC INSrRUCrlON AND EMERGENCY INFORMArlON Extent-of-Play Agreement:

• Four (4) simulated EAS Follow-On News Releases (one for each county, if applicable) following an EAS message containing protective actions may be actually distributed to the LP-1 EAS radio station via the JIC website. The EAS Follow-On News Releases from each county may not necessarily apply to the same EAS Message.

• West. Co. will also post News Releases (and EAS messages) to the county "Exercise" website.

• All simulated EAS Follow-On News Releases will be available to the media via the JIC website.

EMERGENCY INFORMATION Extent-of-Play Agreement:

• At least two (2) media briefings will be conducted and evaluated. The briefings to be evaluated will be selected by a State Controller with concurrence from the lead JIC FEMA evaluator. Preparation and scheduling activities for all media briefings will be conducted in accordance with the JIC procedures.

• AudioNideo conference links from the County EOCs to the JIC will be utilized for media briefings.

PUBLIC INQUIRY Extent-of-Play Agreement:

• The public inquiry function will be staffe~d for evaluation at two (2) locations:

the New York State Tax and Finance Call Center in Albany (-6 people including a supervisor) and the Westchester County Public Inquiry Call Center in White Plains (-10 people including a supervisor).

108

• Inject messages will indicate false or misleading information to enable the public inquiry function to identify trends and false rumors at both locations.

• Coordination of trends and false information will be conducted on the PIC Coordination line.

• Media Monitoring will be conducted at the JIC.

• Callbacks from the NYS Tax and Finance Call Center in Albany may be simulated.

109

EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-element 6.a - Monitoring and Decontamination of Evacuees and Emergency Workers, and Registration of Evacuees Criterion 6.a.1: The reception center/emergency worker facility has appropriate space, adequate resources, and trained per:sonnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

(NUREG-0654, J.10.h; J.12; K.5.a)

Extent-of-Play Agreement:

• Reception centers will be demonstrated as per the offsite extent of play activities schedule. Additional reception centers will be evaluated (baseline evaluations 2008-2013) as agreed to by FEMA, NYSEMO and each county EMO.

• At least 1/3 of the required monitors will be present and at least six (6) simulated evacuees will be monitored.

• Initial personnel monitoring staff will be demonstrated as tabulated below. Staff will be provided to simulate evacuees.

Number of Persons for Initial Personnel Monitoring Category Orange Rockland Westchester Putnam County County County County Radiological monitors 3 3 3 2 for initial monitoring (See Note 4) (S~~e Note 4) (See Note 4) (See Note 1)

Other Personnel 0 0 0 0 (See Note 5) (See Note 2) (See Note 5) (See Note 3)

No. of Portal Monitors 2 2 2 1 Note 1: One monitor for portal monitoring; one monitor for hand held monitoring.

Note 2: Evacuees will be monitored, then either given a "clean" card or directed to decontamination area.

Note 3: Evacuees will be monitored, then either hand-stamped clean or directed to decontamination area.

Note 4: Two monitors for portal monitoring and 1 monitor available for hand held monitoring.

Note 5: Evacuees will be monitored, then directed to a "clean" area or to decontamination area.

• The number of decontamination personnel, vehicle monitoring/decon personnel and social services personnel demonstrating this criterion will be in accordance with each county's plans and procedures.

• Vehicle monitoring will be conducted in accordance with plans.

• There will be only a representative sample of supplies available at each facility.

Ii 0

• As necessary, decontamination techniques will be simulated. At the PMC, activities that may damage property (such as parking vehicle on grass) are to be simulated.

• The monitoring and decontamination teams will not be suited up in anti-anti contamination clothing. However, alll"equired materials will be available for inspection. The initial use of gloves will be demonstrated.

• Reception Center floors may be covered with a representative sample of paper/plastic during this demonstration. However, all required materials will be available for inspection.

• One decon area will be set up and used to demonstrate both male and female decontamination technique by appropriate personnel.

• Portal monitors will be operated in accordance with each county's procedures. Portal monitors are checked with a check source to verify operability and the capability to meet the FEMA portal monitor standard (11JCi Cs-137 at midline).

• Monitoring and decontamination capabilities for a school reception center (Rockland County only) will be demonstrated as per the Offsite Extent-of-Play Activities Schedule.

