ML18065A198

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Final After Action Report for the Limerick Generating Station Radiological Emergency Preparedness Plume Exercise Held on November 14th, 2017
ML18065A198
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/01/2018
From: Tierney M
US Dept of Homeland Security, Federal Emergency Management Agency
To:
Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML18065A198 (178)
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Text

U.S. Department of Homeland Security Region ill One Independence Mall, 6th Floor 615 Chestnut Street Philadelphia, PA 19106-4404 FEMA Nuclear Regulatory Commission Headquarters

  • office ofNuclear Security and Incident Response Document Control Desk U.S. Nucl<;::ar Regulatory Commission Washington; D.C. 20555-0001 To Whom It May Concern:

Enclosed is the final After Action Report for the Limerick Generating Station Radiological **

Emergency Preparedness Plume Exercise that was held on November 14th, 2017. This report ctlso includes the Mass Care Assessments that were conducted on October30th and 31st, and the Out of Sequence Exercises that were conducted on November 14th and 15th, 2017.

  • There were no Level l Findings identified during the exercise.. There were six Level 2 Findings identified, two of which were successfully re-demonstrated during the exercise night on November 14, 2017. The other four Level 2 Findings were re-demonstrated successfully on February 22, 2018. Also, there was one Planning Issue id~ntified.*

Based on the results of the exercise and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

If you have any questions, please contact Thomas Scardino at (215) 931-5.546.

Sincerely, MaryAnn Tierney Regional Administrator Enclosure www.fema.gov

Limerick Generating Station After Action Report/

Improvement Plan

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station This page is intentionally blank.*

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Unclassified Radiological Emergency Preparedness Program.(REP)

After Action Report/Improvement Plan Limerick Generating Station Limerick Generating Station After Action Report/Improvement Plan Final Published February 26, 2018

  • EXECUTIVE

SUMMARY

.......................................................................................................... 5 SECTION 1: EXERCISE OVERVIEW ..................................................................................... 6 1.1 Exercise Details ......................................................... :........ :........................ .'........................ 6 1.2 Exercise Planning Team Leadership .................................................. :.............................. 6 1.3 Participating Organizations ........................................_. .................................... ;............. ,... 7 SECTION 2: EXERCISE DESIGN

SUMMARY

.................................................................... 15 2.1 Exercise Purpose and Design ..............................................,. ................ *******:********************* 15 2.2 Exercise Objectives, Capabilities and Activities ............................................................. 18 2.3 Scenario Summary ........... '. ..................... .'. ................................................................ .- ........ 18 SECTION 3: ANALYSIS OF CAPABILITIES ....................................................................... 20 3.1 Exercise Evaluation and Results ...................................................................................... 20 3.2 Summary Results of Exercise Evaluation ....................................................................... 20 3.3 Criteria Evaluation Summaries ....................................................................................... 34 3.3.1 State Jurisdictions................. ;........................................................................................ 34 3.3.2 Risk Jurisdictions ...*...... ;...... *.......................................................................................... 36 3.3.3 Support Jurisdictions ............................... , .................................................................... 71 3.3.4 Private Jurisdictions ......................................... ~.: .......................................................... 74 SECTION 4: DEMONSTRATED STRENGTHS ............................................... :.................... 77 4.1 State Jurisdictions ..................................................... ,..................................................... :.77 4.2 Risk Jurisdictions .......................................................... .-................................................:;.77 4.3 Support Jurisdictions ..................................................... ;............................ :............,......... 78 SECTION 5: CONCLUSION .................................................................................................... 79 APPENDIX A: EXERCI.SE TIMELINE .................................................................................. 81 APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS ................................ 87 APPENDIX C: ACRONYMS AND ABBREVIATIONS ........................................................ 98 APPENDIX D: EXTENT OF PLAY AGREEMENT ............................................................ 100 3

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station This page is intentionally blank.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EXECUTIVE

SUMMARY

On November 14, 2017, a full-scale Plume Exposure Pathway exercise was conducted and evaluated for the 10 Mile Emergency Planning Zone (EPZ) around the Limerick Generating Station (LGS) by the Federal Emergency Management Agency (FEMA), Region III. The previous full-scale exercise at this site was evaluated on November 17, 2015.

Out-of-Sequence demonstrations were conducted on November 14 and 15, 2017. The purpose of the Exercise and Out-of-Sequence demonstrations was to assess the capabilities of State, counties, and local jurisdictions to implement Radiological Emergency Plans and Procedures (RERP) to protect the property and lives of residents and transients in the event of an emergency at Limerick Generating Station. The findings in this report are based on the evaluations of the Federal evaluation team, with final determinations made by the FEMA, Region III Regional Assistance Committee (RAC) Chairperson, and approved by FEMA Headquarters. These reports are provided to the Nuclear Regulatory Commission (NRC) and participating States. State and local governments utilize the findings contained in these reports for the purposes of planning, training, and improving emergency preparedness.

The evaluation of this Exercise determined that there were no Level 1 Findings identified during the exercise. There were six Level 2 Findings identified, two of which were successfully re-demonstrated during the exercise night on November 14, 2017. The other four Level 2 Findings were re-demonstrated successfully on February 22, 2018. Also, there was one Planning Issue identified.

A Level 1 Finding is defined by the FEMA Radiological Emergency Preparedness Program Manual as follows: "An observed or identified inadequacy of organizational performance in an

  • exercise that could cause a determination thatoffsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a

. Nuclear Power Plant (NPP)." A Level 2 Finding 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." Finally, a Planning Issue is: "An observed or identified inadequacy in the ORO's emergency plan/implementing procedures, rather than that of the ORO's performance."

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania, risk Counties (Berks, Chester and Montgomery) and support Counties (Bucks and Lehigh). 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 the exercise.

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Unclassificd Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Plume 2017-11-14 Type of Exercise Plume Exercise Date November 14, 2017 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Minimal Release 1.2 Exercise Planning Team Leadership Tina Lai Thomas Emergency Management Specialist, Evaluator Federal Emergency Management Agency 615 Chestnut Street Sixth Floor One Independence Mall Philadelphia, PA, 19106 (215) 931-5680 tina. thomas@fema.dhs.gov Sara Schmidt Emergency Preparedness Specialist Exelon Corporation 200 Exelon Way Kennett Square, PA 19348 Office: 610.765.5036

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan . Limerick Generating Station 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Limerick Generating Station Plume Exercise:

State Jurisdictions Commonwealth of Pennsylvania/Commonwealth Response Coordination Center (CRCC)

  • American Red Cross
  • Auxiliary Communication Services (ACS)
  • Department of Military and Veteran Affairs
  • Pennsylvania Department ofI Conservation and Natural Resources
  • Public Utility Commission
  • United States Postal Service (USPS)
  • Voluntary Organizations Active in Disasters (VOAD)

. PA Joint Information Center/Exelon Joint Information Center

  • Exelon Corporation

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station RISK JlIJRISDICTIONS Berks County Berks County Emergency Operations Center (EOC)

  • American Red Cross
  • Berks County Chief Administration Officer
  • Berks County Department of Education
  • Berks County Department of Emergency Services
  • Berks County Department of Human Resources
  • Berks County Department of Mental Health and Developmental Disabilities
  • Berks County Department of Purchasing
  • Berks County Department of Transportation
  • Berks County Information Systems
  • Berks County 911
  • Berks County Planning Commission
  • Berks County Public Works
  • Berks County Sheriff's Department
  • Civil Air Patrol
  • Exelon
  • Met Ed Electric
  • Radio Amateur Civil Emergency Services (RACES)
  • Reading Hospital
  • St. Joseph's Hospital Boyertown-Colebrookdale (EOC)
  • Boyertown Fire and Rescue
  • Boyertown Department of Transportation
  • Boyertown Emergency Medical Agency
  • - Boyertown Municipal Planning
  • Boyertown Police Department
  • Radio Amateur. Civil Emergency Services (RACES)

Boyertown Borough-Colebrookdale Back-up Route Aierting (1&2)

  • Boyertown Fire and Rescue
  • Boyertown Police Department Earl Township (EOC) 8

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

  • Earl Township Emergency Management Agency
  • Earl Township Board of Supervisors
  • Berks County RACES/ARES Berks County Reception Center (Robeson Townsh~p Building)
  • Gibraltar Fire Company No. 1
  • Robeson Police
  • Robeson Township Berks County Emergency Worker Monitoring/Decontamination (Daniel Boone High School)
  • Birdsboro Union Fire Department Berks County Evacuee Monitoring/Decontamination/Mass Care (Schuylkill Valley High School)
  • American Red Cross
  • Lehigh Valley-Bucks Chapter
  • Tri-County Chapter, American Red Cross
  • Union Fire Company 1 Chester County Chester County Emergency Operations Center (EOC)
  • Chester City First
  • Chester County American Red Cross.
  • Chester County Department of Emergency Services
  • Chester County Department of Human Services
  • Chester County Department of Information Services
  • Chester County Department of Procurement
  • Chester County Sheriff's Department
  • Knowledge Center
  • Philadelphia Police Department Vanguard Charlestown Township EOC
  • Charlestown Township Police and Safety
  • Chester County ARES/ Radio Amateur Civilian Emergency Services (RACES)

East Coventry Township EOC 9

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lmprovemeU:t Plan Limerick Generating Station

  • East Coventry Township Police Department .
  • East Coventry Township Public Works Departments
    • Radio Amateur Civil Emergency Services (RACES)
  • Ridge Fire Company East Pikeland Township EOC
  • Chester County ARES/ Radio Amateur Civilian Emergency Services (RACES)
  • East Pikeland Emergency Management Agency
  • East Pikeland Township Police Department
  • East Pikeland Transportation Department
  • Kimberton Volunteer Fire Department Schuylkill Township EOC
  • Chester County ARES/RACES
  • . Chester County Department of Emergency Services
  • Schuylkill Township Police Department
  • Valley Forge Fire'Department Uwchlan Township EOC
  • Chester County ARES/RACES
  • Uwchlan Township Police Department
  • Uwchlan Ambulance Township
  • Lionville Fire Company .
  • Uwchlan Township Chair
  • Uwchlan Township Supervisor
  • Uwchlan Township Manager West Vincent Township EOC
  • Chester County ARES/RACES
  • Ludwigs Corner Fire Company
  • West Vincent Communications
  • West Vincent Police Department
  • West Vincent Township Emergency Operations Center Chester County Reception Center/Evacuee Monitoring/Decontamination Station
  • West Whiteland Fire Department 10

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester County Emergency Worker Monitoring/Decontamination Station (Twin Valley Fire Dept.)

  • Twin Valley Fire Department Chester County Schools
  • Chester County Department of Emergency Services
  • Downingtown Area School District
  • Lionville Elementary School
  • Uwchlan Hills Elementary School
  • Lionville Middle School
  • Downingtown High School East
  • Great Valley School District
  • Great Valley Middle School
  • Great Valley High School
  • Owen J. Roberts School District
  • French Creek Elementary School
  • East Vincent Elementary School
  • . West Vincent Elementary School
  • Phoenixville Area School District
  • Manavon Elementary School & Phoenixville Area Early Learning Ctr.

Montgomery County Montgomery County Emergency Operations Center

  • American Red Cross Southeast PA Chapter
  • Montgomery County ARES/RACES
  • Montgomery County Critical Incident Stress Management Team
  • Montgomery County Emergency Communications Division
  • Montgomery County Emergency Management
  • Montgomery County HAZMAT Response Team
  • Montgomery County Health Department
  • Montgomery County Office of Emergency Medical Service~
  • Greenlane Borough Council / Board of Supervisors 11

Unclassified Radiological Emergency Preparedne~s Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

  • Greenlane Fire Department
  • Harleysville Area Emergency Medical Services
  • Marlborough Police Department
  • Marlborough Township
  • Radio Amateur Civilian Emergency Services (RACES)

Limerick Township EOC

  • ARES/ Radio Amateur Civilian Emergency Services (RACES) *
  • Friendship Ambulance
  • Limerick Fire Company
  • Limerick Police Department
  • Trappe Emergency Medical Services Lower Frederick Township EOC
  • Lower Frederick Township Fire Service
  • Lower Frederick Township Health and Medical Services (EMS)
  • Lower Frederick Township Police Department
  • Lower Frederick Township Public Works Department
  • Radio Amateur Civilian Emergency Services (RACES)

Lower Pottsgrove Township EOC

  • ARES/ Radio All).ateur Civilian Emergency Services (RACES)
  • Lower Pottsgrove Emergency Management
  • Lower Pottsgrove Police Department

.* Lower Pottsgrove Fire Marshall New Hanover Township EOC

  • New Hanover Police Department Perkiomen Township EOC
  • Perkiomen Township Emergency Management Agency
  • Perkiomen Township Fire Depaitment
  • Perkiomen Township Public Works Trappe Borough EOC
  • Radio Amateur Civil Emergency Services (RACES)
  • Trappe Borough Council 12

Unclassified

. Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

  • Trappe Borough Emergency Management Agency
  • Trappe Borough Emergency Medical Services
  • Trappe Borough Fire Company Montgomery County Evacuee Monitoring/Decontamination Station (Plymouth)
  • Exelon
  • Plymouth Fire Company Montgomery County EW Monitoring/Decontamination Station (Indian Valley Middle School)
  • Telford Volunteer Diving and Rescue Unit Montgomery County Schools
  • Methacton Area School District
  • Methacton Senior High School
  • Woodland Elementary School
  • Eagleville Elementary School
  • Perkiomen Valley School District
  • Perkiomen Valley Middle School East
  • South Elementary School
  • Pottsgrove School District
  • Pottsgrove High School
  • West Pottsgrove Elementary School
  • Pottstown Area School District
  • Lincoln Elementary School
  • Pottstown High School
  • Souderton Area School District
  • Salford Hills Elementary School
  • Spring Ford Area School District
  • Spring-Ford Area High School
  • Upper Providence Elementary School
    • 5th & 6th Grade Center
  • 7th Grade Center
  • 8th Grade Center
  • Upper Perkiomen School District
  • Upper Perkiomen High School
  • Upper Perkiomen Middle School
  • Marlborough Elementary School 13

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station SUPPORT JURISDICTIONS Bucks County Bucks County Emergency Operations Center (EOC)

  • American Red Cross
  • Bucks County Board of Commissioners
  • Bucks County Department of General Services
  • Bucks County Emergency Medical Services
  • Bucks County Fire Department
  • Bucks County Health Department
  • Bucks County Sheriff's Department
  • Bucks County Voluntary Organizations Active in Disasters (VOAD)

Lehigh County Lehigh County Emergency Operations Center

  • American Red Cross
  • Catasauqua Fire Department
  • Lehigh County Emergency Management Agency
  • Lehigh County Sheriff's Department
  • Lehigh Valley Animal Rescue Team
  • Lower Macungie Emergency Management Agency
  • Radio Amateur Civil Emergency Services (RACES)
  • Saint Luke's Hospital Lehigh County Reception Center/Monitoring/Decontamination/Mass Care Center (Southern Lehigh High School)
  • American Red Cross
  • Lehigh County Emergency Management Agency
  • Lehigh County Special Operations
  • Upper Saucon Fire Department
  • Upper Saucon Police Department 14

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station SECTION 2: EXERCISE DESIGN

SUMMARY

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

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

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

A. 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; B. Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises conducted by State and local governments; C. Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated December 7, 2015 Federal Register, Vol. 81, No. 57, March 24, 2016); and D. 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 Region III Regional Assistance Committee (RAC), which is chaired by FEMA. A REP Plume Exposure Pathway Exercise was conducted 15

Un classified Radiological Emergency Preparedl}ess Program (REP)

After Action Report/Improvement Plan Limerick Generating Station during the week of November 13, 2017, 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 Limerick Generating Station (LGS). The purpose of this exercise report is to present th.e exercise results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency. The findings presented in this report are based on the evaluations of the Federal evaluation team, with final determinations made by the FEMA Region III RAC Chairperson and approved by FEMA Headquarters.

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

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

  • NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, "November 1980;
  • Radiological Emergency Preparedness Program Manual, January 2016; Section 1 of this report, entitled "Exercise Overview," presents the "Exercise Planning Team" and the "Participating Organizations."

Section 2 of this report entitled "Exercise Design Summary", and includes the "Exercise Purpose and Design", "Exercise Objectives, Capabilities and Activities", and the "Scenario Summary".

Section 3 of this report, entitled "Analysis of Capabilities", presents detailed "Exercise Evaluation and Results" information on the demonstration for each jurisdiction or functional entity evaluated in a jurisdiction-based, issue-only format (Criteria Evaluation Summaries).

Section 4 of this report entitled "Demonstrated Strengths" includes exemplary performances that were demonstrated during the exercise and information on best practices that were observed.

Section 5 of this report entitled "Conclusion" presents a summary of the findings and performance of the evaluated agencies.

The appendices, present supplementary information that is relevant to the exercise. They include:

Appendix A - Exercise Timeline. A table that depicts the times when an event or notifications were noted at participating agencies and locations.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Appendix B - Exercise Evaluators and Team leaders. A table listing the evaluator names, organizations, and responsibilities of the evaluators and management.

Appendix C - Acronyms and Abbreviations. An alphabetized table defining the formal names used in this report.

Appendix D-Extent of Play Agreement Emergency Planning Zone

Description:

Limerick Generating Station (LGS) is located in southeastern Pennsylvania on the Schuylkill River about 1.7 miles southeast of Pottstown Borough: The river passes through the site, separating the western portion, which is in East Coventry Township in Chester County, from the eastern p0rtion, which is in Limerick and Lower Pottsgrove Townships in Montgomery County.

The plant is owned and operated by Exelon Nuclear. Two boiling water reactors each generate an electrical output of 1,050 megawatts (MW). Unit 1 was issued a full-power license in August 1985; commercial operations began in February 1986. Unit 2 was issued a full-power license in August 1989 with commercial operations beginning in January 1990.

The site encompasses 595 acres and is divided into three (3) parts. The principal portion, where the major operating equipment and buildings are located, is on the east bank of the Schuylkill River. This portion is separated from the second segment, where the cooling water intake is located, near the main line of the Reading Railroad. The third portion lies on the west bank of the river, adjacent to Conrail railroad tracks. The site coordinates are approximately 40°13'27"N and 75°35'15"W.

The minimum exclusion distance for the LGS is 2,500 feet from the center of each reactor. The utility owns all the land within the exclusion area. No private residences are located within the exclusion area; however, some farming may be permitted.

There are 165 sirens installed to cover the 10-mile. plume exposure pathway EPZ. These sirens are activated three (3) minutes before the Emergency Alert System (EAS) messages issued by the Commonwealth of Pennsylvania are broadcast. Soils in this area are of the Reaville-Penn-Klinesville Association and are characteristic of rolling uplands. They are underlain by sedimentary rocks of the Brunswick Formation, consisting mostly of red shale with some fine-grained sandstone interbedding. The normal pool elevation of the Schuylkill River in this area is 200 feet above mean sea level (msl). The topography of the area is hilly, with elevations ranging from 100-300 feet above msl within five (5) miles of the site. The plant is approximately 217 feet above msl.

The climate in this area is dominated by prevailing westerly winds that produce humid, continental-type weather characterized by warm summers and moderately cold winters.

Montgomery County is the warmest part of Pennsylvania, with an average annual temperature of 17

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 57°F. Annual precipitation is approximately 42 inches. The area in the immediate vicinity of the plant is made up mostly of agricultural and other open land. The Pottstown Borough in Montgomery County is the nearest community. The nearest major population center (more than 25,000 people) is Philadelphia that lies 25 miles to the southeast of the site.

Two major industries employ a total of 850 persons within two (2) miles of the plant. Two small airfields are also located nearby. A small private airfield is about one (1) mile to the northeast, but its runway is oriented so that the flight path does not pass over the plant. The Pottstown ,

Municipal Airport is 4.3 miles northwest of the site. The LGS does not lie in the approach pattern for this airport. No major thoroughfares are located in the immediate vicinity of the plant. The main line of the Reading Railroad runs along the north bank of the Schuylkill River and traverses the site about 500 feet from the plant.

2.2 Exercise Objectives, Capabilities and Activities The objective of the 2017 Limerick Generating Station (LOS) Plume Exercise were to demonstrate the capabilities of State and local emergency management agencies to mobilize emergency management and emergency response personnel, to activate emergency operations centers and support facilities, and to protect the health, lives, and property of the citizens residing within the 10 mile Emergency Planning Zone (EPZ).

To demonstrate the ability to communicate between multiple levels of government and provide timely, accurate, and sufficiently detailed information to the public, the emergency management agencies use a variety of resources, including radios, telephones, the Internet, the media, the Emergency Alert System (EAS), and the utility Alert and Notification System (ANS) Sirens. All of these communication resources were employed and evaluated. The EAS and ANS were simulated a11d media information was prepared but not actually released.

An essential capability of the Radiological Emergency Preparedness Program (REPP) is to evacuate, monitor and decontaminate, if necessary, and provide temporary c.are and shelter to displaced residents from the EPZ. The ability of the risk/support counties to mobilize personnel and resources to establish reception, monitoring and decontamination, and mass care centers was demonstrated.

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

2.3 Scenario Summary DHS/FEMA Region III, Limerick 2017 Plume Exposure pathway Exercise - November 14, 2017 18

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station LGS Unit 1 a boiling water reactor was operating at 100 percent power. The wind direction was from 270 de,grees (W) into the East at 6 miles per hour. The atmospheric stability class was E, slightly stable. The weather forecast was for the wind direction to be from the south west (SW).

On or before 1620, an Unusual Event was declared based on emergency action level (EAL)

RU3, the reactor coolant radioactivity exceeded the technical specification allowable level.

On or before 1705, an ALERT was declared in accordance with EAL MA3, automatic or manual actions in the control room failed to shut the reactor down.

On or before 1815, a Site Area Emergency was declared in accordance with EAL FS 1,. loss of two*fission product barriers, the reactor coolant system and reactor containment.

On or before 1935, a General Emergency was declared. based on EAL FG 1, loss of any two fission product barriers and the loss or potential loss of the third barrier. A radiation release from the reactor building to the main stack continued.

The Commonwealth of Pennsylvania Emergency Management Agency (PEMA), Bureau of Radiation Protection and county and local agencies implemented protective response strategies based on recommendations from utility representatives and State dose/accident assessment teams.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station SECTION 3:.ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the November 14, 2017, biennial Plume Exposure Pathway EPZ Radiological Emergency Preparedness (REP) Exercise, and the Out of Sequence Exercise evaluations on October 30th and 3 !5\ November 14th and 15th, 2017. The exercise was conducted to demonstrate the ability of the Offsite Response Organizations of State and local government to protect the health and safety of the public in the 10 mile Emergency Planning Zone surrounding the Limerick Generating Station.

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

Detailed information on the exercise evaluation area criteria and the Extent of Play Agreement can be found in the Exercise Plan.

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Program Manual that was scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise evaluation area criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters:

(D) Demonstrated Strength: an observed action, behavior, procedure, and/or practice that is worthy of special notice and positive recognition, Note: this is already a common practice that many Regions employ when identifying demonstrated strengths. * *

(Ll) Level 1 Finding: an observed or identified inadequacy or organizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant (NPP).

(L2) Level 2 Finding: an observed or identified inadequacy of organizational performance in ai:i exercise that is not considered, by itself, to adversely impact public health and safety.

(P) Plan Issue: an observed or identified inadequacy in the offsite response organizations' (OROs) emergency plan/implementation procedures, rather than that of the ORO's performance.

(N) Not Demonstrated: term applied to the status of a REP exercise Evaluation Area Criterion indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area Criterion, as required in the extent-of-play agreement or at the two-year or eight-year interval required in the FEMA REP Program Manual.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station (M) Met: The jurisdiction or functional entity performed all activities under the Demonstration Criterion to the level required in the Extent-of-Play Agreement, with no Level 1 or Level 2 Findings assessed under that criterion in the current exercise and no unresolved prior Level 2 Findings.

  • 21

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Tables 3.1 - Summary of Exercise Evaluation Table 3.la - Exercise Evaluation by Classification Date: November 14, 2017 Site: Limerick Generatin*g Station t ~.Critericl*Title. . ; ,: . Criteria  : Class.fficatio.n

  • BrCo UTwp EOC Implementation ofEmergency Worker Exposure Control 3al L2 Re-demonstrated Successfully BrCoByrCbrkEOC Activation of the Back-up ANS sa3 p CCECTEOC Implementation of Emergency Worker Exposure Control 3al L2 Re-demonstrated Successfully CCECTEOC Direction and Control lcl L2 Re-demonstrated Successfully MCTrpBrEOC Mobilization lal L2 Re-demonstrated Successfully MCTrpBrEOC Implementation ofEmergency Worker Exposure Control 3al L2 Re-demonstrated Successfully MCGLMrlbrTwpEOC Implementation of Emergency Worker Exposure Control 3al L2 Re-demonstrated Successfully Table 3.lb- Exercise Evaluation - Criteria Not Demonstrated Date: November 14, 2017 Site: Limerick Generating Station

. Location'-Abbreviation* . .. .. * *Criteria Title *

~

--;7 Criteria .*. .

f' ~ .. ,*. .

