ML18233A416

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After Action Report/Improvement Plan State of West Virginia Exercise Held on June 12, 2018, Radiological Emergency Preparedness (REP) Program
ML18233A416
Person / Time
Site: Beaver Valley  FirstEnergy icon.png
Issue date: 07/05/2018
From:
US Dept of Homeland Security, Federal Emergency Management Agency
To:
Office of Nuclear Security and Incident Response
References
Download: ML18233A416 (105)
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Text

  • . Beaver Valley Power Station

. After Action Report/

Improvement Plan -

State of West *Virginia Exercise Date- June 12, 2018 .

Radiological Emergency Preparedness (REP) Progr*am

_J

  • After Action Report/Improvement Plan Beaver Valley Power Station Published 5 July 2018 This page is intentionally blank .

2

After Action Report/Improvement Plan Beaver Valley Power Station .

Beaver Valley Power Station After Action Report/Improvement Plan Published July 5, 2018 EXECUTIVE SUMJ\1ARY. .............................................................

............................................ 5 SECTION 1: EXERCISE OVERVIEW ....... :....................................................................... .: .... 6
  • 1.1 Exercise Details ..................... ::.............. : .............................................................................. 6 1.2 Exercise Planning Team.Leadership ...................... :........................................ :............ :.... 6 1.3 Participating Organizations .............. ,................... ,*............................................................ 8 SECTION 2: EXERCISE DESIGN

SUMMARY

.................................................................... 11 2.1 Exercise Purpose and Design ........................................................................ :................... 1i

  • 2.2 Exercis~ Qbjectives, Capabilities and Activities: ............................................................ 13 2.3 Scenario Summary*****************************************:**** ............................................................._.. 13 SECTION 3: ANALYSIS OF CAPABILITIES .................. :.................................................... 16 3.1 Exercise Evaluation and Results ............... ,............................................................. :........ 16 3.2 Summary Results of Exercise Evaluation ............... :....................................................... 16 3.3 Criteria Evaluation Summaries ..................................... *.... ,...... ;..................... :................ 20 3.3.1 State Jurisdictions ........ :......... :................................................................................... :.. 20 3.3.2 Risk Jurisdictions .............. :.:.............................................................*....................*........ 22 SECTION 4: DEMONSTRATED STRENGTHS ................................................... 25
  • SECTION 5: CONCLUSION .............. ,........ :............................................................ :................ 26 APPENDIX A: EXERCISE TIMELINE ............................................................. :.................... 27

. APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS ................................ 28 APPENDIX C: ACRONYMS AND ABBREVIATIONS ................................................... :.... 30

  • APPENDIX D: EXTENT OF PLAYAGREEMENT .......................................................... :.... 33
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After Action Report/Improvement Plan Beaver Valley Power Station EXECUTIVE

SUMMARY

On 12 June, 2018, a full-scale Plume Exposure Pathway exercise was conducted and evaluated for the 10 Mile Emergency Planning Zone (EPZ) around the Beaver Valley Power Station (BVPS) by the Federal Emergency Management Agency (FEMA), R,egiori III. The previous full-scale exercise at this *site was evaluated on 14 June, 2016 Out-of-Sequence demonstrations were conducted on 1-3 May, 2018. 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 BVPS. 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 rep01is are provided to .the Nuclear Regulatory Commission (NRC) and participating States. State and local governments utilize the findings contained in these rep01is for the purposes ofplanning, training, and improving emergency preparedness ..

The evaluation of this Exercise determined that there were No Level 1 Findings, No Level 2 Finding, and ONE Plan Issue (PI). All prior Performance and Planning Issues were resolved during the previous exercise. 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 that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant (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 eff01is of many individuals in State of West Virginia and Hancock County. 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 servfoes to their communities. Cooperation and teamwork of all the participants were evident during the exercise.
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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station SECTIO.N 1: EXERCISE OVERVIEW l.l*Exercise Details Exercise Name Plume 2018-06-12*

Type of Exercise Plume Exercise Date June 12, 2018

  • Minimal Release 1_.2 Exercise Planning Team Leadership Chris N emcheck Technological Hazards Program Specialist DHS/FEMA Region III

.One Indeperidence Mall, 6th Floor 615 Chestnut Street .

Philadelphia, PA, 19106-4404 (202) 709-0688-2925 Christopher .nemcheck@fema.dhs.gov Robert Jelacic WV Radiological Emergency Preparedness Program Manager WV Division of Homeland Security and Emergency Management State Capitol Complex 1900 Kanawha Blvd., East Charleston, West Virginia, 25305 304-558-53"80 robert.l.jelacic@wv.gov 6

  • Unclassified Radiological E!nergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Meghan Hutchinson WV Radiological Emergency Preparedness State Agency Coordinator WV Department of Homeland Security and Emergency Management State Capitol Complex 1900 Kanawha'Blvd.; East Charleston, West Virginia, 25305 304-767-1726 Meghan.E.Hutchinson@wv.gov

  • Jason Lively .

WV Radiological Emergency Preparedness County Coordinator Hancock County Office of Emergency Management 82 Emergency Drive New Cumberland, WV 2604 7 304- 545-3058 Jason.K.Lively@wv.gov Jeremy Ober Hancock County Emergency Management Director Hancock County Office of Emergency Management 82 Emergency Drive .

New .Cumberlatid, WV 26047 304- 670-9055 Sam Paletta Offsite Coordinator First Energy Nuclear Operating Company

  • Beaver Valley Power Station Route 168
  • Shippingpo1i, Pennsylvania, 15077 724-682-5774 palettas@firstenergycorp.com
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Unclassified Radiological Emergency Preparedness Brogram (REP)

After Action Report/Improvement Blan Beaver Valley Power Station 1.3 Participating Organizations

  • Agencies and organizations of the following jurisdictions participated in the Beaver Valley Power Station exercise:

Federal o National Weather Service - Charleston Office State Jurisdictions State of West Virginia e West Virginia National.Guard e West Virginia Department of Environmental Protection

@ West Virginia Department of Health and Human Resources e West Virginia Division of Highways

@ West Virginia Division of Homeland Security and Emergency Management o West Virginia Intelligence Fusion Center e1 . WV Department of Agriculture Other States s Pennsylvania Emergency Management Agency Private Organizations c,

a WV Chapter of the American Red Cross e First Energy Nuclear Operating Company/BVPS Public Information Center

@ WVDEP

  • 0 WVIFC - Rumor Control 0 WVNG 0 WVDHHR - JPIC Accident Assessment e WVDHHR

"' West Virginia University RAD Health Safety - BVPS EOF Field Air Monitoring Team (1) and (2)

~ State of West Virginia Department of Environmental Protection o State of West Virginia, Department of Health and Human Resources 8

After Action Report/Improvement Plan Beaver Valley Power Station Risk Jurisdictions Hancock County EOC

& Amateur Radio Emergency Services l'l American Red Cross Mass Care Q Beaver Valley Power Station Liaisons o Hancock County 911 e Hancock County Commissioners e Hancock County Department of Health*

  • e e

!D Hancock County Emergency Medical Services Hancock County Fire Services Hancock County Office of Emergency Management ea Hancock County Radiological Officer o Hancock County School District e Hancock County Sheriffs Department (l West Virginia University / Hancock Co. Agriculture Extension Service o West Virginia Department of Health and Human Resource WV Division of Homeland Security and Emergency Management Private Organizations

c. Amateur Radio Emergency Services o American Red Cross Q FirstEnergy Nuclear Operating Company School Districts Ill Hancock County School District o Oak Glen Middle School
  • Hancock County Off-Site Response Organizations
  • o Emergency Worker Decontamination Center o New Cumberland VFD o Oakland VFD c:i New Manchester VFD G Reception/l\1ass Care e Weirton FD o Brooke County EMA c Traffic Access Control e Chester PD 9

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Support Jurisdictions

. BROOKE COUNTY s Brooke County Emergency Management Agency MARSHALL COUNTY e Marshall County Emergency.Management Agency OHIO COUNTY o Ohio County Emergency Management Agency 10

After Action Report/Improvement Plan Beaver Valley Power 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 3 52. 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 ofUnderstanding between the NRC and FEMA dated December 7, 2015 (Federal Register, Vol. 81, No. 57', March 24, 2016).

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. Depaiiment of Agriculture,

- U.S. Depaiiment 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 Exposui*e Pathway Exercise was conducted during the week of 11 June, 2018, to assess the capabilities of State and local emergency

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the Beaver Valley Power Station

  • (BVPS). The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency. The findings presented in this report are based on the evaluations of the Federal evaluation team, with final determinations made by the FEMA Region III RAC Chairperson and approved by FEMA Headquaiiers.

These reports are provided to the NRC and participating States. State and local governments utilize the findings contained in these repo1is 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; I!) Radiological Emergency Preparedness Prog1;am Manual, January 2016; Section 1 of this rep01i entitled "Exercise Overview" presents the "Exercise Planning Team" and the* "Paiiicipating Organizations."

.Section 2, of this report entitled "Exercise Design Summary" includes the *"Exercise Purpose and Design", "Exercise Objec;tives, 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 rep01i 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:

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

Appendix B - Exercise Evaluators and Team leaders. A table listing the evaluator names, organizations, and responsibilities of the evaluators and management.

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After Action Report/Improvement Plan Beaver Valley Power Station Appendix C - Acronyms and Abbreviations. An alphabetized table defining the formal names used in this report.

Appendix D - Extent of Play Agreement Emergency Plann~ng Zone

Description:

BVPS is located in western Pennsylvania on !he southern bank of the Ohio River in Beaver County, Pennsylvania. The site is located. near Shippingport Borough, about 1.5 miles from Midland, Pennsylvania, on 501 acres of fairly level terrace owned by the First Energy Nuclear Operating

  • Company (FENOC). The latitude for the site is 40°37'18" north; the longitude is 80°26'02 11 west. Two pressurized water reactors are located on the 17 acres of the parcel occupied by the power station.

The operating licenses for the facility were granted in July 1976 (Unit 1) and August 1987 (Unit 2);

commercial operations began at the site during October 1976 (Unit 1) and November 1987 (Unit 2).

Vnit 1 generates an output of 954 megawatts (MW); the Unit 2 output is 978 MW. One hundred and eighteen sirens cover the plume EPZ; eighty three ofthe sirens are in Pennsylvania, twelve in West Virginia and twenty three are in Ohio.

  • Steep slopes that contributed to the development ofriver mill towns, where most of the industry and residences are located, characterize the general topography of the region. The region is part of the large industrial complex centered around Pittsburgh, Pennsylvania. The te1Tain rises from the Ohio River to a maximum elevation of 1,160 feet above mean sea level (MSL). Drainage is predominantly toward the river. The soils in the area are made up of alluvial sands and gravel. The bedrock geology consists of sedimentary formations composed of shale and sandstone. No faults are located under or near the facility. The Ohio River is about 664 feet above MSL, and the plant grade is 735 feet above MSL.

The climate is a humid continental type. The average annual temperature for the area is about 50°F.

Annual precipitation is approximately 36 inches. The area around the plant is mostly agricultural or undeveloped. The nearest community is Shippingport Borough, Pennsylvania, which is the parent borough for the site and has a population of 23 7. The nearest major population center of more than 25,000 people is Pittsburgh, which has an estimated population of 305,841 and lies 22 miles to the

  • southeast. The maximum population distribution, including residents and transients, is 112,445 in the 10-mile EPZ.

Four major industries employ a total of 8,000 persons within 10 miles of the plant. One small airfield (HeITon Airport) is also in the 10 mile EPZ. The runway at the airport is oriented so that the.

extensions do not pass over the plant. No major thoroughfares exist in the immediate vicinity. The main line of the Norfoll< Southern Railroad runs parallel to the plant along the north bank of the Ohio River.

2:2 Exercise Objectives, Capabilities and Activities The objective of the 2018 I?eaver Valley Power Station BVPS Plume Exercise was to demonstrate the capabilities of State and local emergency rr:ianagement agencies to mobilize

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station

  • 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 \}tility Alert and Notification System (ANS) Sirens. All of these communication resources were employed and-evaluated. The EAS and ANS were simulated and med_ia information was prepared but rtot actually released.

