ML110330241

FEMA, Submittal of After Action Report/Improvement Plan for Susquehanna Plume Radiological Emergency Preparedness Exercise Old 10/05/10

ML110330241
Person / Time
Site:	Susquehanna
Issue date:	01/25/2011
From:	Tierney M US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML110330241 (173)

Text

U.S. Department of Homeland Security One Independence Mall, Sixth Floor 615 Chestnut Street Philadelphia, PA 19106-4404 VyAR~

FEMA JAN 2 5 2011 NRC Headquarters' Document Control Desk U.S. Nuclear Regulatory CQmmission Washington, D.C. 20555-0001 To Whom It May Concern:

Enclosed is the After Action Report/Improvement Plan for the Susquehanna Steam Electric Station (SSES) Plume Radiological Emergency Preparedness Exercise that was held on October 05, 2010.

There were no deficiencies identified during the exercise. Five Areas Requiring Corrective Action (ARCAs) were identified; two were immediately re-demonstrated successfully and two others were re-demonstrated successfully on October 21, 2010. Three ARCAs from a previous exercise were successfully re-demonstrated. Four new planning issues were identified and have been resolved.

Based on the results of the exercise, the offsite radiological emergency response plans and procedures for the Commonwealth of Pennsylvania, and the affected local jurisdictions, site-specific to the Susquehanna Steam Electric Station 10-Mile Emergency Planning Zone, were adequately demonstrated and there is reasonable assurance that the plans are adequate and can be implemented, as demonstrated in the exercise.

If you have any questions, please contact Barton Freeman at (215) 931-5567.

Sincerely MaryAnn Tierney Regional Administrator Enclosure

Susquehanna Steam Electric Station After Action Report/

Improvement Plan Exercise Date - October 05, 2010 Radiological Emergency Preparedness (REP) Program I' FEMA Published December 14, 2010

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Susquehanna Steam Electric Station After Action Report/Improvement Plan Published December 14, 2010 Contents Executive Summary .7 Section 1: Exercise Overview 12 1.1 Exercise Details 12 1.2 Exercise Planning Team Leadership 12 1.3 Participating Organizations 14 Section 2: Exercise Design Summary 19 2.1 Exercise Purpose and Design 19 2.2 Exercise Objectives, Capabilities and Activities 20 2.3 Scenario Summary 21 Section 3: Analysis of Capabilities 24 3.1 Exercise Evaluation and Results 24 3.2 Summary Results of Exercise Evaluation 24 3.3 Criteria Evaluation Summaries 33 3.3.1 Pennsylvania Jurisdictions 33 3.3.1.1 Pennsylvania Emergency Operations Center 33 3.3.1.2 Pennsylvania Joint Information Center 33 3.3.1.3 Pennsylvania Accident Assessment Center, State 33 Emergency Operations Center-Bureau of Radiation Protection 3.3.1.4 Pennsylvania Bureau of Radiation Protection 34 Activities, Susquehanna Steam Electric Station Emergency Operations Facility 3.3.1.5 Pennsylvania Media Operations Center, Wilkes- 34 Barre 3.3.1.6 Pennsylvania Bureau of Radiation Protection, 34 Radiological Rapid Response Vehicle 3.3.1.7 PA State Field Monitoring Team A, South East 34 Region 1

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After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.1.8 PA State Field Monitoring Team B, South East 35 Region 3.3.1.9 Pennsylvania State Traffic and Access Control 35 Points, State Police Barracks Bloomsburg 3.3.2 Risk Jurisdictions 35 3.3.2.1 Columbia County Emergency Operations Center 35 3.3.2.2 Columbia County Emergency Worker Monitoring 36 and Decontamination Station, Columbia Montour Vo-Tech School 3.3.2.3 Columbia County, Berwick Borough/Briar Creek 37 Borough Emergency Operations Center 3.3.2.4 Columbia County, Berwick Borough/Briar Creek 38 Borough Back-up Route Alerting 3.3.2.5 Columbia County, North Centre Township 39 Emergency Operations Center 3.3.2.6 Columbia County, North Centre Township Back-up 39 Route Alerting 3.3.2.7 Columbia County, South Centre Township 39 Emergency Operations Center 3.3.2.8 Columbia County, South Centre Township Traffic 40 and Access Control 3.3.2.9 Luzerne County Emergency Operations Center 41 3.3.2.10 Luzerne County Emergency Worker Monitoring and 41 Decontamination Station, Wright Township Volunteer Fire Department 3.3.2.11 Luzerne County, Conyngham Township Emergency 44 Operations Center 3.3.2.12 Luzerne County, Conyngham Township Back-up 46 Route Alerting 3.3.2.13 Luzerne County, Dorrance Township Emergency 46 Operations Center 3.3.2.14 Luzerne County, Hollenback Township Emergency 46 Operations Center 3.3.2.15 Luzerne County, Nanticoke City Emergency 47 Operations Center 3.3.2.16 Luzerne County, Nanticoke City Traffic and Access 47 Control 3.3.2.17 Luzerne County, Slocum Township Emergency 47 Operations Center 3.3.3 Support Jurisdictions 48 2

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After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.3.1 Lackawanna County Emergency Operations Center 48 3.3.3.2 Lackawanna County Reception Center, Big Lots 48 Center 3.3.3.3 Lackawanna County Monitoring and 48 Decontamination Center, Scranton/Dunmore YMCA 3.3.3.4 Lackawanna County Mass Care Center, Dunmore 48 YMCA 3.3.3.5 Lycoming County Emergency Operations Center 49 3.3.3.6 Lycoming County Reception Center, Lycoming Mall 49 3.3.3.7 Lycoming County Monitoring and Decontamination 49 Center, Hughesville High School 3.3.3.8 Lycoming County Mass Care Center, Hughesville 50 High School 3.3.3.9 Montour County Emergency Operations Center 50 3.3.3.10 Northumberland County Emergency Operations 51 Center 3.3.3.11 Northumberland County Reception Center, 51 Shikellemy High School, Sunbury -

3.3.3.12 Northumberland County Monitoring and 51 Decontamination Center, Shikellemy High School -

Sunbury 3.3.3.13 Northumberland County Mass Care Center, 52 Shikellemy High School - Sunbury 3.3.3.14 Schuylkill County Emergency Operations Center 52 3.3.3.15 Schuylkill County Reception Center, Marian High 53 School 3.3.3.16 Schuylkill County Mass CareCenter, Marian High 53 School 3.3.3.17 Schuylkill County Monitoring and Decontamination 53 Center, Marian High School 3.3.3.18 Union County Emergency Operations Center 53 3.3.3.19 Union County Reception Center, Montandon 54 Elementary School 3.3.3.20 Union County Monitoring and Decontamination 54 Center, Lewisburg Area High School 3.3.3.21 Union County Mass Care Center, Lewisburg Area 54

.High School 3.3.3.22 Wyoming County Emergency Ooperations Center 55 3

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After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.3.23 Wyoming County Reception Center, Tunkahannock 55 Middle School 3.3.3.24 Wyoming County Monitoring and Decontamination 55 Center, Tunkahannock Middle School 3.3.3.25 Wyoming County Mass Care Center, Tunkahannock 55 Middle School 3.3.3.26 Columbia County, Benton Area School District 56 3.3.3.27 Columbia County, Benton Area School District, 56 Benton Area Middle/High School 3.3.3.28 Columbia County, Berwick Area School District 56 3.3.3.29 Columbia County, Berwick Area School District, 56 Nescopeck Elementary School 3.3.3.30 Columbia County, Berwick Area School District, 57 Salem Elementary School 3.3.3.31 Columbia County, Bloomsburg Area School District 58 3.3.3.32 Columbia County, Bloomsburg Area School District, 58 Bloomsburg High School 3.3.3.33 Columbia County, Bloomsburg Area School District, 58 Bloomsburg Area Middle School 3.3.3.34 Columbia County, Central Columbia School District 59 3.3.3.35 Columbia County, Central Columbia School District, 59 Central Columbia Middle School 3.3.3.36 Columbia County, Columbia-Montour Area 59 Vocational Technical School 3.3.3.37 Luzerne County, Crestwood School District 59 3.3.3.38 Luzerne County, Crestwood School District, Rice 60 Elementary School 3.3.3.39 Luzerne County, Greater Nanticoke Area School 60 District 3.3.3.40 Luzerne County, Greater Nanticoke Area School 60 District, K.M. Smith Elementary School 3.3.3.41 Luzerne County, Greater Nanticoke Area School 60 District, Greater Nanticoke Education Center 3.3.3.42 Luzerne County, Hazleton Area School District 61 3.3.3.43 Luzerne County, Hazelton Area School District, 61 Valley Elementary School 3.3.3.44 Luzerne County, Northwest Area School District 61 4

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After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.3.45 Luzerne County, Northwest Area School District, 62 Huntington Mills Elementary School 3.3.3.46 Luzerne County, West Side Area Vocational - 62 Technical School 3.3.3.47 Luzerne County, Wilkes-Barre Area Vocational - 63 Technical School Section 4: Conclusion 64 Appendix A: Improvement Plan 65 Appendix B: Exercise Timeline 66 Appendix C: Exercise Evaluators and Team Leaders 70 Appendix D: Acronyms and Abbreviations 74 Appendix E: Exercise Plan 77 5

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After Action Report/Improvement Plan Susquehanna Steam Electric Station EXECUTIVE

SUMMARY

==

Introduction:==

On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume the lead responsibility for all off-site nuclear planning and response. FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP)

Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

44 CFR 350 establishes the policies and procedures for FEMA's initial and continued approval of State and local governments' radiological emergency planning and preparedness for commercial nuclear power plants. This approval is contingent, in part, on State and local government participation in joint exercises with licensees.

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

Taking the lead in offsite emergency planning and in the review and evaluation of Radiological Emergency Response Plans (RERPs) and procedures developed by State and local governments; Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, September 14, 1993; and 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, 7

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After Action Report/Improvement Plan Susquehanna Steam Electric Station

- U.S. Environmental Protection Agency,

- U.S. Department of Energy,

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

- U.S. Department of Transportation,

- U.S. Department of Agriculture,

- U.S. Department of the Interior, and

- U.S. Food and Drug Administration.

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

A REP exercise was conducted on October 5th and 6th, 2010 to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Susquehanna Steam Electric Station (SSES). The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency.

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

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

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

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980; FEMA Guidance Memoranda MS-i, "Medical Services," November 1986; FEMA-REP- 14, "Radiological Emergency Preparedness Exercise Manual," September 1991; 8

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After Action Report/Improvement Plan Susquehanna Steam Electric Station 66 FR 47546, "FEMA Radiological Emergency Preparedness: Alert and Notification,"

September 12, 2001; and 67 FR 20580, "FEMA Radiological Emergency Preparedness: Exercise Evaluation Methodology," April 25, 2002.

Section 1 of this report, entitled "Exercise Overview," presents the Exercise Planning Team and the Participating Organizations.

Section 2, titled "Exercise Design Summary," includes the "Purpose and Design," "Exercise Objectives, Capabilities, and Activities," and the "Scenario Summary."

Section 3 of this report, entitled "Analysis of Capabilities," presents detailed 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, recommended corrective actions, and the State and local governments' schedule of corrective actions for each identified exercise issue and (2) descriptions of ARCAs assessed during previous exercises and resolved at this exercise, including the corrective action demonstrated, as well as ARCAs assessed during previous exercises and scheduled for demonstration at this exercise which remain unresolved.

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

Appendix A - Improvement Plan. A description of Areas Requiring Corrective Action, the parties responsible for implementing a corrective action plan and time frame for completion.

Appendix B - Exercise Time Line. A table that depicts the times that events and notifications were noted at participating agencies and locations.

Appendix C - Exercie Evaluators and Team Leaders. A table listing the names, organizations, and evaluation responsibilities of the evaluators and management.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Appendix D - Acronyms and Abbreviations. An alphabetized table defining the acronyms and abbreviations used in this report.

Appendix E - Exercise Plan. A narrative description of information developed to implement the exercise including the Extent of Play Agreemant with a detailed description of the exercise criteria and the participants' expected responses to the exercise scenario.

EPZ

Description:

The Susquehanna Steam Electirc Station is located in northeastern Pennsylvania on the Susquehanna River in Salem Township, Luzeme County. The plant is owned and operated by Pennsylvania Power & Light Company (PPL). Two boiling water reactors generate an electrical output of 1,194 megawatts each. Unit 1 began commercial operation on June 8, 1983, and Unit 2 on February 12, 1985.

The site encompasses 2,566 acres and is divided into two parts. The principal portion, containing the major operating equipment and buildings, is located 3,000 feet west of the river. The other portion houses the water intake apparatus located near U.S. Route 11. Route 11 passes through the site in a north/south direction, providing both primary and secondary access to the plant. The plant occupies approximately 100 acres of the site. The coordinates are approximately 41' 5'30" north and 760 8'55" west.

The topography of the plant site is hilly, with elevations ranging from 500 feet above mean sea level (MSL) at the river to about 1,100 feet above MSL at the northwest comer of the site. The plant grade is 670 feet above MSL. The minimum exclusion distance is 1,800 feet; all land within the exclusion area is owned by SSES. The surface soil in the area is considered to be glacial outwash and glacial till soils, which are typical of uplands and terraces. The bedrock consists primarily of red shale of the Catskill formation.

The immediate vicinity of the plant is rural, surrounded by farms and undeveloped land. A total of 78 sirens are used for notification of the public; the sirens were installed for coverage of the plume exposure pathway. The nearest population center is Shickshinny Borough (Luzeme County), with a population of 959, located about four miles north of the plant. The nearest population center with more than 20,000 people is the City of Hazleton, with a population of 23,329, located 13 miles to the southeast.

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After Action Report/lmprovemnent Plan Susquehanna Steam Electric Station The Berwick Airfield in Salem Township, Luzerne County, serves private aircraft and lies approximately five miles west of the plant. The airfield presents low risk to the plant. The closest major airport is the Wilkes-Barre/Scranton Airport, located 28 miles northeast of the site.

The 10-mile EPZ contains an estimated population of 68,511 according to 2000 census data.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Susquehanna Steam Electric Station Type of Exercise Plume Exercise Date October 05, 2010 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Barton Freeman Site Specialist FEMA Region III Technological Hazards Emergency Program Specialist 1 Independence Mall, 615 Chestnut St 6th Floor Philadelphia, Pennsylvania, 19106 215-931-5567 barton.freeman@dhs.gov Jesse Wells Exercise Planning Team Lead Pennsylvania Emergency Management Agency Emergency Management Specialist 12

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After Action Report/Improvement Plan Susquehanna Steam Electric Station 2605 Interstate Dr Harrisburg, Pennsylvania, 17110 717-651-2190 jwells@state.pa.us Laurin Fleming State Site Specialist Pennsylvania Emergency Management Agency Emergency Management Specialist 2605 Interstate Dr Harrisburg, Pennsylvania, 17110 717-651-2119 laufleming@state.pa.us Darrell Hammons Planning Team Member FEMA Region III Radiological Emergency Preparedness Branch Chief 1 Independence Mall, 6th Floor 615 Chestnut Street Philadelphia, Pennsylvania, 19106 215-931-5546 darrell.hammons@dhs.gov John Price Planning Team Member FEMA Region III Technological Hazards Emergency Program Specialist 1 Independence Mall, 6th Floor 615 Chestnut St Philadelphia, Pennsylvania, 19106 215-931-5570 john.price@dhs.gov 13

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Henry Tamamini Exercise Planning Team Member Pennsylvania Emergency Management Agency Technological Hazards Planning Division Chief 2605 Interstate Dr Harrisburg, Pennsylvania, 17110 717-651-2723 htamanini@state.pa.us 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Susquehanna Steam Electric Station exercise:

State Jurisdictions Pennsylvania Bureau of Radiation Protection Activities Pennsylvania Department of Agriculture Pennsylvania Department of Corrections Pennsylvania Department of Education Pennsylvania Department of Environmental Protection Pennsylvania Department of General Services Pennsylvania Department of Health Pennsylvania Department of Public Welfare Pennsylvania Department of Revenue Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency (PEMA)

Pennsylvania Fish and Boat Commision Pennsylvania Office of Administration Pennsylvania State Police Public Utility Commission Risk Jurisdictions Columbia County Commissioners Columbia County Emergency Management Agency Columbia County, Berwick Borough Emergency Management Agency Columbia County, Berwick Borough Fire Department 14

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Columbia County, Berwick Borough Reliance Fire Company Columbia County, North Centre Township Columbia County, South Centre Township Fire Department Columbia County, South Centre Township Police Department Columbia County, Benton Area School District Columbia County, Benton Area School District, Benton Area Middle/High School Columbia County, Berwick Area School District Columbia County, Berwick Area School District, Nescopeck Elementary School Columbia County, Berwick Area School District, Salem Elementary School Columbia County, Bloomsburg Area School District Columbia County, Bloomsburg Area School District, Bloomsburg Area Middle School Columbia County, Bloomsburg Area School District, Bloomsburg High School Columbia County, Central Columbia School District Columbia County, Central Columbia School District, Central Columbia Middle School Columbia County, Columbia-Montour Area Vocational Technical School Luzerne County Emergency Management Agency Luzerne County Fire and Emergency Medical Services Luzerne County Health/Medical Services Luzerne County Public Information (External Affairs)

Luzerne County Public Works Luzerne County Radiological Protection Luzerne County Sheriffs Department Luzerne County Transportation Luzerne County, Conyngham Township Luzerne County, Conyngham Township Pond Hill Ambulance Station 108 Luzerne County, Dorrance Township Board of Supervisors Luzerne County, Dorrance Township Citizens Volunteers Luzerne County, Dorrance Township Emergency Management Agency Luzerne County, Dorrance Township Emergency Medical Services Luzerne County, Dorrance Township Fire Rescue Services Luzerne County, Hollenback Township Board of Supervisors Luzeme County, Hollenback Township Emergency Management Agency 15

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Luzerne County, Hollenback Township Public Works Department Luzerne County, Hollenback Township Volunteer Fire/Emergency Medical Services Luzerne County, Nanticoke City Citizen Volunteers Luzeme County, Nanticoke City Fire Department Luzeme County, Nanticoke City Police Department Luzeme County, Slocum Township Board of Supervisors Luzeme County, Slocum Township Fire and Ambulance Company Luzerne County, Wright Township Volunteer Police Department Luzerne County, Wright Township Volunteer Fire Department Luzerne County, Crestwood School District Luzerne County, Crestwood School District, Rice Elementary School Luzerne County, Greater Nanticoke Area School District Luzerne County, Greater Nanticoke School District, Greater Nanticoke Education Center Luzerne County, Greater Nanticoke School District, KM Smith Elementary School Luzerne County, Hazleton Area School District Luzerne County, Hazelton Area School District, Valley Elementary School Luzerne County, Northwest Area School District Luzerne County, Northwest Area School District, Huntington Mills Elementary School Luzeme County, West Side Area Vocational - Technical School Luzerne County, Wilkes-Barre Area Vocational - Technical School Support Jurisdictions Lackawanna County 911 Lackawanna County Ambulance Lackawanna County Emergency Management Agency Lackawanna County Emergency Operations Center Lackawanna County, Mayfield Borough Emergency Management Agency Lackawanna County, Scranton Fire Department Lycoming County 911 Center Lycoming County Agricultural Department Lycoming County Board of Commissioners Lycoming County Conservation District 16

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Lycoming County Department of Public Safety Lycoming County Emergency Management Agency Lycoming County Human Resources Lycoming County Radiological Response Team Lycoming County Radiological Team Lycoming County Reception Center, Lycoming Mall Lycoming County Sheriff Montour County Northumberland Borough Fire Department Northumberland County Department of Public Safety Northumberland County Emergency Management Agency Schuylkill County Emergency Management Agency Schuylkill County, Butler Township Fire Department Schuylkill County, Rush Township Emergency Services Schuylkill County, Tamaqua Fire Department Union County Emergency Management Agency Union County Maintenance Department Union County, William Cameron Engine Company Wyoming County Commissioners Wyoming County Emergency Management Agency Private Organizations American Red Cross (ARC) Columbia County Chapter American Red Cross (ARC) Lewisburg Chapter American Red Cross (ARC) Murgas Chapter American Red Cross (ARC) North Central Pennsylvania Chapter American Red Cross (ARC) Schuykill and Eastern Norhumberland County Chapter American Red Cross (ARC) Scranton Chapter American Red Cross (ARC) Sunbury Area Chapter American Red Cross (ARC) Union County Chapter American Red Cross (ARC) Upper Northumberland County Chapter American Red Cross (ARC) Wyoming County Chapter American Red Cross (ARC) Wyoming Valley Chapter Community Medical Center (CMC) 17

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Datom Products Hazmat Moses Taylor Hospital Pennsylvania Power and Light (PPL)

Radio Amateur Civilian Emergency Serives (RACES) Columbia-Montour Radio Amateur Civilian Emergency Serives (RACES) Endless Mountain Amateur Radio Group Radio Amateur Civilian Emergency Serives (RACES) Lackawanna County Radio Amateur Civilian Emergency Serives (RACES) Murgas Amateur Radio Club Radio Amateur Civilian Emergency Serives (RACES) Union County Radio Amateur Civilian Emergency Serives (RACES) Upper North Cumberland Chapter Federal Jurisdictions Federal Emergency Management Agency Nuclear Regulatory Commission Environmental Protection Agency USDA Food Agriculture Council (FAC) 18

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After Action Report/Improvement Plan Susquehanna Steam Electric Station SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design On October 5, 2010, a full-scale plume exercise was conducted in the 10-mile plume exposure pathway, emergency planning zone (EPZ) around the Susquehanna Steam Electric Station (SSES) by the Federal Emergency Management Agency (FEMA), Region III. Out-of-sequence demonstrations were conducted on October 5 and 6, 2010. The purpose of the exercise and the out-of-sequence demonstrations was to assess the level of State and local preparedness in responding to a radiological emergency. The exercise and out-of-sequence.demonstrations were held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The most recent prior full-scale exercise at this site was conducted on October 21, 2008.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania; its two risk counties (Columbia, Luzerne) and risk municipalities (Berwick Borough, Briar Creek Borough, North Center Township, South Center Township, Conyngham Township, Dorrance Township, Hollenback Township, Nanticoke City, and Slocum Township);

and six support counties (Lackawanna, Lycoming, Montour, Northumberland, Union, and Wyoming) that were evaluated at this exercise.

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

Cooperation and teamwork of all the participants were evident during this exercise.

This report contains the final evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities:

• Reception Center: Conducted on October 6, 2010 between 1900 and 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> in Lackawanna, Lycoming, Northumberland, Schuylkill, Union, and Wyoming Counties.

• Mass Care, Monitoring and Decontamination: Conducted on October 6, 2010 between 1900 and 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> in Lackawanna, Lycoming, Northumberland, Schuylkill, Union, and Wyoming Counties.

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- Emergency Worker Monitoring and Decontamination: Conducted on October 6, 2010 between 1900 and 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> in Columbia, Luzerne County

- Schools: Conducted on October 5, 2010 between 0900 and 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> in Columbia and Luzerne Counties.

The State and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies identified. Five Areas Requiring Corrective Action (ARCAs) were identified as a result of this exercise; two of the ARCAs were successfully re-demonstrated during the exercise and two other ARCAs were successfully redemonstrated on October 21, 2010. In addition, three ARCAs from a previous exercise were successfully demonstrated at this exercise.

Four new planning issues were identified during the exercise. All were successfull resolved with plan changes submitted prior to the publication of this report. There were no planning issues carried forward from prior exercises.

2.2 Exercise Objectives, Capabilities and Activities The objective of the SSES 2010 Plume Exercise is to demonstrate the capabilities of State and local emergency management agencies to mobilize emergency management and emergency response personnel, to activate emergency operations centers and support facilities, and to protect the health, lives, and property of the citizens residing within the 10 mile Emergency Planning Zone (EPZ).

To demonstrate the ability to communicate between multiple levels of government and provide timely, accurate, and sufficiently detailed information to the public, the emergency management agencies use a variety of resources including radios, telephones, the Internet, the media, the Emergency Alert System (EAS), and the utility Alert and Notification System sirens (ANS). All of these communications resources were employed and evaluated. The EAS and ANS was simulated and media information was prepared but not actually released.