BRPR3V Mobilization lal BRPR3V '* Communications Equipment ldl BRPR3V Equipment and Supplies to Support Operations lel BRPR3V Implementation of Emergency Worker Exposure Control 3al BRPR3V Field Team Management 4a2 CCECTEOC Implementation of KIP AD for Institutionalized Individuals/Public 3bl CC WVncntTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl EJIC Communications Equipment ldl EJIC Equipment and Supplies to Support Operations lel EJIC Emergency Information & Instructions for the Public/Media 5bl PA JIC/RumCon Mobilization lal PA JIC/RumCon Communications Equipment ldl PA JIC/RumCon Emergency Information & Instructions for the Public/Media 5bl PAAACSEOCBRP Mobilization lal PAAACSEOCBRP Direction and Control lei PAAACSEOCBRP Communications Equipment ldl PAAACSEOCBRP Equipment and Supplies to Support Operations lel PAAACSEOCBRP Emergency Worker Exposure Control Decisions 2al PAAACSEOCBRP Accident Assessment and P ARs for the Emergency Event 2bl P AAACSEOCBRP PAD decision-making process and coordination for the General Public 2b2 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station PACRCC Mobilization lal PACRCC Communications Equipment ldl PACRCC Equipment and Supplies to Support Operations lel SFMT ASER Mobilization 1a1 SFMT ASER Communications Equipment ldl SFMTASER Equipment and Supplies to Support Operations lel SFMT ASER Implementation of Emergency Worker Exposure Control 3al SFMT ASER Plume Phase Field Measurement, Handling, & Analyses 4a3 SFMTB SER Communications Equipment ldl SFMTB SER Equipment .and Supplies to Support Operations lel SFMTB SER Implementation of Emergency Worker Exposure Control 3al SFMTB SER Plume Phase Field Measurement, Handling, & Analyses 4a3 Table 3.lc - Exercise Evaluation - Criteria Met Date: November 14, 2017 Site: Limerick Generating Station

.... .Loca!i8!1/Abbr~jatio':.

j\ ' .. .::. . ,: . -1*,iJ,:;" -. i ...?.:C::rite,ri/!::f:itle .. .;::, . b*** . . . :: *,*: ..; .. .. :: ,:.-. ,; ... Crit~~i.~...

BkCo EOC (S) Mobilization lal BkCoEOC (S) Direction and Control lcl BkCoEOC (S) Communications Equipment ldl BkCoEOC (S) Equipment and Supplies to Support Operations lel BkCoEOC (S) Emergency Information & Instructions for the Public/Media 5bl BrCo BASD ' Implementation of PADs for Schools 3c2 BrCo BASD ByrtwnSHS Implementation of PADs for Schools 3c2 BrCo BASD EES Implementation of PADs for Schools 3c2 BrCo BASD NH/UFES Implementation of PADs for Schools 3c2 BrCo BASD WES Implementation of PADs for Schools 3c2 BrCo DBASD Implementation of PADs for Schools 3c2 BrCo EOC Implementation of KI PAD for Institutionalized Individuals!Public 3bl BrCo EOC Implementation of P ADs for disabilities & access/functional needs people 3cl BrCoEOC Implementation of PADs for Schools 3c2 BrCoEOC Implementation of Traffic & Access Control 3dl BrCoEOC Impediments to Evacuation 3d2 BrCoEOC Mobilization lal BrCo EOC Communications Equipment ldl BrCo EOC Direction and Control lcl BrCoEOC Equipment and Supplies to Support Operations lel BrCoEOC Implementation of Emergency Worker Exposure Control 3al BrCoEOC Activation of the Prompt Alert & Notification System 5al BrCoEOC Activation of the Back-up ANS 5a3 BrCoEOC PADs for disabilities & access/functional needs people 2cl BrCoEOC Emergency Information & Instructions for the Public/Media 5bl BrCo Er!Twp EOC Implementation of KI PAD for Institutionalized Individuals!Public 3bl 23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station BrCo Er!Twp EOC Mobilization lal BrCo Er!Twp EOC Communications Equipment ldl BrCo ErlTwp EOC Equipment and Supplies to Support Operations lel BrCo ErlTwp EOC Implementation of PADs for Schools 3c2 BrCo ErlTwp EOC Direction and Control lcl BrCo Er!Twp EOC Implementation of PADs for disabilities & access/functional needs people 3cl BrCo Er!Twp EOC Implementation of Traffic & Access Control 3dl BrCo Er!Twp EOC Impediments to Evacuation 3d2 BrCo Er!Twp EOC Implementation of Emergency Worker Exposure Control 3al BrCo EWNIDS DBC Direction and Control lcl BrCo EWNIDS DBC Communications Equipment ldl BrCo EWNIDS DBC Implementation ofEmergency Worker Exposure Control 3al BrCo EWNIDS DBC Equipment and Supplies to Support Operations lel BrCo EWNIDS DBC Monitoring/Decontamination of Emergency Workers/Equipment/Vehicles 6bl BrCO MDC GMSHS Direction and Control lcl BrCO MDC GMSHS Communications Equipment ldl BrCO MDC GMSHS Implementation of Emergency Worker Exposure Control 3al BrCO MDC GMSHS Equipment and Supplies to Support Operations lel BrCO MDC GMSHS Monitoring, Decontamination, & Registration of Evacuees 6al BrCo MDC MSHS Direction and Control lcl BrCo MDC MSHS Communications Equipment ldl BrCo MDC MSHS Equipment and Supplies to Support Operations lel BrCo MDC MSHS Implementation of Emergency Worker Exposure Control 3al BrCo MDC MSHS Monitoring, Decontamination, & Registration of Evacuees 6al BrCo MDC Sclk!VlySCplx Direction and Control lcl BrCo MDC SclklVlySCplx Communications Equipment ldl BrCo MDC SclklVlySCplx Equipment and Supplies to Support Operations lel BrCo MDC SclklVlySCplx Implementation of Emergency Worker Exposure Control 3al BrCo MDC SclklVlySCplx Monitoring, Decontamination, & Registration of Evacuees 6al BrCo RC RobTwpBldg. Communications Equipment ldl BrCo RC RobTwpBldg Equipment and Supplies to Support Operations lel BrCo RC RobTwpBldg Implementation of Emergency Worker Exposure Control 3al BrCo RC RobTwpBldg Monitoring, Decontamination, & Registration of Evacuees 6al BrCo UTwp EOC Mobilization lal BrCo UTwp EOC Direction and Control lcl BrCo UTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl BrCo UTwp EOC Implementation of PADs for Schools 3c2 BrCo UTwp EOC Implementation of Traffic & Access Control 3dl BrCo UTwp EOC Communications Equipment ldl BrCo UTwp EOC Implementation ofPADs for disabilities & access/functional needs people 3cl BrCo UTwp EOC Impediments to Evacuation 3d2 BrCo UTwp EOC Equipment and Supplies to Support Operations lel BrCo UTwp EOC Implementation of Emergency Worker Exposure Control 3al BrCoByrCbrkEOC Mobilization lal 24.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station BrCoByrCbrkEOC Direction and Control lcl BrCoByrCbrkEOC Comi;nunications Equipment ldl BrCoByrCbrkEOC Equipment and Supplies to Support Operations lel BrCoByrCbrkEOC Implementation of Emergency Worker Exposure Control 3al BrCoByrCbrkEOC Implementation of KI PAD for Institutionalized Individuals!Public 3bl BrCoByrCbrkEOC Implementation of P ADs for disabilities & access/func;tional needs people 3cl BrCoByrCbrkEOC Implementation of PADs for Schools 3c2 BrCoByrCbrkEOC Implementation of Traffic & Access Control 3dl BrCoByrCbrkEOC Impediments to Evacuation 3d2 BrCoByrCbrkEOC Activation of the Back-up ANS 5a3 BrCoByrCbrkTACP Communications Equipment ldl BrCoByrCbrkTACP Equipment and Supplies to Support Operations lel BrCoByrCbrkTACP Implementation of Emergency Worker Exposure Control 3al BrCoByrCbrkTACP Implementation of Traffic & Access Control 3dl BrCoDBASDBdsbrES Implementation of PADs for Schools 3c2 BrCoMCCGMSHS Direction and Control lcl BrCoMCCGMSHS Communications Equipment ldl BrCoMCCGMSHS Equipment and Supplies to Support Operations lel BrCoMCCGMSHS Temporary Care of Evacuees 6cl BrCoMCCMSHS Equipment and Supplies to Support Operations lel BrCoMCCMSHS Temporary Care of Evacuees 6cl BrCoMCCMSHS Direction and Control lcl BrCoMCCMSHS Communications Equipment ldl BrCoMCCSVSC Direction and Control lcl BrCoMCCSVSC Communications Equipment ldl BrCoMCCSVSC Equipment and Supplies to Support Operations lel BrCoMCCSVSC Temporary Care of Evacuees 6cl BRPR3V Mobilization lal BRPR3V Communications Equipment ldl BRPR3V Equipment and Supplies to Support Operations lel BRPR3V Implementation of Emergency Worker Exposure Control 3al BRPR3V Field Team Management 4a2 BuCoMDCTFC Direction and Control lcl BuCoMDCTFC Communications Equipment ldl BuCoMDCTFC Equipment and Supplies to Support Operations lel BuCoMDCTFC Implementation of Emergency Worker Exposure Control 3al BuCoMDCTFC Monitoring, Decontamination, & Registration of Evacuees 6al BuCoRCTFC Monitoring, Decontamination, & Registration of Evacuees 6al BuCoRCTFC Communications Equipment

  • ldl BuCoRCTFC Equipment and Supplies to Support Operations lel BuCoRCTFC Implementation of Emergency Worker Exposure Control 3al ByrCbrkBURA (1) Mobilization lal ByrCbrkBURA (1) Communications Equipment ldl ByrCbrk BURA (1) Equipment and Supplies to Support Operations lel 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station ByrCbrk BURA (1) Implementation of Emergency Worker Exposure Control 3al ByrCbrk BURA (2) Mobilization lal ByrCbrk BURA (2) Communications Equipment ldl ByrCbrk BURA (2) Equipment and Supplies to Support Operations lel ByrCbrk BURA (2) Implementation of Emergency Worker Exposure Control 3al CC CtwnEOC Mobilization lal CC CtwnEOC Equipment and Supplies to Support Operations lel CC CtwnEOC Implementation of Emergency Worker Exposure Control 3al CC CtwnEOC Communications Equipment ldl CC CtwnEOC Implementation of PADs for Schools 3c2 CC CtwnEOC Implementation of PADs for disabilities & access/functional needs people 3cl CC CtwnEOC Direction and Control lcl CC CtwnEOC Implementation of Traffic & Access Control 3dl CC CtwnEOC Impediments to Evacuation 3d2 CC CtwnEOC Implementation ofKI PAD for Institutionalized Individuals/Public 3bl CCDASD Implementation-of PADs for Schools 3c2 CCDASDDHSE Implementation of PADs for Schools 3c2 CCDASDLES Implementation of PADs for Schools 3c2 CCDASDLMS Implementation of PADs for Schools 3c2 CCDASDUHES Implementation of P ADs for Schools 3c2 CCECTEOC Implementation of P ADs for disabilities & access/functional needs people 3cl CCECTEOC Implementation of Traffic & Access Control 3dl CCECTEOC Implementation of P ADs for Schools ~c2 CCECTEOC Mobilization lal CCECTEOC Implementation of Emergency Worker Exposure Control 3al CCECTEOC Impediments to Evacuation 3d2 CCECTEOC Direction.and Control lcl CCECTEOC Communications Equipment ldl CCECTEOC Equipment and Supplies to Support Operations lel CCECTEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl CC ECvntryTwp TACP Implementation of Traffic & Access Control 3dl CC ECvntryTwp TACP Communications Equipment ldl CC ECvntryTwp T ACP Equipment and Supplies to Support Operations lel CC ECvntryTwp TACP Implementation of Emergency Worker Exposure Control 3al CCEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl CCEOC Implementation of PADs for Schools 3c2 CCEOC Impediments to Evacuation 3d2 CCEOC Implementation of Traffic & Access Control 3dl CCEOC Implementation of PADs for disabilities & access/functional needs people 3cl CCEOC Mobilization lal CCEOC Implementation of Emergency Worker Exposure Control 3al CCEOC Communi.cations Eqt!ipment ldl CCEOC Equipment and Supplies to Support Operations lel CCEOC Activation of the Prompt Alert & Notification System 5al 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station CCEOC Activation of the Back-up ANS 5a3 CCEOC PADs for disabilities & access/functional needs people 2cl CCEOC Emergency Information & Instructions for the Public/Media 5bl CCEOC Direction and Control lcl CC EPklndTwp TACP Communications Equipment ldl CC EPklndTwp T ACP _Equipment and Supplies to Support Operations lel CC EPklndTwp TACP Implementation of Traffic & Access Control 3dl CC EPklndTwp T ACP Implementation of Emergency Worker Exposure Control 3al CC EWJ\IDS TVFD Direction and Control lcl CC EWJ\IDS TVFD Communications Equipment ldl CC EWJ\IDS TVFD Equipment and Supplies to Support Operations lel CC EWJ\IDS TVFD Implementation of Emergency Worker Exposure Control 3al CC EWJ\IDS TVFD Monitoring/Decontamination of Emergency Workers/Equipment/Vehicles 6bl CCGVSD Implementation of PADs for Schools 3c2 CCGVSDGVHS Implementation of P ADs for Schools 3c2 CCGVSDGVMS Implementation of PADs for Schools 3c2 CC l\IDC WWhtlnd

  • Communications Equipment ldl CC l\IDC WWhtlnd Implementation of Emergency Worker Exposure Control 3al CC l\IDC WWhtlnd Monitoring, Decontamination, & Registration of Evacuees 6al CC l\IDC WWhtlnd Direction and Control lcl CC l\IDC WWhtlnd Equipment and Supplies to Support Operations lel CCPASD Implementation of P ADs for Schools 3c2 CC P ASD MES & P AELC Implementation of PADs for Schools 3c2 CCRCWWTwp Communications Equipment ldl CCRCWWTwp Equipment and Supplies to Support Operations lel CCRCWWTwp Implementation ofEmergency Worker Exposure Control 3al CCRCWWTwp Monitoring, Decontamination, & Registration of Evacuees 6al CC SchlkTwp EOC Mobilization lal CC SchlkTwp EOC Implementation of PADs for Schools 3c2 CC SchlkTwp EOC Implementation of Traffic & Access Control 3dl CC SchlkTwp EOC Impediments to Evacuation 3d2 CC SchlkTwp EOC Direction and Control lcl CC SchlkTwp EOC Communications Equipment ldl CC SchlkTwp EOC Equipment and Supplies to Support Operations lel CC SchlkTwp EOC Implementation of Emergency Worker Exposure Control 3al CC SchlkTwp EOC Implementation of KIP AD for Institutionalized Individuals/Public 3bl CC SchlkTwp EOC Implementation of PADs for disabilities & access/functional needs people 3cl CC SchlkTwp T ACP Communications Equipment ldl CC SchlkTwp T ACP Implementation of Emergency Worker Exposure Control 3al CC SchlkTwp TACP Implementation of Traffic & Access Control 3dl CC SchlkTwp TACP Equipment and Supplies to Support Operations lel CCUTwpTACP Communications Equipment ldl CCUTwpTACP Equipment and Supplies to Support Operations lel CCUTwpTACP Implementation of Traffic & Access Control 3dl 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station CCUTwpTACP Implementation of Emergency Worker Exposure Control 3al CC WVncntTwp EOC Implementation of KI PAD for Institutionalized Individuals!Public 3bl CC WVncntTwp EOC Mobilization lal CC WVncntTwp EOC Direction and Control lcl CC WVncntTwp EOC Communications Equipment ldl CC WVncntTwp EOC Implementation of P ADs for Schools 3c2 CC WVncntTwp EOC Implementation of PADs for disabilities & access/functional needs people 3cl CC WVncntTwp EOC Equipment and Supplies to Support Operations lel CC WVncntTwp EOC Implementation of Emergency Worker Exposure Control 3al CC WVncntTwp EOC Implementation of Traffic & Access Control 3dl CC WVncntTwp EOC Impediments to Evacuation 3d2 CC WVncntTwp EOC Activation of the Back-up ANS 5a3 CC WVncntTwp TACP Equipment and Supplies to Support Operations lel CC WVncntTwp TACP Communications Equipment ldl CC WVncntTwp TACP Implementation of Emergency Worker Exposure Control 3al CC WVncntTwp TACP Implementation of Traffic & Access Control 3dl CCEPTEOC Impediments to Evacuation 3d2 CCEPTEOC Direction and Control lcl CCEPTEOC Implementation of PADs for Schools 3c2 CCEPTEOC Implementation of Traffic & Access Control 3dl CCEPTEOC Mobilization lal CCEPTEOC Implementation of KI PAD for Institutionalized Individuals!Public 3bl CCEPTEOC Equipment and Supplies to Support Operations lel CCEPTEOC Implementation ofPADs for disabilities & access/functional needs people 3cl CCEPTEOC Communicati9ns Equipment ldl CCEPTEOC Implementation of Emergency Worker Exposure Control 3al CCOJRSD Implementation of PADs for Schools 3c2 CCOJRSDEVES Implementation ofPADs for Schools 3c2 CCOJRSDFCES Implementation of PADs for Schools 3c2 CCOJRSDWVES Implementation of P ADs for Schools 3c2 CCUclanTwpEOC Mobilization lal CCUclanTwpEOC Implementation of Traffic & Access Control 3dl CCUclanTwpEOC Communications Equipment ldl CCUclanTwpEOC Impediments to Evacuation 3d2 CCUclanTwpEOC Equipment and Supplies to Support Operations lel CCUclanTwpEOC Implementation of P ADs for Schools 3c2 CCUclanTwpEOC Implementation of P ADs for disabilities & access/functional needs people

  • 3cl CCUclanTwpEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl CCUclanTwpEOC Direction and Control lcl CCUclanTwpEOC Implementation of Emergency Worker Exposure Control 3al EJIC Communications Equipment ldl EJIC Equipment and Supplies to Support Operations lel EJIC Emergency Information & Instructions for the Public/Media Sbl LhCo EOC (S) Communications Equipment ldl 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station LhCoEOC (S) Equipment and Supplies to Support Operations lel LhCo EOC (S) Direction and Control lcl LhCoEOC (S) Mobilization lal LhCo EOC (S) Emergency Information & Instructions for the Public/Media 5bl LhCo MDC SLHS Direction and Control lcl LhCo MDC SLHS Communications Equipment ldl LhCo MDC SLHS Equipment and Supplies to Support Operations lel LhCo MDC SLHS Implementation of Emergency Worker Exposure Control 3al

. LhCo MDC SLHS Monitoring, Decontamination, & Registration of Evacuees 6al LhCoRC SLHS Communications Equipment ldl LhCoRC SLHS Equipment and Supplies to Support Operations lei LhCoRC SLHS Implementation of Emergency Worker Exposure Control 3al LhCoRC SLHS Monitoring, Decontamination, & Registration of Evacuees 6al LhCoMCCSLHS Direction and Control lei

.LhCoMCCSLHS Communications Equipment ldl LhCoMCCSLHS Equipment and Supplies to Support Operations lel LhCoMCCSLHS Temporary Care. of Evacuees 6cl LimTown BURA (1) Mobilization la!

LimTown BURA (1) Communications Equipment !di LimTown BURA (1) Equipment and Supplies to Support Operations lel LimTown BURA (1) Implementation of Emergency Worker Exposure Control 3al LimTown BURA (1) Activation of the Back-up ANS 5a3 LimTown BURA (2) Mobilization Jal LimTown BURA (2) Communications Equipment ldl LimTown BURA (2) Equipment and Supplies to Support Operations lel LimTown BURA (2) Implementation of Emergency Worker Exposure Control 3al LiinTown BURA (2) Activation of the Back-up ANS 5a3 LowPtgv Twn T ACP Communications Equipment ldl LowPtgv Twn TACP Equipment and Supplies to Support Operations lei LowPtgv Twn TACP Implementation of Emergency Worker Exposure Control 3al LowPtgv Twn T ACP Implementation of Traffic & Access Control 3dl MCEOC Implementation of Emergency Worker Exposure Control 3al MCEOC Activation of the Prompt Alert & Notification System Sal MCEOC Activation of the Back-up ANS 5a3 MCEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MCEOC Implementation of PADs for disabilities & access/functional needs people 3cl MCEOC Implementation of P ADs for Schools 3c2 MCEOC Implementation of Traffic & Access Control 3dl MCEOC Impediments to Evacuation 3d2 MCEOC Emergency Information & Instructions for the Public/Media 5bl MCEOC Mobilization !al MCEOC Communications Equipment ldl MCEOC Equipment and Supplies to Support Operations lel MCEOC PADs for disabilities & access/functional needs people 2cl 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station MCEOC Direction and Control lcl MCEVMDCPFC Direction and Control lcl MCEVMDCPFC Communications Equipment ldl MC EVMDC*PFC Equipment and Supplies to Support Operations lel MCEVMDCPFC Implementation of Emergency Worker Exposure Control 3al MCEVMDCPFC Monitoring, Decontamination, & Registration of Evacuees 6al MC EWMDS IVMS Direction and Control lcl MC EWMDS IVMS Communications. Equipment ldl MC EWMDS IVMS Implementation of Emergency Worker Exposure Control 3al MC EWMDS IVMS Equipment and Supplies to Support Operations lel

.MC EWMDS IVMS Monitoring/Decontamination of Emergency Workers/Equipment/Vehicles 6bl MCLFTWPEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MCLFTWPEOC Implementation of PADs for disabilities & access/functional needs people 3cl MCLFTWPEOC Mobilization lal MCLFTWPEOC Implementation of PADs for Schools 3c2 MCLFTWPEOC Direction and Control lcl MCLFTWPEOC Communications Equipment ldl MCLFTWPEOC Equipment and Supplies to Support Operations lel MCLFTWPEOC Implementation of Emergency Worker Exposure Control 3al MCLFTWPEOC Implementation of Traffic & Access Control 3dl MCLFTWPEOC Impediments to Evacuation 3d2 MC LmkTwp TACP Communications Equipment ldl MC LmkTwp TACP Equipment and Supplies to Support Operations I lel MC LmkTwp TACP Implementation of Emergency Worker Exposure Control 3al MC LmkTwp TACP Implementation of Traffic & Access Control 3dl MC LmrkTwp EOC Implementation of PADs for Schools 3c2 MC LmrkTwp EOC Implementation of Traffic & Access Control 3dl MC LmrkTwp EOC Impediments to Evacuation 3d2 MC LmrkTwp EOC Mobilization lal MC LmrkTwp EOC Direction and Control lcl MC LmrkTwp EOC Communications Equipment ldl MC LmrkTwp EOC Equipment and Supplies to Support Operations lel MC LmrkTwp EOC Implementation of Emergency Worker Exposure Control 3al MC LmrkTwp EOC Activation of the Back-up ANS 5a3 MC LmrkTwp EOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MCLmrkTwp EOC Implementation of PADs for disabilities & access/functional needs people 3cl MC MboroTwp TACP Communications Equipment ldl MC MboroTwp TACP Equipment and Supplies to Support Operations lel MC MboroTwp TACP Implementation of Traffic & Access Control 3dl MC MboroTwp TACP Implementation of Emergency Worker Exposure Control 3al MCMSD Implementation of PADs for Schools 3c2 MCMSDEES Implementation of PADs for Schools 3c2 MCMSDMHS Implementation of PADs for Schools 3c2 MCMSDWES Implementation of P ADs for Schools 3c2 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station MCPASD Implementation of PADs for Schools 3c2 MCPASDLES Implementation of P ADs for Schools 3c2 MCPSD Implementation of PADs for Sc]:iools 3c2 MCPSDWPES Implementation of P ADs for Schools 3c2 MCPVSD Implementation of PADs for Schools 3c2 MCPVSES Implementation of PADs for Schools 3c2 MC RC PFC Communications Equipment ldl MC RC PFC Equipment and Supplies to Support Operations lel MC RC PFC Implementation of Emergency Worker Exposure Control 3al MC RC PFC Monitoring, Decontamination, & Registration of Evacuees 6al MCSASD Implementation ofPADs for Schools 3c2 MCSFASD Implementation of PADs for Schools 3c2 MC SF ASD 567GC Implementation of PADs for Schools 3c2 MC SF ASD SFAHS Implementation o:f P ADs for Schools 3c2 MC SF ASD UPES Implementation of PADs for Schools 3c2 MCTrpBrEOC Communications Equipment ldl MCTrpBrEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MCTrpBrEOC Implementation ofPADs for disabilities & access/functional needs people 3cl MCTrpBrEOC Implementation of PADs for Schools 3c2 MCTrpBrEOC Implementation of Traffic & Access Control 3dl MCTrpBrEOC Impediments to Evacuation 3d2 MCTrpBrEOC Mobilization lal MCTrpBrEOC Facilities lbl MCTrpBrEOC Direction and C<;;mtrol lcl MCTrpBrEOC Equipment and Supplies to Support Operations lel MCTrpBrEOC Implementation of Emergency Worker Exposure Control 3al MCUPSD Implementation of PADs for Schools 3c2 MCUPSDMES Implementation of PADs for Schools 3c2 MCUPSDUPHS Implementation of PADs for Schools 3c2 MCGLMrlbrTwpEOC Implementation of PADs for Schools 3c2 MCGLMrlbrTwpEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl MCGLMrlbrTwpEOC Communications Equipment ldl MCGLMrlbrTwpEOC Equipment and Supplies to Support Operations lel MCGLMrlbrTwpEOC Impediments to Evacuation 3d2 MCGLMrlbrTwpEOC Implementation of Traffic & Access Control 3dl MCGLMrlbrTwpEOC Implementation of P ADs for disabilities & access/functional needs people 3cl MCGLMrlbrTwpEOC Direction and Control lei MCGLMrlbrTwpEOC Implementation of Emergency Worker Exposure Control 3al MCGLMrlbrTwpEOC Mobilization lal MCLrPgrvTwpEOC Mobilization lal MCLrPgrvTwpEOC Direction and Control lei MCLrPgrvTwpEOC Implementation of PADs for Schools 3c2 MCLrPgrvTwpEOC Implementation of Traffic & Access Control 3d]

MCLrPgrvTwpEOC Impediments to Evacuation 3d2 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station MCLrPgrvTwpEOC Communications Equipment ldl MCLrPgrvTwpEOC Equipment and Supplies to Support Operations lel MCLrPgrvTwpEOC Implementation of Emergency Worker Exposure Control 3al

. MCLrPgrvTwpEOC Implementation of PADs for disabilities & access/functional needs people 3cl MCLrPgrvTwpEOC Implementation of KIP AD for Institutionalized Individuals/Public 3bl MCNHvrTwpEOC Mobilization lal MCNHvrTwpEOC Impediments to Evacuation 3d2 MCNHvrTwpEOC Direction and Control lcl MCNHvrTwpEOC Communications Equipment ldl MCNHvrTwpEOC Implementation of Traffic & Access Control 3dl MCNHvrTwpEOC Implementation of P ADs for Schools 3c2 MCNHvrTwpEOC Equipment and Supplies to Support Operations lel MCNHvrTwpEOC Implementation of Emergency Worker Exposure Control 3al MCNHvrTwpEOC Implementation of KIP AD for Institutionalized Individuals/Public 3bl MCNHvrTwpEOC Implementation of PADs for disabilities & 11ccess/functional needs people 3cl MCNHvrTwpTACP Implementation of Traffic & Access Control 3dl MCNHvrTwpTACP Implementation of Emergency Worker Exposure Control 3al MCNHvrTwpTACP Equipment and Supplies to Support Operations lel MCNHvrTwpT ACP Communications Equipment ldl MCPASDPHS Implementation of PADs for Schools 3c2 MCPrkmnTwp EOC Implementation of KIP AD for Institutionalized Individuals/Public 3bl MCPrkmnTwp. EOC Implementation of P ADs for disabilities & access/functional needs people 3cl MCPrkmnTwp EOC Implementation of PADs for Schools 3c2 MCPrkmnTwp EOC !mplementation of Traffic & Access Control 3dl MCPrkmnTwp EOC Impediments to Evacuation

  • 3d2 MCPrkmnTwp EOC Mobilization lal MCPrkmnTwp EOC Direction and Control lcl MCPrkmnTwp EOC Communications Equipment ldl MCPrkmnTwp EOC Equipment and Supplies to Support Operations lel MCPrkmnTwp EOC Implementation of Emergency Worker Exposure Control 3al MCPSDPgrvHS Implementation of PADs for Schools 3c2 MCPVSDPVMSE Implementation of PADs for Schools 3c2 MCSASDSHES Implementation of P ADs for Schools 3c2 MCSFASD7GC Implementation of PADs for Schools 3c2 MCSFASD8GC Implementation of P ADs for Schools 3c2 MCUPSDUPMS Implementation of PADs for Schools 3c2 PA JIC/RumCon Mobilization lal PA JIC/RumCon Communications Equipment ldl PA JIC/RumCon Emergency Information & Instructions for the Public/Media 5bl PA TACP SPB TROOP J Mobilization lal PA TACP SPB TROOP J Communications Equipment ldl PA TACP SPB TROOP J Equipment and Supplies to Support Operations lel Implementation of Emergency Worker Exposure Control PA TACP SPB TROOP J 3al PA TACP SPB TROOP J Implementation of Traffic & Access Control 3dl 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station PA TACP SP~ TROOP J Impediments to Evacuation . 3d2 PAAACSEOCBRP Mobilization lal PAAACSEOCBRP Direction and Control lcl PAAACSEOCBRP Communications Equipment  ; ldl PAAACSEOCBRP Equipment and Supplies to Support Operations le!