111

EVALUATION AREA S: SUPPORT OPERATION/FACILITIES Sub-element S.b - Monitoring and Decontamination of Emergency Worker Equipment Criterion S.b.1: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles. (NUREG-06S4, K.S.b)

Extent-of-Play Agreement

• Emergency Worker Personnel Monitorin!~ Centers (EWPMC) will be demonstrated as per the offsite extent-of-play agreement schedule.

• Each facility will demonstrate the following:

• At least two (2) monitors for personnel decontamination (1 male and 1 female);

• At least one (1) monitor for vehicle monitoring;

• At least one (1) monitor for vehicle decontamination.

• The monitoring and decontamination teams will not to be suited up in anti-anti contamination clothing. However, all required materials will be available for

. inspection. The initial use of gloves will be demonstrated.

• Decontamination actions are to be simulated. At the PMC, activities that may damage property (such as parking vehiclles on grass) are to be simulated.

• EWPMC floors may be covered with a representative sample of paper/plastic during this demonstration. However, all required materials will be available for inspection.

• One (1) portal monitor for personnel monitoring will be demonstrated by Westchester and Rockland Counties. Two (2) portal monitors for personnel monitoring will be demonstrated by Orange County.

• One decon area will be set up and Llsed to demonstrate both male and female decontamination technique by appropriate personnel.

• The Portal monitor will be operated in accordance with each county's procedures. Portal monitors are checked with a check source to verify operability and the capability to meet the FEMA Portal Monitor standard (1 uCi Cs-137 at midline).

112

EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-element 6.c - Temporary Care of Evacuees 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 (found in MASS CARE-Preparedness Operations, ARC 3031). 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, J.10.h, J.12).

Extent-of-Play Agreement:

• This criterion will be demonstrated at the following facility only:

o Orange Co. - Middletown H.S., Middletown, NY 113

EVALUATION AREA S: SUPPORT OPERATION/FACILITIES Sub-element S.d - Transportation and Treatment of Contaminated Injured Individuals Criterion S.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.

(NUREG-0654, F.2; H.1 0; K.S.a, b; L.1, 4)

Extent-of-Play Agreement:

• MS-1 drills for the four EPZ counties will be conducted as per the Offsite Extent-Ot-Play Activities Schedule.

• The use ot flashing lights and sirens for 13xercise play is not required.

114

Appendix 4 ENTERGY NUCLEAR NORTHEAST INDIAN POINT ENERGY CENTER, UNIT 3 DECEMBER 3, 2008 FEMA/NRC Exercise Initial Condition Indian Point Unit 3 Nuclear Power Plant has been operating for the last 500 days at 100% power. Plant operations personnel are completing shi ft turnover. #32 480 volt emergency diesel generator (EOG) was taken out of service 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ago for a malfunctioning governor. Maintenance work has been completed and the diesel has been running for 30 minutes as part of the post work test. Unit #3 will be required to start a plant shut down in 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> sunless the test em #32 EDG passes. The 13.8kv/6.9 kV transformer to the Unit #3 13. 8kv electrical bus shorted out 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> ago and was disconnected and denergized. The Unit #3 6.9kv bus emergency power diesel generator (Appendix R) needed to be taken out of service to allow work on the 13.8kv electrical bus. #33 safety Injecti on pump SI Pump) is out-of- service for motor and electrical circuit breaker preventive mainte nance. The Local Government Radio (LGR) is also out of service.

Meteorological Data is Pasquill Category: E. Wind Speed: 4.5 m/s. Wind Direction from 30 degrees. Skies are cloudy with a temperature of 35 degrees.

Indian Point Unit 2 Nuclear Power Plant has been operating for the last 200 days at 100% power. The only equipment out of service is the LGR.

Narrative Summary Approximately 5 minutes after the new crew takes over the shift a Nuclear Plant Operator will call the simula tor Central Co ntrol Room (CCR) a nd inform the crew tha t

1. 32 480 v olt emergency diesel generator (EDG) tripped and failed its retest. A plant shutdown will be required.