An essential capability of the Radiological Emergency Preparedness Program (REPP) is to evacuate, monitor and decontaminate if necessary, and provide temporary care and shelter to displaced residents from the EPZ. The ability of the support counties to mobilize personnel and 20

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After Action Report/mnprovement Plan SuIsquehanna Steam Electric Station resources to establish reception, monitoring and decontamination, and mass care centers was demonstrated.

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

2.3 Scenario Summary NOTE: All information below is scenario simulated. The times for the events are approximate as the NRC licensee's operations crew on the reactor training simulator will be provided some allowance for free play.

There are two nuclear units at the Susquehanna Steam Electric Station (SSES), Pennsylvania.

Both are Boiling Water Reactors, MARK 2 design. SSES Unit 1.will be participating in the exercise.

On October 5, 2010, SSES Unit 1 is operating at 100 percent power. The Unit has recently completed a refueling outage and has been at full power operation for 4 days. The routine condenser off gas release rate is higher than normally expected. The cause is traced to fuel clad failures in misplaced fuel bundles in the reactor core. This error occurred during the refueling outage. The routine release is from the Turbine Building roof top.

The weather is clear with light winds at 3 to 5 miles per hour (mph) from 45 degrees, the North East (NE) into the South West (SW). The stability class is D. These conditions are expected to remain unchanged into the night.

At 1530, the exercise begins in the Training Simulator Control Room. At 1535, the Training Simulator Control Room receives Hi-Hi condenser off gas alarms. This is verified by chemistry sampling as being just above the trigger level for an Unusual Event. At 1545, an Unusual Event is declared in accordance with emergency action level (EAL) MU7, "fuel cladding degradation".

There is a non routine radioactive release in progress as a result of this event. Unit 1 continues to operate at 100 percent power.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station At 1646, a fire protection system water line ruptures and floods the E diesel generator room. At 1700, an ALERT is declared by the Shift Manager in accordance with Emergency Action Level EAL-OA5, "Flooding in an area of the plant that results in degraded performance of safety systems". There is an ongoing non routine radioactive release. Unit 1 continues to operate at 100 percent power.

At 1745, the main steam line radiation monitor readings begin to rise rapidly owing to additional fuel clad failures in the misplaced fuel bundles. Direction is given to shut the reactor down immediately and close the main steam line isolation valves (MSIV). The reactor is successfully shut down. But, except for the inboard MSIV on the D main steam line, all other MSIV close.

Also, the outboard MSIV on the D main steam line is not completely shut. This allows for the continued flow of highly radioactive steam to the condenser. This is confirmed by flow indicator readings and elevated radiation monitor readings on the D main steam line. At 1750, the non routine Turbine Building roof top radioactive release increases significantly owing to the increase in the level of radioactivity in the condenser off gas.

At 1750, there are indications that there is a moderate leak from the reactor coolant system into the drywell (primary reactor containment). The drywell radiation monitor readings are increasing. At 1845, as a result of the leak from the reactor coolant system, the drywell radiation monitor reading exceeds 3000 R/hr. At 1900, a Site Area Emergency is declared based on EAL FS 1, "Loss of reactor coolant system barrier and potential loss or loss of fuel clad barrier".

There is an ongoing non routine radiological release from the Turbine Building rooftop. The wind direction is 45 degrees, the wind speed is 4 mph and the stability class is D.

At 2010, a drain line breaks in the condenser bay causing an additional release of radioactive gas to the environment through the Turbine Building filtration system. This causes another significant increase in the non routine release from the Turbine Building rooftop. At 2020, dose projections indicate that the EPA protective action guides (PAG) are exceeded off site.

At 2030, a General Emergency is declared based on EAL RG1, "Release rates exceed the General Emergency level". A Protective Action Recommendation is issued by SSES as "Evacuate 0-2 miles 3600 and 2 to 10 miles in downwind sectors WSW, SW and SSW and, advise the general public in the evacuated area to administer KI in accordance with the state plan. Advise the remainder of the EPZ to monitor for EAS messages."

Subsequent dose projections by the Commonwealth of Pennsylvania will indicate that the EPA 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station protective action guides (PAG) are exceeded in the 0 to 1 mile distance from the SSES.

By 2045 radiation releases will begin to decrease. However, the radioactive releases will continue until the end of the exercise. The wind direction remains at 45 degrees and the wind speed is 4 mph with stability class D.

At 2200 the SSES Evaluated Exercise will end if all objectives are met and, when announced by the Pennsylvania State Emergency Operations Center.

23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the October 5 and 6, 2010, biennial Radiological Emergency Preparedness (REP) Exercise.

Each jurisdiction and functional entitiy ws evaluated on the basis of its demonstration of the Exercise Evaluation Area Criteria contained in the REP Exercise Evaluation Methodology.

Detailed information on the Exercise Evaluation Area Criteria and the Extent-of-Play Agreement used in this exercise are found in Appendix E.

The Pennsylvania Emergency Operations Center, Pennsylvania Bureau of Radiation Protection Accident Assessment Center, Pennsylvania Bureau of Radiation Protection Field Monitoing Teams, and the Skuylkill County Emergency Operations Center participated in this exercise but were exempted from evaluation because they had been previously evaluated in another exercise.

Therefore, results of their participation will appear as an "N" on Table 3.1, "Summary of Exercise Evaluation."

3.2 Summary Results of Exercise Evaluation The Susquehanna Steam Electirc Station 2010 Plume Exercise evaluation included 73 participating locations, with 64 being Federally Evaluated and 9 participating and being observed. Fifty-nine evaluators provided analyses of 296 Exercise Criteria. These analyses resulted in a determination of 5 Areas Requiring Corrective Action (ARCA) of which 2 were successfully redemonstrated during the exercise; two others were successfully redemonstrated on October 21, 2010. In addition, 4 new Planning Issues were assessed. All Planning Issues were resolved. There were 3 ARCAs from the previous 2008 SSES Plume Exercise that were successfully demonstrated and resolved.

24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 3.1 - Summary of Exercise Evaluation (7 pages)

DATE: 2010-10-05 ,

SITE: Susquehanna Steam Electric Station, PA M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not U G < = W Demonstrated t Emergency Operations Management Mobilization lal N N N M N N M M Facilities IbI Direction and Control Ici N NIN M Communications Equipment Idl N N M N N N M M Equip & Supplies to support operations lel N N N N M N N N M M M Protective Action Decision Making MM Emergency Worker Exposure Control 2al N N N N M M Radiological Assessment and PARs 2bl N N Decisions for the Plume Phase -PADs 2b2 N N PADs for protection of special populations 2cl N M Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective Action Implementation Implementation of emergency worker exposure control 3al N N N N M M M Implementation of KI decision 3b1 N N N N M M Implementation of protective actions for special populations - EOCs 3c1 M Implementation of protective actions for Schools 3c2 M Implementation of traffic and access control 3dl M M Impediments to evacuation are identified and resolved 3d2 M M Implementation of ingestion pathway decisions - availability/use of info 3e 1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3Hf FieldMeasurementad ly, s Adequate Equipment for Plume Phase Field Measurements 4al N N N Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 N N N Post plume phase field measurements and sampling 4b 1 Laboratory operations 4c 1 Emergency Notification and Public Info Activation of the prompt alert and notification system 5al N M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 M Emergency information and instructions for the public and the media 5bl N N M M Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M Mon / decon of emergency worker equipment 6b1 M Temporary care of evacuees 6c 1 Transportation and treatment of contaminated injured individuals 6d1 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/7)

U >

DATE: 2010-10-05 U oU U SITE: Susquehanna Steam Electric Station, PA U U M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated U zU U 5 o 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 N N N N N Emergency Operations Management Mobilization lal M M M M M M M M M M Facilities IbI Direction andControl lcl M M M M M M M Communications Equipment ldl M M M M M M M M M M Equip & Supplies to support operations lel M M M M M M M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2al M M M M M M M Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c 1 M Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective Action Implementation Implementation of emergency worker exposure control 3al M M M M A M M M M M M Implementation ofKI decision 3b] M M M M M M M M M Implementation of protective actions for special populations - EOCs 3cl M M M M M Implementation of protective actions for Schools 3c2 M M M M M M Implementation of traffic and access control 3d1 M M M M M M M Impediments to evacuation are identified and resolved 3d2 M M M M M M M Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3fl Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laboratory operations 4c /

Emergency Notification and Public Info Activation of the prompt alert and notification system 5al M M M M M M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 M M M M M M Emergency information and instructions for the public and the media 5b 1 M SupportOperations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M Mon / decon of emergency worker equipment 6b 1 M Temporary care of evacuees 6c I Transportation and treatment of contaminated injured individuals 6d1 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/7)

~<

DATE: 2010-10-05 I< U SITE: Susquehanna Steam Electric Station, PA 2 P M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not 22 2 C U U Demonstrated 0 0 0 0 0 0 0 Emergency Operations Management[I Mobilization lal M M M M M I M Facilities lbl Direction and Control lcl M M M M M Communications Equipment ldl M M MMM M M Equip & Supplies to support operations lel M M M M M M M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2al M M M M Radiological Assessment and PARs 2b 1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective ActiOn Implementation,*,

Implementation of emergency worker exposure control 3al M M M M M M M M Implementation of KI decision 3bl M M M M Implementation of protective actions for special populations - EOCs 3cl M M M Implementation of protective actions for Schools 3c2 M M M Implementation of traffic and access control 3d1 M M M M M M Impediments to evacuation are identified and resolved 3d2 M M M M Implementation of ingestion pathway decisions - availability/use of info 3e 1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3"1 Field Measurement and Analysis.

Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b 1 Laboratory operations 4c 1 Emergency otifieation and Public Info Activation of the prompt alert and notification system 5al M M M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5b 1 M M Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M M M Mon / decon of emergency worker equipment 6b 1 Temporary care of evacuees 6c1 M Transportation and treatment of contaminated injured individuals 6d1 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 4/7)

CO2 DATE: 2010-10-05 CIO SITE: Susquehanna Steam Electric Station, PAw -

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not W5o U )

Z U o U0 oU 0 0 W Demonstrated U U U U Emergency Operations Management  : .

Mobilization lal M M N Facilities IbI Direction and Control Icl M M N Communications Equipment ldl M M N Equip & Supplies to support operations lel M M M M M M N M M M Protective Action Decision Making Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2b 1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c 1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective Action Implementation Implementation of emergency worker exposure control 3al M M M M Implementation of KI decision 3bl Implementation of protective actions for special populations - EOCs 3c1 Implementation of protective actions for Schools 3c2 Implementation of traffic and access control 3d1 M M Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3e1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3fl Field Measurement and Analysis,,

Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b 1 Laboratory operations 4c 1 EmArctiv o~iL~ation andPuliItado Activation of the prompt alert and notification system 5a2 Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5bl M M N Support 6pýaiions/FaciliticS Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M M M M M Mon / decon of emergency worker equipment 6bl Temporary care of evacuees 6c0 M M M Transportation and treatment of contaminated injured individuals 6dl 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 5/7)

DATE: 2010-10-05 A V)

SITE: Susquehanna Steam Electric Station, PA 0 :E

< En 0 Q M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated o o0o o Emergency Operations Managemen11" ".l Mobilization lal M M Facilities lbl Direction and Control icl M M Communications Equipment Idl M M Equip & Supplies to support operations lel M M M M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2b 1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c 1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective Action Implementation, ~

Implementation of emergency worker exposure control 3al _ M M M M1 Implementation of KI decision 3b I Implementation of protective actions for special populations - EOCs 36 Implementation of protective actions for Schools 3c2 M M Implementation of traffic and access control 3dl M M Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3e1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3fl Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4bl Laboratory operations 4c0 Emergency Notification and Public In.fo..

Activation of the prompt alert and notification system 5al Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5bl M M Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M M M M Mon / decon of emergency worker equipment 6b 1 Temporary care of evacuees 6c1 M M Transportation and treatment of contaminated injured individuals 6d1 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 6/7)

Con

• 0)

DATE: 2010-10-05 a-SITE: Susquehanna Steam Electric Station, PA Z CnE nE M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not - a >

DemonstratedA o 0 0 0 0 a 0 0 0 O 0 0 0 0 0 0 0 0 0 N Emergency Operations Management :

Mobilization 1al Facilities 1bl Direction and Control 1cl Communications Equipment 1Idl Equip & Supplies to support operations lel Protective Action Decision Making Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective Action Implementation Implementation of emergency worker exposure control 3al Implementation of KI decision 3bl Implementation of protective actions for special populations - EOCs 3c]

Implementation of protective actions/for Schools 3c2 M M M M M M M M M M Implementation of traffic and access control 3d1 Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entr, and return decisions. 3f1 Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b 1 Laboratory operations 4c 1 Emergency Notification and Publ..ic.

Activation of the prompt alert and notification system 5al Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5b 1 Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6b 1 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Temporary care of evacuees 16cl I I I1I 1II 1I1 Transportation and treatment of contaminated injured individuals 6dl Table 3.1 - Summary of Exercise Evaluation (Continued. page 7/7)

DATE: 2010-10-05 SITE: Susquehanna Steam Electric Station, PA M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Z Z Demonstrated N N IN NI N Nj NI N NI NI Emergency Operations Management Mobilization 1 al Facilities IbI Direction and Control ici Communications Equipment 1dl Equip & Supplies to support operations lel Protective Action Decision Making Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective Action ImlAetto Implementation of emergency worker exposure control 3al Implementation of KI decision 3bl Implementation of protective actions for special populations - EOCs 3cd Implementation of protective actions for Schools 3c2 M M M M M M M M M M Implementation of traffic and access control 3d1 Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3e1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3fl Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b 1 Laboratory operations 4c 1 Amctrgnncv Naotifi and PubliceIn cation 5 Activation of the prompt alert and notification system 5a2 Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5bl Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6b 1 Temporary care of evacuees 6c 1 Transportation and treatment of contaminated injured individuals 6d1 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3 Criteria Evaluation Summaries 3.3.1 Pennsylvania Jurisdictions 3.3.1.1 Pennsylvania Emergency Operations Center

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 1.a. 1, 1.c. 1, 1.d. 1, 1.e. 1, 2.a. 1, 2.b.2, 2.c. 1, 5.a. 1, 5.b. 1.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 Pennsylvania Joint Information Center

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 1.a.1, 1.e.1, 5.b.1.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 Pennsylvania Accident Assessment Center, State Emergency Operations Center-Bureau of Radiation Protection

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 1.a. 1, 1.c. 1, 1.e. 1, 2.a. 1, 2.b. 1, 2.b.2.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.1.4 Pennsylvania Bureau of Radiation Protection Activities, Susquehanna Steam Electric Station Emergency Operations Facility

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 3.a.1, 3.b.1.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.5 Pennsylvania Media Operations Center, Wilkes-Barre

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.6 Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Vehicle

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: i.a.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.3.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.7 PA State Field Monitoring Team A, South East Region

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.3.

f. PRIOR ISSUES - RESOLVED: None 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.8 PA State Field Monitoring Team B, South East Region

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 1.a.1, 1.d.1, 1.e.1, 2.a.1, 3.a.1, 3.b.1, 4.a.1, 4.a.3.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.9 Pennsylvania State Traffic and Access Control Points, State Police Barracks Bloomsburg

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2 Risk Jurisdictions 3.3.2.1 Columbia County Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.c.2.

ISSUE NO.: 63-10-3c2-P-01 CRITERION: OROs/school officials decide upon and implement protective actions for schools (NUREG-0654, J.10.c.d.g.)

CONDITION: The school populations referenced in Columbia County Emergency 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Management Agency Radiological Emergency Response Plan were incorrect and the list of private and parochial schools with children who lived inside the 10-mile EPZ was incomplete.

POSSIBLE CAUSE: This data was not verified against the school plans.

REFERENCE:

NUREG 0654 J10.c, d, g Columbia County Emergency Management Agency Radiological Emergency Response Plan, Attachment A, Appendix 14 EFFECT: Incorrect population data could result in a lack of resources at the relocation schools or a lack of buses for evacuation for school districts. Incomplete lists of schools could cause inaccurate accountability of students-and in a lack of notification to parents.

CORRECTIVE ACTION DEMONSTRATED: Columbia County submitted a change to the RERP that eliminated the population data from the table and refers the reader to the appropriate school district plan.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 Columbia County Emergency Worker Monitoring and Decontamination Station, Columbia Montour Vo-Tech School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 36

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.2.3 Columbia County, Berwick Borough/Briar Creek Borough Emergency Operations Center

a. M ET: 1.a. 1, 1.c. 1, 1.d. 1, 1.e. 1, 2.a. 1, 3.a. 1, 3.b. 1, 3.c.2, 3.d. 1, 3.d.2, 5.a. 1, 5.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 3.b.1, 3.c.2.

ISSUE NO.: 63-08-3bl-A-01 ISSUE: The Emergency Operations Center (EOC) received notification from the Columbia County EOC over the radio and telephone that Emergency Workers were to ingest potassium iodide (KI). However, these messages were not passed forward to the Emergency Management Coordinator.

CORRECTIVE ACTION DEMONSTRATED: At 2114 the combined Berwick Borough/Briar Creek Borough Emergency Operations Center (EOC) received Message Number 25 from the Columbia County EOC authorizing evacuation and the decision to take Potassium Iodide (KI). This message was immediately relayed to all staff members in the EOC and they used radios to instruct their field personnel to take their issued tablet (1) of KI. This action resolves previous issue 63-08-3bl-A-01.

ISSUE NO.: 63-08-3c2-A-02 ISSUE: The Emergency Medical Services Representative did not provide Fire/Rescue personnel with contact information for all hearing impaired individuals for their use in route alerting and failed to notify or address other special needs individuals.

CORRECTIVE ACTION DEMONSTRATED: During the SSES 2010 Plume exercise, the Berwick/Briar Creek Borough EOC Medical Services Representative demonstrated to the evaluator that the EOC maintained contact information in accordance with guidance in the 2009 Draft REPP Manual, Page 11-47, for Special 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Needs individuals including, but not limited to: sensory, motor-skills, mental/emotional disabilities; institutionalized settings; elderly, children, diverse cultures; limited or no English-speaking proficiency; transportation disadvantaged; in the EOC Resource Lists. This information was provided to Fire/Rescue personnel for use in route alerting. Actual notifications were simulated in accordance with the Extent of Play. This resolves issue number 63-08-3c2-A-02.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.4 Columbia County, Berwick Borough/Briar Creek Borough Back-up Route Alerting

a. M ET: 1.a.1, 1.d.1, 1.e.l, 2.a.1, 3.a.1, 5.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 5.a.3.

ISSUE NO.: 63-08-5a3-A-03 ISSUE: The crew that demonstrated the Berwick Borough/Briar Creek Borough (BBC) backup alert route (Zone 1) ran the route simulating the use of the vehicle's siren, emergency lights and public address system. After completing the route, the crew was asked to demonstrate the vehicle's emergency notification equipment. The siren and emergency lights tests were satisfactory. However, the volume of the public address system was insufficient to provide adequate carrying power of the message.

The volume was not much louder than ordinary conversation level. Several minutes were spent attempting to raise the volume without success. The crew was advised that if the volume could be raised, a re-demonstration could occur. Eventually, the BBC Emergency Management Director and the Fire/Rescue Officer were informed and agreed that the volume could not be improved.

CORRECTIVE ACTION DEMONSTRATED: Since the route alerting team demonstrated the ability to complete the hearing impaired, as well as back up route alerting, two years ago, in the prescribed time on less than 45 minutes this demonstration was simulated. During the exercise two years ago the public address system was deemed to be not loud enough and ARCA 63-08-5a3-A-03 was issued.

38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station During this demonstration the evaluator was taken to an area where no one would be disturbed and the Public Address System was demonstrated. The evaluator stood approximately 100 yards from the vehicle and could clearly hear the drill message, thus resolving this issue.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.5 Columbia County, North Centre Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.6 Columbia County, North Centre Township Back-up Route Alerting

a. MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 5.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.7 Columbia County, South Centre Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: 3.a.1.

ISSUE NO.: 63-10-3al-A-01 CRITERION: OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers IAW plans and procedures. Emergency workers periodically and at the end of each mission read and record dosimeter reading. (NUREG-0654, K.3) 39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station CONDITION: Emergency workers at the South Centre Township EOC and South Centre Township Traffic and Access Control Points did not read their dosimetry every 30 minutes or record exposure information during the exercise.

POSSIBLE CAUSE: The radiological briefing did not emphasize the importance of periodic reading of dosimetry and no recording form was issued. Although the plans/procedures refer to recording and reporting exposure, they do not specify particular forms or methods.

REFERENCE:

NUREG-0654, K.3.a, b South Centre Township, Columbia County, Radiological Emergency Response Plan, Attachment I "Radiological Protection Services Officer (Operations) Standard Operating Procedures" EFFECT: Emergency workers and traffic control officers could have received radiological exposure in excess of the approved limits.

RECOMMENDATION: South Centre Township should institute a system for ensuring that EW exposure is monitored throughout an incident, including periodic reminders to read dosimetry and provide an exposure recording form for recording the readings.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.8 Columbia County, South Centre Township Traffic and Access Control

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.9 Luzerne County Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.10 Luzerne County Emergency Worker Monitoring and Decontamination Station, Wright Township Volunteer Fire Department

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

b. AREAS REQUIRING CORRECTIVE ACTION: 3.a. 1, 6.a. 1.

ISSUE NO.: 63-10-3al-A-02 CRITERION: OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers IAW plans and procedures. Emergency workers periodically and at the end of each mission read and record dosimeter reading. (NUREG-0654, K.3)

CONDITION: A radiological briefing was not conducted for the Wright Township Fire Department monitoring and decontamination personnel.

POSSIBLE CAUSE: The Wright Township Fire Department (FD), Radiological Emergency Worker Decontamination Station Procedure requires the Radiological Officer to distribute Personal Record Dosimeters (PRD), Dosimetry/KI Report Forms and survey equipment and perform a radiological briefing. Wright Township FD personnel indicated that they were not required to conduct a radiological briefing because the emergency workers at that facility were classified as Category C and were issued only a PRD.

41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

REFERENCE:

NUREG-0654, K.3.a and K.5.a Wright Township Fire Department, Radiological Emergency Worker Decontamination Station Procedure,Section V.B.3, September 2010 EFFECT: A radiological briefing should be conducted to ensure that all workers understand the use of their dosimetry, report forms and use of instrumentation. It should also address monitoring techniques and protocols for managing contaminated individuals, vehicles and equipment. If the briefing is not conducted, less experienced workers may not source check radiological survey instruments properly, monitor correctly or direct decontamination activities effectively.

CORRECTIVE ACTION DEMONSTRATED: During a redemonstration drill on October 21, 2010, the Wright Township Emergency Worker Monitoring and Decontamination Station Incident Commander successfully demonstrated a Radiological Briefing for Pennsylvania Category "C" Emergency Workers. The IC also provided each Emergency Worker with a briefing card that includes the Dosimetry Distribution information, data on Potassium Iodide, Dosimetry Reading, and Exposure Limits as well as instructions on what workers should do upon completion of mission. After the briefing, two emergency workers demonstrated their knowledge and familiarity with exposure control procedures by answering questions and referring to the Radiological Information cards.

ISSUE NO.: 63-10-6al-A-05 CRITERION: Reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers. (NUREG-0654, J. 10.h.,

K.5.b)

CONDITION: A thyroid scan was not conducted on a simulated State Police officer who was monitored with a portal monitor and found to be clean (not contaminated).

42

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station POSSIBLE CAUSE: The Wright Township Fire Department (FD) facility had an outdated flow chart set up that did not include the step to perform a thyroid scan.

Additionally, radiological workers at the FD indicated that they understood the procedure to require a thyroid scan of individuals who were contaminated, but not individuals who were non-contaminated. The Wright Township Fire Department (FD), Radiological Emergency Worker Decontamination Station Procedure states, "Perform thyroid monitoring on non-contaminated or decontaminated Emergency Workers who were exposed or potentially exposed to the plume in accordance with Section 4." Section 4 provides instruction on how to conduct a thyroid scan. It was noted that Appendix 3, Annex A, Tab 2, Attachment A flow chart contained a thyroid monitoring decision block that was not fully understood by the FD staff.