An essential capability of the Radiological Emergency Preparedness Program (REPP) is to evacuate, monitor and decontaminate, if necessary, and provide temporary care and shelter to displaced residents from the EPZ. The ability of the 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, BEAVER VALLEY POWER STATION 2018 PLUME EXPOSURE PATHWAY EXERCISE- June 12, 2018 The exercise begins at 1600 with Units #1 and #2 at Beaver Valley Power Station operating at 100%.

An earthquake occurs which is felt by operators in the control room prompting plant operators to declare a Notice of Unusual Event (NOUE) at 1610. Notifications _are made to the States of

Emergency management officials begin mobilization of personnel and activation ofEOCs due to the earthquake.

At 1715 an ALERT is declared due to a loss of power and a fuel leak in the diesel generator.

Plant operators decide to shut down Units #1 and #2.

At 1820 a Site Area Emergency (SAE) .is declared due to severe damages to plant systems from two eaiihquake aftershocks and a radiologi~al release occurs.

Emergency management officials initiate appropdate protective actions according to plans and procedures in response to the worsening plant conditions.

  • At 1950 corrective actions are taken by plant officials and the radiological release is terminated.

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After Action Report/Improvement Plan Beaver Valley Power Station At 2000 the exercise is terminated .

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power 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 12 June, 2018 biennial Plume Exposure Pathway Radiological Emergency Preparedness (REP) Exercise, and the Out of Sequence Exercise evaluations conducted on 1-3 May 2018. 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 Beaver Valley Power 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 Pian.

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 identifiedr 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 th1;: vicinity of a Nuclear Power Plant (NPP).

(L2) Level 2 Finding: an observed or identified inadequacy of organizational performance in an 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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After Action Report/Improvement Plan Beaver Valley Power 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 .

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Tables 3.1 - Summary of Exercise Evaluation Table 3.la - Exercise Evaluation by Classification Date: 12 June 2018 Site: Beaver Valle Power Station WV FAMT2 Plume Phase Field Measurement, Handling, & Analyses 4a3 p Table 3.lb-Exercise Evaluation -Criteria Met

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  • 1 I,*~-*~*  :.~:;., -

Date: 6/12/2018 Site: Beaver Valley Power Station

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  • ,- ' .. -** - .~.---~* *-** ,,...:~. :'.:::',,*:.,£'C::j>!:/Y*;: :. * . ; .' ?'ii(:/;\ .,Criteri~.

BV JPIC Mobilization lal BV JPIC Comi:nunications Equipment ldl BV JPIC Equipment and Supplies to Support Operations lel BV JPIC Emergency Information & Instructions for the Public/Media , 5bl HCEOC Mobilization lal HCEOC Communications Equipment ldl HCEOC Equipment and Supplies to Support Operations lel HCEOC Implementation of Emergency Worker Exposure Control 3al HCEOC Activation of the Back-up ANS 5a3 HCEOC Mobilization lal HCEOC Facilities lb.1 HCEOC Direction and Control lcl HCEOC Communications Equipment ldl HCEOC Equipment and Supplies to Support Operations lel HCEOC PAD Decision-making Process and Coordination for the General Public 2b2 HCEOC Implementation of Emergency Worker Exposure Control 3al Implementation of KI Decision for Institutionalized Individuals and the HCEOC 3bl Public HCEOC Implementation of PADs for disabilities & access/functional needs people 3cl HCEOC Implementation of PADs for Schools 3c2 HCEOC HCEOC HCEOC Implementation of Traffic & Access Control Impediments to Evacuation Activation of the Prompt Alert & Notification Systems 3dl 3d2 Sal' HCEOC Emergency Information & Instructions for the Public/Media 5bl Implementation of PADs for disabilities & access/functional needs people HCHCS 3cl (Transportation Dependent)

HCHCSOGMS Implementation of PADs for Schools 3c2 HCMCCWHS Equipment and Supplies to Support Operations lel HCMCCWHS Temporary Care of Evacuees 6cl HCMDCWHSC Equipment and Supplies to Support Operations lel 18

1. Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station HCMDCWHSC Implementation of Emergency Worker Exposure Control 3al HCMDCWHSC Monitoring, Decontamination, and Registration of Evacuees 6al HCEWMDC NCFD Direction and Control lcl HC EWMDC NCFD Communications Equipment ldl HCEWMDC NCFD Equipment and Supplies to Support Operations lel HCEWMDC NCFD Implementation of Emergency Worker Exposure Control 3al Monitoring and Decontamination of Emergency Workers and their HCEWMDC NCFD 6bl fquipment and Vehicles HCRCWHS Equipment and Supplies to Support Operations lel HCRCWHS Monitoring, Decontamination, and Registration of Evacuees 6al HCTACPCCPD Communications Equipment ldl

  • HCTACPCCPD HCTACPCCPD HCTACPCCPD Equipment and Supplies to Support Operations Implementation of Emergency Worker Exposure Control Implementation of Traffic & Access Control lel 3al 3dl WVFAMTl Mobilization lal WVFAMTl Communications Equipment ldl WVFAMTl Equipment and Supplies to Support Operations lel WVFAMTl Impl~mentation of Emergency Worker Exposure Control 3al WVFAMTl* Plume Phase Field Measurement, Handling, & Analyses 4a3 WVFAMT2 Mobilization lal WVFAMT2 Communications Equipment ldl WVFAMT2 Equipment and Supplies to Support Operations lel WVFAMT2 Implementation of Emergency Worker Exposure Control 3al WVFAMT2 Plume Phase Fi~ld Measurement, Handling, & Analyses 4a3 WVSFMTM Mobilization lal WVSFMTM Direction and Control lcl WVSFMTM Communications Equipment I ldl WVSFMTM Equipment and Supplies to Supp01i Operations lel WVSFMTM Field Team Management 4a2 WVAAC Mobilization lal WVAAC Direction and Control lcl WVAAC Communications Equipment ldl WVAAC Equipment and Supplies to Support Operations lel WVAAC Emergency Worker Exposure Control Decisions 2al
  • WCAAC WVAAC WVEOC Accident Assessment and P ARs for the Emergency Event PAD decision-making process and coordination for the General Public Mobilization 2bl 2b2 lal WVEOC Direction and Control lcl WVEOC Communications Equipment ldl WVEOC Equipment and Supplies to Support Operations lel WVEOC PAD Decision-making Process and Coordination for the General Public 2b2 WVEOC PADs for Disabilities & Access/Functional Needs People 2cl WVEOC Implementation of KI PAD for Institutionalized Individuals/Public 3bl WVEOC Activation of the Prompt Ale1i & Notification System Sal WVPIC Mobilization lal WVPIC Communications Equipment ldl WVPIC Equipment and Supplies to Support Operations lel WVPIC Emergency Information & Instructions for the Public/Media 3al
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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 3.3 Criteria Evaluation Summaries 3.3.1 State Jurisdictions 3.3.1.1 State of West Virginia Emergency Operations Center In summary, the status of DHS/FEMA ci:iteria for the State jurisdiction is as follows:*

a. J\1ET: I.a.I, l.b.1, l.c.1, l.d.1, l.e.l, 2.b.2, 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 3.3.1.2 West Virginia Accident Assessment Center In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:
a. J\1ET: I.a.I, l.q.l, l.d.l, I.el, 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 3.3.1.3 West Virginia Field Air Monitoring Team 1 In summary, the status ofDHS/FEMA criteria for the State jurisdiction is as follows:
a. J\1ET: I.a.I, l.d.l, l.e.l, 3.a.1, 4.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE 20
  • Unclassified .

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station

e. PRJOR ISSUES-RESOLVED: 03-14-4a3-P-01
f. PRJOR ISSUES - UNRESOLVED: NONE 3.3.1.4 West-Virginia Field Air Monitoring Team 2 In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:
a. MET: l.a.1, 1.d.l, 1.e.l, 3.a.1, 4.a.3
b. LEVEL 1 FINDINGS: NONE
  • c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: ONE .
e. PRJOR ISSUES - NONE
f. PRJOR ISSUES - UNRESOLVED: NONE ISSUE FOR CRITERION: 4.a.3 CONDITION: The West Virginia Field Air Monitoring Team (FAMT) would not know if they are still in the plume while the air sample is being collected as they do not take survey readings before, during and after the air sample collection.

POSSIBLE CAUSE: The current procedure does not include the requirement to take survey readings during the collection of the air sample.

REFERENCE:

NUREG-0654/FEMA-REP-1, C.1; H.12; I.8,9; J.lOa

-State of West Virginia FMT Standard Operating Procedure, Rev 1, 2018 Annex C "Air Sampling"- Appendix 14 "WV Rad Health Air Sampling Data Sheet,"

EFFECT: The air sample that is collected could misrepresent the inhalation dose,

  • thereby ui1der estimating exposure .

RECOMMENDATION: The State of West Virginia FAMT Standard Operating Procedure, Rev 1, 2018 Annex C "Air Sampling" should include direction to take field monitoring reading at the start, middle and end of the air sampling. Additionally, Appendix 14 "WV Rad Health Air Sampling Data Sheet,"

CORRECTED ACTION: On June 22, 2018 the State of West Virginia revised their plan to add the verbiage to monitor at beginning, middle and end while collecting a

  • sample.

3.3.1.6 West Virginia State Fiel~ Monitoring Team Management In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

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After Action Report/Improvement Plan Unclassified Radiological Emergency Preparedness Program (REP)

Beaver Valley Power Station

a. MET: I.a.I, 1.c.1, 1.d.1, 1.e.1, 4.a.2
b.
  • LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRJOR ISSUES - NONE
f. PRJOR ISSUES - UNRESOLVED: NONE 3.3.2 Risk Jurisdictions 3.3.2.1 Hancock County Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:
a. MET: 1.a. l, l.c.l, Ld.1, l.e.l, 2.b.2, 3.a.l, 3.b.1, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.a.1, 5.a.3, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
e. PRJOR ISSUES: RESOLVED: NONE
f. PRJOR ISSUES -.UNRESOLVED: NONE 3.3.2.2 Hancock County Emergency Worker Mon and Decontamination Sfation, New Cumberland FD In summary, the status ofDHS/FEMA criteria for the Risk jurisdiction is as follows:
a. MET: 1.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. PRJOR ISSUES: RESOLVED: NONE
f. PRJORISSUES- UNRESOLVED: NONE 3.3.2.3 Hancock County Mass Care Center, Weir High School Complex 22
  • Unclassified Radiological E_mergency Preparedness l'rograrn (REP)

Aftel' Action Report/Improvement Plan Beaver Valley Power Station In summary, the status ofDHS/FEMA criteria for the Risk jurisdiction is as follows:

a. lVIBT: l.c.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 Hancock County Monitoring and Decontamination Center, Weir High School Complex In summary, the status of DHS/FEMA criteria for tpe Risk jurisdiction is as follows:
a. lVIBT: l.c.l, l.d.l, l.e.l, 3.a.1, 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 3.3.2.5 Hancock County Reception Center, Weir High School Complex
  • In summary,the status ofDHS/FEMA criteria for the Risk jurisdiction is as follows:
  • a. lVIBT: 1.c. l, l .e. 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 3.3.2.6 Hancock County Traffic & Access Control, Chester City Police Department In summary, the status ofDHS/FEMA criteria for the Risk jurisdiction is as follows:
  • 23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station

a. MET: l.d.l, l.e.l, 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. 7 Hancock County, Hancock County School~

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

a. MET: 3.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 3.3.2.8 Hancock County, Hancock County Schools, Oak Glen Middle 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: 03-16-3.c.2-L2-02
f. PRIOR ISSUES - UNRESOLVED: NONE 24

After Action Report/Improvement Plan Beaver Valley Power Station SECTION 4: DEMONSTRATED STRENGTHS JIC (JPIC)- WV & PA o The West Virginia PIOs maintained effective, continuous coordination with all public information participating agencies, and with Hancock County throughout the exercise.

