A Field Measurement Based Rapid Decision-Making Approach Ingestion Tabletop Exercise State/Federal Interface Issues. Lou Brandon, Tony Katarsky

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1 A Field Measurement Based Rapid Decision-Making Approach Ingestion Tabletop Exercise State/Federal Interface Issues Lou Brandon, Tony Katarsky Part A: The Michigan Approach for Post-Plume Decision-Making/Lou Brandon The State of Michigan has adopted a rapid post-plume decision-making process following a radiological release from a nuclear power plant. Technically sound decisions are made post-plume with a GM meter and scintillator by identifying the extent and intensity of deposited contamination. Post-plume relocation decisions are made before soil or other samples are assessed in the laboratory. This approach allows immediate decision-making rather than waiting for processing of samples. Estimates of the radial extent of contamination are projected with a near release point centerline measurement of deposition. Agricultural advisories and embargoes are implemented in the Ingestion Pathway Zone within minutes of plume passage. A footprint based on field team measurements is defined within hours. Additional field measurements and sampling allow further refinement of the evacuation and relocation protective action orders. Most essential decision-making is accomplished within two to four hours of release termination. Part B: Federal Interface Issues/Tony Katarsky In June 2000, the State of Michigan conducted an ingestion pathway tabletop exercise in conjunction with numerous federal agencies allowing the state to explore interface issues. Given the Michigan approach to post-plume decision making, we were concerned that federal personnel would not understand the reasoning for our post-plume decisions, which might jeopardize exercise results. Numerous questions arose. What is the A team? When would it be available? What is the I team? Who defines responsibilities? When would a fly-over occur? How sensitive is federal instrumentation and what levels of deposition could be defined? What footprint maps can be expected? Could we seamlessly integrate federal resources? Should we integrate emergency facilities? What tasks would federal radiological monitors be willing to assume? Would the state still be in charge? What decisions would need to be made before federal arrival? Several meetings and conference calls were conducted to iron out interface issues and maximize exercise play. We knew that the half-day plume phase would be played primarily as a state decision-making process. However, postplume phase details were unknown. What would the state accomplish before federal assistance was available? Agreement was finally reached on time jumps and the time of interjection of federal participants. A highly compressed 1½ day sequence with four time jumps was finally decided.

2 During the tabletop, constructive interactions took place as federal agencies supported emergency response and provided key insights to issues. In spite of lengthy advance discussions, it became clear that there were many issues to resolve. While public monitoring and decontamination can be handled short term by local agencies, federal resources could be used to improve performance. Guidance needs to be more specific on advisories to the unevacuated public in areas where food embargoes have been implemented. Discussions with federal players took longer than anticipated, which forced significant time line adjustments. These difficulties were likely due to lack of federal participation during the drills and lack of federal familiarity with Michigan s approach, which would be the case during an actual event. An unanticipated factor observed was the manner in which public perception may influence the decision-making process. In summary, the presence of federal players provided invaluable insights as we addressed many potential difficulties and recognized others that might occur during an actual event. We regretted not having more time to play out the scenario further with federal participants and fully address interface issues. Lou Brandon is Chief of the Nuclear Facilities Unit in the Radiological Protection Section of the Michigan Department of Environmental Quality. His primary responsibility is currently nuclear power plant emergency response. He has served the State as a health physicist, addressing radiation safety and radiological emergency response aspects since Mr. Brandon was previously employed as a field engineer with Schlumberger, performing down hole surveys of oil wells with a variety of radioactive sources, and has taught at the high school and university level. Mr. Brandon holds Bachelor and Master of Science degrees in Physics from Michigan State University, is a member of the Health Physics Society and is a Certified Health Physicist. Tony Katarsky is Chief of the Radiological Emergency Planning Unit in the Emergency Management Division of the Michigan State Police. His primary responsibility is managing nuclear power plant emergency response planning and training for the State of Michigan. Mr. Katarsky was previously supervisor of emergency planning for the Big Rock Point and Palisades Nuclear Power Plants. He also assisted in the development of initial emergency response plans for Monroe County, Michigan and the Enrico Fermi 2 Nuclear Power Plant and assisted Detroit Edison preparations for its first emergency exercise in Mr. Katarsky holds Bachelor and Master of Arts degrees from Wayne State University.