PAAACSEOCBRP Emergency Worker Exposure Control Decisions 2al PAAACSEOCBRP Accident Assessment and P ARs for the Emergency Event 2bl PAAACSEOCBRP PAD decision-making process and coordination for the General Public 2b2 PACRCC Mobilization lal PACRCC Communications Equipment ldl PACRCC Equipment and Supplies to Support Operations lel PACRCC Direction and Control lcl PACRCC Emergency Worker Exposure Control Decisions 2al PACRCC Accident Assessment and P ARs for the Emergency Event 2bl PACRCC Implementation of KI PAD for Institutionalized Individuals/Public* 3bl PACRCC Activation of the Prompt Alert & Notification System 5al SFMTASER Mobilization lal SFMTASER Communications Equipment ldl SFMT ASER Equipment and Supplies to Support Operations lel SFMTASER Implementation of Emergency Worker Exposure Control 3al SFMT ASER Plume Phase Field Measurement, Handling, & Analyses 4a3 SFMTB SER Mobilization lal SFMTB SER Communications Equipment ldl SFMTB SER Equipment and Supplies to Support Operations lel SFMTB SER Implementation of Emergency Worker Exposure Control 3al SFMTB SER Plume Phase Field Measurement, Handling, & Analyses 4a3 WVBURA Mobilization lal WVBURA Communications Equipment ldl WVBURA Equipment and Supplies to Support Operations lel WVBURA Implementation of Emergency Worker Exposure Control 3al WVBURA Activation of the Back-up ANS 5a3 WVBURA(2) Communications Equipment ldl WVBURA(2) Activation of the Back-up ANS 5a3 WVBURA(2) Equipment and Supplies to Support Operations lel WVBURA(2) Mobilization lal WVBURA(2) Implementation of Emergency Worker Exposure Control 3al WVBURA(3) Communications Equipment ldl WVBURA(3) Equipment and Supplies to Support Operations lel WVBURA(3) Mobilization lal WVBURA(3) Implementation of Emergency Worker Exposure Control 3al WVBURA(3) Activation of the Back-up ANS 5a3 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 State Jurisdictions 3.3.1 PA State Field Monitoring Team A, South East Region In summary, the status of DHS/FEMA criteria for the1 State jurisdiction is as follows:

Criteria Not Demonstrated Observed only

a. MET: I.a.I, l.d.l, Le.I, 3.a.l, 4.a.3
b. LEVEL I FINDINGS: NONE c.. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.2 PA State Field Monitoring Team B, South East Region In summary, the status ofDHS/FEMA criteria for the State jurisdiction is as follows:

Criteria Not Demonstrated Observed only

a. MET: I.a.I, 1.d.1, Le.I, 3.a.I, 4.a.3
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.3 PA State Traffic and Access Control Points, State Police Barracks, Troop J, Embreeville In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:
a. MET: I.a.I, 1.d.I, Le.I, 3.a.I, 3.d.l, 3.d.2
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.4 Pennsylvania Accident Assessment Center, State EOC-Bureau of Radiation Protection In su.mmary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

Criteria Not Demonstrated Observed only

a. MET: 1.a.1, 1.c.l, l.d.l, 1.e.l, 2.a.l, 2:b.l, 2.b.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.5 Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Vehicle In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

Criteria Not Demonstrated Observed only

a. MET: I.a.I, 1.d.l, 1.e.l, 3.a.l, 4.a.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e.
  • PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.6 Pennsylvania Commonwealth Response Coordination Center In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

Criteria Not Demonstrated Observed only

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

b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f.
  • PRIOR ISSUES: UNRESOLVED: NONE 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.1. 7 Pennsylvania Joint Information Center/Rumor Control In summary, the status ofDHS/FEMA criteria for the State jurisdiction is as follows:

Criteria Not Demonstrated Observed Only

a. MET: l.a.l, l.c.l, 1.d.l, l.e.l, 2.a.l, 2.b.l, 4.a.2 ' .
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2 Risk Jurisdictions 3.3.2. 1 Berks County Emergency Operation Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: La.I, l.c.l, 1.d.1, l.e.l, 2.c.l, 3.b.l, 3.c.l, 3.c.2, 3.d.1, 3.d.2, 5.a.l, 5.a.3, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e .. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 2 Berks County Emergency Worker Monitoring and Decontamination Station, Daniel Boone Complex In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.1, l.d.l, 1.e.l, 3.a.1, 6.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES:.UNRESOLVED: NONE 36

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2. 3 Berks County Mass Care Center, Governor Mifflin Senior High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: l.c.l, l.d.l, l.e.l, 6.c.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 4 Berks County Mass Care Center, Muhlenberg Senior High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, l.d.l, l.e.l, 6.c.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 5 Berks County Mass Care Center, Schuylkill Valley School Complex In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, l.d.l, l.e.1, 6.c.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 6 Berks County Monitoring and Decontamination Center, Schuylkill Valley High School .

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: l.c.1, l.d.1, l.e.1, 3.a.1, 6.a.1
b. LEVEL 1 FINDINGS: NONE 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 7 Berks County Monitoring and Decontamination Center, Governor Mifflin Senior High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 1.c.1, 1.d.l, Le.I, 3.a.l, 6.a.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 8 Berks County Mass Care Center, Governor Mifflin Senior High School
  • In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, 1.d.l, 1.e.l, 6.c.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 9 Berks County Monitoring and Decontamination Station, Muhlenberg Senior High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 1.c.l, 1.d.l, 1.e.l, 3.a.l, 6.a.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE 38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 10 Berks County Mass Care Center, Muhlenberg Senior High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, l.d.l, Le.I, 6.c.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 11 Berks County Reception Center, Robeson Township Building In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.d.l, l.e.l, 3.a.l, 6.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 12 Berks County, Boyertown Area School District In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE d.. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 13 Berks County, Boyertown Area School District, Boyertown Senior High School 39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 14 Berks County, Boyertown Area School District, Earl Elementary School

'In summary, the status ofDHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3.c.2
b.
  • LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 15 Berks County, Boyertown Area School District, New Hanover/Upper Frederick ES In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 16 Berks County, Boyertown Area School District, Washington Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2 *
b. LEVEL 1 FINDINGS: NONE 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

  • c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 17 Berks County, Boyertown Borough/Colebrookdale Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.a.l, l.c.l, l.d.l, l.e.l, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
b. PLAN ISSUES: 1
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE ISSUE FOR CRITERION: 5.a.3 CONDITION:

At 1901, the EOC was informed that Siren Number 105 had failed and the Back-Up Route Alerting Team for Route 16D should immediately be dispatched. Upon notice of the siren failure the Fire Chief directed the Fire Captains to report to the EOC. The Fire Captains arrived at 1920. The Fire Captains then received an Emergency Worker briefing, dosimetry kits and instructions for route alerting for Route 160; The Fire Captains left the EOC and returned to their respective Fire Companies at 1930. After arriving at the Fire Companies, the Captains conducted an Emergency Worker briefing, distributed dosimetry kits and instructions for route alerting for Route 16D. The Back-Up Route Alerting Teams reported to the EOC that it had completed its route at 2015, 75 minutes after the notification of the failed siren.

POSSIBLE CAUSE:

The procedure for Back-Up Route Alerting Teams to report to their fire companies to receive an Emergency Worker briefing, Dosimetry Kits, and back-up route alerting procedures at the Site Area Emergency ECL were not followe?.

REFERENCE:

  • NUREG0654/FEMA-REP-1, E.6, Appendix 3.B.2.c
  • Radiological emergency Response Plan for Boyertown Borough Colebrookdale Township, Firefighting Limerick Support Annex, January 2017, page 3: SITE AREA EMERGENCY.

41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EFFECT:

Notification to the public to evacuate was not received in a timely manner following a siren failure.

RECOMMENDATION:

Ensure personnel strictly adhere to the procedures for mobilization of back up route alert teams. Consider amending procedures for mobilization of back up route alert teams to first report to the Emergency Operations Center (EOC) at Emergency Classification Level (ECL) of Site Area Emergency (SAE) or sooner, rec;eive an Emergency Worker Radiological Officer's Briefing, issue of dosimetry, Potassium Iodide (KI), Emergency Worker Exposure Cards, and back-up route alerting procedures and maps. Back-Up route alert teams .can then be placed on stand-by, prepared and ready for a rapid deployment in the event of a siren failure.

3.3.2. 18 Berks County, Boyertown Borough/Colebrookdale Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: l.d.l, l.e.1, 3.a.l, 3.d.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 19 Berks County, Daniel Boone Area School District In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 20 Berks County, Daniel Boone Area School District, Birdsboro Elementary In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction. is as follows:
a. MET: 3.c.2 42

Unclassified Radiological Emergency Preparedness Program (REP)

' After Action Report/Improvement Plan Limerick Generating Station

b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 21 Berks County, Earl Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.a.1, l.c.1, l.d.l, l.e.1, 3.a.l, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE
  • 3.3.2. 22 Berks County, Union Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.a.1, l.c.1, l.d.1, Le.I, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: 1 Re-demonstrated Successfully
d. PLAN ISSUES.: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE ISSUE FOR CRITERION: 3.a;l CONDITION:

The Radiological Officer at the Union Township Emergency Operations Center(EOC) did not give a radiological briefing to EOC staff at Site Area Emergency ECL, as indicated in the Union Township Radiological Emergency Response Plan (RERP). When asked to do so, his briefing was incomplete and contained inaccurate information.

POSSIBLE CAUSE:

43

Unclassified Radiological _Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station The Radiological Officer may have needed refresher training. There was not a clear radiological briefing sheet included in the Union Township RERP.

REFERENCE:

1. NUREG-0654/FEMA-REP-1, K.3.a, b; K.4
2. Demonstration Criterion 3.a.1; Union Township Radiological Emergency Response Plan
3. Limerick Generating Station Support Annex, ESF #10-Hazardous ;Materials, Page 3 (Site

. Area Emergency Checklist), Items 5-11.

EFFECT:

Without a clear radiological briefing, emergency workers could have misunderstandings about the importanc~ and use of dosimetry and Potassium Iodide (Kl), putting their own

. health and safety at risk. Since the EOC also briefs those emergency workers going into the Emergency Planning Zone (EPZ) for traffic and access control duties, it is especially

  • important to have* a clear briefing. ,

REDEMONSTRATION:

The Radiological Officer from Berks County did re-training on dosimetry and KI with Union Township staff. Through interview, the Union Township staff and Radiological Officer.

  • indicated an understanding on the uses and importance of dosimetry and Kl. It is recommended that staff be provided further training on dosimetry, and be provided a clear briefing sheet to read to emergency workers.
  • 3.3.2. 23 Boyertown/Colebrookdale Back up Route Alerting (1)

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: l.a.l, l.d.i, l.e.l, 3.a.l, 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e .. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 24 JBoyertown/Colebro(jkdale Back up Route Alerting (2)

In summary, the status of DHS/FEMA criteria fqr the Risk Jurisdiction is as follows:

a. MET: l.a.l, l.d.l, 1.eJ, 3;a), 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE 44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 25 Chester County Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: La.I, Le.I, Ld.I, Le.I, 2.c.l, 3.a.I, 3.b.l, 3.c.l, 3.c.2, 3.b.l, 3.c.l 3.c.2, 3.d.I, 3.d.2, 5.a.I, 5.a.3, 5.b.I
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 26 Chester County Monitoring and Decontamination Center, West Whiteland In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, l.d.l, l.e.l, 3.a.l, 6.a.I
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED.: NONE 3.3.2.27 Chester County Phoenixville Area School District, Manavon Elementary School &

Phoenixville Area Early Learning Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3.c.2
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE.
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 28 Chester County Reception Center, West Whiteland Township 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: l.d.l, l.e.l, 3.a.l, 6.b.l
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE .
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 29 Chester County, Charlestown Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: I.a.I, Le.I, 1.d.1, Le.I, 3.a.l, 3.b.1, 3.c.1, 3.c.2, 3.d.l, 3.d.2
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. _30 Chester County, Downingtown Area School District In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 31 Chester County, Downingtown Area School District, Downingtown High School East In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:*
a. MET: 3 .c.2
b. LEVEL I FINDINGS: NONE 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

c. LEVEL 2 FINDINGS: NONE
d.
  • PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 32 Chester County, Downingtown Area School District, Lionville Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 33 Chester County, Downingtown Area School District, Lionville Middle School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 34 Chester County, Downingtown Area School Distrkt, Uwchlan Hills Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 35 Chester County, East Coventry Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.a.l, l.d.l, l.e.1, 3.b.l, 3.c.l, 3.c.2, 3.d.1, 3.d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: 2 Successfully Re-Demonstrated
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE ISSUE FOR CRITERION: 1.c.1 CONDITION:

The EMC did not demonstrate the ability to carry out the essential functions required for response. Required actions and requests were not properly processed and completed.

POSSIBLE CAUSE:

Lack of detailed training to include: understanding Radiological Emergency Preparedness plans and procedures and procedures to brief staff with situational awareness information.

Position task and exercise experience knowledge should have a position evaluated competency.

REFERENCE:

NUREG-0654/FEMA-REP-1, A.1.d; A.2.a, b; A.3; C.4, 6 EFFECT:

The Emergency Management Coordination did not know, initially, to contact the Chester County Emergency Operations Center if there were issues or questions concerning the response he could not correct. If allowed to progress the township residents would have been placed in un-do risk.

RECOMMENDATION:

Provide detailed training on the Radiological Incidents plan and procedures to key East Coventry Township Emergency Operations Center. Provide exercise simulations for practice.

RE-DEMONSTRATION:

On February 22, 2018, the East Coventry Township Emergency Operations Center (ECTEOC) successfully demonstrated the ability to provide direction and control during 48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station the Re-demonstration exercise for the November 14, 2017 Limerick Generating Station (LGS) Biennial Plume Exercise.

At the ECTEOC, the individual in charge of the emergency response was the Township Emergency Management Coordinator. The Emergency Management Coordinator held frequent briefings to the EOC staff on the status of the incident; including but not limited to all changes of plant Emergency Classification Levels (ECL), direction to initiate position specific ECL Checklists, plant events prompting specific ECLs, and briefings on Protective Action Recommendations and Decisions from Pennsylvania Bureau of

  • Radiation Protection (BRP).

Briefings to the ECTEOC staff included the following key items:

- 1833 initial EOC briefing following Alert ECL and EOC Activation

- 1839 facility reported operational to Chester County and second shift roster developed to support 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operations

- 1936 following escalation to Site Area Emergency

- 1945 on first siren sounding

- 1948 on the Governor's Declaration and precautionary actions of sheltering livestock, placing livestock on stored feed and water, and restrictions of air, rail, and river traffic in the ten mile plume exposure Emergency Planning Zone (EPZ)

- 2011 directing EOC staff to disseminate livestock and agricultural precautionary information to farmers via reverse 911

- 2028 on escalation to General Emergency

- 2040 on direction from BRP via Chester County for Emergency Workers and the general public to ingest potassium iodide, and direction of general evacuation of the entire EPZ The EOC staff assistant also ensured that a detailed event log was maintained on a large dry erase board readily visible to the entire EOC.

At 1741, positive communication checks were conducted with Chester Ccmnty via a dedicated land line and by the county wide 800 MHZ public safety radio system. Positive communications through these systems and by email were maintained throughout the exercise, and notifications of ECL changes, significant events, and precautionary and

  • protective actions were promulgated successfully by all three means. Additionally, following the escalation to Alert and the activation of the EOC, Chester County posted a liaison officer with a county 800MHZ radio and mobile device with access to county email alerts in the EOC. In one instance in which the full ECL change sheet was not attached to an email as a PDF, based on accurate information received by the email text, 800 MHZ radio, dedicated land line, and discussions with the Chester County Liaison Officer, the ECT Emergency Management Coordinator called back to the county for clarification and was provided with the correct sheet.

Response activities with other organizations were coordinated by respective Emergency Support Function (ESF) leads, who were very familiar with each other's' organizations,

  • personnel, and resources to support the Township's actions. ESF leads were proactive 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station and forward leaning with actions. Following EOC activation, the Township Police Chief serving as law enforcement services ESF lead obtained a weather report and report from his department regarding any traffic accidents that might impede evacuation, and began discussions with the firefighting and emergency services ESF lead regarding potential need for fire police personnel to support traffic and access control points. Immediately following the notification that sirens would be sounded, the firefighting and emergency services ESF lead began review of pre-printed siren coverage charts and back up route alerting procedures in the event any sirens should fail.

In accordance with Pennsylvania's Radiological Emergency Response Plan (RERP),

Protective Action Decisions (PADs) were made by the State of Pennsylvania; specifically BRP, and risk counties and municipalities may add additional precautionary actions. The Emergency Management Coordinator received accurate information and inputs from his supporting staff regarding actions necessary to effectively implement P ADs directed by the state, made timely decisions on this information, and provided clear guidance to the ECTEOC staff.

The ECTEOC staff all had folders of position specific ECL checklists and procedures for radiological emergencies at their stations, as well as accurate and updated contact information for their respective counterpart agencies. All participants in the ECTEOC were familiar with internal and external communication systems and procedures, and provided forceful backup to each other to ensure the development of an accurate common operating picture.

All activities were based on the plans and procedures and completed as they would have been in an actual emergency except as noted in the extent of play agreement.

ISSUE FOR CRITERION: 3.a.1 CONDITION: Exposure control equipment and procedures were not adequately demonstrated. The Oil and Hazardous Materials Coordinator (OHMC) zeroed the Area Kit dosimetry twice during the exercise. No Area Kit record was created by the OHMC for the EOC, 30 minute DRD readings were not taken or recorded. No Emergency Working briefing or exposure control equipment and KI were provided to a Patrol Officer who was dispatched to staff a traffic control post.

.POSSIBLE CAUSE:

Lack of detailed training to include: hands on equipment and form completion experience.

Position task and exercise experience needs to have position evaluated competency.

REFERENCE:

NUREG-0654/FEMA-REP-l, J.lOe; K.3.a, b; K.4 .

EFFECT:

Both the East Coventry Township Emergency Operations Center staff and an EW in the field would have been placed at risk for exposure to radiation without knowing.

RECOMMENDATION:

50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Provide detailed training on radiological exposure control and related plan and procedures to key East Coventry Township Emergency Operations Center key staff.

RE-DEMONSTRATION:

On February 22, 2018, the East Coventry Township Emergency Operations Center (ECTEOC) successfully issued appropriate dosimetry, Potassium Iodide (KI) as well as managed radiological exposure to emergency workers during the Re-demonstration Exercise for the November 14, 2017 Limerick Generating Station (LGS) Biennial Plume Exercise. The Radiological Officer (RO) was responsible for issuing exposure control equipment, forms and describing procedures, as well as maintaining appropriate record-keeping of the administration of KI to Emergency Workers (EW).

The East Coventry Township EOC is located at 855 Ellis Woods Road, Pottstown, PA.

All equipment assigned to the East Coventry EOC was in the EOC in a sealed yellow pelican case with an inventory sheet attached to the top outside. The inventory matched what was in the plan and the seal to the case had not been opened. There was a set of exercise demonstration radiological exposure equipment available. It contained two Direct-Reading Dosimeters (DRD) range 0-20R, one DRD range 0-200R, a DRD charger, a sheet simulating 10 Permanent Record Dosimeters (PRD) and a photocopy of KI tablets for simulated.

At 1834, an Alert was declared at LGS and the East Coventry Emergency Management Coordinator (EMC) notified the RO to report to the EOC. The RO arrived at the EOC at 1837 .. The RO prepared the control PRD for transport to the County. At 1850, the EMC requested a radiological briefing for all emergency workers in the EOC. The RO conducted the briefing from the worksheet provided and all required elements where discussed. The radiological briefing explained that workers undertaking life-saving missions or protecting valuable property or large populations may face increased risk from radiation. The RO identified the equipment that will be distributed and used such as a PRD, a 0-20R and a 0-200R DRD, and four 65mg KI tablets. The EWs were instructed where to place the equipment and to report the readings on the DRD every thirty minutes to the RO. The DRD's were zeroed utilizing the CDV-750. The EW were instructed that when the level reaches 5 Rem they would be pulled from duty and sent to the monitoring and decontamination center at the Twin Valley Fire Department. It was explained that KI was a thyroid blocking agent and taking KI protects the thyroid by filling it with non-ionized iodine. They were told to only take the KI if directed to do so by the Secretary of the Department of Health. When told to do so emergency workers were to take two 65mg tablets in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.

An inventory check was conducted and DRDs in use for the exercise where zeroed. At 1937, the East Coventry EOC was notified of a Site Area Emergency at Limerick Generating Station. At 1945, an Area Kit was placed in the EOC and two emergency workers where issued a PRD, a DRD and KI. These individuals where briefed, subsequently interviewed and knew how to use the equipment, take KI and the reporting values.

51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station At 2025, the EMC reported a General Emergency had been declared at the Limerick Generating Station. Though not demonstrated during this exercise, any EW that would have been deployed for route alerting or traffic and access control would have been issued Category A equipment and briefed by the RO. The RO did inform the EWs to read their dosimeters every 30 mins and at the end of their shifts. AU equipment was-to be returned to the RO who would then process the PRDs through Chester County Health Department for readings.

The exercise was terminated.at 2054 and all equipment was returned to the RO.

All activities where demonstrated in accordance with plans and procedures or as directed in the extent-of-play agreement.

3.3.2. 36 Chester County, East Coventry Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 1.d.l, 1.e.l, 3.a.1, 3.d.1
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 37 Chester County, East Pikeland Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: I.a.I, 1.c.l, 1.d.l, 1.e.l, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l., 3.d.2
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 38 Chester County, East Pikeland Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 1.d.I, Le.I, 3.a.I, 3.d.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS:.NONE 52

Unclassified Radiological Emergency Preparedness Program (REP)

. After Action Report/Improvement Plan Limerick Generating Station

d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 39 Chester County, Emergency Worker Monitoring and Decontamination Station Twin Valley FD In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, l.dJ, 1.e.1, 3.a.l, 6.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 40 Chester County, Great Valley School District, Great VaHey Middle School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 41 Chester County, Owen J. Ro.berts School District In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE d; PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE 53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES: UNRESOLVED: NONE 3~3.2. 42 Chester County, Owen J. Roberts School District, East Vincent Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 43 Chester County, Owen J. Roberts School District, French Creek Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a; MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 44 Chester County, Owen J. Roberts School District, West Vincent Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 45 Chester County, Phoenixville Area School District*

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

54

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

a. MET: 3 .c.2
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE.