Soon after, a loss of offsite power will occur due to a fault on the station auxiliar y transformer. Operators will identify entry conditions fo r procedure AOP-138KV-1, "Loss of Power to 6.9KV bus 5 andl or 6". While performing steps, the main generator and the turbine will trip. Operators will enter procedure E-O "Reactor Trip or Safety Injection".

The crew will be required to establish auxiliary feedwater flow to the stearn generators.

1. 31 480 volt emergency diesel generator (EOG) will initially start and then it will fail.

0800 0858 1120 1220 1335 1455 1555 INITIAL SITE AREA GENERAL RELEASE WINDSHIFT RELEASE EXERCISE CONDITION EMERGENCY EMERGENCY BEGINS ENDS ENDS DECLARED DECLARED (EAl6.1.4) (EAl1.2.2) 115

ENTERGY NUCLEAR NORTHEAST INDIAN POINT ENERGY CENTER, UNIT 3 DECEMBER 3, 2008 FEMA/NRC Exercise After auxiliary feedwater fI ow is established to the* steam generators, #33 emergency diesel gen erator will trip (shut down). Unit #3 will now have a total loss of all power, normal and back up. Unit #3 Operators will enter procedure ECA-O.O, "Loss of All AC Power." A Site Area Emergency should be declared, based on Emergency Action Level (EAL) 6.1.4 " Loss of All AC Power> 1e; minutes and inability to power required core cooling systems".

The reactor coolant pump (RCP) seals begin to fail due to loss of electrical power.

A 3500 gallon per minute loss of reactor coolant (L.OCA) occurs.

OSC field teams will be successful in restorin~) #32~ emergency diese I gen erator. After power is restored the operators will take actions to restore make up water (charging flow) to the reactor coolant system. The field tea rn will be dispatched to align the refueling water storage tank (RWST) to the charging pump suction. (Charging flow will not be established before red path core cooling conditions exist.) Operators will complete required act ions in procedure EC A-O.O and transition to procedure ECA-0.2 "Loss of All AC Power Recovery with SI Required."

Operators will attempt to start #31 safety injec:tion pump; however it will trip automatically. The control room will dispatch operators to investigate. The reactor vessel level indicating system (RVLlS) begins to decrease be low 33% and reactor core exit temperatures (CETs) increase greater than 715°. This would indicate the fuel is not being cooled and is over heating. This condition results in a Red Path in core cooling.

Actions to reduce temperatur e less than 715° will be unsuccessful. Conditions for a General Emergency (GE) will exist and aGE shoud be declared base upon EAL 1.2.2 "Red Path Core Cooli ng and Functional restoration actions taken and procedures not effective within 15 minutes" To facilitate the objectives of a site radiological release, the radiation detectors in the vapor containment building (R25/26) will be rampe!d from 1R to BOOR and radiation monitors R2 and R7 will fail high. This will allow simulation of significant core damage.

Approximately 3 minutes after the GE is declared, alignment to the RWST will be successful. Operators will start a charging pump and NPOs will be successful in 0800 0858 1120 1220 '1335 1455 1555 INITIAL SITE AREA GENERAL RELEASE WINDSHIFT RELEASE EXERCISE CONDITION EMERGENCY EMERGENCY BEGINS ENDS ENDS DECLARED DECLARED (EAL 6.1.4) (EAL 1.2.2) 116

ENTERGY NUCLEAR NORTHEAST INDIAN POINT ENERGY CENTER, UNIT 3 DECEMBER 3, 2008 FEMA/NRC Exercise returning #31 safety injection (SI) pump to se rvice. Operators will complete the required actions for power restoration and transition to procedure FR C-1, "Inadequate Core Cooling". OSC field teams will be successful in restoring #31 emergency diesel generator. Simulator CCR should start #31 residual heat removal (RHR) and #32 safety injection (SI) pumps. Within 1 minute after they start, both will trip on overcurrent. These pumps will not be repaired. Core cooling flow will be limited through out the exercis e to preclude operators from establishing cold leg recirculation.

A monitored radiological release from cont ainment occurs. The release will be detected by rising levels on plant vent radiation monitors R-1 4 and R-27. The source of the release will be from a failed containment penetratic,n for post accident containment venting.

Meteorological data will change causing additional Protective Action Recommendations

=

(PARs) to be generated. Meteorological data will change to WS 4.5 mIs, WD from

=

150 0 , and Pasquill E. .

