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FEMA - Three Mile Island 1 Final Exercise Conducted on 04/22/03
	ML040340119
Person / Time
Site:	Three Mile Island
Issue date:	12/19/2003
From:	; Federal Emergency Management Agency
To:	; NRC/FSME
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Final Exercise Report Three Mile Island Power Station Licensee: AmerGen Corporation Exercise Date: April 22, 2003 Report Date: December 19, 2003 FEDERAL EMERGENCY MANAGEMENT AGENCY ONE INDEPENDENCE MALL, 6TH FLOOR 615 CHESTNUT STREET PHILADELPHIA, PENNSYLVANIA 19106-4404

THIS PAGE INTENTIONALLY LEFT BLANK TABLE OF CONTENTS I. EXECUTIVE

SUMMARY

................................................................................................. 6 II. INTRODUCTION............................................................................................................... 8 III. EXERCISE OVERVIEW.................................................................................................. 10 A. Plume Emergency Planning Zone Description...................................................... 10 B. Exercise Participants ............................................................................................. 12 C. Exercise Timeline.................................................................................................. 20 IV. EXERCISE EVALUATION AND RESULTS ................................................................. 25 A. Summary Results of Exercise Evaluation ............................................................. 25 B. Status of Jurisdictions Evaluated .......................................................................... 32

1. Commonwealth of Pennsylvania............................................................... 34 1.1 State Emergency Operations Center (SEOC)................................ 34 1.2 Joint Public Information Center (Harrisburg) ............................... 34 1.3 Emergency News Center (Harrisburg) .......................................... 34 1.4 Accident Assessment Center......................................................... 36 1.5 Accident Assessment Center (EOF Coatesville)........................... 36 1.6 State Traffic/Access Control Points .............................................. 36

2. Risk Jurisdictions ...................................................................................... 38 2.1 Cumberland County ...................................................................... 38 2.1.1 Cumberland County Emergency Operations Center ......... 38 2.1.2 Monitoring/Decontamination, Reception, and Mass Care Center - Big Spring High School ............................. 39 2.1.3 Emergency Worker Monitoring/Decontamination Center - Lemoyne Fire Dept. #11 ..................................... 39 2.1.4 New Cumberland Borough Emergency Operations Center ................................................................... 40 2.1.4.1 New Cumberland Route Alerting...................................... 41 2.1.5 Newville Community EMS - Carlisle Regional Medical Center .................................................................. 41 2.2 Dauphin County ............................................................................ 42 2.2.1 Dauphin County Emergency Operations Center ............... 42 2.2.2 Reception Center - Williams Valley High School............ 44 2.2.3 Monitoring/Decontamination and Mass Care Center -

Upper Dauphin High School ............................................. 45 i

2.2.4 Emergency Worker Monitoring/Decontamination Center - Harrisburg Area Community College................. 45 2.2.5 Conewago Township Emergency Operations Center........ 46 2.2.6 Londonderry Township Emergency Operations Center .... 46 2.2.6.1 Londonderry Route Alerting ............................................. 47 2.2.7 Lower Paxton Emergency Operations Center ................... 47 2.2.8 Highspire Borough Emergency Operations Center ........... 47 2.3 Lancaster County........................................................................... 48 2.3.1 Lancaster County Emergency Operations Center.............. 48 2.3.2 Reception Center - Park City Mall ................................... 48 2.3.3 Monitoring/Decontamination and Mass Care Center -

Mannheim Township High School Complex.................... 49 2.3.4 Emergency Worker Monitoring/Decontamination Center - Mount Joy Fire Department................................ 50 2.3.5 Mount Joy Township Emergency Operations Center........ 51 2.3.6 Elizabethtown Borough/West Donegal Emergency Operations Center.............................................................. 52 2.3.6.1 Elizabethtown Route Alerting........................................... 53 2.4 Lebanon County ............................................................................ 53 2.4.1 Lebanon County Emergency Operations Center ............... 53 2.4.2 Monitoring/Decontamination and Reception Center -

Lebanon Vo-Tech.............................................................. 55 2.4.3 Mass Care Center - Eastern Lebanon City High School Complex ................................................................... 55 2.4.4 Emergency Worker Monitoring/Decontamination Center - Annville Union Hose Fire House ....................... 57 2.4.5 South Londonderry Township Emergency Operations Center ................................................................... 57 2.4.5.1 South Londonderry Township Route Alerting .................. 57 2.5 York County.................................................................................. 58 2.5.1 York County Emergency Operations Center..................... 58 2.5.2 Monitoring/Decontamination, Reception, and Mass Care Center - Red Lion Jr. High School Complex ........... 58 2.5.3 Emergency Worker Monitoring/Decontamination Center - Springettsbury Fire Department.......................... 59 2.5.4 Conewago Township Emergency Operations Center........ 59 2.5.5 Fairview Township Emergency Operations Center........... 60 2.5.5.1 Fairview Township Route Alerting................................... 60 2.5.6 Goldsboro Borough Emergency Operations Center.......... 60 2.5.7 Hellam Township Emergency Operations Center............. 61 2.5.8 Springettsbury Township Emergency Operations Center ................................................................... 61 ii

2.5.9 Warrington Township/Wellsville Borough Emergency Operations Center.............................................................. 62 2.5.10 York Haven Borough Emergency Operations Center ....... 62

3. Support Counties....................................................................................... 63 3.1 Adams County............................................................................... 63 3.1.1 Adams County Emergency Operations Center.................. 63 3.1.2 Monitoring/Decontamination, Reception, and Mass Care Center - New Oxford Middle School ....................... 63 3.2 Franklin County............................................................................. 64 3.2.1 Franklin County Emergency Operations Center ............... 64 3.2.2 Monitoring/Decontamination, Reception, and Mass Care Center - Scotland School.......................................... 64 3.2.3 Monitoring/Decontamination and Mass Care Center -

Faust Jr. High School ........................................................ 66 3.3 Schuylkill County.......................................................................... 67 3.3.1 Schuylkill County Emergency Operations Center............. 67 3.3.2 Monitoring/Decontamination, Reception, and Mass Care Center - Blue Mountain High School....................... 67

4. School Districts ......................................................................................... 69 4.1 Cumberland County ...................................................................... 69 4.1.1 West Shore School District - Hillside Elementary School ................................................................... 69 4.2 Dauphin County ............................................................................ 69 4.2.1 Central Dauphin School District - Tri-Community Elementary School ............................................................ 69 4.2.2 Derry Township School District - Hershey Elementary School ................................................................... 69 4.2.3 Harrisburg School District - Foose Elementary School.... 70 4.2.4 Lower Dauphin School District - Londonderry Elementary School ............................................................ 71 4.2.5 Middletown Area School District - Feaser Middle School ................................................................... 71 4.2.6 Milton Hershey School District - Milton Hershey School ................................................................... 71 4.2.7 Steelton-Highspire School District - Steelton-Highspire High School ...................................................... 72 4.3 Lancaster County........................................................................... 72 4.3.1 Donegal School District - Maytown Elementary School ................................................................... 72 iii

4.3.2 Elizabethtown Area School District - East High St.

Elementary School ............................................................ 72 4.4 Lebanon County ............................................................................ 73 4.4.1 Palmyra Area School District - Palmyra High School...... 73 4.5 York County.................................................................................. 73 4.5.1.1 Central York School District - Sinking Springs Elementary School ............................................................ 73 4.5.1.2 Central York School District - Central Middle School .... 73 4.5.2.1 Northeastern School District - Northeastern High School ................................................................... 74 4.5.2.2 Northeastern School District - Orendorf Elementary School ................................................................... 74 4.5.3 Dover Area School District - Dover Area High School ... 74 4.5.4 Eastern School District - Eastern High School................. 75 iv

APPENDICES Appendix 1 Acronyms and Abbreviations .................................................................... 76 Appendix 2 Exercise Evaluators and Team Leaders..................................................... 79 Appendix 3 Exercise Evaluation Area Criteria and Extent-of-Play Agreement ........... 83 Appendix 4 Exercise Scenario .................................................................................... 124 Appendix 5 Planning Issues ........................................................................................ 128 Appendix 6 Additional Prior Issues ............................................................................ 134 LIST OF TABLES Table 1 Exercise Timeline...................................................................................... 21 Table 2 Summary Results of 2002 Exercise Evaluation ........................................ 26 v

I. EXECUTIVE

SUMMARY

On April 22 and 23, 2003, the Federal Emergency Management Agency (FEMA), Region III, conducted an exercise in the plume exposure pathway emergency planning zone (EPZ) around the Three Mile Island Nuclear Generating Station (TMINGS). The purpose of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency. This exercise was held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The most recent previous exercise at this site was conducted on May 22, 2001.

FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise. The Commonwealth of Pennsylvania, five risk counties (Cumberland, Dauphin, Lancaster, Lebanon, and York) and fifteen risk municipalities in the risk counties. The risk municipality for Cumberland County was New Cumberland Borough. The risk municipalities for Dauphin County included Conewago Township, Londonderry Township, Lower Paxton Township, and Highspire Borough. The risk municipalities for Lancaster County included, Mount Joy Township, and Elizabethtown Borough / West Donegal. The risk municipality for Lebanon County was South Londonderry Township. The risk municipalities for York County included, Conewago Township, Fairview Township, Goldsboro Borough, Hellam Township, Springettsbury Township, Warrington Township / Wellsville Borough and York Haven Borough. Three support counties, Adams, Franklin, and Schuylkill also participated.

The following out-of-sequence evaluation activities were conducted during the exercise week. On the morning of April 22, 2003, FEMA evaluated fifteen school districts in the risk counties, and the State Police from all five-risk county troop locations for Traffic/Access control activities in Pennsylvania. In the evening on April 23, 2003, FEMA conducted out-of-sequence evaluations of Monitoring/Decontamination/Mass Care/Reception Center and Emergency Worker Monitoring and Decontamination facilities at the five risk counties and three support counties. A Medical Services evaluation was performed in Cumberland County for Carlisle Regional Medical Center, and Newville Community EMS.

Evaluations were conducted in the evening on April 22, 2003, of the EOCs in the five risk counties, three support counties and the Commonwealth of Pennsylvania. There were also fifteen Risk County Municipalities, which were also evaluated in the evening of April 22, 2003.

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 evaluations of the out-of-sequence activities conducted on April 22 and 23, 2003.

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The State and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. Zero Deficiencies and 12 Areas Requiring Corrective Action (ARCA) were identified, however 4 were satisfactorily re-demonstrated during the Exercise period, leaving 8 ARCAs. There were 23 prior ARCAs evaluated during this exercise; all were resolved. There were 6 outstanding ARCAs that were not scheduled for demonstration during this exercise. Eight Planning Issues were also identified during this exercise.

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II. INTRODUCTION On December 7, 1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. FEMAs activities are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351, and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

FEMA Rule 44 CFR 350 establishes the policies and procedures for FEMAs initial and continued approval of tribal, 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.

FEMAs 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 (44 CFR Part 354, Appendix A, 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,

- 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 Regional Assistance Committee (RAC), which is chaired by FEMA.

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The Commonwealth of Pennsylvania and local jurisdictions submitted their RERPs for the THREE MILE ISLAND NUCLEAR GENERATING STATION to FEMA Region III and were granted formal approval of the RERPs on August 24, 1998, under 44 CFR 350.

FEMA Region III conducted a joint REP exercise on April 22 and April 23, 2003, 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 Three Mile Island Nuclear Generating Station. Out-of-sequence demonstrations of monitoring

/decontamination centers, reception centers, and mass care centers were conducted on April 23, 2003.

The purpose of this exercise report is to present the exercise results and findings on the performance of the offsite 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 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;

FEMA Guidance Memoranda MS-1, Medical Services, November 1986;

Interim Radiological Emergency Preparedness (REP) Program Manual, August 2002;

67 FR 20580, FEMA Radiological Emergency Preparedness: Exercise Evaluation Methodology, April 25, 2002; and

66 FR 47546, FEMA Radiological Emergency Preparedness: Alert and Notification, September 12, 2001.

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 that 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 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 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 unresolved ARCAs assessed during previous exercises and the status of the OROs efforts to resolve them.

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III. EXERCISE OVERVIEW This section contains data and basic information relevant to the April 22, 2003, demonstrations and the exercise, to test the offsite emergency response capabilities in the area surrounding the Three Mile Island Nuclear Generating Station. This section of the exercise report includes a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were evaluated and a tabular presentation of the actual time of occurrence of key exercise events and activities.

A. Plume Emergency Planning Zone Description The TMI Nuclear Power Station (40° 9' 12" N/76° 43' 25" W) is a nuclear power plant operated by the AmerGen Energy Company, LLC. The site consists of two pressurized water-type units. Unit One is an 819-megawatt (MW) reactor, and Unit Two is a 906-MW reactor. Unit 1 received its license in June 1974 and began commercial operation in September 1974. Unit 2 began commercial operation in February 1978; it was damaged in March 1979 and has been shut down and placed in a monitored storage mode.

The minimum exclusion distance specified for the TMI plant is 2,000 feet. Included within the 2,000-foot radius are a portion of Three Mile Island, a portion of Shelly Island, and a portion of the Susquehanna River. AmerGen and GPU Nuclear Corporation own all the land within the exclusion area.

The TMI plant is located in south-central Pennsylvania in Londonderry Township, Dauphin County.

The site is part of an 814-acre tract consisting of several adjacent islands in the Susquehanna River. The power plant is located on Three Mile Island, which is one of the largest islands of the group. The site is at an elevation of 300 feet above mean sea level (msl), relatively flat, and wooded on the periphery and the southern portion. Of the 470 acres that make up the island, the plant occupies approximately 200 acres in the northern portion.

Soils on the island are of the Duncannon-Chavies-Tioga Association, which comprises deposits of alluvial sand, silt, and clay. Underlying bedrock is red sandstone and shale.

The normal pool elevation of the Susquehanna River in this area is 277 feet above msl. Hills on both sides of the river in this vicinity rise to elevations of over 500 feet. The plant grade is 300 feet above msl.

An access bridge for plant personnel connects State Route 441 with the north end of the island. A wooden bridge connects the southern portion of the island with State Route 441. Conrail lines are located on both sides of the river; the closest is a one-track line adjacent and parallel to Route 441 on the east shore.

The area within 10 miles of the TMI Nuclear Power Station is located in south-central Pennsylvania, and includes portions of Cumberland, Dauphin, Lancaster, Lebanon, and York counties. The site is surrounded mostly by farmland within a 10-mile radius. The nearest community is Goldsboro Borough, on the west shore of the Susquehanna River, 1 mile from the plant. The nearest major population center 10

with more than 25,000 people is Harrisburg (population 53,624), which lies just over 10 miles to the north.

Twenty-three industrial firms are located within a 5-mile radius; they employ approximately 2,400 people. The Harrisburg International Airport is located 2 miles northwest of the TMI plant. An NRC estimate of aircraft risk to TMI Units One and Two indicates an acceptably low risk for either unit, provided fewer than 2,400 operations per year are by aircraft in excess of 200,000 pounds. The NRC requires Amergen to continue periodic monitoring and reporting of airport usage and will reevaluate the adequacy of plant protection if aircraft traffic is reliably projected to exceed 2,400 operations per year.

The major railroads operating in the EPZ include Amtrak, Blue Mountain and Ridge, Chessie System, Conrail, and the Maryland and Pennsylvania Railroad.

The climate of the five-county risk EPZ is mild and humid. Weather is variable because the prevailing westerly winds bring both high- and low-pressure systems through the area every few days. Average annual precipitation for the southern portion of the county is about 38 inches, and the average annual temperature is 52°F.

On the basis of the 2000 census, the total population of the 10-mile EPZ is 201,800. There are 79 sirens used to provide coverage of the plume exposure pathway EPZ. The county in which it is located operates each siren system.

The 10-mile EPZ for Three Mile Island Nuclear Generating Station covers the following jurisdictions which participated in the April 22, 2003 REP Exercise:

Cumberland County New Cumberland Borough Dauphin County Conewago Township Londonderry Township Lower Paxton Township Highspire Borough Lancaster County Mount Joy Township Elizabethtown Borough/West Donegal Lebanon County South Londonderry Township York County Conewago Township 11

York County (cont)

Fairview Township Goldsboro Borough Hellam Township Springettsbury Township Warrington Township/Wellsville Borough York Haven Borough B. Exercise Participants The following agencies, organizations, and units of government participated in the Three Mile Island Nuclear Generating Station out-of-sequence demonstrations and REP exercise held on April 22-23, 2003.

Commonwealth of Pennsylvania Exelon Nuclear Pennsylvania Bureau of Radiation Protection Pennsylvania Department of Agriculture Pennsylvania Department of Corrections Pennsylvania Department of Education Pennsylvania Department of Environmental Protection (DEP),

Pennsylvania Fish and Boat Commission Pennsylvania Game Commission Pennsylvania Secretary for Public Information Pennsylvania Department of Health Pennsylvania Department of Military Affairs Pennsylvania Emergency Management Agency Pennsylvania State Police (PSP)

Pennsylvania Public Utility Commission (PUC)

Pennsylvania Department of Transportation (PennDOT)

Pennsylvania Turnpike Commission Pennsylvania Department of Conservation/Natural Resources Pennsylvania Department of General Services Pennsylvania Department of Labor Press Secretary Office Pennsylvania Department of State Press Secretary Office Pennsylvania Governor's Office Pennsylvania Water Sanitation Department WHTM - TV, Channel 27, Harrisburg, PA.