REFERENCE:

NUREG-0654, K.3.a and K.5.a; Wright Township Fire Department, Radiological Emergency Worker Decontamination Station Procedure, Attachment A, Section B.3 and Attachment A flowchart, September 2010 EFFECT: Emergency Workers who have been in the plume could have absorbed enough radioactive iodine in their thyroid to warrant follow up evaluation even if they were below the contamination screening requirement for external contamination using a portal monitor.

CORRECTIVE ACTION DEMONSTRATED: A Pennsylvania Emergency Management Agency (PEMA) representative called a "time out" and conducted training on the requirement to conduct a thyroid scan on emergency workers who were exposed or potentially exposed to the plume. The Wright Township FD emergency worker appropriately redemonstrated performing a thyroid scan on the non-contaminated emergency worker.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.11 Luzerne County, Conyngham Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: 3.b. 1, 5.a.3.

ISSUE NO.: 63-10-3bl-A-04 CRITERION: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the admin of KI for emergency workers and institutionalized individuals (not general public) is maintained. (NUREG-0654, E.7., J.10.e.f.)

CONDITION: The Conyngham Township Emergency Operations Center (EOC) staff and emergency field workers did not simulate the ingestion of Potassium Iodide (KI) when directed by the proper authority in the Luzerne County EOC.

POSSIBLE CAUSE: The message announcing a General Emergency and directing the administration of KI was misinterpreted by the Township's EOC staff to wait until further direction and approval from the Pennsylvania Secretary of Public Health, through proper channels, rather than immediately administering KI as intended. This interpretation is different from expectations contained in the Township's Radiological Emergency Response Plan and Standard Operation Procedures.

REFERENCE:

NUREG-0654/FEMA REP-1, J.10.e; Conyngham Township Radiological Emergency Response Plan, Attachment 1-3 page 13 of 16; and Conyngham Township Standard Operating Procedure-B page 3 of 7 EFFECT: Emergency workers may have received higher internal radiological dose than if they had simulated ingested KI when directed.

CORRECTIVE ACTION DEMONSTRATED: Conyngham Township EOC successfully re-demonstrated this criterion on October 7, 2010 by receiving a General Emergency message from Luzerne County EOC and announcing the decision to 44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station administer Potassium Iodide Emergency Workers and the General Public (KI) to the EOC Staff. The EOC manager thensimulated directing the communications officer to notify all deployed Emergency Workers to take KI in accordance with their Radiological Briefing.

ISSUE NO.: 63-10-5a3-A-03 CRITERION: Activities associated with FEMA approved exception areas are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup A&N of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary A&N system. (NUREG-0654, E.6., Appendix 3.B.2.c)

CONDITION: The criterion requires that back-up route alerting be completed within 45 minutes. Conyngham Township EOC did not adequately demonstrate back-up route alerting.

POSSIBLE CAUSE: The Conyngham Township EOC had not planned to provide an actual demonstration of back-up route alerting through Sector 2 because fire personnel, who normally conduct this function with their fire equipment, were not scheduled to participate in the exercise.

REFERENCE:

NUREG-0654, E.6 FEMA-REP-1, Appendix 3.B.2.c EFFECT: The back-up route alerting process due to a siren failure would not have provided residents of Sector 2 with information about an emergency situation within the prescribed time.

CORRECTIVE ACTION DEMONSTRATED: Conyngham Township Emergency Management in coordination with SSES Off-site Emergency Planning revised and edited the RERP by redefining the boundries of the Route Alert Sectors. There are now 4 sectors.

45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station In a redemonstration route alert drill on October 21, 2010, Conyngham Township Volunteer Fire Department successffully completed route in Sector #2 (Pond Hill) in 40 minutes driving at a reasonable speed to facilitate notification of the residents in the Sector.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.12 Luzerne County, Conyngham Township Back-up Route Alerting

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.13 Luzerne County, Dorrance Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.14 Luzerne County, Hollenback Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.15 Luzerne County, Nanticoke City Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.16 Luzerne County, Nanticoke City Traffic and Access Control

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.17 Luzerne County, Slocum Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.3 Support Jurisdictions 3.3.3.1 Lackawanna County Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.2 Lackawanna County Reception Center, Big Lots Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.3 Lackawanna County Monitoring and Decontamination Center, Scranton/Dunmore YMCA

a. MET: 1.e.1, 3.a.1, 6.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.4 Lackawanna County Mass Care Center, Dunmore YMCA

a. MET: 1.e.1, 6.a.1, 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.5 Lycoming County Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.6 Lycoming County Reception Center, Lycoming Mall

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.7 Lycoming County Monitoring and Decontamination Center, Hughesville High School

a. MET: 1.e.1, 3.a.1, 6.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.3.8 Lycoming County Mass Care Center, Hughesville High School

a. MET: 1.e.1,6.a.1,6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.9 Montour County Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 5.b.1.

ISSUE NO.: 63-10-5b1-P-02 CRITERION: 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, G.4.a.b.c)

CONDITION: The power plant named in the Montour County pre-scripted press releases is incorrect.

POSSIBLE CAUSE: The error was not identified during the last plan review.

REFERENCE:

NUREG-0654, E.5., 7., G.3.a, G.4.a.b.c Montour County Emergency Management Agency (Nuclear/Radiological Incident Plan) Appendix 3, Attachment A, paragraphs 1 and 2 EFFECT: Press releases could result in media or public misunderstanding.

CORRECTIVE ACTION DEMONSTRATED: Montour County Emergency Mangement provided a copy of the page change to the pre-scripted media release that corrected the name of the utility. Copies of the changed page have been 50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station disseminated to all holders of the plan.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.10 Northumberland County Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.11 Northumberland County Reception Center, Shikellemy High School, Sunbury

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.12 Northumberland County Monitoring and Decontamination Center, Shikellemy High School - Sunbury

a. MET: 1.e.1, 3.a.1, 6.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 6.a. 1.

ISSUE NO.: 63-06-6al-A-04 ISSUE: No "Range of Readings" sticker was affixed to the side of the survey 51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station instrument indicating acceptance criterion for a souce check.

CORRECTIVE ACTION DEMONSTRATED: A range of readings was affixed to each hand-held survey meter. Operational checks were performed and compared to the readings on the labels.

ISSUE NO.: 63-06-6al-A-05 ISSUE: Contrary to the Extent of Play, the same player demonstrated all 3 monitoroing tasks at the facility: portal monitor, survey meter monitoring of the contaminate individual, and vehicle monitoring. In an actual event one person would not be able to perform requrere tasks simultaneously.

CORRECTIVE ACTION DEMONSTRATED: Six trained monitoring personnel were at the facility. Five demonstrated radiological monitoring, each at a separate monitoring station.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.13 Northumberland County Mass Care Center, Shikellemy High School - Sunbury

a. MET: 1.e.1, 6.a.1, 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.14 Schuylkill County Emergency Operations Center

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: L.a.1, 1.c.1, 1.d.1, 1.e.1, 5.b.1.

52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.15 Schuylkill County Reception Center, Marian High School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.16 Schuylkill County Mass Care Center, Marian High School

a. MET: 1.e.1, 6.a.1, 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.17 Schuylkill County Monitoring and Decontamination Center, Marian High School

a. MET: 1.e.1, 3.a.1, 6.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.18 Union County Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.19 Union County Reception Center, Montandon Elementary School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.20 Union County Monitoring and Decontamination Center, Lewisburg Area High School

a. MET: 1.e.1, 3.a.1, 6.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.21 Union County Mass Care Center, Lewisburg Area High School

a. MET: 1.e.1,6.a.1,6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 54

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.3.22 Wyoming County Emergency Ooperations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.23 Wyoming County Reception Center, Tunkahannock Middle School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.24 Wyoming County Monitoring and Decontamination Center, Tunkahannock Middle School

a. MET: 1.e.1, 3.a.1, 6.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.25 Wyoming County Mass Care Center, Tunkahannock Middle School

a. MET: 1.e.1, 6.a.1, 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None 55

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.26 Columbia County, Benton Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.27 Columbia County, Benton Area School District, Benton Area Middle/High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.28 Columbia County, Berwick Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.29 Columbia County, Berwick Area School District, Nescopeck Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 56

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.30 Columbia County, Berwick Area School District, Salem Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.c.2.

ISSUE NO.: 63-10-3c2-P-04 CRITERION: OROs/school officials decide upon and implement protective actions for schools (NUREG-0654, J.10.c.d.g.)

CONDITION: The Berwick Area School District and the Columbia County plans identify different host schools for Salem Elementary School.

POSSIBLE CAUSE: The inconsistency was not identified during the last review and update of the plans.

REFERENCE:

NUREG-0654 J. 10.g.j.

Radiological Emergency Response Plan for the Berwick Area School District for Incidents at the Susquehanna Steam Electric Station (August 9, 2010), page 10 Columbia Country Radiological Emergency Response Plan to Nuclear Power Plant Incidents (March 2010), page 8 EFFECT: The public and students' parents could be confused about where the students were evacuated.

CORRECTIVE ACTION DEMONSTRATED: The discrepancy was in the Columbia County Radiological Emergency Response Plan. The Berwick Area School District plan correctly identifies Liberty Elementary School as the host school. A change to the Columbia County RERP resolved this planning issue.

57

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.31 Columbia County, Bloomsburg Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.32 Columbia County, Bloomsburg Area School District, Bloomsburg High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.33 Columbia County, Bloomsburg Area School District, Bloomsburg Area Middle School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 58

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station 3.3.3.34 Columbia County, Central Columbia School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.35 Columbia County, Central Columbia School District, Central Columbia Middle School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.36 Columbia County, Columbia-Montour Area Vocational Technical School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.37 Luzerne County, Crestwood School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None 59

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.38 Luzerne County, Crestwood School District, Rice Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.39 Luzerne County, Greater Nanticoke Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.40 Luzerne County, Greater Nanticoke Area School District, K.M. Smith Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.41 Luzerne County, Greater Nanticoke Area School District, Greater Nanticoke Education Center

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None 60

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.42 Luzerne County, Hazleton Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.43 Luzerne County, Hazelton Area School District, Valley Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.44 Luzerne County, Northwest Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.c.2.

ISSUE NO.: 63-10-3c2-P-03 CRITERION: OROs/school officials decide upon and implement protective actions for schools (NUREG-0654, J.10.c.d.g.)

CONDITION: The Northwest Area School District Plan is not current.

61

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station POSSIBLE CAUSE: Garrison Memorial Elementary was closed and other schools were renamed, consolidated, and reconfigured. The plan was not updated with the correct information.

REFERENCE:

NUREG 0654 Section P.4 Northwest Area School District Plan Radiological Emergency Response Plan EFFECT: Inaccurate information may be released and students' parents could go to the wrong locations to pick up children after an evacuation.

CORRECTIVE ACTION DEMONSTRATED: Northwest Area School District provided an update and revision of the Radiological Response Plan that corrects the erroneous information.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.45 Luzerne County, Northwest Area School District, Huntington Mills Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.46 Luzerne County, West Side Area Vocational - Technical School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 62

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.47 Luzerne County, Wilkes-Barre Area Vocational - Technical School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 63

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station SECTION 4: CONCLUSION As stated before, the State and local emergency management organizations displayed a knowledge of their emergency plans and procdures and adequately implemented them, thereby demonstrating reasonable assurance that those agencies can respond and protect the health, lives and property of the residents of the SSES Emergenccy Planning Zone.

64

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station APPENDIX A: IMPROVEMENT PLAN IsueNumberII'* 63-10i3l-AI-0ll1 Crtrin 3a ISSUE: Emergency workers at the South Centre Township EOC and South Centre Township Traffic and Access Control Points did not read their dosimetry every 30 minutes or record exposure information during the exercise.

RECOMMENDATION: South Centre Township should institute a system for ensuring that EW exposure is monitored throughout an incident, including periodic reminders to read dosimetry and provide an exposure recording form for recording the readings.

CORRECTIVE ACTION DESCRIPTION: After discussion with county and utility leaders and after careful consideration concerning the matter, the Commonwealth of Pennsylvania believes that the root cause of the matter rests either in a failure of education of the Radiological Officers and field personnel or a failure of the Radiological Officers and field personnel to follow the procedures given. The first priority would be to strengthen training to emphasis the need to do 30 minute dosimetry readings once the equipment is issued. Secondary priority would be a training emphasis for the EOC Radiological Officer to be more cognizant of the need for 30 minute dosimetry checks and to consider methods they could utilize to remind personnel at the appropriate times such as the use of timers/alarms.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Weapons of Mass Destruction (WMD) and Hazardous Pennsylvania Emergency Management Agency Materials (HazMat) Response and Decontamination CAPABILITY ELEMENT: START DATE:

Training 2011-01-01 AGENCY POC: ESTIMATED COMPLETION DATE:

Laurin Fleming 717-651-2119 2012-10-01 65

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station APPENDIX B: EXERCISE TIMELINE The tables on the following pages present the times at which key events and activities occured during the SSES exercise on October 5, 2010. Also included are times notifications were made to the participating jurisdictions and functional entities.

Table 1 - Exercise Timeline DATE: 2010-10-05, SITE: Susquehanna Steam Electric Station, PA Unusual Event 1630 N/A 1643 N/A 1640 1637 1651 Alert 1725 1744 1744 N/A 1735 1734 1745 Site Area Emergency 1832 1850 1847 1832 1838 1845 1851 General Emergency 2026 2043 2032 2026 2030 2033 2045 Simulated Rad. Release Started 1630 1647 1643 1728 1644 1637 1642 Simulated Rad. Release N/A N/A N/A N/A N/A N/A N/A Terminated Facility Declared Operational 1749 1749 1826 1813 1800 1826 Governor's Declaration of State of Emergency 1905 1905 1919 1955 1916 2011 Local Declaration of State of Emergency N/A N/A N/A 1854 1837 1840 Exercise Terminated 2202 2158 2155 2155 2204 2147 Precautionary Actions: Restrict Airspace 1905 1905 1956 1916 1916 1909 Restrict Rail Traffic 1905 1905 1956 N/A 1916 1909 Restrict Water Traffic 1902 1905 1956 N/A 1916 1909 Shelter livestock, place on stored feed 1902 1905 1956 N/A 1925 1909 1st A & N Decision 1905 1905 N/A 1907 1907 1915 Stay tuned to EAS radio stations N/A N/A N/A N/A N/A N/A 1st Siren Activation N/A N/A N/A N/A N/A N/A 1st EAS Message N/A N/A N/A N/A N/A N/A 2nd A & N Decision 2100 2101 N/A N/A 2105 N/A Evacuate 360 degrees to 10 miles 2100 2101 N/A N/A 2105 N/A 2nd Siren Activation N/A N/A N/A N/A N/A N/A 2nd EAS Meassage N/A N/A N/A N/A N/A N/A KI Adminstration Decision: Emergency Workers 2100 2101 2145 2117 2105 2114 KI Adminstration Decision: General Public 2100 2101 2145 2117 2105 2114 KI Administration Decision: EWs and General N/A N/A N/A N/A N/A N/A Public advised NOT to take KI I 66

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 1 - Exercise Timeline DATE: 2010-10-05, SITE: Susquehanna Steam Electric Station, PA Emergency Classification ey OF 3l E U U UnusualGeea4Eegnc Event 06 1630 01 1649 202 1715 23 1637 204 1648 201 N/A 24 1650 Alert 1725 1743 1755 1732 1745 1741 1741 Site Area Emergency 1832 1847 1848 1841 1845 1845 1848 General Emergency 2026 2041 2042 2034 2042 2041 2042 Simulated Rad. Release Started 1630 1757 1732 1637 1648 1750 1650 Simulated Rad. Release N/A N/A N/A N/A N/A N/A N/A Terminated Facility Declared Operational 1725 1730 1751 1820 1823 1748 Governor's Declaration of State of Emergency 1915 1918 1908 N/A 2003 2004 Local Declaration of State of Emergency 1909 1840 N/A N/A N/A N/A Exercise Terminated 2130 2150 2204 2205 2205 2145 Precautionary Actions: Restrict Airspace 1917 1920 1910 N/A N/A N/A Restrict Rail Traffic 1917 N/A 1910 N/A N/A N/A Restrict Water Traffic 1917 N/A 1908 N/A N/A N/A Shelter livestock, place on stored feed 1939 1856 1906 1922 1920 2145 1st A & N Decision 1918 1918 1905 2108 1918 1918 Stay tuned to EAS radio stations N/A N/A N/A N/A N/A N/A 1st Siren Activation N/A N/A 1915 N/A N/A N/A I st EAS Message N/A N/A 1918 N/A N/A N/A 2nd A & N Decision 2111 N/A 2105 N/A 2108 2110 Evacuate 360 degrees to 10 miles 2111 N/A 2105 N/A N/A N/A 2nd Siren Activation N/A N/A 2110 N/A N/A N/A 2nd EAS Meassage N/A N/A 2115 N/A N/A N/A KI Adminstration Decision: Emergency Workers 2111 2114 2118 N/A 2108 2110 KI Adminstration Decision: General Public 2111 2114 2102 N/A 2108 2110 KI Administration Decision: EWs and General N/A N/A N/A N/A N/A N/A Public advised NOT to take KI 67

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 1 - Exercise Timeline DATE: 2010-10-05, SITE: Susquehanna Steam Electric Station, PA Emergency Classification Level o "

U Unusual Event 1630 1646 N/A 1658 1659 1658 1647 Alert 1725 1747 1638 1748 1747 1759 1754 Site Area Emergency 1832 1849 1748 1849 1856 1850 1857 General Emergency 2026 2042 2042 2048 2047 2047 2049 Simulated Rad. Release Started 1630 1646 1638 1638 1659 1730 1647 Simulated Rad. Release N/A N/A N/A N/A N/A N/A N/A Terminated Facility Declared Operational 1800 1709 1800 1858 1728 1823 Governor's Declaration of State of Emergency 2002 2004 1937 1922 1929 1924 Local Declaration of State of Emergency N/A N/A N/A 1925 1936 1935 Exercise Terminated 2140 2123 2159 2120 2234 2150 Precautionary Actions: Restrict Airspace N/A N/A N/A 1932 2004 N/A Restrict Rail Traffic N/A N/A N/A 1932 2004 N/A Restrict Water Traffic N/A N/A N/A 1932 2004 N/A Shelter livestock, place on stored feed 1920 1920 1910 1905 1917 1930 1st A & N Decision 1911 1905 N/A 1922 1922 N/A Stay tuned to EAS radio stations N/A N/A N/A N/A N/A N/A 1st Siren Activation N/A N/A N/A N/A N/A N/A 1st EAS Message N/A N/A N/A N/A N/A N/A 2nd A & N Decision 2109 2109 2105 2105 2105 2105 Evacuate 360 degrees to 10 miles N/A N/A N/A N/A N/A N/A 2nd Siren Activation N/A N/A N/A N/A N/A N/A 2nd EAS Meassage N/A N/A N/A N/A N/A N/A KI Adminstration Decision: Emergency Workers 2109 2109 2105 2105 2105 2105 KI Adminstration Decision: General Public 2109 2109 2105 2105 2105 2105 KI Administration Decision: EWs and General N/A N/A N/A N/A N/A N/A Public advised NOT to take KI 68

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Table 1 - Exercise Timeline DATE: 2010-10-05, SITE: Susquehanna Steam Electric Station, PA Emergency Classification Level or U Event 0 0

Unusual Event 1630 1647 Alert 1725 1754 Site Area Emergency 1832 1858 General Emergency 2026 2043 Simulated Rad. Release Started 1630 1647 Simulated Rad. Release Terminated N/A N/A Facility Declared Operational 1815 Governor's Declaration of State of Emergency 1915 Local Declaration of State of Emergency N/A Exercise Terminated 2200 Precautionary Actions: Restrict Airspace 1925 Restrict Rail Traffic N/A Restrict Water Traffic N/A Shelter livestock, place on stored feed 1938 1st A & N Decision N/A Stay tuned to EAS radio stations N/A 1st Siren Activation N/A 1st EAS Message N/A 2nd A & N Decision 2105 Evacuate 360 degrees to 10 miles N/A 2nd Siren Activation N/A 2nd EAS Meassage N/A KI Adminstration Decision: Emergency Workers 2105 KI Adminstration Decision: General Public 2105 KI Administration Decision: EWs and General Public N/A advised NOT to take KI 69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leaders for the SSES 2010 Plume Exercise evaluated on October 5 and 6, 2010. The following consitutes the managing staff for the Exercise Evaluation:

Darrell Hammons, DHS, Radiological Assistance Committee Chairman Barton Freeman, DHS, Exercise Evaluation Program Manager and Site Specialist John Price,DHS, Team Leader, Pennsylvania Emergency Operations Center Martin Vyenielo, DHS, Team Leader,, Luzerne County Emergency Operations Center Robert Neff, DHS, Team Leader, Columbia County, Emergency Operations Center Richard Kinard, DHS, Team Leader, Technical Evaluations Joseph Suders, DHS, Team Leader, Out of Sequence Events - Schools, Reception, Mass Care Andrew Hower, DHS, Team Leader, Support County Emergency Operations Centers Also, the following personnel evaluated locations as representatives of the Radiological Assistance Committee:

Richard Barkley, US Nuclear Regulatory Commission James Ostaszewski, US Department of Transportation, Federal Aviation Administration Marcos Aquino, US Environmental Protection Agency Additional evaluation assistance was provided by FEMA Regions I and II by providing the following Radiological Emergency Preparedness Program personnel:

Bob Swartz, Region I Patricia Mason, Region II Christopher Cammarata, Region II Miriam Weston, Region II Laura Forrest, Region II Brian Hasemann, Region II 70

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station DATE: 2010-10-05, SITE: Susquehanna Steam Electric Station, PA LOCATION EVALUATOR AGENCY Pennsylvania Emergency Operations Center Paul Cormier ICF

• John Price FEMA RIll Pennsylvania Joint Information Center Paul Cormier ICF Pennsylvania Accident Assessment Center, State Emergency *Richard Kinard FEMA RII1 Operations Center-Bureau of Radiation Protection Pennsylvania Bureau of Radiation Protection Activities, Susquehanna Reggie Rodgers ICF Steam Electric Station Emergency Operations Facility Pennsylvania Media Operations Center, Wilkes-Barre Roger Kowieski NTHMC Pennsylvania Bureau of Radiation Protection, Radiological Rapid *Richard Kinard FEMA RIII Response Vehicle PA State Field Monitoring Team A, South East Region *Richard Kinard FEMA RIII PA State Field Monitoring Team B, South East Region *Richard Kinard FEMA RIII Pennsylvania State Traffic and Access Control Points, State Police Michael Meshenberg ICF Barracks Bloomsburg Columbia County Emergency Operations Center Joseph Keller ICF

• Robert Neff FEMA RIII Roy Smith ICF Wendy Swygert ICF Columbia County Emergency Worker Monitoring and Ronald Biemacki ICF Decontamination Station, Columbia Montour Vo-Tech School Columbia County, Berwick Borough/Briar Creek Borough Emergency John Flynn ICF Operations Center Tina Lai - FEMA RI11 Columbia County, Berwick Borough/Briar Creek Borough Back-up John Flynn ICF Route Alerting Columbia County, North Centre Township Emergency Operations Thomas Hegele ICF Center Patricia Mason FEMA RII Columbia County, North Centre Township Back-up Route Alerting Thomas Hegele ICF Columbia County, South Centre Township Emergency Operations Laura Forrest FEMA RII Center Elizabeth Haney ICF Columbia County, South Centre Township Traffic and Access Control Elizabeth Haney ICF Luzeme County Emergency Operations Center James McClanahan ICF Michael Shuler FEMA RIII

• Martin Vyenielo FEMA RIII Luzeme County Emergency Worker Monitoring and Decontamination Marcy Campbell ICF Station, Wright Township Volunteer Fire Department Luzeme County, Conyngham Township Emergency Operations Center Robert Black ICF Robert Lemeshka ICF Luzerne County, Conyngham Township Back-up Route Alerting Robert Lemeshka ICF Luzeme County, Dorrance Township Emergency Operations Center Quirano Iannazzo ICF Bob Swartz FEMA RI Luzeme County, Hollenback Township Emergency Operations Center Marcos Aquino EPA RPII Rosemary Samsel ICF Luzeme County, Nanticoke City Emergency Operations Center Henry Christiansen ICF Kent Tosch ICF Luzeme County, Nanticoke City Traffic and Access Control Kent Tosch ICF Luzeme County, Slocum Township Emergency Operations Center Michael Bums ICF Robert Gantt ICF Lackawanna County Emergency Operations Center Miriam Weston FEMA RII Lackawanna County Reception Center, Big Lots Center Tina Lai FEMA Ri 71