3.3.2. 46 Chester County, Schuylkill Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: I.a.I, Le.I, l.d.1, Le.I, 3.a.I, 3.b.1, 3.c.I, 3.c.2, 3.d.1, 3.d.2, 5.a.1
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 47 Chester County, Schuylkill Township Traffic and Access Control In summary, the status ofDHS/FEMA criteria for the Risk Jurisdiction is*as follows:
a. MET: l.d.1, Le.I, 3.a.1, 3.d.I
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.46 Chester County, Uwchlan Township Emergency Operations Center In summary, the status of DHS/FEMA criteria.for the Risk Jurisdiction is as follows:
a. MET: I.a.I, Le.I, l.d.I, Le.I, 3.a.I, 3.b.I, 3.c.1, 3.c.2, 3.d.I, 3.d.2 .
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE 55

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 48 Chester County, Uwchlan Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.d.l, l.e.l, 3.a.1, 3.d.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 49 Chester County, West Vincent Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: I.a. I, l.c.1, l.d. l, l.e. l, 3.a.I, 3 .b. l, 3 .c. l, 3.c.2, 3 .d. l, 3 .d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.49 Chester County, West Vincent Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.d.1, l.e.l, 3.a.1, 3.d.1
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 56

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.50 Chester County, West Vincent Township Back Up Route Alerting (1)

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: l.a.l, l.d.l, l.e.l, 3.a.l, 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSU'ES: UNRESOLVED: NONE 3:3.2. 500 Chester County, West Vincent Township Back Up Route Alerting (2)

In summary, the status of DHS/FEMA criteria for the Risk Jurjsdiction is as follows:

a. MET: l.a.l, l.d.l, l.e.l, 3.a.l, 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 510 Chester County, West Vincent Township Back Up Route Alerting (3)

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: l.a.l, l.d.1, i.e.l, 3.a.l, 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.51 Chester County, Great Valley School District In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE 57

Unclassificd Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

c. LEVEL 2 FINDINGS: NONE *
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. .PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.52 Chester County, Great Valley School District, Great Valley High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 523 Montgomery County Emergency Operations Center In summary, the status ofDHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.a.l, l.c.l, l.d.l, l.e.l, 2.c.l, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.1, 3.d.2, 5.a.l, 5.a.3 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 534 Montgomery County Emergency Worker Monitoring and Decontamination Station, Indian Valley Middle School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, l.d.l, 1.e.1, 3.a.l, 6.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE 58

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 545 Montgomery County, Evacuee Monitoring/Decontamination Center, 'Plymouth Fire Company In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, l.d.l, 1.e.l, 3.a.l, 6.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.56 Montgomery County, New Hanover Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: I.a.I, l.c.l, 1.d.l, l.e.l, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 557 Montgomery County, Green Lane Borough/Marlboro Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: I.a.I, l.c.l, l.d.l, 1.e.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: 1 Re-demonstrated Successfully
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 59

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station ISSUE FOR CRITERION: 3.a.1 The OROs issue appropriate dosimetry, KI 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. OROs maintain appropriate record-keeping of the administration of KI to emergency workers.

CONDITJION:

The Radiological Officer (RO) provided an insufficient briefing to Emergency Workers (EWs). When interviewed, the EWs were unfamiliar with dosimetry, dose limits, KI, and documentation.

POSSIBLE CAUSE:

The Radiological Officer did not follow the checklist for the briefing.

REFERENCE:

NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4 EFFECT:

Without the proper training and understanding of dose limits and equipment operation, Emergency Workers entering a radiation area would risk unnecessary exposure.

RECOMMENDATION:

Ensure the RO is provided with up to date checklists to use when providing a dosimetry brief.

The checklist should be annotated as to which statements must be read to the EWs receiving the brief, what documentation must be distributed to the EWs, and what dosimetry they must receive.

REDEMONSTRATION:

Following the initial RO briefing, the Pennsylvania Emergency Management Agency (PEMA) Observer/Controller provided just-in-time training to the RO. The training consisted of reminding the RO to use his checklist and procedures to perform the brief. Additionally to actually pass out all of the documentation and complete the forms. Following this, the RO re-demonstrated successfully by providing another brief. The two EWs were again interviewed and knew both the answers to those questions missed previously plus additional questions when asked.

  • 3.3.2. 568 Montgomery County, Greenlane Borough/Marlboro Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.d.l, l.e.l, 3.a.l, 3.d.1
b. LEVEL 1 FINDINGS: NONE
a. LEVEL 2 FINDINGS: 1 Re-demonstrated Successfully
d. PLAN ISSUES: NONE 60

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 579 Montgomery County, Limerick Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET:* 1.a.1, 1.c.1, 1.d.1, l.e.1, 3.a.l, 3.b.1, 3.c.1, 3.c.2, 3.d.l, 3.d.2, 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.60 Montgomery County, Limerick Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 1.d.l, 1.e.1, 3.a.l, 3.d.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.61 Montgomery County, Limerick Township Back Up Route Alerting (1)

In summary, the status of DHS/FEMAcriteria for the Risk Jurisdiction is as follows:

a. MET: I.a.I, l.c.1, l.d.l, l.e.l, 3.a.l, 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.62 Montgomery County, Limerick Township Back Up Route Alerting (2)

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

61

Unclassified Radiological Emergency Preparedness Program (REP)

After-Action Report/Improvement Plan Limerick Generating Station

a. MET: l.a.1, l.c.l, l.d.l, l.e.l, 3.a.l, 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2*FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE.
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.63 Montgomery County, Lower Frederick Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.a.l, l.c.l, l.d.l, l.e.1, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.64 Montgomery County, Lower Pottsgrove Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.a.l, Le.I, l.d.1, l.e.l, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, ~.d.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3~3.2.65 Montgomery County, Lower Pottsgrove Township Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.d.l, l.e.l, 3.a.l, 5.a.3 b: LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE 62

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE .

3.3.2. 586 Montgomery County, Marlborough Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: l.d.l, l.e.l, 3.a.1, 3.d.1
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE f.. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 59 Montgomery County, Methacton School District, In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 608 Montgomery County, Methacton School District, Eagleville Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 63

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2. 61 Montgomery County, Methacton School District, Methacton High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 62 Montgomery County, Methacton School District, Woodland Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 631 Montgomery County, New Hanover Township Traffic and Access Control In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.d.l, l.e.1, 3.a.1, 3.d.1
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.72 Montgomery County, Perkiomen Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.a.l, l.c.l, l.d.l, l.e.l, 3.a.1, 3.b.l, 3.c.l, 3.c.2, 3.d~l, 3.d.2
b. LEVEL 1 FINDINGS: NONE 64

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.73 Montgomery County, Perkiomen Valley School District In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a.* MET: 3.c.2

b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOL \TED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.74 Montgomery County, Perkiomen Valley School District, Perkiomen Middle School East Ih summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL I FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.75 Montgomery County, Perkiomen Valley South Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE 65

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 646 Montgomery County, Pottsgrove School District In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 657 Montgomery County, Pottsgrove School District, Pottsgrove High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 668 Montgomery County, Pottsgrove School District, West Pottsgrove Elementary School In summary, the status ofDHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 679 Montgomery County, Pottstown Area School District In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

66

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.80 Montgomery County, Pottstown Area School District, Lincoln Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE c .. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.81 Montgomery County, Pottstown Area School District, Pottstown High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE*
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.82 Montgomery County, Reception Center Plymouth Fire Company In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: l.c.l, l.d.l, l.e.1, 3.a.l, 6.b;l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE 67

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.83 Montgomery County, Souderton Area School District*

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3 :c.2 '
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE *
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 68 Montgomery County, Soudertoµ Area School District, Salford Hills Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE
  • 3.3.2.85 Montgomery County, Spring-Ford Area School District I

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 68

Unclassified Radiological E_mergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2. 69 Montgomery County, Spring-Ford Area School District, 5th & 6th Grade Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3.c.2 *
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 70 Montgomery County, Spring-Ford Area School District, 7th Grade Center In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3 .c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES.: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 71 Montgomery County, Spring-Ford Area School District, 8th Grade Center (Old.

Middle School)

In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 72 Montgomery County, Spring-Ford Area School District, Spring-Ford Area High School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2 69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lmproveinent Plan Limerick Generating Station

b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.90 Montgomery County, Spring-Ford Area School District, Upper Providence Elementary In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.91 Montgomery County, Trappe Borough Emergency Operations Center
a. MET: l.c.1, l.b.1, l.d.1, l.e.1, 3.b.1, 3.c.1, 3.c.2, 3.d.l, 3.d.2
b. LEVEL 1 FINDINGS: NONE
b. LEVEL 2 FINDINGS: 2 Successfully Re-Demonstrated
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE ISSUE FOR CRITERION: 1.a.1 CONDITION:

The Trappe Borough EOC does not have adequate personnel to staff positions or maintain 24-hour operations.

  • POSSIBLE CAUSE:

Inability to recruit and/or maintain staff for emergency management operations.

70

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

REFERENCE:

NUREG0654/FEMA-REP-1, A.La, e; A.3, 4; C.l, 4, 6; D.4; E.1, 2; G.3.a; H.3, 4 EFFECT:

The lack of sufficient personnel to staff critical positions within the EOC could result in an inability to implement precautionary/protective actions, therefore placing the public at risk.

RECOMMENDATION:

Implement compensatory measures that provide staffing solutions and/or recruit adequate personnel.

RE-DEMONSTRATION:

On February 22, 2018, the Trappe Borough Emergency Operations Center (EOC) located at 25 West 5th Avenue, Trappe, Pennsylvania 19426, Trappe Borough successfully demonstrated the use of effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner during Re-demonstration exercise for the November 14, 2017 Limerick Generating Station (LGS) Biennial Plume Exercise.

The Trappe Borough EOC was authorized to pre-stage during this re-demonstration in accordance with the Extent of Play Agreement and received an initial notification of an Alert from Montgomery County Emergency Management Agency (EMA) at 1832 via 800 MHz radio and verified the Alert with Montgomery County EMA at 1833. The Trappe Borough EMC simulated a digital page notification to Borough elected officials and other staff and declared the EOC operational at 1834. Other notification systems available to the Trappe Borough EOC include cell phone, land line, Knowledge Center, and Radio Amateur Civil Emergency Service (RACES). At 1840, the Trappe Borough EMC established a 24-hour staffing roster and began an initial briefing to the EOC Staff concerning the Alert at LGS. The EMC directed the establishment of Knowledge Center, staff to review their Alert checklist, inventory of dosimetery, placed traffic control personnel on stand-by, and identified special needs facilities and citizens within the borough in the event the incident escalated. At 1841, the Trappe Borough EMC communicated an unmet need with the Montgomery County EMA via 800 MHz radio requesting a RACES team. In addition, a notification was simulated to the Pennsylvania State Police at Skippack Barracks Troop K, requesting traffic control be placed on standby per Memornndum of Agreement for the purpose of covering a portion of the .

Trappe Borough Traffic Control Points (TCPs). At 1845, the Trappe Borough EMC directed the Radiological Officer (RO) conduct a briefing to EOC staff.

At 1935, a notification of a Site Area Emergency (SAE) was received and verified by the Trappe Borough EMC via 800 MHz radio from Montgomery County EMA. Follow up electronic copies of notification forms along with precautionary actions such as placing livestock on stored feed and water, air, rail, and water restrictions were received via Knowledge Center. The Trappe Borough conducted a briefing to the EOC staff and directed them to review their SAE checklist in addition to feedback from each Emergency Support Function (ESP) position. At 1940, a notification from Montgomery 71

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick *Generating Station County EMA was received via 800 MHz radio announcing the sounding of sirens at 1945 and an Emergency Alert Broadcast (EAS) at 1948. There were no Protective Action Decisions (PADs) communicated at this time however a report of a radiological release in progress was reported at 1940. Trappe Borough reported no unmet needs. rn* addition, it was simulated at 1840 that the RACES team requested at 1841 had arrived on site at the EOC. At 1942, the Trappe Borough EMC verified that all dosimetery had been issued to staff to include Traffic Control Personnel, Route Alerting Teams, hearing impaired teams, and the placement of a dosimetry area kit within the EOC. It was noted by the Trappe Borough EMC that in an event of an evacuation of the EOC due to radiation hazard, the alternate facility located at the Montgomery County Library in Norristown, Pennsylvania would be occupied.

At 2026, a report of a General Emergency (GE) was received by Trappe Borough and verified via 800 MHz radio from Montgomery County EMA. At 2033, Montgomery County EMA notified Trappe Borough that sirens would be sounded at 2035 followed by and EAS message at 2038. In addition, the EAS message included a recommendation to evacuate the 10-mile Emergency Planning Zone (EPZ) by the Governor of Pennsylvania, and the recommendation by the Pennsylvania Secretary of Heath for Emergency Workers, institutionalized individuals, and the general public ingest Potassium Iodide (KI). The Trappe Borough EMC ensured regular briefings occurred and included follow ups with staff on ensuring KI was ingested by Emergency Workers, the opening of shelters, and that the redeployment requirements for Emergency Workers including traffic control, and alerting teams were followed. A notification of termination of the exercise was received by Trappe Borough EMC at 2055 from Montgomery County EMA via 800 MHz radio. The Trappe Borough EMC ensured that all checklists were completed with no unmet needs prior to releasing EOC staff.

All activities were based on the plans and procedures and completed as they would have been in an actual event except as noted in the extent of play agreement.

ISSUE FOR CRITERION: 3.a.1 The OROs issue appropriate dosimetry, KI 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. OROs maintain appropriate record-keeping of the administration of KI to emergency workers.

CONDIT][ON:

The Radiological Officer (RO) provided an insufficient briefing to Emergency Workers (EWs). When interviewed, the EWs were unfamiliar with dosimetry, dose limits, KI, and documentation.

POSSIBLE CAUSE:

The Trappe Borough Radiological Officer (RO) provided a shortened version of a Radiological Officer's Briefing to the Trappe Borough Emergency Operations Center (EOC) staff which resulted in critical protective measures for emergency responders not 72

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick G~nerating Station being delivered. Missing information from the RO briefing checklist included identification of the location of Emergency Worker Monitoring Decontamination Station, exposure and reporting limits, location of Permanent Record Dosimeters (PRDs ),

contamination thresholds, information concerning the ingestion of Potassium Iodide (KI),

use of Area dosimetry, issue of dosimetry kits to emergency workers, and management of emergency workers in the field. The Trappe Borough was declared operational at 1715 which permitted adequate time to mobilize and conduct a thorough RO briefing. The RO briefing did not begin until 1823, one minute following the declaration of a Site Area Emergency (SAE).

REFERENCE:

NUREG-0654/FEMA-REP-l, J.10.e; K.3.a, b; K.4 EFFECT:

Without the proper training and understanding of dose limits and equipment operation, Emergency Workers entering a radiation area would risk unnecessary exposure.

RECOMMENDATION:

Ensure the Trappe Borough Radiological Officer has sufficient training to perform the duties of an RO such as the State Radiological Officer's Course, along with a current and adequate RO Briefing Checklist, knowledge of exposure limits, KI, dosimetry equipment issue, use and location of where dosimetry is stored, and the ability to manage emergency workers assigned within the 10-mile Emergency Planning Zone (EPZ). Ensure the RO is provided with up to date checklists to use when providing a Radiological Officer's dosimetry brief. The checklist should be annotated as to which statements must be read to the EW s receiv.ing the brief, what documentation must be distributed to the EW s, and what dosimetry they must receive.

RE-DEMONSTRATION:

On February 22, 2018, the Trappe Borough Emergency Operations Center (EOC) successfully demonstrated the issue of appropriate dosimetry, Potassium Iodide (KI) and procedures, and management ofradiological exposure control to Emergency Workers (EWs) during the Re-demonstration Exercise for the November_ 14, 2017 Limerick Generating Station (LGS) Biennial Plume Exercise.

For the purpose. of this re-demonstration exercise, the staff at the Trappe Borough EOC was pre-positioned. At 1832, the Emergency Management Coordinator (EMC) received notification from the Montgomery County EOC that the Limerick Generating Station had declared an Alert Emergency Classification Level (ECL) and at 1834 the EMC declared the EOC operational.

At 1836, the Radiological Officer began preparing (8) Emergency Worker (EW)

Exposure Kits and (1) Area Kit. Each kit contained a Dosimetry/KI Report Form, an Acknowledgment of Receipt Form, a 0-20R Direct Reading Dosimeter (DRD), a Personal Record Dosimeter (PRD) and four 65mg Potassium Iodide (KI) tablets. At 1845, the Radiological Officer (RO) conducted a thorough briefing for EOC staff utilizing the Radiological Officer Briefing Checklist.

73

UIi classified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station The briefing included zeroing out DRDs, reading dosimeters every 30 minutes, instructions to contact him to report readings or any increases in IR increments, filling out the Dosimetry-KI Report Forms with required information and how to wear the PRD and DRD. Radiation exposure limits were explained as lOR for protecting valuable property; 25R for lifesaving or protection of large populations, and greater than 25R for lifesaving or protection of large populations (must be a volunteer). Exposures greater than 20R would require the issuance of a higher range dosimeter to the emergency worker. (10) 0-200R DRDs were available for this purpose. He explained the procedure on changing emergency workers based on their exposure levels and the approval process for authorizing lifesaving missions. Information on when to take KI, why it is taken, as well as contraindications were discussed. The RO also explained that at the end of their mission, Emergency Workers should report to the Monitoring and Decontamination Center located at Methacton High School.

The RO explained that emergency workers are grouped into categories A, B or C depending on their assignments and locations, and that an Area Kit would be used for all EOC staff remaining in the building. Emergency Worker categories were explained as:

Category A - Mobile Emergency Workers located in or entering the 10-mile Emergency Planning Zone (EPZ) (e.g., Route Alerting, Traffic Control); receive(!) PRD per worker, (1) 0-20R DRD per worker, Standard KI Issue-2 day dosage and (1)

Dosimetry/KI Report Form.

Category B - Collect1vely grouped persons in the EPZ will have at least one area kit (e.g., EOCs, hospitals, nursing homes); receive (1) PRD per worker, Standard KI Issue -

2 day dosage, (1) Dosimetry/KI Report Form.

Category C - Emergency workers located outside the EPZ that may come in contact with potentially contaminated persons/equipment (e.g., monitoring and decontamination centers, reception centers); receive (1) PRD per worker and (1) Dosimetry/KI Report Form.

The RO stated that a similar briefing would be conducted for any emergency workers dispatched from the EOC that had not been present for the first briefing.

At 1935, the EMC received notification from the Montgomery County EOC that the Limerick Generating Station had declared a Site Area Emergency (SAE). Following the notification, the Radiological Officer conducted another thorough Radiological Briefing to the EOC staff. Following the second RO briefing, an EOC staff member was interviewed and demonstrated an adequate knowledge of the information covered in the briefing. They were specifically asked about dosimetry and KI usage and recordkeeping, dose limits, KI precautions, and authorizations for exposure extensions.

At 2026, the EMC received notification that the LGS had declared a General Emergency (GE) ECL. Notification was also received stating the Governor of Pennsylvania recommends the evacuation of all persons within the Emergency Planning Zone of Berks, Chester and Montgomery counties and that the Secretary of Health has advised that 74

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station emergency workers, special populations and the general public should take Potassium Iodide (KI). .

All activities were based on the plans and procedures and completed as they would have been in an actual event, except as noted in the extent of play agreement.

3.3.2. 733 Montgomery County, Upper Perkiomen SchoorDistrict In summary, the status ofDHS/FEMA criteria for the Risk Jurisdiction is as follows:

a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 74 Montgomery County, Upper Perkiomen School District, Marlborough Elementary School In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.95 Montgomery County, Upper Perkiomen School District, Upper Perkiomen Middle School
  • In summary, the status of DHS/FEMA criteria for the Risk Jurisdiction is as follows:
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. .PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE 75

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.3 Support Jurisdictions 3.3.3.1 Bucks County Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Support Jurisdiction is as follows.:
a. MET: l.a.l, l.c.l, l.d.l, l.e.l, 5.b.l
b. LEVEL 1 FINDINGS: NONE c.. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.3. 2 Bucks County Monitoring and Decontamination Center, Neshaminy Mall (at.

Trevose Fire Company)

In summary, the status of DHS/FEMA criteria for the Support Jurisdiction is as follows:

a. MET: l.c.l, l.d.l, l.e.l, 3.a.l, 6.a.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE.
d. PLANISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE .

. f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.3. 3 Bucks County Reception Center., Neshaminy Mall (at. Trevose Fire Company)

In summary, the status ofDfIS/FEMA criteria for the Support Jurisdiction is as follows:

a. MET: l.c.l, l.d.1, l.e.l, 3.a.l, 6.a.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE

. f. PRIOR ISSUES: UNRESOLVED: NONE

  • 3.3.3.4 Lehigh County Emergency Operations Center 76

Unclassified .

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station In summary, the status of DHS/FEMA criteria for the Support Jurisdiction is as follows:

a. MET: l.c.l, l.d.l, 1.e.1, 3.a.l, 6.aJ
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. . P.RIOR ISSUES: UNRESOLVED: NONE 3.3.3.5 Lehigh County Mass .Care Center, Southern Lehigh High School In summary, the status of DHS/FEMA criteria for the Support Jurisdiction is as follows:
a. MET: l.c.l, l.d.l, l.e. l, 6.c. l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE.

3.3.3.6 Lehigh County Monitoring and Decontamination Center, Southern Lehigh High School In summary, the status of DHS/FEMA criteria for the Support Jurisdiction is as follows:

a. MET: l.c.1, l.d.l, l.e.1, 6.c.1
b. LEVEL l FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.3.7 Lehigh County Reception Center, Southern Lehigh High School In summary, the status ofDHS/FEMA criteria for the Support Jurisdiction is as follows:
a. MET: l.d.1, l.e.1,. 3 .a.1, 6.a.1 b.* LEVEL 1 FINDINGS: NONE 77

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.4 Private Jurisdictions 3.3.4. 1 Exelon Joint Information Center Criteria Not Demonstrated Observed only In summary, the status of DHS/FEMA criteria for the Private Jurisdiction is as follows:
a. MET: l.d.l, l.e.l, 5.b.1 .
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 78

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

. SECTION 4: DEMONSTRATED STRENGTHS State Jurisdictions 4.1 Commonwealth Response Coordination Center (CRCC)

  • CRCC leadership and staff remained fully engaged in exercise play Excellent Direction and Control
  • Protection of the public remained as a constant priority Risk Jurisdictions 4.2 Berks County Worker Mon/Decou Center - Daniel Boone Jr. /Sr. High School
  • The Birdsboro Union Fire Department demonstrated good team work, and adherence to procedures.
  • Good teamwork and adherence to procedures by the Birdsboro Union Fire Department.

4.3 Chester County

  • The Chester County EOC utilized the Computer Aided Dispatch System which enabled the EOC to monitor the fire department during the backup route alerting.

4.3.1 Charlestown Township EOC

  • Throughout the exercise, the Charlestown Township EMC coordinated and implemented local decision making, ensuring EOC staff had good situational awareness of response activities. Charlestown Township EOC staff understood the goals and objectives for the exercise, trusted each other's feedback; listening and collaborating while planning for the next steps were commendable.

4.3.2 Schuylkill Township EOC

  • The participants from the Schuylkill Township Emergency Operating Center, Police Department, and ARES/RACES, along with the Valley Forge Fire Department, were
  • prepared and professional in their actions and responsibilities of managing the Limerick Generating Station Plume emergency during the Tuesday, November 14, 2017, exercise. They all communicated well with each other and were dedicated in providing protective actions, correct instructions to the agencies they represented, and current information to the public and to those calling in for assistance.

4.3.3 Downingtown Area School District

  • Downingtown Area School District personnel provided excellent knowledge on their plan and procedures.

4.3.4 Great Valley School District

  • Great Valley School District utilized Skype to simultaneously communicate with the individual schools for briefing and updates using a grant from Exelon Corporation.

4.4 Montgomery County EOC 79

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

  • The Radiological *officer delivered an outstanding clear, concise, and factual dosimetry and KI briefing such that all EOC staff who were interviewed about exposure control understood exposure limits and how to use dosimetry and KI should they have to.

4.4.1 Spring-Ford Area School District

  • The participants from Spring-Ford Area School District (SFSD), Intermediate Grades were prepared and professional in their actions and responsibilities of managing the protective actions taken for the SFSD students during the Limerick Generating Station Plume Exercise on November 14, 2017. The Principal communicated well with her staff and teachers as she and her Secretary demonstrated how dedicated they were in implementing those protective actions for their students.

Support Jurisdictions 4.5 Lehigh County Reception Center -Southern Lehigh High School

  • Outstanding community involvement with this operation. There were approximately 20 volunteer evacuee actors which added to the realism of demonstrating registration and monitoring/decontamination. Local police, fire police, and multiple fire companies all supported this event to the extent that traffic control was among the best ever observed and all stations were manned with back up.

80

Unclassified Radiologic_al Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station SECTION 5: CONCLUSION The Commonwealth of Pennsylvania and local jurisdictions, except where noted in this report demonstrated knowledge of their Radiological Emergency Response Plans (RERP) and procedures were adequately implemented during the Limerick Generating Station Plume exercise evaluated on November 14, 2017.

Federal Emergency Management Agency (FEMA) evaluators assessed 441 evaluation criteria in six Assessment Areas:

  • Evaluation Area 1: Emergency Operations Management .
  • Evaluation Area 2: Protective Action Decision Making
  • Evaluation Area 3: Protective Action Implementation
  • Evaluation Area 4: Field Measurement and Analysis
  • Evaluation Area 5: Emergency Notification and Public Information
  • Evaluation Area 6: Support Operation/Facilities There were no Level 1 Findings identified during the exercise. There were six Level 2 Findings identified, two of which were successfully re-demonstrated during the exercise night on November 14, 2017. The other four Level 2 Findings were re-demonstrated successfully on February 22, 2018. Also, there was one Planning Issue identified.