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Risk Jurisdictions Cumberland County Cumberland County Public Information Team Cumberland County Sheriffs Department Cumberland County Transportation Department Cumberland County Commissioners Cumberland County Emergency Management Agency Cumberland County Special Hazards Operations Team Lemoyne Fire Department #11 West Shore Bureau of Fire Pennsylvania Army National Guard Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency Pennsylvania State Police U.S. Department of Agriculture Cooperative Extension Friendship Hose Company of Newville Vigilant Hose Company #1 of Shippensburg Newville Area Community Ambulance Unit #147 EMTs Carlisle Regional Medical Center New Cumberland Borough Council New Cumberland Fire Department, NCFD Company 10 New Cumberland Borough Emergency Management Coordinator New Cumberland Police Dauphin County Dauphin County Area Agency on Aging Dauphin County Office of Mental Health/Mental Retardation Dauphin County Commissioners Office Dauphin County Emergency Management Agency Pennsylvania Army National Guard (Lewisburg)

Pennsylvania State Police Dauphin County Emergency Management Agency Hazardous Materials/Special Operations Harrisburg Area REACT Williams Town Borough/Williams Township EMA Environmental Products and Services, Inc.

Conewago Township Township Board of Supervisors Fire Department, Police Department 13

Londonderry Township Township Board of Supervisors Londonderry Fire Department, Londonderry Police Department Lower Paxton Lower Paxton Township Police Dept Lower Paxton Township Heath Dept Lower Paxton Township Fire Dept Lower Paxton Township Public Works Highspire Borough Highspire Borough Emergency Management Highspire Borough Police Department Highspire Borough Fire Department Highspire Borough First Aid Squad Highspire Borough Public Works Highspire Borough Administrator Highspire Borough Mayor Highspire Borough Council Members (6)

Lancaster County Lancaster County Emergency Services Lancaster County Engineers Department Lancaster Fire Services Lancaster Geographics Information Systems Lancaster Medical Services Lancaster Public Works Manheim Township Fire Services Pennsylvania DOT Pennsylvania National Guard Pennsylvania State Police County Administrator Lancaster County Emergency Management Agency Lancaster County Emergency Management Coordinator Manheim Township Emergency Management Agency Neffsville Community Fire Department Lancaster County HAZMAT Team #29 Mount Joy Township Mount Joy Fire Department Mount Joy Township Emergency Management Agency 14

Elizabethtown Borough / West Donegal Elizabethtown EOC Staff Elizabethtown Fire Department Friendship Fire and Hose Company, Number 1 Elizabethtown Rheems Fire Company, West Donegal Lebanon County Pennsylvania Army National Guard Lebanon County Emergency Management Agency Lebanon County Sheriffs Dept.

Lebanon County Agricultural Extension Office Lebanon County Conservation District Pennsylvania State Police (Troop L)

Lebanon County EMA (4)

Lebanon County EMA HASMAT (6)

Union Water Works Fire Co. (5)

Lebanon County Auxiliary Patrol (4)

Union Hose - Annville Fire Police (2)

Schaefferstown Ambulance Co. (5)

Lebanon County Career and Technical Center (Vo-Tech) (2)

South Londonderry Township South Londonderry Township Emergency Management Agency South Londonderry Township Emergency Management Coordinator Lebanon County Emergency Management Agency (HAZMAT Team)

South Londonderry Township Supervisors South Londonderry Police Dept.

South Londonderry Fire Dept.

South Londonderry Township supervisors South Londonderry Township Manager South Londonderry EMS York County Pennsylvania State Police York County Department of Public Works York County Emergency Management Agency York County Emergency Medical Assistance York County Haz-Mat Team York County Police Department York County Department of Emergency Services York County Sheriffs Department York County 911 York County Department of Public Works York County Extension Agency York County Park Service 15

Pennsylvania Army National Guard Pennsylvania Department of Transportation Grangeville Fire Company Hazmat 51 - out of Hanover Red Lion Area Ambulance Conewago Township Conewago Township Emergency Medical Services Conewago Township Emergency Management Agency Conewago Township Fire/Rescue Department Conewago Township Transportation Department Conewago Township Public Works Conewago Township Police Department Conewago Township Public Information Conewago Township Supervisors Fairview Township Fairview Township Fire Department (44-Volunteer fire fighters)

Fairview Township Police Department Fairview Board of Supervisors Fairview Township Emergency Medical Services Fairview Township Public Works Fairview Township Transportation York County Amateur Radio Communications 50+ Volunteers Fairview Township Fire Department (Volunteer)

Goldsboro Borough Goldsboro Emergency Management Agency Goldsboro Borough Council Radio Amateur Civil Emergency Service Hellam Township Hellam Township Hellam Borough Hellam Township Police Hellam Volunteer Fire Company Eastern York County Medical Services Wrightsville Borough Fire Company RACES Springettsbury Township Springettsbury Police Department RACES Warrington Township / Wellsville Borough 16

Wellsville Borough Elected Officials Warrington Township Elected Officials York County Safety Office Wellsville Volunteer Fire Company RACES York Haven Borough Members of Borough Council including Borough President Fire Department Radio Amateur Civil Emergency Services (RACES)

Support Counties Adams County The Adams County Emergency Operations Center staff Adams County Coordinator, Adams County Deputy Coordinator, Adams County Public Information Officer, Adams County Radiological Officer Adams County Communication Officer PEMA Liaison.

American Red Cross Radio Amateur Civil Emergency Services (RACES)

Gettysburg Fire/Police Franklin County County Emergency Management Coordinator Director of Emergency Services Public Information Officer PEMA Liaison Officer Eleven (11) Franklin County EOC Functional Position Representatives RACES Representatives Franklin County Department of Emergency Services American Red Cross, Franklin County Schuylkill County Schuylkill County Emergency Management Agency Pennsylvania Emergency Management Agency Department of Corrections Schuylkill County Emergency Medical Services Schuylkill County Sheriff Department of Agriculture County Public Works Pennsylvania State Police Department County Fire Department 17

Schuylkill County Exelon Nuclear Pennsylvania Department of Health USDA Farm Services Schuylkill County Radiological Response Team Schools Cumberland County West Shore School District Hillside Elementary School Dauphin County Central Dauphin School District Tri-Community Elementary Derry Township School District Hershey Elementary Harrisburg School District Foose Elementary Lower Dauphin School District Londonderry Elementary Middletown Area School District Feaser Middle School Milton Hershey School District Milton Hershey School Steelton-Highspire School District Steelton-Highspire School Lancaster County Donegal School District Maytown Elementary School Elizabethtown Area School District East High St. Elementary School Lebanon County Palmyra Area School District Palmyra High School 18

York County Central York School District Sinking Springs Elementary School Central Middle School Northeastern School District Orendorf Elementary School Northeastern High School Dover Area School District Dover Area High School Private/Volunteer Organizations The following private and volunteer organizations participated in the THREE MILE ISLAND NUCLEAR GENERATING STATION exercise at many different locations throughout the area.

We thank them and all those who volunteer their services to State, county, and municipal governments during emergencies.

American Red Cross Radio Amateur Civil Emergency Services (RACES)/Amateur Radio Emergency Service (ARES) 50+ Volunteers 19

C. Exercise Timeline Table 1, on the following page, presents the times at which key events and activities occurred during the Three Mile Island Nuclear Generating Station April 22, 2003 exercise. Also included are times notifications were made to the participating jurisdictions/functional entities.

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TABLE 1. EXERCISE TIMELINE DATE AND SITE: April 22, 2003, Three Mile Island Nuclear Generating Station Time That Notification Was Received or Action Taken Emergency Time PA Accident EOF Media Cumberland New Dauphin Conewago Londonderry Lower Highspire Classification Utility State Assessment Ops EOC Cumberland EOC EOC Twp EOC Paxton Boro Declared EOC Center EOC EOC EOC Unusual Event 1557 1622 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 1635 1642 1647 1642 1702 1641 1650 1642 1651 1648 1652 1650 SAE 1752 1755 1754 1752 1752 1804 1808 1759 1815 1816 1807 1808 General 1929 1939 1931 1931 1930 1944 1950 1939 1950 1944 1944 1948 Emergency Rad Release 1635 1642 1655 1926 1730 1804 1811 1642 1720 1806 1740 1650 Release 2003 2013 2012 2045 N/A N/A N/A N/A N/A N/A N/A Terminated Facility 1659 1535 1712 1738 1703 1730 1657 1740 1715 1735 1730 Operational Gov Declaration 1946 NR NR 2005 1955 1948 1955 NR 2006 1958 2003 of State of Emergency Local N/A 1905 2007 Declaration of Emergency Exercise 2113 2115 2140 2126 2052 2100 2103 2035 2048 2102 2100 Terminated Precautionary Shelter Livestock 1620 1819 1848 1904 NR NR 1853 1908 1911 1910 1912 Close Highway 1956 Close Railroad 1956 1st A&N Dec 1810 N/A 1842 1812 1812 1819 1820 1812 1st Siren Act 1820 N/A 1820 1820 1820 1820 1820 1820 1820 1820 1st EAS 1823 N/A 1823 1823 1823 1823 1823 1823 1823 1823 2nd A&N Dec 1948 N/A 2008 1948 1955 1956 1955 1957 1956 1957 1957 2nd Siren Act 1958 N/A 1958 1958 1958 1958 1958 1958 1958 1958 2nd EAS 2001 N/A 2001 2001 2001 2001 2001 2001 2001 2001 KI Decision 1955 1955 1955 2022 2028 2017 2023 2027 2035 2035 Action Taken 2005 NR NR 2022 2028 NR NR NR NR NR NR- Not Received 21

TABLE 1. EXERCISE TIMELINE DATE AND SITE: April 22, 2003, Three Mile Island Nuclear Generating Station Time That Notification Was Received or Action Taken Emergency Time Lancaster Mt Elizabethtown York Conewago Fairview Goldsboro Hellam Springettsbury Warrington Classification Utility EOC Joy West Donegal EOC EOC EOC EOC EOC Twp EOC Wellsville Declared EOC EOC EOC Unusual Event 1557 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 1635 1642 1657 1649 1646 1655 1647 1647 N/A 1648 1658 SAE 1752 1759 1759 1806 1802 1805 1807 1806 1759 1759 1806 General 1929 1939 1948 1945 1942 1949 1945 1939 1939 1942 1955 Emergency Rad Release 1635 1939 1948 1945 1646 1949 1759 1931 1939 1759 2001 Release 2003 NA NA NA NA NA N/A N/A N/A N/A N/A Terminated Facility 1745 1759 1702 1612 1745 1725 1719 1717 1705 1738 Operational Gov Declaration 1951 NR 2005 1951 2010 2002 NR 2002 2035 NR of State of Emergency Local NA NA NA NA NA NA NA NA 2001 NA Declaration of Emergency Exercise 2116 2116 2045 2113 2113 2113 2035 2118 NA 2111 Terminated Precautionary Shelter Livestock NA 1901 1900 1849 1855 1855 1851 1855 1849 1855 Close Highway Close Railroad 1st A&N Dec 1814 1827 1820 1815 1820 1852 1852 1820 NR 1945 1st Siren Act 1820 1820 1820 1820 1820 1820 1820 1810 1820 1820 1st EAS 1823 1823 1823 1823 1823 1823 1823 1823 1823 1823 2nd A&N Dec 1951 2000 2000 2000 2001 2001 2001 1939 1956 1957 2nd Siren Act 1958 1958 1958 1958 1958 1958 1958 1958 1958 1958 2nd EAS 2001 2001 2001 2001 2001 2001 2001 2001 2001 2001 KI Decision 2006 2020 2025 2007 2022 2023 2024 2012 2007 2020 Action Taken NR NR NR 2016 2023 2024 2024 NR 2010 NR NR- Not Received 22

TABLE 1. EXERCISE TIMELINE DATE AND SITE: April 22, 2003, Three Mile Island Nuclear Generating Station Time That Notification Was Received or Action Taken Emergency Time York Lebanon South Adams Franklin Schuylkill Classification Utility Haven County Londonderry County County County Declared EOC EOC EOC EOC EOC EOC Unusual Event 1557 N/A N/A N/A N/A N/A N/A Alert 1635 1700 1642 1645 1708 1705 1711 SAE 1752 1759 1801 1804 1817 1824 1825 General 1929 1939 1952 1943 1951 1950 2000 Emergency Rad Release 1635 1700 1642 1958 1951 1950 2000 Release 2003 NA NA NA NA NA N/A Terminated Facility 1752 1732 1718 1714 1730 1726 Operational Gov Declaration 1958 2006 2001 1956 1955 2038 of State of Emergency Local NA NA NA NA NA NA Declaration of Emergency Exercise 2015 2102 2103 2110 2107 2107 Terminated Precautionary Shelter Livestock 1900 1905 NR 1852 1855 1943 Close Highway Close Railroad 1st A&N Dec NR 1810 NR NR NR 2030 1st Siren Act 1820 1820 1820 1820 1820 1820 1st EAS 1823 1823 1823 1823 1823 1823 2nd A&N Dec NR NR 2001 NR NR NR 2nd Siren Act 1958 1958 1958 1958 1958 1958 2nd EAS 2001 2001 2001 2001 2001 2001 KI Decision 2007 1955 2055 2006 2023 2041 Action Taken 2007 NR NR NA NA NA NR- Not Received 23

TABLE 1. EXERCISE TIMELINE DATE AND SITE: April 22, 2003, Three Mile Island Nuclear Generating Station THIS PAGE INTENTIONALLY LEFT BLANK 24

IV. EXERCISE EVALUATION AND RESULTS Contained in this section are the results and findings of the evaluation of all jurisdictions and locations that participated in the April 22-23, 2003, out-of-sequence demonstrations and the April 22, 2003, REP exercise to test the offsite emergency response capabilities of State and local governments in the 10-mile EPZ surrounding the Three Mile Island Nuclear Generating Station.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the exercise evaluation area criteria contained in the FEMA REP Exercise Evaluation Methodology. Detailed information on the exercise evaluation area criteria and the extent-of-play agreement used in this exercise is found in Appendix 3 of this report.

A. Summary Results of Exercise Evaluation The matrix presented in Table 2, on the following pages, presents the status of the exercise evaluation area criteria from the FEMA REP Exercise Evaluation Methodology that were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise evaluation area criteria are listed by number (reference Section IV, Appendix 3, Exercise Evaluation Area Criteria and Extent-of-Play Agreement) and the demonstration status of the criteria is indicated by the use of the following letters:

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

D Deficiency assessed A ARCA(s) assessed A1 ARCA(s) assessed, but successfully redemonstrated R Resolved ARCA(s) from prior exercise(s)

U Unresolved ARCA(s) from prior exercises N Not Demonstrated (Reason explained in Section IV.B)

M - Met (No Deficiency or ARCA(s) assessed) A - ARCA(s) Assessed A1 - ARCA(s) assessed, but successfully redemonstrated U - Unresolved ARCA(s) from prior exercise(s)

D - Deficiency assessed Blank - Not scheduled for demonstration R - Resolved ARCA(s) 25

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2003 Three Mile Island Nuclear Generating Station SUPPORT OFFSITE RESPONSE EMERGENCY OPNS PROTECTIVE ACTION FIELD MEASUREMENT EMERG NOTIF &

PROTECTIVE ACTION IMPLEMENTATION OPERATION/

ORGANIZATION MANAGEMENT DECISION-MAKING & ANALYSIS PUBLIC INFO FACILITIES COMMONWEALTH OF 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 PENNSYLVANIA State EOC M M M M M M M M M M M Emergency News Center (JIC) M M CENIC (PI at SEOC) M R Accident Assessment Center M M M M M M M State Field Monitoring Team 1 State Field Monitoring Team 2 Emergency Operations Facility M M M M State DEP/BRP Laboratory State Field Sampling Team 1 State Field Sampling Team 2 State Traffic/Access Control Pts (

M R M M M M Barracks H)*

State Eastern Area EOC (Hamburg)

State Central Area EOC (Selinsgrove)

RISK JURISDICTIONS CUMBERLAND COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 County EOC (Cumberland) M M M M M M M M M M M M R Reception Ctr/Mass Care/ Mon/Decon-M M M M M Big Spring HS Emergency Worker Mon/Decon M M M A1 M Lemoyne Fire Dept. #11 New Cumberland Borough EOC M M M M M M M M M M M M M New Cumberland Route Alerting M M M Newville Community EMS / Carlisle Regional Medical Center A M A M - Met (No Deficiency or ARCA(s) assessed) A - ARCA(s) Assessed A1 - ARCA(s) assessed, but successfully redemonstrated U - Unresolved ARCA(s) from prior exercise(s)

D - Deficiency assessed Blank - Not scheduled for demonstration R - Resolved ARCA(s) 26

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2003 Three Mile Island Nuclear Generating Station SUPPORT OFFSITE RESPONSE EMERGENCY OPNS PROTECTIVE ACTION FIELD MEASUREMENT EMERG NOTIF &

PROTECTIVE ACTION IMPLEMENTATION OPERATION/

ORGANIZATION MANAGEMENT DECISION-MAKING & ANALYSIS PUBLIC INFO FACILITIES PENNSYLVANIA RISK JURISDICTIONS (CONTINUED)

DAUPHIN COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 County EOC (Dauphin) M M M M M M M M R M M M A Reception Center - Williams Valley HS M M M Mass Care-Mon/Decon - Upper Dauphin HS M M M R M Emergency Worker Mon/Decon Harrisburg Area College M M M M M Conewago Twp. EOC M M M M M M M M M M M M M Londonderry Twp. EOC M M M M M M M M M M M M M Londonderry Twp. Route Alerting M M M Lower Paxton Twp. EOC M M M M M M M M M M M M M Highspire Borough EOC M M M M M M M M M M M M M LANCASTER COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 County EOC (Lancaster) M M M M M M M M M M M M M Reception Center M M M Park City Mall Emergency Worker Mon/Decon M M M M R Mount Joy Fire Dept.

