ML040850632

FEMA: Final Exercise Report, H. B. Robinson Steam Electric Plant

ML040850632
Person / Time
Site:	Robinson
Issue date:	01/12/2004
From:	Burris K Federal Emergency Management Agency
To:	Reyes L NRC/RGN-II
Schneck D 415-3079 NRR/NUEPPO
References
Download: ML040850632 (51)

Text

ITS. Iparlntent or Ihinmalnd Securits Rcgion IV 3(X)3 Chambsle TUcker Riud Atlatah. iA 3(0341 2 FEMA Final Exercise Report H. B. Robinson Steam Electric Plant Licensee: Progress Energy Exercise Date: October 7, 2003 Report Date: January 12, 2004 w^viv. Fe a o %gz

U.S. Department of Homeland Security Region IV 3003 Chamblee Tucker Road Atlanta, GA 30341 I FEMA January 12, 2004 Mr. Luis A. Reyes Regional Administrator - Rll Nuclear Regulatory Commission 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303

Dear Mr. Reyes:

Enclosed is a copy of the final exercise report for the October 7, 2003, full participation, plume exposure pathway exercise of the offsite radiological emergency response plans site-specific to the H. B. Robinson Nuclear Station. This report addresses the evaluation of the plans and preparedness for the State of South Carolina and Chesterfield, Darlington, And Lee Counties within the 10-Mile Emergency Planning zone and Florence County, a host county. The Federal Emergency Management Agency Region IV staff prepared the final exercise report. Copies of this report will be forwarded to the State of South Carolina, FEMA Headquarters and NRC Headquarters by my staff.

State and County personnel, as well as, numerous volunteers and elected officials participated in this exercise.

The Emergency Alert System (LP-I) radio station WJMX, added realism by participating in the exercise and demonstrated its commitment to keep the residents of South Carolina informed during an emergency. The State of South Carolina and the counties have dedicated emergency response staff who are serious and professional in executing their duties.

The Department of the Health and Environmental Control dispatched their field teams from Columbia for the exercise. The radiological monitoring field teams professionally performed their duties. Although they also dispatched a mobile laboratory to the Darlington National Guard Armory, the Forward EOC, the mobile laboratory only demonstrated sample screening and did not demonstrate the capabilities required of a radiological laboratory. We have discussed this situation with the State of South Carolina and will evaluate their laboratory capabilities during the January 13, 2004, Oconee Exercise. The evaluation of the radiological laboratory should verify the last of the DHEC capabilities that were called into question after the July 2003 V.C. Summer exercise.

No Deficiencies or Areas Requiring Corrective Action (ARCA) were identified during this exercise. The ARCA concerning the direction and control of field teams identified during the July 2003 V. C. Summer exercise was corrected during this exercise.

wiviv.fema.gov

Based on the results of the October 7, 2003, exercise and FEMA's review of the State's Annual Letters of Certification for 2001 and 2002, the offsite radiological emergency response plans for the State of South Carolina and the affected local jurisdictions, site-specific to the H. B. Robinson Nuclear Station can be implemented and are adequate to provide a reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site. The Title 44 CFR, Part 350, approval of the State of South Carolina's offsite radiological emergency response plans and preparedness site-specific to the H. B. Robinson Nuclear Station, granted on December 29, 1981, will remain in effect.

Should you have any questions, please contact Eddie Hickman at 770/220-5370.

Sincerely, Kenneth . Burris, Jr. -

Regional Director Enclosure cc: Ms. Vanessa E. Quinn, Chief Federal Emergency Management Agency Headquarters Radiological and Emergency Preparedness Branch - NP-TS-RP 500 C eet, SW, Room 202 Washington, D. C. 20472 t4s. Debra A. Schneck, Chief Emergency Preparedness and Health Physics Section Operator Licensing, Human Performance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

U.S. IDepartmenl of Iluniland Securit%

Region IV 3003 C(hatmbiee Tucker Road Atlanta. (6A 30341 t FEMA 4~,, ,. i .

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Final Exercise Report . .; - .,l H. B. Robinson Steam Electric Plant Leo E

Licensee: Progress Energy, I. ., I.

Exercise Date: October 7, 2003 Report Date: January 12, 2004 weww.fema.gov

TABLE OF CONTENTS Page

1. EXECUTIVE

SUMMARY

.................................................................................................I II. INTRODUCTION................................................................................................................2 III. EXERCISE OVERVIEW ................................. 4 A. Emergency Planning Zone Description ............................... 4 B. Exercise Participants ................................. 4 C. Exercise Timeline ................................. 5 IV. EXERCISE EVALUATION AND RESULTS ....... ......................... 7 A. Summary Results of Exercise Evaluation - Table 2 ................................... 7 B. Status of Jurisdictions Evaluated .................................... 9

1. STATE OF SOUTH CAROLINA ....................... 11 1.1 State Emergency Operations Center ............................... 11 1.2 Radiological Liaison ............................... 11 1.3 Dose Assessment ............................... 12 1.4 Mobile Laboratory ............................... 13 1.5 Radiological Field Monitoring Teams ............................... 14 1.6 Emergency Operations Facility ............................... 14 1.7 Joint Information Center ............................... 15 1.8 LP-I Radio Station WJMX ............................... 15 1.9 State Traffic Control Point ............................... 16

2. RISK JURISDICTIONS ................ 16 2.1 CHESTERFIELD COUNTY ............................... 16 2.1.1 Emergency Operations Center ............................... 16 2.1.2 Protective Actions for Schools ............................... 17 2.1.3 Traffic Control Points ............................... 1.8 2.1.4 Emergency Worker Decontamination ............................... 18 2.1.5 Reception and Congregate Care ............................... 19 i

2.2 DARLINGTON COUNTY ....................................... 19 2.2.1 Emergency Operations Center ....................................... 19 2.2.2 Protective Actions for Schools ....................................... 20 2.2.3 Traffic Control Points ....................................... 20 2.2.4 Emergency Worker Decontamination ............................... 21 2.2.5 Lake Warning ....................................... 21 2.2.6 Medical Service Drill (MS-I) ....................................... 22 2.3 LEE COUNTY ....................................... 23 2.3.1 Emergency Operations Center ....................................... 23 2.3.2 Traffic Control Points ....................................... 24 2.3.3 Emergency Worker Decontamination ............................... 24 2.3.4 Reception and Congregate Care Center ............................. 25

3. HOST JURISDICTION . . ................................25 3.1 FLORENCE COUNTY ........................................ 25 3.1.1 Reception and Congregate Care ........................................ 25

4.

SUMMARY

OF AREAS REQUIRING CORRECTIVE ACTION ......... 27 4.1 PRIOR ARCAs RESOLVED .................................... 27 4.1.1 61-03-4.a.2-A-01 State of South Carolina Dose Assessment ...................................... 27 4.2 NOT DEMONSTRATED ...................................... 28 4.2.1 Mobile Laboratory Exercise Area Criterion ..................... 28 List of Appendices APPENDIX I - ACRONYMS AND ABBREVIATIONS .29 APPENDIX 2 - EXERCISE EVALUATORS .31 APPENDIX 3 - EXERCISE CRITERIA AND EXTENT-OF-PLAY AGREEMENT .33 APPENDIX 4 -EXERCISE SCENARIO .34 ii

List of Tables Table I - Exercise Timeline ............................ 6 Table 2 - Summary of Exercise Evaluation ............................ 8 iii

I. EXECUTIVE

SUMMARY

On October 7, 2003, a full participation exercise was conducted inthe plume exposure emergency planning zone (EPZ) around the H. B. Robinson Steam Electric Plant. The purpose of the exercise was to assess the level of State and local preparedness inresponding to a radiological emergency. This exercise was conducted in accordance with the Federal Emergency Management Agency's (FEMA) policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The previous exercise at this site was conducted on October 9, 2001. The qualifying emergency preparedness exercise was conducted on March 11-12, 1981.