Based on the results of the exercise and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

An After Action Improvement Plan (IP) will not be developed as part of this report.

81

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReporUimprovement Plan Limerick Generating Station This page is intentionally blank.

82

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station AENDIX A: EXERCISE TIMELINE TABLE 1: EXERCISE TIMELINE DATE: November 14, 2017 SITE: Limerick Generating Station This section contains the Exercise Timeline. A table that depicts the times when an event or notifications were noted at participating agencies and locations.

Time That Notification Was Received aUhe Listed Location Emergency Time Utility Classification Boyertown Charlestown Declared Level or Event PAAAC ExelonJIC Berks County Bro/Colebrookdale Earl Township Union Township Chester County l'ACRCC Township Township Unusual Event 1609 1645 1619 NIA 1645 NIA 1618 1710 Alert 1658 1725 1713 -1725 1727 1742 1736 1735 1715 1747 ISAE 1802 1818 1818 1820 1824 1834 1841 1839 1818 1823 IGE 1917 1947 1936 1920 1947 2020 2013 2009 1953 1933 1Start of Simulated 1609 1645 1619 1749 1645 1742 1736 1735 1618 1709

!Radiation Release Termination of Simulated NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA Radiation Release

"'acility Declared Operational 1700 NIA 1823 1730 1748 1759 1801 1629 1705 Govemoi:'s Declaration of 1849 1913 1908 2020 1911 1941 State of Emergency Exercise Terminated 2055 2100 2055 2057 2035 2102 2058 2100 2052 83

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station First Precautionary/Protectiv~ 1845 1835 1859 1831 1904 1904 1832 1827 (W)

Actions: Describe:

1916 (R)

!Airspace restriction, 3K feet, 3

~niles, Boating and fishing 1916 (S) restriction, Water/rail restriction, 10 miles and Shelter and place livestock on stored feed Siren Sounding 1855 1855 1855 1855 1855 1855 1855 1855 EAS Broadcast time 1858 1858 1858 1858 1858 1858 1858 1903 Second Precautionary/Protective Actions. Describe:

Recommend population within 10 miles to evacuate. Special 1955 1941 1958 1955 2020 2025 2022 1955 2007 Population shelter in place and ingest Kl Air Restriction, 10 miles; IOK feet Siren Sounding 2000 11 2000 2000 2000 2000 1 --

EAS Message Broadcast 2003 2003 2003 2003 2003 2003 Kl Decision (YES) EWs 1955 1941 1958 1955 2020 2025 2022 2003 2020 Kl Decision (YES) General Public 1955 1941 1958 1955 2020 2025 2022 2003 2020 Kl Decision (YES) Persons with Disabilities or Access Functional 1955 1941 1958 1955 2020 2025 2022 2003 2020 needs 84

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

' ' Ti'nie ThafNoiification '\Vas Rec~ived at tlie Listed Locatih1t . .: 1

        • Emergency
Time Utility Greenlane
    • Classification . Declared : IEast Coventry Schuylkill West Vincent Montgomery Bor/Marlborough

'Level.or-Event* ~ ' ' ;< < ,:

East Pikeland Pwchlan Townshii Township Township Township County Township Unusual Event 1625 1633 1623 1630 1623 1622 1627 Alert 1745 1743 1745 1835 1744 1707 1717 SAE 1829 1833 1829 1839 1833 1815 1821 GE 1948 1951 1946 2008 1934 1930 1982 Start of Simulated 1829 1833 1829 1839 1744 1622 1627 Radiation Release Termination of Simulated NIA NIA NIA NIA NIA NIA NIA Radiation Release Facility Declared Operational 1659 1648 1639 1710 1635 1640 1700 Governor's Declaration of State 1916 1939 1918 2040 1915 1915 of Emergency

!Exercise Terminated 2102 2041 2049 2050 2107 2050 First Precautionary/Protective 1850 (W) 1847 1848 (A) 1932 (A) 1836 (W) 1820 2013 Actions: Describe:

1843 (R) 1834 (W) 1921 (W) 1842 (R)

!Airspace restriction, 3K feet, 3 tmi!es. Boating and fishing 1838 (S) 1842 (R) 1936 (R) 1839 (S) restriction, Water/rail restriction, 10 miles and Shelter and place livestock on stored feed Siren Sounding 1855 1909 1856 1856 1855 1855 EAS Broadcast time 1910 1855 1912 1856 1858 1858 85

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Second Precautionary/Protective Actions. Describe: 2008 (E) 2012 Recommend population within 1920 (R) 2027 1953 (KI) 2010 Evac, KI 1952 2013 10 miles to evacuate. Special Population shelter in place and 1859 (A) ingest KI. Air Restriction, 10 miles, lOK feet Siren Sounding 2027 2000 2010 2000 2000 EAS Message Broadcast 2027 2003 2010 2003 2003 KI Decision (YES) EWs 2019 2027 2010 2018 1952 2012 KI Decision (YES) General 2019 2027 1953 2040 2018 1952 2012 Public KI Decisions (YES) Persons with Disabilities or 2019 2027 NIA 2018 1952 2012 Access/Functional needs

    • .... .j Time,ThatNotificatfon W;ls'Received at.the ListedLocation . .. .

,Emergency .. **:* * * ,.,. ** .. .:::,** .:******""*:. . .. ,... '***. *:* ,, '* . . . *.,, ,, ,, , **' *, .*.,:.. , . ;:* *.: '* ..  :

', Classification. : rime. Utility. ll===L=im=e=r""ic=k====r===========r===========r=========,===P=e=r=ki=o=m=e=n===;==T=r=a=pp=e=T=o=w""n"'s=hi=p==r=====B=u=c=ks======;=====L=e=h=ig=h====#=========H

  • Level or Evebt :'*Declared: Lower Frederick Lower Pottsgrove New Hanover

..,, Township Township Township Township County County

.Township Unusual Event 1627 1626 1646 1630 1627 1626 1701 NIA Alert 1716 1715 1714 1715 1713 1715 1728 1729 SAE 1821 1817 1822 1822 1821 1822 1824 1827 GE 1932 1932 1933 1932 1931 1933 1947 1947 Start of Simulated 2005 1627 1824 1834 Radiation Release Termination of Simulated NIA NIA NIA NIA NIA NIA NIA NIA Radiation Release 86

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Facility Declared Operational 1802

  • 1720 1701 1642 1740 1715 1730 1829 Governor's Declaration of State 1916 2000 1916 2007 1917 1915 of Emergency Exercise Terminated 2057 2100 2048 2103 2050 2052 2100 2100 First Precautionary/Protective 2007 2004 1846 1848 1830 1832

!Actions: Describe:

~irspace restriction, 3K feet, 3 miles. Boating and fishing trestriction, Water/rail restriction, 10 miles and Shelter and place livestock on stored feed Siren So1mding us55 1855 1855 1855 1855 1855 1855 1855 EAS Broadcast time 1858 1858 1858 1858 1858 1858 1858 1858 Second Precautionary/Protective Actions. Describe:

Recommend population within 1915 (R) 1915 (R) 2005 2005 2007 2009 10 miles to evacuate. Special 1952 (Kl, S) 1952 (KI, S)

Population shelter in place and ingest Kl. Air Restriction, 10 miles, 1OK feet Siren Sounding 2000 2005 2000 2000 2000 2000 EAS Message Broadcast 2003 2003 2003 2003 2003 Kl Decision (YES) EWs 2007 2005 2005 2005 2007 2010 1953 1953 KI Decision (YES) General Public, specify if restricted to 2007 2005 2005 2007 1953 1953 sectors Kl Decisions (YES) Persons with Disabilities or 2007 2005 2005 2007 1953 1953 Access/Functional needs 87

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leaders for the Limerick Generating Station 2017 Radiological Emergency Preparedness Plume Exercise evaluated on November 14. The following constitutes the managing staff for the Exercise Evaluation:

.

  • Thomas Scardino, DHS/FEMA, Regional Assistance Committee (RAC) Chairman
  • Tina Thomas, DHS/FEMA, Project Officer and Site Specialist
  • Roger Kowieski, Regional Coordinator DATE: November 14, 2017 SITE: Limerick Generating Station
  • .. *,: '"1t:i,(LQCAJ'XQN:(\ .,'~

. ' ':\*

!'? ~

. *.. 1'~

' illEAM,LEADER:: i

"';;,',\<<!<<,,.

',{"1!*

. .: ,.*;' ,/:., A0ENC:Y: ,t\ ;, *.,:

Berks County Emergency Operation Center Nicholas Buls FEMARIII Berks County Emergency Worker Monitoring and Nicholas Buls FEMARIII Decontamination Station, Daniel Boone Complex Berks County Mass Care Center, Governor Mifflin Nicholas Buls FEMARIII Senior Hicli School Berks County Mass Care Center, Muhlenberg Senior Nicholas Buls FEMARIII High School Berks County Mass Care Center, Schuylkill Valley Nicholas Buls FEMARIII School Complex Berks County Monitoring and Decontamination Center, Nicholas Buls FEMARIII Schuylkill Valley School Co Berks County Monitoring and Decontamination Center, Nicholas Buis FEMA RIII Governor Mifflin Senior HS Berks County Monitoring and Decontamination Station, Nicholas Buis FEMA RIII Muhlenberg Senior High School Berks County Reception Center, Robeson Township Nicholas Buis FEMARIII Building Berks County, Boyertown Area School District Patricia Gardner FEMARIII Berks County, Boyertown Area School District, Patricia Gardner FEMA RIII Boyertown Senior High School Berks County, Boyertown Area School District, Earl Patricia Gardner FEMARIII Elementary School Berks County, Boyertown Area School District, New Patricia Gardner FEMARIII Hanover/Upper Frederick ES I Berks County, Boyertown Area School District, Patricia Gardner FEMARIII Washington Elementary School Berks County, Boyertown Borough/Colebrookdale Nicholas Buis FEMARIII Township Emergency Operations Center 88

-i I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Berks County, Boyertown Borough/Colebrookdale Nicholas Buls FEMARIII Township Traffic and Access Control Berks County, Daniel Boone Area School District Patricia Gardner FEMARIII Berks County, Daniel Boone Area School District, Patricia Gardner FEMARIII Birdsboro Elementary Berks County, Earl Township Emergency Operations Nicholas Buis FEMARIII Center Berks County, Union Township Emergency Operations Nicholas Buls FEMA RIil Center Boyertown/Colebrookdale Back up Route Alerting (1) Nicholas Buis FEMARIII Boyertown/Colebrookdale Back up Route Alerting (2) Nicholas Buls FEMARIII Bucks County Emergency Operations Center William McDougall FEMARIII Bucks County Monitoring and Decontamination Center, William McDougall FEMARIII Trevose Fire Company Bucks County Reception Center, Trevose Fire Company William McDougall FEMARIII Chester County Emergency Operations Center John Price FEMARIII Chester County Monitoring and Decontamination John Price FEMARIII Center, West Whiteland Chester County Phoenixville Area School District, Patricia Gardner FEMARIII Manavon Elementary School & Phoenixville Area Early Leaming Center Chester County Reception Center, West Whiteland John Price FEMARIII Township Chester County, Charlestown Emergency Operations John Price FEMARIII Center Chester County, Downingtown Area School District Patricia Gardner FEMARIII Chester County, Downingtown Area School District, Patricia Gardner FEMARIII Downingtown High School East Chester County, Downingtown Area School District, . Patricia Gardner FEMARIII Lionville Elementary School Chester County, Downingtown Area School District, Patricia Gardner FEMARIII Lionville Middle School Chester County, Downingtown Area School District, Patricia Gardner FEMARIII Uwchlan Hills Elementary School Chester County, East Coventry Township Emergency John Price FEMARIII Operations Center Chester County, East Coventry Township Traffic and John Price FEMARIII Access Control Chester County, East Pikeland Township Emergency John Price .FEMARIII Operations Center Chester County, East Pikeland Township Traffic and John Price FEMARIII Access Control Chester County,Emergency Worker Monitoring and John Price FEMARIII Decontamination Station Twin Valley FD Chester County, Great Valley School District Patricia Gardner FEMARIII Chester County, Great Valley School District, Great Patricia Gardner FEMARIII Valley High School Chester County, Great Valley School District, Great Patricia Gardner FEMARIII Valley Middle School 89

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester County, Owen J. Roberts School District Patricia Gardner FEMARlll Chester County, Owen J. Roberts School District, East Patricia Gardner FEMARlll Vincent Elementary School Chester County, Owen J. Roberts School District, Patricia Gardner FEMARlll French Creek Elementary School Chester County, Owen J. Roberts School District, West Patricia Gardner FEMARlll Vincent Elementary School Chester County, Phoenixville Area School District Patricia Gardner .FEMARlll Chester County, Schuylkill Township Emergency John Pri'ce FEMARlll Operations Center Chester County, Schuylkill Township Traffic and John Price FEMARlll Access Control Chester County, Uwchlan Township Emergency John Price FEMARlll Operations Center Chester County, Uwchlan Township Traffic and Access John Price FEMARlll Control Chester County, West Vincent Township Emergency John Price FEMARlll Operations Center Chester County, West Vincent Township Traffic and John Price FEMARlll Access Control Exelon Joint Information Center Joseph Suders FEMARIII Lehigh County Emergency Operations Center William McDougall FEMARlll Lehigh County Mass Care Center, Southern Lehigh William McDougall FEMARlll High School.

Lehigh County Monitoring and Decontamination William McDougall FEMARlll Center, Southern Lehigh High School Lehigh County Reception Center, Southern Lehigh High William McDougall FEMAR1II School Limerick Township Back Up Route Alerting Lee Torres FEMAR1II Limerick Township Back Up Route Alerting (2) Lee Torres FEMARlll Lower Pottsgrove Township Traffic and Access Control Lee Torres FEMARlll Point Montgomery County Emergency Operations Center Lee Torres FEMARlll Montgomery County Emergency Worker Monitoring Lee Torres FEMARlll and Decontamination Station, Indian Valley MS Montgomery County, Evacuee Lee Torres FEMARlll Monitoring/Decontamination Center, Plymouth Fire Company Montgomery County, Green Lane Borough/Marlboro Lee Torres FEMARlll Township Emergency Operations Center Montgomery County, Limerick Township Emergency Lee Torres FEMA RIil Operations Center Montgomery County, Limerick Township Traffic and Lee Torres FEMAR1II Access Control Montgomery County, Lower Frederick Township Lee Torres . FEMARlll Emergency Operations Center Montgomery County, Lower Pottsgrove Township Lee Torres FEMARlll Emergency Operations Center 90

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery County, Marlborough Township Traffic Lee Torres FEMA RIii and Access Control Montgomery County, Methacton School District, Patricia Gardner FEMARIII Montgomery County, Methacton School District, Patricia Gardner FEMARIII Eagleville Elementary School Montgomery County, Methacton School District, Patricia Gardner FEMARIII Methacton High School Montgomery County, Methacton School District, Patricia Gardner FEMARIII Woodland Elementary School Montgomery County, New Hanover Township Lee Torres FEMARIII

. Emergency Operations Center Montgomery County, New Hanover.Township Traffic . Lee Torres FEMARIII and Access Control Montgomery County, Perkiomen Township Emergency Lee Torres FEMA RIII Operations Center Montgomery County, Perkiomen Valley School District Patricia Gardner. FEMA RIii Montgomery County, Perkiomen Valley School District, Patricia Gardner FEMARIII Perkiomen Middle School East Montgomery County, Perkiomen Valley South Patricia Gardner FEMARIII Elementary School Montgomery County, Pottsgrove School District Patricia Gardner FEMARIII Montgomery County, Pottsgrove School District, Patricia Gardner FEMARIII Pottsgrove High School Montgomery County, Pottsgrove School District, West Patricia Gardner FEMARIII Pottsgrove Elementary School Montgomery County, Pottstown Area School District Patricia Gardner FEMARIII Montgomery County, Pottstown Area School District, Patricia Gardner *FEMARIII Lincoln Elementary School Montgomery County, Pottstown Area School District,

  • Patricia Gardner FEMARIII Pottstown High School Montgomery County, Reception Center Plymouth Fire Lee Torres FEMARIII Company Montgomery County, Souderton Area School District Patricia Gardner FEMA RIII Montgomery County, Souderton Area School District, Patricia Gardner FEMA RIii Salford Hills Elementary School Montgomery County, Spring-Ford Area School District Patricia Gardner FEMARIII Montgomery County, Spring-Ford Area School District, Patricia Gardner FEMARIII 5th & 6th Grade Center Montgomery Couno/, Spring-Ford Area School District, Patricia Gardner FEMARIII 7th Grade Center Montgomery County, Spring-Ford Area School District, Patricia Gardner FEMARIII 8th Grade Center (Old Middle School)

Montgomery County, Spring-Ford Area School District, Patricia Gardner FEMARIII Spring-Ford Area High School Montgomery County, Spring-Ford Area School District, Patricia Gardner FEMARIII Upper Providence Elementary Montgomery County, Trappe Borough Emergency Lee Torres FEMARIII Operations Center Montgomery County, Upper Perkiomen: School District, Patricia Gardner FEMARIII Upper Perkiomen High School 91

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery County, Upper Perkiomen School District Patricia Gardner FEMARIII Montgomery County, Upper Perkiomen School District, Patricia Gardner FEMARIII Marlborough Elementary School Montgomery County, Upper Perkiomen School District, Patricia Gardner FEMARIII I Uooer Perkiomen Middle School PA State Field Monitoring Team A, South East Region Michael Shuler FEMARIII PA State Field Monitoring Team B, South East Region Michael Shuler FEMARIII PA State Traffic and Access Control Points, State Police Joseph Suders FEMARIII Barracks, Troop J, Embreeville Pennsylvania Accident Assessment Center, State EOC- Michael Shuler FEMA RIil Bureau of Radiation Protection Pennsylvania Bureau of Radiation Protection, Michael Shuler FEMARIII Radiological Rapid Response Vehicle Pennsylvania Commonwealth Response Coordination Joseph Suders FEMARIII Center Pennsylvania Joint Information Center/Rumor Control Joseph Suders FEMA RIII West Vincent Township Back Up Route Alerting John Price FEMARIII West Vincent Township Back Up Route Alerting (2) John Price FEMARIII West Vincent Township Back Up Route Alerting (3) John Price FEMARIII LOCATION EVALUATOR AGENCY Berks County Emergency Operation Center Barbara Thomas FEMA Region 1 Berks County Emergency Operation Center John Rice FEMA Region 1 Berks County Emergency Operation Center Taneeka Hollins FEMA Region 1 Berks County Emergency Operation Center Nicholas Buis FEMARIII Berks County Emergency Worker Monitoring and Reggie Rodgers ICFI Decontamination Station, Daniel Boone Complex Berks County Mass Care Center, Governor Mifflin Brian Clark ICFI Senior High School Berks County Mass Care Center, Muhlenberg Senior Michael Henry ICFI High School Berks County Mass Care Center, Schuylkill Valley Bruce Swiren ICFI School Complex Berks County Monitoring and Decontamination Center, Paul Nied ICFI Schuylkill Valley School Berks County Monitoring and Decontamination Center, Thomas Hegele ICFI Governor Mifflin Senior High School Berks County Monitoring and Decontamination Station, BradMcRee ICFI Muhlenberg Senior High School Berks County Reception Center, Robeson Township Roy Smith ICFI Building Berks County, Boyertown Area School District Barbara Thomas FEMA Region 1 92

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Berks County, Boyertown Area School District, Taneeka Hollins FEMA Region 1 Boyertown Senior High School Berks County, Boyertown Area School District, Earl David Kayen ICFI Elementary School Berks County, Boyertown Area School District, New William McDougall FEMARIII Hanover/Upper Frederick ES Berks County, Boyertown Area School District, John Rice FEMA Region 1 Washington Elementary School Berks County, Boyertown Borough/Colebrookdale Clark Duffy ICFI Township Emergency Operations Center Berks County, Boyertown Borough/Colebrookdale Danny Loomis ICFI Township Emergency Operations Center Berks County, Boyertown Borough/Colebrookdale Clark Duffy ICFI Township Traffic and Access Control Berks County, Daniel Boone Area School District Nicholas Buls FEMARIII Berks County, Daniel Boone Area School District, Clark Duffy ICFI Birdsboro Elementary Berks County, Earl Township Emergency Operations Gary Bolender ICFI Center Berks County, Earl Township Emergency Operations Rosemary Samsel ICFI Center Berks County, Union Township Emergency Operations Ingrid Pierce Region 01 Center Berks County, Union Township Emergency Operations Rebecca Thomson ICFI Center Boyertown/Colebrookdale Back up Route Alerting (1) Gary Goldberg ICFI Boyertown/Colebrookdale Back up Route Alerting (2) Deborah Blunt ICFI Bucks County Emergency Operations Center William McDougall FEMARIII Bucks County Monitoring and Decontamination Center, John Wiecjorek ICFI Trevose Fire Company Bucks County Reception Center, Trevose Fire Company Roger Jobe ICFI Chester County Emergency Operations Center Miriam Weston FEMA Region 2 Chester County Emergency Operations Center John Price FEMARIII Chester* County Emergency Operations Center Patricia Gardner FEMARIII Chester County Emergency Operations Center Clayton Spangenberg ICFI Chester County Monitoring and Decontamination Deborah Blunt ICFI Center, West Whiteland 93

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester County Phoenixville Area School District, Roger Kowieski ICFI Manavon Elementary School & Phoenixville Area Early Leaming Center Chester County Reception Center, West Whiteland Gary Goldberg ICFI Township Chester County, Charlestown Emergency Operations Lisa Rink FEMAHQ Center Chester County, Charlestown Emergency Operations Alonzo Mcswain Headquarters Center Chester County, Downingtown Area School District John Price FEMARIII Chester County, Downingtown Area School District, Lenora Borchardt ICFI Downingtown High School East Chester County, Downingtown Area School District, Patricia Gardner FEMARIII Lionville Elementary School Chester County, Downingtown Area School District, Lisa Rink FEMAHQ Lionville Middle School Chester County, Downingtown Area School District, John Zeidler ICFI Uwchlan Hills Elementary School Chester County, East Coventry Township Emergency Kevin Reed ICFI Operations Center Chester County, East Coventry Township Emergency Ronald Bonner ICFI Operations Center . '

Chester County, East Coventry Township Traffic and Ronald Bonner ICFI Access Control Chester County, East Pikeland Township Emergency Brian Hasemann FEMA Region 2 Operations Center Chester County, East Pikeland Township Emergency Ryan Jones Region 01 Operations Center Chester County, East Pikeland Township Traffic and Ryan Jones Region 01 Access Control Chester County, Emergency Worker Monitoring and James Hickey ICFI Decontaminatfon Station Twin Valley FD Chester County, Great VaUey School District Michael Shuler FEMARIII Chester County, Great Valley School District, Great Ingrid Pierce Region 01 Valley High School Chester County, Great Valley School District, Great Clayton Spangenberg SLS Enterprises, Inc.

Valley Middle School Chester County, Owen J. Roberts School District Kent Tosch ICFI Chester County, Owen J. Roberts School District, East Ryan Jones Region 01 Vincent Elementary School Chester County, Owen J. Roberts School District, Gary Bolender ICFI French Creek Elementary School Chester County, Owen J. Roberts School District, West Richard Smith ICFI Vincent Elementary School 94

Unclassified

\

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester County, Phoenixville Area School District Roger Kowieski ICFI Chester County, Schuylkill Township Emergency Lynn Steffensen ICFI Operations Center Chester County, Schuylkill Township Emergency Meg Swearingen ICFI Operations Center Chester County, Schuylkill Township Traffic and Lynn Steffensen ICFI Access Control Chester County, Uwchlan Township Emergency James Greer ICFI Operations Center Chester County, Uwchlan Township Emergency Thomas Gahan ICFI Operations Center Chester County, Uwchlan Township Traffic and Access James Greer ICFI Control Chester County, West Vincent Township Emergency DavidKayen ICFI Operations Center Chester County, West Vincent Township Emergency Michael Meshenberg ICFI Operations Center Chester County, West Vincent Township Traffic and

  • Michael Meshenberg ICFI Access Control Exelon Joint Information Center Roger Kowieski ICFI Lehigh County Emergency Operations Center Richard Smith ICFI Lehigh County Mass Care Center, Southern Lehigh Michael Meshenberg ICFI High School Lehigh County Monitoring and Decontamination Michael Howe Headquarters Center, Southern Lehigh High School '

Lehigh County Reception Center, Southern Lehigh High Carol D. Shepard ICFI School Limerick Township Back Up Route Alerting Roger Jobe ICFI Limerick Township Back Up Route Alerting (2) Carol D. Shepard ICFI Lower Pottsgrove Township Traffic and Access Control Carl Wentzell ICFI Point Montgomery County Emergency Operations Center Lee Torres FEMARIII Montgomery County Emergency Operations Center Megean Brown FEMARIII Montgomery County Emergency Operations Center Bruce Swiren ICFI Montgomery County Emergency Operations Center Paul Nied ICFI Montgomery County Emergency Worker Monitoring Bart Ray ICFI and Decontamination Station, Indian Valley MS 95

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery County, Evacuee Thomas Essig ICFI Monitoring/Decontamination Center, Plymouth Fire Company Montgomery County, Green Lane Borough/Marlboro Brian Clark ICFI Township Emergency Operations Center Montgomery County, Green Lane Borough/Marlboro Michael Burriss ICFI Township Emergency Operations Center Montgomery County, Limerick Township Emergency Robert Duggleby ICFI Operations Center Montgomery County, Limerick Township Emergency Robert Lemeshka ICFI Operations Center Montgomery County, Limerick Township Traffic and Robert Lemeshka ICFI Access Control Montgomery County, Lower Frederick Township Michael Henry ICFI Emergency Operations Center Montgomery County, Lower Frederick Township James Hickey ICFI Emergency Operations Center Montgomery County, Lower Pottsgrove Township Carl Wentzell ICFI

. Emergency Operations Center Montgomery County, Lower Pottsgrove Township Robert Walker ICFI Emergency Operations Center Montgomery County, Marlborough Township Traffic Brian Clark ICFI and Access Control Montgomery County, Methacton School District, Henry Christiansen ICFI Montgomery County, Methacton School District, Lee Torres FEMARIII Eagleville Elementary School Montgomery County, Methacton School District, Megean Brown FEMARIII Methacton High School Montgomery County, Methacton School District, Robert Lemeshka ICFI Woodland Elementary School Montgomery County, New Hanover Township Henry Christiansen ICFI Emergency Operations Center Montgomery County, New Hanover Township John Zeidler ICFI Emergency Operations Center Montgomery County, New Hanover Township Traffic Henry Christiansen ICFI and Access Control Montgomery County, Perkiomen Township Emergency BradMcRee ICFI Operations Center Montgomery County, Perkiomen Township Emergency Dennis Wilford ICFI Operations Center Montgomery County, Perkiomen Valley School District Miriam Weston FEMA Region 2 Montgomery County, Perkiomen Valley School District, Bart Ray ICFI Perkiomen Middle School East Montgomery County, Perkiomen Valley South Carl Wentzell ICFI Elementary School 96

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery County, Pottsgrove School District Christopher Nemcheck FEMARJII Montgomery County, Pottsgrove School District, Christopher Nemcheck FEMARJII Pottsgrove High School Montgomery County, Pottsgrove School District, West Rosemary Samsel ICFI Pottsgrove Elementary School Montgomery County, Pottstown Area School District Alonzo Mcswain Headquarters Montgomery County, Pottstown Area School District, Alonzo Mcswain Headquarters Lincoln Elementary School Montgomery County, Pottstown Area School District, Joseph Suders FEMARIII Pottstown High School Montgomery County, Reception Center Plymouth Fire Dennis Wilford ICFI Company Montgomery County, Souderton Area School District Ronald Bonner ICFI Montgomery County, Souderton Area School District, Kevin Reed ICFI Salford Hills Elementary School Montgomery County, Spring-Ford Area School District Rebecca Thomson ICFI Montgomery County, Spring-Ford Area School District, Meg Swearingen ICFI 5th & 6th Grade Center Montgomery County, Spring-Ford Area School District, Thomas Gahan ICFI 7th Grade Center Montgomery County, Spring-Ford Area School District, James Greer ICFI 8th Grade Center (Old Middle School) .