Mass Care - Mon / Decon M A M M M Mannheim Twp. High School Mount Joy Twp. EOC M M R M M M M M R M M M M Elizabethtown Borough/West Donegal M M M M M M M A M M M M M EOC Elizabethtown Route Alerting M R R LEBANON COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 County EOC (Lebanon) M M M M M M M M M M M M R Reception Ctr / Mon/Decon - Lebanon M M M M Vo Technical School Mass Care-Eastern Lebanon City HS M R M Emergency Worker Mon / Decon-M M M M M Annville Union Hose Fire Dept.

South Londonderry Twp EOC M M M M M M M M M M M M M S Londonderry Twp Route Alerting M M M M - Met (No Deficiency or ARCA(s) assessed) A - ARCA(s) Assessed A1 - ARCA(s) assessed, but successfully redemonstrated U - Unresolved ARCA(s) from prior exercise(s)

D - Deficiency assessed Blank - Not scheduled for demonstration R - Resolved ARCA(s) 27

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2003 Three Mile Island Nuclear Generating Station OFFSITE RESPONSE EMERGENCY OPNS PROTECTIVE ACTION FIELD MEASUREMENT EMERG NOTIF & SUPPORT PROTECTIVE ACTION IMPLEMENTATION ORGANIZATION MANAGEMENT DECISION-MAKING & ANALYSIS PUBLIC INFO OPERATION/

PENNSYLVANIA RISK JURISDICTIONS (CONTINUED)

YORK COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 County EOC (York) M M M M M M M M M M M M M M M Reception Center, Mass Care, M M M M M Mon/Decon - Red Lion Jr HS Emergency Worker Mon/Decon M M M M M Springettsbury Fire Dept.

1 Conewago Twp EOC M M M M M M M A M M M M M Fairview Twp EOC M M M M M M M M M M M M M Fairview Route Alerting M M M Goldsboro Borough EOC M M M M M M M M M M M M M Hellam Twp EOC M M M M M M M M M M M M M Springettsbury Twp EOC M M M M M M M M M M M M M Warrington / Wellsville Boro EOC M M M M M M M M M M M M M York Haven Boro EOC M M M M M M M M M M M M M M - Met (No Deficiency or ARCA(s) assessed) A - ARCA(s) Assessed A1 - ARCA(s) assessed, but successfully redemonstrated U - Unresolved ARCA(s) from prior exercise(s)

D - Deficiency assessed Blank - Not scheduled for demonstration R - Resolved ARCA(s) 28

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2003 Three Mile Island Nuclear Generating Station SUPPORT OFFSITE RESPONSE EMERGENCY OPNS PROTECTIVE ACTION FIELD MEASUREMENT EMERG NOTIF &

PROTECTIVE ACTION IMPLEMENTATION OPERATION/

ORGANIZATION MANAGEMENT DECISION-MAKING & ANALYSIS PUBLIC INFO FACILITIES SUPPORT COUNTIES 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 Adams County EOC M M M M M M Mon/Decon, Reception Ctr, Mass Care - New Oxford M M M A M Middle School Franklin County EOC M M M M M M Mon/Decon, Reception Ctr, M M M A M Mass Care - Scotland School Mon/Decon, Mass Care - Faust M M M R M Jr. High School Schuykill County EOC M M M M M A1 Mon/Decon, Reception Ctr, M M M M M Mass Care - Blue Mountain HS M - Met (No Deficiency or ARCA(s) assessed) A - ARCA(s) Assessed A1 - ARCA(s) assessed, but successfully redemonstrated U - Unresolved ARCA(s) from prior exercise(s)

D - Deficiency assessed Blank - Not scheduled for demonstration R - Resolved ARCA(s) 29

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2003 Three Mile Island Nuclear Generating Station SUPPORT OFFSITE RESPONSE EMERGENCY OPNS PROTECTIVE ACTION FIELD MEASUREMENT EMERG NOTIF &

PROTECTIVE ACTION IMPLEMENTATION OPERATION/

ORGANIZATION MANAGEMENT DECISION-MAKING & ANALYSIS PUBLIC INFO FACILITIES PENNSYLVANIA SCHOOL DISTRICTS CUMBERLAND COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 West Shore SD - Hillside ES M DAUPHIN COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 Central Dauphin SD - Tri-Community Elementary School M

Derry Township SD - Hersey ES A1 Harrisburg SD - Foose ES A Lower Dauphin SD - Londonderry Elementary School M

Middletown Area SD - Feaser MS M Milton Hershey SD - Milton Hershey M Steelton-Highspire SD - Steelton-Highspire HS M

LANCASTER COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 Donegal SD - Maytown ES M Elizabethtown Area SD - East High Sreet ES* M LEBANON COUNTY 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 Palmyra Area SD - Palmyra HS M YORK COUNTY (PA) 1.a.1 1.b.1 1.c.1 1.d.1 1.e.1 2.a.1 2.b.1 2.b.2 2.c.1 2.d.1 2.e.1 3.a.1 3.b.1 3.c.1 3.c.2 3.d.1 3.d.2 3.e.1 3.e.2 3.f.1 4.a.1 4.a.2 4.a.3 4.b.1 4.c.1 5.a.1 5.a.2 5.a.3 5.b.1 6.a.1 6.b.1 6.c.1 6.d.1 Central York SD - Sinking Springs M

Elementary School M

Central York SD - Central Middle School M

Northeastern SD - Northeastern HS Northeastern SD - Orendorf ES M Dover Area SD - Dover Area HS M Eastern SD - Eastern HS M M - Met (No Deficiency or ARCA(s) assessed) A - ARCA(s) Assessed A1 - ARCA(s) assessed, but successfully redemonstrated U - Unresolved ARCA(s) from prior exercise(s)

D - Deficiency assessed Blank - Not scheduled for demonstration R - Resolved ARCA(s) 30

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2003 Three Mile Island Nuclear Generating Station THIS PAGE INTENTIONALLY LEFT BLANK M - Met (No Deficiency or ARCA(s) assessed) A - ARCA(s) Assessed A1 - ARCA(s) assessed, but successfully redemonstrated U - Unresolved ARCA(s) from prior exercise(s)

D - Deficiency assessed Blank - Not scheduled for demonstration R - Resolved ARCA(s) 31

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 criteria demonstration status.

Met - Listing of the demonstrated exercise evaluation area 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 evaluation area criteria under which one or more Deficiencies were assessed during this exercise.

Included is a description of each Deficiency and recommended corrective actions.

Area Requiring Corrective Actions - Listing of the demonstrated exercise evaluation area criteria under which one or more ARCAs were assessed during the current exercise. Included is a description of the ARCAs assessed during this exercise and the recommended corrective actions to be demonstrated before or during the next biennial exercise.

Not Demonstrated - Listing of the exercise evaluation area criteria, which were not scheduled to be demonstrated during this exercise and the reason they were not demonstrated.

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

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

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

A Deficiency is defined in the Radiological Emergency Preparedness Program Manual 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 32

a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant.

An Area Requiring Corrective action (ARCA) is defined 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.

A Plan Issue is defined as an observed or identified inadequacy in the OROs emergency plan or implementing procedures, rather than in the OROs performance. Plan issues are not considered to be exercise issues.

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.

Evaluation Area Criterion - A letter and number corresponding to the criteria in the FEMA Interim Radiological Emergency Preparedness Program Manual.

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

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

33

1. Commonwealth of Pennsylvania 1.1 State Emergency Operations Center (SEOC)

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

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 Joint Public Information Center (Harrisburg)

a. MET: 5.a.1 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 1.3 Emergency News Center (Harrisburg)

a. MET: 5.a.1 5.b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None 34

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 5.b.1 Issue No.: 64-01-11-A-01 (5.b.1)

Description:

The Emergency Alert System (EAS) messages issued at the Site Area Emergency and the General Emergency did not include the current emergency conditions at the nuclear power plant with reference to both the potential for (and) actual release of radioactivity and the current Emergency Classification Level. This is required by NUREG-0654, E.7 and FEMA guidance memo dated 02 February 1999. In addition, the title of the official authorizing the release of the EAS message must be included. (NUREG-0654, E.7)

Corrective Action Demonstrated: Both EAS messages issued by the SEOC staff contained all of the FEMA requirements as reflected in the Federal Register Notice, Volume 66, Number 177, September 12, 2001.

Issue No.: 64-01-13-A-02 (5.b.1)

Description:

On several occasions rumor control was not always provided with up-to-date information regarding the status of events during the exercise. Specifically, although News Release #4 (TMI Alert Caused by Fire) was released at 1735, rumor control did not receive a copy of the news release until 1858 (1-hour and 23 minutes after the initial release).

In addition, rumor control did not learn about the evacuation order until 2034 when the Pennsylvania State Police forwarded an e-mail to rumor control questioning whether Dauphin County had started evacuating members of the general public 24 minutes after the decision to activate the emergency alert system at 2010 had been ordered. And although rumor control received News Release #8 (General Emergency Declaration at Three Miles Island Nuclear Generating Station), rumor control never received copies of the emergency broadcast (EBS) messages. Section 4.B.4(a), Page E-16.4, of Appendix 16, Annex E, Public Education and Information, states that the Commonwealth Emergency News and Information Center (CENIC) will receive, compile, and prepare timely and accurate information for evaluation and release, and rumor control did not receive all information in a timely manner.) (NUREG-0654, G.4.a.,b.,c.)

Corrective Action Demonstrated: A new computer system has been installed which allowed Rumor Control to receive all messages and press releases as they are issued. These messages are duplicated and issued to 35

the rumor control operators so they have updated and current information at all times.

f. PRIOR ARCAs - UNRESOLVED: None 1.4 Accident Assessment Center

a. MET: 1.b.1 2.a.1 4.a.2 1.c.1 2.b.1 1.d.1 1.e.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: 1.a.1

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.5 Accident Assessment Center (EOF Coatesville)

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.6 State Traffic/Access Control Points

a. MET: 1.d.1 2.a.1 3.a.1 1.e.1 3.b.1 3.d.1 36

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 1.e.1 Issue No.: 64-01-05-A-03 (1.e.1)

Description:

Documentation reflecting that dosimetery electrical leakage tests were not available for inspection at the Pennsylvania State Police Headquarters. (NUREG-0654, J.10. and K.3.a.)

Corrective Action Demonstrated: The Direct Reading Dosimeters utilized have a 0-20 R range and were a mixture of Victoreen, CDV-730, and Dosimeter Corporation of America (DCA - Model 622). A document was provided that contained the results of the electrical leakage tests performed on these dosimeters between March 12 - 14, 2002 and again between November 19 - 21, 2002. One dosimeter was picked at random from the box of available dosimeters. This was a DCA Model 622, Serial

40636. The Leak Test information for this dosimeter was located on the last page (page 8) of the November test data. However, the data entry apparently could be improved. This DCA Model 622 is recorded as a Victoreen; but also, although it appears to be a data entry error (the ditto marks were left off), there is no information included for this dosimeter.

This did not cause any exercise problem since this particular dosimeter was not actually issued. In addition, data entries for the dosimeters actually issued (#40835, #60572, #60859, #60670, #60423) are all complete.

f. PRIOR ARCAs - UNRESOLVED: None 37

2. Risk Jurisdictions 2.1 Cumberland County 2.1.1 Cumberland County Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 5.b.1 Issue No.: 64-99-11-A-05 (5.b.1)

Description:

FEMA guidance on use of the new Emergency Alert System (EAS) for emergency public information stipulates that more detailed Special News Broadcasts should follow the brief initial messages. The two EAS messages issued by Dauphin County did not contain detailed information such as the conditions at the nuclear power plant, the emergency classification level (ECL), the name and position of the person authorizing the release of the information, the protective action recommendation (PAR), and the potential for a radiological release. The Dauphin County EOP also does not contain instructions regarding the detailed Special News Broadcasts. The EAS messages refer the listener to the detailed information provided in the emergency pages of the telephone directories. Because not all residents and transient populations have a telephone directory, some would not have access to protective action information. In addition, the emergency section of the phone directories does not provide specific information for transients. (NUREG-0654, E.5.

and E.7; G.3.a; G.4.c)

Corrective Action Demonstrated: Both EAS messages issued by the staff contained all of the FEMA requirements as reflected in the Federal Register Notice, Volume 66, Number 177, September 12, 2001.

38

Issue No.: 64-01-11-A-01 (5.b.1)

Description:

The Emergency Alert System (EAS) messages issued at the Site Area Emergency and the General Emergency did not include the current emergency conditions at the nuclear power plant with reference to both the potential for or actual release of radioactivity and the current emergency classification level. This is required by NUREG-0654, E.7 and FEMA guidance memo dated 02 February 1999.

In addition, the title of the official authorizing the release of the EAS message must be included. (NUREG-0654, E.5,7; G.3.a; G.4.c)

Corrective Action Demonstrated: Both EAS messages issued by the PIO staff contained all of the FEMA requirements as reflected in the Federal Register Notice, Volume 66, Number 177, September 12, 2001.

f. PRIOR ARCAs - UNRESOLVED: None 2.1.2 Monitoring/Decontamination, Reception, and Mass Care Center - Big Spring High School

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.1.3 Emergency Worker Monitoring/Decontamination Center - Lemoyne Fire Dept. #11

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

b. DEFICIENCY: None 39

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 6.a.1 Issue: 64-03-6.a.1-A-01

Description:

The Station Manager assumed that his procedures directed that only persons who alarmed the portal monitors, or were otherwise found to be contaminated, would be thyroid screened for radioiodine uptake. However, the procedure states (page 9, A (1)) In addition to the steps outlined for personnel monitoring, emergency workers are to be screened for thyroid gland uptake of radio-iodine. The extent of play also stated that screening would be done of all workers.

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

Corrective Action Demonstrated: When the first uncontaminated worker was not screened, the controller stopped play and performed an immediate correction.

The Station Manager agreed to implement the screening per the extent of play agreement. The screening was redemonstrated successfully on the uncontaminated worker. The manufacturer of the portal monitor has informed Cumberland County that the sensitivity of the portal monitor permits a thyroid uptake to be identified in the absence of external contamination.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.1.4 New Cumberland Borough Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None 40

f. PRIOR ARCAs - UNRESOLVED: None 2.1.4.1 New Cumberland Route Alerting

a. MET: 1.d.1 3.a.1 3.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 2.1.5 Newville Community EMS - Carlisle Regional Medical Center

a. MET: None

b. DEFICIENCY: None

d. AREAS REQUIRING CORRECTIVE ACTION: Criterion 1.b.1, 3.a.1, 6.d.1 Issue 64-03-1.b.1-A-02

Description:

Procedural steps, as listed in the Carlisle Regional Medical Center (CRMC) Safety Manual Policy and Procedures for Radiation Safety that describe the setup of contaminated patient reception, monitoring, and decontamination areas were not followed. Also the setup and use of a new decontamination tent is not identified in the procedure and the storage location for equipment and material has been changed without changing the procedure. Training had not been conducted in setting up and using the new decontamination equipment. Setup and use of this unlighted tent after dark adversely affected monitoring and decontamination activities. The tent is not insulated for use in freezing weather conditions; nor is their response during inclement weather addressed in the procedures. The Dosimetery Record Form used was different than the one attached to the procedure. (NUREG-0654, F.2; H.10; K.5.a,b;L.1;L.4) 41

Recommendation: Evaluate the use of new equipment and locations. Change procedures to reflect the use of new locations, forms, and equipment. Add descriptive setup drawings to procedures for all new locations and equipment.

Provide hands on training in the setup and use of equipment and decontamination areas.

Schedule of Corrective Actions: Procedures will be reviewed and rewritten, if necessary, to ensure they are up to date concerning new equipment and procedures and forms. Personnel will be retrained to ensure they are competent in the use of new equipment and procedures.

Issue 64-03-6.d.1-A-03

Description:

Step-off pads, for emergency workers were not installed at exit points between clean and contaminated areas and a visual aid detailing exit procedures was not available. (NUREG-0654, F.2; H.10; K.5.a,b;L.1;L.4)

Recommendation: Review / Rewrite procedures to include the use of step-off pads. Develop visual aids to allow emergency responders to follow correct exit procedures.

Schedule of Corrective Actions: Procedures will be reviewed and rewritten to include the use of step-off pads or other methods to prevent the spread of contamination. Visual aids detailing exit procedures have been provided to the hospital.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2 Dauphin County 2.2.1 Dauphin County Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.b.1 2.c.1 3.b.1 1.c.1 3.c.1 1.d.1 3.c.2 1.e.1 42

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 5.b.1 Issue 64-03-5.b.1-A-04

Description:

A News Release, issued at 5:34 PM, provided contradictory and misleading information regarding whether an Alert or a Site Area Emergency (SAE) Emergency Classification Level (ECL) had been declared. (NUREG-0654, E.5,7;G.3.a; G.4.c)

Recommendation: In future exercises, as during an actual event, News Releases should be reviewed and approved by another individual, independent of the PIO preparing them.

Schedule of Corrective Actions: While this may be a valid ARCA it should be annotated as corrected. The cited message was confusing because it was labeled as an Alert at the top of the message and as a Site Area Emergency at the bottom. However, a very similar message announcing an escalation to General Emergency (GE) was released later.

This GE message was correctly labeled as a General Emergency at both the top and bottom. If this does not meet the definition of a redemonstration nothing does. It is no different from exceeding the old 15-minute notification time limit at Alert but later meeting the 15-minute time limit at Site Area Emergency. The latter demonstration always corrected the earlier failure. This mislabeling should be treated the same way. It would be ridiculous to wait for 2-years in order to correct the same ECL message. Corrective action has already been demonstrated with the release of the GE message.