FEMA wishes to acknowledge the efforts of the many individuals inthe State of South Carolina, the Risk Counties of Chesterfield, Darlington and Lee and the Host County of Florence who participated in this exercise. Protecting the public health and safety is the full-time job of some 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 evaluation of the biennial exercise and the evaluation of a Medical Service Drill that was conducted on October 8, 2003.

The State and local organizations demonstrated knowledge of their emergency response plans and procedures and the ability to implement them. No Deficiencies or Areas Requiring Corrective Action (ARCA) were identified. Although DHEC dispatched a mobile laboratory to the Darlington National Guard Armory. The mobile laboratory served as an intermediate screening station for samples. This laboratory did not demonstrate the capabilities of a radiological laboratory. The capability will be demonstrated during the January 2004, Oconee Exercise. The ARCA concerning the direction and control offield teams identified during the V. C. Summer Exercise was corrected.

II. INTRODUCTION On December 7, 1979, the President directed FEMA to assume the lead responsibility for offsite planning and response for nuclear power plants. FEMA's activities are conducted pursuant to Title 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.

Title 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 the commercial nuclear power plants. This approval is contingent, in part, on State and local government participation in joint exercises with licensees.

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

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

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

• Responding to requests by the NRC pursuant to the Memorandum of Understanding between the NRC and FEMA (Federal Register, Vol. 58, No. 176, September 14, 1993)

• Coordinating the activities of Federal agencies with responsibilities in the radiological emergency planning process:

- Department of Agriculture,

- Department of Commerce,

- Department of Energy,

- Department of Health and Human Services,

- Department of the Interior,

- Department of Transportation,

- Environmental Protection Agency,

- Food and Drug Administration and

- Nuclear Regulatory Commission.

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

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Formal submission of the RERPs for the H. B. Robinson Steam Electric Plant to FEMA Region IV by the State of South Carolina and involved local jurisdictions occurred on February 13, 1981. Formal approval of the RERP was granted by FEMA on December 29, 1981, under Title 44 CFR 350.

A REP exercise was conducted on October 7, 2003, by FEMA Region IV, 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 the H. B. Robinson Steam Electric Plant. The purpose of this report is to present the exercise results and findings on the performance of the offsite response organizations (ORO) during a simulated radiological emergency.

The findings presented are based on the evaluations of the federal evaluator team, with final determinations made by the FEMA Region IV RAC Chairperson and the FEMA Lead Evaluator, and approved by the Regional Director.

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

• 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;

• Exercise Evaluation Methodology, April 25, 2002.

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

Section IV of this report, entitled "Exercise Evaluation and Results," presents detailed information on the demonstration of applicable exercise objectives at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all ARCAs assessed during this exercise, recommended corrective actions, and the State and local governments' response, and (2) descriptions of ARCAs assessed during previous exercises and the status of the OROs' efforts to resolve them.

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111. EXERCISE OVERVIEW Contained in this section are data and basic information relevant to the October 7, 2003, exercise to test the offsite emergency response capabilities in the area surrounding the H. B.

Robinson Steam Electric Plant.

A. Emergency Planning Zone Description The H1. B. Robinson Steam Electric Plant is located west of the Lake Robinson Dam in western Darlington County. The facility is owned and operated by Progress Energy.

In operation since March 1971, the H. B. Robinson Steam Electric Plant has one pressurized water reactor. The reactor, Unit No. 2, has an electric power generating capacity of approximately 700 megawatts.

Portions of Darlington, Lee and Chesterfield Counties are located in the plume exposure pathway. The land use within the Emergency Planning Zone (EPZ) is primarily agriculture. The City of Hartsville lies within the 10-mile EPZ. The total population for the EPZ is 32,550. There are eleven emergency response planning areas within the EPZ.

Major parks include portions of the Carolina Sand Hills National Wildlife Refuge and the Sand Hills State Forest. The Lynches and Pee Dee Rivers are fed from watersheds draining through the probable affected area.

Over the facility, the prevailing winds are from the southwest and shift primarily from southwest to northwest. The greatest probability for an accident with off-site implications would affect Darlington County.

CSX railway passes next to the plant. A spur is utilized for delivery of coal to an adjoining coal burning electrical generating plant.

B. Exercise Participants The following agencies, organizations, and units of government participated in the H. B. Robinson Steam Electric Plant exercise on October 7, 2003.

STATE OF SOUTH CAROLINA Department of Health and Environmental Control, Bureau of Land Waste Management Department of Natural Resources Department of Social Services Office of the Adjutant General, Emergency Preparedness Division 4

South Carolina Highway Patrol RISK JURISDICTIONS Chesterfield County Darlington County Lee County HOST JURISDICTION Florence County PRIVATENVOLUNTEER ORGANIZATIONS American Red Cross Carolina Pines Regional Medical Center Radio Amateur Civil Emergency Service (RACES)

WJMX Radio Station C. Exercise Timeline Table 1, on the following page, presents the time at which key events and activities occurred during the H. B. Robinson Steam Electric Plant exercise on October 7, 2003.

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I I I I I rI r r r r r r rI I Table 1. Exercise Timeline DATE AND SITE: October 7, 2003 - H. B. Robinson Steam Electric Plant Emergency Time Time That Notification Was Received or Action Was Taken Classification Utilty Level or Event Declared l SEOC DOSE l JIC CHESTERFIELD DARLINGTON LEE FMTs 1 COUNTY COUNTY COUNTY Unusual Event 0713 0722 0722 0725 Alert 0812 0819 0822 0819 0824 I Site Area Emergency 0939 0956 0954 0952 1000 0955 General Emergency 1039 1052 1059 1040 1052 1048 1052 1059 Simulated 0805 0920 0819 0805 1000 0830 Rad. Release Started 1032 1110 Simulated Rad. Release On going On going Terminated Facility Declared Operational 0830 0915 0827 0830 0915 Declarntion of State of Emergeney Stat 0854 0920 0900 0905 1132 Local: _ 0911 0905 N/A 11 Exercise Terminated 1233 12 1222 1220 1144 1144 1144 Early Precautionary Actions: School Evac. 0830-School Evac 0932 Lake Clearing Hunting & fishing outdoor 0956 1009 1st Protective Action Decision Alert Public Stay tuned 1009 1009 0956 1009 1stSiren Activation 015 1015 1015 1015 1018 I 1st EAS Messanie 1018 1018 1018 1018 1020 2nd Protective Action Decision Evacuate: A-0,B-I,B-2,C-1,C-2 1110 1115 1110 1018 1112 Shelter: D-l. D-2. A-4. A-2. E-l. E-2 Livestock Feed and Water 1018 _ _

2nd Siren Activation 1120 1120 1120 1018 1121 I 2 EASMessn 1123 1123 1223 1018 1123 KI: EW & Institutionalized 1000 _ 1009 0956 1009

6- IV. EXERCISE EVALUATION AND RESULTS Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities, which participated in the October 7, 2003 exercise to test the offsite emergency response capabilities of Sate and local governments in the 10-mile EPZA surrounding the H. B. Robinson Steam Electric Plant.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria delineated in the exercise evaluation methodology published in the Federal Register, April 2002. Detailed informnation on the exercise evaluation criteria and the extent-of-play agreement used in this exercise are found in Appendix 3 of this report.