West Virginia Emergency Operations Center

  • o The Shift Leader and the State Agency Coordinator, both new to Radiological Emergency Response (REP) exercises, went abov.e and beyond and clearly worked countless hours to incorporate the recommendations that were provided to them following the Dry Run Exercise on May 29, 2018.

o The two volunteer runners were truly an integral paii of message distribution, keeping all sections informed of briefings, and ensuring all information flowed in a timely manner .

  • - 25

Unclassified Radiologisal Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station

  • sECTION 5: CONCLUSION The State of West Virginia and local jurisdictions, except where noted in this repmi demonstrated knowledge of their Radiological Emergency Response Plans (RERP) and procedures were adequately implemented during the Beaver Valley Power Station Plume exercise evaluated on 12 June, 2018.

Federal Emergency Management Agency (FEMA) evaluators assessed 304 evaluation criteria in six Assessment Areas:

~ Evaluation Area 1: Emergency Operations Management

  • e Evaluation Area 2: Protective Action Decision Making e Evaluation Area 3: Protective Action Implementation e Evaluation Area 4: Field Measurement and Analysis e Evaluation Area 5: Emergency Notification and Public Inforrnation c Evaluation Area 6: Suppmi Operation/Facilities These analyses resulted in a determination of No Level 1 Finding, No Level 2 Finding and (1)

ONE New Plan Issue. The Plan Issue was resolved on June 25, 2018.

Based on the results of the exercise and a review of the offsite radiological emergency response.

plans and procedures submitted, FEMA Region III has dete1mined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-l, 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.

26

After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX A: EXERCISE TIMELINE This section contains the Exercise Tirneline. A table that depicts the times when an event or notifications were noted at participating agencies and locations.

Tiine ThatNcitification ,vas Received atthe Listed Location  :

Enierg~niY ,.,

  • Titne l}tility West Virginia State Accident Hancock
  • Classifica'.tfori .** State
  • ** Declarecl JPIC Assessment County (WV)

!;eve] 'oi~vent' EOC EOC QUE 1617

  • lert SAE 1717 1832 1722 1.836 1743 1845 1723 1835 1728 1838 GE NIA NIA NIA Start of Simulated Radiation Release 1924 1934 Termination of Simulated Radiation 1955 Facility Declared Operational 1735 1745 1735 1700 Gove111or's Declaration of State of 1731 1739 1755 1819 xercise Terminated 2005 2008 2008 2005 First Protective Action Decision 1855 1908 1900 1906 1855 .1908 1900 ir 3000 @3 miles Water 10 miles 1855 1908 1900 ail IO miles imals stored feed and water Siren Sounding 1900. 1900 1900
  • EAS Broadcast time Additional Precautionary Actions Describe:

1903 1903 1903 Second Protective Action Decision Describe:

Siren Sounding EAS Message Broadcast KI Decision - .

Emergency Workers KI Decision - .

General Public 27

Unclassified .

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leaders for the Beaver Valley Power Station 2018 Radiological Emergericy Preparedness Plume Exercise evaluated on 12 June, 2018. The following constitutes the managing staff for the Exercise Evaluation:

  • Thomas Scardino, DHS/FEMA, Regional Assistance Committee (RAC) Chairman
  • Chris Nemcheck DHS/FEMA, Project Officer and Site Specialist
  • Paul Neid, Regional Coordinator DATE: 6/12/2018 SITE: Beaver Valley Power Station
f;;;:;lttil1:i~\1~:ffi.)J;*::i\;>i*:Bo~g~)JQN:~i::~]Gf~i!i'.}'(;t='}*;::tf .. t;\\.-~JE'.£\¥.*tJP}P:8~ /}:/.[ it*:r::;:).:~:tA~~~;Crn.\:t:,:t;:;:1, Hancock County Emergency Operations Center Patricia Gard.ner FEMARIII Hancock County Emergency Worker Mon and Christopher Nemcheck FEMARIII Decontamin Station, New Cumberland FD Hancock County Mass Care Center, Weir High School Lee Torres FEMARIII Complex Hancock County Monitoring and Decontamination Christopher Nemcheck FEMARIII Center, Weir High School Complex Hancock County Reception Center, Weir High School Christopher Nemcheck FEMARIII Complex Hancock County Traffic & Access Control, Chester City William McDougall FEMARIII Police Department Hancock County, Hancock County Schools Christopher Nemcheck FEMARIII Hancock County, Hancock County Schools, Oak Glen Lee Torres FEMARIII Middle School State of West Virginia Emergency Operations Center Lee Torres FEMARIII West Virginia Accident Assessment Center Kenneth Wierman FEMAHQ West Virginia Field Air Monitoring Team 1 West Virginia Field Air Monitoring Team 2 Kenneth Wierman Kenneth Wierman FEMAHQ FEMAHQ West Virginia Public Information Center Lee Torres FEMARIII West Virginia State Field Monitoring Team Kenneth Wierman FEMAHQ Management 28

After Action Report/Improvement Plan Beaver Valley Power Station

);~cy:}?;J;,:,),' \, ;:;;;;\.!,,)'.' ;;,c,,::,*-r:

';;--;',il;{fr, i:i'h A-rtri'rr-sr:::"' ,!J:," .,ti>?*,,/'* ., *** ' ,

" ",,,. - .'.. -.,' ),::ff'o\;)'. '

  • \(t>

(tf;f~Y:AfV~R:'~~11:,;~tt;J{ iJ{t,;:::'."'.:AGt~§)\};;":\j/-c, Hancock County Emergency Operations Center Brian Hasemann FEMA Region 2 Hancock County Emergency Operations Ce_nter Patricia Gardner FEMARIII Hancock County Emergency Operations Center DavidKayen Hancock County Emergency Operations Center Robert Walker Hancock County Emergency Worker Mon and Decontamin Station, New Christopher Nemcheck FEMARIII Cumberland FD Hancock County Emer.gency Worker Mon and Decontamin Station, New Lee Torres FEMARIII Cumberland FD Hancock County Mass Care Center, Weir High School Complex Lee Torres FEMARIII Hancock County Monitoring and Decontamination Center; Weir High School Christopher Nemcheck FEMARIII.

  • Complex Hancock County Reception Center1 Weir High School Complex Hancock County Traffic & Access Control, Chester City Police Department Christopher Nemcheck
  • William McDougall FEMARIII FEMARIII Hancock County, Hancock County Schools Christopher Neincheck FEMARIII Hancock County, Hancock County Schools Lee Torres FEMARIII Hancock County, Hancock County Schools, Oak Glen Middle School Lee Torres FEMARIII Lawerance County Reception Center!Public Monitoring and Decontamination Helen Laforge FEMA Region 1 Station, Mohawk Area High School Lawrence County Emergency Operations Center Helen Laforge _FEMA Region 1 Lawrence County Mass Care Center, Mohawk Area High* School Taneeka Hollins FEMA Region 1 PA State Field Monitoring Team A, South West Region Michael DeBonis FEMA PA State Field Monitoring Team B, South West Region Michael Petullo Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Kenneth Wie1man FEMAHQ Vehicle Pennsylvania State Traffic and Access Control Points Michael Meshenberg State of West Virginia Emergency Operations Center Lisa Rink FEMAHQ State of West Virginia Emergency Operations Center Lee Torres FEMARIII State of West Virginia Emergency Operations Center Larry Broockerd Headquarters State of West Virginia Emergency Operations Center Clark Duffy Washington County Emergency Operations Center Thomas Gahan Washington County Mass Care Center, Trinity High School Alonzo Mcswain Headquarters Washington County Monitoring and Decontamination Center, Trinity High Barbara Thomas FEMA Region 1 School Washington County Reception Center County Fair Grounds William McDougall FEMARIII West Virginia Accident Assessment Center Roger Winkelmann West Virginia Field Air Monitoring Team 1 Carol D. Shepard West Virginia Field Air Monitoring Team 2 Kent Tosch West Virginia Public Information Center Henry Christiansen ICFI West Virginia State Field Monitoring Team Management Reggie Rodgers
  • 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX C: ACRONYMS AND ABBREVIATIONS t~il:ilt~i~~~Wii~~~;:~lJ~fftiil~i~ll~~!it~:~~.Miifl~~

ACP Access Control Point ALARA As Low As Reasonably Achievable ARC American Red Cross ARES BURA BVPS Amateur Radio Emergency Services Back Up Route Alerting Beaver Valley Power Station CAD Computer Aided Display CCNP Cisco Certified Network Professional CDE Committed Dose Equivalent CERC Corporate Emergency Response Center CERT Community Emergency Response Team co Communication Officer CPM Counts Per Minute CST Civil Support Team DAC Dose Assessment Coordinator DAD Digital Alarming Dosimet1y DAS Director of Auxillary Services DDHS Department of Health and Human Services DOT Department of Transportation DRF- Dosimetry Record Form EAL Emergency Action Level EARA Exception Area Route Alerting EAS Emergency Alert System EC Emergency Coordinator ECL ECO EMC Emergency Classification Level Exposure Control Officer Emergency Management Coordinator EMD Emergency Management Director EMnet Emergency Management Network EMS Emergency Medical Services EOC Emergency Operations Center EOF Emergency Operations Facility EOP Extent of Play EPA Environmental Protection Agency EPT Exercise Planning Team EPZ Emergency Planning Zone ER Emergency Room I

ERM Emergency Response Manager ERV Emergency Response Vehicle 30

After Action Report/Improvement Plan Beaver Valley Power Station ESC Emergency Services Coordinator ESP Emergency Support Function ETA Estimated Time of Arrival EW Emergency Workers FD Fire Department FEMA Federal Emergency Management Agency FMT Field Monitoring Teai.n Federal Radiological Monitoring Assessment FRMAC Center FSE Full Scale Exercise

  • FTC GE GIS Field Team Coordinator General Emergency Geographic Information Systems GPS Global Positioning System HAN Health Aleti Network HazMat Hazardous *Materials HF High Frequency Homeland Security Exercise and Evaluation HSEEP Program IPZ Ingestion Pathway Zone IWP Initial Warning Point JIC Joint Information Center KI .Potassium Iodide LCD Liquid Crystal Display:

LEOF Local Emergency Operations Facility LHD Local Health Department MDDT Mobile Data Display Terminal MDT Mobile Data Terminals MHz Megahertz Meteorological Information Dose Assessment MIDAS System

  • MS-1 MSEL M~dical Services Hospital Master Scenario Events List Orange County Depaiiment of Fire/Emergency OCDFEMS Medical Services ORB Office of Radiological Health OSD Optically Stimulated Dosimeter PA Public Affairs PAD* Protective Action Decision PAG Protective Action Guidelines PAR
  • Protective Action Recommendation PARA Primary Area Route Alerting PAZ Protective Action Zone PD Police Department Persons with Disabilities/Access and Funtional PDAFN Needs PED Personal Electronic Dosimeter
  • 31

Unclassified Radiological Emergency Preparedness Program (REP)*

After Action Repo1t/lmprovement Plan Beaver Valley Power Station PIO Public Information Officer PPE Personal Protective Equipment PRA Primary Route Alerting PRD Permanent Record Dosimeter RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Services RAO Radiation Assessment Officer RDO Radiation Defense Officer REA Radiation Emergency Area REC Radiation Exposure Control REP RERP RHP Radiological Emergency Plan Radiological Emergency Response Pian Radiological Health Program RML Radiological Mobile Laboratory RO Radiological Offic*er ROO Radiological Operations Officer RTF Radiological Task Force SA Staging Area SAC Staging Area Coordinator SAE Site Area Emergency SAIC Science Applications International Corporation SAM Staging Area Manager SCBA Self-Contained Breathing Apparatus SEOC State Emergency Operations Center SERS State Emergency Radio System SFMT State Field Monitoring Team SIRN Statewide Interoperability Radio Network so State Official SOP Standard Operating Procedure SRO School Resources Officer sso Social Services Officer STARS SWAN Statewide Area Radio System State Warning Alert Notification TCP Traffic Control Point TEDE Total Effective Dose Equivalent TO Transportation Officer UEM Utility Emergency Manager VHF Very High Frequency 32

After Action Report/Improvement Plan Beaver Valley Power :Station APPENDIX D: EXTENT OF PLAY AGREEMENT The 2018 Beaver Valley Power Station Plume Exercise Extent-of-Play was negotiated and agreed upon by FEMA Region III, WV Division of Homeland Security and Emergency Management, and the Emergency Management Agencies of the Risk Counties .