Radioactive releas e will be stopped by the Repai r and Corrective Action team being successful in repairing containment penetration.

OSC field teams will be successful in rest oring #32 EDG. Simulator CCR should start

1. 32 Containment Spray Pump, #32 RHR pump, and #35 Fan Cooler Unit.

After consultation with the Onsite and Offsite Exercise Controller Organization and determination that all objectives have been given ample opportunity for demonstration by BOTH onsite and offsite responders, the Exercise will end.

0800 0858 1120 1220 1335 1455 1555 INITIAL SITE AREA GENERAL RELEASE WINDSHIFT RELEASE EXERCISE CONDITION EMERGENCY EMERGENCY BEGINS ENDS ENDS DECLARED DECLARED (EAL 6.1.4) (EAL 1.2.2) 117

APPENDIX 5 PLANNING ISSUES

1. Orange County - Field Monitoring T,eam 2 ISSUE NO: 32-08-3.b.I-P-OI CONDITION: While appropriate KI was available for use by emergency workers, the issuance of KI to FMTs was not in accordance with the current requirements of Procedure 24, "Exposure Control." This procedure also does not accurately reflect the intended manner of distribution of dosimetry and KI at the new Orange County EOC. Specifically, according to Procedure 24, Steps 5.2.1 and 5.2.5, issuance of dosiffi4~try and KI to workers is the sole responsibility of the Emergency Worker Supe:rvisor. However, current protocol at the Orange County EOC is for FMTs to deploy directly to the new EOC and begin inventory and operational checks without necessarily interfacing with an emergency worker supervisor. In this exercise, the RACES Team members assigned to the FMTs were p(!rforming the functions of dosimetry and KI issuance. However issuance of dosimetry or KI by anyone other than the Field Team supervisor is a deviation from Procedure 24 requirements. The RACES personnel did not use or have an appropriate procedure to accomplish this task and while dosimetry was appropriately provided to Team 1, KI was not.

When questioned about KI prior to dispatch, Team 1 technical members recalled that the KI was stored in a cabinet and they proceeded to obtain sufficient KI to take to the field. It is not clear whether this would have been accomplished had the question not been asked, however the existing exposure control Procedure 24, as implemented without the field team supervisor, did not drive KI issuance by the RACES support personnel. Other KI responsibilities, including providing instructions for continued use after initial authorization to take it, and instruction on the potential allergic reactions, were also not accomplished during issuance of KI or during the FMT briefing by the Field Team Coordinator. Lastly, the Form 3, Individual Radiation Exposure Record Form does not include a place to record KI expiration, although Procedure 22 - "Field Radiological Monitoring," Step 4.2.3 requires the Field Teams to record the KI expiration date on the form. Since 118

Procedure 22 does not address RACES team member tasks and KI issuance was being done by RACES personnel and not technical team members using Procedure 22 for operational checks, this step in the procedure was never performed and the expiration date was not recorded on the Form 3 for team I.

POSSIBLE CAUSE: Field Team Supervisor is no longer expected to engage with field teams at the time of inventory and operational checks and prior to dispatch. As such, the procedural steps for dosimetry and KI issuance assigned to this position were not completed.

REFERENCE:

NUREG-0654, J.l 0 e.,f.

EFFECT: Field Teams could inadvertently be deployed to the field without KI in their posession and without adequate instruction as to side effects and use requirements in the days following an emergency.

RECOMMENDATION: Revise procedures to reflect proper issuance of dosimetry and KI. Also consider inclusion of KI tablets in field team kits.

2. Orange County - Field Monitoring Team 2 ISSUE NO: 32-08-4.a.l-P-02 CONDITION: During the RM-14 operability check, neither the procedural instruction nor other mechanism (equipment label, etc) specified an acceptable range of readings needed to ensure the equipment was indeed operational and suitable for field use. In order to be properly tested for operability, a given instrument reading must fall within both a lower and upper range of values specific to the source being used. However Procedure 22, "Field Radiological Monitoring," states only that the Cs-137 check source must read greater than 10.000 cpm. No upper level is provided for which a higher reading would also indicate an equipment malfunction and no specific source is identified. The source provided in the kit delivered only 9000 cpm and the team then borrowed a check source from anmher kit and found that the instrument response with this source was well over the required 10000 cpm.