3 PALISADES 2000 INGESTION EXERCISE / FEDERAL INTERFACE ISSUES (Tony Katarsky) On June 6-7, 2000, the State of Michigan conducted an ingestion pathway tabletop in conjunction with the Palisades Nuclear Power Plant and participants from six federal agencies. The State of Michigan employs a unique decisionmaking process, which was detailed in a presentation at this conference by Lou Brandon, of the Michigan Department of Environmental Quality. Decisions are based on field data rather than waiting on laboratory analysis of field samples, which may take 24 hours to process. This approach, coupled with an extremely aggressive scenario time line, led to state/federal interface issues that warrant consideration by other jurisdictions. The State of Michigan was eager to conduct an ingestion exercise with federal participants because we had not conducted one for six years, and had never participated with federal players in the State Emergency Operations Center. We sought to explore the use of federal resources and their alignment with state personnel performing similar functions. State decision-makers intermingled freely with federal advisors, which proved to be a tremendous benefit to state personnel. Exercise Planning Planning began nine months prior to the exercise. Key parties from the State of Michigan included the Michigan State Police Emergency Management Division, which bears overall responsibility for emergency management and planning, and the Department of Environmental Quality, which provides radiological monitoring and technical analyses. The Nuclear Regulatory Commission and Department of Energy participated in exercise planning from the federal government. Federal representatives were knowledgeable on conduct of post-plume exercises and provided good ideas on how the exercise should be conducted. This proved to be of great assistance, but also caused some difficulty when state requests went beyond what had been encountered in past exercises. Detailed planning began about seven months in advance of the exercise. At this point, discussion of exercise specifics began. This process involved a repeated pattern of conference calls, summarized discussion notes, revisions, and subsequent conference calls. Agreement was finally reached on the following: 1) We would conduct a tabletop exercise; 2) Plume phase data would be disconnected from the ingestion phase data; and 3) Scenario time lines with associated time jumps were established. 1 During this phase, it was critical to develop written summaries of what had been discussed and conclusions 1 Refer to Attachments 1 and 2, time lines for the State Emergency Operations Center and the Field Team Center.

4 reached, as we found that conference call participant recollections were often not fully aligned when notes were provided. Exercise Scenario Both DOE and NRC representatives were open to ideas and supportive of state wishes on how the exercise should be conducted. Two significant recommendations were made by federal representatives and followed by state exercise planners: 1) Do not attempt to link ingestion scenario data to plume exposure scenario data; and 2) Conduct the exercise in a tabletop format. Uncoupling the plume and ingestion scenarios minimized the burden placed on utility scenario writers who have to be very creative in order to identify mechanisms to place significant deposition in areas far from the plant. The tabletop format allowed maximum interface between state and federal exercise participants and eliminated wasted time waiting for requested samples to be taken and analyzed. Field monitoring personnel used the same scenario as the State Emergency Operations Center, but participated independently and used a different time line. There were no communications between the State Emergency Operations Center and the Field Team Center. Field teams were comprised of federal and state personnel to maximize the learning opportunity for both groups. Similarly, the state laboratory analyzed environmental samples collected, but had no interface with the Field Team Center or the State Emergency Operations Center. Although federal representatives recommended against the use of multiple time jumps due to potential confusion they might introduce, state exercise planners decided to employ four time jumps to more realistically simulate support that would be available at key junctures. This time line acquainted players with key issues as they would unfold during an actual event, where decisions by state personnel might be required prior to the arrival of federal advisors. The plume phase began at 0830 and ended at At this point, the state had issued agricultural protective action orders and had formed the state Ingestion Pathway Committee. A few Department of Energy and Nuclear Regulatory Commission personnel had arrived at the State Emergency Operations Center and began to function as members of the Executive Group. This was followed by a four-hour time jump where state field teams had identified the border of contaminated areas contiguous to the plant. A map with 500 ìr/hour and 20 ìr/hour hotspot boundaries adjacent to the plant was provided to exercise participants. At this stage, state efforts focused on development of a sampling regimen and specific sample locations. This phase was to have been completed by 1430, but took until 1530 to complete.