Montgomery County, Spring-Ford Area School District, Robert Walker ICFI Spring-Ford Area High School Montgomery County, Spring-Ford Area School District, Lynn Steffensen ICFI Upper Providence Elementary Montgomery County, Trappe Borough Emergency Lenora Borchardt ICFI Operations Center

  • Montgomery County, Trappe Borough Emergency Thomas Essig ICFI Operations Center Montgomery County, Upper Perkiomen School District, Brian Hasemann FEMA Region 2 Upper Perkiomen High. School Montgomery County, Upper Perkiomen School District. Brenda Rembert ICFI Montgomery County, Upper Perkiomen School District, Thomas Hegele ICFI Marlborough Elementary School Montgomery County, Upper Perkiomen School District, Robert Duggleby ICFI Upper Perkiomen Middle School PA State Field Monitoring Team A, South East Region Cristina Schulingkamp ICFI PA State Field Monitoring Team B, South East Region Reggie Rodgers ICFI 97

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station PA State Traffic and Access Control Points, State Police Kent Tosch ICFI Barracks, Troop J, Embreeville Pennsylvania Accident Assessment Center, State EOC- Michael Howe Headquarters Bureau of Radiation Protection Pennsylvania Bureau of Radiation Protection, Michael Shuler FEMARIII Radiological Rapid Response Vehicle Pennsylvania Commonwealth Response Coordination Joseph Suders FEMA RIII Center Pennsylvania Commonwealth Response Coordination Christopher Nemcheck FEMARIII Center Pennsylvania Joint Information Center/Rumor Control Christopher Nemcheck FEMARIII West Vincent Township Back Up Route Alerting Brenda Rembert ICFI West Vincent Township Back Up Route Alerting (2) Roy Smith ICFI West Vincent Township Back Up Route Alerting (3) John Wiecjorek ICFI 98

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station APPENDIX C: ACRONYMS AND ABBREVIATIONS ACS Auxiliary Communications Service AO Agriculture Officer AP Assistant Principal ARC American Red Cross ARRA Area Requiring Corrective Action ARES Amateur Radio Emergency Services BCEOC Berks County Emergency Operations Center CCEOC Chester County Emergency Operations Center .

CCEPRS Chester County Emergency Preparedness Radio System CERT Crisis Emergency Response Team CRCC Commonwealth Response Coordination Center DRD Direct Reading Dosimeter DT Douglass Township EAL Emergency Action Level EAS Emergency Alert System ECC Emergency Communications Center ECL Emergency Classification Level EDO Emergency Duty Officer EMA Emergency Management Agency EMC Emergency Management Coordinator EMD Emergency Management Director EMS Emergency Medical Services EOC Emergency Operations Center*

EOCD Emergency Operations Center Director EPLO Emergency Preparedness Liaison Officer EPT Emergency Preparedness Team EPZ Emergency Planning Zone ERP Emergency Response Procedure

  • ERT Emergency Response Team ESF Emergency Support Function EW Emergency Workers FAA Federal Aviation Authority FCP Forward Command Post FEMA Federal Emergency Management Agency FRT Facility Response Team GE General Emergency GIS Geospatial Information System nc Joint lnfonnation Center LGS Limerick Generating Station LSC Logistic Section Chief MC Montgomery County MCCEOC Montgomery County Emergency Operations Center 99

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station MCT Mobile Computer Terminal MDC Mobile Data Computer MDT Mobile Data Terminal MERT Medical Emergency Response Team MPS Municipal Planner Specialist MTFD Montgomery Township Fire Department NARS Nuclear Accident Reporting System ORO Offsite Response Organization PAD Protective Action Decision PBEMA Phoenixville Borough Emergency Management Agency PBEOC Phoenixville Borough Emergency Operations Center PCS Personal Communications Services PEIRS Pennsylvania Emergency Incident Reporting System PEMA Pennsylvania Emergency Management Agency PIO Public Information Officer PM Portal Monitor PRD Permanent Radiation Dosim*eter PSP Pennsylvania State Police PWD Public Works Department RACES Radio Amateur Civil Emergency Services RAT Route Alerting Teams REOP Radiological Emergency Operations Plan REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RO Radiological Officer RSAN Roam Secure Alert Network RSO Radiation Safety Officer SAC Staging Area Commander SAE Site Area Emergency SEOC State Emergency Operations Center SEVAN Statewide Emergency Voice Activation Network SSL School Services Liaison TCP Traffic Control Points Tl~DE Total Effective Dose Equivalent TLD Thermos Luminescent Dosimeter 100

unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station APPENDIX D.: EXTENT OF PLAY AGREEMENT The 2017 Limerick Generating Station Plume Exercise Extent-of-Play was negotiated and agreed upon by FEMA Region III, Pennsylvania Emergency Management Agency, and the Emergency Management Agencies of the Risk Counties.

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After Action Report/Improvement Pl~n Limerick Generating Station

{tFEMA LIMERICK PLUME EXPOSURE PATHWAY EXERCISE By signing th.is Extent of Play Agreement the Commonwealth of Pennsylvania and the FEMA ~egion Ill exercise planning team confirm that all conditions have be.en met to satisfy the requirements to drive exercise play and satisfy the Demonstration Criteria as agreed upon for the November 14, 2017 Limerick 2017 Plume Exposure Pathway Exercise.

. 7

. FEMA SITE SPECIALIST LEAD STATE PLANNER

~ .

FEMA TEAM LEAoE~

. 102

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION EXTENT OF PLAY 2017 RADIOLOGICAL EMERGENCY

  • PREPAREDNESS -EXERCISE 103

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station THIS PAGE IS INTENTIONALLY LEFT BLANK 104

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table of Contents METHOD OF OPERATION ......................................*.......... ~ ......... ~ ..........................-.....-....... 106 I. L_imerick Generating Station (LGS) ................................................*................. ~ .......... 106 II. Bureau of Radiation Protection (BRP) ....................................*.............. ;................*..... _106 Ill PEMA Operations at the CRCC .............*........................... .-.... .- .... :*************************** 106 IV. PEMA Area Office Operations .. ~ .............................................................................. 108 V. Counties Designated to Participate .............................................................................. 108 VI. PEMA Liaison Officers ................................................................................*.............. 108 VII. Controllers ................................................................................................... ~ .............. 108 VIII. PEMA Observers ........................................................................................................ 108 IX. FEMA Evaluators ......................... ~ .............

110 X. Demonstration Windows ..... ~ ... ;..........................................................................*.......... 110 XI. Stand-down ..............*................................................................................................... 111 XII. General Con_cepts ......................... .-.................................... _.; ....................................... 111 XIII. Re-demonstrations ..................................................................................................... 112 EXTENT-OF-PLAY AGREEMENJ:'.: ....... :........... ~ ....................*..._................... ~ ......:............. 113 EVALUATION AREA 1 ............. ;................................................ ;....................................... 113 EVALUATION AREA 2 .~.................................................................................................... 123 EVALUATION AREA.3 .............. ;................................................................................... :... 132 EVALUATION AREA 4 ........................................... '. .......................................................... 143 EVALUATION AREA 5 .............*........................................................................................ 151 EVALUATION AREA 6 ..........................................................*........................................... 159 AMERICAN RED CROSS RISK AND SUPPORT COUNTY CHAPTERS: .................... 168 ATTACHMENT A .......................................... '. ...................................................... :........ ~ ......... 172 I. Plume Phase Exercise .................................................................................................... 172 II. Mass Care Center Walkdowns ..................................................................................... 178 ATTACHMENT B .........................*.......................................................................................... 180 105

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION 2017 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE METHOD OF OPERATION I. Limerick Generating Station (LGS)

The facility normally uses off-watch section personnel to participate in the exercise. The

  • plant's simulated events, radiation readings, and emergency classifications will trigger offsite exercise actions. A pre-approved exercise scenario will be used. LGS will notify the Commonwealth Response Coordination Center (CRCC), the Bureau of Radiation Protection and Risk Counties of emergency classifications.

IL Bureau of Radiation Protection (BRP)

BRP personnel will be present at the CRCC, the nuclear facility EOF, Branch and field locations; BRP field teams will NOT be evaluated during this exercise. BRP field teams will perform air sampling out-of-sequence, preferably before they deploy to the plume area.

This is for observation only by FEMA.

III. . PEMA Operations at the CRCC This "Method of Operation" Document includes activities for the Full-Scale Plume Exercise (November 14, 2017), and the "Out-of-sequence" Activities (November 15, 2017).

A. Plume Exercise - November 14, 2017 PEMA staff, augmented by designated PEMA personnel from the Fire Commissioner's Office, the Bureau of Administration, Technical Services, Planning, Training, and Exercise, plus Agency Representatives (~Ps) with accompanying response team members from designated state departments/agencies, including representatives.from the USDA State Emergency Board will comprise. initial operations at the CRCC. The CRCC will not be evaluated during this exercise.

B. Plume Exercise- "Out-of-Sequence" Activities - November 14, 2017 PEMA staff, augmented by designated PEMA personnel will disseminate exercise related messages to the participating Counties for dissemination to the participating School Districts during the morning ofNovember 14, 2017. The CRCC and County EOCs will NOT be evaluated during the "Out-of-Sequence" component. PEMA personnel will serve as "Observers" at the identified School Districts.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station C. "Out-of-Sequence" Activities- November 15, 2017 PEMA personnel will serve as "Observers" at the various field exercise locations during the evening "Out-of-Sequence" component November 15, 2017. An exercise coordinator will remain in the CRCC. The CRCC and Counties will NOT be evaluated during the evening "Out-of-Sequence" component.

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After Action Report/Improvement Plan Limerick Generating Station The Pennsylvania State Police (PSP) demonstration will take place at PSP Troop J -Embreeville Barracks, 997 Lieds Road, Coatesville, Chester County. The PSP briefing will be performed out-of-sequence in a demonstration window of 10:00 a.m. to 12:00 noon on November 15, 2017.

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

V. Counties Designated to Participate The three risk counties (Berks, Chester, and Montgomery), in coordination with PEMA, will demonstrate the capability to mobilize appropriate staff, activate their respective Emergency Operations Centers and implement emergency response operations to include sheltering and/or evacuation. County government will provide direction and coordination to risk municipalities. The two support counties (Bucks and Lehigh) will participate in their assigned support roles. Actual sheltering or evacuation of the general public will be simulated.

  • VI. PEMA Liaison Officers Liaison officers will be present at the participating risk and support county EOCs, the LGS Emergency Operations Facility (EOF), and LGS Joint Information Center (JIC) to provide assistance, guidance, and support. These liaison officers will participate as players in the exercise.

VIL Controllers A lead controller will be present in the CRCC on November 14, 2017. Controllers will be pre~ent at the emergency worker monitoring/decontaminating stations and the mass care monitoring/decontamination centers (November 15, 2017). Controllers are not players.

Controllers will provide pre-approved injects and information to the players, as appropriate, regarding radiological readings during the monitoring of personnel. Live radioactive sources will not be used. Exception: Individuals tasked with the setup ofportal monitoring equipment will use a standard I micro curie Cesium 13 7 source for the purpose of conducting operational tests. Additionally, appropriate test sources will be available and used to verify the operation of the monitoring/survey instruments per manufacturer's recommendations.

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

Observers will not take an active part in the proceedings, but will interact with staff 108

Unclassified Radiological Emergency Preparedness Program.(REP)

After Action Report/Improvement Plan Limerick Generating Station members to the extent necessary to fulfill their observer responsibilities. Coaching of players by observers is not permitted except to provide training to participants awaiting a re-demonstration. (Refer to paragraph XIII) 109

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station IX. FEMA Evaluators Federal evaluators will be present at the risk and support county EOCs, identified risk municipal EOCs; and at appropriate field locations to evaluate player response to the actual and simulated events in the exercise scenario. FEMA will evaluate approximately one-Jourth of the risk municipalities in Berks, Chester, and Montgomery Counties.

Out-of-Sequence Period (November 14 and 15, 2017): On November 14, Federal evaluators will be present. at the identified "out-of-sequence" demonstration sites per Attachment A, Section I.A. I. These include the identified Public School Districts and participating school buildings. On November 15, Federal evaluators will also be present at identified Reception Centers, Emergency Worker Monitoring and Decontamination Stations, Mass Care Centers and Mass Care Monitoring and Decontamination Centers, as

  • identified in Attachment A, Sections I.B.l, I.B.2, I.B.3, and I.B.4.

Plume Phase Exercise (November 14, 2017): Federal evaluators will be present at the identified risk and support county EOCs to evaluate player response to the actual and simulated events in the exercise scenario. Additionally, approximately one-third of the risk municipalities will be federally evaluated.

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

The "demonstration windows" for this exercise are:

A. Plume Phase Exercise The out-of-sequence MS-1 hospital demonstration will be federally evaluated at Brandywine Hospital, Chester County on September 28, 2017.

Twenty-five mass care centers (0 in Berks, 18 in Bucks, 0 in Chester, 3 in Lehigh, and 4 in Montgomery) will receive "assessment" baseline evaluations on October 30 and 31, 2017. These 25 mass care centers will not be evaluated during the evening of November 15. There are three co-located Mass Care/Monitoring and Decontamination Centers in Berks and one in Lehigh that will be evaluated on the evening of November 15. (Please refer to the Extent-of-Play Demonstration Tables, Attachment A)

The mass care assessment will have team(s) consisting of a FEMA Evaluator, PEMA, County Representative, ARC Representative, and Exelon Representative (optional). The mass care centers mentioned will have a team enter the facility to verify layout, usable common areas, square footage estimate, and capability of 110

Unclassified Radiological Emergency Preparedness Program (REP).

After Action Report/Improvement Plan Limerick Generating Station being used as a mass care facility. An assessment of mass care facilities scheduled for evaluation will be accomplished to satisfy FEMA's evaluation process.

The out-of-sequence exercise window for school demonstrations will be on November 14, 2017 from 9:00 - 11 :00 a.m.

County and municipal EOC operations will be conducted on November 14, 2017 with exercise period from approximately 4:00 - 10:00 p.m. unless terminated by the Lead Controller in coordination with the Utility and PEMA. (Please refer to the Extent of Play Demonstration Tables, Attachment A)

The out-of-sequence interview of PSP traffic control/access control points will be on November 15, 2017 from 10:00 a.m. -12:00 p.m.

The out-of-sequence demonstration of reception centers, mass care centers (as indicated), monitoring/decontamination centers and emergency worker stations will be conducted on November 15, 2017 from 7:00 - 9:30 p.m. Locations are specified within Attachment A, Sections LB.I; I.B.2, I.B.3, and I.B.4.

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

B. Post Plume Exercise No post-plume phase exercise is scheduled during this evaluation.

XI. Stand-down

,All jurisdictions will request approval on a jurisdiction by jurisdiction basis prior to stand-down. Upon completion of all requirements and after having informed the.FEMA evaluator that all evaluation areas have been demonstrated and/or completed, the risk municipality EOGs may request approval from their county EOC to stand-down their portion of the exercise.

A. Support counties may request approval to stand-down upon completion of all evaluated objectives from the CRCC.

B. The risk county EOC will remain operational until the exercise is officially terminated by the State Lead Controller. The CRCC will issue an Exercise Termination Message.

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

The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a 111

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station plan that they cannot take actions that are more protective of the public. Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so that the plan can be modified and_ the appropriate negative assessment applied.

XIII. Re-demonstrations During the exercise, any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants provided it does not negatively interfere with the exercise. Refresher training may be provided by'the players, observers, and/or controllers.

Evaluators are not permitted to provide refresher training. Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. PEMA may advise the RAC Chair prior to initiating any re-demonstrations. It is permissible to extend the demonstration window, within reason, to accommodate the re-demonstration. Activities*

corrected from a re-demonstration will be so noted.

112

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station LIMERICK GENERATING STATION 2017 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE EXTENT-OF-PLAY AGREEMENT EVALUATION AREA 1 Emergency Operations Management Sub-element 1.a - Mobilization INTENT

  • This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and 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/FEMA-REP-1, A.La, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; H.3, 4)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, out-of-sequence evaluation or by means of drills conducted at any time.

Responsible OROs must demonstrate the capability to receive notification of an incident from the licensee; verify the notification; and contact, alert, and mobilize key emergency personnel in a timely manner, and demonstrate the ability to maintain and staff 24-hour operations.

Twenty-four-hour operations can be demonstrated during the exercise via rosters or shift changes or otherwise in an actual activation. Local and/or Tribal responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner when they receive information from the licensee or alternate sources. Responsible OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. Activation of facilities and staff, including those associated with the Incident Command System, must be completed in accordance with ORO plans/procedures. The location and contact information for facilities included .in the incident command must be available to all appropriate responding agencies and the NPP after these facilities have been activated.

Pre-positioning of emergency personnel is appropriate, in accordance with the Extent-of-Play*

Agreement, at those facilities located beyond a normal commuting distance from the individual's duty location or residence. This includes the staggered release of resources from an assembly area.

Additionally, pre-positioning of staff for out-of-sequence demonstrations may be used in accordance with the Extent-of-Play Agreement.

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After Action Report/Improvement Plan Limerick Generating Station The REP program does not evaluate Incident Command Post tactical operations (e.g., Law Enforcement hostile action suppression techniques), only coordination among the incident command, the utility, and all ~ppropriate OROs, pursuant to plans/procedures.

Initial law enforcement, fire service, HAZMAT, and emergency medical response to the NPP site may impact the ability to staff REP functions. The ability to identify and request additional resources or identify compensatory measures must be demonstrated. Exercises must also address the role of mutual aid in the incident, as appropriate. An integral part of the response to an HAB scenario at an NPP may also be within the auspices of the Federal Government (e.g., FBI, NRC, or DHS). Protocols for requesting Federal, State, local, and Tribal law enforcement support must be demonstrated, as appropriate. Any resources must be on the ORO's mobilization list so they can be contacted during an incident, if needed.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Pre-positioning of state emergency personnel (Liaison Officers) at the Emergency Operations Facility (EOF), the Utility Joint Information Center (JIC) and Risk and Support Counties is appropriate due to the commuting distance from the individual's duty location or residence. Risk counties/municipalities will conduct call-outs to demonstrate the mobilization of key personnel.

The utility JIC will be evaluated for this drill.

  • Actual calls (or pager notifications) will be made to the county/municipal EOC personnel for the Plume Phase exercise per plans and procedures.
  • In all instances, the demonstration of a shift change is NOT required. Twenty-four hour staffing will be demonstrated by means of a roster or staffing chart.
  • All out-of-sequence players will be pre-positioned and equipment will be demonstrated or shown to be inventory (School District personnel, PSP TCP/ACP, Reception Centers, Emergency Worker Monitoring and Decontamination Stations Mass Care/Sheltering Centers and Monitoring and Decontamination Centers).
  • Individuals working in state facilities and county EOCs may be pre-positioned for the plume phase.
  • Other locations, including Municipal EOCs, will NOT pre-stage but will wait for notification of emergency before staffing their duty location.

Sub-element 1.b - Facilities INTENT

. This sub-element derives from NUREG-0654/FEMA-REP-1, which provides that OROs have facilities to support the emergency response.

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

(NUREG-0654/lFEMA-REP-1, G.3.a; H.3; J.10.h; J.12; K.5.b) 114

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

  • Limerick Generating Station Assess men t/Exten t-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, SAVs, or by out-of-sequence evaluations.

Responsible OROs must demonstrate, no less than once every eight years, the availability of facilities to support accomplishment of emergency operations. This includes all alternate and backup facilities. Evaluations are typically performed for EOCs and JICs, as well as other facilities such as reception/relocation centers. Some of the areas evaluated within the facilities are adequate space, furnishings, lighting, restrooms, ventilation, access to backup power, and/or alternate facility, if required to support operations. Radio stations, laboratories, initial warning points and hospitals are not evaluated under l .b. l.

In addition, facilities will be evaluated for this criterion during the first biennial exercise after any new or substantial changes in structure, equipment, or mission that affect key capabilities, as outlined in respective emergency plans/procedures. A substantial change is one that has a direct effect or impact on emergency response operations performed in those facilities. Examples of substantial changes include modifying the size or configuration of an emergency operations center, adding more function to a center, or changing the equipment available for use in a center.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

None Sub-element 1.c - Direction and Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs 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/FEMA-REP-1, A.1.d; A.2.a, b; A.3; C.4, 6)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished in a biennial or tabletop exercise.

Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and requests.)

115

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement

  • resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident, if needed.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent of Play None 116

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Sub-element 1.d - Communications Equipment INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which reqmres that OROs establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such *as contiguous governments within the EPZ, Federal emergency response organizations, the licensee and its facilities, EOCs, Incident Command Posts, and FMTs.

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

(NUREG-0654/FEMA-REP-1, F.1, 2)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion is accomplished initially in a baseline evaluation and subsequently in periodic testing and drills. System familiarity and use must be demonstrated as applicable in biennial or tabletop exercise, or if their use would be required, during an actual event.

OROs must demonstrate that a primary system and at least one backup system are fully functional at all times. Communications systems are maintained and tested on a recurring basis throughout the assessment period and system status is available to all operators. Periodic test results and corrective actions are inaintained on a real time basis. 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 are used as needed for transmission and receipt of exercise messages. All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. Exercise scenarios may require the failure of a communication system and use of an alternate system, as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-:of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Risk and Support Counties will communicate with the CRCC via SEVAN (primary) and e-mail (secondary.) PASTAR, State 800 MHz Radio System, and commercial telephone are available for back-up. The CRCC may communicate with the utility and the risk counties via dedicated telephone circuits, commercial "dial-up" lines, or other available means.

117

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Risk. Counties will communicate with their risk municipalities via public safety radio frequencies (EMA Radio), Commercial Telephone, Fax, or Amateur Radio Communications (ARES/RACES) or other available means.

118

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

  • Limerick Generating Station Sub-element 1.e - Equipment and Supplies to Support Operations*

INTENT This Sub-element is derived from NUREG-0654/FEMA.-REP-1, which requires that ORO~ have

. emergency equipment and supplies adequ~te to support the emergency response.

Criterion 1.e.1: Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (Kl) and other supplies are sufficient to support emergency operations.

(NUREG-0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation and subsequent periodic inspections.

A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is encouraged. For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows:

KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized indi'viduals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transients) within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special.

Weapons and Tactics Teams, urban search and rescue, bomb' squads, HAZMAT, or other ancillary groups) as identified in plans/procedures. The plans/procedures must include the forms to be used 1 for documenting emergency worker ingestion of KI, as well as a mechanism for. identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined KI in advance.

ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical . il).spection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV.

Available supplies of KI must 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.

Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to perform an ORO mission. In addition, OROs must demonstrate provisions to make 119

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures.

120

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After Action Report/Improvement Plan Limerick Generating Station Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures.

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary.

Civil Defense Victoreen Model 138s (CD V-138s) (0-200 mR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary. This leakage testing will be verified during the exercise through documentation submitted in the ALC and/or through an SAV.

Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer's instructions and be verified during the exercise, through documentation submitted in the ALC and/or through an SAV.

Monitoring Instruments: All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation must be calibrated annually. Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source.

For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta radiation. These instruments must be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on air sample collection media, consistent with the intended use of the instrument and the ORO's plans/procedures. An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than IR/hr) and for high-range instruments when available. If a source is not available for a high-range instrument, a procedure must exist to operationally test the instrument before entering an area where only a high-range instrument can make useful readings.