FEMA Response: The conditions of this issue were a contributing factor resulting in the Deficiency issued against Dauphin County in the May 2001 REP Exercise. This Deficiency was subsequently redemonstrated correctly in January 2003. However in their May 2003 exercise the news release issued at 5:34 again contained incorrect information by not correctly stating the current ECL. Although the inaccurate and contradictory information that was issued in the 5:34 press release was later corrected at a 6:55 PM media briefing the problem of inaccurate and contradictory press releases still continues. A procedure needs to be put into place to insure a thorough review of press releases is conducted prior to dissemination. This ARCA remains.

d. NOT DEMONSTRATED: None 43

e. PRIOR ARCAs - RESOLVED: Criterion 3.b.1, 5.b.1

f. Issue No.: 64-01-11/12/14-D-02 (3.b.1; 5.b.1)

Description:

The initial prescripted EAS notification message released by the Dauphin County Emergency Operations Center (EOC) omitted information on the nuclear power plant conditions, the emergency classification level (ECL), the position of the person authorizing the release of the information, and the potential for a radiological release, as required by the FEMA policy letter dated February 2, 1999. The news release for the General Emergency declaration did not distinguish whether it was a drill or not, nor did it distinguish whether the evacuation was recommended or ordered by the Governor. It also did not include the precautionary message to shelter animals. This is the second consecutive exercise in which this problem has occurred. (NUREG-0654, E.7, E.,

E.5.7)

Corrective Action Demonstrated: On January 14, 2003, FEMA evaluated the Dauphin County Emergency Operations Center (EOC) to satisfy the requirement to re-demonstrate Objectives 11 and 14. Objective 11, Public Instructions and Emergency Information, and Objective 14, Implementation of Protective Actions- Use of KI for Emergency Workers, Institutionalized Individuals and the General Public were satisfactorily demonstrated. This resulted in objective 12 being carried to the next REP Exercise as an Area Requiring Corrective Action (ARCA).

On April 22, 2003, during a full-scale exercise, this prior issue, objective 12 was corrected. During a media briefing at 6:55 PM, the Chief of Staff/Chief Clerk of the Board of Commissioners provided the accurate information on the initial EAS notification including the status of radiological conditions, the possibility of corrective actions, and identified trends by the rumor control staff.

f. PRIOR ARCAs - UNRESOLVED: None 2.2.2 Reception Center - Williams Valley High School

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None 44

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.3 Monitoring/Decontamination and Mass Care Center - Upper Dauphin High School

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 6.a.1 Issue No.: 64-95-18-A-12 (6.a.1)

Description:

The first person registered was not screened to make sure that he had been monitored for contamination. Procedures need to be established between monitoring/ decontamination teams, security personnel, and the American Red Cross (ARC) to eliminate the possibility of contaminated individuals entering the mass care facility. Mass care staff must be trained to review documentation that will identify each evacuee's status regarding monitoring and decontamination before registering that person. (Objective 18; NUREG-0654, J.12.)

Corrective Action Demonstrated: Evacuees wishing to register at the Upper Dauphin High School Mass Care Center must present to the Registrar a completed Monitoring/Decontamination Report Form. If no contamination is found, the First Monitoring box must be annotated as passed. If contamination is detected, the Second Monitoring After Decontamination or Third Monitoring After Decontamination box must be annotated passed.

f. PRIOR ARCAs - UNRESOLVED: None 2.2.4 Emergency Worker Monitoring/Decontamination Center - Harrisburg Area Community College

a. MET: 1.e.1 3.a.1 6.a.1 45

3.b.1 6.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 2.2.5 Conewago Township Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.6 Londonderry Township Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 46

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.6.1 Londonderry Route Alerting

a. MET: 1.d.1 3.a.1 3.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 2.2.7 Lower Paxton Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.8 Highspire Borough Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.b.1 2.c.1 3.b.1 1.c.1 3.c.1 1.d.1 3.d.1 1.e.1 3.d.2 47

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3 Lancaster County 2.3.1 Lancaster County Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.2 Reception Center - Park City Mall

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 48

2.3.3 Monitoring/Decontamination and Mass Care Center - Mannheim Township High School Complex

a. MET: 1.b.1 3.a.1 6.a.1 6.c.1

b. DEFICIENCY: None

b. AREAS REQUIRING CORRECTIVE ACTION: Criterion 1.e.1 c.

Issue: 64-03-1.e.1-A-05

Description:

The CDV 700 survey meters used by the Lancaster County Hazmat Team #29 personnel for monitoring of vehicles, did not have calibration stickers indicating the most recent calibration, nor was there any other evidence of calibration of these instruments at the facility. (NUREG-0654, H.7,10;J.10.a,b,e; J.11;K.3.a)

Recommendation: Only instruments with current calibrations be used for monitoring and that the calibration date and any correction factors to be applied be displayed on the instruments.

Schedule of Corrective Actions: It appears that this issue would more accurately be categorized as a planning issue. Proper amounts of equipment with current calibration dates was available at the demonstration, but past due meters were pulled off of the response vehicle. This was an oversight on the part of the responders. The proper use of the equipment was never an issue. The responders met all other criteria. Lack of a calibration sticker was the only shortcoming.

Properly calibrated meters were available on the same truck. The users simply grabbed the wrong meters. This issue can easily be disproved through a staff assistance visit or copies of the paperwork showing when the meters were last calibrated. The only other option will be to wait another 6-years until this facility is scheduled to be evaluated again. Lancaster County is working with the utility to bring all necessary equipment (not just REP) into current calibration.

FEMA Response: In accordance with the Extent of Play, CDV-700 survey instruments are to be calibrated every 4 years in Pennsylvania and a label indicating such calibration should be on each instrument. The fact that the instruments used by the monitoring/Decon team did not have labels is an issue.

Since this was a Federally scheduled and evaluated exercise these instruments should have been checked and not made part of the available equipment inventory to be used as observed by the evaluator. The ARCA remains.

49

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.4 Emergency Worker Monitoring/Decontamination Center - Mount Joy Fire Department

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 6.b.1 Issue No.: 64-99-22-A-22 (6.b.1)

Description:

Personnel at the Lancaster County monitoring/decontamination station (Mt. Joy Fire Department) did not demonstrate adequate procedures to prevent cross-contamination.

Monitoring personnel walked completely around an individual, rather than asking the individual to turn around on the monitoring pad, which may have caused the monitor to walk into a potentially contaminated area. Also, after workers were monitored, the area designated for clean and contaminated individuals was not clearly marked and communicated to the individuals (NUREG-0654, K.5.b.)

Corrective Action Demonstrated: Monitors utilized good contamination control practices while conducting contamination surveys of emergency workers. The process used was consistent with the Radiological Monitoring and Decontamination Station, Enclosure 2, Procedures for Radiological Monitoring Teams. The recorder/procedure reader provided direction to the monitor to prepare for and conduct monitoring by reading this procedure.

Traffic flow patterns were established within the facility such that contaminated persons and those to be monitored would not mix with uncontaminated persons that had already been monitored.

50

f. PRIOR ARCAs - UNRESOLVED: None 2.3.5 Mount Joy Township Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 1.c.1, 3.b.1 Issue No.: 64-99-03/14-A-23 (1.c.1; 3.b.1)

Description:

The Communications Officer failed to inform the EMC of two important messages from the Lancaster EMA: (1) to shelter animals and place them on stored feed, and (2) the Secretary of Healths recommendation for emergency workers to take KI. In addition, the Radiological Officer did not inform the emergency workers to take KI.

(NUREG-0654, A.2.a., and J.10.f.)

Corrective Action Demonstrated: The Communications Officer logged messages that were received from the Lancaster County EMA and communicated them to the EMC.

At 7:01 PM the Communications Officer in the EOC received the recommendation from Lancaster County EOC to place farm animals within the 10-mile emergency planning zone on stored feed and water.

The message was communicated to the EMC.

At 8:20 PM the Communications Officer received the recommendation of the Secretary of the Pennsylvania Department of Health for emergency workers to take KI. The message was communicated to the EMC and at 8:22 PM instructions to Traffic Control Point officers to ingest KI.

51

g. PRIOR ARCAs - UNRESOLVED: None 2.3.6 Elizabethtown Borough/West Donegal Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 3.a.1 Issue: 64-03-3.a.1-A-06

Description:

The Radiological Officer (RadOff) did not brief staff about or simulate issuance of dosimetery and potassium iodide (KI) to Emergency Operations Center (EOC) staff in accordance with the Standard Operating Procedures (SOP). The SOP requires that the RadOff brief the EOC staff at the Emergency Classification Level (ECL) Site Area Emergency and issue the dosimetery and KI at that time. Dosimetery and KI are required for the EOC staff since the EOC is located in the Emergency Planning Zone (EPZ) 10-mile radius from the Three Mile Island (TMI) nuclear plant. (NUREG-0654, K.3.a,b)

Recommendation: It is recommended that the Radiological Officer and the EOC staff follow their plan.

Schedule of Corrective Actions: The Radiological Officer will receive additional training and the radiological briefing to the EOC staff will be demonstrated the next time this facility is evaluated.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 52

2.3.6.1 Elizabethtown Route Alerting

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 3.a.1, 3.b.1 Issue No.: 64-97-05/14-A-10 (3.a.1, 3.b.1)

Description:

The route alerting team did not have written procedures or proper instructions for using dosimetery and KI. They did not know to read dosimetery every 30 minutes, were not aware of radiation exposure limits, and did not know who to ask to obtain authorization to exceed exposure limits. (NUREG-0654, J.10.e., J.10.f., K.3.a., K.3.b., and K.4.)

Corrective Action Demonstrated: All Route Alert Teams viewed the video of the radiological dosimetery and potassium iodide (KI) briefing prior to being dispatched. Route Alert Teams were familiar with dosimetery reading and ingestion of KI, as well as related documentation.

Route Alert Teams could explain the procedures for exceeding exposure limits.

f. PRIOR ARCAs - UNRESOLVED: None 2.4 Lebanon County 2.4.1 Lebanon County Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None 53

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 5.b.1 Issue No.: 64-99-11-A-24 (5.b.1)

Description:

The Lebanon County EOP on page E-4-2 states: The Lebanon County PIO, with the assistance of PEMA, will prepare and update prepared statements for broadcast over the EAS in the event of an emergency. Further, the Plan, on page E-4-2, states: When the emergency situation makes it prudent to alert the public, the Lebanon County Commissioners, assisted by EMC and County PIO, may commence issuing public information statements . . .

Two A&N sequences were conducted by the Lebanon County EOC, one each at the Site Area Emergency (SAE) (broadcast at 1803) and the other at the GE (broadcast at 1950); both followed by media advisories faxed to local media outlets. The messages the EAS stations were instructed to broadcast were, in fact, PEMA worksheets rather than the actual prescripted messages included in the EOP and so were missing key facts needed by the public.

Specifically, the EAS message broadcast at 1950, the media advisory issued at 2000, and the follow-up press briefing at 2024 all lacked required evacuation information, including:

The evacuation routes to the mass care facility Information for transportation-dependent individuals (a bus pickup point was arranged in South Londonderry Township) What evacuees should take and leave behind. Information for transients The EOCs rumor control telephone number for more information Guidance on referring to the emergency pages of the telephone directory for detailed information.

In addition, the EAS message notifying farmers to shelter animals and protect feed and water supplies was not issued by the Lebanon County EOC as required by the Lebanon County Plan. At 1900, the Pennsylvania Department of Agriculture issued an advisory (News Release #6) Farmers Advised to Shelter Animals and Protect Feed and Water Supplies. The Lebanon County Plan, on page E-15-22, states, EAS will broadcast the Pennsylvania Department of Agriculture advisories and guidance through EAS channels in coordination with BRP and PEMA. No prescripted agricultural advisory is included in the Plan and none was prepared and provided to the EAS station.

54

Finally, EAS messages were not faxed to the Joint Information Center and to the CENIC, as required by the Plan on page E-4-3 and the extent-of-play agreement. (NUREG-0654, E.5, E.6, E.7, G.4.a, and N.1.a.)

Corrective Action Demonstrated: Lebanon County Public Information Officer held a Press Briefing that included required resident evacuation information. Copies of the briefing were faxed to PEMA (CENIC) and TMI (JIC).

f. PRIOR ARCAs - UNRESOLVED: None 2.4.2 Monitoring/Decontamination and Reception Center - Lebanon Vo-Tech

a. MET: 1.e.1 3.a.1 6.a.1 6.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 2.4.3 Mass Care Center - Eastern Lebanon City High School Complex

a. MET: 1.b.1 6.c.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 6.a.1 Issue No.: 64-99-18-A-26 (6.a.1)

Description:

The monitoring area at the Eastern Lebanon County Middle School was out-of-doors, which may prevent radiological monitoring operations during inclement weather. In addition, it was not demonstrated 55

that more than one monitoring station could be set up (six would be needed); a second monitoring station was set up in an aisle that served as a pathway to decontamination areas for contaminated individuals. There was not sufficient space for even two monitoring stations to operate.

(NUREG-0654, J.12).

Corrective Action Demonstrated: With the successful demonstration of Monitoring/Decontamination at the Lebanon Vo-Tech Reception Center, Eastern Lebanon City High School Complex will no longer be used as a Monitoring / Decontamination or Reception Center. It will only be a Mass Care Center. Criterion 6.a.1 Monitoring and Decontamination of Evacuation and Emergency Workers and Registration of Evacuees, will not be evaluated at the Eastern Lebanon City High School Complex and therefore this prior ARCA is administratively corrected.

Issue No.: 64-99-18-A-29 (6.a.1)

Description:

Insufficient space was available at the Lebanon County monitoring/ decontamination center at Eastern Lebanon High School for initial monitoring of evacuees. (NUREG-0654, J.12.)

Corrective Action Demonstrated: With the successful demonstration of Monitoring/Decontamination at the Lebanon Vo-Tech Reception Center, Eastern Lebanon City High School Complex will no longer be used as a Monitoring / Decontamination or Reception Center. It will only be a Mass Care Center. Criterion 6.a.1 Monitoring and Decontamination of Evacuation and Emergency Workers and Registration of Evacuees, will not be evaluated at the Eastern Lebanon City High School Complex and therefore this prior ARCA is administratively corrected.

Issue No.: 64-99-18-A-30 (6.a.1)

Description:

Only one shower station is available for decontamination at the Lebanon County monitoring/decontamination center at Eastern Lebanon High School, where 1,775 evacuees were expected to arrive. No signs were available for rotation of different genders through the showers.

(NUREG-0654, J.12.)

Corrective Action Demonstrated: With the successful demonstration of Monitoring/Decontamination at the Lebanon Vo-Tech Reception Center, Eastern Lebanon City High School Complex will no longer be used as a Monitoring / Decontamination or Reception Center. It will only be a Mass 56

Care Center. Criterion 6.a.1 Monitoring and Decontamination of Evacuation and Emergency Workers and Registration of Evacuees, will not be evaluated at the Eastern Lebanon City High School Complex and therefore this prior ARCA is administratively corrected.

g. PRIOR ARCAs - UNRESOLVED: None 2.4.4 Emergency Worker Monitoring/Decontamination Center - Annville Union Hose Fire House

a. MET: 1.e.1 3.a.1 6.a.1 3.b.1 6.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 2.4.5 South Londonderry Township Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.4.5.1 South Londonderry Township Route Alerting 57

a. MET: 1.d.1 3.a.1 3.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 2.5 York County 2.5.1 York County Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.5.2 Monitoring/Decontamination, Reception, and Mass Care Center - Red Lion Jr.

High School Complex

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 58

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.5.3 Emergency Worker Monitoring/Decontamination Center - Springettsbury Fire Department

a. MET: 1.e.1 3.a.1 6.a.1 3.b.1 6.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 2.5.4 Conewago Township Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 3.a.1 Issue: 64-03-3.a.1-A-07

Description:

The Radiological Protection Officer did not have a master record of Dosimeters and potassium iodide (KI) issued to the emergency workers. The Radiological Protection Officer did not complete the master record of equipment distribution called the Acknowledgement of Receipt by Emergency Workers for Dosimetery-KI and Survey Meters (Attachment I-8 of the Conewago Emergency Operations Plan).(NUREG-0654, K.3.a, b)

Corrective Action Demonstrated: At the end of the exercise, the Radiological Protection Officer and emergency workers correctly completed the Acknowledgement of Receipt form.

59

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.5.5 Fairview Township Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.5.5.1 Fairview Township Route Alerting

a. MET: 1.d.1 3.a.1 3.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 2.5.6 Goldsboro Borough Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.b.1 2.c.1 3.b.1 60

1.c.1 3.c.1 1.d.1 3.d.1 1.e.1 3.d.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.5.7 Hellam Township Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.5.8 Springettsbury Township Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None 61

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.5.9 Warrington Township/Wellsville Borough Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.5.10 York Haven Borough Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 62

3. Support Counties 3.1 Adams County 3.1.1 Adams County Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 3.1.2 Monitoring/Decontamination, Reception, and Mass Care Center - New Oxford Middle School

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 6.a.1 Issue: 64-03-6.a.1-A-08

Description:

Personnel changed the alarm setpoint for contamination on the Bicron portal monitor. A person is considered contaminated if there is a reading of 18,000 counts/second (cps) using the Bicron TPM-903 portal monitor. This action limit was derived from the 300 counts/minute (cpm) contamination threshold utilized for monitoring with a CDV-700 (300cpm x 60 seconds/minute = 18000 cps). The contamination limit may be too high and should not be calculated using this method due to the differences in detector efficiency and sensitivity. (NUREG-J.10.h; J.12; K.5.a) 63

Recommendation: Consult with a technical representative to determine what the correct limit should be based on the CDV-300 limit.

Revise the procedure to incorporate the correct limit.