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Lackawanna County Monitoring and Decontamination Center, Nicholas DePierro ICF Scranton/Dunmore YMCA Lackawanna County Mass Care Center, Dunmore YMCA Nicholas DePierro ICF Lycoming County Emergency Operations Center Brian Hasemann FEMA RII Lycoming County Reception Center, Lycoming Mall Daryl Thome ICF Lycoming County Monitoring and Decontamination Center, Ronald Bonner ICF Hughesville High School Lycoming County Mass Care Center, Hughesville High School Daryl Thome ICF Montour County Emergency Operations Center Bernie Hannah ICF Northumberland County Emergency Operations Center Christopher Cammarata FEMA RII Northumberland County Reception Center, Shikellemy High School, Robert Jeffries ICF Sunbury Northumberland County Monitoring and Decontamination Center, Sonia Eischen ICF Shikellemy High School - Sunbury Northumberland County Mass Care Center, Shikellemy High School - Robert Jeffries ICF Sunbury Schuylkill County Emergency Operations Center Administrative Evaluator Schuylkill County Reception Center, Marian High School William Palmer ICF Schuylkill County Mass Care Center, Marian High School William Palmer ICF Schuylkill County Monitoring and Decontamination Center, Marian David Jacobson ICF High School Union County Emergency Operations Center James Ostaszewski DOT/FAA Union County Reception Center, Montandon Elementary School David Petta ICF Union County Monitoring and Decontamination Center, Lewisburg Reggie Rodgers ICF Area High School Union County Mass Care Center, Lewisburg Area High School David Petta ICF Wyoming County Emergency Ooperations Center Richard Barkley Nuclear Regulatory Commission, Region I Wyoming County Reception Center, Tunkahannock Middle School Kim Wood ICF Wyoming County Monitoring and Decontamination Center, Keith Earnshaw ICF Tunkahannock Middle School Wyoming County Mass Care Center, Tunkahannock Middle School Kim Wood ICF Columbia County, Benton Area School District Paul Cormier ICF Columbia County, Benton Area School District, Benton Area Paul Cormier ICF Middle/High School Columbia County, Berwick Area School District Nicholas DePierro ICF Columbia County, Berwick Area School District, Nescopeck Nicholas DePierro ICF Elementary School Columbia County, Berwick Area School District, Salem Elementary Daryl Thome ICF School Columbia County, Bloomsburg Area School District Ronald Bonner ICF Columbia County, Bloomsburg Area School District, Bloomsburg Ronald Bonner ICF High School Columbia County, Bloomsburg Area School District, Bloomsburg Ronald Bonner ICF Area Middle School Columbia County, Central Columbia School District Robert Jeffries ICF Columbia County, Central Columbia School District, Central Robert Jeffries ICF Columbia Middle School 72

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Columbia County, Columbia-Montour Area Vocational Technical Sonia Eischen ICF School Luzerne County, Crestwood School District William Palmer ICF Luzeme County, Crestwood School District, Rice Elementary School William Palmer ICF Luzerne County, Greater Nanticoke Area School District David Jacobson ICF Luzerne County, Greater Nanticoke Area School District, K.M. Smith David Petta ICF Elementary School Luzerne County, Greater Nanticoke Area School District, Greater David Jacobson ICF Nanticoke Education Center Luzerne County, Hazleton Area School District Larry Harrington ICF Luzerne County, Hazelton Area School District, Valley Elementary Larry Harrington ICF School Luzerne County, Northwest Area School District Kim Wood ICF Luzerne County, Northwest Area School District, Huntington Mills Kim Wood ICF Elementary School Luzerne County, West Side Area Vocational - Technical School Keith Earnshaw ICF Luzerne County, Wilkes-Barre Area Vocational - Technical School Ronald Biemacki ICF

• Tcam Leaderi 73

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station APPENDIX D: ACRONYMS AND ABBREVIATIONS AD Administrative Director ALARA As Low As Reasonably Achievable ARC American Red Cross ARES Amateur Radio Emergency Services BASD Bloomsburg Area School District CART County Animal Rescue Team CCEMA Columbia County Emergency Management Agency CCEMO Colombia County Emergency Management Office CCEOC Columbia County Emergency Operations Center CCSD Central Columbia School District CDE Committed Dose Equivalent CEB County Emergency Board CHS Crestwood High School CMC Community Medical Center CSD Crestwood School District DEMC Deputy Emergency Management Coordinator DRD Direct Reading Dosimeter DT Dorrance Township DTEMA Dorrance Township Emergency Management Agency DTEOC Dorrance Township Emergency Operations Center DVD Digital Video Disk EAL Emergency Action Level EAS Emergency Alert System ECL Emergency Classification Level EDRD Electronic Direct Reading Dosimeter EM Emergency Manager EMA Emergency Management Agency EMC Emergency Management Coordinator EMD Emergency Management Director EMS Emergency Medical Service EOC Emergency Operations Center EOP Emergency Operations Plan EPZ Emergency Planning Zone ESF Emergency Support Function 74

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station EW Emergency Worker FAC Food Agriculture Council FD Fire Department FEMA Federal Emergency Management Agency GE General Emergency HMES Huntington Mills Elementary School HMSO Health Medical Services Officer IC Incident Commander JIC Joint Information Center LAHS Lewisburg Area High School LCEMA Luzerne County Emergency Management Agency LCEOC Lycoming County Emergency Operations Center LHS Lewisburg High School MCEOC Montour County Emergency Operations Center MES Montandon Elementary School MHSMCC Marian High School Mass Care Center MHSRC Marian High School Reception Center MOC Media Operations Center NRC Nuclear Regulatory Commission PA Public Address PAD Protective Action Decision PAR Protective Action Recommendation PEMA Pennsylvania Emergency Management Agency PIM Public Information Manager PIO Public Information Officer PPHD Pennsylvania Public Health Department PRD Permanent Record Dosimeters PSP Pennsylvania State Police RAC Radiological Assistance Committee RACES Radio Amateur Civil Emergency Service RCM Reception Center Manager REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RES Rice Elementary School RO Radiological Officer RSO Radiation Safety Officer RTES Rush Township Emergency Services SAC Staging Area Commander SAE Site Area Emergency SCEMA Schuylkill County Emergency Management Agency 75

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station SCTEOC South Centre Township Emergency Operations Center.

SES Smith Elementary School SESS Susquehanna Electric Steam Station SEVAN State Emergency Voice Alerting Network SOP Standard Operating Procedure SSES Susquehanna Steam Electric Station TC Transportation Coordinator TCP Traffic Control Points TEDE Total Effective Dose Equivalent UC Union County UCMCC Union County Mass Care Center UCRC Union County Reception Center VHF Very High Frequency 76

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station APPENDIX E: EXERCISE PLAN The enclosed Exercise Plan was created as an overall tool for facilitation and implementation of the SSES 2010 Plume Exercise and to integrate the concepts and policies of the Homeland Security Exercie Evaluation Program with the Radiological Emergency Preparedness Program Exercise Methodology. The Exercise Plan was originally drafted and published by the Pennsylvania Emergency Agency (PEMA) as a independent document and is annexed here.

The "Susquehanna Steam Electric Station Extent of Play 2010 Radiological Emergency Preparedness Exercise" was negotiated and agreed upon by FEMA Region III, PEMA, and the emergnecy management agencies of the Risk and Support Counties. It is included as an Appendix of the Exercise Plan.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station U.S. DEPARTMENT OF HOMELAND SECURITY

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Homeland Security Exercise and Evaluation Program (HSEEP)

ExPlan 2010 SUSQUEHANNA STEAM ELECTRIC STATION PLUME EXERCISE PREFACE The 2010 Susquehanna Steam Electric Station Plume Exercise Evaluated Full Scale Exercise (FSE) is sponsored by the Federal Emergency Management Agency (FEMA) and the Pennsylvania Emergency Management Agency (PEMA). This Exercise Plan (ExPlan) was produced with input, advice, and assistance from the Exercise Planning Team (EPT), which followed the guidance set forth in the Federal Emergency Management Agency, Homeland Security Exercise and Evaluation Program (HSEEP).

The ExPlan gives officials, observers, media personnel, and players from participating organizations the information necessary to observe or participate in a nuclear power plant accident response exercise focusing on participants' emergency response plans, policies, and procedures as they pertain to this type of event. The information in this document is current as of the date of publication and is subject to change as dictated by the EPT.

The 2010 Susquehanna Steam Electric Station Plume Exercise is an unclassifiedexercise. The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, Controllers, and Evaluators, but Players may view other materials deemed necessary to their performance. The ExPlan may be viewed by all exercise participants, but the Controllerand Evaluator (C/E) Handbook is a restricteddocument intendedfor Controllers and Evaluatorsonly.

All exercise participants should use appropriate guidelines to ensure the proper control of information within their areas of expertise and to protect this material in accordance with current jurisdictional directives. Public release of exercise materials to third parties is at the discretion of DHS and the EPT.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station HANDLING INSTRUCTIONS

1. The title of this document is the 2010 SusquehannaSteam Electric Station Plume Exercise Plan (ExPlan).

2. The information gathered in this ExPlan is For Official Use Only (FOUO)and should be handled as sensitive information not to be disclosed. This document should be safeguarded, handled, transmitted, and stored in accordance with appropriate security directives.

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

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

4. For more information, please consult the following points of contact (POCs):

Federal POC(s):

Barton Freeman Emergency Management Program-Specialist Federal Emergency Management Agency 615 Chestnut Street Philadelphia, Pa 19106-4404 215-931-5567 Barton.freeman@dhs.gov State POC(s):

Jesse Wells Emergency Management Specialist Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, Pa. 17110 717-651-2190 jewells@state.pa.us ORO POC(s):

Laurin Fleming Emergency Management Specialist Pernsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, Pa. 17110 717-651-2119 laufleming@state.pa.us 82

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After Action Report/Improvement Plan Susquehanna Steam Electric Station TABLE OF CONTENTS Exercise Plan ............................................ 78 SUSQUEHANNA STEAM ELECTRIC STATION FEMA EVALUATED REP EXERCISE .......

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

Preface ............................................................................................................... 80 Handling Instructions .................................................................................. 82 Chapter 1: General Information ................................................................... 85 Introd uctio n ......................................................................................... . . 85 Confidentiality ................................................... 85 Purpose ........................................................ 85 Target Capabilities ................................................ 86 Exercise Objectives ................................................................................ 86 Outstanding Issues ................................................................................ 87 Chapter 2: Exercise Logistics ................................. 88 Exercise Summary .................................................................................. 88 G enera l .................................................................................................................................. 88 A ssump tion s .......................................................................................................................... 88 Constructs and Constraints ........................................... 89 Exercise Participants ............................................... 89 Exercise T ools ....................................................................................... 90 Controller and Evaluator Handbook .................................................................................. 90 M aster Scenario Events List .............................................................................................. 90 Exercise Implementation ......................................................................... 91 E xercise Play ......................................................................................................................... 91 E xercise Rules ....................................................................................................................... 91 Safety Requirements ............................................................................... 91 G enera l .................................................................................................................................. 91 Exercise S etup ......................................................................................... 92 Accident Reporting and Real Emergencies ............................................... .... 92 S ite Access .............................................................................................. 92 S ecurity ................................................................................................................................. 93 PEMA Observers and Liaison Officers .............................................................................. 93 Parking and D irections ..................................................................................................... 94 R estroom Facilities .......................................................................................................... . . 94 Exercise Identification ............................................. 94 83

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After Action Report/Improvement Plan Susquehanna Steam Electric Station TABLE OF CONTENTS Communications Plan ............................................................................ 94 Exercise Start, Suspension, and Termination Instructions ............................................... 94 Player C ommunication .................................................................................................... 94 P lay er Briefin g ...................................................................................................................... 95 P ub lic Affairs ........................................................................................................................ 95 Chapter 3: Player Guidelines .................... I.................................................. 96 Exercise Staff ........................................................................................ 96 T ru sted A gents ..................................................................................................................... 96 L ead C ontroller ..................................................................................................................... 96 Co ntro llers ............................................................................................................................. 97 L ead E v alu ator ...................................................................................................................... 97 E v alu ato rs .............................................................................................................................. 97 Player Instructions ................................................................................ 97 B efore the Exercise ........................................................................................................ .. 97 During the E xercise ........................................................................................................ .. 98 Follow ing the E xercise ..................................................................................................... . 98 Simulation Guidelines ............................................................................. 99 Chapter 4: Evaluation and Post-Exercise Activities .................................... 100 Exercise Docum entation ........................................................................... 100 Exercise Evaluation G uides ........................................................................ 100 De b riefin g ............................................................................................... 10 0 Ho tw a sh ................................................................................................. 10 0 Participants and Public/Media Briefings ....................................................... 101 A fter Action Report ................................................................................... 10 1 After Action Conference and Improvement Plan ........................................... 101 A fter A ction Conference ..................................................................................................... 10 1 84

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Im provem ent P lan .............................................................................................................. 10 1 Appendix A: Exercise Schedule .................................................................... 102 Appendix B: Extent of Play Inform ation ........................................................ 103 85

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After Action Report/Improvement Plan Susquehanna Steam Electric Station CHAPTER 1: GENERAL INFORMATION Introduction The 2010 Susquehanna Steam Electric Station Plume Exercise is a full-scale exercise (FSE) designed to establish a learning environment for players to exercise emergency response plans, policies, and procedures as they pertain to Nuclear Power Plant accidents. An FSE is a complex event that requires detailed planning. To conduct an effective exercise, subject matter experts (SMEs) and local representatives from numerous agencies have taken part in the planning process and will take part in exercise conduct and evaluation.

This Exercise Plan (ExPlan) was produced at the direction of the Federal Emergency Management Agency and the Pennsylvania Emergency Management Agency with the input, advice, and assistance of the Exercise Planning Team. The 2010 Susquehanna Steam Electric Station Plume Exercise is evidence of the growing partnership between State and local jurisdictions for response to the threats our Nation and communities face.

Confidentiality The 2010 Susquehanna Steam Electric Station Plume Exercise is an unclassifiedexercise. The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, controllers, and evaluators, but players may view other materials deemed necessary to their performance. This ExPlan may be viewed by all exercise participants, but the Controllerand Evaluator (C/E) Handbooks are restricteddocuments intendedfor controllers and evaluators only.

All exercise participants should use appropriate guidelines to ensure the proper control of information within their areas of expertise and protect this material in accordance with current Federal Emergency Management Agency and the Pennsylvania Emergency Management Agency directives.

Public release of exercise materials to third parties is at the discretion of the Federal Emergency Management Agency (FEMA) and the Exercise Planning Team.

Purpose The purpose of this exercise is to evaluate player actions against current response plans and capabilities for a nuclear power plant-related incident, and to comply with the requirements of 44 CFR 350 and the guidelines of NUREG 0654/FEMA-REP-1. Exercise planners utilized the elements described in the 67 FR 20580 (April 25, 2002) and Interim Radiological Emergency Preparedness (REP) Program Manual (August 2002) to develop this exercise.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station The objective of the Federal Emergency Management Agency and the Pennsylvania Emergency Management Agency is to demonstrate reasonable assurance that the public can be protected during a nuclear power plant emergency.

Target Capabilities The establishment of the National Preparedness Priorities have steered the focus of homeland security toward a capabilities-based planning approach. Capabilities-based planning focuses on planning under uncertainty, since the next danger or disaster can never be forecast with complete accuracy. Therefore, capabilities-based planning takes an all-hazards approach to planning and preparation which builds capabilities that can be applied to a wide variety of incidents. States and Urban Areas use capabilities-based planning to identify a baseline assessment of their homeland security efforts by comparing their current capabilities against the Target Capabilities List (TCL) and the critical tasks of the Universal Task List (UTL). This approach identifies gaps in current capabilities and focuses efforts on identifying and developing priority capabilities and tasks for the jurisdiction. These priority capabilities are articulated in the jurisdiction's homeland security strategy and Multi-Year Training and Exercise Plan (TEP), of which this exercise is a component of.

The capabilities listed below have been selected by the Exercise Planning Team (EPT) from the priority capabilities identified in Pennsylvania Multi-Year TEP and the FEMA Interim Radiological Emergency Preparedness Program Manual (August 2002), Exercise Evaluation Criteria. These capabilities provide the foundation for development of the exercise objectives and scenario, as the purpose of this exercise is to measure and validate performance of these capabilities and their associated critical tasks.

• Communications

• Emergency Operations Center Management

• Responder Safety and Health

• Public Safety and Security Response

• WMD/HazMat Response and Decontamination

• Citizen Evacuation and Shelter-In-Place

" Emergency Public Information and Warning

• Mass Care (Sheltering, Feeding, and Related Services)

Exercise Objectives The Emergency Preparedness Evaluation Areas - the elements and sub-elements - for this exercise are those that are required to be demonstrated in every exercise, as required by 67 FR 20580 (April 25, 2002) and the Interim REP ProgramManual (August 2002). Appendix B Extent of Play shows the emergency preparedness elements that are required to be demonstrated in the 2010 Susquehanna Steam Electric Station Plume Exercise, along with the level of demonstration that will be displayed in the exercise (i.e., fully demonstrated, limited demonstration, simulated, out-of-sequence interviews, not demonstrated).

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After Action Report/Improvement Plan Susquehanna Steam Electric Station The objective of this exercise is to demonstrate reasonable assurance that the health and safety of the public can be protected, through successful demonstration of tasks identified in Appendix B.

Outstanding Issues There are 3 Areas Requiring Corrective Action (ARCAs) as a result of the FEMA-evaluated plume-phase exercise at Susquehanna Steam Electric Station in October 2008:

ARCA issue numbers:

Condition: The Emergency Operations Center (EOC) received notification from the Columbia County EOC over the radio and telephone that 63-08-3.b.1-A-01 Emergency Workers were to ingest potassium iodide (KI): However, these messages were not passed forward to the Emergency Management Coordinator.

Condition: The Emergency Medical Services Representative did not 63-08-3.c.2-A-02 provide Fire/Rescue personnel with contact information for all hearing impaired individuals for their use in route alerting and failed to notify or address other special needs individuals.

Condition: The crew that demonstrated the Berwick Borough/Briar Creek Borough (BBC) backup alert route (Zone 1) ran the route simulating the use of the vehicle's siren, emergency lights and public address system. After completing the route, the crew was asked to demonstrate the vehicle's emergency notification equipment. The siren and emergency lights tests 63-08-53A03 were satisfactory. However, the volume of the public address system was insufficient to provide adequate carrying power of the message. The volume was not much louder than ordinary conversation level. Several minutes were spent attempting to raise the volume without success. The crew was advised that if the volume could be raised, a re-demonstration could occur.

Eventually, the BBC Emergency Management Director and the Fire/Rescue Officer were informed and agreed that the volume could not be improved.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station CHAPTER 2: EXERCISE LOGISTICS Exercise Summary General The 2010 Susquehanna Steam Electric Station Plume Exercise is designed to establish a learning environment for players to exercise their plans and procedures for responding to an incident at a nuclear power plant. The 2010 Susquehanna Steam Electric Station Plume Exercise will be conducted on October 5, 2010. Out of sequence evaluations will be conducted as follows:

Schools - October 5 th Pennsylvania State Police - October 5 th Emergency Worker Monitoring & Decontamination - October 6 th Reception Centers - October 6th Mass Care Shelters - October 6 th Exercise play on October 5 th is scheduled to end at 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> or before. The exercise may conclude when the Lead Controller in consultation with FEMA and the Utility determine that the exercise objectives have been met at each venue.

Assumptions Assumptions constitute the implied factual foundation for the exercise and, hence, are assumed to be present before the start of the exercise. The following general assumptions apply to the 2010 Susquehanna Steam Electric Station Plume Exercise:

" The exercise will be graded against the REPP criteria. Elements outside the scope of the REPP criteria will not be graded.

" This exercise will be conducted in a no-fault learning environment wherein systems and processes, not individuals, will be evaluated.

• Exercise simulation will be realistic and plausible, containing sufficient detail from which to respond.

• Exercise players will react to the information and situations as they are presented, in the same manner as if this had been a real event.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Constructs and Constraints Constructs are exercise devices designed to enhance or improve exercise realism. Alternatively, constraints are exercise limitations that may detract from exercise realism. Constraints may be the inadvertent result of a faulty construct or may pertain to financial and staffing issues.

Although there are a number of constructs and constraints (also known as exercise artificialities) for any exercise, the EPT recognizes and accepts the following as necessary:

" Players will utilize normal, everyday communications methods, channels, and equipment.

" Out-of-Sequence play is allowed.

" Certain simulations are allowed.

The participating agencies may need to balance exercise play with real-world emergencies. It is understood that real-world emergencies will take priority.

Exercise Participants The following are the categories of participants involved in this exercise; note that the term "participant" refers to all categories listed below, not just those playing in the exercise:

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

Controllers.Controllers set up and operate the exercise site; plan and manage exercise play; act in the roles of response individuals and agencies not playing in the exercise.

Controllers direct the pace of exercise play and routinely include members from the exercise planning team. They provide key data to players and may prompt or initiate certain player actions to ensure exercise continuity.

Simulators. Simulators are control staff personnel who role-play as nonparticipating organizations or individuals. They most often operate out of the Simulation Cell (SimCell), but may occasionally have face-to-face contact with players. Simulators function semi-independently under the supervision of the Lead Controller, enacting roles (e.g., as media reporters or next of kin) in accordance with instructions provided in the Master Scenario Events List (MSEL). All simulators are ultimately accountable to the Lead Controller. For this exercise, the SimCell will be restricted to the Rumor Control Function.

Evaluators. Evaluators are chosen to evaluate and provide feedback on a designated functional area of the exercise. They are chosen based on their expertise in the functional area(s) they have been assigned to review during the exercise and their familiarity with local emergency response procedures. Evaluators assess and document players' performance against established emergency plans and exercise evaluation criteria, in 90

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• accordance with HSEEP standards and within the bounds of REP Program guidance and regulations. They are typically chosen from amongst planning committee members or the agencies/organizations that are participating in the exercise. FEMA evaluators are members of the Region III REP Program staff, representatives of the Radiological Assistance Committee, and contractors. FEMA Evaluators will not serve as Controllers.

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

" Observers. Observers visit or view selected segments of the exercise. Observers do not play in the exercise, and do not perform any control or evaluation functions. Observers will view the exercise from a designated observation area and will be asked to remain within the observation area during the exercise. PEMA observers will be present at selected locations as assigned by the Lead Controller. PEMA observers will receive an observer briefing prior to the day of the exercise. Any V.I.P.s or other visitors will be handled by each agency or location (Municipal EOC, County EOC, etc.) according to that agencies policies and procedures.

• Media Personnel. Some media personnel may be present as observers pending approval by the Exercise Director in coordination with the PEMA Press Office. Media interaction may also be simulated by Actors at the Joint Information Center during the simulated press briefing to enhance realism and meet related exercise objectives.

" Support Staff Exercise support staff includes individuals who are assigned administrative and logistical support tasks during the exercise (i.e. registration, catering, etc.

Exercise Tools Controller and Evaluator Handbooks The 2010 Susquehanna Steam Electric Station Plume Exercise Controller and Evaluator Handbooks are designed to help exercise Controllers and Evaluators conduct and evaluate an effective exercise. These Handbooks also enable Controllers and Evaluators to understand their roles and responsibilities in exercise execution and evaluation. Should a Player, Observer, or media representative find an unattended Handbook, it should be provided to the nearest Controller or Evaluator.

Master Scenario Events List The MSEL outlines benchmarks, as well as injects that drive exercise play. It also details realistic input to the exercise players as well as information expected to emanate from simulated organizations (i.e., those nonparticipating organizations, agencies, and individuals who would usually respond to the situation). An inject will include several items of information, such as inject time, intended recipient, responsible controller, inject type, a short description of the event, and the expected player action.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station For the 2010 Susquehanna Steam Electric Station Plume Exercise the MSEL will be used primarily for out of sequence exercise play. During the plume phase the exercise will be driven by the simulator at the utility. Notifications will go out from the utility in the same manner as they would in a real event with all communications being preceded and terminated by the phrase "This is a Drill". Additionally, Bureau of Radiation Protection (BRP) field teams will be utilizing "exercise measuring instruments" that receive input from the Virtual Plume software. The Virtual Plume software will be programmed to reflect expected conditions at any given time during the exercise.