33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Annex B: Method of Operation and Extent of Play ASSESSMENT AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.a - Mobilization Intent This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

  • Criterion 1.a~l: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654/ FEMA-REP-1, A.I.a, e; A.3, 4; Cl,4, 6; D.4; E.1, 2; H.3, 4)

Assessment/Extent of Play Assessment of this Demonstration Criterion may pe accomplished during a full-scale or functional'exercise, an actual event, or by means of drills conducted at any time.

Responsible OROs inust demonstrate the capability to receive notification of an incident from the licensee; verify the notification; and contact, ale1i, and mobilize key emergency personnel in a timely manner and demonstrate the ability to maintain arid 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 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 an-ival. 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.

The REP program does not evaluate Incident Command System tactical operations, only coordination among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

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

  • Agreement, at those facilities located beyond a normal commuting distance from the individual's duty location or residence. 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.

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 atan 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 suppo1i must be demonstrated, as appropriate. Any resources identified through LOA/1\10Us must be on the ORO's mobilization list so they can be contacted during an incident, if needed. All activities 34

After Action Report/Improvement Plan Beaver Valley Power Station 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.

State Negotiated Extent of Play:

e Demonstrate the capability to receive and verify notification of an emergency situation from the licensee. Contact, alert, and simulate mobilization of key emergency personnel. (WV EOG will simulate notification/activation of the key state agencies deemed necessary, but not physically represented in the EOG during the exercise.)

  • a Demonstrate the activation of facilities for immediate use by personnel in attendance for the exercise when they arrive.

o Activation procedures (simulated or actual) will not start until an Alert is declared.

e Simulation of activation of facilities will be completed in accordance with the plan and/or proce.dures.

o Personnel will be pre-positioned. This pre-positioning will be for all locations, to include EOC, field locations and any out-of-sequence demonstrations.

o EOC Twenty-four (24) Hour Staffing will be demonstrated by roster.

Risk and Support Jurisdictions Negotiated Extent of Play:

e Demonstrate the capability to receive and verify notification of an emergency situation from the licensee. Contact, alert, and mobilize key emergency personnel in a timely manner (simulated).

o Demonstrate the activation of facilities for immediate use by mobilized

  • personnel when they arrive to begin emergency operations .

_0 Activation of facilities should be completed in accordance with the plans and procedures.

e Activation of facilities will not start until an Alert is declared .

., Personnel will be pre-positioned. This pre-positioning will be for all locations*,

to include EOC, field locations and any out-of-sequence demonstrations.

e EOC Twenty-four (24) Hour Staffing will be demonstrated by roster.

Outstanding Issues:

  • 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Po,ver Station None 36

After Action Report/Improvement Plan

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

Criterion 1. b.1: Facilities are sufficient to support the emergency response. (NUREG-0654, H.3).

Extent of Play

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

Facilities must be set up based on the ORO's plans and procedures and demonstrated as they would be used in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

State Negotiated Extent of Play:

a All facilities were evaluated during the 2014 exercise. State facilities will not be evaluated during this exercise unless the move to the new State EOC is completed prior to the exercise.

Risk and Support Jurisdictions Negotiated Extent of Play:

o The HCEOC and building locations were evaluated during the 2016 exercise and will not be evaluated.

  • Outstanding Issues:
  • None
  • 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 1.c - Direction and Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to control their overall response to an emergency.

  • Criterion J.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.J.d; A.2.a, b; A.3; C.4, 6) . .

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished in a full scale, functional, 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.) 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.

State Negotiated Extent of Play:

o Designated EOC personnel should demonstrate the ability to carry out essential

  • functions of the response effort, for *example: keeping the staff informed through periodic briefings and/or other means, coordinating with other appropriate response organizations, and ensuring completion of requirements and requests.

Risk and Support Jurisdictions Negotiated Extent of Play:

  • o Leadership personnel should demonstrate the ability to carry out essential functions of the response effort, for example: keeping the staff informed through periodic briefings and/or other means, coordinating \(1/ith other appropriate response organizations, and ensuring completion of requirements and requests.

Outstanding Issues:

None 38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 1.d - Communications Equipment Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires 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-le 0654/FEMA-REP-1, F.l, 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 full scale,functional and tabletop exercises, or if their use would be required, during an actual event. -

OROs must demonstrate that a primary system, and at least one backup system for fixed facilities, is 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 maintained 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 i~ independent of the commercial telephone system. Responsible OROs must demonstrate the capability to manage the communication systc:ms and ensure that all message traffic is handled without delays that might disrupt emergency operations. OROs must ensure that a coordiqated communication link for fixed and mobile medical support facilities exists. Exercise scenarios may require the failure of~

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.

State Negotiated Extent of Play:

o Telephone communications will be available for demonstration. At least orie other communication system utilized by the EOC staff will be explained.

o If a communications system is not functional, and exercise performance is not affected, no exercise issue will be assessed.

  • 39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station

  • Demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt the conduct of emergency operations.

Risk and Support Jurisdictions Negotiated Extent of Play:

e Telephone and at least one additional communications system will be available for demonstration.

o If a communications system is not functional, and exercise petformance is not affected, no exercise issue will be assessed.

  • e Demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt the conduct of emergency operations.

c Out-of-sequence demonstrations will have communications available but not necessarily demonstrate them.

e

  • Communications associated with medical support facilities were demonstrated during the March 2017 MS-1 Federal Evaluated Exercise.

Outstanding Issues:

None

\

40

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 1.e - Equipment and Supplies to Support Operations Intent This Sub-element is derived from_NUREG-0654/FEMA-REP-l, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.

Criterion J.e.J: Equipment, maps, displays, monitoring instruments, dosimetly, potassium iodide (KI) and other supplies are sufficient to support emergency operations (NUREG-0654/FEMA-REP-1, H 7, JO; L 7, 8, 9; J.10.a, b, e; J.11, 12; K3.a; KS.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 arid 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 f<?llows:

KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized individuals, 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, urbari 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 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 quantitie~ of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current invento1y submitted during the exercise, provided in the ALC submission, arid/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. Phannacopoeia

.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 inake 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).

  • 41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Repo1-t/Improvement Plan Beaver Valley Power Station Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative repmiing 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.

  • Mutual Aid Resources: If the incoming resources atTive with their own equipment (i.e., monitors and/or dosimetry), they will be evaluated by REP Pro grain standards. FEMA will not invento1y equipment that is not part of the REP Pro grain. If an agency has a defined role in the REP Plan, they at*e subject to the platming process and standai*ds, as well as the guidance of this Manual.

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 instrum.ents 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 u~ed to measure activity must have a sticker-affixed to their-sides indicating the effective range of the readings. The range ofreadings 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/exp.osure 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 4igh-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.

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

State Negotiated Extent of Play:

42

After Action Report/Improvement Plan Beaver Valley Power Station

.. Maps and displays will be utilized in the EOC.

o Radiological instruments used by the State Field Teams will be with the teams in Hancock County. Dosimetry for the State Field Teams will be issued by the Courity.

Radiological instruments will- be operation.ally checked. A label indicating such calibration should be on each instrument or verifiable by other means, such as a letter.

., Kl is pre-distributed by the State to the General Public .

  • Risk and Support Jurisdictions Negotiated Extent of Play:

e The dosimetry is exchanged annually and documentation will be verified during the exercise.

0 The County will demonstrate the capability to maintain inventories of Kl sufficient for use by emergency workers.

0 Adequate quantities of Kl for the public are stored at the County Health Department. Dosimetry and Kl for Emergency Workers are stored at the HCEOC and will be confirmed by physical inspection during the April 30 1h-May 4th timeframe.

  • Available supplies of Kl will be within the expiration date indicated on Kl bottles or blister packs.

a Maps and displays will be utilized in the EOC.

0 Hancock County does not pre-distribute dosimetry.

\...

8 Dosimetry "Training Kits with simulated TLD's" will be available at the field

  • e locations to demonstrate the use of dosimetry if applicable. By using Training Kits, not all Emergency Workers at the Field Locations will receive dosimetry.

0 Kl is pre-distributed to the General Public.

C

"' A Law Enforcement Officer in the County EOC will discuss Traffic and Access Control. An actual control point will not be established.

(> Traffic Control/Access Control Points supplies/equipment will be_ explained during the April 301h, 2018 interview.

" The inventory of equipment and supplies will be verified during the out-of-sequence evaluation Outstanding Issues: *

  • 43

Unclassified ,

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station None 44

After Action Report/Improvement Plan Beaver Valley Power Station ASSESSMENT AREA 2: 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 permitted 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.J: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of Ia, 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; J.10. e,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 full scale;functional or tabfotop 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 doses 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 PA Gs 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.
  • 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station State Negotiated Extent of Play:

  • As appropriate, demonstrate the capability to make decisions on the administration of Kl as a protective measure for emergency workers. This may be demonstrated by interview. *

,. The decision for Kl can be "not to administer' Kl.

Risk and Support Jurisdictions Negotiated Extent of Play:*

0 Demonstrate the capability to make decisions concerning the authorization of exposure levels in excess of pre-authoriied levels and to the number of emergency workers receiving radiation dose above pre-authorized levels. This will be done by interview.

The decision-making process for Kl can be demonstrated through interview.

Outstanding Issues:

None 46

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 2.b. - Radiological Assessment and Precautionary and/or Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Intent This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare the.se 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.l: Appropriateprotective 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 ojfsite environmental conditions. (NUREG-0654/FEMA-REP-l, 110 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 full-scale, functional 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 P ARs 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 dewonstrate 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 the 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 pre-arranged 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 to use any additional data to refine projected doses and exposure rates and revise the associated PA.Rs.

  • 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.

State Neaotiated Extent ofPlav:

  • 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station

" Protective Action Recommendations will be developed in accordance with Plans and/or Procedures.

~ If the scenario does not involve a release, this can be demonstrated by interview.

  • If adequate data becomes available, accident assessment wiH be performed and PARs developed.

Risk and Support Jurisdictions Negotiated Extent ofPlay:*

  • E> N/A Outstanding Issues:

Findings: Planning Issue The State of West Virginia (WV) did not have specific procedures to conduct radiation dose projections using Meteorological Information and Dose Assessment System (MIDAS) dose projection software or procedures for alternate methods that could be used (hand calculations), to include calculations using field monitoring team data. With assistance from the licensee, the WV Accident Assessment Manager was able to complete a MIDAS dose projection.

48

After Action Report/Improvement Plan Beaver Valley Power Station 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.f, m)

Assessment/Extent Play of Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a full-scale, functional 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 Decision in a timely manner appropriate to the incident,

  • based on info1mation 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 co111I11and), 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 effmis 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 inpµt regarding considerations for subsequent P ARs based on the magnitude of the ongoing threat, the response, and/or site conditions. The decision-makets must demonstrate the capability to change protective actions based on the combination of all these factors.

If the ORO .has determined that Kl will be used as a protective measure for the general public un.der 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 P AG for KI administration. The Kl 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 and coordinate P ADs with each other. In addition, decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of

.decisions to all the affected locations.

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.

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.

  • 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station State Negotiated Extent of Play:

e The State will demonstrate capability to make both initial and subsequent PARs. However, based on the recommendation by the State, the final decision will be made by county administration Risk and Support Jurisdictions Negotiated Extent of Play:

e o

Demonstrate the ability to make initial PADs in a timely manner.

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

e The PAD should be coordinated between the 3 States and risk counties. A coordinated PAD does not necessarily mean the same PAD.

"' The PAD will be coordinated between the State of West Virginia and Hancock

.Coun~.