5 A 12-hour jump was then provided to players where a map depicting federal fixed wing flyover results were shown. Additionally, hot sample results were received from the state laboratory. The flyover identified additional hot spots at 500 ìr/hour, 100 ìr/hour, and 20 ìr/hour levels. The Advance Party Briefing was conducted to develop an implementation plan for the Federal Radiological Monitoring and Assessment Center (FRMAC). Federal representatives at this session included Department of Energy and Nuclear Regulatory Commission personnel. Previously issued protective action orders were reevaluated in light of additional areas of contamination identified. While termination had been planned for 1630, participants worked until 1830 to address the information provided by the scenario. The second day began at 0800 with a time jump of 24 hours. State personnel were greeted by federal participants representing the Environmental Protection Agency, the Nuclear Regulatory Commission, the Department of Energy, the Department of Agriculture, the Food and Drug Administration and the Department of Health and Human Services. Players now were provided a refined map of Department of Energy flyover data, which included 1000 ìr/hour, 500 ìr/hour, and 20 ìr/hour hotspot boundaries. Players were tasked with developing a revised sampling regimen and revisiting previously issued protective action orders. This phase was designed to end at 1000, but lasted until 1230, when the exercise was terminated. Efforts during this period focused on development of long term monitoring plans, reevaluation of protective action orders, and recovery plans. Participants never saw the final time jump of 72 hours where they would have been provided laboratory analyses and asked to address reentry and return issues. Long term state and federal monitoring plans would also have been developed. In retrospect, the use of multiple time jumps allowed players to see events occur in a more realistic manner and gain a feel for how long it would actually take Department of Energy personnel to identify deposition via flyovers. It also led state players to make decisions prior to the arrival of federal personnel. Scenario Data Development of data to drive ingestion exercise events was relatively straight forward for the State Emergency Operations Center. Maps were the key agent to spur player actions. Each time jump was accompanied by a map to depict newly found deposition areas and an approximate aircraft flight path. Players responded to this information to develop initial protective action orders and subsequent modifications based on new information. Additional data inputs at the State Emergency Operations Center included support from a controller to provide state laboratory analyses and Field Team Center survey results and dose assessments.

6 Field Team Center personnel used data from the same maps provided to the State Emergency Operations Center, but employed a different time sequence. No data was provided to the state laboratory, which simply analyzed the samples provided and reported findings as found. Guiding Responder Actions Although numerous visual aids were provided to players, it took far longer to reach appropriate decisions than anticipated by exercise planners. Prior to the exercise, state responders were briefed both individually and in groups to acquaint them with decisions and actions expected at each stage of exercise play. Delays in decisions are attributed to 1) inexperience in post-plume data inputs and decisions required, 2) difficulty adjusting to time jumps, 3) inexperience in interacting with federal counterparts, and 4) an aggressive postplume scenario time line. Post-plume action guides were provided to players during the exercise and have been incorporated in State Emergency Operations Center response procedures to provide direction on expected data inputs, anticipated availability, and associated actions to be taken. 2 In the absence of procedural guidance, state responders would rely on memory of exercise actions alone. In our case, the previous ingestion exercise had been conducted six years earlier. The guidance provided allowed players to understand what was expected by evaluators at each time jump. It is imperative that the knowledge gained during a post-plume exercise be captured in procedures to guide actions during an actual event. Exercise Issues The tabletop format selected allowed federal and state players to intermingle and interact freely, which was of great benefit to both state and federal responders as they were able to discuss issues face to face. During the exercise planning phase, federal representatives had suggested that we place FRMAC participants in a separate room. We ultimately decided against this recommendation and allowed personnel to mix freely and to organize themselves into groupings based on common interests. We were very pleased with the level and tone of discussions between state and federal responders. All perspectives were made known and thoroughly discussed face to face, which we believe provided the greatest benefit to both state and federal personnel in terms of understanding each others perspectives. The decision to intermingle state and federal personnel required that exercise planners account for external emergency facilities and associated data inputs including the state laboratory, the Field Team Center, and data that normally would have originated in the FRMAC. Scenario data inputs included a fixed-wing 2 See Attachments 3 and 4.