Exercise Implementation Exercise Play Exercise play will begin at approximately 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br /> with a situation update going to each participating venue. Play will proceed according to the events outlined in the MSEL, in accordance with established plans and procedures. The exercise will conclude upon the completion of operations and attainment of the exercise objectives, as determined by the Lead Controller after consultation with FEMA and the Utility.

Exercise Rules The following are the general rules that govern exercise play:

" Real-world emergency actions take priority over exercise actions.

• Exercise participants will comply with real-world response procedures, unless otherwise directed by control staff.

• All communications (written, radio, telephone, etc.) made during the exercise will begin and end with the phrase, "This is a drill. "

Exercise participants placing telephone calls or initiating radio communication with the SimCell must identify the organization, agency, office, and/or individual with whom they wish to speak.

Safety Requirements General Exercise participant safety takes priority over exercise events. Although the organizations involved in the 2010 Susquehanna Steam Electric Station Plume Exercise come from various response agencies, they share the basic responsibility for ensuring a safe environment for all personnel involved in the exercise. In addition, aspects of an emergency response are dangerous.

Professional health and safety ethics should guide all participants to operate in their assigned roles in the safest manner possible. The following general requirements apply to the exercise:

• An exercise Safety Controller will be identified and be responsible for participant safety.

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" All exercise controllers, evaluators, and staff will serve as safety observers while the exercise activities are underway. Any safety concerns must be immediately reported to the Safety Controller.

" Participants will be responsible for their own and each other's safety during the exercise.

It is the responsibility of all persons associated with the exercise to stop play if, in their opinion, a real safety problem exists. Once the problem is corrected, exercise play can be restarted.

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

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

Accident Reporting and Real Emergencies

• Anyone observing a participant who is seriously ill or injured will provide aid within their training, call the County 911 Center for additional aid or enlist the aid of another person to call, and advise the nearest controller. Anyone calling County 911 will use the phrase "this is not a drill" prior to explaining the injury or illness.

" The controller who is made aware of a real emergency will contact the County 911 center (if this call hasnot already been made) and request the appropriate aid. The controller will use the phrase "this is not a drill" prior to explaining the injury or illness.

" The controller will then contact the Lead Controller and Exercise Director with the following information:

o Venue/function o Location within the venue/function o Condition of injured parties o Requirements for medical aid, fire suppression, rescue, or security resources.

• If the nature of the emergency requires a suspension of the exercise at the venue/function, all exercise activities at that facility will immediately cease. Exercise play may resume at that venue/function once the emergency situation has been addressed.

" Exercise play at other venue/functions should not cease if one venue/function has declared a "Real-World Emergency" unless they are reliant on the affected venue.

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. If a real emergency occurs that affects the entire exercise, the exercise may be suspended or terminated at the discretion of the Exercise Director and Lead Controller. The notification will be made from the State Emergency Operations Center. The Lead Controller will notify the SimCell by phone.

Site Access Security Exercise play for the 2010 Susquehanna Steam Electric Station Plume Exercise will be conducted at numerous sites with varying degrees of security requirements. The Susquehanna Steam Electric Station will control entry to the Utility and the Emergency Operations Facility.

Security at State, County, and Municipal Emergency Operations Centers will be conducted according to their individual security procedures. Individual Site Controllers will be in charge of entry into their respective exercise sites. To prevent confusion and interruption of the exercise, access to the exercise sites and the SimCell will be limited to exercise participants and approved Observers only. Players should advise their venue's controller or evaluator if an unauthorized person is. present. Each organization should follow its internal security procedures, augmented as necessary to comply with exercise requirements.

PEMA Observers and Liaison Officers PEMA will assign Observers and Liaison Officers to each County and Municipal Emergency Operations Center that is being evaluated in the 2010 Susquehanna Steam Electric Station Plume Exercise. The Lead Controller will provide a list of Observers and Liaison Officers to the appropriate Off-Site Response Organizations prior to the day of the exercise. All Observers and Liaison Officers will receive a pre-exercise briefing.

PEMA Observers are not intended to be players and should excuse themselves from any active participation in the exercise. If an Observer is engaged in any way by one of the exercise players he/she should refer the player to the PEMA Liaison Officer.

PEMA Liaison Officers are players and are assigned specific responsibilities for the exercise.

Liaison Officers are instructed to call into the State Emergency Operations Center (SEOC) upon arrival at the exercise venue. They are required to confirm their arrival and provide to the SEOC Watch Officer phone numbers at which they can be reached during the exercise. Liaison Officers are allowed to interact in the exei'cise as a PEMA representative and are sometimes required to provide injects to facilitate exercise play.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Parking and Directions Directions to each venue area are available from the Lead Controller. Parking will be controlled according to existing policy at each individual location.

Restroom Facilities Restroom facilities will be available at each venue.

Exercise Identification Exercise participants will display their existing organizational identification badges.

Communications Plan Exercise Start, Suspension, and Termination Instructions The exercise on October 5, 2010 is scheduled to run for 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> or until the Lead Controller after consultation with FEMA and the Utility determine that the exercise objectives have been met. The exercise is scheduled to end by 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br />. The Lead Controller will announce the exercise suspension or termination through the State Emergency Operations Center.

sttmnTI IS ADRL.

Player Communication Players will use routine, in-place agency communication systems. Additional communication assets may be made available as the exercise progresses. All exercise communication over primary dispatch channels will cease immediately if a real world emergency is announced.

Communications concerning a real world emergency will be preceded by the phrase "This is not drill". In. no instance will exercise communication interfere with real-world emergency communications. Exercise communication over these channels will recommence when authorized by the Exercise Director after he is advised by County 911 that it is safe to do so.

Each venue will coordinate its own internal communication networks and channels.

The primary means of communication among the SimCell, Controllers, and the venues will be telephone. A list of key telephone and fax numbers, and radio call signs will be available as a Communication Directory before the start of the exercise.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Player Briefing Controllers may be required to read specific scenario details to the participants to begin exercise play. They may also have technical handouts or other materials to give to players in order to better orient them to the exercise environment.

Public Affairs Joint Information Centers will be established at both the Utility Emergency Operations Facility and the State Emergency Operations Center. Actors will play the role of reporters and (simulated not publicly broadcast) "public briefings" will be given as they would for a real incident. The briefings will be available for viewing at the County EOCs.

Any participation by the actual media will be coordinated through the Exercise Director in conjunction with the PEMA Public Information Office.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station CHAPTER 3: PLAYER GUIDELINES Exercise Staff Exercise Director The Exercise Director has the overall responsibility for planning, coordinating, and overseeing all exercise functions. The Exercise Director for the 2010 Susquehanna Steam Electric Station Plume Exercise is the Radiological Emergency Preparedness Regional Assistance Committee Chair.

The Exercise Director has delegated the following responsibilities to other team members:

The FEMA Region III Site Specialist for the Susquehanna Steam Electric Station has authority to make determinations concerning evaluation issues and re-demonstrations, The PEMA HSEEP Coordinator has responsibility to organize and lead the Exercise Planning Team.

Trusted Agents Trusted agents are exercise planners and participants who are responsible for developing the Scenario and the Master Scenario Events List (MSEL). These documents are restricted and are not available to the rest of the Exercise Planning Team, Players, or other Participants. The trusted agents for the 2010 Susquehanna Steam Electric Station Plume Exercise include the Exercise Director, Lead Controller, Bureau of Radiation Protection (BRP) Representative, FEMA Emergency Management Program Specialist, and the Radiological Emergency Preparedness Regional Assistance Committee (RAC) Chair.

Lead Controller The Lead Controller also functions as a Trusted Agent. As such he is involved in developing the Master Scenario Events List and is privy to the scenario used at the Utility to generate exercise play. The Lead Controller is responsible for scheduling controllers at the "Out of Sequence" components of the exercise and the 2010 Susquehanna Steam Electric Station Plume Exercise.

The Lead Controller monitors exercise progress and coordinates decisions regarding deviations or significant changes to the scenario caused by unexpected developments during play. The Lead Controller monitors actions by individual Controllers and ensures they implement all designated and modified actions at the appropriate time. The Lead Controller will be the PEMA REP Training Program Manager and is stationed in the State EOC during the Plume Exercise.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Controllers At least one controller will be onsite with every facility and field team participating in the exercise, and at each out-of-sequence interview. The Controller at each location will coordinate any changes that impact the scenario or affect other areas of play through the Lead Controller The individual controllers issue exercise materials to players as required and monitor the exercise timeline. Controllers also provide injects to the players as described in the MSEL. The Trusted Agent from the Utility will act as the Controller at the Utility Site during the Plume exercise and the BRP Trusted Agent will act as Controller for the BRP Field Teams.

Lead Evaluator The Lead Evaluator is responsible for the overall evaluation of the 2010 Susquehanna Steam Electric Station Plume Exercise. The Lead Evaluator monitors exercise progress and stays in contact with the Lead Controller regarding changes to the exercise during play. The Lead Evaluator monitors actions of individual Evaluators and ensures they are tracking progress of the players in accordance with the Overview of Play. The Lead Evaluator debriefs the evaluators after the exercise and oversees the entire evaluation and After Action process. The Lead Evaluator will be the FEMA Region III REP Site Specialist.

Evaluators Evaluators work under the direction of the Lead Evaluator, and as a team with Controllers.

Evaluators are Subject Matter Experts who record events that take place during the exercise and assess/submit documentation for review and inclusion in the After Action Report (AAR).

Evaluators should refrain from any direct interaction with the players during exercise play except with the facilitation of a Controller for clarification of issues or during scheduled interviews.

Player Instructions Before the Exercise

" Review the appropriate emergency plans, procedures, and exercise support documents.

" Arrive at the exercise location as instructed. Wear appropriate uniform/identification badge.

" If you gain knowledge of the scenario before the exercise, notify a controller so that appropriate actions can be taken to ensure a valid evaluation.

• Read your Player Information Handout, which includes information on exercise safety.

• Please sign in.

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• Bureau of Radiation Protection Field Monitoring Teams will be briefed by the BRP Coordinator.

During the Exercise

" Respond to the exercise events and information as if the emergency were real, unless otherwise directed by an exercise controller.

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

You are expected to obtain other necessary information through existing emergency information channels.

" Do not engage in personal conversations with controllers, evaluators, observers; or media personnel while the exercise is in progress. If you are asked an exercise-related question, give a short, concise answer. If you are busy and cannot immediately respond, indicate so, but report back with an answer at the earliest time possible.

" If you do not understand the scope of the exercise or if you are uncertain about an organization's or agency's participation in an exercise, ask a controller.

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

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

" When communicating with the SimCell, identify the organization, agency, office, and/or individual with which you want to speak.

" Verbalize out loud when taking an action. This will ensure that evaluators are made aware of critical actions as they occur.

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

Following the Exercise

" At the end of the exercise at your facility, participate in a debriefing with the controllers and evaluators.

" Provide all rosters, sign in sheets, logs, messages, notes or materials generated from the exercise to your controller or evaluator for review and inclusion in the AAR.

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• Bureau of Radiation Protection Field Monitoring Teams will be debriefed immediately following the exercise by the BRP Coordinator.

Simulation Guidelines Because the 2010 Susquehanna Steam Electric Station Plume Exercise is of limited duration and scope, the physical description of what would fully occur at the incident sites and surrounding areas will be relayed to the Players by Simulators or Controllers.

If a real emergency occurs during the exercise, the exercise at your respective venue may be suspended or terminated at the discretion of the controller(s) at each venue. If a real emergency occurs, provide assistance up to the level of your training, call 911 and use the phrase "This is not drill" and ask for the appropriate assistance, and notify the nearest Controller and Evaluator.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station CHAPTER 4: EVALUATION AND POST-EXERCISE ACTIVITIES Exercise Documentation The goal of the 2010 Susquehanna Steam Electric Station Plume Exercise is to comprehensively exercise and evaluate the OROs' plans and capabilities as they pertain to a potential nuclear power plant incident. After the exercise, data collected by Controllers, Evaluators, and Players will be used to identify strengths and areas for improvement in the context of the exercise design objectives.

Exercise Evaluation Guides DHS has developed Exercise Evaluation Guides (EEGs) that identify expected activities for evaluation, provide consistency across exercises, and link individual tasks to disciplines and expected outcomes.

The EEGs selected by the Exercise Planning Team are contained in the evaluator materials packet along with the Evaluator Handbook. These EEGs have been selected because the activities they describe can be expected to be observed during the exercise and will guide evaluation to match the exercise design objectives. Supplemental REP evaluation material designed for the exercise may also be used.

DEBRIEFING Immediately following the completion of exercise play, Controllers will facilitate a debriefing with Players from their assigned location. The debriefing is an opportunity for Players to voice their opinions on the exercise and their own performance. At this time, Evaluators can also seek clarification on certain actions and what prompted Players to take them. The debriefing should not last more than 30 minutes. However, the Players comments in the debriefing will not become part of the Evaluators' analysis and evaluation.

Exercise Evaluation Hotwash Controllers, Evaluators, and selected exercise participants will attend a facilitated Controller and Evaluator Hotwash on October 7 at 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> at the Ramada Inn. During the Hotwash these individuals will discuss their observations of the exercise in an open environment to clarify actions taken during the exercise.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Participants and Public/Media Briefings The Participants Briefing will be conducted on October 8 at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> followed immediately by the Public/Media Briefing at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />. Both briefings will be held at the Ramada Inn.

After Action Report The AAR is the culmination of the exercise. It is a written report outlining the strengths and areas for improvement identified during the exercise. The AAR will include the timeline, executive summary, scenario description, mission outcomes, and capability analysis. The AAR will be drafted by a core group of individuals from the exercise planning team.

After Action Conference and Improvement Plan The improvement process represents the comprehensive, continuing preparedness effort of which the 2010 Susquehanna Steam Electric Station Plume Exercise is a part. The lessons learned and recommendations from the AAR will be incorporated into the Improvement.Plan (IP).

After Action Conference The After Action Conference (AAC), scheduled for November 4, 2010 at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />, is a forum for jurisdiction officials to hear the results of the evaluation analysis, validate the findings and recommendations in the draft AAR, and begin development of the IP. The After Action Conference will be conducted via a conference call.

Improvement Plan The IP identifies how recommendations will be addressed, including what actions will be taken, who is responsible, and the timeline for completion. It is created by key stakeholders from the 2010 Susquehanna Steam Electric Station Plume Exercise participating agency officials during the AAC scheduled for November 4, 2010.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station APPENDIX A: EXERCISE SCHEDULE Table A.1 Susquehanna Steam Electric Station 2010 Plume Exercise Schedule

[10/05/101 09:00 AM Out of Sequence Staff School Exercise 11:00 AM Out of Sequence Staff PSP T/ACP Exercise 04:00 PM Plume Exercise Staff Plume Exercise

[10/06/101 07:00 PM Out of Sequence Staff Reception, Mon/Decon, Mass Care Exercise

[10/07/101 03:00 PM Federal, State, County EMA Exercise Hotwash

[10/08/101 10:00 AM Federal, State, County, Local Exercise Players Briefing EMA Exercise Critique 11:00 AM Public Public Meeting/Briefing 103

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After Action Report/Improvement Plan Susquehanna Steam Electric Station APPENDIX B: EXTENT OF PLAY INFORMATION The following Extent of Play for the Susquehanna Steam Electric Station 2010 Plume Exercise was completed and published on September 14, 2010. The Extent of Play begins on the following page.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station SUSQUEHANNA STEAM ELECTRIC STATION EXTENT OF PLAY 2010 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE 105

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Intentional Blank Page 106

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Table of Contents Page Method of Operation 108

1. Susquehanna Steam Station 108

2. Bureau of Radiation Protection 108

3. PEMA Operations at State EOC/PEMA Headquarters 108

4. PEMA Area Offices 109

5. Counties Participating 109

6. PEMA Liaison Officers 110

7. Controllers 110

8. PEMA Observers 110

9. DHS (FEMA/REP) Evaluators 111

10. Demonstration Windows 110

11. Stand-down 112

12. General Concepts 113

13. Re-demonstrations 113 Extent of Play Agreement 114 Evaluation Area 1 114 Evaluation Area 2 120 Evaluation Area 3 127 Evaluation Area 4 138 Evaluation Area 5 144 Evaluation Area 6 149 American Red Cross Chapter Listing 156 Attachment A - Demonstration Tables School Districts 159 County Emergency Operation Centers 160 Municipal Emergency Operations Centers 160 Route Alerting 161 Traffic/Access Control Points 162 Reception Centers 163 Mass Care & Monitoring / Decontamination Centers 163 Emergency Worker Monitoring / Decontamination Stations 165 Post Plume Exercise 165 Attachment B - Listing of Prior Issues 165 107

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After Action Report/Improvement Plan Susquehanna Steam Electric Station SUSQUEHANNA STEAM ELECTRIC STATION 2010 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE METHOD OF OPERATION

1. Susquehanna Steam Electric Station (SSES)

The facility normally uses off-watch section personnel to participate in the exercise. The plant's simulated events, radiation readings, and emergency classifications will trigger offsite exercise actions. A pre-approved exercise scenario will be used. The SSES will notify the State EOC, the Bureau of Radiation Protection and Risk Counties of emergency classifications.

2. Bureau of Radiation Protection (BRP)

Personnel from the Pennsylvania Bureau of Radiation Protection (BRP) will be present and participate in the following aspects of the exercise as follows:

Plume Exercise - Nuclear facility EOF - (NOT Evaluated)

Plume Exercise - Field Sampling Teams & Command Vehicle - (10/5/2010) - (NOT Evaluated)

BRP personnel working in the SEOC will NOT be evaluated as participants

3. PEMA Operations at State EOC / PEMA Headquarters This "Method of Operation" Document includes activities for the Full-Scale Plume Exercise 10/05/20 10, and the "Out of Sequence" Activities - 10/5 & 10/6/20 10.

A. Plume Exercise - (10/05/2010)

The PEMA State Emergency Operations Center, augmented by designated PEMA personnel from the Fire Commissioner's Office, the Bureau of Administration, Technical Services, Plans, plus Emergency Preparedness Liaison Officers (EPLO's) with accompanying response team members from designated state departments/agencies, including representatives from the USDA State Emergency Board will comprise initial operations at the State Emergency Operations Center (EOC). The State EOC will participate but will NOT be evaluated during this exercise.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station B. Plume Exercise - "Out of Sequence" Activities - (10/5 & 10/6/2010)

The PEMA State Emergency Operations Center, augmented by designated PEMA personnel will disseminate exercise related messages to the participating Counties for dissemination to the participating School Districts during the morning of 10/5/2010.

The State Emergency Operations Center (SEOC) and County EOC's will participate however NOT be evaluated during the "Out of Sequence" component. PEMA personnel will serve as "observers" at the identified School Districts.

NOTE: The Montour County EOC will be evaluated during the school district exercise during the morning of 10/5/20 10.

C. "Out of Sequence" Activities - (10/5 & 10/6/2010) See Attachment A for Time PEMA personnel will serve as "Observers" at the various field exercise locations during the evening "Out-of-Sequence" component 10/5 .& 10/6/2010. An exercise coordinator will remain in the State EOC. The State Emergency Operations Center (EOC) and Counties EOC's will NOT be evaluated during the evening "Out of Sequence" component (10/6/2010).

4. PEMA Area Office Operations The PEMA Area Offices (Hamburg -Eastern Area and Harrisburg - Central Area) will not be activated nor evaluated during this exercise. Selected staff of the Area Offices will serve as Liaison Officers to Risk and Support Counties as assigned. Liaison Officers are exercise participants.

5. Counties Designated to Participate A. Plume Phase Exercise: (10/05/2010)

The two risk counties (Columbia and Luzerne), in coordination with PEMA, will demonstrate the capability to mobilize appropriate staff, activate their respective Emergency Operations Centers and implement emergency response operations to include sheltering and/or evacuation. County government will provide direction and coordination to risk municipalities. The six support Counties (Lackawanna, 109

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Lycoming, Northumberland, Schuylkill, Union and Wyoming) will participate in their assigned support roles. Actual sheltering or evacuation of the general public will be simulated.

NOTE: The Montour County EOC will not be evaluated during the plume phase exercise.

6. PEMA Liaison Officers Liaison officers will be present at the participating risk and support county EOC's, the SSES Emergency Operations Facility (EOF) and the SSES Joint Information Center (JIC) to provide assistance, guidance, and support. These liaison officers will participate as players in the plume phase exercise on 10/05/20 10.

7. Controllers A lead controller will be present in the state EOC for the plume exercise and the out of sequence school exercise. Controllers will be supplied by the utility and will be present at the emergency worker monitoring/decontaminating stations and the mass care monitoring/

decontamination centers on 10/6/2010. Controllers are not players. Controllers will provide pre-approved injects and information to the players, as appropriate, regarding radiological readings during the monitoring of personnel. Live radioactive sources will not be used. Exception: individuals tasked with the setup ofportal monitoringequipment will use a standardI micro curie Cesium 137 sourcefor the purpose of conducting operational tests. Additionally, appropriatetest sources will be available and used to verify the operation of the monitoring/ survey instrumentsper manufacturer'srecommendations.

8. PEMA Observers PEMA staff, qualified county emergency management personnel, and/or nuclear power plant personnel will be assigned, if required, to key locations for the purpose of observing, noting response actions and conditions, and recording observations for future use.

Observers will not take an active part in the proceedings, but will interact with staff members to the extent necessary to fulfill their observer responsibilities. Coaching of players by observers is not permitted except to provide training as appropriate to participants awaiting a re-demonstration. (Refer to paragraph 13) 110

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9. Department of Homeland Security (FEMA/REP) Evaluators A. Plume Exercise:

Out of Sequence Period: (10/5/2010) Federal evaluators will be present at the identified "out-of-sequence" demonstration sites per Attachment A,Section I.A. 1 These include the identified Public School District locations. NOTE: The Montour County EOC will be evaluated during the school district exercise during the morning of 10/5/2010 Plume Phase Exercise: (10/05/2010) Evaluators representing the federal government will be present at the identified risk and support county EOC's to evaluate player response to the actual and simulated events in the exercise scenario. Additionally, one-third of the risk municipalities in Columbia and Luzerne counties will be federally evaluated. As required, a "floating-evaluator" will be made available for the purpose of evaluating any ORO locations not scheduled to have a federal evaluator, but having a prior issue (Attachment A,Section I.A.2 and I.A.3).

Out of Sequence Period: (10/6/2010) Federal evaluators will be present at identified Reception Centers, Emergency Worker Monitoring and Decontamination Stations and Mass Care / Shelters and Mass Care Monitoring and Decontamination Centers, as identified in Attachment A,Section I.B. 1, I.B.2 and I.B.3.

Out of Sequence Period: (10/6/2010) Federal evaluators will be present at the identified "out-of-sequence" demonstration sites per Attachment A, I.A.5. This includes the Pennsylvania State Police location.

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

demonstrated.

The "demonstration windows" for this exercise are:

A. Plume Phase Exercise The out-of-sequence MS-1 hospital demonstration was federally evaluated at 111

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Susquehanna Health on October 1, 2009.

The out-of-sequence exercise window for school demonstrations will be from 9:00 -

11:00 a.m. on Tuesday, 10/5/2010.

The out-of-sequence demonstration of reception centers, mass care centers, monitoring

/ decontamination centers and emergency worker stations will be conducted from 7:00 -

9:30 p.m. on Wednesday 10/6/2010. Locations are specified within Attachment A,Section II.

The out-of-sequence interview of Pennsylvania State Police traffic control / access control points will be from 10:00 a.m. - 12:00 noon on Wednesday, 10/6/2010.

Municipal TCP demonstrations will occur in conjunction with Municipal EOC operations on Tuesday 10/5/2010. (Please refer to the Extent of Play Demonstration Tables, Attachment A)

All demonstrations will commence promptly and, barring any complications, not continue beyond the time of the designated demonstration window.

County and municipal EOC operations will be conducted on Wednesday 10/05/2010 from 4 p.m. - 10:30 p.m. with the exception of Montour County which will be evaluated during the out of sequence school phase on 10/5/2010. (Please refer to the Extent of Play Demonstration Tables, Attachment A)

B. Post Plume Exercise NOTE: The last post-plume (ingestion) exercise was conducted August 2004 for the SSES.

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

A. Upon completion of all requirements and after having informed the FEMA / REP evaluator that all evaluation areas have been demonstrated and/or completed, the risk municipality EOC's may request approval from their county EOC to "stand-down".