No upper range was evaluated since the proc(~dure (or other instruction) did not specify one.

119

POSSIBLE CAUSE: The procedures are not adequate in assuring the operability of the RM-14.

REFERENCE:

NUREG 0654 H.lO EFFECT: Equipment may may pass operational test but still be defective due to insufficient testing criteria.

RECOMMENDATION: Update procedures for operational checks of equipment to include upper ranges specific to each source.

3. Orange County ~ Medical Services Hospital - St Lukes Cornwall Hospital ISSUE NO: 32-08-6.d.l-P-03 CONDITION: Use of the 44-9 probe with the Ludlum Model 14 survey meter should utilize the counts-per-minute (cpm) scale for detection of contamination. This is inconsistent with the contamination decision criteria designated in the hospital procedure, which provides action levels in mR/hr.

The procedure specifies survey action levels of less than 0.05 mR/hr as background, 0.005-100 mR/hr as contamination, and greater than 100 mR/hr as heavy contamination.

POSSIBLE CAUSE: The procedure addresses risk in terms of radiation risk from exposure, rather than determining contamination level.

REFERENCE:

NUREG-0654 K.5.a. FEMA-REP-22: Contamination Monitoring Guidance for Portable Instruments used for Radiological Emergency Response to Nuclear Power Plant Accidents.

EFFECT: Counts-per-minute is the proper unit for instrument readings when measuring beta-gamma emitting surface contamination. For purposes of accuracy and technical appropriateness. the proper scale should be utilized.

RECOMMENDATION: It is recommended that Procedure IP 1018 be revised to use decontamination decision criteria for individuals in cpm, consistent with FEMA-REP-22.

120

4. Orange County - Medical Services Transport Cornwall Volunteer Ambulance Corps.

ISSUE NO: 32-08-6dl-P-04 CONDITION: The crew from the Cornwall Volunteer Ambulance Corps and staff at the St. Luke's Cornwall Hospital were unaware of the procedure that requires the ambulance crew to report to an Orange County Emergency Worker Personnel Monitoring Center (EWPMC) if found to be contaminated after monitoring by hospital staff.

POSSIBLE CAUSE: Lack of training and ambiguity in how the procedure is written.

REFERENCE:

F2; H.IO; K.5.a,b; L.l; LA, Orange County RERP July 2006, Attachment 9: "Guidelines for the Treatment and Transport of Potentially Contaminated Injured People",Section III, Paragraph B, Page 10-23.

EFFECT: If ambulance crew members are decontaminated and treated at the hospital instead of a dedicated County Emergency Worker Personnel Monitoring Center, this will take up space and hospital staff time that will be needed at the hospital Radiation Emergency Arc~a (REA) for the treatment of the general public that may have been contaminated.

CORRECTIVE ACTION DEMONSTRATED: In Attachment 9, Under Section III. Paragraph B, on page 10-23 in the Orange County RERP, it reads as follows:

B. For Rescue-Squad personnel:

1. Hospital personnel will perform a survey of clothing, ambulance, etc.

upon arrival at the hospital before undertaking further activity.

2. If contaminated, discard clothing in container marked "Radioactive"

3. All rescue-squad personnel that are found to be contaminated should report to an activated Orange County Emergency Worker Personnel Monitoring Center.

121

This procedure needs more clarity on what actions is to take place on part of hospital staff and ambulance crew after the patient is discharged into the hospital's care. The procedure should state under what circumstances if any, that ambulance crew members are to be decontaminated and treated at the hospital, or "must" report to a EWPMC instead of "should". The removal of contaminated clothing by ambulance crew members at the hospital and the sending them to a EWPMC may not be feasible due to weather conditions and temperatures, and what the clothing requirements are of the Rescue Squad.

The Orange County Radiological Officer has agreed with this recommendation and has revised the procedure accordingly. The updated procedure has been reviewed and approved by FEMA.

5. Rockland County - Field Monitoring Team 2 ISSUE NO: 32-08-3.b.l-P-05 CONDITION: One Rockland County Field Monitoring Team 2 (RC FMT2) team member commented that she was allergic and could not take KI. When the team was instructed by the Field Team Coordinator (FTC) to take KI the other RC FMT2 team members took their KI (simulated) and notified the FTC that they had done so. The FTC was not advised that one team member was unable to take KI.