A. Summary Results of Exercise Evaluation - Table 2 The matrix presented in Table 2, on the following page, presents the status of all Exercise Evaluation Criteria, which were scheduled for demonstration during this exercise by participating jurisdictions and functional entities. Exercise criteria are listed by number and the demonstration status of those criteria is indicated by the use of the following letters:

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

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

N - Not Demonstrated (Reason explained in Subsection B) 7

I f I I rI r I I I I Table 2. Summary of Exercise Evaluation DATE AND SITE: October 7,2003 - H. B. Robinson Steam Electric Plant ELEMENT/Sub-Element SEOC IIC DHEC EOF LP-I CHESTERFIELD DARLINGTON LEE FLORENCE COUNTY COUNTY COUNTY COUNTY L EMERGENCY OPERATIONS MANAGEMENT ta.l. Mobilization M M M M M M M I.b.l. Facilities M M M M M M M I.c. I. Direction and Control M M M _ M M M Id. 1. Communications Equipment M M M M M M M I.e. I. Equipment k Supplies to Support Operations M M M M M M M

2. PROTECTIVE ACTION DECISION MAKING M M 2.a. 1. Emergency Worker Exposure Control M M M M 2.b. 1. Rad Assessment & PARs & PADs Based on Available Info M M M M 2.b.2. Rad Assessment and PARs and PADs for the General Public M M M M M 2.c. 1. Protective Action Decisions for Special Populations 2.d. 1. Rad Assessment h Decision Making for Ingestion Exposure 2.e. 1. Rad Assessment & Decision Making for Relocation. Re-entry &..

Return -

3. PROTECTIVE ACTION IMPLEMENTATION 3.a. 1. Implementation of Emergencv Worker Control M M M M M M M 3.b.1. Implementation of KI Decisions 3.c. 1. Implementation of PADs for Special Populations 3.c.2. Implementation of PADs for Schools 3.d. 1. Implementation of Traffic and Access Control M M M M 3.d.2. Impediments to Evacuation and Traffic and Access Control M M M M I co 3.e. 1. Implementation of Ingestion Decisions Using Adequate Info = =_-

3.e.2. Implementation of IP Decisions Showing Strategies and Instructional Materials _

3.f.1. Implementation of Relocation. Re-entry and Return Decisions _

4. FIELD MEASUREMENT and ANALYSIS 4.a. 1. Plume Phase Field Measurement h Analysis Equipment _ _

4.a.2. Plume Phase Field Measurement & Analysis Management M 4.a.3. Plume Phase Field Measurements & Analysis Procedures = __

4.b. 1. Post Plume Field Measurement & Analvsis 4.b.2. Laboratory Operations N _

5. EMERGENCY NOTIFICATION & PUBLIC INFO = .

5.a. 1. Activation of Prompt Alert and Notification M M M M 5.a.2. Activation of Prompt Alert and Notification 1 5-Minute (Fast Breaker) 5.a.3. Activation of Prompt Alen and Notification Backup Alert and M M M Notification Sb. I. Emergency Info and Instructions for the Public and the Media M M M M M M

6. SUPPORT OPERATIONS/FACILITIES __ ____

6.a.1. Monitoring and Decon of Evacuees and EWs and Registration of M M M Evacuees 6.b.1. Monitoring and Decon of Emergency Worker Equipment . = M M M 6.c.1. Temporary Care of Evacuees _ _ . M 6.d.1. Transport and Treatment ofContaminated Injured Individuals _

LEGEND1I: 1= eI~ci~cncy D~l=I~C A=AC N ~tDmntae LEULNO: M = MM ID Delicicncy A = ARIUA N= Not LDemonstrated

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

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

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

• Area Requiring Corrective Actions - Listing of the demonstrated exercise criteria under which one or more ARCAs were assessed during the current exercise or ARCAs assessed during prior exercises that remain unresolved.

Included is a description of the ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise.

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

• Prior ARCAs - Resolved - Descriptions of ARCAs assessed during previous exercises, which were resolved in this exercise because corrective actions were demonstrated.

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

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

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

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

FEMA has developed a standardized system for numbering exercise issues (Deficiencies and ARCAs). This system is used to achieve consistency in numbering exercise issues among FEMA Regions and site-specific exercise reports within each Region. It is also used to expedite tracking of exercise issues on a nationwide basis.

The identifying number for Deficiencies and ARCAs includes the following elements, with each element separated by a hyphen (-).

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

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

• Criterion Number - A numeral, alpha, numeral combination corresponding to the criterion number in Exercise Evaluation Methodology dated April 2002.

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

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

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1. STATE OF SOUTH CAROLINA 1.1 State Emergency Operations Center The State Emergency Operations Center (SEOC) is a modem facility with state of the art technology. The State's Emergency Management Director's participation enhanced the overall direction and control that was superbly executed by the Operations Chief and his staff. The Internet Routed Information System (IRIS), the State's emergency

_ rmanagement tool, and the checklists that were followed at each Emergency Classification Level (ECL) enhanced a well-coordinated emergency response operation. Protective action recommendations (PAR) and decisions were timely and appropriate for the exercise. Alert and Notification of the public following the Site Area Emergency (SAE) and the General Emergency (GE) was well executed and performed with a sense-of-urgency.

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

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs -UNRESOLVED: NONE 1.2 Radiological Liaison The Department of Health and Environmental Control (DHEC) shared the responsibility for the DHEC Emergency Response Coordinator between two individuals as they

- transitioned operations form the Farrow Road Command Center to the SEOC. The activation of the DHEC section at the SEOC was delayed because of the deployment of the field monitoring teams to the Forward Emergency Operations Center (FEOC). Prior to the Emergency Response Coordinator's arrival at the SEOC, the DHEC staff performed communication checks and supported SEOC operations. Communications and briefings were thorough and timely. The Emergency Response Coordinator routinely discussed radiological conditions, protective action strategy, and options with the SEOC Chief of Operations. Plant dose assessments were verified.

a. MET: Criteria I.c. 1, L.d. , I.e. I, 2.a. 1, 2.b. Iand 2.b.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE 11

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED:

f. PRIOR ARCAs - UNRESOLVED: NONE 1.3 Dose Assessment The Dose Assessment Coordinator at the FEOC in Darlingto4 competently, demonstrated the capability to calculate dose projections using the RASCAL model. This information was provided to the DHEC Emergency Response Coordinator. The field team director effectively managed field"team operations. All activities were demonstrated in accordance with the plan, procedures and extent of play agreement.

a. MET: Criteria 1.c. 1, 1.d. 1, 1.e. 1, 2.a. 1, 2.b. 1 and 2.b.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED:

Issue No.: 61-03-4.a2-A-01

Description:

Field team management was inadequate in several respects.

Additional staff members should have been assigned to the Field Team Director to assist in communications with the field team. This shortage of staff personnel resulted in the Field team Director having to communicate with the field team.

This communication responsibility detracted from his ability to effectively conduct other duties. Additionally, reception problems with both radios and cell phones resulted in the inability to maintain timely and effective communications with the field team.

Because of these communications shortfalls, several problems resulted in the management of field team activities. Briefly, the field team misinterpreted a message to distribute KI, but rather team members ingested KI. Additionally, while the field team was advised to initiate radioiodine air sampling, the Field Team Director neglected to follow-up on the status of the air samples; consequently, no calculation of I-131 concentration from air samples was received.

Corrective Action Demonstrated: An additional staff member to support communications was assigned to the Field Team Director. There were no losses of communications during the exercise. Although communication "dead zones" were 12

noted by a field team during the exercise, at least one communications system operated at all times which ensured contact with the Field Team Director. The Field Team Director provided plant status and plume release data to the field teams. He also directed field teams to sampling locations as well as coordinated pickup of field team samples to be returned to the mobile lab for processing.