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After Action Report/Improvement Plan Susquehanna Steam Electric Station B. Support counties may likewise request approval from the State EOC to terminate the exercise upon completion of all evaluated objectives.

C. The risk county EOC's will remain operational until the exercise is officially terminated by the State. The State EOC will issue an Exercise Termination Message.

12. General Concepts An emergency plan is drafted to address the generally expected conditions of an emergency. Not everything in the emergency plan may be applicable for a given scenario.

The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a plan that they cannot take actions that are more protective of the public. Therefore, if, by not following the plan, the responders protect the public equally as well as provided in the plan, it should be noted for possible modification of the plan, but not classified as a negative incident. Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so that the plan can be modified and the appropriate negative assessment corrected.

13. Re-demonstrations During the out of sequence demonstrations on 10/5 & 10/6/2010, or the plume phase demonstrations on 10/05/2010, any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants during the exercise, provided it does not negatively interfere with the exercise. Refresher training may be provided by the players, observers, and/or controllers. Evaluators are not permitted to provide refresher training. Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. PEMA may advise the RAC Chair prior to initiating any re-demonstrations. It is permissible to extend the demonstration window, within reason, to accommodate the re-demonstration. Activities corrected from a re-demonstration will be so noted.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station SUSQUEHANNA STEAM ELECTRIC STATION 2010 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE EXTENT OF PLAY AGREEMENT Sub-element L.a - Mobilization INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations(ORO) should have the capability to alert, notify, and mobilize emergency personnel and to activate and staff emergency facilities.

Criterion 1.a.l: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654, A.4; D.3, 4; E.1, 2; H.4)

EXTENT OF PLAY Responsible OROs should demonstrate the capability to receive notification of an emergency situation from the licensee, verify the notification, and contact, alert, and mobilize key emergency personnel in a timely manner. Responsible OROs should demonstrate the activation of facilities for immediate use by mobilized personnel when they arrive to begin emergency operations. Activation of facilities should be completed in accordance with the plan and/or procedures. Pre-positioning of emergency personnel is appropriate, in accordance with the extent of play agreement, at those facilities located beyond a normal commuting distance from the individual's duty location or residence. Further, pre-positioning of staff for out-of-sequence demonstrations is appropriate in accordance with the extent of play agreement.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station PEMA NegotiatedExtent of Play:

Pre-positioningof state emergency personnel (LiaisonOfficers) at the Emergency Operations Facility (EOF), the Utility Joint Information Center (JIC)and Risk and Support Counties is appropriatedue to the commuting distancefrom the individual'sduty location or residence.

Risk counties/municipalitiesand support counties will conduct call-outs to demonstrate the mobilization of key personnel. The utility JIC will be evaluatedfor this drill.

" Actual calls (orpager notifications)will be made to the county/municipal EOC personnelfor the Plume Phase exercise, 10/05/2010per plans andprocedures.

• In all instances, the demonstrationof a shift change is NOT required Twenty-four hour staffing will be demonstratedby means of a roster or staffing chart.

" All out-of-sequenceplayers will be pre-positionedand equipment will be demonstratedor shown to be in inventory (School Districtpersonnel, PennsylvaniaState Police TCP/ACP,Reception Centers, Emergency Worker Monitoring and DecontaminationStations Mass Care/ShelteringCenters and Monitoring and DecontaminationCenters andfor the purpose of this exercise, Montour County EOC).

Sub-element 1.b - Facilities INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have facilities to support the emergency response.

Criterion 1.b.l: Facilities are sufficient to support the emergency response.

(NUREG-0654, H.3)

EXTENT OF PLAY Facilities will only be specifically evaluated for this criterion if they are new or have substantial changes in structure or mission. Responsible OROs should demonstrate the availability of facilities that support the accomplishment of emergency operations. Some of the areas to be considered are: adequate space, furnishings, lighting, restrooms, ventilation, backup power and/or alternate facility (if required to support operations.)

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Facilities must be set up based on the ORO's plans and procedures and demonstrated as they would be used in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play: None. Note: Allfacilities have been evaluated in previous exercises.

Sub-element 1.c - Direction and Control INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to control their overall response to an emergency.

Criterion 1.c. 1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible. (NUREG-0654, A.1 .d; A.2.a, b)

EXTENT OF PLAY Leadership personnel should demonstrate the ability to carry out essential functions of the response effort, for example: keeping the staff informed through periodic briefings and/or other means, coordinating with other appropriate OROs, and ensuring completion of requirements and requests.

All activities associated with direction and control must be performed based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless otherwise noted above or indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play: None Sub-element 1.d - Communications Equipment - N/A INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response 116

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Organizations (ORO) should establish reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as the following:

appropriate contiguous governments within the emergency planning zone (EPZ), Federal emergency response organizations, the licensee and its facilities, emergency operations centers (EOC), and field teams.

Criterion 1.d.l: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations. (NUREG-0654, F.1, 2)

EXTENT OF PLAY OROs will demonstrate that a primary and at least one backup system are fully functional at the beginning of an exercise. If a communications system or systems are not functional, but exercise performance is not affected, no exercise issue will be assessed. Communications equipment and procedures for facilities and field units should be used as needed for the transmission and receipt of exercise messages. All facilities and field teams should have the capability to access at least one communication system that is independent of the commercial telephone system. Responsible OROs should demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt the conduct of emergency operations.

OROs should ensure that a coordinated communication link for fixed medical facilities and mobile medical units exists. The specific communications capabilities of OROs should be commensurate with that specified in the response plan and/or procedures. Exercise scenarios could require the failure of a communications system and the use of an alternate system, as negotiated in the extent of play agreement.

All activities associated with the management of communications capabilities must be demonstrated based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless otherwise noted above or in the extent of play agreement.

PEMA NegotiatedExtent of Play:

The plant will communicate to the risk counties and State EOC utilizing the Automatic Ring Down System (ARD) (Primary)and telephone/internet(Secondary). Risk and Support Counties will intercommunicate 117

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After Action Report/Improvement Plan Susquehanna Steam Electric Station with the State EOC via Telephone (Primary,SEVAN (Secondary) and other systems. In the event that the plant is unable to contact the state EOC then Luzerne County EOC will be contacted andfulfill the role of primary contact until such time as communicationswith the State EOC can be made.

Risk Counties will communicate with their risk municipalitiesvia public safety radiofrequencies (EMA Radio) (Primary),Commercial Telephone (Secondary), Internet, Fax,Amateur Radio Communications (ARES/RA CES) or other available means.

Sub-element L.e - Equipment and Supplies to Support Operations INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have emergency equipment and supplies adequate to support the emergency response.

Criterion 1.e.l: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654, H.7, 10; J.10.a, b, e, J.11; K.3.a)

EXTENT OF PLAY Equipment within the facility (facilities) should be sufficient and consistent with the role assigned to that facility in the ORO's plans and/or procedures in support of emergency operations. Use of maps and displays is encouraged.

All instruments, including air sampling flow meters (field teams only), should be inspected, inventoried, and operationally checked before each use. Instruments should be calibrated in accordance with the manufacturer's recommendations. Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation should be calibrated annually.

Modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration should be on each instrument, or the calibration frequency may be verified by other means. Additionally, instruments being 118

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After Action Report/Improvement Plan Susquehanna Steam Electric Station used to measure activity should have a range of reading sticker affixed to the side of the instrument. The above considerations should be included in 4.a. 1 for field team equipment; 4.c. 1 for radiological laboratory equipment (does not apply to analytical equipment; reception center and emergency worker facilities' equipment under 6.a. 1; and ambulance and medical facilities' equipment under 6.d. 1.

Sufficient quantities of appropriate direct-reading and permanent record dosimeters and dosimeter chargers should be available for issuance to all categories of emergency workers that could be deployed from that facility. Appropriate direct-reading dosimetry should allow individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans and procedures.

Dosimetry (DirectReading Dosimeters) should be inspected for electrical leakage at least annually and replaced, if necessary. CDV-138s, due to their documented history of electrical leakage problems, should be inspected for electrical leakage at least quarterly and replaced if necessary. This leakage testing will be verified during the exercise, through documentation submitted in the Annual Letter of Certification, and/or through a staff assistance visit.

Responsible OROs should demonstrate the capability to maintain and distribute inventories of KI sufficient for use by emergency workers, as indicated on rosters; institutionalized individuals, as indicated in capacity lists for facilities; and, where stipulated by the plan and/or procedures, members of the general public (including transients) within the plume pathway EPZ.

Quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at storage location(s) or through documentation of current inventory submitted during the exercise, provided in the Annual Letter of Certification submission, and/or verified during a Staff Assistance Visit. Available supplies of KI should be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may produce a letter from a certified private or State laboratory indicating that the KI supply remains potent, in accordance with U.S.

Pharmacopoeia standards.

At locations where traffic and access control personnel are deployed, appropriate equipment (for example, vehicles, barriers, traffic cones and signs, etc.) should be available or their availability described.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station PEMA NegotiatedExtent of Play:

RadiologicalSurvey Instruments are calibratedper manufacturesrecommendations. Support counties do not have DRDs, or K1, but those responsiblefor reception centers and/or monitoring and decontamination centers will have PRDs.

Evaluation of KI quantitieswill be verified using inventory sheets. KI will not be removedfrom storage locations and boxes /packages will not be opened. KI questions will be addressed through interviews.

Electronic DRD's are in use in the SSES Plume EPZ. Calibration/testinginformation will be available to the evaluator.

Reception Centers shall be evaluated on their ability to use maps or other documentation to direct evacuatingpersons to the correct Monitoring/DecontaminationCenters and/orMass Care Centers.

EVALUATION AREA 2 Sub-element 2.a - Emergency Worker Exposure Control INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans and procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.

Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates emergency workers may be permitted to incur during an emergency. These limits include any pre-established administrative reporting limits (that take into consideration Total Effective Dose Equivalent or organ-specific limits) identified in the ORO's plans and procedures.

Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including 120

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After Action Report/Improvement Plan Susquehanna Steam Electric Station the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

(NUREG-0654, K.4, J.10. e, f)

EXTENT OF PLAY OROs authorized to send emergency workers into the plume exposure pathway EPZ should demonstrate a capability to meet the criterion based on their emergency plans and procedures.

Responsible OROs should demonstrate the capability to make decisions concerning the authorization of exposure levels in excess of pre-authorized levels and to the number of emergency workers receiving radiation dose above pre-authorized levels.

As appropriate, OROs should demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure, based on the ORO's plan and/or procedures or projected thyroid dose compared with the established Protective Action Guides (PAGs) for KI administration.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

Radiological briefings (verbal and/or video) will be provided to address exposure limits and procedures to replace those approachingexposure limits and how permission to exceed limits is obtainedfrom the municipality and county. Emergency workers will also be briefed on when to take KI and on whose authority. Distributionof KI to emergency workers will be simulated The completion of a "Dosimetry-KIReport Form" will be demonstrated.

Sub-element 2.b. - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to use all available data to independently project integrated dose and compare the estimated dose savings with the protective action guides. OROs have the capability to choose, among a range of protective actions, those most appropriate in a given emergency situation. OROs base these choices on PAGs from the ORO's plans and 121

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station procedures or EPA 400-R-92-001 and other criteria, such as, plant conditions, licensee protective action recommendations, coordination of protective action decisions with other political jurisdictions (for example, other affected OROs), availability of appropriate in-place shelter, weather conditions, and situations that create higher than normal risk from evacuation.

Criterion 2.b.l: 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 onsite and offsite environmental conditions. (NUREG-0654, 1.8, 10 and Supplement 3)

EXTENT OF PLAY During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO should demonstrate the capability to use appropriate means, described in the plan and/or procedures, to develop protective action recommendations (PARs) for decision-makers based on available information and recommendations from the licensee and field monitoring data, if available.

When the licensee provides release and meteorological data, the ORO also considers these data.

The ORO should demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs appropriate to the scenario. In all cases, calculation of projected dose should be demonstrated. Projected doses should be related to quantities and units of the PAGs to which they will be compared. PARs should be promptly transmitted to decision-makers in a prearranged format.

Differences greater than a factor of 10 between projected doses by the licensee and the ORO should be discussed with the licensee with respect to the input data and assumptions used, the use of different models, or other possible reasons. Resolution of these differences should be incorporated into the PAR if timely and appropriate. The ORO should demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station PEMA NegotiatedExtent of Play: None/Not Evaluated Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PAD) for the general public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654, J.9, 10.f, m)

Offsite Response Organizations (ORO) should have the capability to make both initial and subsequent PADs. They should demonstrate the capability to make initial PADs in a timely manner appropriate to the situation, based on notification from the licensee, assessment of plant status and releases, and PARs from the utility and ORO staff.

The dose assessment personnel may provide additional PARs based on the subsequent dose projections, field monitoring data, or information on plant conditions. The decision-makers should demonstrate the capability to change protective actions as appropriate based on these projections.

If the ORO has determined that KI will be used as a protective measure for the general public under off-site plans, then the ORO should demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for the general public to supplement shelter and evacuation. This decision should be based on the ORO's plan and/or procedures or projected thyroid dose compared with the established PAG for KI administration. The KI decision-making process should involve close coordination with appropriate assessment and decision-making staff.

If more than one ORO is involved in decision-making, OROs should communicate and coordinate PADs with affected OROs. OROs should demonstrate the capability to communicate the contents of decisions to the affected jurisdictions.

All decision-making activities by ORO personnel must be performed based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station PEMA NegotiatedExtent of Play: NoneNot Evaluated Sub-element 2.c - ProtectiveAction Decisions Considerationfor the Protectionof Special Populations INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to determine protective action recommendations, including evacuation, sheltering and use of potassium iodide (KI), if applicable, for special population groups (for example, hospitals, nursing homes, correctional facilities, schools, licensed day care centers, mobility impaired individuals, and transportation dependent individuals). Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups. (NUREG-0654, J.9, J.1A.d, e)

EXTENT OF PLAY Usually, it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range of PAGs, except for situations where there is a high-risk environment or where high-risk groups (e.g., the immobile or infirm) are involved. In these cases, examples of factors that should be considered are weather conditions, shelter availability, availability of transportation assets, risk of evacuation vs. risk from the avoided dose, and precautionary school evacuations. In situations where an institutionalized population cannot be evacuated, the administration of KI should be considered by the OROs.

Applicable OROs should demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students. Contacts with public school systems/districts must be actual.

In accordance with plans and/or procedures, OROs and/or officials of public school systems/districts should demonstrate the capability to make prompt decisions on protective actions for students. Officials should demonstrate that the decision making process for protective actions considers (that is, either accepts automatically or gives heavy weight to) protective action recommendations made by ORO personnel, the ECL at which these recommendations are received, preplanned strategies for protective actions for that ECL, and the location of students at the time (for example, whether the students are still at home, en route to the school, or at the school).

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station All decision-making activities associated with protective actions, including consideration of available resources, for special population groups must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play: None The State EOC will not be evaluatedduring this exercise; however, this element will be demonstrated duringthe plume phase exercise as a control mechanism.

Sub-element 2.d. - Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway INTENT This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PAGs, and make timely, appropriate protective action decisions to mitigate exposure from the ingestion pathway.

During an accident at a nuclear power plant, a release of radioactive material may contaminate water supplies and agricultural products in the surrounding areas. Any such contamination would likely occur during the plume phase of the accident and, depending on the nature of the release, could impact the ingestion pathway for weeks or years.

PEMA NegotiatedExtent of Play:

This sub-element will NOT be evaluatedduring this exercise. This element was demonstrated duringthe Post Plume (Ingestion)Exercise conducted during the week ofAugust 16, 2004.

Sub-element 2.e. - RadiologicalAssessment and Decision-MakingConcerningRelocation, Re-entry, and Return Relocation: OROs should demonstrate the capability to estimate integrated dose in contaminated areas and to compare these estimates with PAGs, apply decision criteria for relocation of those individuals in the general public who have not been evacuated but where projected doses are in excess of relocation PAGs, and control access to evacuated and restricted areas. Decisions are made for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PAGs.

Determination of areas to be restricted should be based on factors such as the mix of radio 125

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station nuclides in deposited materials, calculated exposure rates vs. the PAGs, and field samples of vegetation and soil analyses.

Re-entry: Decisions should be made regarding the location of control points and policies regarding access and exposure control for emergency workers and members of the general public who need to temporarily enter the evacuated area to perform specific tasks or missions.

Examples of control procedures are: the assignment of, or checking for, direct-reading and non-direct-reading dosimetry for emergency workers; questions regarding the individual's objectives and locations expected to be visited and associated time frames; availability of maps and plots of radiation exposure rates; advice on areas to avoid; and procedures for exit including: monitoring of individuals, vehicles, and equipment; decision criteria regarding decontamination; and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

Responsible OROs should demonstrate the capability to develop a strategy for authorized re-entry of individuals into the restricted zone, based on established decision criteria. OROs should demonstrate the capability to modify those policies for security purposes (e.g., police patrols),

for maintenance of essential services (e.g., fire protection and utilities), and for other critical functions. They should demonstrate the capability to use decision-making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g.,

to care for farm animals or secure machinery for storage), or to retrieve important possessions.

Coordinated policies for access and exposure control should be developed among all agencies with roles to perform in the restricted zone. OROs should demonstrate the capability to establish policies for provision of dosimetry to all individuals allowed to re-enter the restricted zone. The extent that OROs need to develop policies on re-entry will be determined by scenario events.

Return: Decisions are to be based on environmental data and political boundaries or physical/geological features, which allow identification of the boundaries of areas to which members of the general public may return. Return is permitted to the boundary of the restricted area that is based on the relocation PAG.

Other factors that the ORO should consider are, for example: conditions that permit the cancellation of the Emergency Classification Level and the relaxation of associated restrictive measures; basing return recommendations (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis) on measurements of radiation from ground deposition; and the capability to identify services and facilities that require restoration within a few days and to identify the procedures and resources for their restoration.

Examples of these services and facilities are: medical and social services, utilities, roads, schools, and intermediate term housing for relocated persons.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station PEMA Negotiated Extent of Play:

This sub-element will NOT be evaluatedduring this exercise. This element was demonstrated duringthe Post Plume Exercise conducted during the week ofAugust 16, 2004.

EVALUATION AREA 3 Protective Action Implementation INTENT This sub-element derives from NUREG-0654, which provides that OROs should have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; the reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; and establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides, always applying the ALARA (As Low As is Reasonably Achievable) principle as appropriate.

Criterion 3.a.l: 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 OFPLAY OROs should demonstrate the capability to provide appropriate direct-reading and permanent record dosimetry, dosimeter chargers, and instructions on the use of dosimetry to emergency workers. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows individual(s) to read the administrative reporting limits (that are pre-established at a level low enough to consider subsequent calculation of Total Effective Dose Equivalent) and maximum exposure limits (for those emergency workers involved in life saving activities) contained in the ORO's plans and procedures.

Each emergency worker should have the basic knowledge of radiation exposure limits as specified in the ORO's plan and/or procedures. Procedures to monitor and record dosimeter readings and to manage radiological exposure control should be demonstrated.

During a plume phase exercise, emergency workers should demonstrate the procedures to be 127

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station followed when administrative exposure limits and turn-back values are reached. The emergency worker should report accumulated exposures during the exercise as indicated in the plans and procedures. OROs should demonstrate the actions described in the plan and/or procedures by determining whether to replace the worker, to authorize the worker to incur additional exposures or to take other actions. If scenario events do not require emergency workers to seek authorizations for additional exposure, evaluators should interview at least two emergency workers, to determine their knowledge of whom to contact in the event authorization is needed and at what exposure levels. Emergency workers may use any available resources (for example, written procedures and/or co-workers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission and adequate control of exposure can be affected for all members of the team by one dosimeter worn by the team leader. Emergency workers who are assigned to low exposure rate areas, for example, at reception centers, counting laboratories, emergency operations centers, and communications centers, may have individual direct-reading dosimeters or they may be monitored by dosimeters strategically placed in the work area. It should be noted that, even in these situations, each team member must still have their own permanent record dosimetry.

Individuals without specific radiological response missions, such as farmers for animal care, essential utility service personnel, or other members of the public who must re-enter an evacuated area following or during the plume passage, should be limited to the lowest radiological exposure commensurate with completing their missions.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

Radiologicalbriefings will be providedto address exposure limits andprocedures to replace personnelapproachinglimits andhow permission to exceed limits is obtainedfrom the municipality and county. Emergency workers will also be briefed on when to take KI and on whose authority.

Distributionof KI will be simulated The completion of a "Dosimetry-KIReport Form" will be demonstrated OROs should also demonstrate the use of all applicabledosimetryforms.

At any time, players may ask other players or supervisors to clarify radiologicalinformation.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station In Pennsylvania, emergency workers outside of the EPZ do not have turn back values.

Emergency workers who are assignedto low exposure rate areas, e.g., at counting laboratories, emergency operationscenters, and communications centers, may have individualpermanent record dosimeters or they may be monitored by dosimeters strategicallyplaced in the work area.

In Pennsylvaniathis will be accomplished through the use of an area kit. The area kit process is explained in State, County and MunicipalPlans.

Standardissue of dosimetry andpotassium iodidefor each category of emergency worker is as follows:

Category A: 1 PRD, 1 DRD, and 1 unit of KI Category B: 1 PRD and I unit of K!

Category C: 1 PRD All locations that have dosimetry equipment indicatedwithin their RadiologicalEmergency Response Plan (RERP), will make the dosimetry equipment (andKI) availablefor inspection by the FederalEvaluator. In order to demonstrate an understandingof the use of the dosimetry equipment, KI and associatedforms; the location need only remove and distribute/ issue a maximum of six (6) units of dosimetry from their inventory. Simulation PRDs with mock serial numbers may be used.

Sub-element 3.b - Implementation of KI Decision INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to provide radio protective drugs for emergency workers, institutionalized individuals, and, if in the plan and/or procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide KI to emergency workers and institutionalized individuals, the provision of KI to the general public is an ORO option and is reflected in ORO's plans and procedures. Provisions should include the availability of adequate quantities, storage, and means of the distribution of radio protective drugs.

129

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Criterion 3.b.l: 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 Offsite Response Organizations (ORO) should demonstrate the capability to make KI available to emergency workers, institutionalized individuals, and, where provided for in the ORO plan and/or procedures, to members of the general public. OROs should demonstrate the capability to accomplish distribution of KI consistent with decisions made. Organizations should have the capability to develop and maintain lists of emergency workers and institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. The ingestion of KI recommended by the designated ORO health official is voluntary.

For evaluation purposes, the actual ingestion of KI is not necessary. OROs should demonstrate the capability to formulate and disseminate appropriate instructions on the use of KI for those advised to take it. If a recommendation is made for the general public to take KI, appropriate information should be provided to the public by the means of notification specified in the ORO's plan and/or procedures:

Emergency workers should demonstrate the basic knowledge of procedures for the use of KI whether or not the scenario drives the use of KI. This can be accomplished through an interview by the evaluator.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play:

Within Pennsylvania,the PennsylvaniaDepartment of Health is responsiblefor distributionof KI to the generalpublic located within the EPZ. Pre-distributionis accomplished on an annual basis. Pennsylvania does not distributeKI at reception centers.

Evaluation of emergency worker KI quantities will be verified using inventory sheets. KI will not 130

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station be removedfrom storage locations and boxes will not be opened. KI questions will be addressed through interviews.

Personnelassignedto operate Monitoring/Decontamination centers and stations are not issued DRDs or KI since the centers/stationsare locatedoutside the EPZ. Simulated PRDs with mock serialnumbers may be issued.

Sub-element 3.c - Implementation of ProtectiveActionsfor Special Populations INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to implement protective action decisions, including evacuation and/or sheltering, for all special populations. Focus is on those special populations that are (or potentially will be) affected by a radiological release from a nuclear power plant.

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)

EXTENT OF PLAY Applicable OROs should demonstrate the capability to alert and notify (for example, provide protective action recommendations and emergency information and instructions) special populations (hospitals, nursing homes, correctional facilities, mobility impaired individuals, transportation dependent, etc.). OROs should demonstrate the capability to provide for the needs of special populations in accordance with the ORO's plans and procedures.