POSSIBLE CAUSE: County of Rockland Rockland.. Office of Fire and Emergency Services procedure DOH-7. "Field Monitoring Team Coordinator," Paragraph 5.4.11, only requires the FTC to ensure that all field teams have been instructed to take KI when the decision has been made for it to be taken. The procedure does not provide guidance in the event that a field team member is unable to take Kl. County of Rockland, Office of Fire and Emergency Services procedure DOH-S, "Potassium Issue and Use." Paragraph 5.S, requires emergency workers to record how much and when KI was taken but does not require reporting when an individual is unable to take KI.

REFERENCE:

NUREG 0654 1.1 O.e EFFECT: Not knowing that a field team memb~:r has not taken KI, the Field 122

Team Coordinator could direct the team into an area. or direct the team to stay in an area, where the individual could receive excess thyroid dose.

RECOMMENDATION: Procedures should be updated to require emergency workers to report taking, or not taking, KI when instructed to do so.

Procedures should also include guidance for emergency worker coordinators to take appropriate measures when an emergency worker is unable to take KI.

6. Rockland County Emergency Operations Center ISSUE NO: 32-08-2.b.2-P-06 CONDITION: The Rockland County Radiological Emergency Preparedness Plan,Section III, Rev. 07/08, page III-25, Table III- L states that when the projected dose to the population is 25 rem committed dose equivalent (CDE) to the thyroid from radioiodine, then the recommended action is to administer stable iodine.

The projected 25 rem thyroid CDE to warrant the recommendation to ingest KI is consistent with the U.S. Food and Drug Administration (FDA) guidance found in the U.S. Environmental Protection Agency Manual of Protective Action Guides and Protective Actions for Nuclear Emergencies, 1992, EPA- EPA 400-R-92-00 1. However, this guidance has been superceded by the FDA Guidance: "Potassium Iodide as a Thyroid Blocking Agent in Radiation Emergencies," November 2001. This guidance recommends the ingestion of KI as a function of age and projected thyroid CDE. It includes the recommendation to ingest KI for:

Children from birth to 18 years <<70 kg in w.!ight): > 5 rem thyroid CDE Pregnant or lactating women: > 5 rem thyroid CDE Adults 18 through 40: > 10 rem thyroid CDE Adults over 40: > 500 rem thyroid CDE Also, the policy in Table III-I is not consistent with the Rockland County Procedure, DOH-8 "Potassium Iodide Issue and Use," Rev 07/08, page 3, that states, " ... upon declaration of a General Emergency by the licensee, a recommendation to evacuate and take KI would be made simultaneously."

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POSSIBLE CAUSE: Failure of the Rockland County Radiological Emergency Preparedness Plan to use the most current FDA guidance for recommending KI for the public and the Rockland County Radiological Emergency Preparedness Plan is not consistent with the DOH-S procedure.

REFERENCE:

NUREG 0654 J.I O.e; Rockland County Plan, Rev. 07/08, page III-25, Table III-I; and DOH-S.

EFFECT: The difference between Table III**J and DOH-8 could result in confusion for the decision makers. Also, using the outdated projected 25 rem thyroid CDE as the trigger for recommending KI for members of the public between birth and 40 years old subjects those individuals to an increased thyroid cancer risk.

RECOMMENDATION: Modify the county plan to be consistent with DOH-8 and the current FDA guidance on the projected thyroid CDE that warrants the ingestion of KI by the public.

7. Westchester County - Field Monitoring Team HD-l ISSUE NO: 32-08-4.a.3-P-07 CONDITION: IP-3.2, Attachment 5 "Conduct of an Air Sample" Step 3.0 directed the Field Monitoring Teams to take a 10 cubic feet air sample and referred the reader to Attachment 6 (Air Sampler Model H-809C) for air sampler run times. However, Attachment 6 contained no run times for obtaining al 0 cubic feet air sample at different flow rates. For the two air samples taken, the flow rates were 0.9 and 0.& cubic feet per minute (cfm),

less than calibration flow rate of 1 cfm. When the EOC was informed of this, Field Monitoring Team HD-l was instructed to continue to use 10 minutes as the sampling time because the air sampler was calibrated for 1 cfm and to not adjust the time duration.