£ PRIOR ARCAs - UNRESOLVED: NONE 1.4 Mobile Laboratory The DHEC Mobile Radiological Laboratory (MRL) was deployed to the National Guard Armory in Darlington, South Carolina. DHEC demonstrated actual deployment of its field assets. The MRL served as an intermediate screening station for sample transfer because the instrumentation that DHEC sent forward only allowed for the screening of samples to determine the need for fiurther analysis. The samples slated for further analysis would be transported to Columbia for analysis in the DHEC laboratory. The MRL staff members were all well versed on their procedures, radiation protection protocols and displayed a sense of purpose and professionalism. They did an excellent job in carrying out their duties.

a. MET: Criteria L.e. I and 3.a. I

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED:

The criterion 4.c. I extent-of-play states that 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. DHEC did not demonstrate this criterion. FEMA does not require a mobile laboratory but does require the demonstration of a capability to analyze samples. The instrumentation that DHEC sent forward only allowed for the screening of samples to determine the need for further analysis, i.e. a hot sample. The samples slated for further analysis would be transported to Columbia for analysis in the DHEC laboratory. DHEC has agreed to demonstrate the State's radiological laboratory capability during the January 2004 Oconee Exercise.

e. PRIOR ARCAs - RESOLVED: NONE L PRIOR ARCAs - UNRESOLVED: NONE 13

1.5 Radiological Field Monitoring Teams DHEC mobilized its radiological field monitoring teams (FMT) in Columbia and deployed to the FEOC. They demonstrated the ability to assemble, train-up, and deploy to an emergency location for the conduct of field operations. Subsequently the teams demonstrated the effective use of their equipment, and their implementation of established procedures ensured that assigned tasks were accomplished. Team members knew their exposure limits and turn back value and were properly equipped with individual dosimetry and KI. They correctly performed equipment inventory and instrumentation checks, conducted sampling activities in accordance with their procedures and communicated results to the Field Team Director. . .

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

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE.

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 1.6 Emergency Operations Facility The H. B. Robinson Emergency Operations Facility (EOF), located on site in the facility training complex, is an excellent facility from which all participating organizations can effectively manage ongoing emergency operations. Communications, coordination, and the flow of technical information between the utility operator and applicable State officials were excellent. State officials deployed to the EOF were well trained, knowledgeable, followed applicable procedures; and overall, performed their respective responsibilities in an efficient and professional manner.

a. NIET: Criteria I.a.1, l.d.1 and l.e.I

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs -RESOLVED: NONE f PRIOR ARCAs - UNRESOLVED: NONE 14

1.7 Joint Information Center The professional staff in the JIC successfully demonstrated their capability to provide timely and accurate emergency information and instructions to the news media for broadcast to the public. Representatives from the State of South Carolina, Chesterfield, Darlington, Florence, and Lee Counties did a commendable job in coordinating and disseminating emergency information. The two news conferences were well organized and provided information consistent with the emergency status. The rumor control and public inquiry team handled 61 calls. Rumors were identified and addressed in a timely manner. The Public Inquiry Coordinator maintained constant information flow between the team and the JIC staff.

a. MET: Criteria 1.a.1; L.b.I, L.e.l and 5.b.1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 1.8 LP-1 Radio Station WJMX The staff of WJMX, the LP-1 Radio Station, demonstrated the capability to promptly broadcast Emergency Alert System (EAS) messages issued by the SEOC. SEOC staff communicated with the Program Director of WJMX by phone to confirm authentication codes, receipt of the test message, and the time of broadcast. EAS messages can be broadcast manually or automatically when the station is unmanned. Documentation of all test messages and the EAS Handbook are maintained in the broadcast room; backup power generation is in place. The staff was professional and supportive of the station's role in safeguarding the public.

a. MET: Criterion 5.b.1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE 1-5

e. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 1.9 State Traffic Control Point The South Carolina Highway Patrol (SCHP) troopers fully 'demonstrated their capability to conduct traffic control point (TCP) operations. Maps, dosimetry, potassium iodide (KI) and other supplies were sufficient for emergency operations. The Darlington County Emergency Operations Center (EOC) issued the direct-reading dosimeters (DRDs) and permanent-record dosimeters, along with an excellent radiation exposure handbook. They correctly zeroed the DRDs and completed their Radiation Exposure Record forms. KI and appropriate instructions were available, and the officers were knowledgeable of-when to take the K1. SCHP troopers displayed an understanding of radiological exposure control. Personnel readily established on-scene traffic and access control at the three TCP locations, and knew to report any impediments to evacuation beyond their capability to the SCHP supervisor at the Darlington County EOC.

a. MET: Criteria l.e.I, 3.a.1, 3.b.1, 3.d& and 3.d.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE

£ PRIOR ARCAs - UNRESOLVED: NONE

2. RISK JURISDICTIONS 2.1 CHESTERFIELD COUNTY 2.1.1 Emergency Operations Center EOC staff demonstrated their ability to protect their citizens in the event of an incident at the plant. The Emergency Management Director was very assertive in the EOC operation.

Excellent and frequent staff briefings were evident. The staff professionally handled all tasks with actual phone calls to the appropriate agency for completion. Because of their activities, all criteria were fully and accurately met. They are to be commended for an excellent exercise.

16

a. MET: Criteria l.a.1, l.b.1, l.c.1, l.d.1, L.ei, 2.a.1, 2.c.1, 5.a.1, 5.a.3 and 5.b.1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED:

e; PRIOR ARCAs - UNRESOLVED: NONE 2.1.2 Protective Actions for Schools The Assistant Superintendent for Operations ofthe Chesterfield County School District participated in an interview pertaining to protective actions taken within the county school system in the event of an incident at the H.B. Robinson Steam Electric Plant. The three schools located in the 10-mile EPZ have emergency plans that supplement the District's Crisis Management Manual. Sufficient transportation was available to relocate the student and faculty population. Procedures are in-place to notify parents of a school evacuation in a timely maimer. Each school principal was contacted during the exercise and two conducted practice evacuation drills. The School District is well prepared to safeguard students in their charge in the event of a potential or actual radiological release.

a. MET: Criterion 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE it PRIOR ARCAs - UNRESOLVED: NONE 17

2.1.3 Traffic Control Points Establishment of TCPs in Chesterfield County was demonstrated by interview with a Deputy Sheriff at the EOC. The capability of the Sheriffis Department to establish and operate the five designated TCPs in the County was thoroughly explained and conformed to a detailed TCP procedures manual. The Deputy Sheriff was familiar with emergency worker radiation exposure control procedures and the~means for resolving road impediments to evacuation.

a. MET: Criteria 3.a. 1,3.b. l, 3.d. 1 and 3.d.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs -RESOLVED: NONE

e. PRIOR ARCAs - UNRESOLVED: NONE 2.1.4 Emergency Worker Decontamination Emergency Medical Services (EMS) personnel from First Health of Carolinas demonstrated all of the elements required to set up and conduct decontamination procedures for emergency workers and vehicles. The participants in the exercise exhibited a thorough degree of training and had a high degree of confidence in the personnel and equipment they used for detection and decontamination. The County Radiological Officer was on site and supervised the operations.

a. MET: Criteria 3.a. 1 and 6.a. 1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE

£ PRIOR ARCAs - UNRESOLVED: NONE 18

2.1.5 Reception and Congregate Care Volunteers from the American Red Cross (ARC), EMS personnel from First Health of Carolinas and ahiateur radio operators demonstrated all of the elements required to set up, monitor and conduct shelter operations. Monitoring of incoming evacuees was performed by the EMS personnel. The shelter manager oversaw shelter Registration, communications, and evacuee needs. The participants in the exercise exhibited a thorough degree of training and had a high degree of compassion towards meeting the needs of the displaced evacuees.

a. MET: Criteria 1.e. I, 3.a. 1, 6.a.1 and 6.c. 1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE E PRIOR ARCAs - UNRESOLVED: NONE 2.2 DARLINGTON COUNTY 2.2.1 Emergency Operations Center The Director of Emergency Preparedness and the Special Programs Coordinator provided effective direction and control of the EOC. The competent and supportive staff knew their duties and performed them conscientiously. The Director of Emergency Services consistently coordinated with the State and other counties in the formulation and implementation of the evacuation and sheltering-in-place protective action decisions (PAD), activation of the sirens and issuing of EAS messages. The presence of the County Administrator, two County Councilmen, the utility and State liaison provided vital support to this successful operation. The WebEOC and GIS system continuously displayed significant information and events. This along with periodic EOC briefings, agency updates and the availability of computers for all EOC staff facilitated the flow of information. An impressive array of electronic status boards, fax machines, a variety of maps and other equipment supported this emergency response operation.