Schedule of Corrective Actions: Response personnel will be trained to not change the factory alarm setting in the future.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

h. PRIOR ARCAs - UNRESOLVED: None 3.2 Franklin County 3.2.1 Franklin County Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 3.2.2 Monitoring/Decontamination, Reception, and Mass Care Center - Scotland School

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

b. DEFICIENCY: None 64

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 6.a.1 Issue: 64-03-6.a.1-A-09

Description:

The Reception Center was not set-up in accordance with the extent of play agreement and/or the Franklin County Plan, (Appendix 3 Reception Center Operations), for demonstration of the facilities capabilities. The extent of Play from PEMA readsSet-up of the facility will be performed the same as for an actual emergency with all route markings and contamination control measures in place including step-off pads, with the exception of long runs of plastic covered with paper which will not be demonstrated In order for this facility to become operational in accordance with the Plan and the extent of play agreement prior to evacuees arriving, the following steps should be performed (not all inclusive): vehicle and people traffic flow patterns should be established in order to ensure that the spread of contamination can be controlled utilizing such items as cones, stanchions, rope, tape, plastic sheeting, rolls of paper, and step-off pads etc; receptacles for contaminated waste should be available; and an area to separate contaminated from non-contaminated individuals should be established; and evacuee processing should be controlled when each individual is moving from one stop-point to another.

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

Recommendation: The Reception Center must be set up in accordance with the County Plan and the agreeded upon Extent of Play document, i.e.,

vehicle and people traffic flow patterns, i.e., cones, stanchions, rope, tape, plastic sheeting, rolls of paper, and step-off pads, receptacles for contaminated waste, etc., separation of contaminated and non-contaminated individuals, personal and vehicle monitoring, shower/clean up, re-monitoring, registration of evacuees, etc.

Schedule of Corrective Actions: Response personnel and managers will be trained to ensure the reception/monitoring/decontamination centers are set-up IAW the plan and extent of play for future exercises. This criterion will be re-tested the next time this facility is scheduled to play.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 65

3.2.3 Monitoring/Decontamination and Mass Care Center - Faust Jr. High School

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Criterion 6.a.1 Issue No.: 64-99-18-A-46 (6.a.1)

Description:

Six trained radiological monitors (three teams) were present to operate the monitoring instruments at the Franklin County monitoring and decontamination center at Faust Junior High School. The extent-of-play agreement stated that four teams would participate. (NUREG-0654, N.1.a.)

Corrective Action Demonstrated: This issue was transferred to Scotland Veteran School from the Faust Junior High School because radiological monitoring is performed only at the Scotland Veteran School Reception Center/Mass Care Center. There were five (5) monitoring teams stationed at the Scotland School, which is a sufficient number of monitoring teams for this facility.

Issue No.: 64-99-18-A-47 (6.a.1)

Description:

During monitoring activities conducted at the Franklin County monitoring and decontamination center at Faust Junior High School, the individual conducting radiological monitoring moved around the evacuee being monitored instead of having the evacuee turn around.

This approach could result in the monitor stepping into a contaminated area and becoming contaminated. (NUREG-0654, J.12.)

Corrective Action Demonstrated: This issue was transferred to Scotland Veteran School from the Faust Junior High School because radiological monitoring is performed only at the Scotland Veteran School Reception Center/Mass Care Center. The monitoring team member performing the survey remained in one place and had the individual being monitored turn 180 degrees to complete the survey.

66

f. PRIOR ARCAs - UNRESOLVED: None 3.3 Schuylkill County 3.3.1 Schuylkill County Emergency Operations Center

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 5.b.1 Issue: 64-03-5.b.1-A-10

Description:

Rumor Control personnel gave out incorrect information to a caller who requested information on where to pick up KI pills. The current State/County policy is for pills (KI) to be distributed only to emergency workers and not to the general public. The Rumor Control representative responded by advising the caller that he should not panic since he and his neighbors were not located in the 10-mile emergency-planning zone. He was also advised that if circumstances warranted the distribution of pills (KI) that he would be informed of where and how to pick up his pills and that he should listen to the radio for additional information. (NUREG-0654 E.5, 7; G.3.a, G.4.c)

Corrective Action Demonstrated: The Emergency Management Coordinator (EMC) was advised of the call received in Rumor Control and the answer that the staff member provided to the caller. This criterion was correctly re-demonstrated when the EMC briefed the emergency operations center staff advising them that the current State/County policy is for pills (KI) to be distributed only to emergency workers and not to the general public.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 3.3.2 Monitoring/Decontamination, Reception, and Mass Care Center - Blue Mountain High School 67

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

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 68

4. School Districts 4.1 Cumberland County 4.1.1 West Shore School District - Hillside Elementary School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2 Dauphin County 4.2.1 Central Dauphin School District - Tri-Community Elementary School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2.2 Derry Township School District - Hershey Elementary School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 3.c.2 Issue: 64-03-3.c.2-A-11 69

Description:

The School District secretary was unfamiliar with the procedure for authenticating calls regarding events at Three Mile Island Nuclear Generating Station. The District Secretary (DS) received a call from the Dauphin County EMA at 9:20 AM. This call stated that Three Mile Island Generating Station (TMI) had declared an Alert, gave wind speed and direction and stated that no release was in progress.

Upon receipt of the call the DS notified the Incident Response Team Coordinator (IRTC) at 9:23 AM. It was noted that the District Secretary did not authenticate the message as required in the School District Plan. When questioned about how to verify the call, the DS referred to the Plan and noted that the DCEMA should be called to verify all messages. (NUREG-0654 J.10.c, d, g)

Corrective Action Demonstrated: A re-demonstration of the verification of the message was requested and performed by the DS satisfactorily at 9:29AM.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2.3 Harrisburg School District - Foose Elementary School

a. MET: None

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: Criterion 3.c.2 Issue: 64-03-3.c.2-A-12

Description:

Parents of children attending schools in the Harrisburg School District have not been informed of the plan or provided information as to where to pick up their children if they are sheltered or evacuated. (NUREG-0654 J.10.c, d, g)

Recommendation: Send the letter to parents informing them of the actions to be taken in the event of an incident at Three Mile Island Nuclear Generating Station (Appendix 4). Revise the plan to require coordination with the Dauphin County Emergency Operations Center for information to be released to the media regarding protective actions taken for school children during this type of incident.

70

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2.4 Lower Dauphin School District - Londonderry Elementary School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2.5 Middletown Area School District - Feaser Middle School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2.6 Milton Hershey School District - Milton Hershey School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 71

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2.7 Steelton-Highspire School District - Steelton-Highspire High School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.3 Lancaster County 4.3.1 Donegal School District - Maytown Elementary School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.3.2 Elizabethtown Area School District - East High St. Elementary School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 72

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.4 Lebanon County 4.4.1 Palmyra Area School District - Palmyra High School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.5 York County 4.5.1.1 Central York School District - Sinking Springs Elementary School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.5.1.2 Central York School District - Central Middle School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None 73

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.5.2.1 Northeastern School District - Northeastern High School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.5.2.2 Northeastern School District - Orendorf Elementary School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.5.3 Dover Area School District - Dover Area High School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 74

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.5.4 Eastern School District - Eastern High School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 75

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

A&N Alert and Notification AAC Accident Assessment Center ACP Access Control Point ALARA As Low As Reasonably Achievable ARC American Red Cross ARCA Area Requiring Corrective Action ARES Amateur Radio Emergency Service ATL Alternate Team Leader BOR Borough BRP Bureau of Radiation Protection CFR Code of Federal Regulations cpm Counts per Minute CRD Control rod drive DEP Department of Environmental Protection DRD Direct-Reading Dosimeter EAL Emergency Action Level EAS Emergency Alert System EBS Emergency Broadcast System ECL Emergency Classification Level EMA Emergency Management Agency EMC Emergency Management Coordinator ENC Emergency News Center EOC Emergency Operations Center EOF Emergency Operations Facility EOP Emergency Operating Plan EPA U.S. Environmental Protection Agency EPLO Emergency Preparedness Liaison Officer EPZ Emergency Planning Zone EW Emergency Worker EWM/DS Emergency Worker Monitoring/Decontamination Station FAA Federal Aviation Administration FEMA Federal Emergency Management Agency FMT Field Monitoring Team FNF Fixed nuclear facility 76

FR Federal Register FRERP Federal Radiological Emergency Response Plan FTC Field Team Coordinator GE General Emergency HPSW High-pressure service water ICF ICF Consulting IP Implementing Procedure IPZ Ingestion Pathway Zone KI Potassium iodide LOCA Loss of coolant accident MDE Maryland Department of the Environment MEMA Maryland Emergency Management Agency Mon/Decon Monitoring/Decontamination mR milliroentgen(s) mR/h milliroentgen(s) per hour MSIV Main stream isolation valve MSL Mean sea level MW Megawatt NERO Nuclear Emergency Response Organization NRC U.S. Nuclear Regulatory Commission NUREG-0654 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 ORO Offsite Response Organization OSC Operations Support Center PAD Protective Action Decision PAG Protective Action Guidelines PAR Protective Action Recommendation PBAPS Peach Bottom Atomic Power Station PEMA Pennsylvania Emergency Management Agency PIO Public Information Officer PSP Pennsylvania State Police R Roentgen(s)

RAC Regional Assistance Committee 77

RACES Radio Amateur Civil Emergency Service RCIC Reactor core isolation cooling REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan R/h Roentgen(s) per hour RHP Radiation Health Protection RO Radiological Officer RPO Radiological Protection Officer RPS Reactor protection system RPV Reactor pressure vessel RSO Radiological Services Officer SAE Site Area Emergency SEOC State Emergency Operations Center SOP Standard Operating Procedure(s)

SRD Self-Reading Dosimeter SRTF State Response Task Force TCP Traffic Control Point TL Team Leader TLD Thermoluminescent Dosimeter TSC Technical Support Center TWP Township 78

APPENDIX 2 EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel who evaluated the Three Mile Island Power Station exercise on April 22, 2003. Evaluator Team Leaders are indicated by (TL) after their organizations name. Alternate Evaluator Team Leaders are indicated by (ATL) after their organizations name. The organization that each evaluator represents is indicated by the following abbreviations:

EPA Environmental Protection Agency FAA Federal Aviation Administration FEMA Federal Emergency Management Agency NRC U.S. Nuclear Regulatory Commission ICF ICF Consulting, Inc.

Evaluation Site Evaluator Organization COMMONWEALTH OF PENNSYLVANIA Pennsylvania EOC Al Henryson FEMA (TL)

Cedric Cherry FEMA William Edmonson ICF Seth Kelly ICF Emergency News Center (EOF Carl Bebrich FEMA Coatesville)

Emergency News Center (Harrisburg) Al Lookabaugh ICF Accident Assessment Center Sheri Minnick EPA Melody Geer ICF Accident Assessment Center (EOF Robert Bores NRC Coatesville)

State Traffic/Access Control Points (Risk David Duncan ICF Counties) Jon Fox ICF RISK JURISDICTIONS Cumberland County Cumberland County EOC Larry Robertson FEMA (TL)

Ernest Boaze ICF (ATL)

Laura Moore ICF David Moffett ICF Monitoring/Decontamination, Mass Care, Tom Deaner ICF and Reception Center*

Emergency Worker Rowena Argall ICF

Evaluated out-of-sequence on April 23, 2003.

79

Evaluation Site Evaluator Organization Monitoring/Decontamination Center*

New Cumberland Borough EOC Jerry Staroba ICF New Cumberland Route Alerting Linda Ploener FEMA Dauphin County Dauphin County EOC John Price FEMA (TL)

Tom Reynolds FEMA (ATL)

David Gilder FEMA Roger Kowieski ICF Reception Center* Rod Arpin ICF Monitoring/Decontamination and Mass Frank Bold ICF Care Center*

Emergency Worker Walter Gawlak ICF Monitoring/Decontamination Center*

Conewago Township EOC Helen Wilgus FEMA Londonderry Township EOC Henry Christiansen ICF Londonderry Route Alerting Landton Malone FEMA Lower Paxton Township EOC John Barrett ICF Highspire Borough EOC Harold Spedding ICF Lancaster County Lancaster County EOC Yvette Porter FEMA (TL)

Roy Smith ICF (ATL)

Richard Marks ICF P.J. Nied ICF Reception Center* David Duncan ICF Monitoring/Decontamination and Mass Jim Hickey ICF Care Center*

Emergency Worker W.B. McRee ICF Monitoring/Decontamination Center*

Mount Joy Township EOC Tracey Green ICF Elizabethtown Borough/West Donegal Bob Fernandez ICF Township EOC Elizabethown Borough Route Alerting Bart Freeman FEMA Lebanon County Lebanon County EOC Roman Helo FEMA (TL)

Pat Tenorio FEMA (ATL)

Charles Richey ICF Bob Bradshaw ICF Monitoring/Decontamination and Jim McClanahan ICF Reception Center*

Evaluated out-of-sequence on April 23, 2003.

80

Evaluation Site Evaluator Organization Mass Care Center* Robert Noecker ICF Emergency Worker Stan Maingi ICF Monitoring/Decontamination Center*

South Londonderry Township EOC Ronald Van ICF South Londonderry Township Route Robert Noecker ICF Alerting York County York County EOC Angela Hough FEMA (TL)

Ken Wierman FEMA (ATL)

Chris Thompson FAA Rosemary Samsel ICF Monitoring/Decontamination, Mass Care, Carol Herzenberg ICF and Reception Center*

Emergency Worker Deborah Blunt ICF Monitoring/Decontamination Center*

Conewago Township EOC David Goldbloom-Helzner ICF Fairview Township EOC Lynn Mariano ICF Fairview Township Route Alerting Laurel Ryan FEMA Goldsboro Borough EOC Nancy Johnson ICF Hellam Township EOC Bob Black ICF Springettsbury Township EOC Robert Neisius ICF Warrington Township/Wellsville Borough David Schweller ICF EOC York Haven Borough EOC Quirino Iannazzo ICF SUPPORT COUNTIES Adams County Adams County EOC Eddie Fuente ICF Monitoring/Decontamination, Mass Care, Marcy Campbell ICF and Reception Center*

Franklin County Franklin County EOC George MacDonald ICF Monitoring/Decontamination, Mass Care, W. McCance ICF and Reception Center*

Monitoring/Decontamination and Mass David Stuenkel ICF Care Center*

Schuylkill County Schuyldill County EOC Gary Naskrent FEMA Monitoring/Decontamination, Mass Care, Keith Earnshaw ICF

Evaluated out-of-sequence on April 23, 2003.

81

Evaluation Site Evaluator Organization and Reception Center*

SCHOOL DISTRICTS Cumberland County West Shore School District Tom Deaner ICF Dauphin County Central Dauphin School District Bill Neidermeyer ICF Derry Township School District Rowena Argall ICF Harrisburg School District Marcy Campbell ICF Lower Dauphin School District Keith Earnshaw ICF Middletown Area School District Rod Arpin ICF Milton Hershey School District Walter Gawlak ICF Steelton-Highspire School District Frank Bold ICF Lancaster County Donegal School District Jim Hickey ICF Elizabethtown Area School District W.B. McRee ICF Lebanon County Palmyra Area School District Stan Maingi ICF York County Central York School District Deborah Blunt ICF Jim McClanahan ICF Northeastern School District William McCance ICF David Stuenkel ICF Dover Area School District John Flynn ICF Easter School District Carol Herzenberg ICF

Evaluated out-of-sequence on April 23, 2003.

82

APPENDIX 3 EXERCISE EVALUATION AREA CRITERIA AND EXTENT-OF-PLAY AGREEMENTS This appendix lists the exercise evaluation area criteria that were scheduled for demonstration in the Three Mile Island Nuclear Generating Station exercise on April 22-23, 2003, and the extent-of-play agreement approved by FEMA Region III on , February 26, 2003.

The exercise evaluation area criteria, contained in the FEMA Radiological Emergency Preparedness Exercise Evaluation Methodology, 67 FR 20580, April 25, 2002, represent a functional translation of the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980.

Because the exercise evaluation area criteria are intended for use at all nuclear power plant sites, and because of variations among offsite plans and procedures, an extent-of-play agreement is prepared by the State and approved by FEMA to provide evaluators with guidance on expected actual demonstration of the evaluation area criteria.

A. Exercise Evaluation Area Criteria Listed below are the specific radiological emergency preparedness (REP) evaluation area criteria scheduled for demonstration during this exercise.

B. Commonwealth of Pennsylvania Extent-of-Play Agreement The extent-of-play agreement on the following pages was submitted by the Commonwealth of Pennsylvania, and was approved by FEMA Region III on February 26, 2003, in preparation for the THREE MILE ISLAND NUCLEAR GENERATING STATION exercise on April 22-23, 2003. The extent-of-play agreement includes any significant modification or change in the level of demonstration of each exercise evaluation area criterion listed in Subsection A of this appendix.

83

THREE MILE ISLAND NUCLEAR GENERATING STATION 2003 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE Evaluation Area 1 Emergency Operations Management Sub-element 1.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.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)

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 appropriate, in accordance with the extent of play agreement, at those facilities located beyond a normal commuting distance from the individuals 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 OROs 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:

State agencies, risk and support counties, and risk municipalities will demonstrate call-outs. All out-of-sequence players and equipment will be pre-positioned.

Sub-element 1.b - Facilities INTENT 84

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

Criterion 1.b.1: Facilities are sufficient to support the emergency response. (NUREG-0654, 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.)

Facilities must be set up based on the OROs 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 Negotiated Extent of Play:

One-third of ORO facilities will be evaluated during this exercise in order to establish a baseline.

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.

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All activities associated with direction and control must be performed based on the OROs 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 Negotiated Extent of Play: None Sub-element 1.d - Communications Equipment INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response 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.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.

(NUREG-0654, F.1, 2)

EXTENT 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 and mobile medical support facilities 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 OROs plans and procedures and completed as they would be in an actual emergency, unless otherwise noted above or in the extent of play agreement.

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PEMA Negotiated Extent of Play: None Sub-element 1.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.1: Equipment, maps, displays, dosimetery, 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 OROs plans and/or procedures in support of emergency operations. Use of maps and displays is encouraged.

