ML110420145

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Final Report for September 28, 2010, Radiological Emergency Preparedness Partial Participation Plume Exposure Pathway Exercise
ML110420145
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 02/04/2011
From: Velasquez A
US Dept of Homeland Security, Federal Emergency Management Agency
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML110420145 (126)


Text

A U.S. Department of Homeland Security Region V 536 South Clark Street, Floor 6 Chicago, IL 60605 WFEMA F.EB 0 4 i NRC Headquarters Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 To Whom It May Concern:

Enclosed is one copy of the Final Report for the September 28, 2010, Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise for the Perry Nuclear Power Plant. The State of Ohio, Lake, Geauga and Ashtabula Counties, and the utility owner/operator, FirstEnergy Nuclear Corporation, participated in this exercise.

No Deficiencies were identified for any jurisdiction during this exercise. There were no Areas Requiring Corrective Action (ARCAs) identified for the State of Ohio during this exercise.

There was one prior ARCA for the State of Ohio under Criterion 2.b. 1 - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency that was resolved during this exercise.

There was one ARCA for Geauga County, identified under 3.a. 1 - Implementation of Emergency Worker Exposure Control, whereby the Transportation Supervisor did not mention the administrative reporting limit of I R, nor the procedure for zeroing the dosimeters and completing the Emergency Worker Dosimetry Exposure Log. This ARCA was successfully re-.

demonstrated during the exercise.

There were two ARCAs identified for Lake County. The first ARCA for Lake County identified under 3.b. I - Implementation of KI, whereby the police officer was unaware that individuals who were allergic to iodine or shellfish should not ingest KI and that those individuals with allergies to KI would not have been allowed to enter the Emergency Planning Zone. This ARCA was successfully re-demonstrated during the exercise.

The second ARCA for Lake County identified under 3.a.1 - Implementation of Emergency Worker Exposure Control, whereby TriPoint Medical Center was the primary MS-I medical facility for the PNPP. The Radiation Technician had significant trouble when attempting to zero the DRDs. The controller provided on-the-spot training, after which the Technician began using www.fema.gov

To whom it may concern Page # 2 the charger in the correct orientation. This ARCA was successfully re-demonstrated during the exercise.

There was one Planning Issue identified for the State of Ohio, two Planning Issues identified for Lake County and one Planning Issue identified Ashtabula County during this exercise.

The Planning Issue Identified for the State of Ohio was issued under 2.b. 1 - Appropriate Protective Action Recommendations are based on available data, whereby the Dose Assessment staff in the Lake County Assessment Room and the Field Monitoring Team Coordinators for the State and Lake County coordinated functions and timely sharing of information. However, the State procedures and standard (suggested) operating guidelines used by these individuals do not address these coordination methods used during the exercise.

The first Planning Issue identified for Lake County was issued under 3.a.1 - Implementation of Emergency Worker Exposure Control, whereby in accordance with the SOP checklist for the Radiation Technician, that person was responsible for zeroing direct-reading dosimeters and placing them on a hook in the treatment room. The SOP checklist provides for the Buffer Zone Nurse to distribute permanent record dosimeters (PRD). In the course of distributing the PRDs, a control PRD was not identified nor removed to another location. There is nothing written in the procedures or position checklists to ensure that a control PRD is identified and removed from the treatment suite to ensure a correct baseline reading is available when the hospital's mission is complete.

The second Planning Issue identified for Lake County was issued under 4.a.2 - Field Teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure, whereby the Lake County Field Monitoring Team Controller did not include a discussion of KI in the field team pre-deployment briefing. The Lake County Standard Operational Guidance for the Radiological Field Team Controller includes an Emergency Response Health and Safety Plan that forms the basis for the health and safety briefing given to the Field Teams prior to their departure. The information includes dosimetry requirements but does not mention the requirement for Field Monitoring Team Members to have KI or instructions for using KI.

The Planning Issue identified for Ashtabula County was issued under 2.a. I - Emergency Worker Exposure Control, whereby the Ashtabula County Radiological Emergency Response Plan does not specifically state who will authorize an individual emergency worker to receive a dose in excess of pre-authorized levels.

A detailed discussion of these issues can be found in Part IV of the Final Report.

Based on the results of the October 7, 2008, exercise, the offsite radiological emergency response plans and preparedness for the State of Ohio and affected local jurisdictions, site-

To whom it may concern Page # 3 specific to the Perry Nuclear Power Plant, can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site.

Therefore, the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and preparedness for the State of Ohio site-specific to the Perry Nuclear Power Plant, granted on June 17, 1994, remain in effect.

Copies of this report have been provided to the DHS/FEMA National Office, Nuclear Regulatory Commission (NRC) Region III, and the State of Ohio.

If you have any questions, please contact William E. King, Chairman, Regional Assistance Committee, DHS/FEMA, Region V, at (312) 408-5575.

Sincerely, Andrew Velasquez Regional Administrator Enclosure (1)

W11*

Perry Nuclear Power Plant After Action Report/

Improvement Plan Exercise Date - September 28, 2010 Radiological Emergency Preparedness (REP) Program

  • I-AFEMA Published February 04, 2011

Unclassified Radiological Erncrgcncy Preparedness Program (REP)

Aftcr Action Rpon/improvcrnem Plan Pcrr. Nuclear Power Plat Perry Nuclear Power Plant After Action Report/Improvement Plan Published Januaiy 24, 2011 Contents Executive Summary 5

Section 1: Exercise Overview I 2 1..1.Exercise Details 12 1.2 Exercise Planning Team Leadership 12 1.3 Participating Organizations 13 Section 2: Exercise Design Summary 16 2.1 Exercise Purpose and Design 16 2.2 Exercise Objectives, Capabilities and Activities 16 2.3 Scenario Summary 16 Section 3: Analysis of Capabilities 17 3.1 Exercise Evaluation and Results 17 3.2 Summary Results of Exercise Evaluation 18 3.3 Criteria Evaluation Summaries 27 3.3.1 Ohio Jurisdictions 27 3.3.1.1 State of Ohio - Initial Notification Point 27 3.3.1.2 State of Ohio - Emergency Operations Center -

27 Executive Room 3.3.1.3 State of Ohio - Emergency Operations Center -

27 Assessment Room 3.3.1.4 State of Ohio - Emergency Operations Center - Joint 29 Information Center 3.3.1.5 State of Ohio - Lakeland Community College - Joint 30 Infonnation Center 3.3.1.6 State of Ohio - Emergency Operations Facility 30 3.3.1.7 State of Ohio - Lake County Emergency Operations 30 Center - State Radiological Analyst 3.3.1.8 State of Ohio - Department of Natural Resources -

30 Route Alerting 1

U nclassified Radiological Emcrgcncy Prcparedness Program (MEP)

After Action Report/lmprovencttt Plan Pcrr' Nuclcar Power Plant 3.3.2 Risk Jurisdictions 31 I

3.3.2.1 Lake County - Initial Notification Point 31 3.3.2.2 Lake County - Emergency Operations Center 31 I

3.3.2.3 Lake County - Field Monitoring Team Coordinator 31 3.3.2.4 Lake County - Lakeland Community College - Joint 33 I

Infor-nation Center 3.3.2.5 Lake County - Field Monitoring Team #1 33 3

3.3.2.6 Lake County - Field Monitoring Team #2 33 3.3.2.7 Lake County - Leroy Fire Department - Backup 33 Route Alerting 3.3.2.8 Lake County - Fairport Harbor School District -

34 Evacuation SchoolI 3.3.2.9 Lake County - Kirtland High School - Kirtland Fire 34 Department - Evacuee Registration 3.3.2.10 Lake County - Kirtland High School - Kirtland Fire 34 Department - Evacuee Monitoring 3.3.2.11 Lake County - Kirtland High School - Kirtland Fire 34 I

Department - Evacuee Decontamination 3.3.2.12 Lake County - Kirtland High School - Kirtland Fire 35 Department - Evacuee Monitoring and Decontamination of Vehicles 3.3.2.13 Lake County - Kirtland High School - Congregate 35 Care Center 3.3.2.14 Lake County - Madison Fire District - Medical 35 Service - TransportationI 3.3.2.15 Lake County - Tri-Point Medical Center - Medical 36 Service - Facility 3.3.2.16 Lake County - Madison Local - Evacuation School 38 3.3.2.17 Lake County - Perry Village Police Department -

38 Traffic Control Point/Access Control Point - Briefing 3.3.2.18 Lake County - Perry Village Police Department -

39 Traffic Control Point/Access Control Point -

I Interview 3.3.2.19 LakeCounty - Grand River Police Department -

39 Traffic Control Point/Access Control Point - Briefing 3.3.2.20 Lake County - Grand River Police Department -

39 Traffic Control Point/Access Control Point -

Interview 3.3.2.21 Ashtabula County - Initial Notification Point 40 2

I

Unclassified Radiological Emergency Prcparcdttess Program (R.EP)

After Action Rcport/improvemcnt Plan Pcrry NucIcar Power Plant 3.3.2.22 Ashtabula County - Emergency Operations Center 41 3.3.2.23 Ashtabula County - Lakeland Community College -

42 Joint Information Center 3.3.2.24 Ashtabula County - Saybrook Fire Department -

42 Emergency Worker Monitoring and Decontamination of Equipment and Vehicles 3.3.2.25 Ashtabula County - Saybrook Fire Department -

43 Emergency Worker Monitoring and Decontamination 3.3.2.26 Ashtabula County - Northwest Ambulance District -

43 Medical Service - Transportation 3.3.2.27 Ashtabula County - Geneva Police Department -

43 Traffic Control Point/Access Control Point - Briefing 3.3.2.28 Ashtabula County - Geneva Police Department -

44 Traffic Control Point/Access Control Point -

Interview 3.3.2.29 Ashtabula County - Harpersfield Volunteer Fire 44 Department - Backup Route Alerting - Briefing 3.3.2.30 Geauga County - Initial Notification Point 44 3.3.2.31 Geauga County - Emergency Operations Center 44 3.3.2.32 Geauga County - Emergency Operations Center -

45 Sheriffs Road Patrol & Dosimetry Coordinator -

Traffic and Access Control Briefing Including DCO Briefing 3.3.2.33 Geauga County - Lakeland Community College -

45 Joint Information Center 3.3.2.34 Geauga County - Thompson Volunteer Fire 45 Department - Route Alerting 3.3.2.35 Geauga County - Ledgemont School District -

46 Evacuation School Section 4: Conclusion 48 Appendix A: Improvement Plan 49 Appendix B: Exercise Timeline 51 Appendix C: Exercise Evaluators and Team Leaders 53 Appendix D: Acronyms and Abbreviations 56 Appendix E: Exercise Plan 59 3

Unclassified Radiological Erncrgcncy Prcparcdncss Program (REP)

After Action Rcporl/hmprovcmcnm Plan I'crrv Nilcicar Power Plant This page is intentionally blank.

I I

4

Unciassifiled Radiological Erncrgcncy Preparecdncss Program (REP)

After Action Rcport/Inmprovernen Plan PcrrY Nuclear Power Plant EXECUTIVE

SUMMARY

On September 28, 2010, a Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise was conducted for the I 0-mile Emergency Planning Zone (EPZ) around the Perry Nuclear Power Plant by the U.S. Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA). The purpose of the exercise was to assess the level of preparedness of State and local jurisdictions in responding to a radiological emergency. This exercise was held in accordance with DHS/FEMA policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERPs) and procedures.

The most recent exercise at this site was conducted on October 7, 2008. The qualifying emergency preparedness exercise was conducted on November 28, 1984.

DHS/FEMA wishes to acknowledge the efforts of the many individuals in the State of Ohio and Lake, Ashtabula and Geauga Counties, who participated in this exercise along with the State government.

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

Cooperation and teamwork on the part of all participants was evident during this exercise.

This Final Report contains the evaluation of the biennial exercise and the evaluation of the following out of sequence activities:

State of Ohio:

Alert and Notification on Lake Erie Lake County:

Medical (MS-1) Services Drill Traffic and Access Control Point Field Monitoring Teams 5

U nelassified Radiological Emcrgcacy Preparcdncss Program (REP)

Aficr Action Rcport]h mprovcrncnt Plan rry c

' Nuclar I'owcr Phint Field Monitoring Teams Coordinator I

Field Monitoring Teams Equipment Inventory (EV-2) School Interview Evacuee Monitoring/Decontamination/Registration Evacuee Vehicle Monitoring and Decontamination 3

Distribution of KI to the General Public Congregate Care Center 3

Back-up Route Alerting Ashtabula County:

I Backup Route Alerting Emergency Worker Monitoring/Decontamination Congregate Care Center Emergency. Worker Vehicle Monitoring/Decontamination Medical (MS-1) Services Drill Traffic and Access Control Point Geauga County:

Back-up Route Alerting (EV-2) School Interview Except where noted in this report, the State and local organizations demonstrated knowledge of and adequately implemented their emergency response plans and procedures.

No Deficiencies were identified for any jurisdiction during this exercise.

There was.one prior ARCA for the State of Ohio under Criterion 2.b. I - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of theI Emergency that was resolved during this exercise.

There was one ARCA for Geauga County, identified under 3.a. I - Implementation of Emergency Worker Exposure Control, whereby the Transportation Supervisor did not mention the 3

administrative reporting limit of I R, nor the procedure for zeroing the dosimeters and 61

Unclassifivii Radiological Emergency Prcparcdncss Prograni (REp' After Action Report/Improvcmcn Plan Pcrry Nuclear Power ]'lan completing the Emergency Worker Dosimetry Exposure Log. This ARCA was successfully re-demonstrated during the exercise.

There were two ARCAs identified for Lake County. The first A RCA identified under 3.b.1 -

Implementation of KI, whereby the police officer was unaware that individuals who were allergic to iodine or shellfish should not ingest KI and that individual's with allergies to KI would not have been allowed to enter the Emergency Planning Zone. This ARCA was successfully re-demonstrated during the exercise.

The second ARCA for Lake County, identified under 3.a.1 - Implementation of Emergency Worker Exposure Control, whereby the Radiation Technician at the TriPoint Medical Center had significant trouble when attempting to zero the DRDs. The controller provided on-the-spot training, after which the Technician began using the charger in the correct orientation. This ARCA was successfully re-dernoistrated during the exercise.

There was one Planning Issue identified for the State of Ohio, two Planning issues identified for Lake County and one Planning Issue identified for Ashtabula County.

The Planning Issue Identified for the State of Ohio was issued under 2.b. I - Appropriate Protective Action Recommendations are based on available data, whereby the Dose Assessment staff in the Lake County Assessment Room and the Field Monitoring Team Coordinators for the State and Lake County coordinated functions and timely sharing of information. However, the State procedures and standard (suggested) operating guidelines used by these individuals do not address these coordination methods used during the exercise.

The first Planning Issue identified for Lake County was issued under 3.a.1 - Implementation of Emergency Worker Exposure Control, whereby in accordance with the SOP checklist for the Radiation Technician, that person was responsible for zeroing direct-reading dosimeters and placing thern on a hook in the treatment room. The SOP checklist provides for the Buffer Zone Nurse to distribute permanent record dosimeters (PRD). In the course of distributing the PRDs, a control PRD was not identified nor removed to another location. There is nothing written in the procedures or position checklists to ensure that a control PRD is identified and removed from the treatment suite to ensure a correct baseline reading is available when the hospital's mission is complete.

7

Unclassilied Radiological Emergency Preparedness Program (REP)

After Action Rcport/lniprovcmcnt Plan Perry Nuclear Power Plant The second Planning Issue identified for Lake County was issued under 4.a.2 - Field Teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure, whereby the Lake County Field Monitoring Team Coordinator did not include a I

discussion of KI in the field team pre-deployment briefing. The Lake County Standard Operational Guidance for the Radiological Field Team Coordinator includes an Emergency 3

Response Health and Safety Plan that forn-s the basis for the health and safety briefing given to the Field Teams prior to their departure. The information includes dosimetry requirements but does not mention the requirement for Field Monitoring Team Members to have KI or instructions for using KI.

3 The Planning Issue identified for Ashtabula County was issued under 2.a.1 - Emergency Worker Exposure Control, whereby the Ashtabula County Radiological Emergency Response Plan does not specifically state who will authorize an individual emergency worker to receive a dose in excess of pre-authorized levels.

INTRODUCTION - EXERCISE BASIS On December 7, 1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. DHS/FEMA activities are conducted pursuant to Title 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element 3

in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

The FEMA Title 44 CFR 350 establishes the policies and procedures for DHS/FEMA's initial and continued approval of State and local governments' radiological emergency planning and 3

preparedness for commercial nuclear power plants. This approval is contingent, in part, on State and local governments' participation in joint exercises with licensees.

DHS/FEMA responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

  • Taking the lead in offsite emergency planning and in the review and evaluation of RERPs and I

procedures developed by State and local governments;

- Deternining whether such plans and procedures can be implemented on the basis of 8

8 I

Ui c lassi fi ed

]Padiological Emcrgency Preparcdncss Program (REP)

Afier Action Repori/lmprovcmcnt Plan Perry Noclear Power Planti observation and evaluation of exercises of the plans and procedures conducted by State and local governments;

- Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 1 7,1993 (Federal Register, Vol. 58, No. 176, September 14, 1993); and

- Coordinating the activities of Federal agencies with responsibilities in the radiological eniergency planning process:

- U.S. Department of Agriculture,

- U.S. Department of Commerce,

- U.S. Department of Energy,

- U.S. Environmental Protection Agency,

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

- U.S. Department of the Interior,

- U.S. Department of Transportation,

- U.S. Food and Drug Administration and

- U.S. Nuclear Regulatory Commission.

Representatives of these agencies serve on the DHS/FEMA Regional Assistance Committee (RAC), which is chaired by DHS/FEMA.

Formal submission of the RERPs for the Perry Nuclear Power Plant to DHS/FEMA Region V by the State of Ohio and involved local jurisdictions occurred on January 23,1 986. Formal approval of these RERPs was granted by FEMA on June 15, 1987, under 44 CFR 350.

A REP Partial Participation Plume Exposure Pathway Exercise was conducted on September 28, 2010, by DHS/FEMA to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the publics health and safety during a radiological emergency involving the Perry Nuclear Power Plant. The purpose of this exercise report is to present the exercise results and findings on the performance of the offsite response organizations (ORO) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluator team, 9

Unclassilied Radiological Emergency Preparedness Program (REP)

Aftcr Action Report/hInprov\\cmcit Plan Pcrry Nuclcar Power Plant with final detenrinations made by the DHS/FEMA RAC Chairman, and approved by I

DHS/FEMA Headquarters.

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

U

- NUREG-0654/FEMA-REP-l, Rev. I, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980;

- FEMA-REP-14, "Radiological Emergency Preparedness Exercise Manual," September 1991; 1

and

  • FEMA "Radiological Emergency Preparedness: Exercise Evaluation Methodology," as published in Federal Register Notice/Vol. 67, No. 80, dated April 25, 2002.

1 Section I of this report, entitled "Exercise Overview", presents information pertaining to the team that planned and-coordinated the exercise. This section also provides a listing of all participating jurisdictions and functional entities that were evaluated.

Section 2 of this report, entitled "Exercise Design Summary", contains the purpose and design of the exercise, a description of the plume pathway EPZ, and presents basic information and data relevant to the exercise scenario.

Section 3 of this report, entitled "Analysis of Capabilities", presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all Deficiencies and ARCAs (if any) assessed during this exercise, recommended corrective actions, I

if applicable, for each identified exercise issue; and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the OROs' efforts to resolve them.

Section 4 of this report, entitled "Conclusion", presents the DHS/FEMA summary of overall exercise conduct and results as evaluated against the requirements of 44 CFR 350.

EMERGENCY PLANNING ZONE (EPZ) DESCRIPTION 5

10

[Jne a ssificd RadilogicaI Emergency Prcparcdncss Program (REP)

After Acion Report/Improvemcnt Plan Perr. Nuelcar Powcr Plant The Perry Nuclear Power Plant (PNPP) reactor is located on the southeast shoreline of Lake Erie in Lake County, Ohio. The site is approximately seven miles northeast of Painesville, Ohio and 35 miles east of Cleveland, Ohio.

The plant site occupies approximnately 1100 acres on a lake plain 50 feet above the lake low-water datum. The terrain surrounding the plant is essentially flat within five miles of the lakeshore. Rising generally to the south, the site is broken only by a lattice work of shallow, north-south stream beds and low, almost unnoticeable east-west ridges; the latter are remnants of ancient lake-shores. About five miles inland, the shoreline plane is abruptly cut by a 1 00-foot-deep ravine of the Grand River. The terrain south of the river is more rolling, interrupted by north-south ravines of tributaries of the Grand, Kellogg, Big, Paine and Mill creeks and several smaller streams. A large portion of the site is forested, some 250 acres are devoted to the plant structural complex and the remainder is open grassland.