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

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTION: NONE 19

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs -RESOLVED: NONE L PRIOR ARCAs - UNRESOLVED: NONE 2.2.2 Protective Actions for Schools An interview was conducted in the EOC with the principals of the Thornwell School for the Arts and -West Hartsville Elementary School, the Assistant Principal of North Hartsville Elementary School, and the Assistant Superintendent and Director of Operations of the Darlington School District. These representatives discussed alert and notification procedures, and actions that would be taken in the event of a school evacuation. The school district has sufficient buses available and the capacity to complete an evacuation of the County School System. Schools conduct annual training for faculty and staff as well as evacuation drills involving students. Throughout the interview, representatives emphasized student safeguarding and accountability and the availability of resources to relocate students.

a. MET: Criteria I.e. 1 and 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs -RESOLVED: NONE L PRIOR ARCAs- UNRESOLVED: NONE 2.23 Traffic Control Points The Darlington City Police Department successfully demonstrated traffic and access control points through interview inthe EOC. Officers were professional, knew their responsibilities, including the removal of road impediments, were familiar with their standard operation procedures (SOPs), and the location of reception centers. The Officers wore appropriate direct-reading and permanent-record dosimetry and were knowledgeable of its use and exposure control procedures.

a. MET: Criteria L.e. 1, 3.a. 1, 3.d. I and 3.d.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE 20

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE' 2.2.4 Emergency Worker Decontamination The Darlington County Fire District, Swift Creek Station, demonstrated emergency worker decontamination. The denmonstration included a discussion on the issuance of permanent and direct-reading dosimeters, a sequential.walkthrough for placing the Ludlum Model 3 survey meter into use and the!activation of the Ludlum Model 52 portal monitor.

All personnel were familiar with self-protective measures and actions to take regarding their exposure levels. The monitoring and-decontamination area was well organized and the separation of clean versus contaminated personnel and'equipment was demonstrated and/or thoroughly discussed. Personnel were knowledgeable of their responsibilities and provided proper responses to questions. All personnel acted professional and worked efficiently as a team.

a. MET: Criteria L.e.1, 3.a. 1, 6.a. and 6.b. I

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE L PRIOR ARCAs - UNRESOLVED: NONE 2.2.5 Lake Warning Two South Carolina Department of Natural Resources (DNR) officers fully demonstrated their capability to perform lake warning operations. Darlington County issued the officers their dosimetry and an excellent radiation exposure handbook. The DNR officers were knowledgeable of radiological exposure control procedures and displayed an excellent knowledge of how to conduct lake warning and clearance. There was a prominent sign with warnings and instructions at the landing site.

21

a. MET: Criteria 3.a. 1, 3.b. 1 and 5.a.3

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs -RESOLVED: NONE

£ PRIOR ARCAs - UNRESOLVED: NONE 2.2.6 Medical Service Drill (MS-i)

On October 8, 2003 a Medical services drill began at approximately 0907 when the Darlington County EMS Ambulance was dispatched to the Byrdtown Fire Station on Byrdtown Road for a patient that had fallen from a four-wheel all terrain vehicle (ATV) in a suspected contaminated area When the ambulance arrived at 0920 the driver, a paramedic, remained in the vehicle. Two paramedics who had donned appropriate personal protective equipment and had direct-reading and permanent-record dosimeters monitored the area and the victim for radiological contamination, using a properly calibrated, Ludlum. Model 3 Survey Meter. Plastic was placed on the ground at the rear of the ambulance and sheets were placed next to the patient to minimize the spread of radioactive contamination. The paramedics then assessed and treated the patient's injuries. The patient's outer clothing was removed and the patient was wrapped insheets to contain contamination, then loaded into the ambulance. The interior of the ambulance had been covered to prevent it from becoming contaminated. Communications were established with the hospital and maintained during transport to the hospital. Emergency treatment and contamination control during the pick-up were excellent.

When the ambulance arrived at the Carolina Pines Regional Medical Center the Radiological Response Team (RRT) from the H.B. Robinson Steam Electric Plant had prepared a receiving area to isolate and transfer the contaminated patient. A health physicist (HP) began surveying the patient immediately following the transfer the patient was then moved inside to a treatment room. The EMS crew and the vehicle were properly surveyed. The ambulance was found to be contaminated and was simulated to have been driven to the Swift Creek Fire Station for decontamination.

Once inside the treatment room the HP again monitored the patient while the RRT doctor began examining the patient's wounds. Decontamination of contaminated areas was begun almost immediately. The contaminated areas were flushed with saline and scrubbed to remove contamination. Swabs were used to obtain samples from the ears and nose to determine if internal contamination had occurred. After the patient had been decontaminated she was taken from the treatment room in a wheel chair. The RRT demonstrated proper exit procedures.

22

Teamwork and contamination control were evident throughout this exercise. All participants are commended for their efforts during this outstanding exercise.

a. MET: Criteria I.a.1, L.e.1, 3.a.1, 3.b.I and 6.d.I

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE C. PRIOR ARCAs - RESOLVED: NONE e PRIOR ARCAs - UNRESOLVED: NONE 2.3 'LEE COUNTY 2.3.1 Emergency Operations Center A professional, paid and volunteer staff operated the EOC. The Emergency Management Director effectively managed emergency operations. The EOC Director held frequent briefings with updates from the plant and, after the declaration of an SAE, included reports from the ESF representatives. Communications were monitored by the Deputy Fire Chief The administrative assistant, who also maintained the status board, monitored the selective signaling system. The EOC Director, who maintained contact and coordination with the other counties and the State, made decisions.

a. MET: Criteria 1.a.1, I.b.1, I.c.1, I.d.1, L.e.1, 2.a.1, 2.b.2, 2.c.1, 5.a.1, S.a.3 and 5.b.1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE E PRIOR ARCAs - UNRESOLVED: NONE 23

23.2 Traffic Control Points Two Captains from the Lee County Sheriffs Department successfully demonstrated TCPs through an interview in the EOC. Both officers had the appropriate dosimetry and were knowledgeable of its use. During the interview process, both officers demonstrated an understanding of their responsibilities, including the information to assist the public. They successfully demonstrated the use of dosimetry and their knowledge of radiological exposure control. Both Captains discussed the actions that would be taken to physically establish a TCP and how to obtain logistical backup (e.g., barricades) if required.

a. MET: Criteria l.e.l, 3.a.1, 3.d.I and 3.d.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE L PRIOR ARCAs - UNRESOLVED: NONE 23.3 Emergency Worker Decontamination Personnel from the County EMS and Fire Department demonstrated radiological monitoring and decontamination of emergency workers and vehicles. Personnel described the actions taken to limit the spread of contamination. Monitoring personnel explained the action levels for determining the need for decontamination of both vehicles-and personnel.