Contact with special populations and reception facilities may be actual or simulated, as agreed to in the Extent of Play. Some contacts with transportation providers should be actual, as negotiated in the extent of play. All actual and simulated contacts should be logged.

All implementing activities associated with protective actions for special populations must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station PEMA Negotiated Extent of Play:

Lists of specialneeds persons including name, address, contact information, and description of need shall be maintainedat their respective municipal EOC (based upon residential jurisdiction). Copies of these lists will not be provided to the evaluators; however, evaluators will be allowed to inspect the lists during the exercise.

Initialcontact, by the County, with specialpopulations (hospitals, nursing homes and county correctionalfacilities)will be actual. All subsequent calls will be simulated. Actual contacts (up to two per Risk County) will be made with transportationprovidersper the county. All actual andsimulated contacts should be logged.

Criterion3.c.2: OROs/School officials implement protective actionsfor schools.

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

EXTENT OF PLAY Public school systems/districts shall demonstrate the ability to implement protective action decisions for students. The demonstration shall be made as follows: At least one school in each affected school system or district, as appropriate, needs to demonstrate the implementation of protective actions. The implementation of canceling the school day, dismissing early, or sheltering should be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process: If accomplished through an interview process, appropriate school personnel including decision making officials (e.g., superintendent/principal, transportation director/bus dispatcher), and at least one bus driver (and the bus driver's escort, if applicable) should be available to demonstrate knowledge of their role(s) in the evacuation of school children. Communications capabilities between school officials and the buses, if required by the plan and/or procedures, should be verified.

Officials of the school system(s) should demonstrate the capability to develop and provide timely information to OROs for use in messages to parents, the general public, and the media on the status of protective actions for schools.

The provisions of this criterion also apply to any private schools, private kindergartens and day care centers that participate in REP exercises pursuant to the ORO's plans and procedures as negotiated in the Extent of Play Agreement.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

School Students will not be involved during the exercise. Actions and activities associatedwith the demonstration of Criterion3. c. 2 will be limited to the School DistrictAdministrationkey personnel and the County. Evacuation of students will be conducted through an interview process with School Districtpersonnel or the buildingprincipal.

The role of the bus driver may be conducted through an interview with school or transportation officials (or designee) if a bus driver is not available. Actual demonstration of the bus route is not requiredand will not be demonstrated. Maps or route descriptionswill be availablefor illustrationpurposes.

Risk County school plans do not require communications between the school and vehicles. Bus drivers are not consideredemergency workers and therefore do not requiredosimetry.

Privateschools, privatekindergartens, andday care centers do notparticipatein REP exercises.

However, OROs will be preparedto show evaluators lists of these facilities that they will contact in the event of an emergency in accordance with plans andprocedures. Any simulated contacts will be logged.

Sub-element 3.d. - Implementation of Traffic and Access Control INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to implement protective action plans, including relocation and restriction of access to evacuated/sheltered areas. This sub-element focuses on selecting, establishing, and staffing of traffic and access control points and removal of impediments to the flow of evacuation traffic.

Criterion 3.d.M: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.g, j) 133

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station EXTENT OF PLAY OROs should demonstrate the capability to select, establish, and staff appropriate traffic and access control points, consistent with protective action decisions (for example, evacuating, sheltering, and relocation), in a timely manner. OROs should demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staff should demonstrate accurate knowledge of their roles and responsibilities. This capability may be demonstrated by actual deployment or by interview, in accordance with the extent of play.*

Where OROs lack the authority to control access for certain types of traffic (rail, water, and air traffic), they should demonstrate the capability to contact the State or Federal agencies who do have the authority to control access.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent ofPlay:

Municipal Traffic and Access control will be demonstratedby interview at the demonstrating EOC ofjurisdiction. The traffic / access controlpersonnel will not be deployed to the traffic /

access controlpoint(s). If the designatedassignment is a location within the EPZ, a radiological briefing will be provided to the assigned individuals.

Reception Centers shallprovide a traffic controlplanfor the location being evaluated.

Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654, J.10.k)

EXTENT OF PLAY OROs should demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation. Actual dispatch of resources to deal with impediments, such as wreckers, need not be demonstrated; however, all contacts, actual or simulated, should be logged. All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station PEMA NegotiatedExtent of Play:

ORO's should demonstrate the capability,as requiredby the scenario, to identify and take appropriateactions concerning impediments to evacuation. Actual dispatch of resources to deal with impediments, such as tow trucks, need not be demonstrated;however, simulatedcontacts will be logged. (Risk counties only)

Sub-element 3.e - Implementation of Ingestion Pathway Decisions INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective actions, based on criteria recommended by current Food and Drug Administration guidance, for the ingestion pathway zone (IPZ), the area within an approximate 50-mile radius of the nuclear power plant. This sub-element focuses on those actions required for implementation of protective actions.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk, and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions. (NUREG-0654, J.9, 11)

EXTENT OF PLAY Applicable ORO's should demonstrate the capability to secure and utilize current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants, and water supply intake points to implement protective actions within the ingestion pathway EPZ. ORO's should use Federal resources as identified in the FRERP, and other resources (e.g., compacts, nuclear insurers, etc.), if available.

Evaluation of these criteria will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

Not demonstratedduring this exercise. This element was demonstratedduring the SSES Post Plume Exercise conductedduring the week ofAugust 16, 2004.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Criterion 3.e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk, and agricultural production. (NUREG-0654, J.9, 11)

EXTENT OF PLAY Development of measures and strategies for implementation of IPZ protective actions should be demonstrated by formulation of protective action information for the general public and food producers and processors. This includes either pre-distributed public information material in the IPZ or the capability for the rapid reproduction and distribution of appropriate reproduction-ready information and instructions to pre-determined individuals and businesses. ORO's should demonstrate the capability to control, restrict or prevent distribution of contaminated food by commercial sectors. Exercise play should include demonstration of communications and coordination between organizations to implement protective actions. Actual field play of implementation activities may be simulated. For example, communications and coordination with agencies responsible for enforcing food controls within the IPZ should be demonstrated, but actual communications with food producers and processors may be simulated.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent ofPlay:

Not demonstratedduring this exercise. This element was demonstratedduring the SSES Post Plume Exercise conducted during the week ofAugust 16, 2004.

Sub-element 3.f - Implementation of Relocation, Re-entry, and Return Decisions INTENT This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should demonstrate the capability to implement plans, procedures, and 136

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station decisions for relocation, re-entry, and return. Implementation of these decisions is essential for the protection of the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a commercial nuclear power plant.

Criterion 3.f.1: Decisions regarding controlled re-entry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented. (NUREG-0654, M.1, 3)

EXTENT OF PLAY Relocation: OROs should demonstrate the capability to coordinate and implement decisions concerning relocation of individuals, not previously evacuated, to an area where radiological contamination will not expose the general public to doses that exceed the relocation PAGs. OROs should also demonstrate the capability to provide for short-term or long-term relocation of evacuees who lived in areas that have residual radiation levels above the PAGs. Areas of consideration should include the capability to communicate with OROs regarding timing of actions, notification of the population of the procedures for relocation, and the notification of, and advice for, evacuated individuals who will be converted to relocation status in situations where they will not be able to return to their homes due to high levels of contamination. OROs should also demonstrate the capability to communicate instructions to the public regarding relocation decisions. ORO's should also demonstrate the capability to provide for short-term or long-term relocation of evacuees .who lived in areas that have residual radiation levels above the (first -, second -, and fifty-year) PAG's.

Re-entry: OROs should demonstrate the capability tocontrol re-entry and exit of individuals who need to temporarily re-enter the restricted area, to protect them from unnecessary radiation exposure and for exit of vehicles and other equipment to control the spread of contamination outside the restricted area. Monitoring and decontamination facilities will be established as appropriate.

Examples of control procedure subjects are: (1) the assignment of, or checking for, direct-reading and non-direct-reading dosimetry for emergency workers; (2) questions regarding the individuals' objectives and locations expected to be visited and associated timeframes; (3) maps and plots of radiation exposure rates; (4) advice on areas to avoid; and procedures for exit, including monitoring of individuals, vehicles, and equipment, decision criteria regarding contamination, proper disposition of emergency worker dosimetry, and maintenance of emergency worker radiation exposure records.

Return: OROs should demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. OROs should demonstrate the capability to identify and prioritize services and facilities that require restoration 137

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After Action Report/Improvement Plan Susquehanna Steam Electric Station within a few days, and to identify the procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads, schools, and intermediate term housing for relocated persons.

Communications among OROs for relocation, re-entry, and return may be simulated; however all simulated or actual contacts should be documented. These discussions may be accomplished in a group setting.

OROs should use Federal resources as identified in the FRERP, and other resources (e.g.,

compacts, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play:

This sub-element will NOT be demonstratedduring this exercise. This was demonstratedduring the SSES Post-Plume Exercise conducted the week ofAugust 16, 2004 EVALUATION AREA 4 Field Measurement and Analysis Sub-element 4.a - Plume PhaseFieldMeasurements and Analyses INTENT This sub-element derives from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume.

In the event of an accident at a nuclear power plant, the possible release of radioactive material 138

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After Action Report/Improvement Plan Susquehanna Steam Electric Station may pose a risk to the nearby population and environment. Although accident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an accident, it is important to collect field radiological data in order to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

Criterion 4.a.l: 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)

EXTENT OF PLAY Field teams should be equipped with all instrumentation and supplies necessary to accomplish their mission. This should include instruments capable of measuring gamma exposure rates and detecting the presence of beta radiation. These instruments should be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on the air sample collection media, consistent with the intended use of the instrument and the ORO's plans and procedures. An appropriate radioactive check source should be used to verify proper operational response for each low range radiation measurement instrument (less than 1 R/hr) and for high range instruments when available. If a source is not available for a high range instrument, a procedure should exist to operationally test the instrument before entering an area where only a high range instrument can make useful readings.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

This sub-element will not be evaluated during this exercise.

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) 139

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After Action Report/Improvement Plan Susquehanna Steam Electric Station EXTENT OF PLAY Responsible Offsite Response Organizations (ORO) should demonstrate the capability to brief teams on predicted plume location and direction, travel speed, and exposure control procedures before deployment.

Field measurements are needed to help characterize the release and to support the adequacy of implemented protective actions or to be a factor in modifying protective actions. Teams should be directed to take measurements in such locations, at such times to provide information sufficient to characterize the plume and impacts.

If the responsibility to obtain peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by State and local monitoring teams. If the licensee teams do not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all field teams (licensee, federal, and ORO) is essential.

Coordination concerning transfer of samples, including a chain-of-custody form, to a radiological laboratory should be demonstrated.

OROs should use Federal resources as identified in the Federal Radiological Emergency Response Plan (FRERP), and other resources (for example, compacts, utility, etc), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

This sub-element will not be evaluatedduring this exercise.

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 140

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After Action Report/Improvement Plan Susquehanna Steam Electric Station appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654, I. 9)

EXTENT OF PLAY Field teams should demonstrate the capability to report measurements and field data pertaining to the measurement of airborne radioiodine and particulates and ambient radiation to the field team coordinator, dose assessment, or other appropriate authority. If samples have radioactivity significantly above background, the appropriate authority should consider the need for expedited laboratory analyses of these samples. OROs should share data in a timely manner with all appropriate OROs. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form for transfer to a laboratory, will be in accordance with the ORO plan and/or procedures.

OROs should use Federal resources as identified in the FRERP, and other resources (for example, compacts, utility, nuclear insurers, etc), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play:

This sub-element will not be evaluatedduring this exercise.

Sub-element 4.b - Post Plume Phase Field Measurements and Sampling INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to assess the actual or potential magnitude and locations of radiological hazards in the IPZ and for relocation, re-entry and return measures.

This sub-element focuses on the collection of environmental samples for laboratory analyses that are essential for decisions on protection of the public from contaminated food and water and direct radiation from deposited materials.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Criterion 4.b.l: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making. (NUREG-0654, 1.8; J.11)

EXTENT OF PLAY The ORO's field team should demonstrate the capability to take measurements and samples, at such times and locations as directed, to enable an adequate assessment of the ingestion pathway and to support re-entry, relocation, and return decisions. When resources are available, the use of aerial surveys and in-situ gamma measurement is appropriate. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form for transfer to a laboratory, will be in accordance with the ORO's plan and/or procedures.

Ingestion pathway samples should be secured from agricultural products and water. Samples in support of relocation and return should be secured from soil, vegetation, and other surfaces in areas that received radioactive ground deposition.

OROs should use Federal resources as identified in the FRERP, and other resources (e.g.,

compacts, utility, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

This element will NOT be demonstratedduring this exercise. This was demonstratedduring the Post Plume Exercise the week ofAugust 16, 2004.

Sub-element 4.c - LaboratoryOperations INTENT This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision-making.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654, C.3; J.11)

EXTENT OF PLAY The laboratory staff should demonstrate the capability to follow appropriate procedures for receiving samples, including logging of information, preventing contamination of the laboratory, preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil (e.g., milk), and keeping track of sample identity. In addition, the laboratory staff should demonstrate the capability to prepare samples for conducting measurements.

The laboratory should be appropriately equipped to provide analyses of media, as requested, on a timely basis, of sufficient quality and sensitivity to support assessments and decisions as anticipated by the ORO's plans and procedures. The laboratory (laboratories) instrument calibrations should be traceable to standards provided by the National Institute of Standards and Technology. Laboratory methods used to analyze typical radio-nuclides released in a reactor incident should be as described in the plans and procedures. New or revised methods may be used to analyze atypical radionuclide releases (e.g.,

transuranics or as a result of a terrorist event) or if warranted by circumstances of the event. Analysis may require resources beyond those of the ORO.

The laboratory staff should be qualified in radioanalytical techniques and contamination control procedures.

OROs should use Federal resources as identified in the FRERP, and other resources (e.g.,

compacts, utility, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

This sub-element will not be evaluatedduring this SSES exercise. This element was demonstrated duringthe 2007 TMI Exercise.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station EVALUATION AREA 5 Emergency Notification and Public Information Sub-element 5.a - Activation of the Prompt Alert and Notification System INTENT This sub-element derives from NUREG-0654, which provides that OROs should have the capability to provide prompt instructions to the public within the plume pathway EPZ. Specific provisions addressed in this sub-element are derived from the Nuclear Regulatory Commission (NRC) regulations (10 CFR Part 50, Appendix E.1V.D.), and FEMA-REP-10, "Guide for the Evaluation of Alert and Notification systems for Nuclear Power Plants."

Criterion 5.a.l: 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 Parts 50, Appendix E.IV.D and NUREG-0654, E.5, 6, 7)

EXTENT OF PLAY Responsible Offsite Response Organizations (ORO) should demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas (permanent resident and transient) throughout the 10-mile plume pathway EPZ. Following the decision to activate the alert and notification system, in accordance with the ORO's plan and/or procedures, completion of system activation should be accomplished in a timely manner (will not be subject to specific time requirements) for primary alerting/notification. The initial message should include the elements required by current FEMA REP guidance.

Offsite Response Organizations (OROs) with route alerting as the primary method of alerting and notifying the public should demonstrate the capability to accomplish the primary route alerting, following the decision to activate the alert and notification system, in a timely manner (will not be subject to specific time requirements) in accordance with the ORO's plan and/or procedures. At least one route needs to be demonstrated and evaluated. The selected route(s) should vary from exercise to exercise. However, the most difficult route should be demonstrated 144

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After Action Report/Improvement Plan Susquehanna Steam Electric Station at least once every six years. All alert and notification activities along the route should be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the mobile public address system will be conducted at some agreed upon location. The initial message should include the elements required by current FEMA REP guidance.

For exercise purposes, timely is defined as "the responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay." If message dissemination is to be identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Procedures to broadcast the message should be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test messages is not required. The alert signal activation may be simulated. However, the procedures should be demonstrated up to the point of actual activation.

The capability of the primary notification system to broadcast an instructional message on a 24-hour basis should be verified during an interview with appropriate personnel from the primary notification system.

All activities for this criterion must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, except as noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

The Commonwealth of Pennsylvaniahas implemented a Statewide EAS Control system in cooperation with the PennsylvaniaAssociation of Broadcastersper the State Emergency Communications Committee and PennsylvaniaEmergency Alert System State EAS Plan (April 1, 2004) (Note that a revisedplan has been submitted to the FCC and is awaitingapproval). The State EOC (PEMA) is the initiatingpointfor the activation of the EAS. Risk Counties have the control equipmentfor activation of sirens. Coordinationwill occur between the State EOC and the affected counties with respect to the Alert andNotification System (ANS) process as to when the sirens and EAS messages will occur. Sirens will be coordinatedand the sounding simulated at the appropriatetime with the simulatedactivation of EAS takingplace approximately 3 minutes following the simulatedactivation of the sirens. Regular Broadcastingwill not be interruptedon the EAS Stations. All subsequent actions to broadcaststations will be simulated.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Broadcastof the message(s) or test message(s) is NOT requiredand NOT requested. Counties may elect to provide Subsequent News Bulletins or County Specific EAS messages to their EAS stations.

Followingthe decision to activate the alert and notificationsystem, in accordance with the ORO's plan and/orprocedures,ANS activationshould be accomplishedin a timely mannerforprimary alerting/notification. This action will NOT be subject to specific time requirements.

All actions to broadcaststations will be simulated Systems that use automatic sending technology may be demonstratedby explanation during an interview.

Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

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, Appendix 3.B.2.c)

EXTENT OF PLAY Offsite Response Organizations (ORO) with FEMA-approved exception areas (identified in the approved Alert and Notification System Design Report) 5-10 miles from the nuclear power plant should demonstrate the capability to accomplish primary alerting and notification of the exception area(s) within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The 45-minute clock will begin when the OROs make the decision to activate the alert and notification system for the first time for a specific emergency situation. The initial message should, at a minimum, include: a statement that an emergency exists at the plant and where to obtain additional information.

For exception area alerting, at least one route needs to be demonstrated and evaluated. The selected route(s) should vary from exercise to exercise. However, the most difficult route should be demonstrated at least once every six years. All alert and notification activities along the route should be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the mobile public address system will be conducted at some agreed-upon location.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Backup alert and notification of the public should be completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. Backup route alerting only needs to be demonstrated and evaluated, in accordance with the ORO's plan and/or procedures and the extent of play agreement, if the exercise scenario calls for failure of any portion of the primary system(s), or if any portion of the primary system(s) actually fails to function. If demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route should be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the mobile public address system will be conducted at some agreed-upon location.

All activities for this criterion must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, except as noted above or otherwise indicated in the extent of play agreement.

PEM4 Negotiated Extent of Play:

Plansspecify that simultaneous Route Alerting will occurfor all municipalitiesfor all siren activations. Each risk county will demonstrate route alertingon one route in one designated municipality. All other routes will be simulated. All routes should be establishedsuch that, in the event of a sirenfailure, the route will be covered within 45 minutesfrom the point at which a sirenfailure is detected.

In accordancewith risk county and risk municipalRERPs, OROs conduct 100% route alertingin support of the Alert and Notification System. OROs with Route Alert responsibilitiesand that are not demonstratingBack-Up Route Alerting (5.a.3) will demonstrate this capabilitythrough interview.

Sub-element 5.b - Emergency Information andInstructionsfor the Public and the Media INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to disseminate to the public appropriate emergency information and instructions, including any recommended protective actions. In addition, NUREG-0654 provides that OROs should ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency. NUREG-0654 also provides that a system should be available for dealing with rumors. This system will hereafter be known as the public inquiry hotline.

Criterion 5.b.l: 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, G.4.c) 14

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After Action Report/Improvement Plan Susquehanna Steam Electric Station EXTENT OF PLAY Subsequent emergency information and instructions should be provided to the public and the media in a timely manner (will not be subject to specific time requirements). For exercise purposes, timely is defined as "the responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay." If message dissemination is to be identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

The ORO should ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information should contain all necessary and applicable instructions (for example, evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, information concerning pets, shelter-in-place instructions, information concerning protective actions for schools and special populations, public inquiry telephone number, etc.) to assist the public in carrying out protective action decisions provided to them. The ORO should also be prepared to disclose and explain the Emergency Classification Level (ECL) of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs should demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

The emergency information should be all-inclusive by including previously identified protective action areas that are still valid, as well as new areas. The OROs should demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the OROs should demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plan and/or procedures.

OROs should demonstrate the capability to develop emergency information in a non-English language when required by the plan and/or procedures.

If ingestion pathway measures are exercised, OROs should demonstrate that a system exists for rapid dissemination of ingestion pathway information to pre-determined individuals and businesses in accordance with the ORO's plan and/or procedures.

OROs should demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include 148

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After Action Report/Improvement Plan Susquehanna Steam Electric Station of the capability to conduct timely and pertinent media briefings and distribute media releases as the situation warrants. The OROs should demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and media releases should be consistent with protective action decisions and other emergency information provided to the public. Copies of pertinent emergency information (e.g., EAS messages and media releases) and media information kits should be available for dissemination to the media.

OROs should demonstrate that an effective system is in place for dealing with calls to the public inquiry hotline. Hotline staff should demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, should be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.

All activities for this criterion must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise

.indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

Subsequent emergency information and instructionsshould be provided to the public and the media in a timely manner. This will NOT be subiect to specific time requirements.

One media briefing will be demonstratedin each risk county.

Risk and Support Counties will receive and handle "PublicInquiry" messages via their individual "PublicInquiry" processes (In compliance with NIMS terminology, Rumor Control is now considered to be "Public Inquiry"). Counties will receive approximately ten (10) public inquiry calls from the State Exercise cell assigned this responsibility. Counties will be expected to receive and log the calls, identify any trends and take appropriateactions to includefollow-up message development, distributionsand/or briefings.

EVALUATION AREA 6 Support Operation/Facilities Sub-element 6.a - Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees 149

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After Action Report/Improvement Plan Susquehanna Steam Electric Station INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to implement radiological monitoring and decontamination of evacuees and emergency workers, while minimizing contamination of the facility, and registration of evacuees at reception centers.

Criterion 6.a.l: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel 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 Radiological monitoring, decontamination, and registration facilities for evacuees/ emergency workers should be set up and demonstrated as they would be in an actual emergency or as indicated in the extent of play agreement. This would include adequate space for evacuees' vehicles. Expected demonstration should include 1/3 of the monitoring teams/portal monitors required to monitor 20% of the population allocated to the facility within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Before using monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation.

Staff responsible for the radiological monitoring of evacuees should demonstrate the capability to attain and sustain a monitoring productivity rate per hour needed to monitor the 20%

emergency planning zone (EPZ) population planning base within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This monitoring productivity rate per hour is the number of evacuees that can be monitored per hour by the total complement of monitors using an appropriate monitoring procedure. A minimum of six individuals per monitoring station should be monitored, using equipment and procedures specified in the plan and/or procedures, to allow demonstration of monitoring, decontamination, and registration capabilities. The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators in order to determine whether the twelve-hour requirement can be met. Monitoring of emergency workers does not have to meet the twelve-hour requirement. However, appropriate monitoring procedures should be demonstrated for a minimum of two emergency workers.

Decontamination of evacuees/emergency workers may be simulated and conducted by interview.

The availability of provisions for separately showering should be demonstrated or explained. The staff should demonstrate provisions for limiting the spread of contamination. Provisions could 150

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After Action Report/Improvement Plan Susquehanna Steam Electric Station include floor coverings, signs and appropriate means (for example, partitions, roped-off areas) to separate clean from potentially contaminated areas. Provisions should also exist to separate contaminated and uncontaminated individuals, provide changes of clothing for individuals whose clothing is contaminated, and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any individual found to be contaminated, procedures should be discussed concerning the handling of potential contamination of vehicles and personal belongings.

Monitoring personnel should explain the use of action levels for determining the need for decontamination. They should also explain the procedures for referring evacuees who cannot be adequately decontaminated for assessment and follow up in accordance with the ORO's plans and procedures. Contamination of the individual will be determined by controller inject and not simulated with any low-level radiation source.

The capability to register individuals upon completion of the monitoring and decontamination activities should be demonstrated. The registration activities demonstrated should include the establishment of a registration record for each individual, consisting of the individual's name, address, results of monitoring, and time of decontamination, if any, or as otherwise designated in the plan. Audio recorders, camcorders, or written records are all acceptable means for registration.