7 flyover deposition map from the DOE/FRMAC, a helicopter flyover deposition map from DOE/FRMAC, state field deposition data from the Field Team Center, dose assessment analyses from the Field Team Center, and state laboratory sample analyses. With the exception of laboratory sample analyses, which required sets of canned analyses based on sample locations decided by exercise players, these data were relatively simple to develop. Two difficulties were noted during interactions with federal responders. The first involved adherence to federally established radiological contamination limits. The State of Michigan has translated post-plume Protective Action Guides into a 20 ìr/hour trigger level for ingestion and a 500 ìr/hour trigger level for relocation. The relocation trigger is conservative in that the resultant annual dose would be expected to be below the federal standard of 2 rem in the first year. While federal exercise planners were informed of this information prior to the exercise, federal players were unaware of the basis of State of Michigan action levels, which resulted in extensive player discussions on adding buffer zones to already conservative post-plume relocation areas determined by state responders. The second issue involved the use of federal resources. When it was suggested that federal radiological monitoring personnel provide assistance to local government monitoring and decontamination centers, there was hesitance to assign these resources. The state process is to treat all resources as a pool where personnel are assigned to areas of greatest need. If identification of deposition is the top priority, federal and state resources will be assigned as needed. If there were long lines at public monitoring and decontamination centers, personnel would be assigned as a priority to these locations. Other questions arose related to agriculturally restricted areas. What does an agricultural protective action order mean to residents within a restricted area? Should all traffic access be restricted or just trucks? Is it prudent to leave residents? What will public perception be in an area where minor, but identifiable, contamination exists? Long Term Issues FRMAC/State Emergency Operations Center Integration The suggestion by federal exercise planners to integrate the State Emergency Operations Center into the Federal Radiological Monitoring and Assessment Center posed significant concern. If this were to occur, the state would lose many of its pre-established communication links and use an unknown facility. Full integration of state and federal personnel would dilute state decision-making capability. The State of Michigan has considered this recommendation and decided that it will not move its emergency operations center to the FRMAC.

8 Field monitoring personnel, however, will transition to the FRMAC and use it as a base of operations when it becomes operational. State/Federal Understanding: Federal Ingestion and Post-Plume Protective Action Guides The State of Michigan post-plume decision-making process is based on conservative radiological trigger points of 20 ìr/hour for agricultural products and 500 ìr/hour for relocation. Protective action orders are intended to be decided in a manner similar to that within the 10-mile plume exposure zone, without discussions on validity, inclusiveness, or public perception. During this exercise, there were lengthy discussions with federal participants on whether to add areas beyond those identified through use of state trigger levels, which are based on federal standards. Extending protective action orders on this basis is akin to extending a plume exposure evacuation zone to 12 miles based on a projected dose of 700 mrem in the first year. Decisions during the plume phase are made based on fixed standards. The same is needed for post-plume decision-making. It is critical that federal ingestion and relocation standards be followed as written. Wandering from these standards places state decision makers in a weakened position to defend decisions made. Realistic Post-Plume Scenario Time Lines and State Decision Making Four time jumps were planned during this eight-hour post-plume tabletop exercise. While ambitious and stressful to exercise players and planners alike, the selected time line allowed state players to see data arrive at more realistic time frames. A scenario employing only a three or seven day time jump reduces the opportunity for state and federal personnel to understand realistic decisionmaking time frames. Resource arrival times have been added to state procedural guidance for responders. Relocation and ingestion protective action orders cannot wait until all federal personnel have arrived and established the Federal Radiological Monitoring and Assessment Center. The State of Michigan intends to act based on established federal guidelines during the post-plume phase, prior to the arrival of federal responders if necessary. Conclusion The 2000 Palisades post-plume tabletop exercise afforded the State of Michigan the opportunity to work side by side with representatives of six key federal agencies. The effort proved successful as many important lessons were learned and captured in procedures for future reference. Federal participants proved to be very knowledgeable and offered valuable perspectives on state decisions and procedures.