Lake County, where the nuclear power plant is located, is the smallest of Ohio's 88 counties, with 232 square miles. The 2000 census approximates the population to be 102,920 residents currently within the 10-mile emergency planning zone (EPZ); 13,591 are residents of Geneva and Harpersfield Townships in Ashtabula County with an estimated 1,930 residents in Geauga County.

FirstEnergy Corporation owns the Pery Nuclear Power Plant.

11

Unclassified Radiological Emergency Prcparcdncss Program (REP)

Aftcr Action Rcport/lmprovcincnt Plan Perry NuIclcar Powcr Plant I

SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details I

Exercise Name Perry Nuclear Power Plant Type of Exercise Pluime Exercise Date September 28, 2010 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership William King Exercise RAC Chair DHS/FEMA Radiological Assistance Committee, Chairman 536 S. Clark Street Chicago, Illinois, 60605 312-408-5575 william.king@dhs.gov Gary Naskrent I

Exercise Director DHS/FEMA 3

Supervisory REP Team Leader 536 S. Clark Street 3

12 I

Unclassiflud Radiological Emergency Prcparcdncss Program (REP)

Aficr Action Report'mprovcmment Plan Pcrry NUcIcar Power Plain Chicago, Illinois, 60605 312-408-5214 gary.naskrent@dhs.gov Dwaine Warren Assistant Exercise Director D-lS/FEMA Supervisory REP Team Leader 536 S. Clark Street Chicago, Illinois, 60605 312-408-5342 dwaine.warren@dhs.gov Bridget Ahlgriin Site Specialist DHS/FEMA Program Specialist 536 S. Clark Street Chicago, Illinois, 60605 312-408-4454 bridget.ahlgrim@dhs.gov 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Perry Nuclear Power Plant exercise:

State Jurisdictions Ohio Army National Guard Ohio Department of Health Ohio Department of Natural Resources - Division of Watercraft Ohio Emergency Management Agency Ohio Environmental Protection Agency Ohio State Highway Patrol 13

Unclassified Radiological Emergency Preparedncss Program (REP)

After Action Report/Improveniett Plan Pcrr' Nuclear Power Plant Ohio State University Extension I

Risk Jurisdictions Ashtabula County Amateur Radio Club Ashtabula County Auditors Department Ashtabula County Commissioners 3

Ashtabula County Courts Ashtabula County Department of Jobs and Family Services 3

Ashtabula County Emergency Management Agency Ashtabula County Engineers Office Ashtabula County School Services Ashtabula County Sheriffs Department East Lake Fire Department Geauga County County Commission Geauga County Emergency Management 3

Geauga County Engineer/Transportation Geauga County Fire/EMS 3

Geauga County Health Department Geauga County School Services Geauga County Sheriffs Department Growth Partnership for Ashtabula County (PIO volunteer)

Lake County Amateur Radio Association Lake County Central Communications Lake County Commissioners Lake County Emergency Management Agency Lake County Engineer Lake County General Health District Lake County GIS 3

Lake County Health Department Lake County Job and Family Services Lake County Retired Senior Volunteer Program Lake County Schools' Services Lake County Sheriffs Office LakeTran Mentor-Fire Department 3

14

Un class ifiled Radiological Emcrgcncy Preparedness Program (REP)

After Action Rcport/hnprovcment Plan PcrrY Nuclear Powcr Plaint North West Ambulance District Perry Fire Department RACES Private Organizations American Red Cross First Energy Nuclear'Operating Company 15

Uniclassifiedi Radiological Emcrgcncy Preparedness Program (I(EP)

Aftcr Action Report/hmprovcmncni Plani Pcrry NuLclear Powcr PPkullt I

SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design I

The DHS/FEMA Region V Office evalutated the PNPP Radiological Emergency Preparedness 3

(REP) Partial Participation Plume Exposure Pathway Exercise conducted on September 28, 2010, to assess the capabilities of local emergency preparedness organizations in implementing their Radiological Emergency Response Plans (RERP) and procedures to protect the publics health and safety during a radiological emergency involving the PNPP. The purpose of this report is to present the results and findings on the performance of the Offsite Response Organizations (OROs) during a simulated radiological emergency.

2.2 Exercise Objectives, Capabilities and Activities I

Exercise objectives and identified Capabilities/REP Criteria selected to be demonstrated are discussed in Appendix D "Exercise Plan".

2.3 Scenario Summary 3

Appendix F, "Scenario Details", contains a summary of the Exercise Scenario, a simulated I

sequence of events, that was used as the basis for invoking emergency response actions by OROs in the PNPP REP Partial Participation Plume Exposure Pathway Exercise on September 28, 2010.

3 This exercise scenario was submitted by the State of Ohio and First Energy and accepted by 3

DHS/FEMA Region V on August 23, 2010.

During the exercise, in addition to information and data provided through the PNPP onsite i

scenario, controllers fiorn the State of Ohio provided "inject messages" containing scenario events and/or relevant data to those persons or locations who would normally receive notification of such events. These inject messages were the method used for invoking additional specific response actions by OROs.

I The details of the scenario are included in Appendix F "Scenario Details".

3 16

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Rcport/hinproverent Plan Pcrry Nudlear Power Plato SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are results and findings of the evaluation of all jurisdictions and functional entities that participated in the September 28, 2010, REP Partial Participation Plume Exposure Pathway Exercise to test the offsite emergency response capabilities of State and local governments in the 10-mile EPZ surrounding the Perry Nuclear Power Plant.

Each jurisdiction and functional entity was evaluated based on its demonstration of exercise criteria delineated in Federal Register Notice/Vol. 67, No. 80, dated April 25, 2002. Detailed information on the exercise criteria and the extent-of-play agreement used in this exercise are found in Appendix D "Exercise Plan" of this report.

Presented below are definitions of the tenns used in this report relative to the criteria demonstration status:

- M - Met: The status of a REP exercise Evaluation Area Criterion indicating that the participating Offsite Response Organization (ORO) demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the extent-of-play agreement with no Deficiencies or ARCAs assessed in the current exercise and no unresolved prior ARCAs.

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

- A - Area Requiring Corrective Action (ARCA) - An observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety. Listing of the demonstrated exercise criteria under which one or more ARCAs was/were assessed during the current exercise or ARCAs assessed during prior exercises remain unresolved. Included is a description of any ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise.

17

Unclassified Radiological Emergency Prcparedncss Program (REP)

P A ter Aflion Rcport/hnpro\\,cmemn Plan Pcr.ry' Nuclcar Power Plani

- P - Plan Issue,- An observed or identified inadequacy in the ORG's emergency plan or implementing procedures, rather than in the ORO's performance.

- N - Not Demonstrated - Exercise criteria that were not demonstrated as scheduled during this exercise and the reason(s) they were not demonstrated.

3

- Prior ARCAs - Resolved - Descriptions of ARCAs assessed during previous exercises that 3

were resolved and the corrective actions demonstrated in this exercise.

- Prior ARCAs - Unresolved - Descriptions of ARCAs assessed during prior exercises that I

were not resolved in this exercise. Included is the reason the ARCA remains unresolved and recommended corrective actions to be demonstrated before or during the next exercise.

I 3.2 Summary Results of Exercise Evaluation 3

The matrix presented in Table 3.1, on the following page(s), presents the status of all exercise 3

criteria frorn Federal Register Notice Vol. 67, No. 80, dated April 25, 2002, which were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. The criterion status box is blank if it was not scheduled for demonstration.

This subsection provides infonrnation on the evaluation of each participating jurisdiction and I

functional entity in a jurisdiction-based, issues-only format.

The DHS/FEMA has developed a standardized system for numbering exercise issues. This system is used to achieve consistency in numbering exercise issues among DHS/FEMA Regions 3

  • and site-specific exercise reports within each Region. It also is used to expedite tracking of exercise issues on a nationwide basis.

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

- Plant Site Identifier - A two-digit number, corresponding to the Utility Billable Plant Site Code (47 for Perry Nuclear Power Plant).

I

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

181

Li aici ssif ie d Radiological Etnercocy Prcparedncss Program (REP)

Aftcr Action Rcportt/Impro\\'cnlcnt Plait Perrv NPLclcar Power 'idl Criterion Number - An alpha and two-digit number corresponding to the criterion number in the six Exercise Evaluation Areas described in Federal Register Notice, Vol. 67, No. 80, dated April 25, 2002, which amends FEMA-REP 14, Radiological Emergency Preparedness Exercise Manual.

" Issue Classification Identifier - (D = Deficiency, A = ARCA, P = Planning Issue).

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

19

Uncrascsified Radiological Emergency P~reparediness Program (PEP)

After Action Rcport/lmprovcnmm Plan Perry Nuclear Power Plant U

I Table 3.1 - Summary of Exercise Evaluation (4 pages)

U DATE: 2010-09-28 i

SITE: Perry Nuclear Power Plant, OH U

I U

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not a

Demonstrated i © z

00 0000 0 0

-C Emcrgaiev,7periatons Man*agme~iii-.i

?...." :,*:,:",: '*,

Mobilization lal M M M M M M M M M M Facilities IbI Direction and Control lcl M M M

M Communications Equipment Id]

M M M M M M M M M M Equip & Supplies to support operations lel M M M

M M

.Proicctiue Acti'hDec~isiin Making "

Emeigency Worker Exposure Control 2a]

M M M

M M Radiological Assessment and PARs 2bl M P M

M Decisions for the Plume Phase - PADs 2b2 M M M

M M PADs for protection of special populations 2cl M M M

M M Rad Assessment and Decision making for Ingestion Pathway 2d]

Rad Assess/Decision making concerning Relocation, Reentry, and Return 2el

"."'i:.

lProtectwedAction hnp cmettn Implementation of emergency worker exposure control 3al M

M M.

Implementation of KI decision 3bl M

M M

Implementation of protective actions for special populations - EOCs 3cl M

Implementation of protective actions for Schools 3R2 MII Implementation of traffic and access controf 3d]

m M MM Impediments to evacuation are identified and resolved

-3d2 M

Imhplementation of in~gestion pathway decisions - availability/use of info 3e 1 Materials for Ingestion Pathway PADs are available 3c2 Implementation of relocation, re-entry, and return decisions 3fl F i e l d M c a s ~u r ~

ii r en ( ' a n c l A n a il,y s i s ".

Adequate Equipment for Plume Phase Field Measurements 4al Field Tearns obtain sufficient information 4a2 Field Teamns Manage Sample Collection Appropriately 4a3 Post plume phase Field measurements and sampling 4b1 Laboratory operations 4d Activation of the prompt alert and notification system 5al M

M M

Activation of the prompt alert and notification systern - Fast Breaker 5a2 Activation of the prompt alert and notification systemn-Exception areas 5a3 Emergency information and instructions for the public and the media 5bl M M M

Support,0Opera ti ons/F.acili i es" 7]*.

Mlon/Decon of evacuees and EWs and registration of evacuiees 6al Mon/Decon of EW worker equipment 6bi Temporary care of evacuees 6c 1 Transportation and treatment of contaminated injured individuals 6d 1 I

I I

U I

I I

I I

I I

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I 20 I

Unclassified Radiological Enicreency Preparedness Program (REP)

After Action Report/inprovemernl Plan Perry Nuclear Power Planm Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/4)

DATE: 2010-09-28 SITE: Perry Nuclear Power Plant, OH M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated i

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EmergencyOpcratidnis Management Mobilization la]

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Direction and Control Icl M

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M M

M M 1 M M M

EqUip & Supplies to support operations lei M M M M M M

M Protective Actloi.Decision Making..

Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2bl Decisions for the Plume Phase - PADs 2b2 PADs for protection of special populations 2cl Rad Assessment and Decision making for Ingestion Pathway 2dl Rad Assess/Decision making concerning Relocation, Reentry, and Return 2el

'Pr P cti~t ve.Ac tion imple-m~entation -.

n i *-.'..-

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Implementation of emergency worker exposure control 3al M M M M M M M

Implemnentation of K] decision 3b1 M M M M M

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Inplementation of traffic and access control 3d]

Impediments to evacuation are identified and resolved 3d2 Irnplementation of ingestion pathway decisions - availability/use of info 3e]

Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions.

3f]

Fieid Measurcment.and Analysis".:..

Adequate Equipment for Plume Phase Field Measurements 4al M M Field Teams obtain sufficient infonnation 4a2 Field Teams Manage Sarnple Collection Appropriately 4a3 M M Post plume phase field measurements and sampling 4b1 Laboratory operations 4c1

  • EmcrgncyNotification and Public Info' 7..

Activation of the prompt alert and notification system 5aI Activation of the prmompt alert and notification systern - Fast Breaker 5a2 Activation of the promnpt alert and notification system - Exception areas 5a3 M

Emergency information and instructions for the public and the rinedia 5bl M I Support 0perations[Facilities

'i Mon/Decon of evacuees and EWs and registration of evacuees 6al NM N NA M Mon/Decon of EW worker equip nent 6b 1 21

Us class ifl ed R~adiological L~mcrgcnc) Prcparerlness I'rogrem (JEl')

I Aftcr Action Rcport/lhmprovcmcnl Plan Perry Ntlciclear Power I'latr Tempor.ary care of evacuees Transportation and treatment of contaminated injured individuals 16cl MI 16d]

MI I

22 I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Perry Nuclear Power Plant Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/4)

DATE: 20 l0-09-28 SITE: Petry Nuclear Power Plant, OH M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated

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Eriiergency Operations Mvlanaen*ent Mobilization lal M

M Facilities IbI Direction and Control Ic)

M Communications Equipmerit dl M M M M

M M

M M

M M M Equip & Supplies to support operations lel M M M M

M M

M M

M M Protective ActiOn Dec6ision M~aking.4 Emergency Worker Exposure Control 2al P

Radiological Assessment and PARs 2b 1 Decisions for the Plume Phase - PADs 2b2 M

PADs for protection of special populations 2cl M

Rad Assessment and Decision making for Ingestion Pathway 2d]

Rad Assess/Decision making concerning Relocation, Reentry, and Return 2e.

Protective Actionlplementation Implementation of emergency worker exposure control 3al P

M M M

M M

M M

M Implementation ofKI decision 3b]

M M M

M M M

Implementation of protective actions for special populations - EOCs 3c]

M Implementation of protective actions for Schools 3c2 M

M implementation of traffic and access control 3dl M

M M

Impediments to evacuation are identified and resolved 3d2 M

implementation of ingestion pathway decisions - availability/use of info 3e1 Materials for lngestion Pathway PADs are available 3e2 implementation of relocation, re-ently, and return decisions 3f)

Field Mcasuiement afid Analysis.

Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4bl Laboratory, operations 4c I Emergency Notification and public Info Activation of the prompt alert and notification system 5al M

Activation of the prompt alert and notification system - Fast Breaker.

5a2 Activation of the prompt alert and.notification system - Exception areas 5a3 Emergency infon-nation and instructions for the public and the media 5bl M

M Support Operations/Facilities.

  • Mon/Decon of evacuees and EWs and registration of evacuees 6al M

Mon/Decon of EW worker equipment 16b I 23

U nclussi lied(

Radiological Enicrgcncy Prcparcdncss Program (REP)

I Aftcr Action Rcport/Improvccmcni Plan Pcrry NuclCar PowCr Planl Temporary care of evacuees ITransportation and treatment of'contaminated injured individuals iel I l

l l

l l

l l

l l

l 6ld I M I I

I I

I I

I I

I I

II I

24 I

U nclass iied Radiological Enmergenv Preparedness Program (REP)

Aftcr Action Report/lmprovcmcnt Plan Pcrry,, Nuclear Powcr Plant Table 3.1 - Summary of Exercise Evaluation (Continued. page 4/4)

DATE: 2010-09-28 SITE: Peny.Nuclear Power Plant, OH M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N:.Not Demonstrated V)

CU V)

-c)

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U-Cý)

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6 a)-

-'a a) 1z a)&

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U C-U H

CU C

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--7.

La

-J Lu 03 La..

C.

C.

Lu 0.

CN P

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Emergcncy.Opcrations Managcmcnt".-.

rMobilization lal M

M Facilities IbI Direction and Control I

M Communications Equipment Idl M

M M

M M

M M

M M

M Equip & Supplies to support operations lel M

M M

M M

M M

M M Protective Action DecisionM aling' Emergency Worker Exposure Control 2al M

Radiological Assessment and PARs 2b]

Decisions for the Plume Phase - PADs 2b2 M

PADs for protection of special populations 2cl M

Rad Assessmnent and Decision making for Ingestion Pathway 2d I Rad Assess/Decision making concerning Relocation, Reentry, and Return 2e]

Protcctiv, Action Imptonientation Implementation of emergency worker exposure control 3a]

M M

M M

.M M

M. M Implementation ofKI decision 3b]

M M MM M

MM M M Implementation of protective actions for special populations - EOCs 3c]

M Implemcntation of protective actions for Schools 3c2 M

M Implementation of traffic and access control 3d]

M M

M hMpediments to evacuation are identified and resolved 3d2 M

Implementation of ingestion pathway decisions - availability/use of info 3e]

Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions 3f]

FieldMeasurement and Analysis.-........

Adequate Equipment for Plume Phase Field Measurements 4a]

Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laboratory operations 4c1 Emergency Notification and-Publicnf". 1..:.-.

n..'..

Activation of the prompt alert and notification system 5a]

M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alml and notification system - Exception areas 5a3 M

M Etnergency information and instructions for the public and the media 5bl M

M 25

Unclassified Radiological Emergency Preparcdness Program (REIP)

Aftcr Action Rcport/[mprovenlcn( Plan Perry Nuclear Power Plant Supp-rt.OplefatibnsFi`cilities

.I:

m Mon/Decon of evactues and EWs and registration of evacuees 6al Mon/Decon of EW worker equipment 6bl Temporary care of evacuees

.6c I

Transportation and treatment of contaminated injured individuals 6d]

M I

I N

I U

I I

I I

I I

I I

I U

I I

I I

26

Undlassified Radiological Erncracncy Prcparcdntcss Program (RPEP)

Artcr Action Report/Ilmprovcmcnt Plan PcrrN Nuitcar Powcr Plana 3.3 Criteria Evaluation Summaries 3.3.1 Ohio Jurisdictions 3.3.1.1 State of Ohio - Initial Notification Point

a. M ET: l.a.l, l.d.1.
b.

AREAS REQUIRING CORRECTIVE ACTION: Noine

c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 State of Ohio - Emergency Operations Center - Executive Room

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

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None
g.

PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 State of Ohio - Emergency Operations Center - Assessment Room

a.

M ET: ].a.l, I.c.l,.d.l, I.e.], 2.a.1, 2.b.2, 2.c.1, 3.d.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: 2.b.1.

ISSUE NO.: 47-10-2bl-P-01 CRITERION: Appropriate PARs are based on available inforniation on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of on and off site environmental conditions.

CONDITION: The Dose Assessment Staff in the State EOC Assessment Room and the Lake County EOC and, the field monitoring team coordinators for the State and 27

Unclassified Radiological Emergcncy Preparcdncss Program (REP)

After Acion Report/Improvcenlnt Plan Pcrry Nuclcar Power Plant Lake County EOC performed well during the Perry exercise exhibiting good U

teamwork, coordination of functions and timely sharing of information. However, the procedures and standard (suggested) operating guidelines used by these I

individuals are mostly silent on the coordination methods used during the exercise.

POSSIBLE CAUSE: The turnover in personnel and, a recent change in coordination methodology partly to correct the Beaver Valley ARCA on dose assessment did not get put into the procedures and operating guidelines.

REFERENCE:

1. NUREG 0654, 1.8, and 1.10.

U

2. State EOC SOP-2010 Field MonitoringTeam Controller Rev date 6/21/2010.
3. State Environmental Protection Agency Monitoring Team Communicator, Radiological Response Guidelines, App. 3 Dose Assessment Room.
4. State OEMA procedure Rad Systems Operator Dose Assessment, OPS-5, 2/24/10.
5. State ODH TSM-EM-202, BRP-2009-005 Dose Assessment Coordinator:

Emergency Phase, Rev 3, 03/15/2010.

6. Lake County Field Monitoring Team Coordinator, SOG, Vol. 1, Rev 11, July 2008.

3

7. Lake County Field Team Leader, SOG Vol. 1, Rev 11, July 2008.

EFFECT: Absence of such instructions will not assure the continued coordination in the mlanner demonstrated during the Perry exercise. Turnover of personnel will also result in a loss of continuity in performance if only trivial knowledge is relied upon.