All activities associated with this criterion must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

Radiologicalmonitoring demonstrationsites shouldpossess a rosterof the monitoringpersonnel requiredto process 2 0% of the population allocatedto thefacility within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period To demonstrate the monitoringprocess, a minimum of six individualsposing as simulated evacuees should be monitoredper monitoringfacility. As an option, it will be acceptable to monitor one individual six times.

Waterfrom decontaminationactivitiesmay go directly to a storm drain or other sewer or drain system or area normally designatedfor wastewater that has been usedfor bathing or washing of vehicles and or equipment.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station At each reception center a minimum of three volunteer evacuees will be processed, briefed, issued the appropriatestrip map or directions, and instructedto proceed to a mass care center designatedfor demonstration of monitoring,decontamination,and registration. A sample of the appropriatestrip maps or directions will be made availablefor the demonstration.As negotiated with FEMA, this criterion will be demonstratedbut not be evaluatedbecause registrationis not done at the reception center.

One mass care center and one mass care monitoring/decontaminationcenter will be demonstratedper support county duringthe out-of-sequence window county (Exception -

Montour County does not operate any mass care centers). The support counties will provide space at designatedmass care centersfor operationof monitoring/decontaminationcenters.

Schematics of these monitoring/decontaminationcenters will be available to show the organizationwithin the facility and space managementfor monitoring and decontamination.

Procedureswill be demonstratedto evidence the separationof contaminatedand non-contaminated(clean) individuals.

At the evacuee monitoring/decontaminationcenter, a minimum of six (6) volunteer evacuees will be monitored(or one volunteer evacuee may be monitoredsix times). Suitable radiological monitoring instruments will be issued to and demonstratedby the initialmonitoringteam(s). A monitoring team consists of one monitor and one recorderequipped with one survey instrument.

Those individualsfound to be free of "contamination", based upon scenario injects, will be directed to the mass care registrationpointforfurtherprocessing. Note: Actual radiological sources will not be attachedto or hidden upon the volunteer evacuees. Note: Ifportal monitors are used, the PortalMonitor Extent of Play describedbelow shall be used One of the simulatedevacuees, based upon controllerinjects, will not be able to be decontaminated. Discussions concerningthe processingof contaminatedpersonnel will include capabilitiesand written proceduresfor showeringfemales separatefrom males. Showering will be simulated,water will not be used. Note: If portalmonitors are used, the PortalMonitor Extent of Play describedbelow shall be used.

At the emergency worker monitorinj/decontaminationstations one emergency worker will be monitored. Discussions concerningprocessingof contaminatedpersonnelwill include capabilitiesand written proceduresfor showeringfemales separatefrom males. Showering will be simulated,water will not be used. Suitable radiologicalmonitoring instruments will be issued to the initialmonitoring team. Note: If portal monitors are used, the PortalMonitor Extent of Play describedbelow shall be used.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station PortalMonitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees and / or emergency workers. The monitoring/

decontamination team requirements will be based on the portal monitor capabilitiesas applicable based on the procedure/guidelines, and the recommendations of the manufacturer.

Note: PEMA guidance shall apply.

Monitoring/decontaminationcenters and Emergency Worker monitoring and decontamination stationpersonnel are not issued DRDs or KI since the centers and stations are outside the EPZ.

Category "C" Dosimetry applies. PersonalRecord Dosimeters (PRD's) will be simulated Radiation readings/ contaminationdatafor the evacuees and vehicle will be provided by the controlleras appropriatebased upon information contained in the scenariopackage. Set-up of thefacility will be performed the same asfor an actual emergency with all route markings and contaminationcontrol measures in place including step-offpads. Long runs ofplastic covered with paper will not be demonstrated,but the materialsshall be availableand explained Positioningof afire apparatuson-site may be simulatedif otherwise required Sub-element 6.b - Monitoring and Decontaminationof Emergency Worker Equipment INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to implement radiological monitoring and decontamination of emergency worker equipment, including vehicles.

Criterion 6.b.l: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment, including vehicles. (NUREG-0654, K.5.b)

EXTENT OF PLAY The monitoring staff should demonstrate the capability to monitor equipment, including vehicles, for contamination in accordance with the Offsite Response Organizations (ORO) plans and procedures. Specific attention should be given to equipment, including vehicles, that was in contact with individuals found to be contaminated. The monitoring staff should demonstrate the capability to make decisions on the need for decontamination of equipment, including vehicles, based on guidance levels and procedures stated in the plan and/or procedures.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station The area to be used for monitoring and decontamination should be set up as it would be in an actual emergency, with all route markings, instrumentation, record keeping and contamination control measures in place. Monitoring procedures should be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles should be demonstrated. Interior surfaces of vehicles that were in contact with individuals found to be contaminated should also be checked.

Decontamination capabilities, and provisions for vehicles and equipment that cannot be decontaminated, may be simulated and conducted by interview.

All activities associated with this criterion must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

Emergency Worker locations will be evaluated on 10/06/10.

Emergency worker stationpersonnel will consist of a minimum of one monitor and one recorder andsufficient personnel to demonstrate monitoringof at least one vehicle. Schematics of these monitoring/decontaminationstations will be available to show organizationand space management. The evaluatorwill request that vehicle decontaminationprocedures be explained after the vehicle (with simulatedcontamination)has been monitored. One radiologicalsurvey meter, will be issued to each vehicle monitoring/decontaminationteam. One vehicle and/or piece of equipment will not be able to be decontaminated. Simulated radiationcontamination data will be included in the scenariopackage, and injected by a controller. Set-up of thefacility will be performed as closely as possible to thatfor an actual emergency with all route markings in place.

Decontaminationcapabilitiesandprovisionsfor vehicles and/or equipment that cannot be decontaminatedwill be simulatedand conducted by interview. Water will NOT be used.

Sub-element 6.c - Temporary Care of Evacuees INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) demonstrate the capability to establish relocation centers in host areas. The American Red Cross (ARC) normally provides, congregate care in support of OROs under existing letters of agreement.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station 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 before entering congregate care facilities. (NUREG-0654, J.10.h, J.12)

EXTENT OF PLAY Under this criterion, demonstration of congregate care centers may be conducted out of sequence with the exercise scenario. The evaluator should conduct a walk-through of the center to determine, through observation and inquiries, that the services and accommodations are consistent with ARC 3031. In this simulation, it is not necessary to set up operations as they would be in an actual emergency. Alternatively, capabilities may be demonstrated by setting up stations for various services and providing those services to simulated evacuees. Given the substantial differences between demonstration and simulation of this objective, exercise demonstration expectations should be clearly specified in extent-of-play agreements.

Congregate care staff should also demonstrate the capability to ensure that evacuees have been monitored for contamination, have been decontaminated as appropriate, and have been registered before entering the facility. This capability may be determined through an interview process.

If operations at the center are demonstrated, material that would be difficult or expensive to transport (for example, cots, blankets, sundries, and large-scale food supplies) need not be physically available at the facility (facilities). However, availability of such items should be verified by providing the evaluator a list of sources with locations and estimates of quantities.

All activities associated with this criterion must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

Each of the supportcounties (Exception- Montour County) will demonstrate the operation of one mass care center during the out-of-sequence window. Floorplans with flow diagrams of the mass care centers will be availableto show organizationwithin the facility andspace management during a real emergency. Mass care center locations are listed in the demonstration tables "Demonstrationof Mass Care Centers (AttachmentA, Section LB.2) ".

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Personnel,at a minimum, will consist of one managerand one assistantfor each mass care center opened during the out-of-sequence window. The evaluator will expect to see sources and quantities of equipment andsupplies as well as a staffing chart byjob titlefor 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing. Schematics of these mass care centers will be available,during the demonstration window, to show organization within thefacility and space allocationfor the registrationandsheltering the evacuatingpublic.

Necessary signs, directionalarrowsandforms will be availableand used to demonstrate registration,at a minimum, of three evacuees requiringemergency housing. Evacuees will be shown the location where they would be housed in an actualsituation. Bedding, cots,food, etc.

normally associatedwith mass care will not be moved to the site, but the sources of those items should be explained to FEMA evaluators. This out-of-sequence demonstrationwindow will befrom 7:00 PM- 9:30 PMon 10/6/2010.

American Red Cross support county chapters:

Wyoming County Chapter 455 SR6 East, Suite 2 P.O. Box 386 Tunkhannock, PA 18657 (570)-836-2626 FAX: (570)-836-3691 E-mail: redcross(oepix.net wMocoARC(iusa.redcross.org Lycoming County Chapter Kathy Stine 320 East 3rd Street Williamsport, PA 17701 (570)-326-9131 FAX: (570)-326-2514 E-mail kstein@ncparedcross.org Scranton Chapter Charlotte Wright 545 Jefferson Avenue Scranton, PA 18510 (570)-344-7281 FAX: (570)-344-6534 E-mail: cwright(ineparc.org 156

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After Action Report/Improvement Plan Susquehanna Steam Electric Station ARC in Schuylkill and Eastern Northumberland County Tim Firestone 1402 Laurel Boulevard Pottsville, PA 17901 (570)-622-9550 FAX: (570)-622-9654 E-mail: redcrossed(,comcast. net Upper Northumberland County Chapter 560 Mahoning Street Milton, PA 17847 (570)-742-9551 FAX (570)-742-2180 E-mail: arcofunc(-ptd.net Union County Chapter 249 Farley Circle P.O. Box 82 Lewisburg, PA 17837 (570)-524-0400 FAX: (570)-524-0462 E-mail: unionarcdis(Zdejazzd.com Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO's) should have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Criterion 6.d.l: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654, F.2; H.10; K.5, a, b; L.1, 4) 157

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After Action Report/Improvement Plan Susquehanna Steam Electric Station EXTENT OF PLAY Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the victim.

Offsite Response Organizations (ORO) should demonstrate the capability to transport contaminated injured individuals to medical facilities. An ambulance should be used for the response to the victim. However, to avoid taking an ambulance out of service for an extended time, any vehicle (e.g., car, truck, or van) may be utilized to transport the victim to the medical facility. Normal communications between the ambulance/dispatcher and the receiving medical facility should be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur prior to releasing the ambulance from the drill. This communication would include reporting radiation-monitoring results, if available. Additionally, the ambulance crew should demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

Monitoring of the victim may be performed prior to transport, done en route, or deferred to the medical facility. Prior to using a monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities should be completed, as they would be in an actual emergency. Appropriate contamination control measures should be demonstrated prior to and during transport and at the receiving medical facility.

The medical facility should demonstrate the capability to activate and set up a radiological emergency area for treatment. Equipment and supplies should be available for the treatment of contaminated injured individuals.

The medical facility should demonstrate the capability to make decisions on the need for decontamination of the individual, to follow appropriate decontamination procedures, and to maintain records of all survey measurements and samples taken. All procedures for the collection and analysis of samples and the decontamination of the individual should be demonstrated or described to the evaluator.

All activities associated with this criterion must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

This sub element was demonstratedduringa MS-1 Drill in October 2009.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Frequency for Evaluation of New Criteria NOTE: This sub-element was evaluated at Susquehanna Health MS-1 on October 1, 2009.

ATTACHMENT A Susquehanna Steam Electric Station 2010 Extent of Play Demonstration Tables I. PLUME PHASE EXERCISE -

A. Activities - 10/05/2010

1. Risk Public School Districts with schools located within the EPZ and those districts situated outside the EPZ, but with students living within the EPZ, will participate and be evaluated by the Federal Emergency Management Agency.

Each identified District Administration Office will be evaluated. When a school system is comprised of multiple buildings (High School, Middle School, Elementary School), the affected buildings (those with students from the EPZ) will be evaluated on a rotational basis to coincide with the six-year exercise cycle.

Time: Out of Sequence - 9:00 - 11:00 AM COUNTY SCHOOL DISTRICT SCHOOL(s) participating in the 2010 exercise Columbia Berwick Area School District Berwick High School and 14 th Street.

Elementary Columbia Benton Area School District Benton Area High School Columbia Bloomsburg Area School District Bloomsburg Area High School Columbia Central Columbia School District Central Columbia Middle School Columbia Columbia Montour AVTS (Vo-Tech) Columbia Montour AVTS Luzerne Crestwood Area School District Crestwood Area Middle School Luzeme Greater Nanticoke Area School District Greater Nanticoke Elementary Center and J F Kennedy Elementary School Luzerne Hazleton Area School District Valley Elementary School Luzerne Northwest Area School District Hunlock Creek Elementary School 159

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Susquehanna Steam Electric Station Luzerne West Side Career & Technology Center West Side C&TC Luzerne Wilkes Barre Career & Technology Wilkes Barre C&TC Center NOTE: Montour County EOC will be evaluated during this phase.

2. County Emergency Operations Centers (EOC's)

Time: Per Scenario DEMONSTRATION FOR EOC MOBILIZATION FOR COUNTIES (Plume Phase Exercise)

COUNTY DATE Time Columbia 10/05/10 04:00 p.m. - 10:30 p.m.

Luzerne 10/05/10 04:00 p.m. - 10:30 p.m.

Lackawanna 10/05/10 04:00 p.m. - 10:30 p.m.

Lycoming 10/05/10 04:00 p.m. - 10:30 p.m.

• Montour 10/05/10 09:00 a.m. - 11:00 a.m.

Northumberland 10/05/10 04:00 p.m. - 10:30 p.m.

• • Schuylkill 10/05/10 04:00 p.m. - 10:30 p.m.

Union 10/05/10 04:00 p.m. - 10:30 p.m.

Wyoming 10/05/10 04:00 p.m. - 10:30 p.m.

• NOTE: Montour County EOC will be evaluated during the schools exercise on 10/05/10

• • NOTE: Schuylkill County EOC will participate but has been granted exemption from evaluation by FEMA.

3. Municipal Emergency Operations Centers (EOC)

Time: 04:00 p.m. - 10:30 p.m. 10/5/10 NOTE: Only the agencies in BOLD will be evaluated for this exercise DEMONSTRATION FOR EOC MOBILIZATION FOR MUNICIPALITIES (Plume Phase Exercise)

RISK COUNTY MUNICIPALITY DATE Columbia Beaver Township Berwick Borough/ Briar Creek Borough* 10/5/10 160

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Briar Creek Township *1-S

+

Fishing Creek Township i1 Mifflin Township North Centre Township 10/5/10 South Centre Township 10/5/10 Luzerne Black Creek Township Butler Township/ Conyngham Borough*

Conyngham Township 10/5/10 Dorrance Township 10/5/10 Hollenback Township 10/5/10 Hunlock Township Huntington Township/ New Columbus Borough*

Nanticoke City 10/5/10 Nescopeck Borough Nescopeck Township Newport Township Nuangola Borough Shickshinny Borough Slocum Township 10/5/10 Sugarloaf Township Union Township Salem Township

• Joint EOC's

4. Route alerting will be demonstrated by one municipality in each risk county during scenario exercise.

Columbia North Centre Township 10/5/10 Luzerne Conyngham Township 10/5/10 161

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After Action Report!Improement Plan Susquehanna Steam Electric Station

5. Traffic and Access Control Points

a. The Pennsylvania State Police will brief at the PSP Bloomsburg Barracks, Those attending the briefing will not actually deploy to the TCP/ACPs.

b. The PSP briefing will be performed out of sequence in a demonstration window of 10:00 a.m. to 12:00 noon on Wednesday, 10/06/10.

c. Evaluated municipalities with a TCP assigned in its plan will demonstrate all preparation duties including TCP responsibilities and radiological briefing during the county/municipal plume exercise on the evening of 10/5/10. Dispatch of persons to the TCP site will not occur during the exercise. For this exercise South Centre Township in Columbia County and Nanticoke City in Luzern County will be evaluated.

d. Municipal and county staffs will be prepared to brief the FEMA evaluator on actions to be taken should there be an impediment to evacuation on a designated route. This will be demonstrated anytime during the exercise.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station B. October 6, 2010

1. Reception Centers (Out of Sequence)

DEMONSTRATION of Reception Centers COUNTY DATE Time Lackawanna 10/6/10 7:00 p.m. - 9:30 p.m.

Lycoming 7:00 p.m. - 9:30 p.m.

Northumberland 7:00 p.m. - 9:30 p.m.

Schuylkill 7:00 p.m. - 9:30 p.m.

Union _ I 7:00 p.m. - 9:30 p.m.

Wyoming 10/6/10 7:00 p.m. - 9:30 p.m.

COUNTY Reception Center Location Lackawanna Big Lots, Scranton Lycoming Lycoming Mall, Pennsdale Northumberland Shikellemy High School, Sunbury Schuylkill Marion High School, Tamaqua Union Montandon Elementary School, Montandon Wyoming Tunkhannock Middle School, Tunkhannock

2. Mass Care Centers and Monitoring / Decontamination Centers (Out of Sequence)

COUNTY DEMONSTRATION of Mass Care Centers DATE Time Lackawanna 10/6/10 7:00 p.m. - 9:30 p.m.

Lycoming 7:00 p.m. - 9:30 p.m.

Northumberland 7:00 p.m. - 9:30 p.m.

Schuylkill 7:00 p.m. - 9:30 p.m.

Union I 7:00 p.m. - 9:30 p.m.

Wyoming 10/6/10 7:00 p.m. - 9:30 p.m.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station COUNTY Mass Care Center Locations Quantity Lackawanna Dunmore YMCA 1 Lycoming Hughesville High School** 1 Northumberland Shikellemy High School, Sunbury 1 Schuylkill Marion High School 1 Union Lewisburg High School 1 Wyoming Tunkhannock Middle School Complex 1

• • Hughesville High School is undergoing remodeling. Floor plan and school walk through will be provided however the equipment setup will occur outside or at another location.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station

3. Emergency Worker Monitoring / Decontamination Stations (Out of Sequence)

Time: 7:00 - 9:30 PM Columbia I Columbia Montour Vo-Tech 10/6/10 Luzerne Wright Township Fire Dept. 10/6/10 II. POST PLUME EXERCISE Not Applicable for this Exercise. The Post-Plume Exercise was conducted in conjunction with the SSES 2004 exercise.

Attachment B Listing of Prior Issues (Pennsylvania)

Reference # FACILITY EVALUATED CRITERIA Current Status Areas Requiring Corrective Action IA Berwick Borough/Briar Creek Borough Emergency 63-08-3.b3l-A-01 Open Operations Center 2A Berwick Borough/Briar Creek Borough Emergency 63-08-3.c.2-A-02 Open Operations Center 3A Berwick Borough/Briar Creek Borough Route Alerting 63-08-5.a.3-A-03 Open 4A Hunlock Township Emergency Operations Center 63-05-3.a. 1-A-04 Re-demonstrated Planning Issues IP Columbia County 63-08-3.c.2-P-04 Open Areas Requiring Corrective Action Reference 1A Issue Number: 63-08-3.b.1-A-01 Condition: The Emergency Operations Center (EOC) received notification from the Columbia County EOC over the radio and telephone that Emergency Workers were to ingest potassium iodide (KI). However, these messages were not passed forward to the Emergency Management Coordinator.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Possible Cause: The Communication Officer (CO), who is stationed outside the main EOC room, apparently did not receive all messages.

References:

NUREG-0654, J.10.e Berwick/Briar Creek Borough Radiological Response Plan Effect: Emergency workers in the 10-mile Emergency Planning Zone could have been exposed to radioactive iodine without the protection of KI.

Recommendation: The CO should be trained to obtain, log, and distribute all messages. The Emergency Management Coordinator should be kept informed about important messages affecting the emergency workers and the public.

Commonwealth Response: The Commonwealth agrees with the above recommendation. The Communications Officer will be provided additional training to obtain, log, and distribute all important messages and shall demonstrate during the next scheduled biennial exercise.

Reference 2A Issue Number: 63-08-3.c.2-A-02 Condition: The Emergency Medical Services Representative did not provide Fire/Rescue personnel with contact information for all hearing impaired individuals for their use in route alerting and failed to notify or address other special needs individuals.

Possible Cause: The Medical Services Representative was not cognizant of his responsibilities with respect to special needs individuals.

References:

NUREG-0654, J.10.c, d, g Berwick/Briar Creek Borough Radiological Response Plan, V.E and X.F Effect: Some hearing impaired and other special needs individuals, including visually impaired, wheelchair-bound, and transportation dependent individuals, might not have been alerted to the evacuation decision and would not have received timely transportation assistance.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Recommendation: The Medical Services Representative should receive training in the position's responsibilities and activities as specified in the Berwick/Briar Creek Borough Radiological Response Plan and standard operating procedures.

Commonwealth Response: The Commonwealth agrees with the above recommendation. The Emergency Medical Services Representatives will be retrained to ensure they are competent in the use of the Berwick/Briar Creek Borough Radiological Response Plan and standard operating procedures and shall demonstrate during the next scheduled biennial exercise.

Reference 3A Issue Number: 63-08-5.a.3-A-03 Condition: The crew that demonstrated the Berwick Borough/Briar Creek Borough (BBC) backup alert route (Zone 1) ran the route simulating the use of the vehicle's siren, emergency lights and public address system. After completing the route, the crew was asked to demonstrate the vehicle's emergency notification equipment. The siren and emergency lights tests were satisfactory. However, the volume of the public address system was insufficient to provide adequate carrying power of the message. The volume was not much louder than ordinary conversation level. Several minutes were spent attempting to raise the volume without success.

The crew was advised that if the volume could be raised, a re-demonstration could occur.

Eventually, the BBC Emergency Management Director and the Fire/Rescue Officer were informed and agreed that the volume could not be improved.

Possible Cause: A mechanical malfunction within the public address system is the most likely cause.

References:

NUREG-0654, E.5, 6, 7 Effect: Without sufficient volume, any emergency message delivered over the vehicle's public address system could not be understood at any distance beyond 30 feet of the truck. This could delay intended recipients from taking the proper course of action and might also lead to more confusion as to why the fire engine is passing by with lights on and intermittent siren soundings.

Recommendation: It is recommended that the BBC authorities correct the insufficient volume of the public address system.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Commonwealth Response: The Commonwealth agrees with the above recommendation. The mechanical malfunction within the public address system for this vehicle has been repaired and tested. This vehicle will be available for demonstration during the next scheduled biennial exercise.

Reference 4A Issue Number: 63-08-3.a.1-A-04 Condition: The Hunlock Township Radiological Officer lacked sufficient knowledge to conduct the radiological briefing for emergency workers and did not have the "standardized" radiological briefing material provided by the Commonwealth of Pennsylvania. He was not knowledgeable on the use of the electronic dosimeters, did not know the correct exposure limits, and was unaware of the requirements and cautions regarding ingestion of potassium iodide (KI).

Possible Cause: The Radiological Officer was new and lacked familiarity with procedures regarding radiological exposure.

References:

NUREG-0654, K.3.a; K.3.b SOP-I (Radiological Protection Services Officer) of the Hunlock Township Radiological Emergency Response Plan of 1996, 2008 revision Effect: Emergency workers were not informed of their exposure limits and the requirements and cautions regarding ingestion of KI.

Recommendation: Provide additional training to the Radiological Officer.

Corrective Action Demonstrated: The Radiological Officer was provided retraining regarding SOP-I and given an opportunity to read material associated with dosimetry and KI. He successfully re-demonstrated an adequate radiological briefing.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station Planning Issues Reference 1P Columbia County Issue Number: 63-08-3.c.2-P-04 Condition: The Columbia County RERP, Change 6, 2008 in Appendix 14, Attachment B indicates the Host School for the Salem Elementary School as being the Mahoney-Cooper Elementary School. The correct listing should be the Liberty Valley Elementary School, which is reflected in the Berwick School District's plans.

Possible Cause: Change was made a few years ago, and this portion of the Columbia County Plan was not changed to reflect this.

Reference:

NUREG-0654, P.4 Effect: Possible confusion at Columbia County EOC about location of host school for the Salem Elementary School.

Recommendation: Update Columbia County RERP in Appendix 14, Attachment B to reflect current host school.

Corrective Action Demonstrated: A comprehensive review and revision of the Columbia County RERP was conducted during 2009. The plan was corrected with Mahoney-Cooper Elementary School being replaced with Liberty Valley Elementary School.

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After Action Report/Improvement Plan Susquehanna Steam Electric Station This page is intentionally blank.

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