All instruments should be inspected, inventoried, and operationally checked before each use.

Instruments should be calibrated in accordance with the manufacturers recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturers 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 calibrated frequency can be verified by other means. Additionally, instruments being 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 dosimetery and dosimeter chargers should be available for issuance to all categories of emergency workers that could be deployed from that facility. Appropriate direct-reading dosimetery should allow individual(s) to read the administrative reporting limits and maximum exposure limits contained in the OROs plans and procedures.

Dosimetery 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.

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Responsible OROs should demonstrate the capability to maintain 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 dosimetery 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 OROs 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:

In Pennsylvania CDV-700s are calibrated every 4-years.

Leakage testing verification and KI extension letters will be available to the evaluator upon request.

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EVALUATION AREA 2 Protective Action Decision-Making 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 OROs 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 OROs plans and procedures.

Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

(NUREG-0654, 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 OROs 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 OROs 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.

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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 OROs plans and 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.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 onsite and offsite environmental conditions. (NUREG-0654, I.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 90

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 OROs 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.

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)

EXTENT OF PLAY OROs 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 OROs 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 OROs 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 91

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

Sub-element 2.c - Protective Action Decisions Consideration for the Protection of 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.10.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 were 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 pubic 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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All decision-making activities associated with protective actions, including consideration of available resources, for special population groups must be based on the OROs 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 Sub-element 2.d. - Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway This sub-element will not be evaluated during this exercise.

Sub-element 2.e. - Radiological Assessment and Decision-Making Concerning Relocation, Re-entry, and Return This sub-element will not be evaluated during this exercise.

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EVALUATION AREA 3 Protective Action Implementation Sub-element 3.a - Implementation of Emergency Worker Exposure Control 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 dosimetery and permanent record dosimetery; the reading of direct-reading dosimetery 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.1: The OROs issue appropriate dosimetery 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 OF PLAY OROs should demonstrate the capability to provide appropriate direct-reading and permanent record dosimetery, dosimeter chargers, and instructions on the use of dosimetery to emergency workers. For evaluation purposes, appropriate direct-reading dosimetery is defined as dosimetery 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 OROs 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 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 94

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 dosimetery.

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 OROs 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:

Radiological briefings will be provided to address exposure limits and procedures to replace those approaching limits and how permission to exceed limits is obtained from the municipality and county. Emergency workers will also be briefed on when to take KI and on whose authority.

Distribution of KI will be simulated. The completion of a KI report form will be demonstrated.

OROs should also demonstrate the use of all dosimetery forms to emergency workers.

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

In Pennsylvania, emergency workers outside of the EPZ do not have turnback values.

Emergency workers who are assigned to low exposure rate areas, e.g., at reception centers, counting laboratories, emergency operations centers, and communications centers, may have individual direct-reading dosimeters or they may be monitored by dosimeters strategically placed in the work area. In Pennsylvania this will be accomplished through the use of an area kit.

Standard issue of dosimetery and potassium iodide for each category of emergency worker is as follows:

Category A: 1 PRD, 1 DRD, and 1 unit of KI Category B: 1 PRD and 1 unit of KI 95

Category C: 1 PRD Sample kits will be pre-distributed to the municipalities for demonstration purposes. These sample kits will consist of 5-DRDs, charger, simulated PRDs and simulated KI, and instructions.

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 radioprotective 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 OROs plans and procedures. Provisions should include the availability of adequate quantities, storage, and means of the distribution of radioprotective drugs.

Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals is maintained. (NUREG-0654, J.10. e)

EXTENT OF PLAY 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 OROs 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.

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All activities must be based on the OROs 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:

Pennsylvania plans do not call for issuance of KI to the general public, only to Emergency Workers.

Evaluation of KI quantities will be verified using inventory sheets and no KI will be removed from the storage location. Boxes will not be opened. KI questions will be addressed through interviews.

Monitoring/decontamination centers and stations personnel are not issued DRDs/KI since the centers/stations are located outside the EPZ.

Sub-element 3.c - Implementation of Protective Actions for 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 OROs 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.

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All implementing activities associated with protective actions for special populations must be based on the OROs 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:

Lists of people with special needs are maintained at the municipal EOCs. Copies of these lists will not be provided to the evaluators however; evaluators will be able to inspect these lists during the exercise.

Initial contact with special populations and reception facilities will be actual (hospitals, nursing homes and correctional facilities). All subsequent calls will be simulated.

Actual contacts (up to two) will be made with transportation providers as per plan. All actual and simulated contacts should be logged.

Criterion 3.c.2: OROs/School officials implement protective actions for schools. (NUREG-0654, J.10.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 drivers 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 OROs plans and procedures as negotiated in the Extent of Play Agreement.

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All activities must be based on the OROs 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:

Evacuation of students will be conducted through an interview process.

Role of the bus driver may be conducted through an interview with school or transportation officials if a bus driver is not available. Actual demonstration of the bus route is not required and will not be demonstrated.

Risk County school plans do not require communications between the school and vehicles.

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

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.1: Appropriate traffic and access control is established.

Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.g, j)

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.

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In instances where OROs lack authority necessary to control access by certain types of traffic (rail, water, and air traffic), they should demonstrate the capability to contact the State or Federal agencies with authority to control access.

All activities must be based on the OROs 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:

Traffic and access control will be demonstrated by interview - no deployment. A radiological briefing will be provided.

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 OROs 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:

Upon request municipal and county staffs will be prepared to brief the evaluator on actions to be taken should there be an impediment to evacuation on a designated route.

Sub-element 3.e - Implementation of Ingestion Pathway Decisions This sub-element will not be evaluated during this exercise.

Sub-element 3.f - Implementation of Relocation, Re-entry, and Return Decisions This sub-element will not be evaluated during this exercise.

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EVALUATION AREA 4 Field Measurement And Analysis Sub-element 4.a - Plume Phase Field Measurements 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 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.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; I.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 OROs 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 OROs 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:

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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; I.8., 11; J.10.a).

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 OROs 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 OROs 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:

Field Team control is expected to initially be out of sequence with the plume timeline.

During the exercise the field teams will be directed to take measurements in locations to provide information sufficient to characterize the plume and impacts.

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Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654, 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 OROs 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 evaluated during this exercise.

Sub-element 4.b - Post Plume Phase Field Measurements and Sampling This sub-element will not be evaluated during this exercise.

Sub-element 4.c - Laboratory Operations This sub-element will not be evaluated during this exercise.

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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.IV.D.), and FEMA-REP-10, "Guide for the Evaluation of Alert and Notification systems for Nuclear Power Plants."

Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP guidance. (10 CFR Part 50, Appendix E.IV.D 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 OROs 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 OROs 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 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 104

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 OROs 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 Negotiated Extent of Play:

Actual contact will take place with the radio stations as per county plans. All subsequent actions to broadcast stations will be simulated. Systems that use automatic sending technology may be demonstrated by interview.

One municipality per risk county will demonstrate route alerting for hearing impaired residents within their jurisdiction.

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) 105

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.

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 OROs 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 OROs 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 Negotiated Extent of Play:

There are no exception areas in the TMI EPZ.

Sub-element 5.b - Emergency Information and Instructions for the Public and the Media 106

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.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.c)

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.

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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 OROs 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 demonstration 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 OROs 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.

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EVALUATION AREA 6 Support Operation/Facilities Sub-element 6.a - Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees 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.1: 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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 meet. 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.

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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 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 OROs 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 individuals 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 OROs plans and procedures and completed, as they would be in an actual emergency, unless otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play:

Expected demonstration should include a roster of the monitoring teams/portal monitors required to monitor 20% of the population allocated to the facility within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

A minimum of six individuals per monitoring station should be monitored (or one person six times).

Water from decontamination activities may go directly to a storm drain or other sewer or drain system or area normally designated for wastewater that has been used for bathing or washing of vehicles and or equipment.

At each reception center, a minimum of three volunteer evacuees will be processed, briefed, issued the appropriate strip map or directions, and instructed to proceed to a mass care center designated for demonstration of monitoring, decontamination, and 110

registration. A sample of the appropriate strip maps or directions will be made available for the demonstration.

One mass care center and one monitoring/decontamination center per risk county will be demonstrated during the out-of-sequence window. All monitoring and decontamination teams will demonstrate monitoring, decontamination and registration procedures at one mass care center per county. The risk counties will provide space at designated mass care centers for operation of monitoring/decontamination centers. Schematics of these monitoring /decontamination centers will be available to show organization within the facility and space management for monitoring and for decontamination of the evacuating public. Procedures will be demonstrated to show minimizing contamination of the facility and separation of contaminated and non-contaminated (clean) individuals.

At the evacuee monitoring/decontamination centers each team, consisting of a minimum of two persons (monitor and recorder), will monitor a minimum of six (6) volunteer evacuees or one (1) volunteer evacuee six times , complete the Monitoring/Decontamination Report Form (either by demonstration or explanation), and instruct the evacuees to proceed to the mass care registration points for further processing. The teams will demonstrate: radiological monitoring of at least one vehicle and the simulated decontamination of at least two evacuees, one unable to be decontaminated based on controller inject data. Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males A CD V-700, or other survey meter, will be issued to each team. For Portal Monitor Use refer to paragraph below. PRDs will be simulated.

At the emergency worker monitoring/decontamination stations each team, consisting of a minimum of two persons (monitor and recorder), will monitor one emergency worker, complete the Monitoring/Decontamination Report Form (either by demonstration or explanation.) Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males.

A CD V-700, or other survey meter, will be issued to each team. For Portal Monitor Use refer to next paragraph. PRDs will be simulated.

(Portal Monitor Use) Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees, emergency workers and/or vehicles. In the instances where a portal monitor is used a draft/interim procedure/guidelines may be used, for this evaluation. The monitoring/ decontamination team requirements will be based on the portal monitor capabilities as applicable based on the draft/interim procedure/guidelines, and manufactures recommendations.

Monitoring/decontamination centers and station personnel are not issued DRDs or KI since the centers and stations are outside the EPZ.

Radiation contamination data for the evacuees and vehicle will be provided by the controller and must be included in the scenario package. Set-up of the facility will be 111

performed the same as for an actual emergency with all route markings and contamination control measures in place including step-off pads; with the exception of long runs of plastic covered with paper which will not be demonstrated, but the materials will be available and explained. Positioning of a fire apparatus on-site may be simulated if otherwise required.

Sub-element 6.b - Monitoring and Decontamination of 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.1: 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.

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.

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All activities associated with this criterion must be based on the OROs 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:

Emergency worker station personnel will consist of a minimum of one monitor and one recorder and sufficient personnel to demonstrate monitoring of at least one vehicle.

Schematics of these monitoring/decontamination stations will be available to show organization and space management within the facility. The evaluator will request that decontamination procedures be explained after the vehicle which has simulated contamination has been monitored. One CD V-700, or other survey meter, will be issued to each monitoring/decontamination team. One vehicle and/or piece of equipment will not be able to be decontaminated. Simulated radiation contamination data will be included in the scenario package, and injected by a controller. Set-up of the facility will be performed as closely as possible to that for an actual emergency with all route markings in place including step-off pads; with the exception of long runs of plastic covered with paper which will not be demonstrated, but the materials will be available and explained.

Decontamination capabilities, and provisions for vehicles and equipment that cannot be decontaminated, will be simulated and conducted by interview.

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.

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) 113

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 OROs 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:

Capabilities will be demonstrated through an interview process. Personnel, at a minimum, will consist of one manager and assistant for each mass care center opened.

Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals This sub-element will be evaluated at the Carlisle Regional Medical Center on April 23, 2003.

INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Extent of Play 114

Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the victim.

Offsite Response Organizations (OROs) 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 b 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 b before releasing the ambulance from the drill. 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 before transport, done enroute, or deferred to the medical facility. Before using a monitoring instrument the monitor should demonstrate the process of checking the instrument for proper operation. All monitoring activities should be completed, as they would be in an actual emergency. Appropriate contamination control measures should be demonstrated before 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 OROs 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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Three Mile Island Nuclear Generating Station Extent of Play Demonstration Tables RISK DEMONSTRATION FOR EOC MOBILIZATION COUNTY FOR COUNTIES AND MUNICIPALITIES MUNICIPALITY DATE Cumberland Lower Allen Township April 22, 2003 New Cumberland Borough April 22, 2003 Dauphin Conewago Township April 22, 2003 Derry Township April 22, 2003 Harrisburg City April 22, 2003 Highspire Borough April 22, 2003 Londonderry Township April 22, 2003

Lower Dauphin Area April 22, 2003 Lower Paxton Township April 22, 2003 Lower Swatara Township April 22, 2003

Middletown/Royalton April 22, 2003 Boroughs Paxtang Borough April 22, 2003 Steelton Borough April 22, 2003 Swatara Township April 22, 2003 Lancaster Conoy Township April 22, 2003 East Donegal Township April 22, 2003

Elizabethtown April 22, 2003 Borough/West Donegal Township Mount Joy Township April 22, 2003 Lebanon South Londonderry April 22, 2003 Township York Conewago Township April 22, 2003 Dover Township April 22, 2003 Fairview Township April 22, 2003 Goldsboro Borough April 22, 2003 Hellam Township April 22, 2003

Lewisberry April 22, 2003 Borough/Newberry Township Manchester Township April 22, 2003

Northeast Area April 22, 2003 Springettsbury Township April 22, 2003 116

Warrington April 22, 2003 Township/Wellsville Borough York Haven Borough April 22, 2003

Joint EOC

1. One reception center in each county.

COUNTY Reception Centers Locations Quantity Cumberlan Big Spring High School 1 d

Dauphin Williams Valley High School 1 Lancaster Park City Mall 1 Lebanon Lebanon County Career & Development 1 York Red Lion High School Complex 1 Adams New Oxford Middle School 1 Franklin Scotland School 1 Schuylkill Blue Mountain High School 1

2. One mass care center and monitoring/decontamination center in each county will be evaluated.

COUNTY Mass Care Center Locations Quantity Cumberlan Big Spring High School 1 d

Dauphin Upper Dauphin High School 1 Lancaster Mannheim Township High School Complex 1 Lebanon Northern Lebanon Jr./Sr. High School 1 York Red Lion Jr High School Complex 1 Adams New Oxford Middle School 1 Franklin Scotland School 1 Schuylkill Blue Mountain High School 1 American Red Cross Chapters and POCs are as follows:

Lebanon County Chapter ARC of the Susquehanna Valley 1220 Mifflin Street 1804 N. Sixth Street, P.O. Box 5740 Lebanon, PA 17046 Harrisburg, PA 17110 117

Dawn Vitez (717) 273-2671 Mike Finkenbinder (717) 234-3101 Cumberland County Chapter Adams County Chapter 1710 Ritner Highway 11 Lincoln Square Carlisle, PA 17013 Gettysburg, PA 17325 Gene Lucas (717) 243-5211 Steve Wentz (717) 309-0395 Franklin County Chapter Schuylkill County Chapter 25 Penncraft Avenue 1402 Laurel Boulevard Chambersburg, PA 17201 Pottsville, PA Janet Diller (717) 264-6214 Celeste Hieser (570) 622-9550 York County Chapter 724 South George Street York, PA 17403 Robert Straw (717) 845-2751

3. Emergency worker monitoring/decontamination station for the risk county(s).

Cumberland Lemoyne FD #11 April 22, 2003 Dauphin Harrisburg Area Community College April 22, 2003 Lancaster Mount Joy FD April 22, 2003 Lebanon Annville Union Hose FD April 22, 2003 York Springettsbury FD April 22, 2003

4. One hearing impaired notification or one route alerting demonstration by one municipality in each risk county.

Cumberland New Cumberland Borough April 22, 2003 Dauphin Londonderry Township April 22, 2003 Lancaster Elizabethtown Borough April 22, 2003 Lebanon South Londonderry Township April 22, 2003 York Fairview Township April 22, 2003

5. Risk School Districts with schools in the EPZ and those districts outside the EPZ but with students living within the EPZ will participate and will be evaluated by FEMA. These include (all schools within EPZ):

COUNTY SCHOOL DISTRICT SCHOOL 118

Cumberland *West Shore Hillside Elementary School Dauphin *Central Dauphin Tri-Community Elementary

Derry Township Hershey Elementary

Harrisburg Foose Elementary

Lower Dauphin Londonderry Elementary

Middletown Area Feaser Middle School

Milton Hershey Milton Hershey School

Steelton-Highspire Steelton-Highspire High School Lancaster *Donegal Maytown Elementary School

Elizabethtown Area East High St. Elementary Lebanon Palmyra Area Palmyra High School York *Central York Sinking Springs Elementary and Central Middle School

Northeastern Northeastern High School and Orendorf Elementary Dover Area Dover Area High School

Eastern Eastern High School

6. Traffic and Access Control Points

a. The Pennsylvania State Police from all five risk county troop locations will be briefed at the PSP Troop H Barracks, located in Harrisburg for Cumberland, Dauphin, Lancaster, Lebanon, and York. Members attending the briefing will not actually deploy to the TCP/ACPs.

b. The PSP briefing will be performed out of sequence in a demonstration window of 9:00 - 11:00 a.m. on April 22, 2002.

7. Each municipal/regional police force with a TCP assigned in its plan will demonstrate all preparation duties including TCP responsibilities and radiological briefing. Dispatch of persons to the TCP site will not occur during the exercise.