RECOMMENDATION: The State Assessment Room dose assessment personnel's 3

procedures (Reference 4, 5) should include the maintenance of close communication during the preparation of dose projections with the Lake County Dose Assessment I

person. There should be a procedure for the State person who does the Lake County dose assessment and it should include the instruction for the maintenance of close communication during the preparation of dose projections with the State Assessment Room dose assessment person. The need to obtain reasonable agreement with the two dose projection results and that of PNPP should be included in both procedures.

The State Field Monitoring Team Coordinator and Monitoring Team Communicator 3

procedure and guidelines (Reference 2 and 3) should include the instruction to I

28 I

U nelassilfid Radiological Emergency Preparedness Program (REP)

After Action Report/Improvemenit Plan "

Pcrr. Nuclear Power Plant closely work with the Lake County, Field Monitoring Team Coordinator and Team Leader (Reference 6 and 7) in the coordination of deployment strategy and the sharing of field team results. The Lake County FMTC and FMTL operating guidelines (Reference 6 and 7) should also be updated to include the new titles of the State personnel and new coordination approach.

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: 2.b. 1.

ISSUE NO.: 03-10-2b] -A-01 ISSUE: The State of Ohio Dose Assessment Team did not dermonstrate a reliable capability to independently develop dose projections and compare them with those provided by the licensee or Columbiana County. Dose projections were not calculated properly and the Dose Assessment Coordinator did not properly review the calculations; thei-efore, the miscalculation went unnoticed, and the dose was significantly greater than what the Dose Assessment Team determined.

CORRECTIVE ACTION DEMONSTRATED: During the Perry exercise, the State Assessment Room, Rad Systems Operator for Dose Assessment worked closely with the Lake County Dose Assessment person and their results were in agreement with the PNPP dose projection. In addition, the State Department of Health Dose Assessment Coordinator in the Assessment Room provided a quality assurance review and oversight function to ensure the accuracy of the dose projection results.

The Dose projection procedures have been revised.

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.1.4 State of Ohio - Emergency Operations Center - Joint Information Center

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None 29

U ncJassified Radiologica( Emergency Prcparcdncss Program (REP)

Aftcr Action Report/Improvcment PlanP Pcrry Nuclear Power Plant

g. PRIOR ISSUES - UNRESOLVED: None I

3.3.1.5 State of Ohio - Lakeland Community College - Joint Information Center

a. M ET: 1.a.1, I.c.,

.d.1, I.e.1,5.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None I
c. DEFICIENCY: None
d. PLAN ISSUES: None I
e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None I

3.3.1.6 State of Ohio - Emergency Operations Facility 1

a. MET: l.a.I,l.d.I,3.a.I,3.b.1.
b. AREAS REQUIRING CORRECTIVE ACTION: None
c. DEFICIENCY: None
d. PLAN ISSUES: None
e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None g.. PRIOR ISSUES - UNRESOLVED: None 3.3.1.7 State of Ohio - Lake County Emergency Operations Center - State Radiological 3

Analyst

a. MET: I.a.I,1.d.1,2.a.1,2.b.1,2.b.2,2.c.1.
b. AREAS REQUIRING CORR-ECTIVE ACTION: None
c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f. PRIOR ISSUES - RESOLVED: None i
g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.8 State of Ohio - Department of Natural Resources - Route Alerting
a. M ET: 1.d.1,I.e.1,3.a.l,3.b.l,5.a. 1.
b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None I

30 II

Ui class ifi ud Radiotoutcal Emcrtency Prcparcdncss Program 'REP)

Alter Action Rcporn/lmpros'cment Plan Perry NuclCar Powcr Plant

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2 Risk Jurisdictions 3.3.2.1 Lake County - Initial Notification Point

a. MET: l.a.1, 1.d.1.
b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 Lake County - Emergency Operations Center

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 Lake County - Field Monitoring Team Coordinator

a.

MET: L.a.I,2.a.1, 2.b.2,2.c.l.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: 4.a.2.

ISSUE NO.: 47-10-4a2-P-02 CRITERION: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, 1.8., 11.,

J.10.a) 31

Uniclassifi ed Radiological Emcrgency Prcparcdness Program (REP)

Aftcr Action Rcport/lhnprovemcnt Plan Pcrry Nuclear Powcr Plant I

CONDITION: The Lake County Field Monitoring Team Coordinator did not include a discussion of KI in the field team pre-deployment briefing.

POSSIBLE CAUSE: The Lake County Standard Operational Guidance for Radiological Field Tearns Volume I, Revision 12, includes Standard Operational Guidance for the Radiological Field Team Controller (FMTC SOG). The FMTC SOG includes an Emergency Response Health and Safety Plan as Attachment 2 that forms the basis for the health and safety briefing given to the Field Teams prior to their departure. The information in Attachmnent 2 includes dosimetry requirements but does not mention the requirement for Field Monitoring Team Members to have Ki, nor instructions for using KI.

REFERENCE:

Lake County Standard Operational Guidance for Radiological Field Teams Volume 1, Revision 12, FMTC SOG Attachment 2, Section D (page A-5 of the FMTC SOG).

EFFECT: The FMTC and Field Monitoring Team Members could be unaware of the need to have KI available to the Field Monitoring Tearn Members, and also may not be aware of the protocols for using KI and its risks. During this exercise the teams were supplied with KI, and the infon-nation on taking KI and documenting that fact were transmitted at the time the Field Teams were told to take KI. No effect on exercise play was observed.

RECOMMENDATION: Add a reference to KI in Section D of the FMTC SOG alongside the reference to the dosimetry requirements. This would remind the FMTC to mention the KI protocols during field team pre-deployment briefing.

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None g

PRIOR ISSUES - UNRESOLVED: None 32

Unclassified Radiological Emergency Prcparedness Program (REP)

Aftcr Action Rcpori/Improvcment Plan Perry Nuclcar Power Plati 3.3.2.4 Lake County - Lakeland Communit, College - Joint Information Center

a. M ET: i.d.,

l.e.,

5.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None
c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None g

PRIOR ISSUES - UNRESOLVED: None 3.3.2.5 Lake County - Field Monitoring Team #1

a. M ET: 1.a.l, I.d.,

L.e.l,3.a.I,3.b.1,4.a.],4.a.3.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d. PLAN ISSUES: None
e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.6 Lake County - Field Monitoring Team #2

a.

M ET: L.a.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.3.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d. PLAN ISSUES: None
e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None
g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.7 Lake County - Leroy Fire Department - Backup Route Alerting

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

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 33

Unclassified Radiological Emnrgcncy Prcparcdncss Program (REP)

Aflcr Action Rcporl/hqpro'cmcnt Plan Perry Nuclcar Powcr Plant 3.3.2.8 Lake County - Fairport Harbor School District - Evacuation School i

a. MET: 1.d.1,1.e.1,3.a.1,3.b.1,3.c.2.
b. AREAS REQUIRING CORRECTIVE ACTION: None
c. DEFICIENCY: None
d. PLAN ISSUES: None
e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES-RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.9 Lake County - Kirtland High School - Kirtland Fire Department - Evacuee i

Registration

a. MET: 6.a. l.
b. AREAS REQUIRING CORRECTIVE ACTION: None
c. DEFICIENCY: None
d.

PLAN ISSUES: None e.. NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None C,. PRIOR ISSUES - UNRESOLVED: None u

3.3.2.10 Lake County - Kirtland High School - Kirtland Fire Department - Evacuee Monitoring

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None
c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.11 Lake County - Kirtland High School - Kirtland Fire Department - Evacuee 3

Decontamination

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None 34

ULn Las sili ed Radiological Emergency Prgoarcdncss Program (RPEP)

After Action Report/Inprovcmcnt Plan Pent Nuclear Power Plant

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.12 Lake County - Kirtland High School - Kirtland Fire Department - Evacuee Monitoring and Decontamination of Vehicles

a.

M ET: 1.c.,

1.d.,

1.e.,

6.a. 1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

IPLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.13 Lake County - Kirtland High School - Congregate Care Center

a.

MET: 1.d.1,6.c.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.14 Lake County - Madison Fire District - Medical Service - Transportation

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 35

Unclassified Radiological Emergency Prcparcdness Program (REP)

After Action Rcport/lrnpro%,cmcnt Plan Perry Nuclear Power Plant 3.3.2.15 Lake County - Tri-Point Medical Center - Medical Service - Facility 1

a. M ET: 1.d.,

.e.1, 6.d. 1.

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

ISSUE NO.: 47-10-3al-A-07 CRITERION: OROs issue appropriate dosimetry and procedures, and manage 3

radiological exposure to emergency workers IAW plans and procedures. Emergency workers periodically and at the end of each mission read and record dosimeter reading. (NUREG-0654, K.3)

CONDITION: TriPoint Medical Center (TPMC) was the primary MS-I medical I

facility for the Perry Nuclear Power Plant (PNPP). The Standard Operating Procedure (SOP) specifies dosimetry in accordance with State of Ohio requirements I

- which is present and within appropriate calibration dates.

I In accordance with the SOP checklist for the Radiation Technician, that person was responsible for zeroing direct-reading dosimeters (DRD) and placing them on a hook in the treatment room.

The Radiation Technician had significant trouble when attempting to zero one of the I

DRDs. She had positioned the DRD in the CD V-750 charger backwards. She attempted to charge three or four different DRDs when-they were in the incorrect I

position.

POSSIBLE CAUSE: This was likely due to a lack of familiarization of procedures and practice on the part of the Radiation Technician.

3

REFERENCE:

NUREG-0654, K.3.

3 EFFECT: There was the potential for not having DRDs that were zeroed in place prior to the potentially contaminated injured victim arriving in the Radiolodical Emergency Area.

CORRECTIVE ACTION DEMONSTRATED: The controller intervened and I

36 I

U nclassifiCd Radiological Emergency Preparedncss Program (REP)

A t'cr Action Reporl/hnprovemcni P)an Perry Nuc]car Power PMlni conducted training to the Radiation Technician on the proper positioning of the DRD in the Charger. Training was also conducted informing the Technician that the wire inside the charger will often become oxidized, preventing a proper connection with the DRD and making zeroing the instrument difficult. After additional instruction on the proper cleaning of the wire, the Radiation Technician was able to properly zero the DRD.

These activities were successfully re-demonstrated following additional training by the controller.

c.

DEFICIENCY: None

d.

PLAN ISSUES: 3.a.1.

ISSUE NO.: 47-10-3al-P-06 CRITERION: OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers IAW plans and procedures. Emergency workers periodically and at the end of each mission read and record dosimeter reading. (NUREG-0654, K.3)

CONDITION: TriPoint Medical Center (TPMC) was the primary MS-I medical facility for the Perry Nuclear Power Plant (PNPP). The S~tandard Operating Procedure (SOP) specifies dosimetry in accordance with State of Ohio requirements

- which was present and within appropriate calibration dates.

In accordance with the SOP checklist for the Radiation Technician, that person was responsible for zeroing direct-reading dosimeters and placing them on a hook in the treatment room. The SOP checklist provides for the Buffer Zone Nurse to distribute permanent record dosimeters (PRD). In the course of distributing the PRDs, a control PRD was not identified nor removed to another location.

POSSIBLE CAUSE: There is nothing written in the procedures or position checklists to ensure that a "control" PRD is identified and removed from the treatment suite to ensure a correct "baseline" reading is available when the hospital's mission is complete.

37

Unclassified Radiological Emergency Prcparcdness Program (REP)

After Action Rcport/lhnprovcencnt Plan Pcrry Nuclcar Power Plant I

REFERENCE:

NUREG-0654, K.3.

3 EFFECT: Without a "baseline" PRD reading, it is not possible to compute an actual total effective dose equivalent (TEDE) for an individual.

I RECOMMENDATION: The TPMC should revise their SOP to identify an individual who will be responsible for ensuring that a control PRD is identified and given to a specific position in the Emergency Room facility.

e. NOT DEMONSTRATED: None
f. PRIOR ISSUES - RESOLVED: None
g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.16 Lake County - Madison Local - Evacuation School
a.

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

3

b. AREAS REQUIRING CORRECTIVE ACTION: None
c. DEFICIENCY: None 3
d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None
g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.17 Lake County - Perry Village Police Department - Traffic Control Point/Access Control Point-Briefing
a.

M ET: I.d.1, l.e.l,3.a.l,3.b. 1.

b. AREAS REQUIRING CORRECTIVE ACTION: None 3
c. DEFICIENCY: None
d. PLAN ISSUES: None
e.

NOT DEMONSTRATED: None I

f. PRIOR ISSUES - RESOLVED: None
g. PRIOR ISSUES - UNRESOLVED: None I

38

Unclassified Radiological Emergcncy Prcparcdncss Program (REP)

Aficr Action Rcpor/ilmprovcment Plan Pcrr' Nuclcar Powcr Plant 3.3.2.18 Lake County - Perry Village Police Department - Traffic Control Point/Access Control Point - Interview

a. M ET: I.d., I.e.l,3.a.l,3.b.1,3.d.1.
b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.19 Lake County - Grand River Police Department - Traffic Control Point/Access Control Point - Briefing

a.

M ET: 1.d.l, l.e.1,3.a.1,3.b.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.20 Lake County - Grand River Police Department - Traffic Control Point/Access Control Point - Interview

a.

M ET: I.d., l.e.l,3.a.l,3.b.l,3.d.I.

b.

AREAS REQUIRING CORRECTIVE ACTION: 3.b.l.

ISSUE NO.: 47-10-3bl-A-08 CRITERION: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the admin of KI for emergency workers and institutionalized individuals (not general public) is maintained. (NUREG-0654, E.7., J. 10.e.f.)

CONDITION: The police officer was unaware that individuals who were allergic to iodine or shellfish should not ingest KI and that individuals with allergies to KI would not have been allowed to enter the I 0-Emergency Planning Zone (EPZ).

39

Unclassified Radiological Emcrgcncy Prcparcdncss Program (REP)

Aftcr Action Rcport/hmprovcrncnt Plan Pcrm' Nuclcar Powcr Plant POSSIBLE CAUSE: The police officer was unfamiliar with the Suggested Operating Guidelines.

REFERENCE:

NUREG-0654, E.7., J. I 0.e.f.

"Suggested Operating Guidelines for an Emergency at the Perry Nuclear Power Plant, EPZ Police Departments," p. 3-1 and 3-2, revision May 2010.

"Potassium Iodide Package Insert" I

EFFECT: This could result in physical harm to a police officer. Had the officer been m

allergic, this lack of knowledge may have been hazardous to the police officer's I

health.

CORRECTIVE ACTION DEMONSTRATED: At the end of the interview, the Controller reviewed the usage of KI with the police officer. The police officer then correctly re-demonstrated this portion of the interview.

c. DEFICIENCY: None 3
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.21 Ashtabula County - Initial Notification Point

a.

MET: 1.a.l, I.d.

3

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None 3

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None I

g.

PRIOR ISSUES - UNRESOLVED: None I

40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/]inprovement Plan Perry: Nuclear Power Plant 3.3.2.22 Ashtabula County - Emergency Operations Center

a. M ET: I.a.1,l.c.I, l.d.l,1.e.l,2.b.2,2.c.1,3.a.l,3.b.l,3.c.L,3.c.2,3.d.l,3.d.2,5.a.],

5.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None
c. DEFICIENCY: None
d.

PLAN ISSUES: 2.a.1.

ISSUE NO.: 47-10-2al-P-03 CRITERION: OROs use a decision-making process to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of admin or PAGs.

CONDITION: The Ashtabula County Radiological Emergency Response Plan does not specifically state who will authorize an individual emergency worker to receive a dose in excess of pre-authorized levels. The extent-of-play agreement and scenario did not test this capability.

POSSIBLE CAUSE: The Ashtabula County Radiological Emergency Response Plan implies that the authority for this decision lies with the Ashtabula County Emergency Operations Center (EOC) Executive Director and Control Group and states that the Radiological Officer is responsible for monitoring and controlling exposures of all County emergency workers.

The State of Ohio Radiological Emergency Response Plan implies that the Ohio Department of Heaith must make this decision. The individual response organizations' Suggested Operating Guidelines refer the individual emergency worker to the Dosimeter Coordinator.

The plan should not imply that there is a pre-authorization for emergency workers to exceed EPA General Public Protective Action Guides.

REFERENCE:

NUREG-0654 K.4 "Each State and local organization shall establish the decision chain for authorizing emergency workers to incur exposures in excess of the EPA General Public Protective Action Guides (i.e., EPA PAGs for emergency 41

Unclassified Radiological Eniergency Preparedness Program (REP)

After Action Report/hmprov'ment Plan Perry Nuclear Power Plarnt workers and lifesaving activities)."

I REP Interim Exercise Evaluation Guide, June 22, 2002, 2.a. I "According to the I

ORO's planlprocedures and the extent-of-play agreement: Who will authorize exposure levels to emergency workers in excess of pre-authorized levels?"

EFFECT: If there is a need to consider emergency worker dose in excess of the pre-authorized limit, there will likely be either a delay in authorizing the dose and threat to completing the mission or the misconception that pre-authorization to exceed exists at a much lower level than intended.

RECOMMENDATION: The plan should depict, either verbally, graphically, or both, I

the communication chain for an emergency worker to request authorization to exceed the EPA General Public Protective Action Guides or some lower administrative limit I

and the communication/command chain to grant the authorization.

I

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None 3

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.23 Ashtabula County - Lakeland Community College - Joint Information Center I

a.

MET: 1.d.1,_l.e.l,5.b.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None 3

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None 3

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.24 Ashtabula County - Saybrook Fire Department - Emergency Worker Monitoring I

and Decontamination of Equipment and Vehicles

a. M ET: 1.d.l, 1.e.1, 3.a.l, 6.b.1.
b. AREAS REQUIRING CORRECTIVE ACTION: None
c. DEFICIENCY: None 3
d.

PLAN ISSUES: None 4

42 I

U n classified RadioloaicIa Emergency Prcparcdnos; Programn (KEP)

After Aclion Report/lmprovcment Plan Perry Nucicar Power Plant

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.25 Ashtabula County - Saybrook Fire Department -.Emergency Worker Monitoring and Decontamination

a.

MET:

.dllel,3.a.1,6.a.I.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES -UNRESOLVED: None 3.3.2.26 Ashtabula County - Northwest Ambulance District - Medical Service -

Transportation

a.

M ET: i.d.i,.e.1,3.a.1,3.b.1,6.d.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.27 Ashtabula County - Geneva Police Department - Traffic Control Point/Access Control Point - Briefing

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None g

PRIOR ISSUES - UNRESOLVED: None 43

Unclassified Radiological Emergency Preparedness Program (REP)

Aftci Action Report/lmprovcnicnt Plan Perr. Nuclear Power Plant 3.3.2.28 Ashtabula County - Geneva Police Department - Traffic Control Point/Access Control Point - Interview

a.

M ET: I.d.1,Le.1,3.a.l,3.b.1,3.d.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.29 Ashtabula County - Harpersfield Volunteer Fire Department - Backup Route Alerting - Briefing

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None
c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None g

PRIOR ISSUES - UNRESOLVED: None 3.3.2.30 Geauga County - Initial Notification Point 3

a.

MET:

.a.l, l.d.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None 3

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.31 Geauga County - Emergency Operations Center 3

a.

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

3

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None 44

UnclassiiLed Radiological EmcrgcncY Prcparcdncss Program (REP)

Aftcr Aclion Rcportlimprovemcnt Plan Perry NucIcar Power Plaio

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.32 Geauga County - Emergency Operations Center - Sheriffs Road Patrol &

Dosimetry Coordinator - Traffic and Access Control Briefing Including DCO Briefing

a.

M ET: 1.d.,

l.e.l, 3.a.1, 3.b.,

3.d.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None
g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.33 Geauga County - Lakeland Community College - Joint Information Center

a.

MET: ].d.1,I.e.1,5.b.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.34 Geauga County - Thompson Volunteer Fire Department - Route Alerting

a. M ET: ].d.1,I.e.],3.a.1,3.b.l,5.a.3.
b.

AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None
d. PLAN ISSUES: None
e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 45

Unclassified Radi6logical Emergency Prcparcdncss Program (REP)

Aftcr Action Rcport/Improvemcrit Plan Perry Nucicar Powcr Plant 3.3.2.35 Geauga County - Ledgemont School District - Evacuation School I

a. M ET: 1.d.1, l.e.1,3.a.l,3.b.l,3.c.2.
b. AREAS REQUIRING CORRECTIVE ACTION: 3.a. 1.