Personnel were knowledgeable of procedures for handling individuals and vehicles that could not be adequately decontaminated. Personnel were registered according to procedures.

a. MET: Criteria L.e.I, 3.a.1, 3.b.1, 6.a.I and 6.b.I

b. DEFICIENCY: NONE

e. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs -RESOLVED: NONE E. PRIOR ARCAs - UNRESOLVED: NONE 24

23.4 Reception and Congregate Care Center Members of the Lee County EMS and Fire Department successfully demonstrated radiological monitoring, decontamination, and registration facilities at Lee Central High School. Evacuees'arriving were monitored and decontaminated along with their vehicles.

EMS and Fire Department personnel described the actions taken to limit the spread of contamination. Monitoring staff explained the action levels for determining the need for decontamination for both vehicles and citizens. The procedures for handling evacuees and vehicles that could not be adequately decontaminated were explained. Evacuees and vehicles were registered according to established procedures.

The congregate care staff also demonstrated the capability to ensure evacuees were registered before entering the shelter. Stations for various services were set up (e.g.,

medical, mental services) according to plans, food and other materials were available.

a. MET: Criteria l.e. 1, 3.a.1; 6.a.1 and 6.c.I

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs -RESOLVED: NONE L PRIOR ARCAs - UNRESOLVED: NONE

3. HOST JURISDICTION 3.1 FLORENCE COUNTY 3.1.1 Reception and Congregate Care The Florence County Emergency Management Agency demonstrated monitoring, decontamination, registration, and care of evacuees at the Florence Civic Center. The Florence City Police and Fire Departments and EMS personnel supported the reception phase. The area layout and demonstrated actions were in accordance with plans and procedures. The congregate care center, supported by personnel from the ARC, South Carolina Department of Social Services and DHEC, was well staffed, organized, and able to meet the needs of the public. All personnel demonstrated an understanding of plans and procedures and are capable of performing required functions.

25

a. MET: Criteria l.e,1, 3.a.1, 6.a.1 and 6.c.l.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE eC, PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 26

4.

SUMMARY

OF AREAS REQUIRING CORRECTIVE ACTION 4.1 PRIOR ARCAs RESOLVED 4.1.1 61-03-4.a.2-A-01

Description:

Field team management was State of South Carolina inadequate in several respects. Additional Dose Assessment staff members should have been assigned to the Field Team Director to assist in communications'with the field team. This shortage of staff personnel resulted in the Field team Director having to communicate with the field team. This communication responsibility detracted from his ability to effectively conduct other duties.

Additionally, reception problems with both radios and cell phones resulted in the inability to maintain timely and effective communications with the field team.

Because of these communications shortfalls, several problems resulted in the management of field team activities. Briefly, the field team misinterpreted a message to distribute KI, but rather team members ingested K!.

Additionally, while the field team was advised to initiate radioiodine air sampling, the Field Team Director neglected to follow-up on the status of the air samples; consequently, no calculation of I-131 concentration from air samples was received.

Corrective Action Demonstrated: An additional staff member to support communications was assigned to the Field Team Director. There were no losses of communications during the exercise.

Although communication "dead zones" were noted by a field team during the exercise, at least one communications system operated at all times which ensured contact with the Field Team Director. The Field Team Director provided plant status and plume release data to the field teams. He also directed field teams to sampling locations as well as coordinated pickup of field team 27

samples to be returned to the mobile lab for processing.

4.2 NOT DEMONSTRATED 4.2.1 Mobile Laboratory The criterion 4.c.I extent-of-play states Exercise Area Criterionthat 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. DHEC did not demonstrate this criterion. FEMA does,not require a -nobile laboratory but does require the demonstration ofa capability to analyze samples. The instrumentation that DHEC sent forward only allowed for the screening of samples to determine the need for further analysis, ie. a hot sample. The samples slated for further analysis would be transported to Columbia for analysis inthe DHEC laboratory.

DHEC has agreed to demonstrate the State's radiological laboratory capability during the January 2004 Oconee Exercise.

28

APPENDIX 1 ACRONYMS AND ABBREVIATIONS The following is a list of the acronyms and abbreviations may have been used in this report.

ARC American Red Cross ARCA' Area Requiring Corrective Action CFR- Code of Federal Regulations DHEC Department of Health and Environmental Control DHHS Department of Health and Human Services DOC Department of Commerce DOE Department 6f Energy DOI Department of the Interior DOT Department of Transportation DRD Direct-Reading Dosimeter DSS Department of Social Services EAL Emergency Action Level EAS Emergency Alert System ECL Emergency Classification Level EEM Exercise Evaluation Methodology EMA Emergency Management Agency EMS Emergency Medical Services EOC Emergency Operations Center EOF Emergency Operations Facility EOP Extent of Play EPA Environmental Protection Agency EPD Emergency Preparedness Division EPZ Emergency Planning Zone FAA Federal Aviation Agency FEMA Federal Emergency Management Agency FR Federal Register FMT Field Monitoring Teams GE General Emergency IRIS Internet Routed Information System JIC Joint Information Center KI Potassium Iodide 29

NRC U.S. Nuclear Regulatory Commission NUREG-0654 NUREG-0654/FEMA-REP-1, Rev. 1, "CriteriaforPreparationand Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980 ORO OfMsite response organizations PAD Protective Action Decision PAR Protective Action Recommendation PIO Public Information Officer '

RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Service i .1, RDO Radiological Defense Officer REP Radiological Emergency Preparedness I

RERP Radiological Emergency Response Plan SAE Site Area Emergency SCHP South Carolina Highway Patrol SEOC State Emergency Operations Center TCP Traffic Control Point USDA U.S. Department of Agriculture 30

APPENDIX 2 EXERCISE EVALUATORS The following isa list of the personnel who evaluated the H. B. Robinson Steam Electric Plant exercise on October 7, 2003. The organization which each evaluator represents is indicated by the following abbreviations:

FEMA - - Federal Emergency Management Agency ICF - ICF Incorporated NRC - Nuclear Regulatory Commnission Lawrence A. Robertson '

4 - Chairman, RAC IV EVALUATION SITE EVALUATOR' ORGANIZATION Chief Evaluator Eddie Hickman FEMA STATE OF SOUTH CAROLINA State Emergency Operations Center Joseph Canoles FEMA Stan Copeland FEMA Radiological Liaison James Lightner ICF Dose Assessment Reginald Rogers ICF Radiological Laboratory Dale Petroff ICF Radiological FMT #1 Keith Earnshaw ICF Radiological FMT #2 Edward Wojnas ICF Emergency Operations Facility Robert Trojanowski NRC JIC/EAS Station David Moffet ICF Rosemary Samsel ICF LP-l Radio Station WJMX Brenda Pittman ICF CHESTERFIELD COUNTY Emergency Operations Center Tom Reynolds FEMA Protective Action for Schools Bill Larrabee ICF 31

Traffic Control Points William E4monson ICF Emergency Worker Decontamination Paul Ringheirser ICF Reception and Congregate Care Paul Ringheirser ICF DARLINGTONCOUNTY FEMA Emergency Operations Center Robert Perdue Protective Actions for Schools Charles Zeppenfeld ICF CountyTraffic Control Points Beth Massey FEMA State Traffic Control Points Mike Dolder FEMA Emergency Worker Decontamination Charles Zeppenfeld ICF Lake Warning Mike Dolder FEMA Medical Service Drill Joseph Canoles FEMA (October 8, 2003) Josh Moore ICF LEE COUNTY Emergency Operations Center Helen Wilgus FEMA Traffic Control Points Wendy Swygert ICF Emergency Worker Decontamination Wendy Swygert ICF Reception and Congregate Care Wendy Swygert ICF FLORENCE COUNTY Reception Center & Congregate Care Josh Moore ICF 32

APPENDIX 3 EXERCISE CRITERIA AND EXTENT-OF-PLAY AGREEMENT This appendix lists the exercise criteria, which were scheduled for demonstration in the H. B. Robinson Steam Electric Plant exercise on October 7, 2003 and were submitted with the extent-of-play agreement submitted by the State of South Carolina and approved by FEMA Region IV.