9 Attachment 1 Palisades Exercise State Emergency Operations Center Time Line, Data, & Actions Time & Day Data Provided to Players Expected Player Actions Day 1 Standard Plume Exposure Data The Usual Post Plume Center Line Data on Red Route 1 MDA Confirms Agricultural PAOs MDEQ Assesses Surface Water Concerns SEOC Conveys Information to NRC, DOE, EPA, et. al. Ingestion Pathway Committee Formed Day Hour Data Footprint Data as Generated by DEQ Field Teams Day Hour Data Gross Federal Fly Over Data (500 ìr/hour) Hot Sample Results from Lab Including Air Samples, Intake Water, Surface Water, Rivers, Grass, & Soil Day Hour Data 24 Hour Federal Fly Over Data (20 & 500 ìr/hour) Day Hour Data Lab Results Including Water, Soil, Grass, Strawberries, Asparagus, and Milk (with Associated Water, Soil, & Grass) to Accommodate: - 2 DOE Teams - 1 MDA Team - 3 DEQ Teams Identify Reentry, Relocation, & Controlled Areas Recommend PAOs Discuss Decontamination Options Discuss Sampling Regimen Develop EMD-34s (Sampling Locations & Types) Provide a Briefing on Realistic Time Frames for Results Federal Play Begins at SEOC (State/Federal Briefing with Advance Party) Develop Advance Party Monitoring & Sampling Plan Develop Implementation Plan for FRMAC & State Reevaluate PAOs Develop 2 nd round of EMD-34s (samples) Interplay with Federal Government Reevaluate PAOs Develop Long Term State & Federal Monitoring Plans Re-entry and Return Decisions Recovery Plans FTC - Field Team Center PAO - Protective Action Order PAR - Protective Action Recommendation EMD-34 - Ingestion Pathway Sampling Form MDA - Michigan Department of Agriculture SEOC - State Emergency Operations Center DOE - US Department of Energy DEQ - Department of Environmental Quality

10 Attachment 2 Palisades 2000 REP Exercise Field Team Center Scenario Time Data Provided to Players Expected Player Actions 0800 PAOs From Plume Phase Preparation, Briefing, DEQ Teams Dispatched 0830 Plume Field Data One DEQ Team Dispatched To Red Route 1 For Center-Line Readings Centerline Red Route 1 Readings For Deposition (Waist DEQ Team Records Data And Notifies FTC High) HPS Runs Computer Model With Center Line Data HPS Documents Discussion With SEOC Regarding Agricultural Footprint Data Readings (20 And 500 mr/h Isodose Contours) For Field Teams Surface Water Sample Contact Beta Readings + 4 Hour Data Completed Footprint Isodose Contours EMD-34s From SEOC 1 M Above Ground Level Gamma And Sample Contact Beta Readings EMD 34s 1 M Above Ground Level Gamma And Sample Contact Beta Readings Hour Data Gross Federal Fly-Over (500 mr/h) Hot Sample Results From Lab Including Air Sample (Plume), Surface Water, Grass & Soil Hour Data 24 Hour Fly-Over Data (20 And 500 mr/h) Hour Data Lab Results From All Samples: Water, Soil, Grass, Strawberries, Asparagus & Milk From DOE, MDA, & DEQ Field Teams Advisories As Soon As Possible DEQ Field Teams Record Initial Footprint Data And Relay Data Points To FTC DEQ Field Team Dispatched For Surface Water Sample(s) HPS Plots Footprint & Sends To SEOC FTC Directs Environmental Sampling of DEQ Teams FTC Briefs And Dispatches MDA & DOE Teams FTC Directs DEQ, DOE And MDA Environmental Sampling Teams HPS Runs Lab Data Through Computer Spreadsheet HPS Documents SEOC Discussions On Dose Assessment HPS/Field Team Center Coordinator Discussions With SEOC Updated Footprint Map Produced By HPS HPS Run Dose Assessment Computer Spreadsheets HPS Project Public And Worker Doses FTC Coordinator Sends PARs To SEOC Team Contamination Levels Teams Run Through Decontamination at FTC Sample Package Rad Levels Samples Packaged & Labeled For Transport To Nuclear Counting Facility in Lansing Latest PAOs From SEOC FTC Coordinator Debriefs All Participants On Data And Decision Making FTC - Field Team Center PAO - Protective Action Order communications van) PAR - Protective Action Recommendation MDA - Michigan Department of Agriculture HPS - Health Physics Support (based in mobile SEOC - State Emergency Operations Center