I ISSUE NO.: 47-10-3al-A-04 CRITERION: OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers IAW plans and procedures. Emergency workers periodically and at the end of each mission read and record dosimeter reading. (NUREG-0654, K.3)

CONDITION: The Transportation Supervisor did not mention the administrative reporting limit of I R (bus driver should contact the supervisor), nor the procedure for the Transportation Supervisor to zero the dosimeters and complete the Emergency Worker Dosimetry Exposure Log before giving the dosimetry packet to the bus driver. These steps are provided as a checklist in the Ledgemont Local School District Suggested Operating Guideline (SOG) for an emergency at the PNPP (Rev.

10/09).

POSSIBLE CAUSE: Training and lack of familiarity with the Ledgemont Local School District Suggested Operating Guideline for an emergency at the PNPP (Rev.

10/09).

REFERENCE:

NUREG-0654 H1. Planning Standards and Evaluation Criteria K. Radiological Exposure Control 3.b Each organization shall ensurethat dosimeters are read at appropriate frequencies and provide for maintaining dose records for emergency workers involved in any nuclear accident.

EFFECT: Not zeroing the dosimeter could cause a false high dosimeter reading; not completing the Emergency Worker Dosimeter Exposure Log could result in an extended time in reading each dosimeter, and would not enable the appropriate record management for emergency workers; not including the I R administrative reporting value during the dosimetry briefing could cause the emergency worker to 46

Unclassified Radiological Emcrgcncy Preparcdncss Program (REP)

After Act ion Rcport/lmprovcmcni Plan Pcrry Nuclcar Powcr Plant be at higher risk for radiation exposure.

CORRECTIVE ACTION DEMONSTRATED: During the re-demonstration, the Transportation Supervisor successfully completed the dosimetry briefing to include zeroing the dosimeters, completing the Emergency Worker Dosimetry Exposure Log before presenting the dosirnetry packet to the driver, and advising that exceeding the administrative limit of I R requires the driver to contact the Transportation Supervisor after being retrained by the Controller.

c. DEFICIENCY: None
d.

PLAN ISSUES: None

e. NOT DEMONSTRATED: None
f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 47

U nclassi flied Radiological Emcrgency Prcparcdncss Program (REP)

Aftcr Action Rcport/lhnprovcmrnc Plan Perry Nuclcar Powcr Planw SECTION 4: CONCLUSION The Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise of September 28, 2010, resulted in one ARCA Corrected on the Spot for Geauga 3

County, and two ARCAs Corrected on the Spot for Lake County. A previous ARCA for the State of Ohio from the 2010 Beaver Valley Full Participation REP Exercise was resolved. There was one Planning Issue for the State of Ohio, two Planning Issues for Lake County, and one Planning U

Issue for Ashtabula County.

II I

I I

I I

U I

N I

I 48 1

U

LUnclassified Radiological Emergency Preparedness Program (REPi After Action Report/Improvcmnent Plan Pcrry Nuclcar Power Plant APPENDIX A: IMPROVEMENT PLAN

  • I ss.

Nu br 471-a-'I0 Critein ISSUE: The Ashtabula County Radiological Emergency Response Plan does not specifically state who will authorize an individual emergency worker to receive a dose in excess of pre-authorized levels. The extent-of-play aftrcement and scenario did not test this capability.

RECOMMENDATION: The plan should depict, either verbally, graphically, or both, the communication chain for an emergency worker to request authorization to exceed the EPA General Public Protective Action Guides or some lower administrative limit and the communication/command chain to grant the authorization.

CORRECTIVE ACTION DESCRIPTION: The county RERP has been revised under section K.5 "Exposure Control and limits" to identify the procedure for extension of dose limits for emergency responders. The SOG's relating to this plan section will also be revised in early 2011.

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY:

Emergency Operations Center Management Ashtabula County CAPABILITY ELEMENT:

START DATE:

Planning 2010-12-10 AGENCY POC:

ESTIMATED COMPLETION DATE:

George Sabo 440-576-9148 2011-02-24 Isu Nu br e1-a--2Ci ISSUE: The Lake County Field Monitoring Team Coordinator did not include a discussion of KI in the field team ore-deolovment briefing.

RECOMMENDATION: Add a reference to KI in Section D of the FMTC SOG alongside the reference to the dosimetry requirements. This would remind the FMTC to mention the KI protocols during field teamn pre-deployment briefing.

CORRECTIVE ACTION DESCRIPTION: An addition of specific KI Briefing Text will be made to the Health and Safety portion of the Lake County Health Department Field Monitoring Team procedure. This procedure will be revised in January 2011.

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY:

Responder Safety and Health Lake County CAPABILITY ELEMENT:

START DATE:

Planning AGENCY POC:

ESTIMATED COMPLETION DATE:

Larry D. Greene 440-350-5499 2011-01-30 49

Unclassified Radiological Emergency Preparcdness Program (REP)

After Action Report/Improvement Plan Pern, Nuclear Power Plant SIsseNu br 47-03lP0 Crtrin 3ill ISSUE: TriPoint Medical Center (TPMC) was the primary MS-1 medical facility for the Perry Nuclear Power Plant (PNPP). The Standard Operating Procedure (SOP) specifies dosimetry in accordance with State of Ohio requirements - which was present and within appropriate calibration dates.

In accordance with the SOP checklist for the Radiation Technician, that person was responsible for zeroing direct-reading dosimeters and placing thern on a hook in the treatment room. The SOP checklist provides for the Buffer Zone Nurse to distribute permanent record dosimeters (PRD). In the course of distributing the PRDs, a control PRD was not identified nor removed to another location.

RECOMMENDATION: The TPMC should revise their SOP to identify an individual who will be responsible for ensuring that a control PRD is identified and given to a specific position in the Emergency Room facility.

CORRECTIVE ACTION DESCRIPTION: A revision will be made to the TriPoint/LakeWest Medical Centers' SOG checklist for the person who is in charge of dosimetry in the REA. The checklist will instruct that the control PRD is to be removed from the proximity of the REA to a remote location.

The SOG will be revised in January 2011 to reflect the change.

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY:

Medical Supplies Management and Distribution Lake County CAPABILITY ELEMENT:

START DATE:

Planning AGENCY POC:

ESTIMATED COMPLETION DATE:

Larry D. Greene 440-350-5499 2011-01-30 I.

Isu Nu br 4-02lP-0 Cr i

ISSUE: The Dose Assessment Staff in the State EOC Assessment Room and the Lake County EOC and, the field monitoring team coordinators for the State and Lake County EOC performed well during the Perry exercise exhibiting good teamwork, coordination of functions and timely sharing of information. However, the procedures and standard (suggested) operating guidelines used by these individuals are mostly silent on the coordination methods used during the exercise.

RECOMMENDATION: The State Assessment Room dose assessment personnel's procedures (Reference 4,

5) should include the maintenance of close communication during the preparation of dose projections with the Lake County Dose Assessment person. There should be a procedure for the State person who does the Lake County dose assessment and it should include the instruction for the maintenance of close communication during the preparation of dose projections with the State Assessment Room dose assessment person. The need to obtain reasonable agreement with the two dose projection results and that of PNPP should be included in both procedures.

The State Field Monitoring Team Coordinator and Monitoring Team Communicator procedure and guidelines (Reference 2 and 3) should include the instruction to closely work with the Lake County Field Monitoring Team Coordinator and Team Leader (Reference 6 and 7) in the coordination of deployment strategy and the sharing of field team results. The Lake County FMTC and FMTL operating guidelines (Reference 6 and 7) should also be updated to include the new titles of the State personnel and new coordination approach.

CORRECTIVE ACTION DESCRIPTION: To ensure continued adequate communication and coordination, procedures for the Field Monitoring Team Coordinator and Radiological Systems Operator at Lake County EOC (dose assessment) will be revised to include provisions requiring communications with each other and county personnel. These revisions will be completed in April, 2011.

I I

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I I

I I

I I

I I

I I

I I

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY:

Communications State of Ohio CAPABILITY ELEMENT:

START DATE:

Personnel AGENCY POC:

ESTIMATED COMPLETION DATE:

Carol O'Claire 614-799-3915 2011-04-24 50

Unciassifled Radioiozical Emergency Preparcdncss Program (REP)

Aftcr Action Report/improvcmcnt Plan Perr.' Nuclear Power Plant APPENDIX B: EXERCISE TIMELINE Table I on the following page, presents the time at which key events and activities occurred during the Periy Nuclear Power Plant REP Partial Participation Plume Exposure Pathway Exercise on September 28, 2010. Also included are times notifications were made to the participating jurisdictions/functional entities.

51

Unclassified Radiological Enmcrgency Prcparcdness Program (REP)

Aftcr Action Report/Improvement PlIan.

Perry Nuclear Power Plant Table 1 - Exercise Timeline DATE: 2010-09-28, SITE: Perry Nuclear Power Plant, OH

_U U

Emergency Classification Level or

.0.

,0 0-.,

u..

-,u Unusual Event N/A N/A N/A N/A N/A N/A N/A Alert 0744 0749 0744 0950 0755 0755 0755 Site Area Emergency 0924 0932 0931 0950 0932 0932 0932 General Emergency 1148 1158 1158 1158 1158 1158 1158 Simulated Rad. Release Started 1031 N/A N/A N/A N/A N/A N/A Simulated Rad. Release N/A N/A N/A N/A N/A N/A N/A Terminated Simulated Major Release of Radioactive N/A 1140 N/A N/A N/A N/A Material Started Facility Declared Operational 0918 0918 1100 0925 0832 0832 Declaration of Local Emergency N/A N/A N/A 0940 0940 0940 Declaration of State of Emergency 1000 N/A N/A N/A N/A N/A Exercise Terminated 1415 1415 1429 1400 1400 1400 General Informational Message 0907 N/A N/A 0907 0907 0907 Early Precautionary Actions: Livestock 0932 N/A 1016 N/A N/A N/A Sheltered & Placed on Stored Feed Early Precautionary Action Decision: Relocation N/A N/A 1016

.0935 0935 0935 of School Children Early Precautionary Action Decision: Restriction 0944 N/A N/A N/A N/A N/A of Air, Water, Rail and Parks Closed Protective Action Recommendation: Evacuate 1212 N/A N/A N/A N/A N/A Sub-Areas 1, 2, 4 & Lake Erie and KI Administration 1st Protective Action Decision: Evacuate Sub-N/A N/A 1209 1207 1207 1207 Areas 1, 2, 4 & Lake Erie and K] Administration 1 st S iren Activation N/A N/A N/A 1215 N/A N/A 1 st EAS or EBS Message N/A N/A N/A 1223 N/A N/A Special Informational Bulletin: Curtail Water N/A N/A N/A 1232 1232 1232 Usage Protective Action Recommendation: Evacuate N/A 1314 N/A N/A N/A N/A Sub-Areas 1, 2, 4, 5 & Lake Erie and KI Administration 2nd Protective Action Decision: Evacuate Sub-N/A N/A 1330 1323 1323 1323 Areas 1, 2, 4, 5 & Lake Erie and K1 Administration 2nd Siren Activation N/A N/A N/A 1330 N/A N/A 2nd EAS or EBS Message N/A N/A N/A 1333 N/A N/A I

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Unclassified Radiological Emergency Prcparcdncss Program (REP)

Aftcr Action Rcport/lmprovcnmcet Plan Perry Nuclcar Pom cr Plant APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel that evaluated the Perry Nuclear Power Plant REP Partial Participation Plume Exposure Pathway Exercise on September 28, 2010. The list includes the evaluation team leadership and all evaluators. The organization each evaluator represents is indicated by the following abbreviations:

DHS/FEMA - Department of Homeland Security/Federal Emergency Management Agency ICF - ICF Consulting Title, Name, Organization Radiological Assistance Committee, Chairman - William E. King - DHS/FEMA Exercise Director - Gary L. Naskrent - DHS/FEMA Assistant Exercise Director - Dwaine Warren - DHS/FEMA Site Specialist - Bridget Ahlgrim - DHS/FEMA Team Leader - State of Ohio - Carolyn Sturghill - DHS/FEMA Team Leader - Lake County - Bridget Ahlgrim - DHS/FEMA Team Leader - Ashtabula County - Edward Diaz - DHS/FEMA Team Leader - Geauga County - James King - DHS/FEMA 53

Unclassified Radiological Emergency Preparedncss Program (REP)

After Action Report/[mprovement Plan Perry Nuclear Power Plant I

I DATE: 2010-09-28, SITE: Perry Nuclear Power Plant, OH

.L."A.:!:N EVAL)A.

U AGENCY State of Ohio - Initial Notification Point Frank Cordaro ICF State of Ohio - Emergency Operations Center - Executive Room Frank Cordaro ICF Onalee Grady-Erickson ICF State of Ohio - Emergency Operations Center - Assessment Room Onalee Grady-Erickson ICF Reggie Rodgers ICF State of Ohio - Emergency Operations Center - Joint Infonnation Frank Cordaro

[CF Center State of Ohio - Lakeland Community College - Joint Information Henry.Christiansen ICF Center State of Ohio - Emergency Operations Facility Jon Christiansen ICF State of Ohio - Lake County Emergency Operations Center - State Raymond Wood ICF Radiological Analyst State of Ohio - Department of Natural Resources - Route Alerting Michael Meshenberg ICF Lake County - Initial Notification Point Clinton Crackel DHSIFEMA Lake County - Emergency Operations Center Kerris Bates DHS/FEMA Clinton Crackel DHS/FEMA Richard Grundstrom ICF Raymond Wood ICF Lake County - Field Monitoring Team Coordinator

  • Bridget Ahlgrirn Df-S/FEMA Raymond Wood ICF Lake County - Lakeland Community College - Joint Infbrmation George R MacDonald ICF Center Lake County - Field Monitoring Team #1 Gary Snodgrass ICF Lake County - Field Monitoring Team #2 Paul Connier ICF Lake County - Leroy Fire Department - Backup Route Alerting Wendy Swygert ICF Lake County - Fairport Harbor School District - Evacuation School David Petta ICF Lake County - Kirtland High School - Kirtland Fire Department -

Raymond Wood ICF Evacuee Registration Lake County - Kirtland High School - Kirtland Fire Department -

Raymond Wood ICF Evacuee Monitoring Lake County - Kirtland High School - Kirtland Fire Department -

Robert Jcffries ICF Evacuee Decontamination Lake County - Kirtland High School - Kirtland Fire Department -

Jon Christiansen ICF Evacuee Monitoring and Decontamination of Vehicles Lake County - Kirtland High School - Congregate Care Center Deborah Fulk DHS/FEMA Lake County - Madison Fire District - Medical Service -

Todd Sniffin

[CF Transportation Lake County - Tri-Point Medical Center - Medical Service - Facility Clayton Spangenberg ICF Lake County - Madison Local - Evacuation School Bruce Swiren 1CE Lake County - Peny Village Police Department - Traffic Control Clayton Spangenberg ICF Point/Access Control Point - Briefing Lake County - Perry Village Police Department - Traffic Control Henry Christiansen ICF Point/Access Control Point - Interview Lake County - Grand River Police Department - Traffic Control Todd Sniffin ICF Point/Access Control Point - Briefing Lake County - Grand River Police Department - Traffic Control Wendy Swygert lCF Point/Access Control Point - Interview Ashtabula County - Initial Notification Point Richard McPeak ICF I

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Unclassifiud Radiological Emcrgency Prcparcdncss Program (REP)

A [ter Action Rcpori/l mprovcmcni Plan Perry Nuclear Power Plant Ashtabula County - Emergency Operations Center James Groves ICF Mike Howe DHS/FEMA Debra Schneck HQ 1CF Ashtabula Count), - Lakeland-Comnmunity College - Joint information George R MacDonald ICF Center Ashtabula County - Saybrook Fire Department - Emergency Worker Bruce Swiren ICF Monitoring and Decontamination of Equipment and Vehicles Ashtabula County - Saybrook Fire Department - Emergency Worker Kerris Bates DHS/FEMA Monitoring and Decontamination Ashtabula County - Northwest Ambulance District - Medical Service - Richard McPeak ICF Transportation Ashtabula County - Geneva Police Department - Traffic Control David Petta ICF Point/Access Control Point - Briefing Ashtabula County - Geneva Police Department - Traffic Control Gary Snodgrass ICF Point/Access Control Point - Interview Ashtabula Count), - Harpersfield Volunteer Fire Department - Backup Debra Schneck ICF Route Alerting - Briefing Geauga County - Initial Notification Point Carl Bebrich DHS/FEMA Geauga County - Emergency Operations Center Carl Bebrich DHS/FEMA William O'Brien ICF Geauga County - Emergency Operations Center - Sheriffs Road Patrol Deborah Fulk DHS/FEMA

& Dosimetry Coordinator - Traffic and Access Control Briefing Including DCO Briefing Geauga County - Lakeland Community College - Joint Information George R MacDonald ICF Center Geauga County - Thompson Volunteer Fire Department - Route Robert Jeffries ICF Alerting_

Geauga County - Ledgemont School District - Evacuation School James Groves ICF Tem Leader 55

Unclassified Radiological Emergency Prcparedncss Program (REP)

I After Action Rcporl/Improvemcnt Plan Pcrry Nuclcar Power Plant APPENDIX D: ACRONYMS AND ABBREVIATIONS AcIronym MeanIng AC Ashtabula County ACP Access Control Points ARC American Red Cross ARCA Area Requiring Corrective Action BSI Body Substance Isolation CAD Computer Automated Dispatch CAS Crisis Action System CC Care Center CE County Engineer CPM Counts Per Minute DC Dosimetry Coordinator DCO Dosimetry Control Officer DHS Department of Homeland Security DRF Dosimetry Report Form DTL Dedicated Telephone Line EAL Emergency Action Level EAS Emergency Alert System ECL Emergency Classification Level ED Executive Director EDL Executive Decision Line EMA Emer gency Management Agency EMAD Emergency Management Agency Director EMD Emergency Management Director EMS Emergency Medical Services EMT Emergency Medical Technician EOC Emergency Operations Center EOF Emergency Offsite Facility EOP Emergency Operations Plan EPA Environmental Protection Agency EPI Emergency Public Information EPZ Emergency Planning Zone ER Emergency Room ERDS Emergency Response Data System ES Elementary School I

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Unclassified Radiological Emcrgcncy Prcparcdness Prourarn (REP)

Aftci Action JRcpo rLdIIIprOvelcielt Plan Pcrry Nuclcar Powur Planw EW FPM A Emeryencv Workers Federal Emnergencv Management Agencv FH Fairport Harbor FHSD Fairport Harbor School District FMTC Field Monitoring Team Coordinator GE General Emergency GIS Geospatial information Service GPD Geneva Police Department GPS Global Positioning System HFD Harpersfield Fire Department HS High School HSAS Homeland Security Advisory Systern ic incident Commander INM Initial Notification Message INP Initial Notification Point IWP Initial Warning Point JIC Joint lnfofrnation Center KSD Kirtland School District LC Lake County LCEMAD Lake County Emergency Management Agency Director LCEOC Lake County Emergency Operations Center LCES Lake County Educational Services LEADS Law Enforcement Automated Data System LEC Law Enforcement Coordinator LRDM Locker Room Decontamination Monitor MARCS Multi Agency Radio Communications System MDT Mobile Data Terminal MPA Metro Parks Authority NAD Northwest Ambulance District NDCL Notre Dame Cathedral Latin NDS Nuclear Data System NRC Nuclear Regulatory Commission NRF National Response Framework NWS National Weather Service OEMA Ohio Emergency Management Agency OEPA Ohio Environmental Protection Agency ORO Off-site Response Organizations OSHP Ohio State Highway Patrol OSL Optically Stimulated Luminescence OSLD Optically Stimulated Luminescence Dosimeter 57

Unclassified Radiological Emcrgcncy Preparedness Program (REP)

Aftcr Action Rcporl/lhnprovcmcnI Plan Pcrry Nucicar Powcr Plant I

I PAD Protective Action Decision PAG Protective Action Guidelines PAR Protective Action Recommendations PD Police Department PIO Public Infon-nation Officer PNPP Perry Nuclear Power Plant PR Press Releases PRD Penrnanent Record Dosimeter PSAP Public Safety Answering Point PVPD Perry Village Police Department RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Services RCS Reception Center Staff REA Radiological Exclusion Area REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RN Registered Nurse RO Radiological Officer RRA Resident Radiological Analyst SAE Site Area Emergency SIB Special Information Bulletins SNB Special News Bulletins SO Sheriffs Office SOG Suggested Operating Guideline SOP Standard Operating Procedure SRD Self Reading Dosimeters SSR Schools Services Representative SUV Sport Utility Vehicles TACP Traffic Access Control Point TBHBV Turbine Building Heater Bay Vent TCP Traffic Control Points TEDE Total Effective Dose Equivalent TL Team Leader TS Transportation Supervisor TSA Transportation Staging Area TSC Technical Support Center UE Unusual Event VHF Very High Frequency I

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Unclassified Radiological Emergency Preparedness Program (RLEP)

After Action Rcportl/hmprovmnent Plan Perry Nuclear Powcr Plant APPENDIX E: EXERCISE PLAN This appendix lists the exercise criteria that were scheduled for demnonstration in the Perry Nuclear Power Plant REP Partial Participation Plume Exposure Pathway Exercise on September 28, 2010, and the offsite extent-of-play agreement approved by DHS/FEM4A on September 2, 2010.