A. Exercise Criteria Attached are the specific radiological emergency preparedness criteria scheduled for demonstration during this exercise.

33

_ Extent of Play Agreement H.B. Robinson Steam Electric Plant REP Exercise October 7, 2003

1. Emergency Operations Management.

Sub-element I.a, Mobilization

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

With the exception of DHEC field teams and mobile radiological laboratory personnel, all state and local government personnel will be pre-positioned.

- Alert rosters will be provided to FEMA evaluators and a discussion of call-down procedures will be conducted.

DHEC will activate and mobilize field team and mobile laboratory resources at the Farrow Road Command Center. Field teams and the mobile radiological laboratory will be deployed to the South Carolina Army National Guard Armory-Darlington, SC in response to scenario events (Note: Deployment of field resources would normally occur at the Site Area Emergency ECL. Due to time constraints and safety considerations, DHEC will initiate mobilization procedures at approximately 0600, October 7, 2003 at the Notification of Unusual Event ECL).

Sub-element 1.b, Facilities Criterion 1.b.1: Facilities are sufficient to support the emergency response.

(NUREG -0654, H)

Counties will be evaluated to establish a baseline for exercise evaluation criteria. 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).

Sub-element 1.c, Direction and Control Criterion I.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., 2.a., b.)

Direction and Control will be at the State Emergency Operations Center (SEOC). County Direction and Control will take place at the Chesterfield County, Darlington County, and Lee County Emergency Operations Centers Change one. 09/09/03

(EOC's). State Emergency Response Team (SERT) participants include the Emergency Management Division (EMD); ESF 6, Mass Care (Department of Social Service$); ESF 8, Health and Medical Services (Department of Health

& Environmental Control); ESF 10, Hazardous Materials, (Department of Health and Environmental Control); and ESF 16, Emergency Traffic Management, (Department of Public Safety',. A simulation cel' will represent the Office of the Governor, Office of the Adjutant General, FEMA Region IV, Georgia, North Carolina, .andnon-playing South- Carolina state agencies. All simulated telephone calls will be made by calling the simulation cell.

-Direction and Control of field teams will take- place at the South Carolina Army National Guard Arrnoqj-Darlington, SC.

Sub-element 1.d, CommunicatiQns,

- Criterion 1.d.1: At last two communications 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.l., 2.)

The Selective Signaling System (SSS) is the primary means of communication to notify off-site response forces. Backup: to, the.SS are commercial telephone lines, satellite telephone and the Local Government Radio (LGR). -

DHEC emergency communications systems at the South Carolina Army National Guard Armory-Darlington, SC will be pre-installed.

Sub-element I.e, Equipment and Supplies to Support Operations Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI),

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

Potassium Iodide for emergency workers will be simulated by candy or other means (empty envelope marked KI). A 14-day supply of KI for 7000 Emergency Workers and Institutionalized Individuals is stored at FNF County EOCs, and Health Departments and at DHEC headquarters in Columbia, SC.

Advance rosters of emergency workers are not maintained. KI is stockpiled for the general public and may be distributed prior to the exercise.

All radiation detection equipment will be inspected, inventoried, and operationally checked before each use. Equipment will be calibrated or leak tested in accordance with existing plans by the South Carolina Emergency Management Division Radiological Lab.

2 Change one. 09/09/03

At locations where traffic and access control personnel are deployed, the availability of appropriate equipnment (e.g.', vehicles, barriers, traffic cones and signs, etc,) will be described by law enforcement personihel.

2. Protective Action Decision Making.

Sub-element 2.a., Emergency Worker-Exposure Control

- Criterion 2.a.1: OROs use a decision-making process, considering relevant factors 'and appropriate ?odrdination, to insure that an exposure control system, including the use of KS, 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.)

- -Dose limits for emergency workers are pre-determined. Emergency workers may voluntarily exceed'dose limits only after beiig fully informed by DHEC of the biological effects 'f radiation and'possible consequences of excessive exposure. -

_ Sub-element 2.b. Radiological'1 Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee

-and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions. (NUREG-0654, 1.8., 10., 11. and Supplement 3.)

Protective action recommendations by DHEC will be based on an evaiuation of information received from the licensee, independent dose assessments and field monitoring team data input.

Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PADs) for the general public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654, J.9., 10.M.)

The Governor or his designee will demonstrate the ability to make appropriate protective action decisions (PADs) based on recommendations from DHEC.

PADs that require sheltering or evacuation of residents or transients inthe 10-mile EPZ will be coordinated with the chief county elected official or designee.

Sub-element 2.c, Protective Action Decisions Consideration for the Protection of Special Populations 3 Change one. 09/09/03

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

3. Protective Action Implementation.

Sub-element 3.a, Implementation of Emergency'Worker Exposure Control

-Criterion 3.a.1: TheOROs issue appropriate dosimotry and procedures, and manage radiological exposure to emnergency 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.)

Emergency Workers o0.emergency worker teams will use Self Reading Dosirneters (SRDs) and simulated Permanent Record Dosimeters (PRDs) to monitor and control their radiation exposure. Emergency workers in low exposure rate areas will use PRDs and maypuse direct reading dosirneters or place them in centralized areas.

Dosimeters are distributed through county emergency-operations centers.

Each county has an adequate inventory' to support first-shift personnel.

Supplementai dosimeters will be provided in, accordance with the South Carolina Dosimetry Redistribution Standard Operating Procedures, and will be discussed at the State Emergency Operations Centet (SEOC).

Department of Public Safety, Highway Patrol maintains and distributes it's own SRDs.

Emergency workers will be interviewed to determine their knowledge of radiation exposure limits.

Sub-element 3.b, Implementation of KI Decision Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not general public) is maintained. (NUREG-0654, E.7., J., 1O.e., f.)

KI is distributed to Emergency Workers prior to their being dispatched. KI is taken by emergency workers on order by the State Health Officer or designee. Record keeping will be discussed at risk county EOCs.

Criterion 3.c.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions.

(NUREG-0654, E.7., J.9., 10.c.d.e.g.)

4 Change one. 09109/03

Chesterfield, Darlington, and Lee counties will demonstrate the ability and resources to implement appropriate protective actions for special population groups. A list of people with special transportation needs will be provided to evaluators. Evacuation assistance will not take place.

Criterion 3.c.2: OROs/School officials decide upon and implement protective actions for schools, (NUREG-0654,J. 10.c., d., g9) ,

Chesterfield and Darlington counties will simulate school evacuations by out-

-ofsequerce interviews with key, school staffrmembers.

Cheste-field County school to be .evaluated is McBee Elementary School.

Darlington County schools to be evaluated are North Hartsville Elementary School, Thornwsll Elementary School and West Hartsville Elementary School.

Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided tojuiffic and access control personnel. (NUREG-0654, J.10.g., j., k.)

Traffic and Access Control Points (TACP's) are pre-determined. The South Carolina Highway Patrol will demonstrate Traffic and Access Control on-scene at TACP #16A, SC-151 and S-23, #16E, US-52/401 and US-15 and

1. 16F US-521401 and SC-41. Lake clearing operations will immediately follow TACP demonstration at Johnson Landing, Darlington County.

Chesterfield County TACP to be evaluated at the county EOC is #13A,US-1 and SC-151.

Darlington County TACP to be evaluated at the county EOC is #16G, US-52 BYP and SC341151.

Lee County TACP to be evaluated at the county EOC is TACP #31A, US 15 and SC 34.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.