In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

Mutual Aid Resources: If the incoming resources arrive with their own equipment (i.e., monitors and/or dosimetry), they will be evaluated by REP Program standards. FEMA will not inventory equipment that is not part of the REP Program. If an agency has a defined role in the REP Plan, they are subject to the planning process and standards, as well as the guidance of this Manual.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

121

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station PEMA Negotiated Extent-of-Play:

In Pennsylvania, support counties do not have DRDs or KI, but those responsible for reception centers and/or monitoring and decontamination centers will have PRDs.

Evaluation of DRD and Kl quantities will be verified using inventory sheets. DRDs and Kl will not be removed from storage locations and boxes/packages will not be opened. Kl questions will be addressed through interviews.

Leakage testing verification and Kl extension letters (as appropriate) will be available to the evaluator.

All DRDs "read" in units of Roentgens. The commonwealth, counties and municipalities do not use direct reading dosimeters which "read" in units of milli-Roentgens.

I 122

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA2 Precautionary and/or Protective Action Decision-Making Sub-element 2.a - Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans/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 that emergency workers may be pennitted to incur during an emergency. These limits include any pre-established administrative reporting limits (that take into consideration TEDE or organ-specific limits) identified in the ORO's plans/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/FEMA-REP-1, C.6; f; K.3.a; K.4)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be assessed concurrently with a licensee exercise

. and may be demonstrated in a biennial or tabletop exercise.

OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures.

Participating OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number of emergency workers receiving radiation dos.es above pre-authorized levels. This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

As appropriate, OROs must demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for emergency workers, based on their plans/procedures or projected thyroid dose compared with the established PAGs for KI administration.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

123

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station PEMA Negotiated Extent-:of-Play:

None 124

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Sub-element 2.b. - Radiological Assessment, Protective Action Recommendations, and Precautionary and/or Protective Action Decisions for the Plume Phase of the Emergency INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PAGs.

OROs must have the capability to choose among a range of protective actions, those most appropriate in a given emergency. OROs base these choices on PAGs from their plans/procedures or EPA' s Manual of Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria, such as plant conditions, licensee PARs, coordination of precautionary and/or protective action decisions with other political jurisdictions (e.g., other affected OROs and incident command), availability of in-place shelter, weather conditions, and situations, to include HAB incidents, the threat posed by the specific hostile action, the affiliated response, and the effect of an evacuation on the threat response effort that create higher than normal risk from general population evacuation.

Criterion 2.b.1: Appropriate protective action recommendations (PARs) ,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/FEMA-REP-1, 1.10 and Supplement 3)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.

During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO must demonstrate the capability to use appropriate means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring data if available. The ORO must also consider any release and meteorological data provided by the licensee.

The ORO must 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 must be appropriate to th~ scenario. In all cases, calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. PARs must be promptly transmitted to decision-makers in a prearranged format.

When the licensee and ORO 'projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the PARs if timely and appropriate._ The ORO must demonstrate the capability 125

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station to use any additional data to refine projected doses and exposure rates and revise the associated PARs.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

(

126

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station PEMA Negotiated Extent-of-Play:

If the scenario has no radiological release, or potential of a radiological release, the decision-making process used to make PARs can be addressed through an interview.

Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make precautionary and/or protective action decisions for the general public (including the recommendation for the use of KI, if ORO policy).

(NUREG-0654/FEMA-REP-1, A.3; C.4, 6; D.4; J.9; J.10.e, f; m)

  • Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.

OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions. OROs must demonstrate the capability to make initial precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action.

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure.

Dose assessment personnel may provide additional PARs based on the subsequent dose projections, field monitoring data, or information on plant conditions. In addition, incident command must provide input regarding. considerations for subsequent PARs based on the magnitude of the ongoing threat, the response, and/or site conditions. The decision-makers must demonstrate the capability to change protective actions based on the combination of all these factors.

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

If more than one ORO is involved in decision making, all appropriate OROs must communicate an'd coordinate precautionary and/or protective action decisions with each other. In addition, 127

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

128 L

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station PEMA Negotiated Extent-of-Play:

None Sub-element 2.c - Precautionary and/or Protective Action Decision Consideration for the Protection of Persons with Disabilities and Access/Functional Needs INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to determine precautionary and/or protective action decisions, including evacuation, sheltering, and use of KI, ifapplicable, for groups of persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals). The focus is on those groups of persons with disabilities and access/functional needs that are or potentially will be affected by a radiological release from an NPP.

Criterion 2.c.1: Precautionary and/or protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs.

(NUREG-0654/FEMA-REP-1, D.4; J.9; J.10.d, e)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise that would include the use of plant conditions transmitted from the licensee.

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 incidents where there is a high-risk environmental condJtion or where high-risk groups (e.g., the immobile or infirm) are involved. In these cases, factors that must be considered include weather conditions, shelter availability, availability of transportation assets, risk of evacuation versus risk from the avoided dose, and precautionary school evacuations. In addition, decisions must be coordinated/communicated with the incident command. In situations where an institutionalized population cannot be evacuated, the ORO must consider use of KI.

Applicable OROs must demonstrate the capability to alert and notify all pubiic school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students. Demonstration requires that the OROs actually contact public school systems/districts during the exercise.

The OROs must demonstrate how the decision-making process takes those with disabilities and access/functional needs (e.g.,

nursing homes, correctional facilities, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals) into account.

In accordance with plans/procedures, OROs and/or officials of public school systems/districts must demonstrate the capability to make prompt decisions on protective actions for students. The decision-making process, including any preplanned strategies for protective actions for that ECL, 129

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station must consider the location of students at the time (e.g., whether the students are still at home, en route to school, or at school).

130

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Since other agencies place requirements on hospitals to prepare for contaminated patients, the REP Program has no need to evaluate hospitals in the EPZ that need to evacuate, or the facilities that are receiving these evacuees, nor does the ORO have the responsibility to provide training or dosimetry to these hospitals/facilities. Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

If the scenario has no radiological release, or potential of a radiological release, the decision-making process used to make PARs can be addressed through an interview.

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 Post-Plume Phase Relocation, Reentry, and Return This sub-element will not be evaluated during this exercise.

131

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA3 Protective Action Implementation Sub-element 3.a-Implementation of Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KI for emergency workers, always applying the "as low as is reasonably achievable" principle as appropriate.

Criterion 3.a.1: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/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. OROs maintain appropriate record-keeping of the administration of KI to emergency workers.

(NUREG-0654/FEMA-REP-1, K.3.a, b; K.4)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and instructions on the use of these items. For evaluation purposes, appropriate

'direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.

During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and tum-back values are reached. The emergency worker must report accumulated exposures during the exercise as indicated in the 132

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station plans/procedures. OROs must demonstrate the actions described in the plans/procedures by determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must i,nterview at least two workers to determine their knowledge of whom 'to contact in case authorization is needed, and at what exposure levels. Workers may use any available resources (e.g., written procedures and/or coworkers) 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. In such cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimeter worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry.

Individuals authorized by the ORO to reenter an evacuated area during the plume (emergency) phase must be limited to the lowest radiological exposure commensurate with completing their missions.

OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers performing various services (e.g., lifesaving, protection of valuable property, all activities). OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require. an urgent response.

OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it.

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

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, *unless noted above or otherwise specified 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 Kl and on whose authority.

Distribution of Kl will be simulated. A maximum of six (6) Dosimetry-Kl report forms will be demonstrated.

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

133

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 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 turn-back 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. The area kit process is explained in State, County and Municipal Plans.

Standard issue of dosimetry and potassium iodide for each category of emergency Worker is as follows:

Category A: 1 PRD, 1 DRD, and 1 unit of Kl CategoryB: 1 PRD and 1 unit ofKl Category C: 1 PRD All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP), will make the dosimetry equipment (and Kl) available for inspection by the Federal Evaluator. Simulation PRDs with mock serial numbers will be used.

Personnel assigned to operate monitoring/decontamination centers and stations are not issued DRDs or Kl since the centers/stations are located outside the EPZ. Each will be issued a simulated P RD with mock serial numbers. For purposes of demonstration, a maximum of six PRDs will be issued.

Sub-element 3.b - Implementation of KI Decision for Institutionalized Individuals and the General Public INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the. capability to provide KI for institutionalized individuals, and, if in the plans/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 institutionalized individuals, providing KI to the general public is an ORO option and must be reflected as such in ORO plans/procedures. Provisions must include the availability of adequate quantities, storage, and means of distributing KL Criterion 3.b.l: KI and appropriate instructions are available if a decision to recommend use of KI is made. Appropriate record-keeping of the administration of KI for institutionalized individuals is maintained. (NUREG-0654/FEMA-REP-1, J.10.e, f)

Assessment/Extent-of-Play 134

Unclassified Radiological Emergency'Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise. Other means may include drills, seminars, or training activities that would fully demonstrate technical proficiency.'

OROs must demonstrate the capability to m:ake KI available to institutionalized individuals, and, where provided for in their plans/procedures, to members of the general public. OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made. OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KL Ingestion of KI recommended by the designated ORO health official is voluntary .. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it.

135

,' Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Within Pennsylvania, the Pennsylvania Department of Health is responsible for distribution of Kl to the general public located within the EPZ. Pre-distribution is accomplished on an annual basis.

Kl is not distributed to the general public at the time of an emergency.

Evaluation of emergency worker Kl quantities will be verified using inventory sheets. Kl will not be removed from storage locations and boxes will not be opened. Kl quesfi(!nS will be addressed through interviews.

Personnel assigned to operate monitoring/decontamination centers and stations are not issued DRDs or Kl since the centers/stations are located outside the EPZ. Each will be issued a simulated PRD with mock serial numbers. For purposes of demonstration, a maximum of six P RDs will be issued.

Sub-element 3.c - Implementation of Precautionary and/or Protective Action Decisions for Persons with Disabilities and Access/Functional Needs INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement precautionary and/or protective action decisions, including evacuation and/or sheltering, for all persons with disabilities and access/functional needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological release from an NPP.

  • Criterion 3.c.1: Precautionary and/or protective action decisions are implemented for persons with disabilities and access/functional needs other than schools within areas subject to protective actions. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, or by means of drills conducted at any time.

Applicable OROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency information and instructions to) persons with disabilities and access/functional needs, including hospitals/medical facilities, licensed day cares, nursing homes, correctional facilities, and mobility-impaired and transportation-dependent individuals. OROs must demonstrate the capability to provide for persons with disabilities and access/functional needs in accordance with plans/procedures.

136

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Contact with persons with disabilities and access/functional needs and reception facilities may be actual or simulated, as agreed to in the Extent-of-Play. Some contacts with transportation providers must be actually contacted, as negotiated in the Extent-of-Play. All actual and simulated contacts must be logged.

137

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limeric)< Generating Station Since other agencies place requirements on hospitals to prepare for contaminated patients, the REP Program has no need to evaluate hospitals in the EPZ that need to evacuate, or the facilities that

  • are receiving these evacuees, nor does the ORO have the responsibility to provide training or dosimetry to these hospitals/facilities. Additionally, hospital evacuation plans do not need to be
  • reviewed or tested by the REP program.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

The names, locations and contact information ofidentified individuals with identified special needs are maintained on a list at their respective municipal EOC (based upon residential jurisdiction).

Copies of these lists will not be provided to the evaluators; however, evaluators will be allowed to inspect the lists during the exercise.

NOTE: Berks County maintains a countywide special needs list for individuals requmng

. assistance. This list may be viewed at the county as it will not be disseminated for exercise purposes.

Evaluators may ask, by interview, about the transportation plans concerning transportation, staging, source of vehicles, radiological protection of the drivers/emergency workers, and routes or assignments of vehicles for transportation dependent individuals and transportation ofpersons with disabilities and access/functional needs. No buses or drivers will be mobilized.

Initial contact, by the County, with special populations (hospitals, nursing homes and county correctional facilities) will be actual. All subsequent calls will be simulated. Actual contacts (up to two per Risk County) will be made with transportation providers per their plan. All actual and simulated contacts should be logged.

Criterion 3.c.2: OROs/School officials implement precautionary and/or protective action decisions for schools. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

  • Assessment/Extent-of-Play Assessment of this Demonstration Criter_ion may be accomplished during a biennial, or tabletop exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.

School systems/districts (these include public and private schools, kindergartens, and preschools) must demonstrate the ability to implement precautionary and/or protective action decisions for students. The demonstration must be made as follows: each school system/district within the 10 mile EPZ must demonstrate implementation of protective actions. At least one school per affected system/district must participate in the demonstration. Canceling the school day, dismissing early, or sheltering in place must 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.

138

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan . Limerick Generating Station If accomplished through an interview, appropriate school personnel including decision-making officials (e.g., schools' superintendent/principals and transportation director/bus dispatchers), and at least one bus driver (and the bus driver's escort, if applicable) must 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 plans/procedures, must be verified.

Officials of the school system(s) must 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.

If a school facility has emergency plans as a condition of licensing, those plans may be submitted to FEMA review in place of demonstration or interview pursuant to the ORO's plans/procedures as negotiated in the Extent-of-play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

School students will not be involved during the exercise. Actions and activities associated with the demonstration of Criterion 3.c.2 will be limited to the School District Administration key personnel and the County. Evacuation ofstudents will be conducted through an interview process with School District personnel or the building principal.

The role of the bus driver may be conducted through an interview with school or transportation officials (or designee) if a bus driver is not available. Actual demonstration of the bus route is not required and will not be demonstrated. Maps or route descriptions will be available for illustration purposes.

Risk County school plans do not require communications between the school and vehicle~. Bus drivers are not considered emergency workers and therefore do not require dosimetry.

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

However, OROs will be prepared to show evaluators lists ofthese facilities that they would contact in the event of an emergency in accordance with plans and procedures. Any simulated contacts should be logged.

Sub-element 3.d. - Implementation of Traffic and Access Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have.

the capability to implement protective action plans/procedures, 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.

  • 139

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.

OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and PADs (e.g., evacuating, sheltering, and

  • relocation) in a timely manner. OROs must demonstrate the capability to provide instructions to traffic and access contrnl 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 must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas, as per the Extent-of-Play Agreement. These capabilities may be demonstrated by actual deployment or by interview, in accordance with the Extent-of-Play Agreement.

In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic), they must demonstrate the capability to contact the State or Federal agencies that have the needed authority, as agreed upon in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement

. PEMA Negotiated Extent-of-Play:

Municipal Traffic and Access control will be demonstrated by interview at the applicable EOC of jurisdiction. The traffic/access control personnel will not be deployed to the traffic/access control point(s). If the designated assignment is a location within the EPZ, a radiological briefing will be provided to the assignedindividuals.

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

(NUREG0654/FEMA-REP-1, J.10.k)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, staff assistance visit, or by means of drills conducted at any time.

OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. In demonstrating this capability, the impediment must remain in place during the evacuation long enough that re-routing of traffic is required and must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

When, due to specifics of the scenario or jurisdiction, the impediment cannot be located on an evacuation route, it must be located so as to impact the evacuation .. When not possible, actual 141

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station dispatch of resources need not be physically demonstrated; however, all contacts; actual or simulated, must be logged. ,;,

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-orPlay:

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 tow trucks, need not be demonstrated; however, simulated contacts will be logged. If the scenario does not lead to evacuation the criteria shall be deemed complete if the ORO can describe to the evaluator through controller iniect or interview the actions they would take to overcome a major traffic impediment during an evacuation and how such actions would be communicated to.the public and affected OROs. (Risk counties only)

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

Sub-element 3.f - Implementation of Post-Plume Phase Relocation, Reentry, and Return D~~~M .

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

142

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EVALUATION AREA4 Field Measurement and Analyses Sub-element 4.a - Plume Phase Field Measurements and Analyses INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to deploy FMTs 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/FEMA-REP-l indicates that OROs must have the capability to use FMTs within the plume exposure pathway EPZ to detect airborne radioiodine in the presence of noble gases and radioactive particulate material in the airborne plume. In an incident at an NPP, the possible release of radioactive material may pose a risk to the nearby population and environment. Although incident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an incident, it is important to collect field radiological data to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

Criterion 4.a.1: [RESERVED]

Criterion 4.a.2: Field teams (2 or more) are managed to obtain sufficient information to help characterize the release and to control radiation exposure'.

(NUREG-0654/FEMA-REP-1, C.1; H.12; 1.7, 8, 11; J.10.a)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise.

Other means may include drills that would fully demonstrate technical proficiency.

Responsible OROs must demonstrate the capability to brief FMTs on predicted plume location and direction, plume travel speed, and exposure control procedures before deployment. During an HAB incident, the Field Team management must keep the incident command informed of field monitoring teams' activities and location. Coordination with FMTs and field monitoring may be demonstrated as out-of-sequence demonstrations, as negotiated in the Extent-of-Play Agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions, or to be a factor in modifying protective actions.

Teams must be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts.

If the responsibility for obtaining 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 ORO monitoring teams. If the licensee FMTs do not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are 143

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Re*port/Improvement Plan Limerick Generating Station necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all FMTs (licensee, Federal, and ORO) is essential.

144

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Unclassified Radiological Emergency Preparedness Program (REP)*

After Action Report/Improvement Plan Limerick Generating Station OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as necessary. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Department of Environmental Protection (DEP), Bureau of Radiation Protection (BRP) field teams are equipped with the necessary instrumentation and supplies. FEMA observers will meet the field teams at the R3V staging area at Wilson Farm Park, 500 Lee Road in Wayne, Pennsylvania 19087 at 1:30 p.m. on November 14, 2017 to observe instrumentation checks and equipment inventory verification.

Field Team Control will be performed within or near the 10 mile EPZ using the DEP Radiological ,

Rapid Response Vehicle (R3V). 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. In addition to field team measurements, remote detectors will be placed by the field teams near the expected plume pathway. These detectors will automatically transmit data to the R3Vand the CRCC. Field teams will follow ALARA principles in the deployment of these detectors.

Field teams will NOT be evaluated by FEMA.

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/FEMA-REP-1, C.1; H.12: 1.8, 9; J.10.a)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise.

Other means may include drills that would fully demonstrate technical proficiency.

Two or more FMTs must demonstrate the capability to make and report measurements of ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority.

FMTs must also demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and to provide the appropriate authority with field data pertaining to measurement. If samples have radioactivity significantly above background, the authority must consider the need for expedited laboratory analyses of these samples. Coordination concerning transfer of samples, including a chain-of-custody form(s), to a radiological laboratory (ies) must be demonstrated.

145

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After Action Report/Improvement Plan Limerick Generating Station

  • OROs must share data in a timely manner with all other appropriate OROs. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form(s) for transfer to a laboratory (ies), will be in accordance with the ORO's plans/procedures.

146

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Measurements will be made by Department of Environmental Protection (DEP), Bureau of Radiation Protection (BRP), in accordance with the State Annex E, Appendix 6, and BRP Standard Implementing Procedures (IPs). Two mobile monitoring teams frorYJ BRP DEP South East Regional Office will demonstrate ambient radiation monitoring and radioiodine and particulate sampling. Field teams will be equipped with appropriate dosimetry and Kl Field teams will NOT be evaluated by FEMA. Each team will be directed to monitoring locations and perform actual radiation measurements at each location. Measurements may consist of truck installed radiation monitor or hand-held radiation instruments. An actual afr sample will be taken at the R3 V staging area prior to field team departure to LGS. Field teams will discuss air sample counting procedures via an interview process. Teams will then take additional simulated air samples, as directed, at additional locations, ifconditions are appropriate for radio iodine sampling and relay information to the Radiological Rapid Response Vehicle (R3 V). In place of silver zeolite cartridges, charcoal cartridges will be used for the exercise. All measurements will be forwarded to theR3V immediately upon obtaining data.

FEMA observers will meet the field teams at the R3V staging area at Wilson Farm Park, 500 Lee Road in Wayne, Pennsylvania 19087 at 1:30 p.m. on November 14, 2017.

Sub-element 4.b- Post-Plume Phase Field Measurements and Sampling INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess the actual or potential magnitude and locations of radiological hazards to determine the ingestion exposure pathway EPZ and to support relocation, reentry, and return decisions. This Sub-element focuses on collecting environmental samples for laboratory analyses that are essential for decisions on protecting the public from contaminated food and water and direct radiation from deposited materials.

Criterion 4.b.1: The field teams (2.or more) demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision making.

(NUREG-0654/FEMA-REP-1, C.1; 1.8; J.11)

Assessment/Extent-of-Play 147

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After Action Report/Improvement Plan Limerick Generating Station Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise. Other means may include drills; seminars or training activities that would fully demonstrate technical proficiency.

The ORO's FMTs must demonstrate the capability to take measurements and samples at such times and locations as directed to enable an adequate assessment of the ingestion pathway and to support reentry, relocation, and return decisions. When resources are available, use of aerial surveys and in-situ gamma measurement is appropriate. All methodology, including contamination control, instrumentation, preparation of samples, and chain-of-custody form(s) for transfer to a laboratory (ies), will be in accordance with the ORO's plans/procedures.

The FMTs and/or other sampling personnel must secure ingestion pathway samples from agricultural products and water. Samples in support of relocation and return must be secured from soil, vegetation, and other surfaces in areas that received radioactive ground deposition.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers) as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

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

Sub-element 4.c - Laboratory Operations INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision making.

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654/FEMA-REP-1, C.1, 3; J.11)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial, tabletop exercise, or an actual event. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

The laboratory staff must demonstrate the capability to follow appropriate procedures for receiving samples, including logging information, preventing contamination of the laboratory(ies),

preventing buildup of background radiation due to stored samples, preventing cross.contamination 148

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station of samples, pres~rving samples that may spoil (e.g., milk), and keeping track of sample identity.

In addition, the laboratory staff must demonstrate the capability to prepare samples for conducting measurements.

The laboratory (ies) must be appropriately equipped to provide, upon request, timely analyses of media of sufficient quality and sensitivity to support assessments and decisions anticipated in the ORO's plans/procedures. The laboratory instrument calibrations must be traceable to standards provided by the National Institute of Standards and Technology. Laboratory methods used to analyze typical radionuclides released in a reactor incident must be as described in the plans/procedures. New or revised methods may be used to analyze atypical radionuclide releases (e.g., transuranic or as a result of a terrorist incident) or if warranted by incident circumstances.

Analysis may require resources beyond those of the ORO.

149

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station The laboratory staff must be qualified in radioanalytical techniques and contamination control procedures.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers) as needed. Evaluation of this criterion will fake into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

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

150

Unclassified Radiological Emergency Preparedness Program (REP)

  • After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 5 Emergency Notification and Public Information Sub-element 5.a - Activation of the Prompt Alert and Notification System INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide prompt instructions to the public within the plume exposure pathway EPZ. Specific provisions addressed in this Sub-element are further discussed in Section V, Part A of this Manual, Alert and Notification Systems.

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 REP guidance.

(NUREG-0654/FEMA-REP-1, E.5, 6, 7)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

Responsible OROs must 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 exposure pathway EPZ. Following the decision to activate the alert and notification system, OROs must complete system activation for primary alert/notification and disseminate the information/instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is 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 must be fully demonstrated as they would in an actual emergency.up to the point oftransmission. Broadcast of the message(s) or test message(s) is not required. The procedures must be demonstrated up to the point of actual activation. The alert signal activation should be simulated, not performed. Evaluations ofEAS broadcast stations may also be accomplished through SAVs.

The capability of the primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview with appropriate personnel from the primary notification system, including verification of provisions for backup power or an alternate station.

The initial message must include at a minimum the following elements:

  • Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message; 151

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  • Identification of the commercial NPP and a statement that an emergency exists there;
  • Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and 152

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After Action Report/Improvement Plan Limerick Generating Station

  • A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the ORO's plans/procedures and the Extent-of-Play Agreement. OROs must demonstrate the capability to accomplish,the primary route alerting in a timely manner (not subject to specific time requirements). At least one route needs to be demonstrated and evaluated. The selected route(s) must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every eight years. All alert and notification activities along the route(s) must be simulated (i.e., the message that would actually be used is read for the evaluator, but not actually broadcast) as negotiated in the Extent of Play. Actual testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of primary alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

The Commonwealth of Pennsylvania has implemented a Statewide EAS Control System in cooperation with the Pennsylvania Association of Broadcasters per the State Emergency Communications Committee and Pennsylvania Emergency Alert System State EAS Plan (November 2, 2011). The CRCC (PEMA) is the initiating point for the activation of the EAS. Risk Counties have the control equipment for activation ofsirens. Coordination will occur between the CRCC and the affected counties with respect to the Alert and Notification System (ANS) process.

Sirens will be coordinated and the sounding simulated at the appropriate time with the simulated activation of EAS taking place approximately 3 minutes following the simulated activation of the sirens. The EAS will be read and explained to the evaluator, and given a copy of the EAS to them.

Regular broadcasting will not be interrupted on the EAS Stations. Broadcast of the message(s) or test message(s) is NOT required and NOT requested. Counties may elect to simulate county specific supplemental messages to their electronic local media.

Following the decision to activate the alert and notification system, in accordance with the ORO 's plan and/or procedures, ANS activation should be accomplished in a timely manner for primary alerting/notification. This action will be performed "with a sense of urgency and without undue delay" (REP Manual-January 2016).

All actions to broadcast stations will be simulated. Systems that use automatic sending technology may be demonstrated by explanation during an interview.

Each evaluated municipality per Risk County will demonstrate, by interview, route alerting of the.

hearing impaired residents within their jurisdiction. Hearing impaired notification teams will not be deployed.

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After Action Report/Improvement Plan Limerick Generating Station Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Backup alert and notification of the public is completed within a reasonable time following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654/FEMA-REP-1, E.6, Appendix 3.B.2.c)

Assess men t/Exten t-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

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 during the exercise, OROs must demonstrate backup means of alert and notification. Backup means of alert and notification will differ from facility to facility.