This exercise criteria, contained in FEMA Radiological Emergency Preparedness Exercise Evaluation Methodology, as published in the Federal Register Notice/Vol. 67, No. 80, dated April 25, 2002, represent a functional translation of the planning standards and evaluation criteria.ofNUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants",

November 1980.

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

Listed below are the specific REP criteria scheduled for demonstration during this exercise.

59

Unclassified Radiological Emcrgency Prcparcdncss Program (REP)

Aftcr Action Report/Irnprovcmcnt Plan Pcrr, Nuclear Power Plant PERRY NUCLEAR POWER PLANT PARTIAL PARTICIPATION EXERCISE EXTENT OF PLAY AGREEMENT I

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I State of Ohio 08/1.2/2010 SEPTEMBER 28, 2010 60 I

Unclassified Radiological Emcrgcncy Prcparcdncss Program (R-EPi Aftcr Action Rcpori/improvcmcn Plan Pcrr) NuLcecar Powcr Plani Criteria that can be re-demonstrated immediately for credit, at the decision of the evaluator, include the following:

3.a. 1, 3.d., 3.d.2, 6.a.1, 6.b.1, 6.c.1 and 6.d. 1. Criteria that may be re-dernonstrated, as approved on a case-by-case basis by the Chairperson of the Regional Assistance Committee, include the following: 2.a.1, 2.b.1, 2.b.2, 5.a. I and 5.b.1.

EVALUATION AREA 1 - EMERGENCY OPERATIONS MANAGEMENT Criterion I.a.l: OROs use effective procedures to alert, notify and mobilize emergency persormel and activate facilities in a timely marmer.

Extent of Play The State Emergency Operations Center (SEOC) and the Ohio Highway Patrol Dispatch Center will receive initial notification over the 24-hour phone line. Once the SEOC Assessment Room is activated all dedicated phone communications will be received there. The State will mobilize all the agencies that have responsibilities in the SEOC, including the Executive Room, Dose Assessment, State Joint Information Center (JIC); the county EOC's; and the PNPP JIC (Lakeland Community College) and Emergency Operations Facility (EOF). The state representatives assigned to the PNPP JIC and. EOF, and the county EOC's will be pre-positioned within approximately 20 minutes after the declaration of the Alert.

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

Extent of Play The baseline exercise for demonstration of this criterion was conducted in April 2002.

Criterion l.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.

Extent of Play Direction and control of state activities will be demonstrated at the SEOC. The Executive Director of Ohio EMA will be positioned in the SEOC Executive Room and will coordinate decisions on behalf of the Governor's office. The Ohio Department of Health is responsible for determining the State PAR in the SEOC Assessment Room and will provide periodic briefings to the.SEOC Executive Room.

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

61

Unclassified Radiological Emergency Prcparedncss Program (REP)

Afler Action Rcport/lmprovcmcnt Plan Pcrry Nuclear Power Plant I

Extent of Play I

The primary means of communications between the State EOC and the County EOCs, PNPP JIC and EOF is by commercial and/or dedicated telephone. Backup communications (radio and/or cellular phones) will be demonstrated.

Criterion L.e.]: Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

Extent of Play The state will demonstrate the use of equipment, maps and displays to support emergency operations. The maps traditionally used in the EOC will be available and used for exercise evaluation purposes.

EVALUATION AREA 2 - PROTECTIVE ACTION DECISION MAKING 3

Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of I

administrative limits or protective action guides.

Extent of Play I

The SEOC Assessment Room staff will consider PAGs and Administrative Limits to develop recommendations, including KI, based on their technical evaluation of the available data. Recommendations will be forwarded to the SEOC Executive group and subsequently to the Lake, Ashtabula and Geauga County EOC's. County EOC's will disseminate recommendations to their emergency workers. Field monitoring data will be provided to the SEOC Assessment Room via controller inj ects.

'I Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and ORO dose projections, as 3

well as knowledge of on-site and off-site environmental conditions.

Extent of Play 3

The SEOC Assessment Room will evaluate the licensee information and complete independent dose projections based on that information and controller injected I

(simulated) field-monitoring data. Assessment Room staff will evaluate the data and forward protective action recommendations to the SEOC Executive Room.

Approved recommendations will then be forwarded to the Lake, Ashtabula, and I

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Unclassified Radiological Emrcrgmcy Prcparcdttcss Program (REP)

.ttcr Action Rportlhmprovm cni Plat)

Purn' NucIcar Power Plato Geauga County EOCs via a dedicated conference line established in the Assessment Room.

This is a re-demonstration to clear the ARCA incurred during the April 20, 2010 Beaver Valley Power Station exercise.

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

Extent of Play The Governor or his designee will demonstrate.the ability to make appropriate protective action recommendations based on technical information from the SEOC Assessment Room. Recommendations concerning the use of KI for the general public and emergency workers and institutionalized are the responsibility of the Ohio Department of Health. They are made in the SEOC Assessment Room in compliance with the ODH KI policy and will accompany the protective action recommendation.

Coordination will take place in the SEOC Executive Room with Lake, Ashtabula and Geauga Counties to ensure consideration of local needs. After the decision is made, counties will disseminateprotective actions to the general public.

At least two (2) Protective Action Decisions will be demonstrated.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for specialpopulation groups.

Extent of Play The recommendation to take KI is developed by the Ohio Department of Health in the SEOC Assessment Room and accompanies the PAR. Upon approval in the SEOC Executive Room, it is then forwarded by the SEOC Assessment to Lake, Ashtabula and Geauga Counties for implementation.

See Lake, Ashtabula and Geauga Extent-of Play Agreements.

Criterion 2.d.l: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria.

Extent of Play 63

U nc lassified Radiological Emergency Preparedness Program (REP)

After Action Rcport/hmprovcmciv Plan Perry Nuclear Power Plant The State demonstrated this criterion at the June 2006 BVPS exercise. It will be demonstrated again at the June 2012 PNPP exercise.

Criterion 2.e.1: Timely re-location, re-entry 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.

3 Extent of Play The State demonstrated this criterion at the June 2006 BVPS exercise. It will be demonstrated again at the June 2012 PNPP exercise.

EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.I: The OROs issue appropriate dosimetry and procedures and manage radiological 3

exposure to emergency workers in accordance with the plan and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.

Extent of Play 3

The State Field Monitoring Teams (FMT's), Communication Van and Sample Screening Point will not be demonstrated this exercise. The State demonstrated this criterion at the Beaver Valley Power Station 2010 exercise. It will be demonstrated again at the April 2012 Perry Nuclear Power Plant exercise. Implementation will be demonstrated by county responders.

3 Implementation will be demonstrated for State personnel responding to the EOF.

Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend I

use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not the general public) is maintained.

I Extent of Play The State Field Monitoring Teams (FMT's), Communication Van and Sample Screening Point will not be demonstrated this exercise. The State demonstrated this criterion at the April 2010 Beaver Valley Power Station exercise. It will be 3

demonstrated again at the April 2012 Perry Nuclear Power Plant exercise.

Implementation will be demonstrated by county responders.

Implementation will be demonstrated for State personnel responding to the EOF.

No KI will be ingested.

3 64 I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvcinent Plan Perry Nuclear Powxcr Plant Criterion 3.c.1: Protective action decisions are implemented for special population groups within areas subject to protective actions.

Extent of Play N/A - This is a county function.

Criterion 3.c.2: OROs/school officials decide upon and implement protective actions for schools.

Extent of Play N/A - This is a county function.

Criterion 3.dMA: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.

Extent of Play The SEOC Dose Assessment Room in coordination with the SEOC Executive group will procedurally demonstrate restricting air, water and rail traffic within the Emergency Planning Zone.

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

Extent of Play

  • N/A

- This is a county function.

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

Extent of Play The State demonstrated this criterion at the June 2006 BVPS exercise. It will be demonstrated again at the June 2012 PNPP exercise.

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.

Extent of Play 65

Unclassified IRadiological Emergency Picparcdncss Programn (REP)

After Action Rcport/Improvcmcnl Plan Perry NuIclcar Powe Piam The State demonstrated this criterion at the June 2006 BVPS exercise. It will be I

demonstrated again at the June 2012 PNPP exercise.

Criterion 3.f.l: Decisions regarding controlled re-entry of emergency workers and relocation I

and return of the public are coordinated with appropriate organizations and implemented.

Extent of Play I

The State demonstrated this criterion at the June 2006 BVPS exercise. It will be 1

demonstrated again at the June 2012 PNPP exercise.

EVALUATION AREA 4 - FIELD MEASUREMENT AND ANALYSIS Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.

U Extent of Play The State Field Monitoring Teams (FMT's), Communication Van and Sample Screening Point will not be demonstrated this exercise. The State demonstrated this criterion at the April 2010 Beaver Valley Power Station exercise. It will be I

demonstrated again at the April 2012 Perry Nuclear Power Plant exercise.

Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize I

the release and to control radiation exposure.

Extent of Play U

The State Field Monitoring Teams (FMT's), Communication Van and Sample Screening Point will not be demonstrated this exercise. The State demonstrated this criterion at the April 2010 Beaver Valley Power Station exercise. It will be demonstrated again at the April 2012 Perry Nuclear Power Plant exercise.

3 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 detennine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media.

Extent of Play The State Field Monitoring Teams (FMT's), Communication Van and Sample Screening Point will not be demonstrated this exercise. The State demonstrated this criterion at the April 2010 Beaver Valley Power Station exercise. It will be demonstrated again at the April 2012 Perry Nuclear Power Plant exercise.

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Unclassified Radiological Emcrgcncy Prcparcdncss Program (REP)

Aftcr Action Rcport/improvcnicnl Plan Pcr-v Nuclear Power Plant Criterion 4.b.1: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making.

Extent of Play The State demonstrated this criterion at the June 2006 BVPS exercise. It will be demonstrated again at the June 2012 PNPP exercise.

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions.

Extent of Play The State demonstrated this criterion at the October 2006 PNPP exercise. It will be demonstrated again at the June 2012 PNPP exercise.

EVALUATION AREA 5 - EMERGENCY NOTIFICATION AND PUBLIC INFORMATION

.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 off-site emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include:

I. Identification of the state or local government organization and the official with the authority for providing the alert signal and instructional message

2. Identification of the commercial nuclear power plant and a statement that an emergency situation exists at the plant
3. Reference to REP-specific emergency infon-nation (e.g., brochures and information in telephone books) for use by the general public during an emergency
4. A closing statement asking the affected and potentially affected population to stay tuned for additional information.

Extent of Play The State will consult with the county EOCs in the Executive Room to determine the best immediate protective action for the populace. Once a decision is reached that requires the activation of the alert and notification system, Lake County in coordination with Ashtabula and Geauga counties will simulate the activation of the sirens and providing EAS messages to the EAS Station. (See the Lake, Ashtabula, and Geauga counties Extent of Play Agreements for-further details.)

The State also notifies the public on Lake Erie (within the 10-mile EPZ) through the US Coast Guard as supported by Ohio Department of Natural Resources (ODNR).

67

Unclassified Radiological Emcrgcncy Prcparcdness Program (REP)

Aftcr Action Rcport/Improvccmw Plan Pcrry' Nuclcar lowcr Plant An interview will be conducted with ODNR at 10:00 am on Wednesday, September U

29 at the Ashtabula Division of Watercraft offices in Ashtabula, Ohio.

Criterion 5.a.2: [RESERVED]

I Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system.

Extent of Play N/A - This is a county function.

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

I Extent of Play The State PIO and a representative from the Ohio Department of Health will be present at the PNPP JIC to address protective actions being implemented and the activities taking place at the State and count), level. Public information representatives from Ohio EMA will be present in the SEOC (JIC) to communicate I

with the PNPP JIC.

A Public Inquiry telephone will be established and demonstrated at the SEOC JIC I

and driven by controller injects. Public Inquiry will address at least 3 calls per hour once Site Area Emergency is declared for two (2) hours. Trends in rumors will be identified and responded to as needed.

EVALUATION AREA 6 - SUPPORT OPERATION/FACILITIES Criterion 6.a.l: The reception center/emergency worker facility has appropriate space, adequate resources: and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

Extent of Play N/A - This is a county function.

Criterion 6.b.l: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles.

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Unclassified Radiological Erncrgency Prcparcdncss Program (REP)

After Action Rcport/lmprovcmcnt Plan Pcrr), Nuclcar Powcr Plant Extent of Play N/A - This is a county function.

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.

Extent of Play N/A - This is a county function.

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

Extent of Play N/A - This is a county function.

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Unclassified Radiological Emcrgcncy Prcparcdncss Progralrl (REP)

Pcrr, Nuclear Power Plant After Action Rcporl/hrnprovemcnl Plan STATE OF OHIO INITIAL NOTIFICATION POINT Address:

Ohio Emergency Management Agency (OHP Dispatch) 2855 W Dublin-Granville Rd Columbus OH 43235-2206

Contact:

Carol O'Claire Telephone:

(614) 799-3915 Date:

Tuesday, 9/28/2010 Time:

Start of exercise.

STATE EMERGENCY OPERATIONS CENTER Address:

Ohio Emergency Management Agency 2855 W Dublin-Granville Rd Columbus OH 43235-2206

Contact:

Carol O'Claire Telephone:

(614) 799-3915 Date:

Tuesday, 9/28/2010 Time:

Start of exercise.

STATE ASSESSMENT ROOM Address:

Ohio Emergency Management Agency 2855 W Dublin-Granville Rd Columbus OH 43235-2206

Contact:

Carol O'Claire Telephone:

(614) 799-3915 Date:

Tuesday, 9/28/2010 I

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Time:

Start of exercise.

PNPP Joint Information Center Address:

Lakeland Community College

Contact:

Telephone:

Date:

Tirme:

Performing Arts Center 7700 Clocktower Drive Mentor, OH Tarnara McBride (614) 799-3695 (office); (440)269-7107 or (440)269-7122 Tuesday, 9/28/2010 30 to 45 minutes after ALERT.

EMERGENCY OPERATIONS FACILITY (EOF)

Address:

Perry Nuclear Power Plant 10 Center Road Perry OH 70

UPnclassiJied Radiological Emcrgency Preparedness Program (REP)

After Action Rcport/lmprovercnt Plan Perry NLIclcar Power Planm

Contact:

Telephone:

Date:

Time:

Brian Martin (419)734-5433 (office); (440)280-5483 or 5746 (EOF)

Tuesday, 9/28/2010 30 to 45 minutes after ALERT ODNR INTERVIEW Address:

Ashtabula Div. of Watercraft I Front Street Ashtabula, Ohio 44004

Contact:

Scott Stauffer Telephone:

440-964-0518 Date:

Wednesday, 9/29/2010 Time:

10:00 am 71

Unclassified Radiological Emergency Prcparcdncss Program (REP)

After Action Report/IniprovcinCew Plan Perry NIclCar Power Plant STATE OF OHIO Demonstrating Agency/

Exercise Controller/

Location Date/

Time Initial Notification Point Ohio Emergency Management Agency 2855 Dublin Granville Road Columbus, OH 09/28/10 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />

Contact:

Carol O'Claire (614) 799-3915 Directions: The State EOC is located on State Route-161, (2855 W. Dublin Granville Road),

- w ema-S-awm il-R*-ad-and-SýR--3-1-5 _Roa-dwayen tra ne-is-to-t-he-sout-h-s ide-of-S-R-q-6 (a-t-the---

ODOT and Med-Flight signs). Stay straight on roadway to the second driveway and park. The EOC building entrance is at the top of the stairway. Upon entry, request that the guard notify your contact.

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State Emergency Operations Center Ohio Emergency Management Agency.

2855 Dublin Granville Road Columbus, OH 09/28/10 0800 - 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />

Contact:

Carol O'Claire (614) 799-3915 State Assessment Room Ohio Emergency Management Agency 2855 Dublin-Granville Road COlumbus OH 09/28/10 0800 - 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />

Contact:

Carol O'Claire (614) 799-3915 Emergency Operations Facility (EOF)

Perry Nuclear Power Plant 10 North Center Road Perry, OH 09/28/10

-0930 hours I

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Unclassified Radiological Emergency Prcparcdncss Protgram (REI')

Aftcr ACLiOnl Rcpor1!lmnprovcMcn1 Plan Purn3, Milcd=il Poweir Plant STATE OF OHIO (continued)

Demonstrating Agency/

Location Date/

Time Exercise Controller/

[Exercise Evaluatorl

Contact:

Brian Martin, State of Ohio EOF Liaison (440) 280-5746 Directions: The EOF is located at the Perry Nuclear Power Plant (10 North Center Road) on the first floor of the Training and Education Center (TEC Building) which is the two-story, brick and cement building off to the left of the road upon entering the PNPP grounds. Take Rt. 2 to the end and continue straight ahead on U.S. Rt. 20 to Center Road. Turn left (north) on Center Road and enter PNPP. The TEC is the first drive on the left.

Joint Information Center Lakeland Community College Performning Arts Center 7700 Clocktower Drive Mentor, OH 09/28/10

-0930 Hours

Contact:

State of Ohio Public Information Officer (PIO)

(440) 269-7107 or (440) 269-7122/7115/7116 Directions: The main entrance (Clocktower Drive) is from Rt. 308, just south of Interstate 90.

(Also, there is a back entrance from Garfield Road not far from the Lake County EOC.) The Performing Arts Center is to the immediate left of the clock tower. Enter the doors directly under the overhead walkway. If the security personnel will not admit you, ask for an Exercise Controller or the Government Liaison person.

Parking: Secured parking is available in the lot directly across from the clock. The parking code to enter will be given at the pre-exercise briefing.

Lake Erie Alert and Notification Ashtabula Div. of Watercraft I Front Street Ashtabula, Ohio 44004 9/29/10 1000 Hours

Contact:

Scott Stauffer 440-964-0518 73

Unclassified Radiological Emcrgcncy Prcparcdncss Program (REP)

I Pcrr, Nocicar Powcr Plant After Action Rcport/linprovcmcnt Plan I

I LAKE COUNTY OHIO I

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Extent-of-Play Agreement For the Perry Nuclear Power Plant Evaluated Exercise Week of September 27, 2010 74

Unclassified Radiological Emcrgcncy Prcparcdncss Program (REP)

Atficr Acion Rcport/hmprovcmcrn Plan Pcrrv' Nucicar Powcr Plant The exercise will take place on September 28, 2010.

Criteria that can be re-demonstrated immediately for credit, by a decision of the evaluator, include the following: 3.a.1, 3.d.I, 3.d.2, 6.a.], 6.b.], 6.c.1 and 6.d.l. Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chain-nan of the Radiological Preparedness Coordinating Committee, include the following: 2.al, 2.b.l, 2.b.2, 5.a.1 and 5.b.l.

EVALUATION AREA 1 - EMERGENCY OPERATIONS MANAGEMENT Criterion 1.a.l: OROs use effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely mranner.

Extent of Play Lake County EOC Staff will mobilize upon notification from the Lake County Sheriff s Central Communications Dispatch Center, which is the 24-hour notification point and receives the call via a dedicated line from the Perry Plant.

Full field notification utilizing primary means of communication will be completed one time only from the EOC, at the Site Area Emergency classification.

Field agency demonstrations will be conducted out-of-sequence and participants will be pre-positioned.

Field activity participants Leroy Fire Department - Back-up Route Alerting Kirtland Fire Department - Public Monitoring & Decontamination at Kirtland High School Care Center Madison School District - Risk School Fairport Harbor School District - Risk School American Red Cross - Evacuee registration & congregate care Lake County General Health District - KI for the general public TriPoint Medical Center - Medical Services (MS-1)

Peny Village Police Department - Traffic/Access Control Grand River Police Department - Traffic/Access Control Madison Fire District - MS-I Transportation Laketran - Transportation for Fairport Harbor School District 75

Unc.assificd Radiological Eniclgcncy Prcparcdncss Program (REP)

A['cr Action Rcporl/Improvcmcnt Plan Pcrry Nuclcar Plac Pa[

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

I Extent of Play 3

N/A - The EOC and JIC have both been evaluated; no changes have been made.

Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

Extent of Play Direction and control of emergency operations will be demonstrated in accordance with the exercise scenario, the Lake County Radiological Emergency Response Plan, Agency SOG and as appropriate for out-of-sequence field demonstrations.

Criterion 1.d.1: At least two communication systems are available and operate properly and communication links are established with appropriate locations.

Communications capabilities are managed in support of emergency operations.

Extent of Play Primary (dedicated phone lines and commercial telephone) and secondary (radio/pagers/cell phones) means of communications will be demonstrated at the EOC and as appropriate for out-of-sequence field demonstrations. Controllers will drive field play.

3 Full field notification utilizing primary means of communication will be completed one time only from the EOC, at the Site Area Emergency classification.

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

Extent of Play The EOC will demonstrate the use of equipment, maps and displays to support emergency operations.

3 In addition to the KI that the local health department made available to the general public to pick up in 2010, there is a quantity stockpiled at the EOC that would be transported to the care centers and distributed by the local health department, as requested.

76

Unclassified Radiological Emergency Prcparcdncss Program (REP)

After Action Rcport/linprovenicnt Plan Pcrry Nuclear Power Plant EVALUATION AREA 2 - PROTrECTIVE ACTION DECISION MAKING Criterion 2.a.1: OROs use a decision--making process, considering relevant factors and appropriate coordination, to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

Extent of Play Lake County relies on the Ohio Department of Health (ODH) for the recommendation to take KI. For out-of-sequence field agency demonstrations, this will be demonstrated by interview with exercise participants or by controller inject, if necessary.

The use of a Controller inject will begin the process of authorization for radiation exposures in excess of administrative limits.

Criterion 2.b.l: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

Extent of Play N/A - Lake County does not demonstrate this criterion; it relies on the State of Ohio.

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

Extent of Play The Lake County EOC Executive Group will demonstrate this criterion in coordination with Geauga and Ashtabula counties' Executive Groups and the State of Ohio.

The Director, or designee, of the Ohio Department of Health (ODIH) makes the decision for the general public and emergency workers to take KI. The ODH through the local health department makes KI available tothe general public, by pre-distribution and by supplies available for distribution at the time of the emergency at care centers.

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Unclassified Radiologica) Emcrgcncy' Prcparcdncss Program (RtEP)I Aftcr Action Rcport/lmprovcnicnit Plan i

Pcrry Nucicar Powcr Plani Criterion 2.c.l: Protective action decisions are made, as appropriate, for special I

population groups.

Extent of Play The Lake County EOC Executive Group will demonstrate this criterion in coordination with Geauga and Ashtabula counties' Executive Groups. Typically, schools relocate at Site Area Emergency per procedures. If not relocated prior to General Emergency, schools follow the protective action decisions for the general public; they are not considered a special population group.

Criterion 2.d.l: Radiological consequences for the ingestion pathway are assessed and 3

appropriate protective action decisions are made based on the ORO planming criteria.

Extent of Play 1

N/A - Lake County relies on the State of Ohio.

Criterion 2.e.l: Timely re-location, re-entry 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.

Extent of Play N/A - This Criterion was successfully demonstrated in 2008.

EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION I

Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures and manage radiological exposure to emergency workers in accordance with the plan and procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.

3 Extent of Play The Lake County EOC Radiological Officer will demonstrate radiation exposure control capabilities. Dosimetry and exposure control procedures will be demonstrated by field agencies during out-of-sequence exercise activities.

Field activity participants:

Dosimetry briefing:

Leroy Fire Department - Back-Up Route Alerting Kirtland Fire Department - Public Monitoring/Decontamination at care center 78 I

Unclassified Radiological Emcrency Prcparedness Program (REP)

After Action Report/improvement Plan Pcrry Nuclear Power Plant Grand River Police Department - Traffic/Access Control at department Perry Village Police Department - Traffic/Access Control at department Madison Fire District - MS-1 Transportation Madison School District - Interview of Transportation Supervisor & bus operator only TriPoint Medical Center - MS-I Laketran (provides transportation for Fairport Harbor School District) - Interview of Transportation Supervisor & bus operator only Criterion 3.b.l: KI and appropriate instructions are available-should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not the general public) is maintained.

Extent of Play The Ohio Department of Health (ODH) will make recommendations regarding the use of KI. Lake County's preparedness measures for KI include pre-distribution to emergency response agencies and to the general public, if they chose to pick it up at designated centers. At the time of the emergency, the agencies distribute the dosierntry and KI to the emergency workers. Demonstration of this criterion may be facilitated by discussion with the Lake County General Health District Coordinator at the EOC. For field agency demonstrations, KI procedures will be demonstrated by interview with exercise participants or by controller inject, if necessary.

Dosimetry and KL have been pre-distributed to Offsite Response Organizations (OROs); the monitoring kits and dosimetry are exchanged annually by the State of Ohio. Supporting documentation is included in the Annual Letter of Certification.

Extent of Play Interview the EOC Lake County General Health District (LCGHD) representative during the exercise regarding the distribution of KI for the public at the care center.

Criterion 3.c.1: Protective action decisions are implemented for special population groups within areas subject to protective actions.

Extent of Play Notification to individuals with special needs within the Lake County portion of the EPZ will be simulated. A list of special needs residents within the Lake 79

U n clas si fied Radiological Emcrgcncy Prcparcdness Programn (REP)

Alicr Action Rcport/Improvcnicnl Plan Perry Nuclear Power Plant County portion of the EPZ is maintained by the Lake County Department of Job U

and Family Services and the Lake County EMA.

The Department of Job and Family Services Coordinator at the EOC will coordinate special needs notification activities and, upon request, will present the confidential list for review by the FEMA evaluator. At least 4 transportationI providers, which in Lake County include school districts, will be contacted to ensure availability of buses and drivers.

Criterion 3.c.2: OROs/school officials decide upon and implement protective actions for schools.

Extent of Play The school districts will demonstrate this criterion out-of-sequence, by interview with the superintendent, high school principal, transportation supervisor and a bus operator. School officials follow the protective action decisions made by the elected officials for the general public, if the school I

districts' superintendents have not made the decision to relocate prior to a General Emergency.

The use of dosimetry and KI will be discussed with transportation personnel only. If the school district has elected to have KI available for students, it is an internal policy and will be discussed during the interview.

During the Exercise all schools in the EPZ will be notified as identified in Criterion l.a. 1, Extent of Play. The EOC County School Services Representative will follow their Suggested Operating Guideline (SOG) during the Exercise.

There will be no movement of buses or students.

Field agency participants Fairport Harbor School District 3

Madison School District Laketran - provides transportation for Fairport Harbor School District Criterion 3.d.l: Appropriate traffic and access control is established.

Accurate instructions are provided to traffic and access control personnel.

Extent of Play 80 I

LiUn class if ed Radiological EtncrgcncY Prcparcdncss Program (IEP)

After Action Rcport/Improvcrncnt Plan Pcrr" Nuclcar Powcr Plant A representative of the police departments listed will demonstrate Traffic and Access Control out-of-sequence, by interview at their respective stations.

Notification of rail, water and air traffic is a State function.

Field activity participants:

Perry Village Police Department Grand River Police Department Criterion 3.d.2: Impediments to evacuation are identified and resolved.

Extent of Play Lake County EOC will demonstrate the capability to identify and take the appropriate actions in dealing with impediments to evacuation. Actual resources will not be utilized. If an impediment cannot be removed in a timely manner, the decision to reroute traffic will be discussed and implemented by the appropriate EOC Staff.

Criterion 3.e.l: The ORO demonstrates the availability and appropriate use of.adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective.

actions.

Extent of Play N/A - Lake County relies on the State of Ohio.

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.

Extent of Play N/A - Lake County relies on the State of Ohio.

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

Extent of Play N/A - This Criterion was successfully demonstrated' in 2008.

81

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improv'emenl Plan Perr. Nuclear Power Plant EVALUATION AREA 4 - FIELD MEASUREMENT AND ANALYSIS Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.

Extent of Play Lake County General Health District will demonstrate the use of two Field Monitoring Teams (FMTs), in sequence.

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

Extent of Play Lake County Health District will demonstrate the use of two Field Monitoring Teams (FMTs), in sequence.

Lake County FMT data is utilized for validation purposes and is not used to generate PARs.

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.

Extent of Play For the exercise, expired silver zeolite cartridges will be used; new cartridges will be available for the FEMA evaluator's observation.

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

Extent of Play N/A - Lake County relies on the State of Ohio 3

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions.

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Unclassified Radiological Emcrgcncy Preparedness Program (REP)

After Action Report/lmprovcmcnt Plan Pcrry Nuclcar Power Plant Extent of Play N/A - Lake County relies on the State of Ohio EVALUATION AREA 5-EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Criterion 5.a.l: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include:

1. Identification of the state or local government organization and the official with the authority for providing the alert signal and instructional message
2. Identification of the commercial nuclear power plant and a statement that an emergency situation exists at the plant
3. Reference to REP-specific emergency information (e.g., brochures and information in telephone books) for use by the general public during an emergency
4. A closing statement asking the affected and potentially affected population to stay tuned for additional information.

Extent of Play Upon a protective action decision (PAD) by the combined Executive Groups of Ashtabula, Geauga and Lake counties, the Lake County EOC Staff will prepare the appropriate Emergency Alert System (EAS) message and simulate sounding the sirens and sending the message over the EAS system. A quiet siren test will be demonstrated by the Lake County EOC in lieu of an actual siren sounding.

Simulation of sending the EAS message(s) will be conducted as follows:

The procedure for the EAS encoder will be followed to deliver the message to WTAM, the Local Primary Station, with the exception that the telephone number to the station will not be dialed. By not connecting to WTAM, there is no possibility of accidentally broadcasting the message over one or more of the participating EAS stations.

The "send' button on the Lake County EAS encoder will be depressed and this action will activate the outgoing alert light and playback of the recorded message.

Also, a data sheet will automatically be printed by the encoder and the time recorded on the data sheet. Ashtabula and Geauga counties have EAS equipment (encoder) and could perform this function, if necessary.

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Unclassified Radiological Emcrgcncy Prcparcdncss Program (REP)

Aftcr Action Rcport/Improvcmcnt Plan Pcrry Nuclear Powcr Plant Lake County will fax a copy of the EAS message(s) to the Joint information Center (JIG) where Public Infor-nation Officers (PIOs) may distribute hard copies to the news media representatives and may, if time and circumstances permit, mnake an announcement regarding the message. Otherwise, the EAS message can be announced at the next scheduled press briefing or in response to news media inquiries about the PAD message. rin delivering information about the EAS message just released, the counties' PlOs may indicate that a corresponding Special News Bulletin (SNB) will be issued soon. Lake County will also fax a copy of the EAS message to Ashtabula and Geauga counties' EOCs.

I Criterion 5.a.2: (RESERVED)

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

situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system.

Extent of Play 3

The Leroy Fire Department will demonstrate back-up route alerting as an out-of-sequence, prepositioned field activity. One predeterrnined siren located in Leroy will be out of service (simulated) and back-up route alerting will be conducted in I

the siren coverage area. Use of the mobile PA system will be simulated during the demonstration; an audible PA test will be conducted prior to departure. The demonstration will be initiated by the exercise controller.

Field Activity Participants 3

Leroy Fire Department Criterion 5.b.l: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.

Extent of Play Based upon the combined PAD(s) of the Executive Groups of Ashtabula, Geauga and Lake Counties, the Lake County EOC Staff will prepare and issue the appropriate EAS message(s) and the corresponding Special News Bulletin(s)

(SNB). SNB's give the same message as their corresponding EAS message U

except SNB's provide greater detail. Lake County will FAX the SNB(s) to the Joint Information Center (JIG) where one of the counties' PIOs will represent the 84

Unclassified Radiological Emcrgcncy Prcparedncss Program (REP)

Aftcr Action Report/Improvement Plan Pcrry Nuclcar Powcr Plant three counties by directly proceeding to the briefing room and reading the contents of the message to the assembly of news media representatives and answering any questions pertaining to the message. This briefing should begin in a timely maimer after transmission of the EAS message fiom the Lake County EOC to the Local Primary EAS Station. Hard copies of the SNB(s) will be distributed to the news media representatives.

Ashtabula, Lake and Geauga counties will also coordinate release of other informational and instructional message as necessary. Such messages may include Special Information Bulletins (SIB), which are a third category of prepared messages contained in the counties' "SOG for EAS Messages, Special News Bulletins and Special Information Bulletins pertaining to the Perry Nuclear Power Plant," These SIB's are considered routine, meaning that they are to be delivered by one of the counties' PiOs at the next scheduled press briefing.

Public Inquiry Workers at the EOC will answer calls from the public. At least one trend will be demonstrated.

EVALUATION AREA 6 - SUPPORTr OPERATION/FACILITIES Criterion 6.a.1: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

Extent of Play Kirtland Fire Department will demonstrate the evacuee portion of this criterion out-of-sequence at Kirtland High School. One locker room will be fully set up and demonstrated; a walk-through of the remaining locker room will be conducted upon request.

Six (6) monitoring demonstrations will be conducted using a portal monitor. One individual with simulated contamination will be walked through the monitoring/decontamination process, which includes whole body monitoring using a survey meter; contamination levels will be provided by a controller.

Decontamination will be simulated.

Monitoring and decontamination of evacuees' vehicles will be conducted by interview only; no actual monitoring or decontamination will take place.

Field activity participants Kirtland Fire Department - Public M/D American Red Cross - Evacuee registration 85

Unclassified Radiological Emcrgcncy Preparedness Program (REP)

After Action Repotl/lmprovcmcnt Plan Perry Nuclear Power Plant Lake County General Health District - KI for the general public I

Criterion 6.b.l: The facility/ORO has adequate procedures and resources for the I

accomplishment of monitoring and decontamination of emergency worker equipment including vehicles.

Extent of Play U

N/A - Lake County will not demonstrate this criterion. Mentor Fire Department I

demonstrated the Lake County Emergency Worker Monitoring Decontamination Station during the 2006 Evaluated Exercise.

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 plamning guidelines. Managers demonstrate the procedures to assure that evacuees have I

been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities.

3 Extent of Play The American Red Cross will demonstrate the congregate care center portion of I

this criterion out-of-sequence at Kirtland High School. American Red Cross personnel will provide a walk-through of the facility and describe their capabilities. Set-up of care center equipment or supplies will be at the discretion of the American Red Cross.

.One person will be processed through the Red Cross portion and a copy of the U

paperwork will be provided to the Evaluator.

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.

3 Extent of Play Madison Fire District will demonstrate this criterion in sequence with the on-site scenario. A simulated contaminated/injured victim from the Perry Power Plant will be transported to TriPoint Medical Center. No emergency lights and/or

.1 sirens will be used.

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Unclassified Radiological Emercency Prcparcdncss Program (REP)

After Action Rcpori!'rnprovcmcnt Plan Pcrr Nuclear Powcr Plaint LAKE COUNTY Demonstrating Agency/

Location Date/

Time School District Fairport School District Superintendent's Office Board of Education 329 Vine Street Fairport, OH 09/27/10 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />

Contact:

Dominic Paolo, Superintendent (440) 354-5400 Directions: Take Rte 2 east to the OH-283/OH-535 exit; go toward Fairport Harbor.

Merge onto Richmond Street; turn slight right onto OH-535/East St. Continue on East St to New 4th Street and turn left; turn right on \\Vine St.

NOTE: Laketran provides bus services for the Fairport School District and will provide a Transportation Supervisor and bus operator for the interview at the school.

Lake County Field Monitoring Teams 09/28/10 Lake County 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> Emergency Operations Center 8505 Garfield Road Mentor, Ohio

Contact:

Bert Mechenbier, Lake County General Health District FMT Coordinator (440) 350-5486 Directions: Lake County EOC located at the end of Garfield Road. The EOC is accessible from (1) Rt. 84 (Mentor) or (2) Lakeland Community College Campus.

Note: The 2 Lake County Field Monitoring Teams will conduct their demonstration in sequence with the evaluated exercise on Tuesday, September 28, 2010, beginning from the Lake Count), EOC.

Back-Up Route Alerting Leroy Fire Department 13028 Leroy Center Road Leroy, OH

Contact:

Chief Frank Huffman (440) 254-4124 09/27/10 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> 87

Un classaified Radiological Emergency Preparedness Program (REP)

After Action Rcport/lmnprovcmcnt Plan Perry Nuclcar Power Plant Demonstrating Agency/

Location cont'd Date!

Time Directions: Take 1-90 east to Vrooman Road and turn right (south). Travel approximately I mile to Leroy Center Rd and turn left; the station is on the right.

Monitoring/Public Kirtland High School 9150 Chillicothe Road Kirtland, OH 44094 Demonstrating Agency: Kirtland Fire Department

Contact:

Chief Tony Hutton (440) 256-8979 09/27/10 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> Directions: Take Route 306 south from 1-90, approximately 2 miles. Kirtland High School is on the right (west).

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I Congregate Care Center/Registration Kirtland High School 9150 Chillicothe Road Kirtland, OH 44094 Demonstrating Agency: American Red Cross

Contact:

Michelene Holland (216) 361-4505 09/27/10 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> Directions: See above Initial Notification Point Lake County Emergency Operations Center (EOC)

Central Communications Center 8505 Garfield Road Mentor, OH

Contact:

Larry Greene, Director (440) 350-5499 09/28/10

-0800 hours Directions: The Central Communications Center is co-located with the Lake County EOC, I

which is located at the end of Garfield Road. The EOC is accessible from (1) Rt. 84 (Mentor) or (2) Lakeland Community College Campus Emergency Operations Center Lake County EOC 8505 Garfield Road Mentor, OH 09/28/10

-0800 hours I

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Unclassified Radiological Emcrgency Prcparcdness Program (REP)

Aftcr Action Rcport/Inmprovcmccnt Plan PcrrN Nuclcar Power Plant Demonstrating Agency/

Location con'd Date!

Time

Contact:

Larry Greene, Director (440) 350-5499 Directions:.see above Joint Information Center Lakeland Community College 7700 Clocktower Drive Mentor, OH 09/28/10

-930 hours

Contact:

Byron Landolfi, Ashtabula County Public hiformation Officer (PIO)

(440) 269-7107 or (440) 269-7122/7115/7116 Medical Services - Transportation 09/28/10 Perry Nuclear Power Plant

-0730 hours Unit # 1, Controlled Access Area 10 North Center Road Perry, OH Demonstrating agency: Madison Fire District 33 Lake St. (Rt. 528)

Madison, OH 44057

Contact:

Chief Eugene Lutz (440) 428-1522 Directions and Notes: The Medical Services demonstration will be conducted in sequence with the evaluated exercise. Contact the Exercise Controller, who will be waiting outside the Primary Access Facility (PAF) at the Perry Power Plant. The Madison Fire District will respond to the Perry Nuclear Power Plant, enter through the PAF vehicle lock, and travel to the transfer point from the Radiological Restricted Area.

Special access and dosimetry is required for all participants, including the FEMA Evaluator. An Exercise Controller will escort the FEMA Evaluator inside the plant's controlled area.

Medical Services - Facilities TriPoint Medical Center 7590 Auburn Road Concord, OH 44077 09/28/10 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br />

Contact:

Pat Cassella (440) 477-7628 (cell) or 216-634-4109 (pager) 89

Unclassified Radiological Emcrgcncy Prcparcdncss Program (PREP)

Perry Nuclcar Powvcr Plant Aftcr Action Rcport/improvcmcnt Plan Demonstrating Agency/

Location Date/

Time Directions: Take Rt. To Rt. 44 south to Auburn Road (approximately 1/8 mi. s of 1-90) and turn right; TriPoint is approximately 1/4 mile on the right.

Joint Information Center 09/28/10 Lakeland Community College 1000 - 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> 7700 Clocktower Drive Mentor, OH

Contact:

Chris Hodges, Lake County Public Information Officer (PIO)

(440) 269-7107 or (440) 269-7122/7115/7116 Directions: The main entrance (Clocktower Drive) is from.Route 308, just south of Interstate 90. (Also, there is a back entrance from Garfield Road not far fi-om the Lake County EOC.) The Performing Arts Center is to the immediate left of the clock tower.

Enter the doors directly under the overhead walkway. If the security personnel will not admit you, ask for an Exercise Controller or the Government Liaison person.