11 Attachment 3 EMD-34 - Ingestion Pathway Sampling Form DOE - US Department of Energy DEQ - Department of Environmental Quality - Out of Sequence with DEQ Field Teams & Worker Decontamination Center

12 Attachment 3 Key Ingestion Pathway Data Inputs, Approximate Timing, & SEOC Anticipated Actions Time Data Expected SEOC Anticipated Actions When Plume Terminated Post Plume Center Line Data on Red Route 1 MDA Confirms Agricultural PAOs MDEQ Assesses Surface Water Concerns SEOC Conveys Information to NRC, DOE, EPA, et. al. Ingestion Pathway Committee Formed + 4 Hours Footprint Data as Generated by DEQ Field Teams Deposition Within and Contiguous to 10 Mile EPZ 500 ìr/hour and 20 ìr/hour Deposition Boundaries Identify Reentry, Relocation, & Controlled Areas Recommend PAOs Discuss Decontamination Options Discuss Sampling Regimen Develop EMD-34s Sampling Forms (Locations & Types) Provide a Briefing on Realistic Time Frames for Results + 12 Hours Deposition as Determined by DOE Fixed Wing Fly Over 500 ìr/hour and 100 ìr/hour Deposition Boundaries Hot Sample Results from Lab Including Air Samples, Intake Water, Surface Water, Rivers, Grass, & Soil Federal Play Begins at SEOC (State/Federal Briefing with Advance Party) Develop Advance Party Monitoring & Sampling Plan Develop Implementation Plan for FRMAC & State Reevaluate PAOs + 24 Hours 24 Hour DOE Helicopter Fly Over Data 500 ìr/hour and 20 ìr/hour Deposition Limits Covers Full Extent of Deposition Develop 2 nd Round of EMD-34 Sampling Forms Interplay with Federal Government + 72 Hours Lab Results Including Water, Soil, Grass, Strawberries, Asparagus, and Milk (with Associated Water, Soil, & Grass) to Simulate: - 2 DOE Teams - 1 MDA Team - 3 DEQ Teams Reevaluate PAOs Develop Long Term State & Federal Monitoring Plans Re-entry and Return Decisions Recovery Plans

13 Attachment 3 Significance & Origin of Radiological Ingestion Data Deposition Level Associated Terminology Associated Protective Actions Source of Radiological Data 500 ìr/hour Relocation Area Relocate Population Initially Provided by DEQ Field Teams Provided by DOE Fixed-Wing Flyover in about 12 Hours Provided by DOE Helicopter Flyover in about 24 Hours 100 ìr/hour None None Informational Value Only Provided by DOE Fixed-Wing Flyover in about 12 Hours For Information Only 20 ìr/hour Controlled Area Agricultural Provided by DEQ Field Teams Provided by DOE Helicopter Flyover in about 24 Hours