Text

After Action Report/Improvement Plan, Radiological Emergency Preparedness (REP) Program
	ML100850453
Person / Time
Site:	Clinton
Issue date:	03/18/2010
From:	; US Dept of Homeland Security, Federal Emergency Management Agency
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML100850453 (71)
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Clinton Power Station After Action Report/

Improvement Plan Exercise Date - November 18, 2009 Radiological Emergency Preparedness (REP) Program

~ FEMA Published March I, 2010

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Clinton Power Station After Action Report/Improvement Plan Published March 18, 2010 Contents Executive Summary 4 Section 1: Exercise Overview 10 1.1 Exercise Details 10 1.2 Exercise Planning Team Leadership 10 1.3 Participating Organizations 12 Section 2: Exercise Design Summary 15 2.1 Exercise Purpose and Design 15 2.2 Exercise Objectives, Capabilities and Activities 15 2.3 Scenario Summary 15 Section 3: Analysis of Capabilities 16 3.1 Exercise Evaluation and Results 16 3.2 Summary Results of Exercise Evaluation 17 3.3 Criteria Evaluation Summaries 22 3.3.1 Illinois Jurisdictions 22 3.3.1.1 State Initial Warning Point 22 3.3.1.2 SEOC/SIRC 22 3.3.1.3 Radiological Emergency Assessment Center 22 3.3.1.4 Unified Area Command 23 3.3.1.5 Emergency Operations Facility 28 3.3.1.6 Joint Infornmation Center 28 3.3.1.7 Illinois State Radiological Advisor - DeWitt County 28 3.3.1.8 Illinois State Liaison - DeWitt County 28 3.3.1.9 Illinois State Liaison - Macon County 29 3.3.1.10 Illinois State Liaison - McLean County 29 3.3. 1.11 Illinois State Liaison - Piatt County 29 3.3.1.12 DCO Briefing - ISP District 6 Headquarters 29 1

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Clinton Power Station 3.3.1.13 TACP at the ISP District 6 Headquarters 30 3.3.1.14 Medical Services (MS-I) Transport - St Marys Hosp 30 3.3.1.15 Medical Services (MS-I) Hospital - St Marys Hosp 30 3.3.1.16 Monitoring of Evacuees and Emergency Workers - 30 Parkland College 3.3.1.17 Decontamination of Evacuees and Emergency 31 Workers - Parkland College 3.3.1.18 Monitoring and Decontamination of Emergency 31 Worker Equipment - Parkland College 3.3.1 .19 Public Registration - Parkland College 31 3.3.2 Risk Jurisdictions 31 3.3.2.1 Congregate Care Center - Parkland College 31 3.3.2.2 Dewitt County - Initial Warning Point 32 3.3.2.3 Dewitt County - Emergency Operations Center 32

.3.3.2.4 Dewitt County - Traffic and Access Control Post 33 3.3.2.5 Dewitt County - Emergency Broadcast Stations 34 3.3.2.6 DeWitt County EV-2 Interview - Deland-Weldon 34 3.3.2.7 Traffic and Access Control Post - Clinton PD 34 3.3.2.8 Macon County - Initial Warning Point 34 3.3.2.9 Macon County - Emergency Operations Center 35 3.3.2.10 Macon County - Traffic and Access Control Post 35 3.3.2.11 McLean County - Initial Warning Point 35 3.3.2.12 McLean County - Emergency Operations Center 35 3.3.2.13 McLean County - Traffic and Access Control Post 36 3.3.2.14 Piatt County - Initial Warning Point 36 3.3.2.15 Piatt County - Emergency Operations Center 36 3.3.2.16 Piatt County - Traffic and Access Control Post 36 Section 4: Conclusion 37 Appendix A: Improvement Plan 38 Appendix B: Lessons Learned 39 Appendix C: Exercise Timeline 41 Appendix D: Exercise Evaluators and Team Leaders 43 Appendix E: Acronyms and Abbreviations 46 Appendix F: Exercise Plan 48 Appendix G: Scenario Details 62 2

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station This page is intentionally blank.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station EXECUTIVE

SUMMARY

On November 18, 2009, a Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise evaluation was conducted by the U.S. Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA) for the 10-mile Emergency Planning Zone (EPZ) around the Clinton Power Station (CPS). The purpose of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency. This exercise was held in accordance with DHS/FEMA's 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 September 12, 2007. The qualifying emergency preparedness exercise was conducted on January 13, 1987.

DHS/FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise. In the State of Illinois, the risk county of DeWitt and the support counties of Macon, McLean and Piatt participated along with 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 the participants were evident during this- exercise.