  • e At least one PAD/ PAR will be demonstrated.

e In West Virginia, Kl is pre-distributed to the General Public.

o If the scenario does not involve a release this can be demonstrated through interview.

Outstanding Issues:

None 50

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 2.c - Precautionary and/or Protective Action Decisions 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, if applicable, for groups of pe1*sons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed daycare centers, mobility-impaired individuals, and transpo1iation-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.J: Precautionary and/or Protective action decisions are made, as appropriate,for groups ofpersons with disabilities and access/functional needs. (NUREG-0654/FEMA-REP-1,D.4; J.9; J.1 O.d, e)

Assessment/Extent of Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exei*cise and may be demonstrated in a full-scale, functional or tabletop exercise that would include the use ofplant 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 PA Gs, except for incidents where there is a high-risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved. Ii1 these cases, factors that must be considered include weather conditions, shelter availability, availability of transp01iation 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 ORQ must consider use of KI.

Applicable OROs must demonstrate the capability to ale1i and notify all public 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.

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, 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).

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 othe1wise specified in the Extent-of-Play Agreement.

State Negotiated Extent of Play:

o NIA Risk and Support Jurisdictions Negotiated Extent of Play:

51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Q Schools will be demonstrated out of sequence on May 2nd,2Q 18.

o Access and functional needs populations will

  • be demonstrated through interview with appropriate EOC staff.

c:, If the scenario does not involve a release, this can be demonstrated through interview.

Outstanding Issues:

. None 52

After Action Rcport/lmproyement Plan Beaver Valley Power Station Sub-element 2.d. - Radiological Assessment and Decision Making for the Ingestion Exposure Pathway Intent This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PAGs, and make timely, appropriate PADs to mitigate exposure from the pathway.

a During an incident at an NPP, release ofradioactive material may contaminate water supplies and agricultural products in the surrounding areas. Any such.contamination would likely occur during the plume phase of the incident and, depending on the nature of the release, could impact

  • the ingestion pathway for weeks or years.

Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriateprotective action decisions ai*e made based on the ORO's planning criteria.

(NUREG-0654/FEMA-REP-l, A.3; C.1, 4; D.4; J.9,11)

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

OROs are expected to take precautionary actions to protect food and water supplies, or to minimize exposure to potentially contaminated water and food, in accordance with their respective plans/procedures. Often OROs initiate such actions based on criteria related to the facility's ECLs. Such actions may include recommendations to place milk animals on stored feed and use protected water supplies. The ORO must use its procedures to assess the radiological consequences of a release on the food and water supplies, such as the development of a sampling plan. The ORO's assessment must include evaluation of the radiological analyses of representative samples of water, food, and other ingestible substances of local interest from potentially impacted areas; characterization of the releases from the facility; and the extent of areas potentially impacted by the release. During this assessment, OROs must consider use of agricultural and watershed data within the SO-mile EPZ. The radiological impacts on the food and water must then be compared to the appropriate ingestion PAGs contained in the ORO' s

  • plans/procedures. The plans/procedures contain PAGs based on specific dose commitment

~riteria or on criteria as recommended by current Food and Drug Administration (FDA) guidance. Timely and)appropriate recommendaJions must be provided to the ORO decision-makers group for implementation decisions. OROs may also include a comparison of taking or not taking a given action on the resultant ingestion pathway dose commitments.

The ORO must demonstrate timely decisions to minimize radiological impacts from the ingestion pathway, based on the given assessments and other information. Any such decisions must be communicated and, to the extent practical, coordinated with neighboring OROs. These decisions include tracking agricultural products entering and leaving the EPZ. Demonstration of plans and procedures which use traffic access control points to track agricultural products entering and leaving the EPZ may be conducted through interview.

53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improveme1.1t Plan .Beaver Valley Power Station OR.Os must use Federal resources, as identified in the Nuclear/Radiological Incident Annex of the NRF and other resources (e.g., compacts or nuclear insurers). Evaluation of this criterion will take into consideration the level of Federal and other participating resources.

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:

State Negotiated Extent of Play:

e N/A Risk and Support Jurisdictions Negotiated Extent ofPlay:

., N/A Outstanding Issues:

54

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 2.e. - Radiological Assessment and Decision Making Concerning Post-Plume Phase Relocation, Reentry, and Return Intent This Sub-element' is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to make decisions on post-plume phase relocation, reentry, and return of the general public. These decisions are essential for protection of the public from direct long-term exposure to deposited radioactive materials from a severe incident at an NPP.

Criterion 2.e.l: Timely post-plume phase relocation, reentry, and return decisions are made

  • and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and/or procedures. (NUREG-0654/FEMA-REP-1, LIO; J.9; K.3.a; M.l)

Assessment/Extent of Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and mqy be demonstrated in a full-scale, functional or tabletop exercise that would

. include the use ofplant conditions transmitted from the licensee.

Relocation: OROs must demonstrate the capability to estimate integrated dose in contaminated areas and compare these estimates with PAGs; apply decision criteria for relocation of those individuals in the general public who have not been evacuated, but where actual or projected doses are in excess of relocation PAGs; and control access to evacuated and restricted areas.

OROs will.make decisions for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PA Gs. Determination of areas to be restricted must be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates versus the PA Gs, and analyses of vegetation and soil field samples.

Reentry: Decisions must be made on location of control points and policies regarding access and exposure control for emergency workers and members of the general public who need to

  • temporarily enter the evacuated area to perform specific tasks or missions.

Examples of control procedures are the assignment of, or checking for, direct-reading and permanent record dosimetry for emergency workers; questions regarding an individual's objectives, locations expected to be visited, and associated timeframes; availability of maps and plots of radiation exposure rates; and advice on areas to avoid. Control procedures also include monitoring of individuals, vehicles, and equipment; the implementation of decision criteria regarding decontamination; and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

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

maintenance of essential services (e.g., fire protection and utilities), and other critical functions.

They must demonstrate the capability to use decision-making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g., to care for farm animals. or secure machinery for storage) or retrieve important possessions. Coordinated policies for access and exposure control must be developed among all agencies with roles to perform in the restricted zone(s). OROs must demonstrate the capability to establish policies for 55

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Repo1*t/Improvement Plan

  • Beaver Valley Power Station provision of dosimetry to all individuals allowed to reenter the restricted zone(s). The extent to which OROs need to develop policies on reentry will be determined by scenario events.

Return: OROs must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis). OROs must base decisions on environmental data and political boundaries or physical/ geological features, which allow identification of the boundaries of areas to which members of the general public may return. Return is permitted to the boundary of the restricted area(s) that is based on the relocation PAG.

  • Other factors that the ORO must consider in decision-making include conditions that permit cancellation of the ECL and relaxation of associated restrictive measures. OROs must base return recommendations on measurements of radiation from ground deposition. OROs must have the capability to identify services and facilities that require restoration within a few days and to identify the procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads, schools, and intermediate-term housing for relocated persons.

All activities mustbe 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.

State Negotiated Extent of Play:

0 NIA Risk and Support Jurisdictions Negotiated Extent ofPlay:

e N/A Outstanding Issues:

  • 56

After Action Report/Improvement Plan Beaver Valley Power Station ASSESSMENT AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-l, whi.ch 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.J: The OROs issue appropriate dosimehy, 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 Kl to emergency workers. (NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional 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 pennanent 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 ofTEDE and maximum exposure limits, for those emergency woi*kers.

involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure liinits 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 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 exerci.se play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview 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.

57

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 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 meinbers 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.

ORbs 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 Kl for those advised to take it. Emergency workers must demonstrate basic knowledge of procedures for using Kl whether or not the scenario drives the implementation of Kl 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.

State Negotiated Extent of Play:

e NIA Risk and Support Jurisdictions Negotiated Extent ofPlay:

  • Emergency Workers who are assigned dosimetry will demonstrate the procedures to monitor and record dosimetry readings. The workers may be interviewed by the evaluator to determine their knowledge of radiological exposure control, radiation exposure limits, turnback values and whom to contact in the event authorization is. needed to exceed their limits.

e OR Os should demonstrate the actions de.scribed in the plan and/or procedures by determining whether to replace the worker, to authorize the worker to incur additional exposures or to take other actions. If scenario events do not require emergency workers to seek authorizations for additional exposure, evaluators 58

  • Unclassified _

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beav,er Valley Power Station should interview at least two emergency workers, to determine their knowledge of whom to contact in the event authorization is needed.

o Emergency workers may use any available resources (e.g., written procedures and/or co-workers) in providing responses.

o Dosimetry "Training Kits with simulated TLD's" will be available at the field locations to demonstrate the use of dosimetry. Area monitoring kits may be utilized.

o The supply of DRDs, TLD's and KL will be available in the Hancock County EOC and reviewed during the out-of-seq~ence evaluation.

o If the scenario does not involve a release, this can be done by interview.

" Demonstrate through interview with County Director (or designee) how Kl would be distributed to EPZ Emergency Worker

  • Outstanding Issues:

None

  • 59

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 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 KI.

Criterion 3.b.1: Kl and appropriate i!'structions are available if a decision to recommend use of Kl is made. Appropriate record-keeping of the administration of Kl for institutionalized individuals and the general public is maintained. (NUREG-0654/FEMA-REP-1, J.10.e,j)

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

OROs must demonstrate the capability to make KI available to institutionalized individuals, and, where provided for in their plans/procedures, to members of the general public. OROs must .

demonstrate the capabil~ty 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 KI. 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.

  • . 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.

  • State Negotiated Extent of Play:

o The State should demonstrate the capability to formulate and disseminate appropriate instructions on the use of Kl for _those advised to take it.

o A decision not to take Kl is an acceptable decision.

Risk and Support Jurisdictions Negotiated Extent of Play:

60

After Action Report/Improvement Plan Beaver Valley Power Station o Kl and appropriate instructions are available if a recommendation to administer the use of Kl is made. Appropriate record-keeping of the administration of Kl for institutionalized individuals is maintained .

., In West Virginia, Kl is pre-distributed to the General Public.

Outstanding Issues:

None

  • 61

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 3.c - Implementation of Precautionary and/or Protective Actions for Persons with Disabilities and Access/Fu.nctional Needs Intent This Sub-.element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to implement PADs, 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.J: Precautionary and/or Protective action decisions are implemented for persons with disabilities and accesslfunctional 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 full-scale or functional 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, nursing homes, c01Tectional facilities, and mobility-impaired and transportation-dependent individuals. OROs mus*t demonstrate the capability to provide for persons with disabilities and access/functional needs in accordance with plans/procedures.

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 actual, as negotiated in the extent of play. All actual and simulated contacts 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.

State Negotiated Extent of Plav:

  • N/A Risk and Support Jurisdictions Negotiated Extent of Play:

., Demonstrate the capability to alert and notify access and functional populations (hospitals, nursing homes, correctional facilities, mobility-impaired individuals, transportation dependent, etc.).

e Demonstrate the capability to provide for the needs of access and functional populations in accordance with plans and procedures.

62

Unclassified Ra~iological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station o Contact with access and functional populations and reception facilities will be simulated.

o Telephone calls will not be made Q One transportation provider will be contacted; all other calls will be simulated.

e All simulated contacts should be logged.

Q Backup Route Alerting will not be. conducted or evaluated .

o Notification of access and functional needs people will be simulated by EOC staff.*

o Notificatien of access and functional needs populations will be procedurally explained.

a The list identifying access and functional needs ROpulation will be available to evaluators, but may not leave the EOC. Due to the nature of protected personnel information the list will be a scrubbed list.

Outstanding Issues:

None

  • 63

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Criterion 3.c.2: OROs/School officials implement precautionary and/or protective actions for schools. (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 full-scale, functional; or tabletop exercise, an actual event, or by means of drills conducted at any time.

Public school systems/districts must demonstrate the ability to implement P ADs for students.

The demonstration must be made as follows: Each school system/district within the IO rriile EPZ must demonstrate implementation of protective actions. At least one school per affected system/district must paiiicipate 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 school~

may actually be demonstrated or accomplished through an interview process.