Backup alert and notification procedures that would be implemented in multiple stages must be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The populations farther away and downwind of any potential radiological release would be covered sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, .and finally the remaining population as directed by authorities). Topography, population density, existing ORO resources, and timing will be considered in judging the acceptability of backup means of alert and notification.

Although circumstances may not allow this for all situations, FEMA and the NRC recommend that OROs and operators attempt to establish backup means that will reach those in the plume exposure EPZ within a reasonable time of failure of the primary alert and notification system, with a recommended goal of 45 minutes. The backup alert message must, at a minimum, include: (1) a statement that an emergency exists at the plant; and (2) instructions regarding where to obtain additional information.

When backup route alerting is demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route(s) must be simulated (i.e., the message that would actually be used is read for the evaluator, but not actually broadcast), as negotiated in the Extent-of-Plai Actual testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of backup alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Back-up alert notification of the public due to a simulated siren failure will be demonstrated.

(Refer to Attachment A, Section IA.4.) County liaisons will give an inject to the county siren 155

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station dispatcher, upon confirmation that sirens were sounded, that a particular siren has failed in the municipalities scheduled to demonstrate back-up route alerting. Notice of the siren failure will then be communicated to the appropriate municipalities/locations so they can demonstrate their recommended goal *of 45 minute per-identified back-up route alert run as per Attachment A, Section IA. 4. Pennsylvania does not have any "exception areas. " The 45-minute clock starts.

when the siren dispatcher receives the notification that a siren has failed.

IPAWS may be used, as long as it does not interfere with the required demonstrated and eval~at~d notifications. Alternate methods of route alerting will NOT be evaluated.

Criterion 5.a.4: 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.

(NUREG-0654/FEMA-REP-1, E.6; Appendix 3.B.2.c)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully demonstrate capability.

OROs with FEMA-approved exception areas (identified in the approved Alert and Notification System Design Report), 5 to 10 miles from the NPP, must demonstrate the capability to accomplish primary alerting and notification of the exception area(s). FEMA and the NRC recommend that OROs and operators establish means that will reach those in approved exception areas within 45 rriinutes once the initial decision is made by authorized offsite emergency officials to notify the public of an incident. The exception area alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain additional information.

For exception area alerting, at least one_ route must be demonstrated and evaluated. The selected route(s) must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every eight years. All alert and notification activities along the route(s) must be simulated (i.e., the message that would actually be used is read for the evaluator, but not actually broadcasted) as negotiated in the Extent-of-Play. Actual testing of the mobile public address system will be conducted at an agreed-upon location. For exception areas alerted by air/water craft, actual routes will be negotiated in the Extent-of-Play, but must be demonstrated no less than once every eight years.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-PlaY,:

This sub-element will not be demonstrated or evaluated during this exercise. Pennsylvania has no exception areas.

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After Action Report/Improvement Plan Limerick Generating Station Sub-element 5.b - Subsequent Emergency Information and Instructions for the Public and the Media INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUREG-0654/FEMA-REP-1 requires OROs to 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/FEMA-REP-1 also ,provides that a system must be available for dealing with rumors. This system will hereafter be known as the "public inquiry hotline."

Criterion 5.b.1: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner.

(NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, or drills. The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in a timely manner following the initial alert and notification (not subject to specific time requirements). For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is 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.

Message elements: The ORO must ensure that emergency information and instructions are consistent with P ADs made by appropriate officials. The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, . shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided. The ORO must also be prepared to disclose and explain the ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs must demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion exposure pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5 .a. I and previously identified protective action areas that are still valid, as well as new areas. Information about any rerouting of evacuation routes due to impediments should also be included. The OROs must 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 must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures.

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After Action Report/Improvement Plan Limerick Generating Station OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures.

If ingestion pathway measures are exercised, OROs must demonstrate that a system exists for rapid dissemination of ingestion pathway information to predetermined individuals and businesses in accordance with the ORO's plans/procedures.

Media information: OROs must 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 incident warrants. The OROs must demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and releases must be consistent with PADs and other emergency information provided to the public.

  • Copies* of pertinent emergency information (e.g., EAS messages and media releases) and media information kits must be available for dissemination to the media.

Public inquiry: OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. Hotline staff must 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, must be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.

HAB considera1tions: The dissemination of information dealing with specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/communicated with appropriate security authorities (e.g., law enforcement and NPP security agencies) in accordance with ORO plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Subsequent emergency information and instructions should be provided to the public and the media in a timely manner. This will NOT be sub;ect to specific time requirements. One media briefing will be demonstrated in each risk county:

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EVALUATION AREA 6 Support Operations/Facilities*

Sub-element 6.a - Monitoring, Decontamination, and Registration of Evacuees INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of evacuees, while minimizing contamination of the facility. OROs must also have the capability to identify and register evacuees at reception centers.

Criterion 6.a.1: The reception center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration *of evacuees.

(NUREG-0654/FEMA-REP-1, A.3; C.4; J.10.h; J.12)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, drills, or SAV.

Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency or as indicated in the Extent-of-Play Agreement. OROs conducting this demonstration must have one-third of the resources (e.g., monitoring teams/instrumentation/portal monitors) available at the facility (ies) as necessary to monitor 20 percent of the population within a 12-hour period. This would include adequate space for evacuees' vehicles.. Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location. Plans/procedures must indicate provisions for service animals.

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. Staff i:esponsible for the radiological monitoring of evacuees must demonstrate the capability to attain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. The monitoring productivity rate per hour is the number of evacuees that cah be monitored, per hour, by the total complement of monitors using an appropriate procedure. For demonstration of monitoring, decontamination, and registration capabilities, a minimum of six evacuees must be monitored per station using equipment and procedures specified in the plans/procedures. The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met.

OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the evacuee's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in 159

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station the plan and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shali not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of- Play Agreement.

Decontamination of evacuees may be simulated and conducted by interview. Provisions for separate showering and* same-sex decontamination must be demonstrated or explained. The staff must demonstrate pro'visions for limiting the spread of contamination. Provisions could include floor coverings, signs, and appropriate .means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees, provide changes of clothing for those with contaminated clothing, and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal belongings. Waste water from decontamination operations does not need to be collected..

Individuals who have completed monitoring and decontamination if needed, must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level or have been placed in a secure area until they can be monitored and decontaminated, if necessary.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not require confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles held in a secure area or monitored and decontaminated (if applicable) and do require confirmation that their vehicle is being held in a secure area or free from contamination prior to entering the congregate care areas.

PEMA Negotiated Extent-of-Play:

. Radiological monitoring demonstration sites should possess a roster of the monitoring personnel required to process the population allocated to the facility within a 12-hour period.

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.

  • Radiological monitoring of the public may be co-located at either reception centers or mass care centers depending on the county plan.

160

1 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station At each reception center (stand-alone - non-monldecon activity sites) a mzmmum 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 registration. A sample of the appropriate strip maps*or directions will be made available for the demonstration. Note: Co-located facilities do not require strip maps or written directions.

Mass care centers and mass care monitoring/decontamination centers will be demonstrated per Attachment A during the out-of-sequence window. The 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 the organization and layout within 1

the facility and space management for monitoring and decontamination. Procedures will be demonstrated to show the separation of contaminated and non-contaminated (clean) individuals to minimize cross contamination.

At the evacuee monitoring/decontamination centers (if using hand-held meters), a minimum of six (6) volunteer evacuees will be monitored (or one volunteer evacuee may be monitored six times). Centers using portal monitors are only required to demonstrate three (3) volunteer evacuees. Suitable radiological monitoring instruments will be issued to and demonstrated by the initial monitoring team(s). A monitoring team consists of one monitor and one recorder equipped with one survey instrument. Those individuals found to be free of "contamination",

based upo,n scenario injects, will be directed to the mass care registration point for further processing. Note: Actual radiological sources will not be attached to or hidden upon the volunteer evacuees.

One of the simulated evacuees, based upon controller injects, will not be able to be decontaminated. Discussions concerning the processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. Showering will be simulated, water will not be used. Note: Ifportal monitors are used, see below.

At the emergency worker monitoring/decontamination stations. two (2) emergency workers will be monitored. Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. Showering will be simulated, water will not be used. Suitable radiological monitoring instruments will be issued to the initial monitoring team. Note: If portal monitors are used, the Portal Monitor Extent-of-Play described below shall be used.

Portal Monitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to . monitor simulated evacuees and/or emergency workers. The monitoring/decontamination team requirements will be based on the portal monitor capabilities as applicable based on the procedure/guidelines, and the recommendations of the manufacturer.

Note: PE¥A Interim Annex E letter, April 2009 or superseding document shall apply.

Monitoring/decontamination centers and Emergency Worker monitoring and decontamination station personnel are not issued DRDs or Kl since the centers and stations are outside the EPZ.

Category "C" Dosimetry applies. Sfmulated permanent record dosimeters (PRDs) will be worn.

161

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Radiation readings/contamination data for the evacuees and vehicle will be prov1ded by the controller as appropriate based upon information contained in the scenario package. Set-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 pad (if used). Long runs of plastic covered with paper will not be demonstrated, but the materials may be available and explained (as appropriate). Positioning of afire apparatus on-site may be simulated if otherwise required.

Note: Re-demonstrations may be performed as appropriate and time permitting.

162

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Sub-element 6.b - Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles INTENT This Sub-element is derived from NUREG0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of emergency workers and their equipment, inclusive of vehicles.

Criterion 6.b.1: The facility/ORO has a*dequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles.

(NUREG-0654/FEMA-REP-1, K.5.a, b)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, an actual event, or SAV. r The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination m accordance with the ORO's plans/procedures.

Specific _attention must be given to equipment, including any vehicles that were in contact with contamination. The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and vehicles based on trigger/action levels and procedures stated in the ORO plans/procedures. Monitoring of emergency workers does not have to meet the 12-hour requirement. However, appropriate monitoring procedures must be .

demonstrated for a minimum of two emergency workers and their equipment and vehicles. Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

The area to be used for monitoring and decontamination must 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 must 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 must be demonstrated. Interior surfaces of vehicles that were in contact with contaminated individuals must also be checked.

Decontamination of emergency workers may be simulated and conducted via interview.

Provisions for separate showering and same-sex decontamination must be demonstrated or

. explained,. The staff must demonstrate provisions for limiting the spread of contamination.

Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated individuals where applicable; provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to_ prevent further contamination of emergency workers or facilities.

163

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

  • OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and if necessary, decontamination must include establishing a registration record consisting of the emergency worker's name, address, results of monitoring,,.and time of decontamination (if any),

or as otherwise designated in the plan/procedures. Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated.

  • Monitoring personnel must explain use of trigger/action* 1evels for determining the need for decontamination. They must also explain the procedures for referring any emergency workers who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures.

Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by interview. Waste water from decontamination operations does not need to be collected.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified 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 radiological 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 clearly defined exit areas, per contamination control procedures and/or step-offpads (if used); with the exception of long runs ofplastic covered with paper which will not be demonstrated, but the materials may be available and explained (as appropriate.).

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

Note: Re-demonstrations may be performed as appropriate and time permitting.

Sub-element 6.c - Temporary Care of Evacuees INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires OROs to have the capability to establish relocation centers in host/support jurisdictions. The American Red Cross normally provides congregate care in support of OROs under existing letters of agr~ement.

164

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654/FEMA-REP-1, J.10.h, J.12) 165

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Assess men t/Exten t-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise,

  • drills, an actual event, or SAV.

The evaluator must conduct a walk-through of the center to deterrµine, through observation and inquiries, that the services and accommodations are consistent with applicable guidance.

For planning purposes, OROs must plan for a sufficient number of congregate care centers in host/support jurisdictions based on their all-hazard sheltering experience and what is historically relevant for that particular area. 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 criterion, exercise demonstration expectations must be clearly specified in Extent-of-Play Agreements.

Congregate care staff must also demonstrate the capability to ensure that evacuees, service animals, and vehicles have been monitored for contamination, decontaminated as appropriate, and registered before entering the facility.

Individuals arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been placed in a secured area or monitored, cleared, and found to have no contamination or contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need

. to have their vehicle monitored. These individuals do not need confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles held* in a secure area until they can be monitored and decontaminated (if applicable) and do need confirmation that their vehicle is being heid in a secure area or free from contamination prior to entering the congregate care areas. 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 (e.g., cots, blankets, sundries, and large-scale food supplies) need not be physically available at the facility (ies ). However, availability of such items must be verified by providing the evaluator a list of sources with locations and estimates of quantities.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

Counties demonstrating the operation of mass care centers during the out-of-sequence window (Berks and Lehigh Counties) will provide floor plans ofthe mass care centers to show organization 166

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Personnel, at a minimum, will consist ofone manager and one assistant for each mass care center opened during the out-of-sequence window. The responsible American Red Cross chapter will show the source qnd quantities, by job functional description, to be provided to mass care centers to support the 24-hour operation. The responsible Red Cross Chapter(s) will be visited, or telephonically contacted during business hours on November 15, 2017, by an exercise evaluator, or interviewed at the mass care center (as appropriate) during the out-of-sequence evaluation to provide information regarding the 24-hour operation. Schematics of these mass care centers will be available, during the demonstration window, to show organization within the facility and space allocation for the registration and sheltering the evacuating public. Necessary signs, directional arrows and forms will be available and used to demonstrate registration, at a minimum, of three evacuees requiring emergency housing. Evacuees will be shown the location where they would be housed in an actual situation. Bedding, cots, food, etc. normally associated with mass care will not be moved to the site, but the sources of those items should be explained to FEMA evaluators.

This out-of-sequence demonstration window will be on November* 15, 2017 from 7:00 PM- 9:30 PM Those facilities identified for the FEMA walk-down evaluations will be supported by a participating representative from the appropriate Red Cross Chapter(s). An interview process will be conducted to determine facility compliance of the above stated requirements.

AMERICAN RED CROSS RISK AND SUPPORT COUNTY CHAPTERS:

Tri County Chapter (Serving Berks and Chester Counties) 701 Centre Avenue Reading, Pennsylvania 19601 Erika Wolfe (215) 347-0425 Greater Lehigh Valley Chapter (Serving Bucks and Lehigh Cou~ties) 3939 Broadway Allentown, Pennsylvania 18104 Erika Wolfe (215) 347-0425 Southeastern Pennsylvania Chapter (Serving Montgomery County) 2221 Chestnut Street Philadelphia Pennsylvania 19103 Angel Ferris (267) 246-4511 Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals INTENT 168

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

  • Limerick Generating Station This Sub-element is derived from NUREG0654/FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Criterion 6.d.l: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

(NUREG-0654/FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4)

I 169

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Assessment/Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, or drills. FEMA has determined that these capabilities have been enhanced and consistently demonstrated as adequate; therefore, offsite medical services drills need only be evaluated biennially. FEMA will, at the request of the involved ORO, continue to evaluate the drills on an annual basis. All hospitals listed in the plan as medical services hospitals must be evaluated, with a transportation provider, every 2 years. Additional transportation providers will be rotated through the drills iil the 8-year exercise cycle. For ambulance providers who do not participate in an evaluated drill during the two-year cycle, training will be provided. This training will be documented in the ALC.

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

OROs must demonstrate the capability to monitor/decontaminate and transport contaminated, injured individuals to medical facilities.

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility. It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "victim(s)" to the medical facility. This option is u'sed in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests of the community.

Normal communications between the ambulance/dispatcher and the receiving medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available. In addition, the ambulance crew must 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 or en route, or may be deferred to the medical facility. Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s). However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored. Before using monitoring instruments, the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities must be completed as they would be in an actual emergency. Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility.

The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment. Medical facilities are expected to have at least one trained physician 170

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station and one trained nurse to perform and supervise treatment of contaminated injured individuals.

Equipment and supplies must be available for treatment of contaminated injured individuals.

The medical facility mu.st demonstrate the capability to make decisions on the need for decontamination of the individual, follow appropriate decontamination procedures, and maintain records of all survey measurements and samples taken. All procedures for collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator. Waste water from decontamination operations must be handled according to facility plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

This sub-element will be evaluated at Brandywine Hospital, Chester County, on September, 28, 2017.

NOTE: Responding EMS crew does not monitor nor decontaminate the injured patient. The injured patient will be monitored .at the hospital. If found contaminated, the patient will be decontaminated at the hospital as well.*

171

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station ATTACHMENT A LIMERICK GENERATING STATION EXTENT OF PLAY DEMONSTRATION TABLES I. Plume Phase Exercice

. A. Activities - November 14, 2017

1. School Districts - Out-of-Sequence Exercise Risk Public School Districts with schools located within the EPZ and those districts situated outside the EPZ, but with students living within the EPZ, will participate and be evaluated by FEMA. Each identified District Administration Office will be evaluated. When a school system is comprised of multiple buildings (High School, Middle School, Elementary School), the affected buildings (those with students from the EPZ) will be evaluated on a rotational basis to coincide with the eight-year exercise cycle.

Time: Out-of-sequence - 9:00 - 11 :00 AM Asterisks (*) items indicate buildings not in EPZ - students may live in the EPZ SCHOOLS COUNTY SCHOOL DISTRICT (approx. 114th evaluated)

Berks Boyertown Area 1. Boyertown Senior High School

2. New Hanover/Upper Frederick Elementary School
3. Earl Elementary School*
4. Washington Elementary School*

Daniel Boone Area 1. Birdsboro Elementary

  • Chester Downingtown Area 1. Lionville Elementary School*
2. Uwchlan Hills Elementary School*
3.
  • Lionville Middle School*
4. Downingtown High School East*

Great Valley 1. Great Valley Middle School*

2. Great Valley High School*

Owen J. Roberts 1. French Creek Elementary School

2. East Vincent Elementary 3 .. West Vincent Elementary Phoenixville Area 1. Manavon Elementary School &

Phoenixville Area Early Learning Center (new for 2017) 172

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan. Limerick Generating Station Montgomery Methacton Area 1. Woodland Elementary

2. Eagleville Elementary*
3. Methacton Senior High School*

Perkiomen Valley 1. South Elementary School 2~ Perkiomen Valley MS - East Montgomery cont'd Pottsgrove 1. Pottsgrove High School

2. West Pottsgrove Elementary Pottstown Area 1. Lincoln Elementary School
2. Pottstown High School Souderton Area 1. Salford Hills Elementary Spring-Ford Area 1. Upper Providence.Elementary

..,,. 2. 5th & 6th Grade Center

3. 7th Grade Center 4: gth Grade Center
5. Spring-Ford Area High School Upper Perkiomen 1. Marlborough Elementary
2. Upper Perkiomen High School*

~* 3. Upper Perkiomen Middle School*

2. County Emergency Operations Center (EOCs)

Time: Per Exercise Scenario DEMONSTRATION FOR EOC MOBILIZATION FOR COUNTIES COUNTY DATE Time Berks November 14, 2017 Exercise Scenario Bucks November 14, 2017 Exercise Scenario Chester November 14, 2017 Exercise Scenario Montgomery November 14, 2017 Exercise Scenario Lehigh November i4, 2017 Exercise Scenario

3. BRP field teams will be OBSERVED at the. R3V staging area located at Wilson Farm Park, 500 Lee Road, Wayne, Pennsylvania 19087 on November 14, 2017 at 1:30 p.m.
4. Municipal Emergency Operations Center (EOCs)

Time: Per Exercise Scenario Asterisks (*) items indicate joint EOCs.

DEMONSTRATION FOR EOC MOBILIZATION FOR MUNICIPALITIES 173

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station RISK COUNTY MUNICIPALITY

- DATE Berks *Boyertown Borough/Colebrookdale Twp - RA November 14, 2017 Earl Twp Nov~mber 14, 2017 Union Twp November 14, 2017 174

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester Charlestown Twp November 14, 2017 East Coventry Twp November 14, 2017 East Pikeland Twp November 14, 2017 Schuylkill Twp November 14, 2017 Uwchlan Twp November 14, 2017 West Vincent Twp - RA November 14, 2017 Monteomerv *Greenlane Borough/Marlborough Twp November 14, 2017 Limerick Twp -RA November 14, 2017 Lower Frederick Twp November 14, 2017 Lower Pottsgrove Twp November 14, 2017 New Hanover Twp November 14, 2017 Perkiomen Twp November 14, 2017 Trappe Borough November 14, 2017

5. Back-up route ale1:'1:ing demonstration by one municipality in each risk county. (During Scenario Exercise)

BACK-UP ROUTE ALERTING COUNTY MUNICIPALITY/ ROUTE / SIREN DATE Berks Boyertown Borough/Colebrookdale Twp

  • November 14, 2017 16D / #105 (2 teams)

Chester West Vincent Township November 14, 2017 East End of 73C / #92 (3 teams)

Limerick Township November 14, 2017 Montgomery 84A / #32 (2 teams)

6. Traffic and Access Control Points
a. The Pennsylvania State Police will brief at the PSP Troop J - Embreeville Barracks, 997 Lieds Road, Coatesville, Chester County. 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 10:00 a.m. - 12:00 p.m. on November 15, 2017.
c. 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.
d. Municipal and county staffs will be prepared to brief the FEMA evaluator on actions to be taken should there be an impediment to evacuation on a designated route. This will be demonstrated between 4:00 p.m. - 10:00 p.m. on November 14, 2017.

175

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 176

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Berks Chester Monteomerv

  • Boyertown East Coventry Township Marlborough Township Borough/Colebrookdale Township

-- East Pikeland Township Limerick Township

-- Schuylkill Township Lower Pottsgrove Township

-- Uwchlan Township New Hanover Township

-- West Vincent Township --

  • Joint EOCs B. Activities - November 15, 2017
1. Recept1on Centers Time:.

Out-of-sequence - 7:00 p.m. -. 9:30 p.m.

The asterisks (*) indicate monitoring/decontamination center activities at the respective reception centers.

RECEPTION CENTERS LOCATIONS COUNTY LOCATION Quantity Berks Robeson Township Building 1 Bucks* Trevose Fire Company 1 Chester* West Whiteland Township Building 1 Lehigh* Southern Lehigh High School 1 Montgomery* Plymouth Fire Company 1

2. Emergency worker monitoring/decontamination stations for each risk county.

EMERGENCY WORKER MONITORING/DECONTAMINATION STATION COUNTY LOCATION DATE Berks Daniel Boone Area High School November 15, 2017 Chester Twin Valley Fire Department November 15, 2017 Montgomery Indian Valley Middle School November 15, 2017

3. Evacuee monitoring/decontamination station for each risk and support counties.

The asterisks (*) indicate mass care center activities at the monitoring/decontamination centers.

EVACUEE MONITORING/DECONTAMINATION STATION COUNTY LOCATION DATE Berks* Schuylkill Valley High School November 15, 2017 Governor Mifflin Senior High School November 15, 2017 177

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Muhlenberg Senior High School November 15, 2017 Bucks Neshaminy Mall November 15, 2017 (alt. Trevose Fire Company)

Chester West Whiteland Township Building November 15, 2017 Lehigh* Southern Lehigh High School November 15, 2017 Montgomery Plymouth Fire Company November 15, 2017

4. Mass Care Centers for risk and support counties.

MASS CARE CENTER COUNTY LOCATION DATE Berks Schuylkill Valley High School November 15, 2017 Governor Mifflin Senior High School November 15, 2017 Muhlenberg Senior High School November 15, 2017 Lehigh Southern Lehigh High School November 15, 2017 IL Mass Care Center Assessment Berks and Lehigh Counties (*) conduct monitoring/decontamination center activities at their mass care centers.

DEMONSTRATION OF MASS CARE CENTERS I HOST SCHOOL COUNTY DATE I TIME

  • Berks (21/0)

Bucks (61/18) Twenty-five Assessment are scheduled for October 30-31, 2017 Chester (10/0) See sche.dule below

  • Lehigh (15/3)

Montgomery (13/4)

MASS CARE CENTER LOCATIONS COUNTY LOCATION Quantity

  • Berks No Assessment 0 Bucks Upper Bucks 18
1. Pennridge High School
2. Pennridge South Jr. School
3. Pennridge Central Middle School RED TEAM 4. Palisades-Sr. High School OCTOBER 30, 2017 5. Central Bucks West High School 9:00AM 6. New Hope-Solebury Complex*
  • Montgomery Mall 7. Palisades Middle School*

Reception Center 8. Central Bucks East High School*

9. Holicong Middle School*
10. Unami Jr. High School*

Lower Bucks

11. Maple Point Middle School 178

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station MASS CARE CENTER LOCATIONS COUNTY LOCATION Quantity

12. Bristol Boro Jr/Sr School RED TEAM 13. Pennwood Middle School OCTOBER 31, 2017 14. Council Rock North High School 9:00AM . 15. Bucks County Community College*
16. William Tennet Complex*
17. Log College Jr. High School*
18. Klinger Middle High School*

Chester No Assessment 0

  • Lehigh 1. Troxell Jr. High School 3
2. Salisbury High School BLUE TEAM 3. Salisbury Middle School OCTOBER 30, 2017 9:00AM Montgomery 1. Sandy Run Middle School 4
2. Upper Dublin Sr. High School BLUE TEAM 3. Upper Moreland High School OCTOBER 30, 2017 4. Upper Moreland Middle School 1:00PM NOTE: The mass care assessment will have team(s) consisting of a FEMA Evaluator, PEMA; County Representative, ARC Representative, and Exelon Representative (optional).

The mass care centers mentioned will have a team enter the facility to verify layout, usable common areas, square footage estimate, and capability of being used as a mass care facility. An Assessment of mass care facilities scheduled for evaluation will be accomplished to satisfy FEMA's evaluation process.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station ATTACHMENT B

. LIMERICK GENERATING STATION PREVIOUS ISSUES WE DID NOT HA VE ANY ISSUES FROM THE LGS PLUME EXERCISE HELD ON NOVEMBER 17, 2015.

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