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

" Illinois State Police (ISP) Dosimetry Control Officers Briefing

" ISP Traffic and Access Control Post at the ISP District 6 Headquarters

" Medical Services Transportation and Hospital evaluation at the St Mary's Hospital

" Protective Actions for Schools (EV-2) for the Deland-Weldon School District

" Monitoring and Decontamination of Evacuees and emergency workers

" Monitoring and Decontamination of emergency worker's equipment

" Public Registration

" Congregate Care Center

" Clinton Police Department Dosimetry Control Officer's Briefing

" Clinton Police Department Traffic and Access Control Post 4

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Except where noted in this report, the State and local organizations demonstrated knowledge of and adequately implemented their emergency response plans and procedures.

There was one Deficiency identified during this exercise for the State of Illinois. The State received a Deficiency finding under Protective Action Decision-Making 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 use of KI if Offsite Response Organization (ORO) policy.

The Deficiency assessed was based on our findings that both the performance and the decision-making processes used by the Unified Area Command (UAC) in the selection of Parkland College as the sole Reception Center resulted in a portion of the public in Sub-Area I being directed to use evacuation routes along the same path the plume was traveling, where they could have received unnecessary radiological exposure, thus compromising health & safety. There were no Deficiencies identified for the Counties of DeWitt, Macon, McLean or Piatt. Section 3 of this report, entitled "Analysis of Capabilities" presents detailed information on the Deficiency.

There was one Area Requiring Corrective Action (ARCA) identified during this exercise for DeWitt County. DeWitt County received an ARCA finding under Direction and Control Criterion 1.c. I - 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. The ARCA assessed was based on our findings that within the DeWitt Emergency Operations Center (EOC) the key personnel with leadership roles did not consistently demonstrate effective direction and control of the overall response effort for which they were responsible.

There were no ARCAs identified during this exercise for the State of Illinois or the Counties of Macon, McLean or Piatt. Section 3 of this report, entitled "Analysis of Capabilities" presents detailed information on the ARCA.

There was one Plan Issue identified during this exercise for Radiological Emergency Assessment Center (REAC). The REAC received a Plan Issue under Emergency Information and Instructions for the Public and the Media criterion 5.b.1 - OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. Residents of the Clinton 10-mile EPZ were not notified that they may need to ingest KI after such a recommendation was made for emergency workers and immobile persons. Information 5

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lInprovement Plan Clinton Power Station contained within the Illinois Plan for Radiological Accidents (IPRA) and Radiological Task Force (RTF) procedure RTF-PARS-2 is not consistent regarding KI information that is provided to the public.

There were no Plan Issues identified for the State of Illinois or the Counties of DeWitt, Macon, McLean or Piatt. Section 3 of this report, entitled "Analysis of Capabilities" presents detailed information on the Plan Issue.

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's activities are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350 "Review and Approval of State and Local Radiological Emergency Plans and Preparedness", 351 "Radiological Emergency Planning and Preparedness" and 352 "Commercial Nuclear Power Plants: Emergency Preparedness Planning."

These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

The FEMA Rule 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 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's 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 procedures developed by State and local governments;

Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments;

Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportlhnprovement Plan Clinton Power Station Register, Vol. 58, No. 176, September 14, 1993); and Coordinating the activities of Federal agencies with responsibilities in the radiological emergency planning process:

U.S. Department of Agriculture; U.S. Department of Commerce; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of the Interior; U.S. Department of Transportation; U.S. Environmental Protection Agency; U.S. Food and Drug Administration; and

- U.S. Nuclear Regulatory Commission.

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

Formal submiission of the RERPs for the Clinton Power Station to FEMA Region V by the State of Illinois and involved local jurisdictions occurred on November 25, 1986. Formal approval of these RERPs was granted by FEMA on August 5, 1987, under 44 CFR 350.

A REP Partial Participation Plume Exposure Pathway Exercise was conducted on November 18, 2009, and evaluated by DHS/FEMA to assess the capabilities of State and local offsite emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the Clinton Station. 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 evaluation team, with final determinations made by the DHS/FEMA Region V RAC Chairperson, and approved by the DHS/FEMA Headquarters.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station The criteria utilized in the FEMA evaluation process are contained in:

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

November 1980;

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

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

Section 1 of this report, entitled "Exercise Overview", presents information pertaining to the team that planned and coordinated the exercise. This section also provides 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: (I) descriptions of all Deficiencies and ARCAs (if any) assessed during this exercise, recommended corrective actions, and the State and local governments' schedule of corrective actions, 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.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station EMERGENCY PLANNING ZONE (EPZ) DESCRIPTION The Clinton Power Station (CPS) is located approximately seven miles northeast of the City of Clinton in Harp Township, within DeWitt County, Illinois. DeWitt County is located near the geographical center of the State of Illinois. The topography of the area is predominantly rolling prairies.

The 10-mile EPZ contains a total population of 12,880 (2000 census) within the risk counties of DeWitt, Macon, McLean and Piatt. Nearly two-thirds of the total EPZ population (8,576) resides in the communities of Clinton, Weldon, Wapella and DeWitt. The land use within the EPZ is predominantly agricultural, with cash grain crops of corn and soybeans. The closest industries are located in the community of Clinton.