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.

The provisions of this criterion also apply to any private schools, private kindergartens, and licensed daycare centers that participate in REP exercises 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.

State Negotiated Extent of Play:

e N/A Risk and Support Jurisdictions Negotiated Extent of Play:

c Demonstrate the capabiliti to alert and. notify the Hancock County School District of emergency conditions that are expected to or may necessitate protective actions for students.

o Contact with the public-school district will be demonstrated during the out-of-sequence school play.

64

  • Unclassified Radiological Emergency Prepa..r~dness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station e The Hancock County OEM and/or officials of the Ha_ncock County School

, District Vl(ill demonstrate the capability to make prompt decisions on protective actions for students.

o School Officials will demonstrate the decision-making *process for protective actions.

o Oak Glen Middle School will participate Out-of-Sequence on May 2nd, 2018 at 0900-1100 hours.

  • e Transportation of sch.col children, if necessary, will be simulated .
  • a One Bus Driver will be available, at the participating school, for an _interview.

" The bus will not run the route to the Host School, but will explain the procedure.

o The implementation of canceling the school day, dismissing early, or sheltering will 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 the host school will be accomplished through an interview process.

o Communications will be verified by the Bus Driver by interview.

0 Officials of the school will demonstrate the capability to develop and provide timely information to the HCEOC for use in messages to parents, the general public, and the media on the status of protective actions for schools.

Outstanding Issues:

Finding: Level Two Hancock County School District representative was not aware of the roles and

  • responsibiiities for the District.

Re-demonstrate during the 2018 Federal Evaluated Exercise

. 65

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 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, ahd removal of impediments to the flow of evacuation traffic.

Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are

.provided to traffic and access control personnel. (NUREG-0654/FEMA-REP-l, A.3; C.1,4;

  • J.10.g,j)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during afull-scale or functional exercise, an actual event, 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 cmTent 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 control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled. Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the ~ffected 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.

State Negotiated Extent of Play:

t. NIA Risk a,id Support Jurisdictions Negotiated Extent ofPlay:

o During the June 121h, 2018 exercise, HCEOC will demonstrate the capability to select, establish,* and staff appropriate traffic and access control points, consistent with protective actions.

o Staffing of Traffic and Access Contrnl Points will be simulated.

I 66 el

After Action Report/Improvement Plan Beaver Valley Power Station I

c The capability to provide instructions to traffic and access control staff will be demonstrated through an interview with the Law Enforcement Officer in the HCEOC during the exercise.

" The HCEOC will demonstrate the ability to control access to rail, water and air traffic, under its control by interview.

ei Traffic Con~rol / Access Control Points will be demonstrated Out of Sequence by interview at the Chester City Building on April 301h , 2018 .

  • Outstanding Issues:

None

  • 67

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654/FEMA-REP-1, J.10.k)

Assessment/Extent of Play .

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, an actual eve~t, 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 Jong enough that re-routing of traffic is required and must also result in demonstration of decision-making and coordination with the nc to communicate the alternate route to evacuees. When, due to specifics of the scenario or jurisdiction, the impediment cannot be located on an evacuation ro1,1te, it must be located so as to impact the evacuation. When not possible, actual dispatch of resources need not be physically demonstrated; however, all contacts, actual or simulated, must be logged."

State Negotiated Extent of Play:

" NIA Risk and Support Jurisdictions Negotiated Extent ofPlay:

& The HCEOC will demonstrate the capability by interview, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation.

o Actual dispatch of resources to deal with impediments will be simulated, and logged. *

. Outstanding Issues:

None 68

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 3:e-Implementation of Ingestion Pathway Decisions Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective actions, based on criteria recommended by cui;-rent FDA guidance, for the ingestion exposure pathway EPZ (i.e., the area within an approximate 50-mile radius of the NPP). This Sub-element focuses on those actions required for implementation of protective actions.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water,food supplies, milk, and agricultural production within the

  • ingestion exposure pathway emergency planning zone for implementation ofprotective actions. NUREG-0654/FEMA-REP-l, A.3; C.1, 4; J.11)

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

Applicable OROs must demonstrate the capability to secure and use current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants, and water supply intake points to implement protective actions within the EPZ. OROs use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex, and other resources (e.g., compacts, nuclear insurers), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

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

State Negotiated Extent of Play:

@ Not Demonstrated

  • Risk and Support Jurisdictions Negotiated Extent ofPlay:

e Not Demonstrated Outstanding Issues:

N/A

  • 69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Criterion 3.e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk, and agricultural production. (NUREG-0654/FEMA-REP-1, G.1, J.9, 11)

Assessment/Extent of Play * .

Assessment of this Demonstration Criterion may be accomplished during a full-scale or

  • functional exercise, an actual event, or by ineans of drills conducted at any time.

OROs must demonstrate the development of measures and strategies for implementation of ingestion exposure pathway EPZ protective actions by formulating protective action information for the general public and food producers*and processors. Demonstration of this criterion includes either pre-distributed public information material in the ingestion exposure pathway EPZ or the capability for rapid reproduction and distribution of appropriate reproduction-ready information and instructions to pre-determined individuals and businesses.

  • OROs must also demonstrate the capability to control, restrict, or prevent distribution of contaminated food by commercial sectors. Exercise play must indlude demonstration of communications and coordination among organizations to implement protective actions. Field play of implementation activities may be simulated. For example, communications and.

coordination with agencies responsible for enforcing food controls within the ingestion exposure pathway EPZ must be demonstrated, but actual communications with food producers and processors may be simulated.

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.

State Negotiated Extent of Play:

" Not Demonstrated Risk and Support Jurisdictions Negotiated Extent ofPlay:

o Not Demonstrated

  • Outstanding Issues:

N/A 70

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 3.f-Implementation of Post-Plume Phase Relocation, Reentry, and Return*

Decisions Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement plans, procedures, and decisions for post-plume phase relocation, reentry, and return. Implementation of these decisions is essential for protecting the public from direct long-term exposure to deposited radioactive materials from a severe. incident at a commercial NPP.

Criterion 3.f.1: Decisions regarding controlled reentry, relocation, and return of individuals

  • during the post-plume phase are coordinated with appropriate organizations and implemented. (NUREG-0654/FEMA-REP-1, E. 7; J.10.j; J.12; KS.b; M.1,,3)

Assessment/Extent of Play Assessm.ent of this Demonstration 0:iterion may be accomplished during a full-scale, functional, or tabletop exercise, an actual event, or by means of drills conducted at any time.

Relocation: OROs must demonstrate the capability to coordinate and* implement decisions concerning relocation of individuals located in radiologically contaminated areas who were not previously evacuated. Such individuals must be relocated to an area(s) where radiological contamination will not expose the general public to doses that exceed the relocation PA Gs.

OROs must also demonstrate the capability to provide for short- or long-term relocation of evacuees who lived in an area(s) that has residual radiation levels above the (first-, second-, and 50-year) PAGs.

Areas of consideration must include the capability of OR.Os to communicate with other OROs regarding timing of actions; notification of the population of procedures for relocation, and notification of, and advice for, evacuated' individuals who will be converted to relocation status in situations where they will not be able to return to their homes due to high levels of contamination. OROs must also demonstrate the capability to communicate instructions to the public regarding relocation decisions and intermediate-term housing for relocated persons .

  • Reentry: OROs must demonstrate the capability to control reentry and exit of individuals who
  • are authorized by the ORO to temporarily reenter the restricted area during the post-plume (i.e.,

intermediate or late) phase to protect them from unnecessary radiation exposure. OROs must also demonstrate the capability to control exit of vehicles and other equipment to control the spread of contamination outside the restricted area(s). Individuals without specific radiological response missions, such as farmers for animal care, essential utility service personnel, or other members of the public who must reenter an evacuated area during th~ post-emergency phase must be limited to the lowest radiological exposure commensurate with completing their missions. Monitoring and decontamination facilities will be established as appropriate.

Examples of control procedures are: (1) assignment of, or checking for, direct-reading and permanent record dosimetry for emergency workers; (2) questions regarding the individuals' objective(s), location(s) expected to be visited, and associated timeframes; (3) maps and plots of radiation exposure rates; (4) advice on areas to avoid; (5) procedures for exit, including

  • 71

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station monitoring of individuals, vehicles, and equipment; (6) decision criteria regarding contamination; (7) proper disposition of emergency worker dosimetry, and (8) maintenance of emergency worker radiation exposure records.

Return: OROs must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. OROs must demonstrate the capability to identify and prioritize services and facilities that require restoration within a few days, and to identify procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads, and schools.

Communication among OROs for relocation, reentry, arid return may be simulated. All simulated or actual contacts must be documented. These discussions may be accomplished in a group setting. *

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

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

State Negotiated Extent of Play:

@ Not Demonstrated Risk and Support Jurisdictions Negotiated Extent of Play:

., .Not Demonstrated Outstanding Issues:

e N/A

  • 72

After Action Report/Improvement Plan Beaver Valley Power Station ASSESSMENT AREA 4: FIELD MEASUREMENTS AND ANALYSIS Sub-element 4.a - Plume Phase Field Measut:ements and Analyses Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, 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-1 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 unce1iainties. 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.J; H.12; L 7, 8, 11; J.10.a)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise. Other means may include drills, seminars or training activities 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 need.ed 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. lfthe licensee FMTs do not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all FMTs (licensee, Federal, and ORO) is essential.

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

  • 73

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Rep01i/lmprovement Plan Beaver Valley Power Station 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.

State Negotiated Extent of Play:

  • Field teams should be equipped with instrumentation and supplies necessary to accomplish their mission as identified in the p!an and/or procedures. *
  • Two Field Teams will be utilized.

o Field Team Equipment will be demonstrated at the first sample location.

o Equipment use will be simulated at all other locations.

-= In-route readings will be taken. Field data will be provided to the field team through controller injects.

" The Field Team will be demonstrated Out-of-Sequence at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on June 12th, 2018. .

e' Responsible Offsite Response Organizations (ORO) will demonstrate the capability to brief teams on predicted plume location and direction, travel speed, and exposure control procedures before deployment.

o A controller will provide Field team readings.

Risk and Support Jurisdictions !Vegotiated Extent of Play:

o N/A Outstanding Issues:

  • None 74

After Action Report/Improvement Plan Beaver Valley Power Station 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.l; H.12: 18, 9; J.10.a)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise. Other means may include drills, seminars or training activities 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. F.MTs 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. <::oordination concerning transfer of samples, including a chain-of-custody form(s), to a radiological laboratory(ies) must be demonstrated. 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.

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Anhex and other resources (e.g., compacts or the licensee). 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.

State Negotiated Extent of Play:

  • e Field teams should demonstrate the capability to report measurements and field data pertaining to the measurement of airborne radioiodine and particulates and ambient radiation to the field team coordinator.

II) Field data should be shared with Ohio and Pennsylvania in a timely manner -

simulated.

.. The request for Federal resources will be simulated by the WVEOC.

o A controller will provide Field Team readings.

Risk and Support Jurisdictions Negotiated Extent of Play:

  • 75

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station e N/A Outstanding Issues:

e None 76

After Action Report/Improvement Plan Beaver Valley Power Station*

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; LS; J.11)

Assessment/Extent of Play

  • Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise. Other means may include drills, seminars or training activities that v,1ould 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 must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers). 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.

State Negotiated Extent of Play:

o Not Demonstrated Risk and Support Jurisdictions Negotiated Extent of Play:

" Not Demonstrated Outstanding Issues:

  • 77

After Action Report/Improvement Plan Beaver Valley Power Station Sub-element 4;c - Laboratory Operations Intent This. Sub-element is derived from NUREG-0654/FEMA-REP-l, 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 ofperforming 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 full-scale, functional, or tabletop exercise. 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 of samples, preserving 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., transuranics or as a result of a terrorist incident) or if warranted by incident circumstances. Analysis may require resources beyond those of the ORO ..

The laboratory staff must be qualified in radio-analytical techniques and contamination control procedures.

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers). Evaluat~on 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.