Parking: Secured parking is available in the lot directly across from the clock. The parking code to enter will be given at the pre-exercise briefing. The gate lifts automatically when exiting. Parking is also available in the student parking lots Traffic/Access Control 09/29/10 Perry Village Police Department 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> 3758 Center Road Perry, OH 44081

Contact:

Chief Ed Matty Phone: (440) 259-2671 Directions: Take Rt. 20 east to Center Road and turn right-(south); the PD is on the right.

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Traffic/Access Control Grand River Police Department 205 Singer Avenue Grand River, OH 44045

Contact:

Chief Barry Dodd Phone: (440) 352-1287 09/29/10 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> Directions: Take Rt. 44 north to Lake Shore Blvd. (Rt. 283) and turn right (east); (Lake Shore Blvd becomes Singer Avenue) and travel approximately I mile.

90

Unclassified Radiological Emcrgency Preparedness Program (REP)

After Action ReporlfImprovcmcnt Plan Pcrr-.' Nuclear Power Plani Demonstrating Agency/

Location Date/

Time School District Madison School District Superintendent's Office Board of Education 6741 North Ridge Road Madison, OH 09/29/10 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />

Contact:

Dr. Roger Goudy, Superintendent (440) 428-2166 Directions: Take Rte. 20 east to just past Route 528. The Madison Board of Education is

< 1/10 mi on the left (north) side.

91

Unclassified Radiological Emergency Preparcdness Program (REP)

Aftcr Action Rcport/lhnprovcenicl Plan Perry Nuclcar Powcr Plant I

I ASHTABULA COUNTY OHIO Extent-of-Play Agreement For the Perry Nuclear Power Plant Evaluated Exercise 1

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I Week of September 27, 2010 92

Unclassified Radiological Emergency Prcparcdncss Program (REP)

Aftcr Action Report/Improvenient Plan Perrty Nuclear Power Plant The EOC portion of the exercise will take place on September 28, 2010.

Criteria that can be re-demonstrated immediately for credit, by a decision of the evaluator, include the following: 3.a.1, 3.d. 1, 3.d.2, 6.a.1, 6.b.1, 6.c.] and 6.d. 1. Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chairnan of the Radiological Preparedness Coordinating Committee, include the following: 2.a. 1, 2.b.I, 2.b.2, 5.a. I and 5.b.1 EVALUATION AREA I - EMERGENCY OPERATIONS MANAGEMENT Criterion L.a.l: OROs use effective procedures to alert, notify and mobilize emergency personmel and activate facilities in a timely manner.

Extent of Play Ashtabula County EOC Staff will mobilize upon notification fromn the Ashtabula County Sheriffs Dispatch Center, which is the 24-hour notification point and receives the call via a dedicated line from the Perry Plant. Full field notification utilizing primary means of communication will be completed one time only from the EOC, at the Site Area Emergency classification.

Field agency demonstrations will be conducted out-of-sequence and participants will be pre-positioned.

Field activity participants Harpersfield Volunteer Fire Department - Back-up Route Alerting Geneva Police - Traffic/Access Control Saybrook Township Fire Department - Emergency Worker Monitoring &

Decontamination at Lakeside High School Northwest Ambulance District (NAD) - MS-I Transportation (at the Lakeside High School Emergency Worker Monitoring &

Decontamination Station)

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

Extent of Play N/A - The EOC and JIC have both been evaluated; no changes have been made.

Criterion 1.c.l: 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.

93

U nclassified Radiological Emnergency Preparedness Program (REP)

Aftcr.Action Repo r/lmpro',cmcnat Plan Perry Nuclear Power Planl Extent of Play Direction and control of emergency operations will be demonstrated in accordance with the exercise scenario, the Ashtabula County Radiological Emergency Response I

Plan, Agency SOG and as appropriate for out-of-sequence field demonstrations.

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

Extent of Play Primary (dedicated phone lines and commercial telephone) and secondary (radio/pagers/cell phones) means of communications will be demonstrated at the EOC and as appropriate for out-of-sequence field demonstrations. Controllers will drive 5

field play.

Full field notification utilizing primary means of communication will be completed one time only from the EOC, at the Site Area Emergency classification.

Criterion 1.e.l: Equipment, maps, displays, dosimetry, potassium iodide (KI) and other 3

supplies are sufficient to support emergency operations.

Extent of Play 3

The EOC will demonstrate the use of equipment, maps and displays to support emergency operations.

I In addition to the KI that the local health department made available to the general public to pick up in 2010, there is a quantity stockpiled at both the EOC and the Health District that would be transported to the care centers and distributed by the local health department, as requested.

Evaluation Area 2 - Protective Action Decision Making Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess 3

of administrative limits or protective action guides.

Extent of Play Ashtabula County relies on the Ohio Department of Health (ODH) for the recommendation to take KI. For~out-of-sequence field agency demonstrations, this 94 I

U nclassified Radiological Emcrgcncy Prcparcdnoss Program (REP)

After Action Rcport/lmprovcmcn Platn Pcer" Nuclcar Power Plant will be demonstrated by interview with exercise participants or by controller inject, if necessary.

The use of a Controller inject will begin the process of authorization for radiation exposures in excess of administrative limits.

Criterion 2.b.l: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

Extent of Play N/A - Ashtabula County does not demonstrate this criterion, It relies on the State of Ohio.

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

Extent of Play The Ashtabula County EOC Executive Group will demonstrate this criterion in coordination with Lake and Geauga counties' Executive Groups and the State of Ohio.

TheDirector, or designee, of the Ohio Department of Health (ODH) makes the decision for the general public and emergency workers to take KI. The ODH through the local health department makes KI available to the general public, by pre-distribution and by supplies available for distribution at the time of the emergency at care centers.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups.

Extent of Play The Ashtabula County EOC Executive Group will demonstrate this criterion in coordination with Lake and Geauga counties' Executive Groups. Typically, schools relocate at Site Area Emergency per procedures. If not relocated prior to General Emergency, schools follow the protective action decisions for the general public; they are not considered a special population group.

Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria.

95

Unciassified Radiological Emergency P'rcparcdncss Program (REP)

After Action Rcport/Improvement Plan Pcr.' Nuclear Powcr Plant Extent of Play N/A - Ashtabula County relies on the State of Ohio, Criterion 2.e.l: Timely re-location, re-entry 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.

Extent of Play N/A - This Criterion was successfully demonstrated in 2008, Evaluation Area 3 - Protective Action Implementation Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures and manage radiological exposure.to emergency workers in accordance with the plan and procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.

Extent of Play The Ashtabula County EOC Radiological Officer will demonstrate radiation exposure control capabilities. Dosimetry and exposure control procedures will be demonstrated by field agencies during out-of-sequence exercise activities.

Field activity participants:

Dosimetry briefing:

Harpersfield Volunteer Fire Department - Back-Up Route Alerting Saybrook Township Fire Department - Emergency Worker Monitoring/Decontamination Northwest Ambulance District - MS-I Transportation Interview & Dosimetry Briefing Geneva Police Department - Traffic & Access Control Criterion 3.b.l: KI and appropriate instructions are available should a decision to recomn-iend use of KI be made. Appropriate record keeping of the administration of KI for, emergency workers and institutionalized individuals (not the general public) is maintained.

Extent of Play 96 I

Undussiitied Radiological Eniergcncy Preparcdness Program (PEP)

Aftcr Action Rcporl/lmprovernent Plan Pcrrn Nuclcar Power Plant The Ohio Department of Health (ODH) will make recommendations regarding the use of KI. Ashtabula County's preparedness measures for KI include pre-distribution to emergency response agencies and the general public, if they chose to pick it up. At the time of the emergency, the agencies distribute the dosimetry and KI to the emergency workers.

If the ODH recommendation for use of K] excludes the portion of the EPZ that is in Ashtabula County, demonstration of this criterion will be facilitated by discussion with the Ashtabula County Radiological Officer at the EOC. For field agency demonstrations, K] procedures will be demonstrated by interview with exercise participants or by controller inject, if necessary.

Dosimetry and KI have been pre-distributed to Offsite Response Organizations (OROs); the monitoring kits and dosimetry are exchanged annually by the State of Ohio. Supporting documentation is included in the Annual Letter of Certification.

Extent of Play Interview the EOC Ashtabula County Health Department representative at the EOC during the exercise regarding the distribution of KI for the public at the care center.

Criterion 3.c.1: Protective action decisions are implemented for special population groups within areas subject to protective actions.

Extent of Play Notification to individuals with special needs within the Ashtabula County portion of the EPZ will be simulated. The Ashtabula County EMA maintains a list of special needs organizations within the Ashtabula County portion of the EPZ. The EOC Job and Family Services Representative will coordinate special needs notification activities and, upon request, will present the list for review by the FEMA evaliator.

At least 2 transportation providers, which in Ashtabula County are school districts, will be contacted to ensure availability of buses and drivers.

Criterion 3.c.2: OROs/school officials decide upon and implement protective actions for schools.

Extent of Play The EOC County School Services Representative will follow their Suggested Operating Guideline (SOG) during the Exercise. Geneva School District, the only school district in the portion of the EPZ that is in Ashtabula County, successfully demonstrated this Criterion in 2008.

97

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Rcport/Improvcmenl Plan PcrrD Nucicar Power Plant Criterion 3.d.M : Appropriate traffic and access control is established. Accurate instructions I

are provided to traffic and access control personnel.

Extent of Play I

A representative of the police department will demonstrate Traffic and Access Control out-of-sequence, by interview at the station.

Notification of rail, water and air traffic is a State function.

3 Field activity participants:

Geneva Police Department H

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

3 Extent of Play*

Ashtabula County EOC will demonstrate the capability to identify and take the appropriate actions in dealing with impediments to evacuation. Actual resources will not be utilized. If an impediment cannot be removed in a timely manner, the decision I

process to re-route traffic will be discussed and implemented by the appropriate EOC Staff.

Criterion 3.e.l: 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 planring zone for implementation of protective I

actions.

Extent of Play 3

N/A - Ashtabula County relies on the State of Ohio.

3 Criterion 3.e.2: Appropriate measures, strategies and pre-printed instructional material are developed fo-implementing protective action decisions for contaminated water, food products, milk and agricultural production.

Extent of Play 3

N/A - Ashtabula County relies on the State of Ohio.

Criterion 3.f.l: Decisions regarding controlled re-entry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented.

98

Unclassified Radiological Emergency Prcparcdncss Program (REP)

Aftcr Action Rcport/lmprovenent Plan Perry Nuclear Power Plant Extent of Play N/A - This Criterion was successfully demonstrated in 2008.

EVALUATION AREA 4 - FIELD MEASUREMENT AND ANALYSIS Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.

Extent of Play N/A - Ashtabula County does not demonstrate this criterion.

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

Extent of Play N/A - Ashtabula County does not demonstrate this criterion.

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.

Extent of Play N/A - Ashtabula County does not demonstrate this criterion.

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

Extent of Play N/A - Ashtabula County does not demonstrate this criterion.

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions.

Extent of Play N/A - Ashtabula County does not demonstrate this criterion.

99

Unucla ss i tied Radiological Emergency Preparedness Program (REP)

P After Action Report/lImprov'emernt Plan Pcrry Nuclear Power Pat EVALUATION AREA 5--EMERGENCY NOTIFICATION AND PUBLIC INFORMATION I

Criterion 5.a.l: Activities associated with primary alertingand notification of the public are completed in a timely manner following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include:

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1. Identification of the state or local government organization and the official with the authority for providing the alert signal and instructional message
2. Identification of the commercial nuclear power plant and a statement that an emergency situation exists at the plant 3
3. Reference to REP-specific emergency information (e~g., brochures and information inl telephone books) for use by the general public during an emergency I
4. A closing statement asking the affected and potentially affected population to stay tuned for additional information.

Extent of Play e

Upon a protective action decision (PAD) by the combined Executive Groups of Ashtabula, Lake and Geauga counties, the Lake County EOC Staff will prepare the appropriate Emergency Alert System (EAS) message and simulate sounding the sirens I

and sending the message over the EAS system. A quiet siren test will be demonstrated by the Lake County EOC in lieu of an actual siren sounding.

No siren activation will be performed by Ashtabula County.

Simulation of sending the EAS message(s) will be conducted as follows:

I The procedure for the EAS encoder will be followed to deliver the message to WTAM, the Local Primary Station, with the exception that the telephone number to the station will not be dialed. By not connecting to WTAM, there is no possibility of accidentally broadcasting the message over one or more of the participating EAS stations.

The "send" button on the Lake County EAS encoder will be depressed, and this action will activate the outgoing alert light and playback of the recorded message. Also, a data sheet will automatically be printed by the encoder and the time recorded on the data sheet. Ashtabula and Geauga counties have EAS equipment (encoder) and could I

provide this function if necessary.

100 II

Unclassified Radiological Emcrgcncy Prcparecdncss Program (MEP)

Aftcr Action Rcpori!Impro'cmcni Plan Pcrr\\' Nuclcar Powcr Plant Lake County will fax a copy of the EAS message(s) to the Joint infornation Center (JlC),where Public Information Officers (PlOs) may distribute hard copies to the news media representatives and may, if time and circumstances permit, make an announcement regarding the message. Otherwise, the EAS message can be announced at the next scheduled press briefing or in response to news media inquiries about the PAD message.

In delivering information about the EAS message just released, the counties' PIOs may indicate that a corresponding Special News Bulletin (SNB) will be issued soon.

Lake County will also fax a copy of the EAS message to Ashtabula and Geauga counties' EOC's.

Criterion 5.a.2: (RESERVED)

Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system.

Extent of Play Harpersfield Volunteer Fire Department will demonstrate back-up route alerting as an out-of-sequence, pre-positioned field activity. One pre-deterrnined siren located in the fire department's jurisdiction will be out-of-service (simulated) and back-up route alerting will be conducted in the siren coverage area. Use of the mobile PA system will be simulated during the demonstration; an audible PA test will be conducted prior to departure. The demonstration will be initiated by the exercise controller.

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

Extent of Play Based upon the combined PAD(s) of the Executive Groups of Ashtabula, Geauga and Lake Counties, the Lake County EOC Staff will prepare and issue the appropriate EAS message(s) and the corresponding Special News Bulletin(s) (SNB). SNB's give the same message as their corresponding EAS message except SNB's provide greater detail.

Lake County will FAX the SNB(s) to the Joint Infornation Center (JIC) where one of the counties' PlOs will represent the three counties by directly proceeding to the briefing room and reading the contents of the message to the assembly of news media representatives and answering any questions pertaining to the message.

101

Unclassified Radiological Emcrgency Prcparedness Program (REP)

After Action Rcport/Ihprovemcnt Plan Pcrt3' Nucicar Power Plat This briefing should begin in a timely manner after transmission of the EAS message I

from the Lake County EOC to the Local Primary EAS Station. Hard copies of the SNB(s) will be distributed to the news media representatives.

Ashtabula, Geauga and Lake Counties will also coordinate release of other informational and instructional message, as necessary. Such messages may include Special Infornation Bulletins (SIB), which are a third category of prepared messages contained in the counties' "SOG for EAS Messages, Special News Bulletins and Special Information Bulletins pertaining to the Perry Nuclear Power Plant." These SIB's are considered routine, meaning that they are to be delivered by one of the counties' PIOs at the next scheduled press briefing.

Public Inquiry Workers at the EOC will answer calls from the public. At least one trend will be demonstrated.

EVALUATION AREA 6 - SUPPORT OPERATION/FACILITIES Criterion 6.a.l: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

Extent of Play Saybrook Township Fire Department will demonstrate the emergency worker facility I

out-of-sequence at Lakeside High School, 6600 Sanborn Road, Saybrook Township.

One locker room will be fully set up and demonstrated; a walk-through of the remaining locker room will be conducted upon request.

Two monitoring demonstrations will be conducted using a portal monitor. One individual with simulated contamination will be walked through the monitoring and decontamination process, which includes whole body monitoring using a survey meter; contamination levels will be provided by a controller. Decontamination will be simulated.

Field activity participants Saybrook Township Fire Department - Emergency Worker M/D Criterion 6.b.l: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles.

Extent of Play 102 I

Lin c a ssi 1i ud Radiological Emcrgency Prcparcdncsý Program i(REP)

Aftcr Action Rcport /hnprovcmcnt Plan Pcrry Nuclear Power Plant The Saybrook Fire Department will demonstrate this criterion at Lakeside High School. One vehicle will be monitored and decontamination will be explained; no actual decontamination will take place.

Criterion 6.c.l: Managers of congregate care facilities demonstrate that the centers have resources to provide serices 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.

Extent of Play The American Red Cross successfully demonstrated this Criterion at the Edgewood High School care center during the 2008 exercise and at the Conneaut Middle School care center during the 2006 exercise.

Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

Extent of Play Northwest Ambulance District - MS-1 Transportation at Lakeside High School Emergency Worker Monitoring & Decontamination Station 103

Unclassified Radiological Emergency Prcparcdncss Program (RPEP)

After Action Rcpori/lmprovcnicnt Plan Perry NuCICar POWCr Plailt ASHTABULA COUNTY Demonstrating Agency/

Location Date!

Time Emergency Worker Monitoring/Decontamination Station 09/27/10 Lakeside High School 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> 6600 Sanborn Road Ashtabula, OH 44004 Saybrook Fire Department

Contact:

Chief John Jyurovat (440) 969-1179 Directions: Take 1-90 east to Route 45 north. Travel approximately 3-4 miles to Route 84 and turn right; Lakeside High School is approximately 3 miles (just past Sanborn Road).on the left (north) side.

Medical Services - Transportation 09/28/10 Lakeside High School 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> 6600 Sanborn Road Ashtabula, OH 44004 Demonstrating agency: Northwest Ambulance District at Lakeside High School

Contact:

Vince Gildone (440) 466-4900 Directions and Notes: See above I

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I Initial Notification Point 09/28/10 Ash tabula County 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> Sheriffs Department Dispatch Center 25 West Jefferson Street Jefferson, OH

Contact:

George Sabo, Director (440) 576-9148 Directions: Take Interstate 90 to State Route 45. Take State Route 45 south to State Route 307.

Take State Route 307 east to State Route 46 (Chestnut Street). Take State Route 46 south (right) to the intersection with Jefferson Street. The Sheriff Department is located with the county courthouse on the right. The Dispatch Center is located in the basement area adjacent to the County EOC.

Emergency Operations Center Ashtabula County Courthouse 25 West Jefferson Street Jefferson, OH 09/28/10

-0800 hours 104

L) nclassilied Radiological Emrcr ncy Preparcdncss Program (REP)

Aficr Action Report/linprovement Plan Perry Nuclcar Powcr Planw Demonstrating Agency/

Date/

Location cont'd Time

Contact:

George Sabo, Director (440) 576-9148 Directions: See above:

Joint Information Center 09/28/10 Lakeland Community College

-0930 hours 7700 Clocktower Drive Mentor, OH

Contact:

Byron Landolfi, Ashtabula County Public Information Officer (PIO)

(440) 269-7107 or (440) 269-7122/7115/7116 Traffic/Access Control 09/29/10 Geneva Police Department 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> 44 North Forest Street Geneva, OH 44041

Contact:

Captain Greg Wiley (440) 466-1111 Directions: Travel east on 1-90 to Rt. 534; turn left (north). Travel approximately 3 miles to Rt.20; turn right (east) on Rt. 20. Take first left (north) onto Forest St.; the PD is on the left side.

Back-Up Route Alerting 09/29/10 Harpersfield Fire Department 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> 5430 Cork Cold Springs Road Harpersfield, OH

Contact:

Chief Everett Henry (440) 466-3877 Directions: Travel east on Rt.90 to Rt. 534; exit and turn right (south). Travel approximately

/4 mi - I mile and turn right on Rt. 307. The station is about '/ mile on the south side.

105

Unclassified Radiological Emcrgency Preparedness Program (REP)

Aftcr Action Report/lmprovement Plan Pcrry Nuclear Power Plant GEAUGA COUNTY, OHIO Extent-of-Play Agreement I

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I For the Perry Nuclear Power Plant Evaluated Exercise Week of September 27, 2010 106

Un cia ss it ed Radiological Emergency Prcparcdncss Program (REP)

Aftcr Action Rcport/Improvcrncnt Plant Pcrry Nuclear Powcr Plant The EOC portion of the exercise will take place on September 28, 2010.

Criteria that can be re-demonstrated immediately for credit, by a decision of the evaluator, include the following: 3.a.], 3.d. 1, 3.d.2, 6.a.l, 6.b.], 6.c.1 and 6.d.l. Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chainnan of the Radiological Preparedness Coordinating Committee, include the following: 2.a. 1, 2.b. 1, 2.b.2, 5.a. I and 5.b.1.