POSSIBLE CAUSE: IP-3.2 was revised 8/08 and run time information was eliminated from Attachment 6. When contacted, the WC EOC instructed HD-I to continue to use 10 minutes as the sampler nm time even if the flow rate is not exactly I cfm.

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REFERENCE:

NUREG-0654 I.9; Westchester County Radiological Emergency Response Plan, Implementation Procedure IP-3.2 "Field Monitoring Team" Attachments 5 and 6.

EFFECT: For this exercise, there was no effect because Field Monitoring Team HD-l was not in the plume when they took their air samples; hence all their measurements were background. However, if the team were in the plume and the air sampler flow rate differed from the calibrated rate, then using a fixed sampling time (10 minutes) would result in a total air volume sampled to be higher or lower than 10 cubic feet that would be used in performing iodine dose calculations.

RECOMMENDATION: Either revise Attachment 5 ofIP-3.2 to instruct the Field Monitoring Teams to record and transmit the air sampler flow rate observed when using a fixed sampling duration or revise Attachment 6 of IP- IP 3.2 to provide the sampling durations (run times) needed to obtain a fixed sampling volume of air of 10 cubic feet.

8. Westchester County - Field Monitoring Team HD-l ISSUE NO: 32-08-4.a.3-P-08 CONDITION: Information was not marked on the envelopes for the air samples as per SOP IP- 3.2 "Field Monitoring Teams". Steps 7.0, 9.0, 10.0, 11.0, and 14.0 of Attachment 5 "Conduct of an Air Sample" directed that the following be marked on the Air Sample Data Collection Envelopes:

Envelope Containing the Particulate Filter Filter Gross CPM, Filter Background CPM, Net Filter CPM and Filter Envelope Contact Dose Ratl!

Envelope Containing the Cartridge Higher of the Cartridge Gross CPM through envelope and Cartridge Net CPM 125

Instead the following were marked:

Envelope Containing the Particulate Filter Date, Team, Sampling location, Filter sample, start and stop times of the air sample and CPM (unknown if gross, background or net).

Envelope Containing the Cartridge Date, Team, Sample location, Cartridge sample, start and stop times of the air sample and CPM for front and back of envelopc~ containing cartridge.

POSSIBLE CAUSE: Steps 7.0 through 15.0 of IP-3.2 were not followed for recording information on the Air Sample Data Collection Envelopes. Although SOP lP-3.2 Attachment 5 identified what should be marked on the envelope, the envelopes provided were blank 5x7-inch brown envelopes. Without a pre- pre printed label or information/data template for the envelope, it made it difficult for Field Monitoring Team HD-l to correctly fill in the information required by to be recorded on the envelopes.

REFERENCE:

NUREG-0654 1.9; Westchester County Radiological Emergency Response Plan, Implementation Procedure IP-3.2 "Field Monitoring Team" and Attachment 5 "Conduct of an Air Sample."

EFFECT: For this exercise, there was no effect because Field Monitoring Team HD-l was not in the plume when air sampling was performed; hence all their filter and cartridge measurements were background. However, if HD-l were sampling in the plume, there would be incomplete field information provided to inform the sample recipient of the potential envelope content when the sample envelopes are transferred to the courier or to the sample custodian at the Westchester County Emergency Worker Decontamination Center,. More importantly, the information required by Attachment 5 to be recorded on the envelopes does not provide key information such as date, location of sampling, time of sampling which HD-I did write on the envelopes.

As written, the recipient of the sample would have no idea of the sampling locations unless Attachment 7 of IP-3.2 accompanied the sample envelopes.

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RECOMMENDATION: Consider revising IP-3.2 Attachment 5 to include a form or label for the sample envelope to prompt for the information/data that should be recorded. Consider revising Attachment 5 to include recording other key data to be attached to the sample envelope or require a copy of Attachment 7 to accompany the envelope.