State Negotiated Extent of Play:

o Not Demonstrated Risk and Support Jurisdictions Negotiated Extent of Play:

0 Not Demonstrated Outstanding Issues:

  • 79

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station

  • N/A 80

After Action Report/Improvement Plan Beaver Valley Power Station ASSESSMENT AREA 5: El\1ERGENCY NOTIFICATION AND PUBLIC INFORMATION Sub-element 5.a -Activation of the Prompt Alert and Notification System Ip.tent This Sub-element is derived from NUREG-0654/FEMA-REP-l, 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 derived from the Guide for the Evaluation ofAlert and Notification Systems for Nuclear Power Plants, FEMA-REP-10, (November 1985) .

  • 5.a.l ... covering essentially 100% of 10 mile EPZ X

5.a.3 ... covering the.10-mile EPZ X Backu Alert and Notification for All Incidents X

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 fufl.:.scale or functional 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 plume EPZ. Following the decision to activate the alert and notification

  • system, OROs must complete system activation for primary ale1i/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.JI 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 of transmission. 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 of EAS broadcast stations may also be accomplished through SAVs.

    • 81

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 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.

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

D Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message; D Identification of the commercial NPP and a statement that an emergency exists there; D 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 D 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 ale1i 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 accomplishthe primary route alerting in a timely manner (not subject to specific time requirements). At least one route needs to be demonstrated and evaluated. The selectedroute(s) must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, 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.

State Negotiated Extent of Play:

e NIA

  • Risk and Support Jurisdictions Negotiated Extent /

ofPlay:

" The County will 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 plum~ pathway EPZ. Following the decision to activate the alert and notification system, in accordance with the County plan and/or procedures, i;;ompletion of system activation should be accomplished in a timely manner (will not be subject to specific time requirements) for primary alerting/notification. The .initial message should include the elements required by current FEMA REP guidance.

o* Siren activation will be explained. Sirens will not be sounded.

82

After Action Report/Improvement Plan Beaver Valley Power Station

  • Procedures to broadcast the message should be fully demonstrated as they would
  • in ar:i actual emergency up to the point of transmission. Broadcast of the message(s) or test messages will not be demonstrated. The alert signal activation will be simulated. The procedures wiU be demonstrated up to the point of actual activation.

o In Hancock County, the EAS Station will be activated according to plans and procedures.

o The capability of *the primary notification system to broadcast an instructional

  • message on a 24-hour .basis should be verified
  • during an interview with the HCOEM Director or designee.

Outstanding Issues:

o None

  • 83

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power 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 3.8.2.c)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational t~sting 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 differfrom 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 consider.ed in judging the acceptability of backup means of alert and notification. Although circumstances JTJay 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 of45 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.

If backup route alerting is demonstrated, only one route needs t.o be selected and demonstrated. All alert,and notification activities along the route(s) must be simulated (that is, the message that would actually be used )s 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 cc;inducted 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.

State Negotiated Extent of Play:

e N/A Risk and Support Jurisdictions Negotiated Extent ofPlay:

84

After Action Report/Improvement Plan Beaver Valley Power Station e Backup Route Alerting will not be demonstrated or evaluated, e Backup alerting will be demonstrated but not evaluated by the use of an electronic* mass notification system to send an alert message to a predetermined list of FEMA evaluators and a test i:nessage to the IPAWS test lab.

Outstanding Issues:

  • "' None 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 3.8.2.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, mu~t 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 minutes 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 ar~a 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 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broad casted) as negotiated in the extent of play. Actual testing of the mobile public address system will be co_nducted 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 8 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.

  • 85

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station State Negotiated Extent of Play:

& No FEMA Approved Exception Areas.

Risk and Support Jurisdictions Negotiated Extent of Play:

e No FEMA Approved Exception Areas.

Outstanding Issues: N/A *

  • 86

After Action Repor.t/lmprovement Plan Beaver Valley Power 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-1, 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.l: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner. (N_UREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c)

Assessment/Exten.t of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, or drills; I

The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a. l 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.

Message elements: The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials. The emergency information must contain aU 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 P ADs 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.l and previously identified protective action areas that are still valid, as well as new areas. The OROs mustdemonstrate 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 il).formation is repeated at pre-established intervals in accordance with the plans/procedures.

OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures.

  • 87

Unclassified Radiological Emergency Preparedness Program (REP)

Afte~ Action Report/Improvement Plan Beaver Valley Power Station If ingestion pathway measures are exercised, OROs must demonstrate that a system exists for rapid dissemination of ingestion pathway information to pre-determined individuals and businesses in accordance with the ORO's plans/procedures.

88

, After Action Report/Improvement Plan Beaver Valley*Power Station 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 infonnation (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 infonnation when trends are noted, must be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.

RAB considerations: The dissemination of information dealing with specific aspects ofNPP 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 an:d completed as they would be in an actual emergency, unless noted above or.otherwise specified in the Extent-of-Play Agreement.

State Negotiated Extent of Play:

e The State will ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials.

The State should be prepared to disclose an.ct explain the Emergency Classification Level (ECL) of the incident.

(/) Public inquiries will be demonstrated at the EOC ..

  • e o

Trends in rumors will be identified, if applicable.

Subsequent emergency information and instructions from the VW State EOC and/or Hancock County EOC will be provided to the public and the media through the Joint Public Information Center.

11i One News Briefing will be conducted at the EOC. It can happen any time after the Alert Declaration. Media will be simulated.

Risk and Support Jurisdictions Negotiated Extent of Play:

The County will ensure that emergency information and instructions are

.consistent with protective action decisions made by appropriate officials.

  • 89

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station The County should be prepared to disclose and explain the Emergency Classification Level (ECL) of the incident.

e Public inquiries will be demonstrated at the EOC.

e Trends in rumors will be identified, if applicable.

e Subsequent emergency information and instructions will be provided to the public and the media through the Joint Public Information Center.

  • News briefs are conducted for the county by the State of WV at the BVPS JPIC.
  • Outstanding Issues:

Finding: Level Two The Public Infonnation Officers (PIOs) in the State Emergency Operations Center (SEOC) provided neither accurate nor timely information to the media for the citizens of West Virginia. Accurate information was provided to the public from the Hancock County EOC.

The finding was successfully re-demonstrated on November 10th, 2016 90

After Action Report/Improvement Plan Beaver Valley Power Station ASSESSMENT 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.J: 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; CA; J.10.h; J.12)

  • Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, drills, or SA V 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 incl,ude adequate space for evacu~es' 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 responsible 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 moni.tor the 20 percent EPZ population planning base. The monitoring productivity rate per hour is the number of evacuees that can be monitored, per hour, by the total complement of monitors using an appropriate 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 the plan and/or procedures. Audio recorders, camcorqers, or written records are all acceptable meai1s for registration.

Monitoring activities shall 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 pla.ns/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

  • 91

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station Decontamination of evacuees may be simulated and conducted by interview. Provisions for separate showering and same-sex monitoring must be demonstrated or explained. The staff must demonstrate provisions for limiting the spread of contamination. Ptovisions 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 a_nd 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 asecure 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.

State Negotiated Extent of Play:

e N/A *

. Risk and Support Jurisdictions Negotiated Extent of Play:

& Reception Center, Monitoring/Decontamination Center will be conducted from 1800 to 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br />, May 2nd, 2018, at the Weir High School Complex.

o Mass Care Center will be conducted from 1800 to 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br />, May 2nd, 2018, at the Weir High School Complex.

o Setup of facilities may be done prior to the exercise.

o Decontamination of evacuees/emergency workers may be simulated.

and conducted by interview.

92

  • Unclassified

. Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station (l> The availability of prov1s1ons for separately showering should be demonstrated or explained.

o The staff should demonstrate provisions for limiting the spread of contamination.

" Provisions should also exist to separate contaminated and uncontaminated individuals, provide changes* of clothing (simulated) for individuals whose clothing is contaminated, and store contaminated clothing and personal belongings to prevent fu'rther contamination of evacuees or facilities,

  • o Any individual found to be coritaminated, procedures should be discussed concerning the handling of potential contamination of vehicles and personal belongings.

0 Mnnitoring personnel should explain the use of action levels for determining the need for decontamination.

o Monitoring personnel should also explain the procedures for referring evacuees who cannot be adequately decontaminated for assessment and follow up.

0 Contamination of the individual will be determined by controller inject and not simulated with any low-level radiation source.

o The capability to register individuals will be demonstr!3ted.

o One monitoring station will be established.

One decontamination area will be established .

o 0 A total of six (6) people will be monitored at the Mass Care Center. At least one (1) will be contaminated.

o Decontamination of personnel / equipment will be explained at all locations.

Actual decontamination will be simulated.

o The Emergency Worker Decontamination Center will be conducted from 1800 to 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br />, April 301h, 2018 at the New Cumberla.nd FD.

Specific Extent-of-Play elements will be addressed in Evaluation Area 6 Sub-Area 6.B Outstanding Issues:

  • 93

After Action Report/Improvement Plan Beaver Valley Power Station Sub-el.ement 6.b -Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles 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 emergency workers and their equipment, inclusive of vehicles.

Criterion 6.b.l: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipinent 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 full-scale or functional exercise, drills, or SAV The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in 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 decontaminatiot1 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 necessaiy 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 monitoring must be demonstrated or explained.

The staff must demonstrate provisions for limiting the spread of contamination. Provisions coµld 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; pi*ovide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belong_ings to prevent further contamination of emergency workers or facilities.

Monitoring activities shall 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

  • 95

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 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.

State Negotiated Extent of Play:

e N/A Risk and Support Jurisdictions Negotiated Extent of Play:

c The Emergency Worker Decontamination Center will be conducted from 1800 to 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br />, April 301h, 2018 at the New.Cumberland Fire Department.

e Setup of facilities may be done prior to the exercise.

o Two Emergency Workers will be monitored for contamination. Discussions on the need for* decontamination will be made based on Controller injected radiation levels.

11 Contamination control and record-keeping procedures will be demonstrated.

c Decontamination efforts will be . procedurally explained, but actual decontamination will be simulated.

c The sequence for monitoring/decontamination efforts and the decision to refer individuals who cannot be decontaminated to medical facilities will be demonstrated via inquiries.

One vehicle will be monitored and decisions regarding the need for decontamination will be made as radiation levels are presented via Controller injects. *

'" Record-keeping procedures will be demonstrated.

m No vehicles will be washed, but decontamination procedures will be explained.

g Decontamination of personnel/equipment will be explained at all locations. Actual decontamination will be simulated.

96

After Action Report/Improvement Plan Beaver Valley Power Station Outstanding Issues:

o None

  • 97

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 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 agreement.

Criterion 6.c.1 :-Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. 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)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during ajull-scale or functional exercise, drills, or SAV The evaluator r.nust conduct a walk-through of the center to determine, 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 qll-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 aninials, 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 IJ10nitored, 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 held 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 98

  • Unclassified ,

_,.Radiological Emergency Prepan,dness Program (REP)

After Action Report/Improvement Plan . Beaver Valley Power Station available at the facilities. 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.

State Negotiated Exte"!t of Play:

,., N/A

  • Risk and Support Jurisdictions Negotiated Extent of Play:

e Mass Care Center will be conducted from 1800 to 2100 hour0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br />s-on_ May 2nd, 2018, at the Weir High School Complex. '

e Mass Care staff will demonstrate the capability to ensure that evacuees have been monitored for contamination, have been decontaminated as appropriate, and have been registered before entering the facility. This capability will be determined through an interview process.

g Material will not be physiGally available at the facility (facilities).

However, availability of such items* will be verified by providing the evaluator a list of sources with locations and estimates of quantities.

Outstanding Issues:

(') None

.. V v

  • 99

I Unclassified

After Action Reportilmprovement Plan Beaver Valley Power Station Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals Intent *

  • This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have th_e 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.1 O; KS.a, b; L.1, 4)

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 dem_onstrated 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 trahspo1tation provider, everv 2 years. Additional transpmtation providers will be rotated tluough the drills in 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 m~dical 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 used 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. Monitoring of the victim may be performed before transport or en route, or may be deferred to the medical facility. 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.