EVALUATION AREA I -EMERGENCY OPERATIONS MANAGEMENT Criterion 1.a.l: OROs use effective procedures to alert, notify and rnobilize emergency personnel and activate facilities in a timely manner.

Extent of Play Geauga County EOC Staff will mobilize upon notification from the. Geauga County Sheriffs Dispatch Center, which is the 24-hour notification point and receives the call via a dedicated line from the Perry Plant. Full field notification utilizing primary means of communication will be completed one time only from the EOC, at the Site Area Emergency classification.

Field agency demonstrations will be conducted out-of-sequence and participants will be pre-positioned.

Field activity participants Thompson Volunteer Fire Department - Back-Up Route Alerting Ledgemont School District - Risk School Traffic/Access Control by interview at the EOC during the Exercise 0

Geauga County Sheriffs Office Criterion 1.b.]: Facilities are sufficient to support the emergency response.

Extent of Play N/A - The EOC and JIC have both been evaluated; no changes have been made.

Criterion 1.c.l: 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.

Extent of Play Direction and control of emergency operations will be demonstrated in accordance with the exercise scenario, the Geauga County Radiological Emergency Response Plan, Agency SOG and as appropriate for out-of-sequence field demonstrations.

107

[juciassifi~d Radiological Emergcney Preparedness P~rogrami (R<EP)

After Action Report/-nprovcment Plan Perry Nuclear Power Plant Criterion 1.d.1: At least two communication systems are available and operate properly and I

communication links are established with appropriate locations. Communications capabilities are managed in support of emergency operations.

Extent of Play Primary (dedicated phone lines and commercial telephone) and secondary (radio/pagers/cell phones) means of communications will be demonstrated at the EOC and as appropriate for out-of-sequence field demonstrations. Controllers will drive field play.

Full field notification utilizing primary means of communication will be completed one 3

time only from the EOC, at the Site Area Emergency classification.

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

Extent of Play 3

The EOC will demonstrate the use of equipment, rnaps and displays to support emergency operations.

I In addition to the KI that the local health department made available to the general public to pick up in 2010, there is a quantity stockpiled at the Health District that would be I

transported to the care centers and distributed by the local health department, as requested.

I EVALUATION AREA 2 - PROTECTIVE ACTION DECISION MAKING Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and I

appropriate coordination, to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

Extent of Play U

Geauga County relies on the Ohio Department of Health (ODH) for the recommendation to take KI. For out-of-sequence field agency demonstrations, this will be demonstrated by interview with exercise participants or by controller inject, if necessary.

The use of a Controller inject will begin the process of authorization for radiation 3

exposures in excess of administrative limits.

108 II

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Impro vctncni Plan Perry Nuclcar Power Plant Criterion 2.b.l: Appropriate protective action recommendations are based on available infon-nation on plant conditions, field monitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

Extent of Play N/A - Geauga County does not dernonstrate this criterion; it relies on the State of Ohio for field monitoring.

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

Extent of Play The Geauga County EOC Executive Group will demonstrate this criterion in coordination with Lake and Ashtabula counties' Executive Groups and the State of Ohio.

The Director, or designee, of the Ohio Department of Health (ODH) makes the decision for the general public and emergency workers to take KI. The ODH through the local health department makes KI available to the general public, by pre-distribution and by supplies available for distribution at the time of the emergency at care centers.

Criterion 2.c.l: Protective action decisions are made, as appropriate, for special population groups.

Extent of Play The GeaugaCounty EOC Executive Group will demonstrate this criterion in coordination with Lake and Ashtabula counties' Executive Groups. Typically, schools relocate at Site Area Emergency per procedures. If not relocated prior to General Emergency, schools follow the protective action decisions for the general public; they are not considered a special population group.

Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria.

Extent of Play N/A - Geauga County relies on the State of Ohio.

Criterion 2.e.l: Timely re-location, re-entry 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.

109

Unclassified Radiological Erncrgcncy Prcparcdncss Program (REP~)I Alter Action Rcport/lnprovcnmcnt Plan Perry Nuclcar Powcr Plant N/A - This Criterion was demonstrated in 2008.

I EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.]: The OROs issue appropriate dosimetry and procedures and manage radiological exposure to emergency workers in accordance with the plan and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.

Extent of Play The Geauga County EOC Radiological Officer will demonstrate radiation exposure 3

control capabilities. Dosimetry and exposure control procedures will be demonstrated by field agencies during out-of-sequence exercise activities.

Field activity participants:

Thompson Volunteer Fire Department - Back-Up Route Alerting Ledgemont School District - Risk School I

Dosimetry briefing:

Thompson Volunteer Fire Department Ledgemont School District - Interview of Transportation Supervisor & bus operator only Interview & dosimetry briefing:

I Geauga County Sheriff s Office - at the EOC during the Exercise' Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend I

use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not the general public) is maintained.

I Extent of Play The Ohio Department of Health (ODH) will make recommendations regarding the use of KI. Geauga County's preparedness measures for KI include pre-distribution to emergency response agencies and to the general public, if they chose to pick it up at designated centers. At the time of the emergency, the agencies distribute the dosimetry and KI to the emergency workers. If the ODH recommendation for use of KJ excludes the portion of the EPZ that is in Geauga County, demonstration of this criterion may be facilitated by discussion with the Geauga County Radiological Officer at the EOC. For field agency demonstrations, KI procedures will be demonstrated by interview with exercise participants or by controller inject, if necessary.

Dosimetry and KI have been pre-distributed to Offsite Response Organizations (OROs);

the monitoring kits and dosimetry are exchanged annually by the State of Ohio.

I 110 I

Unclassified Radiological Emergency Prcparcdness Program (PEPj After Action Rcport/Improvement Plan PcrT' Nuclear Power Plant Supporting documentation is included in the Annual Letter of Certification.

Extent of Play Interview the Geauga County Health District representative at the EOC during the exercise regarding the distribution of KI for the public at the care center.

Criterion 3.c.1: Protective action decisions are implemented for special population groups within areas subject to protective actions.

Extent of Play Notification to individuals with special needs within the Geauga County portion of the EPZ will be simulated. A list of special needs residents within the Geauga County portion of the EPZ is maintained by the Geauga County Department of Emergency Services (DES). The Fire/EMS Coordinator at the EOC will coordinate special needs notification activities and, upon request, will present the confidential list for review by the FEMA evaluator. At least 2 transportation providers, which in Geauga County include school districts, will be contacted to ensure availability of buses and drivers.

Criterion 3.c.2: OROs/school officials decide upon and implement protective actions for schools.

Extent of Play The school district will demonstrate this criterion out-of-sequence, by interview with the superintendent, high school principal, transportation supervisor and a bus operator. School officials follow the protective action decisions made by the elected officials for the general public.

The use of dosimetry and KI will be discussed with transportation personnel only. There will be no movement of buses or students.

The EOC County Schools Services Representative will follow their Suggested Operating Guideline (SOG) during the Exercise.

Field activity participants Ledgemont School District Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.

111

U nelassified Radiological Emergency Prcparedness Program (REP)

After Action Report/Improvemene Plan Pcrn, Nuclear Power PLir Extent of Play I

The EOC Geauga County Sheriff's Office will demonstrate Traffic and Access Control by interview at the Geauga County EOC during the exercise.

Notification of rail, water and air traffic is a State function.

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

Extent of Play U

Geauga County EOC will demonstrate the capability to identify and take the appropriate actions in dealing with impediments to evacuation. Actual resources will not be utilized.

If an impediment cannot be removed in a timely manner, the decision to reroute traffic will be discussed and implemented by the appropriate EOC staff.

I Criterion 3.e.l: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestionl exposure pathway emergency planning zone for implementation of protective actions.

Extent of Play 3

N/A - Geauga County relies on the State of Ohio.

3 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.

Extent of Play 3

N/A - Geauga County relies on the State of Ohio.

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

Extent of Play N/A - This Criterion was demonstrated in 2008.

EVALUATION AREA 4 - FIELD MEASUREMENT AND ANALYSIS Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.

112 I

UncIassified Radiological Enmergency Preparedness Program (REP)

Aftcr Action Report/mlprovcmentPlan Perry Nuclcar Power Plant Extent of Play N/A - Geauga County does not demonstrate this criterion.

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

Extent of Play N/A - Geauga County does not demonstrate this criterion.

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-speci.fied in the plan and/or procedures) amount of radioactivity has been collected on the sampling media.

Extent of Play N/A - Geauga County does not demonstrate this criterion.

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

Extent of Play N/A - Geauga County does not demonstrate this criterion.

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions.

Extent of Play N/A - Geauga County does not demonstrate this criterion.

EVALUATION AREA 5 - EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Criterion 5.a.l: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include:

113

U nciiassified Radiological Emcrgcncy Prcparcdness Program (REP)

A ficr Aclioni Rcport/I mprox'emcnt Plan Perr Nuccar Power Plani I. Identification of the state or local government organization and the official with the authority for providing the alert signal and instructional message

2. Identification of the commercial nuclear power plant and a statement that an emergency situation exists at the plant I
3. Reference to REP-specific emergency information (e.g., brochures and information in telephone books) for use by the general public during an emergency
4. A closing statement asking the affected and potentially affected population to stay tuned for additional information.

Extent of Play I

Upon a protective action decision (PAD) by the combined Executive Groups of Ashtabula, Lake and Geauga counties, the Lake County EOC Staff will prepare the appropriate Emergency Alert System (EAS) message and simulate sounding the sirens and sending the message over the EAS system. A quiet siren test will be demonstrated by the Lake County EOC in lieu of an actual siren sounding.

Simulation of sending the EAS message(s) will be conducted as follows; The procedure for the EAS encoder will be followed to deliver the message to WTAM, the Local Primary Station, with the exception that the telephone number to the station I

will not be dialed. By not connecting to WTAM, there is no possibility of accidentally broadcasting the message over one or more of the participating EAS stations.

The "send" button on the Lake County EAS encoder will be depressed, and this action will activate the outgoing alert light and playback of the recorded message. Also, a data*

sheet will automatically be printed by the encoder and the time recorded on the data I

sheet. Ashtabula and Geauga counties have EAS equipment (encoder) and could perform this function, if necessary.

Lake County will fax a copy of the EAS message(s) to the Joint Information Center (JIG) where Public Information Officers (PIOs) may distribute hard copies to the news media representatives and may, if time and circumstances permit, make an announcement I

regarding the message. Otherwise, the EAS message can be announced at the next scheduled press briefing or in response to news media inquiries about the PAD message.

In delivering information about the EAS message just released, the counties' PIOs may indicate that a corresponding Special News Bulletin (SNB) will be issued soon. Lake County will also fax a copy of the EAS message to Ashtabula. and Geauga counties' EOCs.

Criterion 5.a.2: (RESERVED)

Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are 114 1I

Unclassified Radiological Emcrgcncy Preparcdncss Progranm (REP)

After Action Rcport/Improvement Plan Pcrr\\ NUclcar Powcr PIlat completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system.

Extent of Play Thomnpson. Volunteer Fire Department, the only Geauga County department with this responsibility, will demonstrate back-up route alerting as an out-of-sequence, pre-positioned field activity. One pre-deternined siren located in the fire department's jurisdiction will be out-of-service (simulated) and back-up route alerting will be conducted in the siren coverage area. Use of the mobile PA system will be simulated during the demonstration; an audible PA test will be conducted prior to departure. The demonstration will be initiated by the exercise controller.

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

Extent of Play Based upon the combined PAD(s) of the Executive Groups of Ashtabula, Geauga and Lake Counties,. the Lake County EOC Staff will prepare and issue the appropriate EAS message(s) and the corresponding Special News Bulletin(s) (SNB). SNB's give the same message as their corresponding EAS message except SNB's provide greater detail. Lake County will FAX the SNB(s) to the Joint Information Center (JIC) where one of the counties' PIOs will represent the three counties by directly proceeding to the briefing room and reading the contents of the message to the assembly of news media representatives and answering any questions pertaining to the message. This briefing should begin in a timely manner after transmission of the EAS message from the Lake County EOC to the Local Primary EAS Station. Hard copies of the SNB(s) will be distributed to the news media representatives.

Ashtabula, Geauga and Lake Counties will also coordinate release of other informational and instructional message as necessary. Such messages may include Special Information Bulletins (SIB), which are a third category of prepared messages contained in the counties' "SOG for EAS Messages, Special News Bulletins and Special Information Bulletins pertaining to the Perry Nuclear Power Plant." These SIB's are considered routine, meaning that they are to be delivered by one of the counties' PiOs at the next scheduled press briefing.

Public Inquiry Workers at the EOC will answer calls from the public. At least one trend will be demonstrated.

115

Unciassified Radiological Erncr yicv Preparedness Program (REP)

After Action Rcport/*mprovcnicnt Plan Pny. Nuclcar Power Fela EVALUATION AREA 6 - SUPPORT OPERATION/FACILITIES I

Criterion 6.a.l: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of I

evacuees and/or emergency workers.

Extent of Play U

N/A - Geauga County will not demonstrate this criterion. The two public monitoring/decontamination care centers were evaluated in the past 2 exercises: the Cardinal High School care center in 2008 and the Notre Dame Cathedral Latin High School care center in 2006. In addition, the Geauga County Emergency Worker Monitoring Decontamination facility at Chardon High School was evaluated in the 2008 exercise.

Criterion 6.b.l: The facility/ORO has adequate procedures and resources for the accomplishment of inonitoring and decontamination of emergency worker equipment including vehicles.

Extent of Play N/A - The Chardon Fire Department successfully demonstrated this criterion at Chardon I

High School during the 2008 Evaluated Exercise.

Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources I

to provide services and accommodations consistent with American Red Cross planning guidelines.

Managers demonstrate the procedures to assure that evacuees have been monitored for 3

contamination and have been decontaminated as appropriate prior to entering congregate care facilities.

Extent of Play I

The American Red Cross successfully demonstrated this Criterion at the Cardinal High School care center during the 2008 exercise and at the Notre Dame Cathedral Latin care center during the 2006 exercise.

Criterion 6.d.l: The facility/ORO has the appropriate space, adequate resources, and trained K

personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

Extent of Play "

N/A - Geauga County will not demonstrate this criterion.

116.

3

Unclassified Radiological Emnergency Preparedness Program (UEP)

After Action Rcport/hinprovemcnm Plan Perr' Nuclear Power Plant GEAU GA COUNTY Demonstrating Agency/

Date/

Location Time initial Notification Point 09/28/10 Geauga County

-0800 hours Sheriff's Dispatch Center 12450 Men-itt Road Chardon, OH

Contact:

Dale Wedge, Director Geauga County Department of Emergency Services (DES)

(440)279-2170 Directions: The Sheriffs Dispatch Center is located in the Geauga County Sheriffs Office complex. Take State Route 44 to Merritt Road. Turn left (east) on Merritt Road (about 2 miles south of Route 322) and turn in at the first driveway on the left.

Emergency Operations Center 09/28/10 12518 Merritt Road

-0800 hours Chardon, OH COntact: Dale Wedge, Director 440) 279-2170 Directions: Take Rt. 44 south to Merritt Road. Turn left (east) on Merritt Road (about 2 miles south of Route 322) and turn in at the second driveway on the left.

Joint Inforrnation Center 09/28/10 Lakeland Community College

-930 hours 7700 Clocktower Drive Mentor, OH Contact, Linda Burhenne, Geauga County Public Information Officer (PIO)

(440) 269-7107 or (440) 269-7122/7115/7116 Directions: The main entrance (Clocktower Drive) is from Rt. 308, just south of Interstate 90.

(Also, there is a back entrance from Garfield Road not far from the Lake County EOC.) The Perforning Arts Center is to the immediate left of the clock tower. Enter the doors directly under the overhead walkway. If the security personnel will not admit you, ask for an Exercise Controller or the Government Liaison person.

Parking: Secured parking is available in the lot directly across from the clock. The parking code to enter will be given at the pre-exercise briefing. The gate lifts automatically when exiting.

Parking is also available in the student parking lots.

Back-Up Route Alerting 09/28/10 Thompson Fire Department 1930 hours0.0223 days <br />0.536 hours <br />0.00319 weeks <br />7.34365e-4 months <br /> 6778 Madison Road 117

Uliclassified A fter Action Report Improvcmeinc Plani Radiological Emcrgcncy Prcparcdincss Program (REP)

N Afic Acon Rporllmrovccm lanPcrr' Nucicar Po,,vcr Plaio Demonstrating Agency/

Date/

I Location Time Thompson, OH I

Contact:

Chief Dan Robison (440) 298-1405 1

Directions: Travel east on Rt.90 to Rt. 528; turn right (south) on Rt. 528 and travel approximately 6 miles into Thompson. Go halfway around the square; the fire department is on the right.

I School District Ledgemont School District 09/29/10 Superintendent's Office 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br /> Board of Education 16200 Burrows Road Thompson, OH 44086

Contact:

Ron Donatone, Superintendent (440) 298-3341 Directions: Take Rt. 90 east to Rt. 528; turn right (south) and travel approximately 5 miles into Thompson. Go half-way around the town square and continue on Rt. 528 approximately 3 miles to Burrows Rd. and turn right. The Board of Education is in the Elementary School.

1 118 I

I

Unclassified Radiological Emcrgcncv Picparcdness Program (RPiP)

A Fcr Action Rcport/Improvcmcnt Plan Porr, Nuclear Powcr Plant PERRY NUCLEAR POWER PLANT RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE 09/28/2010 TIMELINE OF EVENTS This exercise will be conducted using an operations crew in the Perry control room simulator which will provide "live" simulator data to exercise participants. Exact event times provided in this Timeline may vary based on crew response or controller direction.

Event No.

Event Description Event Time

1.

Explosion due to a dropped CO2 extinguisher

-0735 damaging Safe-Shutdown equipment.

2.

Contaminated Injured Person

-0735 Explosion - Alert - FA 1

-0750

3.

Main Turbine Trip - Reactor Scram Failure, ATWS

-0915 Failure to Shutdown the Reactor - Site Area

-0930 Emergency - CS I

4.

Main Steam Drain Line Pipe Break

-1030

5.

Emergency Depressurization (ED)

-On ED

6.

Fission Product Barrier Loss and Radioactive

-1140 Release Loss of Fission Barriers and Radiation Release

-1155 General Emergency - AG 1/HG 1

7.

Change in Wind Direction

-1305 Par Changed Based on Wind Direction Change

--1320

8.

Exercise Tenrnination

-1430

9.

Critique'

-1500 119

LU nclassified Radiological Emcrgcncy Prcparcdncss Program (REP)

N A 'tcr Action Rcport/lmprovcmcnt Plan Pcrrs, Nuciear Powcr Plane CONTAMINATED / INJURED PERSON Medical Services (MS-I)

Mini Scenario Demonstration Locations:

  • Lakeside High School (Ashtabula County)

This scenario will involve a contaminated emergency worker slipping in the locker room and sustaining a broken wrist. Fire Department personnel, trained in monitoring and decontamination, will assist as necessary (as players).

At the demonstrating facility, the exercise controller will use oral injects to 3

facilitate this scenario.

" Any individual can act as the contaminated injured emergency worker.

" The victim will sustain a broken left wrist during this fall.

" The location and intensity of the contamination is as 1300 cpm on the left I

palm.

  • The individual had just been decontaminated the 2 nd time and was in the 3

process of being monitored post decon.

NO transportation from the facility will take place.

U STri-Point Center (Lake County) 3 At the demonstrating facility, the exercise controller will use oral injects to facilitate the scenario.

NOTE: Victim scenario - Fire watch inadvertently knocks over a C02 fire I

extinguisher causing the cylinder to explode. The fire watch receives a puncture wound and broken right upper arm by flying debris. The victim was diso sprayed in the face and upper body by leakage (approximately a half pint) from a broken stainless instrument line Containing contaminated liquid. The victim is ambulatory.

3 120

Unclassified Radiological Emcrgcncy Prcparcdincss Program (REP)

After Action Rcport/lmprovcmcnt Plan PerrY Nuclear Power IPlani

  • The location and intensity of the contamination is as identified on Attachment #1.
  • The individual will be decontaminated as appropriate for the contamination Levels and location identified.
  • Two decontamination attempts will be necessary to reduce monitor readings To acceptable levels.
  • Proper nasal smears should be taken based on contamination on the face.

Upon Arrival at Tri-Point Medical Center Mouth and nasal area: 2500 cpm.

Wound area and upper body: 3000 cpm.

2 nd Monitoring After decontamination: 600 cpm.

3rd Monitoring After decontamination: Background.

121

Unclassitfied Radiological Emergcncy Prcparedncss P'ogram (REP)

Aftcr Action Report/Improvcnmcnt Plan Pcry Nucicar Powcr Plant I

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