These municipal/regional police forces (underlined municipality will perform) are (by county):

Northern York County Regional Police (Conewago, Dover and Manchester Townships) 119

Newberry Township Police Department (Goldsboro and York Haven Boroughs, Newberry Township)

Fairview Township Middletown South Londonderry Borough/Royalton Township Borough DerryTownship Steelton Borough Hellam Township Hummelstown Elizabethtown Lewisberry Borough/South Borough/ West Borough/Newberry Hanover Township Donegal Township Township Lower Swatara Mount Joy New Cumberland Township Township Borough 120

2003 Three Mile Island Exercise Listing of Prior Issues No. OLD FACILITY EVALUATED NEW NUMBER CRITERIA 1 64-01-11-A-01 CENIC Content of EAS Msg 5.b.1 2 64-01-13-A-02 CENIC Rumor control not included in all 5.b.1 dist.

3 64-01-05-A-03 PSP Failure to document leak tests 1.e.1 4 64-01-12/14- Dauphin County EOC Media briefing/KI 5.b.1 D-02 information 3.b.1 5 64-01-15-A-04 Lower Dauphin Area EOC 3.c.1 No updated special needs list 6 64-99-11-A-24 Lebanon County EOC 5.b.1 No timely news release after PAD 7 64-99-18-A-26 Lebanon Cty. 6.a.1 Rec/Mon/Decon/MC Center (E.

Lebanon Cty MS)

Lack of space 8 64-97-05/14- Elizabethtown Boro/W. Donegal 3.a.1 A-10 Twp. 3.b.1 Route alerting team problems 9 64-95-18-A-17 Lancaster Cty. Mon/Decon/MC 6.a.1 Center (Centerville Jr. HS)

Disposition of monitoring forms 10 64-99-18-A-08 Dauphin Cty. Mon/Decon/MC 6.a.1 Center (Upper Dauphin Elem/MS)

No demo of decon of vehicles 11 64-99-18-A-09 Dauphin Cty. Mon/Decon/MC 6.a.1 Center (Upper Dauphin Elem/MS)

Improper survey techniques 12 64-99-18-A-10 Dauphin Cty. Mon/Decon/MC 6.a.1 Center (Upper Dauphin Elem/MS)

No change of clothing for evacuees 13 64-99-05-A-11 Dauphin Cty. Mon/Decon/MC 3.a.1 Center (Millersburg HS Complex)

No Dosimetery-KI report forms 14 64-99-18-A-12 Dauphin Cty. Mon/Decon/MC 6.a.1 Center (Millersburg HS Complex)

Mon/Decon not demonstrated 15 64-99-18-A-13 Dauphin Cty. Mon/Decon/MC 6.a.1 Center (Millersburg HS Complex)

Monitoring teams lacked knowledge 121

16 64-95-18-A-12 Dauphin Cty. Mon/Decon/MC 6.a.1 Center (Upper Dauphin HS)

MC staff did not confirm monitoring 17 64-99-05-A-20 Lancaster Cty. Mon/Decon/MC 3.a.1 Center (Mannheim Twp. MS)

Did not fill out PRD forms 18 64-99-18-A-21 Lancaster Cty. Mon/Decon/MC 6.a.1 Center (Mannheim Twp. MS)

Failed to follow checklists 19 64-99-22-A-22 Lancaster Cty. Mon/Decon/MC 6.b.1 Sta. (Mt. Joy FD)

Did not avoid cross-contamination 20 64-99-03/14- Mt. Joy Twp. Route Alerting 1.c.1 A-23 Teams were not provided key info 3.b.1 21 64-99-18-A-29 Lebanon Cty. Mon/Decon/MC 6.a.1 Center (E. Lebanon Cty. HS)

Lack of space 22 64-99-18-A-30 Lebanon Cty. Mon/Decon/MC 6.a.1 Center (E. Lebanon Cty. HS)

Not enough showers 23 64-99-18-A-42 Adams Cty. Rec/Mon/Decon/MC 6.a.1 Center (Gettysburg Area MS)

Rad monitors did not wear gloves 24 64-99-19-A-43 Adams Cty. Rec/Mon/Decon/MC 6.c.1 Center (Gettysburg Area MS)

Unknowledgeable MC manager 25 64-99-18-A-46 Franklin Cty. Rec/Mon/Decon/MC 6.a.1 Center (Faust Jr. HS)

Not enough mon teams 26 64-99-18-A-47 Franklin Cty. Rec/Mon/Decon/MC 6.a.1 Center (Faust Jr. HS)

Did not avoid cross-contamination 27 TMIX89-3R State EOC 1.d.1 Common between state and counties 28 TMIX89-6R State EOC 2.e.1 Establishment of restricted areas 29 TMIX89-30R Juniata Cty. EOC 3.e.1 Unfamiliar with emergency PAGs 30 64-01 P- Lancaster Cty. Mon/Decon/MC 6.b.1 01 Sta. (Pioneer FC)

No detailed decon plan 31 64-01-16-P-02 Harrisburg School District 3.c.2 122

Plan needs updated 32 64 Lebanon Cty. EOC 3.a.1, 05/09/19-P-03 (Henry Skoczalek plan review) 2.b.2, 6.c.1 123

APPENDIX 4 EXERCISE SCENARIO EXELON NUCLEAR THREE MILE ISLAND GENERATING STATION 2003 BIENNIAL EXERCISE Initial Conditions UNIT 1 The unit has been operating at 100% power, the 378th day of the current full power cycle run.

A Reactor building purge is in progress fro containment pressure control.

Emergency Feed pump EFP-2A is out of service for repairs to its discharge check valve, EHV-11A. The pump has been blocked, valve opened and inspected. The valve disk is being replaced. A new disk is at the work site for installation at this time, repairs are expected to continue for another 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

WEATHER FORECAST Partly cloudy skies are forecast tonight. Light variable winds are expected to continue from the west. Look for clearing skies overnight and cooling for tomorrow. The low tonight will be around 40 degrees. Highs tomorrow will near 50 degrees. Moderate westerly wind will continue through tomorrow. Probability of precipitation is near zero.

Scenario Abstract TIME: EVENT:

15:30 (T 00:00) Exercise begins.

15:35 (T 00:05) (Events 1, 2 and 3) A controller acting as a simulated security officer on patrol in Turbine Building (Turbine Building Elevation 355) reports hearing loud banging noise and seeing steam/dust plume on the west side of the Unit 1 turbine. A simulated shell failure has occurred on the E moisture separator resulting in an isolable steam leak (when turbine stop valves close). Both the main turbine and the reactor trip successfully.

During the transient, reactor building purge inboard isolation valve, fails in the intermediate position. Outboard reactor building purge valve closes normally. Alarms are received on annunciator alarm windows indicating:

loss of condenser vacuum.

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15:45 (T 00:15) Operators receive indications of 1A feed pump trip. Trip is due to low auxiliary condenser vacuum caused by loss of auxiliary condenser vacuum pumps. The 1B feed pump continues to run.

Auxiliary operator dispatched to the area of E moisture separator reports significant water impingement on panels and in general area of the turbine building 305 and 322 elevations. 1C turbine plant MCC has been thoroughly wetted. An instrument box has been knocked off the discharge line of the B condenser vacuum pump.

When Auxiliary operator/maintenance personnel are dispatched to AHV-1B MCC, they will report blown control power fuses.

15:50 (T 00:20) An UNUSUAL EVENT should have been declared based upon:

HU4 - Fire Within the Protected Area Boundary NOT Extinguished in <

15 minutes of Detection

2. Unanticipated NON bomb explosion (violent combustion /

pressurized equipment failure) inside the Protected Area.

16:15 (T 00:45) (Event 4) Indications of a tube leak in the A Once-Through Steam Generator (OTSG) of > 160 gallons per minute.

16:30 (T 01:00) An ALERT should have been declared based upon:

FA1 - Fission Product Barrier Matrix

2. Reactor Coolant System Barrier Potential Loss

f. Primary / Secondary Leakage Calculated leak rate > 160 gpm AND Loss of RCS inventory into OSTG 17:45 (T 02:15) (Event 5) Annunciator Alarm Windows AA-1-6 and AA-2-6 are received indicating loss of 480V bus 1C. Loads lost include the A and C condenser vacuum pumps and auxiliary boiler fuel pumps. Loss of vacuum pumps, combined with condenser damage caused by the E moisture separator failure causes a rapid loss of condenser vacuum. With the loss of condenser vacuum and turbine bypass capability, operators will have to shift reactor cooldown to the MSV-4 atmospheric dump valves.

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18:00 (T 02:30) A SITE AREA EMERGENCY should be declared based upon:

FS1 Fission Product Barrier Matrix

2. Reactor Coolant System Barrier Potential Loss

f. Primary / Secondary Leakage

1. EITHER of the following:

High Make Up Flow alarm (D-3-1)

OR

Calculated leak rate > 160 gpm AND Loss of RCS inventory into OSTG

3. Primary Containment Barrier Loss

f. Primary / Secondary Leakage

1. Total OTSG leak >1gpm (Tech. Spec.)

AND Pathway to atmosphere exists from the affected OTSG, as indicated by ANY of the following:

o Steam line break outside Containment o Main Steam Relief stuck open o Steaming via Atmospheric Dump Valves o Turbine-driven Emergency Feed Pump exhaust 18:45 (T 03:15) A controller simulating a security officer on rounds will report a large fuel oil spill in the turbine building at the face of the auxiliary boilers.

19:15 (T 03:45) (Event 4) Loose Parts Monitor alarms on channels 1, 2, 3 and 4 (reactor vessel) indicating loose debris in the reactor vessel.

19:25 (T 03:55) Increasing radiation monitoring system channels provide indication that fuel cladding has been damaged and RCS activity and release to the environment have increased.

19:40 (T 04:10) A GENERAL EMERGENCY should be declared based upon:

FG1 Fission Product Barrier Matrix

1. Fuel Clad Barrier Loss

c. RCS Activity

1. > 2500 µCi/cc (Total) 126

OR Fuel Damage Class 2

2. Reactor Coolant System Barrier Potential Loss

f. Primary / Secondary Leakage

1. EITHER of the following:

o High Make Up Flow alarm (D-3-1)

OR o Calculated leak rate > 160 gpm o AND o Loss of RCS inventory into OSTG

3. Primary Containment Barrier Loss

f. Primary / Secondary Leakage

i. Total OTSG leak >1gpm (Tech. Spec.)

AND Pathway to atmosphere exists from the affected OTSG, as indicated by ANY of the following:

Steam line break outside Containment

Main Steam Relief stuck open

Steaming via Atmospheric Dump Valves

Turbine-driven Emergency Feed Pump exhaust The following Protective Action Recommendation should be presented to the Senior State Representative in the EOF:

Evacuate plant radius 360 degrees 0 to 5 miles When primary conditions meet criteria for isolation of the affected A OTSG, the A OTSG may be isolated. Cooldown continues on the unaffected B OTSG.

When onsite and off site team objectives have been demonstrated and evaluations are completed, confirmation of completion received from off site participating agencies and Facility Lead Controllers have conferred with the Lead Onsite Controller - the Biennial Emergency Exercise is terminated.

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APPENDIX 5 PLANNING ISSUES This appendix contains the Planning Issues assessed during the April 22-23, 2003, exercise at THREE MILE ISLAND NUCLEAR GENERATING STATION. Planning Issues are issues identified in an exercise or drill that do not involve participant performance, but rather involve inadequacies in the plan or procedures. Planning Issues are required to be corrected through the revision and update of the appropriate State and local RERPs and/or procedures in accordance with the following schedule:

Within 120 days of the date of the exercise/drill when the Planning Issue is directly related to protection of the public health and safety.

During the annual plan review and update (reported in the Annual Letter of Certification) when the Planning Issue does not directly affect the public health and safety. However, when the date for the annual plan review and update is imminent and the responsible organization does not have sufficient time to make the necessary revisions in the plans and/or procedures, the revised portion of the plans and/or procedures should be submitted in the subsequent annual plan review and update and reported in the Annual Letter of Certification.

Any requirement for additional training of responders to radiological emergencies necessitated by the revision and update of the plans and/or procedures must be completed within the timeframes described above in order for the Planning Issue to be considered resolved.

Commonwealth of Pennsylvania 1.1 State Emergency Operations Center Issue No.: 64 6.c.1-P-01 CONDITION: Population Census data contained in the Pennsylvania Emergency Operations Plan is not based on the most current census information available. The population for the Three Mile Island Emergency Planning Zone is based on the 1990 Census.

POSSIBLE CAUSE: Failure to update the Emergency Operations Plan.

REFERENCE:

Pennsylvania Emergency Operations Plan, Annex E, Appendix 4, Attachment F, page E-4-16. (NUREG-0654, J.10.h, J.12)

EFFECT: Sufficient resources might not be available for the Monitoring and Decontamination/Reception and Mass Care Centers RECOMMENDATION: Review and update plan.

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Schedule of Corrective Actions: This plan is in the process of being updated.

The new census data will be included in this update.

1.4 Accident Assessment Center Issue No.: 64-03-2.b.1/4.c.2-P-02 CONDITION: Dose projection data developed by Pennsylvania Department of Environmental Protection/Bureau of Radiation Protection (BRP) at the Accident Assessment Center (AAC) and state field monitoring team data were not sent to the licensee Emergency Operations Facility (EOF) for use by the licensee. (Data was requested from the licensee by the BRP Liaison and was then sent to the AAC.) Differences greater than a factor of 10 between projected doses by the licensee and the BRP were not discussed (criterion 2.b.1) and the sharing and coordination of plume measurement information among all field teams (licensee and state) was not performed (criterion 4.a.2).

POSSIBLE CAUSE: The BRP procedures for response to a nuclear power plant accident do not require the sharing of field monitoring team data and dose projection data with the licensee. The licensee did not request the information.

REFERENCE:

NUREG-0654, H.12; I.8, 10, 11; and Supplement 3; BRP-EP-6.07, Rev. 0, 03/03, Emergency Facility Operations.

EFFECT: Although the AAC staff was aware of the differences between the dose projections and understood the reasons for those differences, the licensee did not have the opportunity to consider possible changes needed to their projections, which may have affected future protective action recommendations. The Field Team Coordinator for the AAC considered the location and movement of the licensee field teams, but the licensee was not able to anticipate state field team location or use the state data to coordinate their field team movements.

RECOMMENDATION: The referenced BRP procedure should include (on the appropriate checklists) that the BRP personnel should provide information concerning dose projections and field team locations and monitoring readings to the licensee and that similar licensee information should be requested.

Schedule of Corrective Actions: This cannot possibly be a Lancaster County issue. No county in this state develops or uses dose projection data. It is possible you meant to credit this to BRP.

FEMA Response: This was an administrative error and is now properly identified.

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2.1.5 Newville Community EMS - Carlisle Regional Medical Center Issue No.: 64-03-3.a.1-P-03

Description:

Responding Emergency Medical Technicians (EMTs) from the Newville Community EMS unit #147 had not been issued a Permanent Record Dosimeter (PRD) in accordance with the extent of play. (NUREG-0654, F.2; H.10; K.5.a,b;L.1;L.4)

Recommendation: Review and revise as necessary the plan and procedures to clarify the issuance of PRD to Category C emergency responders. The plan needs to be evaluated to remove any question as to whether the paragraph is referring to the need for Direct Reading Dosimeters (DRDs) and the statement that follows is referring the issuance of the Permanent Record Dosimeter (PRD). The plan needs to state who issues dosimetery to the EMTs when they are responding to a radiological incident for transport of victims to MS-1 hospital.

Schedule of Corrective Actions: This is not an issue. Annex E, Appendix 5 of the state Emergency Operations Plan clearly states that Transporters of contaminated or potentially contaminated individuals outside of an EPZ are not provided dosimetry. That is exactly what the Newville Community EMS personnel were. This is a frequently mis-identified ARCA in MS-1 exercises and stems from lack of understanding of this commonwealths policies by the evaluators. No corrective action is necessary and this ARCA should be cleared.

FEMA Response: Annex E, Appendix 5 of the State Emergency Operations Plan does clearly state that Transporters of contaminated or potentially contaminated individuals outside of EPZ are not provided dosimetry. However the next paragraph entitled Category C Standard Issue: in the same referenced plan clearly states PRD-1 per emergency responder, monitor or hospital staff member as stated in the hospital plan. This clearly can, and has, caused confusion to a reader or user of the plan. The Newville Community EMS Unit #

147 Emergency Medical Technicians are clearly Emergency Responders and by definition in the Category C Standard Issue : paragraph should be issued 1 PRD. The State Plan and corresponding County Plans need to be further reviewed and rewritten to eliminate any possible confusion and ambiguity. This ARCA is reclassified as a Planning Issue.

2.3.1 Lancaster County Emergency Operations Center Issue No.: 64-03-6.a.1-P-04 130

Description:

The Lancaster County Emergency Operations Plan lists 1990 risk population data for the risk municipalities in Lancaster County.

POSSIBLE CAUSE: The risk population was not updated to reflect 2000 census data or there is a typographical error in that 1990 should read 2000.

REFERENCE:

Lancaster County Emergency Operations Plan, Annex E, Part I (TMI), Lancaster County Radiological Emergency Response Procedures to Nuclear Power Plant Incidents, February 1993, Change 8, May 2002.

EFFECT: If the population data contained in the plan is based upon the 1990 census rather then the 2000 census there could be a shortage of recourse for evacuee registration, mass care centers, and sufficient number of monitoring and decontamination teams.

RECOMMENDATION: Update the plan to reflect the current risk populations, mass care requirements, and monitoring and decontamination team requirements.

Schedule of Corrective Actions: Plan will be updated to reflect new data.

3.2.3 Mass Care Faust Jr. High School Issue No.: 64-03-6.a.1-P-05

Description:

The emergency plan for Franklin County lists Faust Junior High School as one of three monitoring/decontamination centers. However, all monitoring and decontamination would be performed at the Reception Center at Scotland School.

POSSIBLE CAUSE:

The cause was possibly due a failure to update the written plans and procedures to reflect current practices.