Normal communications b~tween 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 100

After Action Report/Improvement Plan Beaver Valley Power Station 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 and cine 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 must demonstrate the capability to activate and set up a radiological emergency area for treatment.

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

Tl;ie medical facility must demonstrate the capability to make decisions on the nee,d for decontamination of the individual, follow appropriate decontamination procedures, *and maintain records of aU 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 emei*gency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

State Negotiated Extent of Play:

e NIA Risk and Support Jurisdictions Negotiated Extent of Play:

  • 0 Demonstrated during ,the Evaluated MS-1 Exercise conducted on March 291h, 2017, at the Weirton Medical Center.

Outstanding Issues:

(!

None

  • 101

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station REP MANUAL DEMONSTRATION CRITERIA FREQUENCY MATRIX (7tio1) 1 l.a.l: OROs use effective procedures to aleli, A.1.a,-e; notify, and mobilize emergency personnel and activate facilities in a timely manner.

A.3,4; C.1, 4, 6; D.4; E.1, 2; H.3, 4 At least biennially YES YES NO

b. Facilities

G,3.a; H.3; No less than l.b.l: Facilities are sufficient to supp01i the J..10.h, J.12; once every 8 YES YES YES emergency response.

  • K.5.b years2 Ci. Direction; and Control

) .c. I: Key personnel with leadership roles for the ORO provide direction and control to that pa.ti of A.1.d; A.2.a, b; At least

,the overall re_sponse effort for which they are NO NO NO A.3; C.4, 6 biennially responsible.

d. Communications Equipment l.d. l: At least two communication systems are available, at least one operat:s properly,.and communication links are established and maintained At least with appropriate locations. Communications F.1, 2 YES 3 NO NO biennially capabilities are managed in suppori of emergency operations.
e. Equipment and Suppli_es to Support Operations I.e.!: Equipment, maps, displays, dosimetry, Kl, H.7, 10; 1.7, 8, and other supplies are sufficient to supp01i 9; J.10.a, b, e; At least emergency operations. YES NO YES J.11, 12; K.3.a; biennially K.5.b 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including use of Kl, is in place for C.6; J.10.e, f; At least NO NO NO emergency workers, including provisions to l<.3.a; K.4 biennially authorize radiation exposure in excess of administrative limits or PAGs.

1 See NUREG-0654/FEMA-REP-1 Criteria N.1.b and N.1.d for additional details 2

Facilities evaluated once when they are new and once every 8 years thereafter. Facilities are re-evaluated for this criterion if, in the interim since the last evaluation, they have substantial changes in structure, equipment, or mission that affect key capabilities, as outlined in emergency plans/procedures.

3 Communications equipment can be demonstrated in an out-of-sequence scenario during medical services and reception/relocation center drills as negotiated in the extent of play:

102

After Action Report/Improvement Plan Beaver Valley Power Station

b. Dos_(Ass_es~ment & PARs & P ADs for the Eme1*gency Event
2. b. l: Appropriate P ARs are based on available information on plant condition, field monitoring data, and licensee and ORO dose projections*, as 1.10; At least NO NO NO well as knowledge of onsite and offsite Supp.3 biennially environmental conditions .
  • 2.b.2: A decision-making process involving consideration of appropriate factors and necessary A.3; C.4, 6;
  • coordination is used to make P ADs for the general At least D.4; J.9; J.10.f, NO NO NO public (including the recommendation for use of KI, biennially m

if ORO policy).

c. PAD~ for th~ Protectlpn ot; Persons* wit!:t Disa~ilities arid Access/Functi_onai l'\IE!E'!~~

2.c. l: PADs are made, as appropriate, for groups of people with disabilities and those with access/ D.4; J.9; J.10.d, At least NO NO NO

functional neecjs. e biennially 4

d... -R3cdj61~gicai Assess~~nt

~. '*

and De'cision~Ili~king

. - .. . " :. -- -- - - for the Ingestion- Exposure

J";t~w~;;.

~

2.d. l: Radiological consequences for the ingestion Every pathway are assessed and approp_riate PADs are A.3; C.1, 4; ingestion NO NO NO made based on the ORO planning criteria. D.4; J.9, 11 exercise

e. Ra:cij9Iogical ~sse~s,nent & Decis'io~-lll~I~~~ Concerning P_ost-Plume Phase Re_ioc~tion, _Re~entry, an_d Return', _**.

2.e.l: Timely post-plume phase relocation, re-entry, and return decisions are made and coordinated as No less than appropriate, based on assessments of radiological 1.10; J.9; K.3.a; once every NO NO NO conditions and criteria in the ORO's plan and/or M.1 8 y_ears procedures.

  • a. lm\:il¢mentation of Emergency Worker Exposure Contrnl .

3.a.l: The OROs issue appropriate dosimetry, Kl, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures. Emergency "'!orkers periodically and at the end of each mission read their J.10.e; K.3.a, b; At least YES NO NO dqsimeters and record the readings on the K.4 biennially appropriate exposure record or chart. Appropriate record-keeping of the administration of Kl for emergency workers is maintained.

4 The post-plume phase (ingestion, relocation, re-entry, and return) may be demonstrated separately from the plume phase.

  • 103

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley :Power Station

'brJ~nt?ni~'rt,i#ii!'ifAr$p~~11tfo~:fyttl!\~tii'@#iitii}~'in'i11fiil~~fs, *~nft1itr~b,ijt?\.
3. b. l: KI and appropriate instructions are made available in case a decision to recommend use of KI is made.

At least Appropriate record keeping of the administration of KI for J.10.e, f .YES NO NO biennially' institutionalized individuals and the general public is maintained.

.! . ~ "

c. lmplementati~n of P~otectiv; Actions for Persohs'~ith Disabili.ties and Access/Functional Needs < ; ' '"

3.c. l: PADs are implemented for people with disabilities and those with access/functional needs other than schools within areas subject to protective actions.

  • 3.c.2: OROs/school officials implement protective actions J.10.c, d, e, g No less than once every 8 .

years No less than YES YES YES for schools. J.10.c, d. e. g once every 8 YES YES YES

. years*

d. Implementation of Traffic and Access Control7 3.d. l: Appropriate traffic and access control is established.

A.3; C.1, 4; At least Accurate instructions are provided to traffic and access YES YES YES J.10.g,j biennially control ersonnel.

3.d.2: Impediments to evacuation are identified and At least J.10.k YES YES YES resolved. biennially

e. fmplementation of Ingestion Pathway Decisions 3.e. l: The ORO demonstrates the availability and appropriate use of adequate information regarding water, Every food supplies, milk, and agricultural production within the A.3; C.1, 4; J.11 ingestion YES NO NO ingestion exposure pathway emergency planning zone for implementation of protective actions . exercise

.3.e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing

  • Every PADs for contaminated water, food products, milk, and G.1, J.9, 11 ingestion YES NO NO agric~ltural production.

exercise

f. lmplerilentation°of Post-Plume Phase Relocation;' Re-entry, and Return Decisions 3.f.1: Decisions regarding controlled re-entry, relocation, and return of individuals during the post-plume phase are E.7; J.10.j; J.12; No less than coordinated with appropriate organizations and once every 8 YES NO NO l<.5.b; M.1, 3 implemented. years 5

Demonstrated in every biennial exercise. Participation may be rotated among facilities, but each individual distribution facility must be evaluated no less than once every 8 years.

6 Participation may be rotated among school districts, but each school system/district in the EPZ and at least one of its schools must be evaluated no less than once every 8 years. It is not required that every school within the school system/district be evaluated.

7 Physical deployment of resources is not necessary except in a full-scale exercise 104

After Action Report/Improvement Plan Beaver Valley Power Station

. f firiih*;* PWs~-~{;id jl/i£ht1~~#tJiiiji~1fsef*

4.a.l: (RESERVED) 4.a.2: *Field tea.ms (two or more) a.re managed to obtain Every full sufficient information to help characterize the reiease and C.1; H.12; 1.7, 8, participation YES NO. NO to control radiation exposure. 11; J.10.a

. exercise*

4.a..3: Ambient radiation measurements a.re made and

  • recorded at appropriate locations, and radioiodine and particulate samples a.re collected. Tea.ms will move to an appropriate low-background location to determine whether any significant (as specified in the plan and/or procedures) amount ofradioactivity has been collected C.1; 1.8, 9; H.12; J.10.a Every full participation exercise YES NO NO on the sampling niedia..

.'~:\f~jtr11Mtt~;i}~~1~i(M~~iiirf~eijtii~d'~illlpii~i**.*

4.b. l: The field tea.ms (two or more) demonstrate the capability to make appropriate measurements and collect C.1; samples (e.g., food crops, milk, water, vegetation, and Every ingestion 1.8; YES NO NO soil) to support adequate assessments and protective exercise action decision-making, J.11 J/t~~ifif'11~!'0~'.~t~tiiit~+~;1tr?:;(,

4.c.l: The laboratory is capable of performing required radiological analyses to support PADs.

'~/.~}ii}~!\~~Ji'.!~~:i>f§f'~,foJ~Jt~:~~'#qf1t(~;ft~1:~~~(~tr,-::\:,..

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 At least E.S, 6, 7 YES NO NO emergency situation. The initial instructional message biennially to the public must include as a minimum the elements required by current REP guidance.

5.a.2: (RESERVFD)

  • 5.a._3: Backup a_lert and notification of the public is completed within a reasonable time following detection by the ORO of a failure of E.6; Appendix No less than once every YES NO NO 3.B.2.c the primary alert and notification system. 8 years 8

Each state within the 10-mile EPZ of a commercial nuclear power site shall fully participate in an exercise jointly with the licensee and appropriate OROs at least every 2 *years (44 CFR Part 350.9 (c)(1)), Each state with multiple sites within its boundaries shall fully participate in a joint exercise at some site on a rotationai basis at least every 2 years {44 CFR Part 350.9 (c)(2)). When not fully participating in an exercise at a site, the state shall partially participate at the site to support full participatron of the OROs. See NUREG-0654/FEMA-REP-1 Criterion N.i.b for clarification of full participation.

  • 105

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 5.a.4: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes of the initial decision by E.6; Appendix At least YES NO NO authorized offsite emergency officials to notify the 3.8.2.c biennially public of an emergency situation.

b. Em~t*g~~~y iiiio~matlon a.;_d instr~ctio.;_s fo; the Public and the Media' 5.b.1: OROs provide accurate emergency information and instmctions to the public and news media in a timely°manner.
  • E.5, 7; G:3.a; G.4.a, c At least biennially YES NO NO
  • 6.a.1: The reception center facility has appropriate space, adequate resources, and trained personnel to No less than A.3; C.4; provide monitoring, decontamination, and once every 8 YES YES NO J.10.h; J.12 registration of evacuees. years 9
b. Monitoring and D~contaminat.ion of Emergency Workers and* their .Equipn1erit ariciVehic:les 6.b.1: The facility/ORO has adequate procedures and resources to accomplish monitoring and
  • No less than decontamination of emergency workers and their . l<.5.a, b once every 8 YES YES NO equipment and.vehicles. years
c. Temporary Care of Ei.c1_~1J_E!_es 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consist~nt with-planning guidelines. Managers demonstrate No less than the procedures to assure that evacuees have been J.10.h; J.12 once every 8 YES YES YES monitored for contamination and have been years 10 decontaminated as appropriate before entering congregate ca re facilities.
d. Transportation and Treatment of Contaminated Injured Individuals 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to F.2; H.10;_

provide transport, monitoring, decontamination, At least l<.5.a, b; YES *YES NO and medical services tci contaminated injured . biennially L.1, 4 individuals.

9 Participating may be rotated among facilities, but each facility must be evaluated no less than once every 8 years.

1

°Facilities managed by the American Red Cross under the American Red Cross/FEMA MOU will be evaluated once when designated or when substantial changes occur; all other facilities not managed by the American R~d Cross must be evaluated no less th.an once every 8 years.

. 106

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