9. Westchester County - Medical Services Hospital - Westchester Medical Center ISSUE NO: 32-08-6.d.l-P-09 CONDITION: A number of activities were observed that would be improved by procedure enhancements at the hospitaL Because the Lead Controller had the wrong telephone number for the hospital, the hospital was not notified of the patient being enroute. A security of11cer stationed outside did not inform the drill participants that the ambulance had arrived. In addition, when surveys were conducted in the REA, the probe on the radiation detector (E-520) was not covered. Finally, although the Radiological Safety Physicist stationed outside did a good job reminding the hospita.l crew to read dosimeters every IS minutes, a poster containing similar information should be used in case this individual is not present POSSIBLE CAUSE: Some activities have not been captured in the hospital procedure.

REFERENCE:

NUREG 0654, L.t EFFECT: Although a significant problem is not likely to occur if this issue is not addressed, the processes at the hospital might be improved if they are.

For example, a patient may not wait as long outside ifthe security officer is aware that he must notify hospital staff that an expected ambulance has arrived. Also, covering a radiation detecter probe would most likely prevent it from becoming contaminated. Finally, a poster with dosimeter requirements and action levels may prevent personnel from forgetting to read their DRO's or exceeding a dose limit.

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RECOMMENDATION: Revise the hospital procedure to require covering the detector probe prior to conducting radiologic:al surveys. The procedure should include having the security person stationed outside inform hospital staff when an ambulance is waiting outside with a patient. Also, although the Radiological Safety Physicist stationed outside did a good job reminding the hospital crew to read dosimeters every 15 minutes, a poster containing similar information would be useful in case this individual is not present.

10. Westchester County - Warning Point ISSUE NO: 32-08-l.a.1-P-tO CONDITION: The Emergency Operations Center (EOC) activation list provided to the evaluator to demonstrate quarterly updating was not the same list that was used during the exercise.

POSSIBLE CAUSE: The activation list utilized during the drill had not been replaced with the updated list.

REFERENCE:

NUREG-0654/FEMA-REP**J, E.t, E.2 EFFECT: No negative consequences occurred. Only one phone contact is necessary to activate the EOC and the list had five of the seven correct names.

RECOMMENDATION: Replace the list in the WP with the updated activation list.

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11. Westchester County - School Bus Company - Hendrick Hudson Bus ISSUE NO: 32-08-3.a.l-P-20 CONDITION: The inventory at the School Bus Garage no longer has TLDs.

Instead the TLDs were replaced with a newer technology OSL permanent record dosimeter.

The new inventory is not accurately documented inWestchester County's Plan.

POSSIBLE CAUSE: A possible cause for the deviation between the plan and the inventory of the bus garage is that the plan may not have been updated since the issuance of the newly calibrated dosimeters to the bus garage.

REFERENCE:

NUREG-0654 FEMA-REP 1 Rev. 1 Part II Section K Westchester County Radiological Emergency Plan for the Indian Point EnergyCenter Procedure 5 - DOT, Attachment I EFFECT: The equipment issued to the emergency workers are not the sameas described in the plan.

RECOMMENDATION: It is recommended to update the plan to reflect the new dosimeters in inventory.

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12. Westchester County - School Bus Company - Hendrick Hudson Bus ISSUE NO: 32-1O-3.a.l-P-18 CONDITION: Hendrick Hudson Bus Company did not have proper dosimeters as described in the "Westchester County Radiological Emergency Plan for the Indian Point Energy Center".

The bus company had 50 Arrow-Tech, Model 730 directreading dosimeters with a range ofO-20R.

Procedures 3 and 5 of the Westchester County Radiological Emergency Plan call for a 0-5R dosimeter and a 0-200R dosimeter to be issued.

POSSIBLE CAUSE: Someone changed the type of dosimeters in inventory despite what is described in the plan.

REFERENCE:

NUREG-0654 FEMA-REP 1 Rev. I Part II Section K Westchester County radiological Emergency Plan for the Indian Point Energy Center Procedure 3.3 Radiological Officer, Attachment 7.

EFFECT: If an emergency worker was working in a Life Saving or Protection of Large Populations capacity, they may not be able to monitor their total dose since equipment being issued only goes up to 20R.

RECOMMENDATION: Replace inventory with 0-5R and 0-200R dosimeters that are described in the Westchester County Radiological Emergency Plan for the Indian Point Energy Center," or update the plan to reflect current inventory. The plan should address methods of monitoring above in case emergency workers are conducing life saving operations or protection of large populations.

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