REFERENCES:

NUREG-0654, J.12 Franklin County Emergency Response Plan, Appendix 4, Annex E, Attachment F EFFECT:

The inconsistency between the written plans and the current practice could result in the delivery of monitoring and decontamination equipment to the wrong location, or in some confusion on the part of emergency workers regarding where they are supposed to go.

RECOMMENDATION:

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Plans regarding the monitoring and decontamination of evacuees in Franklin County should be reviewed and revised.

Schedule of Corrective Actions: Plan will be updated to reflect current procedures.

3.3.1 Schuylkill County Emergency Operations Center Issue No.: 64-03-6.a.1-P-06 DESCRIPTION: Annex E, Appendix 3, Reception Center Operations, page E-3-1, contains conflicting guidance on the activation of Reception Centers when an SAE is declared. In this section it indicates that the Emergency Management Coordinator of Schuylkill County will activate the Reception Center when an SAE is declared. However, under Annex E, paragraph 3, Concept of Operations, sub-paragraph E, Monitoring/Decontamination Center(s), sub-element 1, indicates that the PEMA Eastern Region will notify the Schuylkill County EMA when monitoring/decontamination is required.

POSSIBLE CAUSE: Change in procedures occurred without emergency operations plan being changed.

REFERENCE:

Schuylkill County Plan (NUREG 0654, J.10.h, J.12, K.5.a,)

EFFECT: This could be construed to mean that Schuylkill County cannot activate their reception centers unless advised by PEMA Eastern Region to do so.

RECOMMENDATION: Recommend that the EMC of Schuylkill County confer with the PEMA Eastern Region to determine and clarify if the information provided in the County plan is still current. If the requirement still exists for PEMA Eastern Region to contact Schuylkill County when monitoring /

decontamination is required, then this requirement should be reflected on page E-3-1 appropriately.

Schedule of Corrective Actions: Plan will be revised during the next update.

4.2.3 Harrisburg School District - Foose Elementary School Issue No.: 64-03-3.c.2-P-07

Description:

The Harrisburg School District Emergency Evacuation Plan for TMI (Three Mile Island) requires authentication of emergency notification to be accomplished by return phone call to the Dauphin County Emergency Operations Center. No phone number is listed in the 132

plan or is readily available to verify an emergency situation. (NUREG-0654 J.10.c, d, g)

Recommendation: Revise the plan or checklist to include a contact phone number for Dauphin County Emergency Operations Center.

Schedule of Corrective Actions: More information is needed in order to respond to this issue. If the issue is that school personnel failed to authenticate the emergency notification then a rating of ARCA is valid.

However, if the notification was authenticated but the phone number was not available in the plan or checklist, this issue should be a planning issue FEMA Response: Concur that this should be a Planning Issue.

4.2.7 Steelton-Highspire School District - Steelton-Highspire High School Issue No.: 64-03-3.c.2-P-08

Description:

Annex G Nuclear Power Plant Incident Preparedness (TMI) is missing from the Steelton-Highspire School District Dauphin County Emergency Operations Plan. (NUREG-0654 J.10.c, d, g)

Recommendation: Add Annex G to the plan.

Schedule of Corrective Actions: Again, this should be rated as a planning issue. The very fact that the lack of having Annex G attached to the emergency operations plan is the only issue noted proves that all other procedures to protect the public were successfully carried out. Obviously a copy of Annex G should have been attached. The fact that it wasnt did not prevent the players from accomplishing the mission. This is the essence and spirit of the new criteria. A copy of Annex G will be attached to the emergency plan in the future.

FEMA Response: Concur. This is reclassified as a Planning Issue.

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APPENDIX 6 ADDITIONAL PRIOR ISSUES This appendix contains the description and status of ARCAs assessed during prior exercises at the Three Mile Island Nuclear Power Station. These were (1) assessed at jurisdictions or functional entities, which were exempted from demonstration at this exercise, or (2) for ingestion pathway objectives not scheduled for demonstration in this exercise.

PRIOR ISSUES AT FUNCTIONAL ENTITIES NOT SCHEDULED TO BE DEMONSTRATED Issue No.: 64-99-18-A Dauphin County Monitoring/Decontamination/Mass Care Center #1 (Upper Dauphin Elementary/Middle School)

Description:

No demonstration of decontamination of vehicles was conducted at the Dauphin County monitoring/decontamination center at Upper Dauphin Middle School, as required by the extent-of-play agreement. (NUREG-0654, J.12. and N.1.a.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The site should be scheduled for demonstration during the next biennial exercise.

Schedule of Corrective Action:

Issues 64-99-18-A-08 thru 13 below against Dauphin County should all be negated. This was discussed and agreed to prior to the exercise. None of the entities listed below do reception center or monitoring/decontamination activities any longer. All of this is now accomplished at Williams Valley High School for Dauphin County. Unless these are administratively canceled they will remain on the books as ARCAs forever.

FEMA Response: Concur. This function is now accomplished at the Williams Valley High School and was successfully demonstrated, correcting this prior issue.

Issue No.: 64-99-18-A Dauphin County Monitoring/Decontamination/Mass Care Center #1 (Upper Dauphin Elementary/Middle School)

Description:

The radiation monitors at the Upper Dauphin Middle School did not demonstrate proper survey techniques for monitoring individuals and vehicles. The probe window was not always directed toward the person/vehicle, the survey speed varied from extremely rapid to very slow, and the chest and back areas of individuals were not monitored as is directed in the SOP. Several participants did not know how to interpret the action levels for determining who (or what) needed to be decontaminated. (NUREG-0654, J.12. and K.5.b.)

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Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The site should be scheduled for demonstration during the next biennial exercise.

Schedule of Corrective Action:

Issues 64-99-18-A-08 thru 13 below against Dauphin County should all be negated. This was discussed and agreed to prior to the exercise. None of the entities listed below do reception center or monitoring/decontamination activities any longer. All of this is now accomplished at Williams Valley High School for Dauphin County. Unless these are administratively canceled they will remain on the books as ARCAs forever.

FEMA Response: Concur. This function is now accomplished at the Williams Valley High School and was successfully demonstrated, correcting this prior issue.

Issue No.: 64-99-18-A Dauphin County Monitoring/Decontamination/Mass Care Center #1 (Upper Dauphin Elementary/Middle School)

Description:

The Dauphin County SOPs for monitoring/decontamination centers (pages 1, 2, and 6) state that a change of clothing should be available for evacuees to prevent the chance of recontamination. This item is listed on the inventory, but was not available.

(NUREG-0654, J.12.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The site should be scheduled for demonstration during the next biennial exercise.

Schedule of Corrective Action:

Issues 64-99-18-A-08 thru 13 below against Dauphin County should all be negated. This was discussed and agreed to prior to the exercise. None of the entities listed below do reception center or monitoring/decontamination activities any longer. All of this is now accomplished at Williams Valley High School for Dauphin County. Unless these are administratively canceled they will remain on the books as ARCAs forever.

FEMA Response: Concur. This function is now accomplished at the Williams Valley High School and was successfully demonstrated, correcting this prior issue.

Issue No.: 64-99-05-A Dauphin County Monitoring/Decontamination/Mass Care Center #2 (Millersburg High School Complex) 135

Description:

The emergency workers at the Dauphin County monitoring/

decontamination center, Millersburg High School Complex, did not have Dosimetry-KI Report Forms, as required by the Dauphin County EOP, page E-13-46. (NUREG-0654, K.3.b. and N.1.a.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The workers should receive additional training on the importance of having and completing the Dosimetry-KI Report Forms.

Schedule of Corrective Action:

Issues 64-99-18-A-08 thru 13 below against Dauphin County should all be negated. This was discussed and agreed to prior to the exercise. None of the entities listed below do reception center or monitoring/decontamination activities any longer. All of this is now accomplished at Williams Valley High School for Dauphin County. Unless these are administratively canceled they will remain on the books as ARCAs forever.

FEMA Response: Concur. This function is now accomplished at the Williams Valley High School and was successfully demonstrated, correcting this prior issue.

Issue No.: 64-99-18-A Dauphin County Monitoring/Decontamination/Mass Care Center #2 (Millersburg High School Complex)

Description:

Monitoring/decontamination at the Dauphin County Monitoring/Decontamination Center, Millersburg High School Complex, was not demonstrated, as required by the extent-of-play agreement. (NUREG-0654, N.1.a.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The extent-of-play should be followed at the next biennial exercise.

Schedule of Corrective Action:

Issues 64-99-18-A-08 thru 13 below against Dauphin County should all be negated. This was discussed and agreed to prior to the exercise. None of the entities listed below do reception center or monitoring/decontamination activities any longer. All of this is now accomplished at Williams Valley High School for Dauphin County. Unless these are administratively canceled they will remain on the books as ARCAs forever.

FEMA Response: Concur. This function is now accomplished at the Williams Valley High School and was successfully demonstrated, correcting this prior issue.

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Issue No.: 64-99-18-A Dauphin County Monitoring/Decontamination/Mass Care Center #2 (Millersburg High School Complex)

Description:

The monitoring team at the Dauphin County monitoring/ decontamination center, Millersburg High School Complex, did not know how or where to set up the monitoring stations, how to maintain contamination control at the facility, or how to monitor potentially contaminated evacuees or vehicles. (NUREG-0654, J.12.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The monitoring teams in Dauphin County should receive additional training on the setup and procedures of monitoring/decontamination centers.

Schedule of Corrective Action:

Issues 64-99-18-A-08 thru 13 below against Dauphin County should all be negated. This was discussed and agreed to prior to the exercise. None of the entities listed below do reception center or monitoring/decontamination activities any longer. All of this is now accomplished at Williams Valley High School for Dauphin County. Unless these are administratively canceled they will remain on the books as ARCAs forever.

FEMA Response: Concur. This function is now accomplished at the Williams Valley High School and was successfully demonstrated, correcting this prior issue.

Issue No.: 64-95-18-A Lancaster County Monitoring/Decontamination Center (Centerville Jr. High School)

Description:

Although the monitoring/decontamination forms were filled out properly, there was a misunderstanding about what to do with the forms afterward. There is no procedure to collect the forms and direct them to the proper destination. A procedure should be developed to direct monitoring forms to the proper location. (NUREG-0654, J.12.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The site should be scheduled for demonstration during the next biennial exercise.

Issue No.: 64-99-05-A Lancaster County Monitoring/Decontamination/Mass Care Center (Manheim Township Middle School)

Description:

Although issuance of thermoluminescent dosimeters (TLDs) to monitoring and decontamination personnel was simulated at the Lancaster County monitoring/decontamination center (Manheim Township Middle School), the required 137

forms showing TLD number, date/time issued, and to whom and by whom issued, were not filled out in accordance with Attachment B, page 11, of the Lancaster County EOP.

(NUREG-0654, K.3.a.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The site should be scheduled for demonstration during the next biennial exercise.

Schedule of Corrective Actions: Issues 64-99-05-A-20 and 21 below against Lancaster County should be negated. These two ARCAs are probably due to confusion over the layout of the Mannheim Township School Complex. The high school and middle school are in immediate proximity of each other. Both buildings are used for mass care. The reception center and monitoring/decontamination activities are performed at the same place and by the same team every time during exercises. Mannheim Township Middle School was only listed in the 1999 extent of play because that is where the mass care demonstration took place. Any monitoring/decontamination shortcomings at this site in 1999 were corrected in the 2003 exercise.

FEMA Response: Concur. This Prior Issue was successfully demonstrated during the 2003 exercise. This ARCA is now corrected and closed.

Issue No.: 64-99-18-A Lancaster County Monitoring/Decontamination/Mass Care Center (Manheim Township Middle School)

Description:

Several significant actions listed in the "Checklist of Manager Radiological Decontamination Monitoring Center" in the Lancaster County monitoring/decontamination procedures (page 2) for a General Emergency were not demonstrated. Personnel in charge were not aware that the following checklist items were required: (a) enter into log names of all persons screened (using Decontamination Center Report Form, Enclosure 9), (b) report to the County EOC name of any person found to be contaminated to 0.5 milliRoentgens per hour (mR/h) or above, and (c) report to the County EOC, every two hours, number of individuals processed through the Center, number contaminated, number decontaminated, number referred to a medical facility, the highest reading on any particular person, and any unusual or noteworthy findings.(NUREG-0654, K.5.a. and N.1.a.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The site should be scheduled for demonstration during the next biennial exercise.

Schedule of Corrective Actions: Issues 64-99-05-A-20 and 21 below against Lancaster 138

County should be negated. These two ARCAs are probably due to confusion over the layout of the Mannheim Township School Complex. The high school and middle school are in immediate proximity of each other. Both buildings are used for mass care. The reception center and monitoring/decontamination activities are performed at the same place and by the same team every time during exercises. Mannheim Township Middle School was only listed in the 1999 extent of play because that is where the mass care demonstration took place. Any monitoring/decontamination shortcomings at this site in 1999 were corrected in the 2003 exercise.

FEMA Response: Concur. This Prior Issue was successfully demonstrated during the 2003 exercise. This ARCA is now corrected and closed.

Issue No.: 64-99-18-A Adams County Reception/Monitoring/Decontamination/Mass Care Center (Gettysburg Area Middle School)

Description:

The radiological monitors at the Adams County monitoring/

decontamination/mass care center (Gettysburg Area Middle School) did not wear or simulate wearing gloves while surveying individuals and vehicles for contamination, as required by Appendix 5, page E-36, of the Adams County EOP. (NUREG-0654, J.12.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The emergency workers should receive additional training with emphasis on wearing gloves during radiological monitoring.

Issue No.: 64-99-19-A Adams County Reception/Monitoring/Decontamination/Mass Care Center (Gettysburg Area Middle School)

Description:

The American Red Cross (ARC) Manager for the Adams County mass care center, located in the Gettysburg Area Middle School, was not knowledgeable in all aspects of the requirements for this center (e.g., capacity of the center, how many evacuees to expect, and if procedures are available for exceeding the capacity of the center). (NUREG-0654, J.10.h.)

Reason ARCA Unresolved: The site was not scheduled for demonstration during the 2003 exercise.

Recommendation: The ARC Manager, Adams County Chapter, should receive additional training regarding the County EOP or know whom to contact in the county if additional information is needed. He also needs information on the mass care centers capacity.

139

PRIOR ISSUES FOR INGESTION EXPOSURE PATHWAY OBJECTIVES Issue No.: TMIX89-3R - State EOC

Description:

Communications with the participating County EOCs during the ingestion pathway phase of the exercise were complicated by the fact that no direct communications link was established between the State EOC and Juniata and Mifflin counties. Instead, the State EOC used the PEMA Area Office as a "go-between" to these counties for communications. This lack of a direct communications link may have contributed to the fact that a key press release generated by PEMA did not reach Mifflin County. Communications were further complicated during the ingestion phase by use of the fax as the primary means of communication to the participating counties. The fax was enhanced by use of a programmed, automated sequential calldown of the 14 counties and two Area Offices. Despite this enhancement, fax messages were often delayed by 30 minutes at those locations near the bottom of the calldown sequence. Given these unavoidable hard-copy message delays and the lack of a direct State communications link with two of the ingestion pathway counties, it is recommended that key messages between the State EOC and the counties transmitted primarily via fax teletype be accompanied by notice of their pending arrival by telephone calls from the State EOC.

(Objective 4 (Criterion 1.d.1); NUREG-0654, F.1. and F.2.)

Reason ARCA Unresolved: The communication between the State EOC and ingestion counties during the ingestion pathway phase was not scheduled for demonstration during this exercise.

Recommendation: This aspect of Objective 4 (Criterion 1.d.1) should be demonstrated during the next TMI ingestion exposure pathway exercise.

Issue No.: TMIX89-6R - State EOC

Description:

One function central to reentry and recovery measures - the establishment of restricted areas (areas suspected or confirmed to be affected by deposition) - was less than effective on the part of the State EOC decision makers and Situation Analysis Group. The boundaries identified for the Elizabethtown restricted area and forwarded to the counties on October 19, 1989, exceeded the 10-mile EPZ and encompassed parts of Lancaster County not evacuated during the emergency plume phase. According to county estimates, approximately 11,000 residents were located in the part of the restricted area extending beyond the 10-mile EPZ. No actions were taken to address the fact that 11,000 residents remained inside the restricted area until a conference call hosted by the State EOC at 1300 on October 20, 1989, during which PEMA first became aware that the boundaries extended beyond the evacuated 10-mile zone. Additionally, the use of legislative routes for the delineation of restricted area boundaries by the PEMA Situation Analysis Group was problematic for the Lancaster and Dauphin County EOC staffs, who found it necessary to translate them into road names more familiar to county and municipal personnel. The establishment of restricted areas should involve extensive 140

coordination between the Counties and State EOC. (Objective 28 (Criterion 2.e.1);

NUREG-0654, I.10. and M.1.)

Reason ARCA Unresolved: In accordance with the extent-of-play agreement, Objective 28 (Criterion 2.e.1) was not scheduled for demonstration during the April 22, exercise.

Recommendation: Objective 28 (Criterion 2.e.1) should be demonstrated during the next TMI ingestion exposure pathway exercise.

Issue No.: TMIX89-30R - Juniata County EOC

Description:

Although the participating officials were very knowledgeable regarding the food pathways in the County, no one in the EOC was familiar with the preventative and emergency protective action guidelines and corresponding actions for milk, fruits, and drinking water (as outlined in both the Commonwealth EOP and the recently adopted annex to the County Plan). Continued training in radiological matters is recommended for the appropriate county officials, especially in the area of ingestion pathway protective measures. (Objective 27; NUREG-0654, E.5., E.7., J.9., and J.11.)

Reason ARCA Unresolved: Objective 27 (Criterion 3.e.1) was not required to be demonstrated during the June 8, 1999, TMI exercise.

Recommendation: Objective 27 (Criterion 3.e.1) will need to be demonstrated at Juniata County during the next TMI ingestion exposure pathway exercise.

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