(NUREG-0654, J.10.,k.)

Actions to identify and remove impediments to evacuation will be demonstrated by discussion with the highway patrol supervisor at the Darlington County EOC.

4. Field Measurement and Analysis.

Sub-element 4.a, Plume Phase Field Measurements and Analyses 5 Change one. 09/09/03

Criterion 4.a.1: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates. (NUREG-0654, H.10., 1.8., 9., 11.)

.DHEC will conduct a full mobilization of. four field teams and the mobile radiological laboratory. Field teams will receivet a pre-deployment briefing and expedient training prior to deployment. Two field tearris, selected by FEMA evaluators,.and sufficient personnel to operate the mobile radiological laboratory will be deployed to- the- South Carolina Army National Guard Armory-Darlington, SC. The remaining field teams will be assigned to other positions in the DHEC response,.

Zeolite filters will be simulated with charcoal filters. .

Criterion 4.a.2: Field teams are managed to. obtain sufficient information to help characterize the release -and so control radiation exposure. (NUREG-0654, 1.8., 11.,j J.10;a.)

Direction and Control of DHEC Field Teams -will take place at the South CarolinaArmy National GuardArmoryDarlington, SC.

Criterion 4.a.3: Ambient radiation measurements are. made and recorded at

• Appropriate locations, and radioiodine and particulate samples are collected.

Teams will move to an appropriate low background location to determine whether any significant (as specified by the plan andlor procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654, 1.8., 9., l11.)

Dose Assessment will take place at the South Carolina Army National Guard Armory, Darlington, SC.

Criterion 4.b.1: 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.)

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654, C.3., 1.8., 9.,

J.1 1.)

The DHEC Mobile Lab will be located at the South Carolina Army National Guard Armory, Darlington, SC.

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5. Emergency Notification and Public Information Sub-element 5.a, Activation of the Prompt Alert and Notification System Criterion 5.a.1: Activities associated with primary alerting and notification of the' public are completed in a timely manner following the initialdecision by authorized off-site emergency officials to notify the publid of an'emergency situation. The initial instructional message to the 'public must include as a minimum the elements required by current FEMA REP guidance. (10 CFR Part 50, Appendix E & NUREG-0654, ElA., 4'., 5., 6., 7.)

The State will coordinate Protective Action Decisions (PAD) with the Chief South Carolina county elected officials or designees. At Site Area Emergency, sirens and the Emergency Alert System (EAS) will be activated. A test EAS message will be transmitted to the Local Primary (LP-1) EAS station, (WJMX, Florence, SC). A simulated EAS message and follow-on news release will be prepared but will not be transmitted to the LP-1 station. Copies of the simulated EAS message and .news, release will -be provided to the FEMA evaluator at the SEOC. The WP-I station will have szttff available for interview during the EAS demonstration. At General Emergency, activation of the sirens and EAS broadcast will be simulated.

Criterion 5.a.3: Activities associated, with' FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. Backup alert and notification of the pubic 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)

If there is a siren failure, affected counties will describe back-up alerting system.

Sub-element 5_b, Emergency Information and Instructions for the Public and the Media Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E. 5., 7., G.3.a., G.4, a., b., c.)

The State, Chesterfield County, Darlington County. and Lee County will demonstrate the ability to coordinate the formulation and dissemination of accurate information and instructions to the news media at the Joint Information Center (JIC). Rumor control for the State will be demonstrated at the JIC. Rumor control for Chesterfield, Darlington and Lee counties will be demonstrated at the appropriate county EOC. Rumor control personnel will provide a rumor calls log to the FEMA Evaluator.

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Sub-element 6.c, Temporary Care of Evacuees Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines (found in 'MASS CARE-Preparedness Operations, ARC 3031). Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654, J.10.h., 12.)

County shelters will be demonstrated out-of-sequence and concurrently with Evaluation Area 6.a, above. Procedures that assure that only non-contaminated persons enter shelters will be demonstrated.

Sub-element 6.d, Transportation and Treatment of Contaminated Injured Individuals 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.)

A Medical Services Drill (MS-1) will be conducted out of sequence and with a separate scenario. The drill will commence at the Birdstown Community Fire Department and conclude at Carolina Pines RMC on October 8, 2003.

9 Change one. 09109103

APPENDIX 4 EXERCISE SCENARIO This appendix contains'a summaiy 'ofthe simulated sequence of events, Exercise Scenario, which was used as the basis for invoking' emergency response actions by OROs in the H. B. Robinson exercise on October 7, 2003.

This exercise scenario was submitted by the State, of South Carolina and approved by FEMA Region IV.

34

H.B. Robinson Steam Electric Plant Unit No. 2 NRC Biennial Evaluated Exercise October 7. 2003 Narrative Summarm and Timellne g BS E 3

• Sii W At 0630 on October 7,2 003. H. B. Robinson Steam Electric Plant (HBRSEP) Unit Not 'Ž is at 100 percent power and at the middle of core life and has been in continuous operation for 203 days. The Southeast United States has experienced an increase in seismic rnctivity over the past several months.

A strong area of high pressure is located to the southeast and is maintaining a steady position. Partly cloudy skies with variable winds from 5 to'lo miles per hour (mph) lo vill be the forecast for the area through the next weekend. Day time temperatures will be in the mid-fifties through Friday; night time temperatures are expected to be in the loa thirties. Winds will be from the North/North West with a heading of about 315 degree:.

0700 Ttio Operations Crew assumes the watch takinc control of the plant 071 HA  ! eismic alarm will occur in the Control Room The crew is expected to re-: pond to the alarm in accordance with APP-036 and AOP-021, Sic;sri Eve v T Fe Control Room will receive confirmation of seismic activity in the re(Iio.1 07'10 Cornditions are met for the declaration of an UNUSUAL EVENT. An UNUSUAL EVENT should be declared at this time.

0)7 50 A steam leak will occur outside of containment on B main steam fine. The crew will commence a plant shutdown in accordanre with GP-006.

0fllQ RC.>l lIak-age will occur il 'A' Steam Generator a? -50 gpm. An unmonitor^'

rvieiase will occur via the steam driven AFW warm-tip line and will cause secvoncdary side contamination until the release path is isolated. The release Ji1t not impact any offsite locations.

Oe-5 Conditions are met for the declaration of an ALERT due to RCS lenainegteats r thin 50 gpm. An ALERT should be declared by this tirnie.

085' A-* the crew Is responding to RCS leakage into A Steam Generator. Component Cc-:ling Water Pump 'A' trips offline.

0915 Dual indication on purge outlet valves, V12-8/9, will be received in the Control Room. The outer valve will be found closed, thus no pathway is available. Dual Indication problems are caused by faulty limit switches which will need to be replaced.

0930 RIS leakage into 'A' generator will Increase to greater than 250 gpm resulting m a tube rupture. Conditions are met for the declaration of a SITE AREA EMERGENCY due to RCS leakage greater than charging capability.

1000 A Loose parts monitoring system Indication will be received. Fuel damage w:lI occur resulting in elevated radiation levels In the Auxiliary Building.

1100 A PORV will lift resulting in an alarm on R-31 indicating an offsite release is occurring. Conditions will be met for the declaration of GENERAL EMERGENCY. The release offsite will impact major portions of Darlington County within the ten mile area surrounding the plant. HBRSEP Environmental Monitoring Teams will monitor radiological conditions from the plant out to ton miles and determine the activity.

1130 A Damage Control Tearn will be dispatched to attempt repaIr and/or mitigatic~l .!

!thi release. The release will continue while the Control Room cools down ard de-oressurizes the RCS to mitigate the release.

1200 After exercise objectives for RNP and off-site agencies have been met. the exnrcise will be terminated. Facility critiques will be conducted at the end of the exercise.