Recreational facilities outside the municipalities include the Clinton Lake State Recreation Area and the Weldon Springs State Park. The park encompasses approximately 370 acres and contains a 28-acre lake with camping, fishing, and picnicking facilities. Weldon Springs is one of the two sizeable lakes within ten miles of the site. Clinton Lake is a 4,895 acre man-made cooling lake within the CPS property lines. Recreational facilities accommodate camping, boating, hunting, fishing, and hiking.

The nearest major highways are State Highways 54, 10, and 48, all of which intersect the plant location. Other major thoroughfares are U.S. Highway 51, located about six miles west of the plant; and Interstate Highway 74, located about eleven miles northeast of the plant. The nearest railroad is the Illinois Central Gulf Railroad (ICG), which crosses the site east to west and comes within about three-fourths of a mile to the north of the reactor centerline. Another ICG track is located approximately three and a half miles south of the CPS.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Clinton Power Station Type of Exercise Plume Exercise Date November 18, 2009 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership William King Exercise RAC Chairperson DHS/FEMA Radiological Assistance Committee, Chairman 536 South Clark Street Chicago, Illinois, 60605 3 12-408-5575 William.King@dhs.gov Stephen Tulley Exercise Director DHS/FEMA Supervisory REP Team Leader 536 South Clark Street 10

V.V.......... . ;.V~*,~*

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Chicago, Illinois, 60605 312-408-4425 Stephen.Tulley@dhs.gov Todd Gemskie Clinton Site Specialist/Exercise Coordination DHS/FEMA Technical Hazards Program Specialist 536 South Clark Street*

Chicago, Illinois, 60605 312-408-4443 Todd. Gemskie@dhs.gov William Conway State Lead Controller Illinois Emergency Management Agency Manager, REP Section 1035 Outer Park Drive (1 st floor)

Springfield, Illinois, 62704 217-785-9886 William.Conway@Illinois.gov Jerry DeYoung Lead Offsite Controller Exelon Offsite Programs 4300 Winfield Road Warrenville, Illinois, 60555 630-657-4666 gerald.deyoung@exeloncorp.com Mike Muth Lead Offsite Planner 11

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Exelon Offsite Programs 4300 Winfield Road Warrenville, Illinois, 60555 630-657-4674 mike.muth@exeloncorp.com Rick Van Horn Lead Exercise Scenario Developer Exelon Corporate Drill and Exercise Coordinator 4300 Winfield Road Warrenville, Illinois, 60555 630-657-4652 richard.vanhom@exeloncorp.com 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Clinton Power Station exercise:

State Jurisdictions State of Illinois Response Center Communications Center Illinois Department of Natural Resources Illinois Department of Transportation Illinois Emergency Management Agency Illinois Emergency Management Agency Controller Illinois Environmental Protection Agency Illinois State Police Risk Jurisdictions Amateur Radio Emergency Services American Red Cross Bi-County Health Department Clinton Fire Department Clinton Police Department 12

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportl/hmprovement Plan Clinton Power Station DeWitt County Coroner DeWitt County Emergency Services & Disaster Agency DeWitt County Highway Department DeWitt County Sheriff DeWitt Village John Warner Hospital Parkland College Police Regional Superintendent of Schools Village of Clinton Village of Wapella WBNQ/WBWN/WJBC Support Jurisdictions Champaign County Emergency Management Agency Champaign County Public Health Champaign Police Department City of Decatur Fire Department City of Decatur Mayor City of Decatur Police Department Decatur Ambulance Service Decatur Memorial Hospital Exelon Observer Hickory Point Fire Department MABAS Representative Macon County 911 Macon County Board Chairperson Macon County Coroner Macon County Emergency Manager Macon County Health Department Macon County Highway Department Macon County Mental Health Board Macon County Sheriffs Department McLean County.911 Communications Center McLean County Administrator McLean County Assistant Administrator 13

Unclassified Radiologica] Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station McLean County Emergency Management Assistant Director McLean County Emergency Management Director McLean County Emergency Operations Administrative Assistant McLean County Sheriffs Office McLean County Sheriffs Office Deputy Piatt County 911 Communications Center Piatt County Board Chairperson Piatt County Emergency Manager Piatt County Emergency Operations Administrative Assistant Piatt County Emergency Services & Disaster Agency Piatt County Highway Department Piatt County Sheriffs Department St. Mary's Hospital St. Mary's Hospital EMS United Way 14

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design The DHS/FEMA Region V Office evaluated the CPS Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise conducted on November 18, 2009, to assess the capabilities of local emergency preparedness organizations in implementing their Radiological Emergency Response Plans (RERP) and procedures to protect the public health and safety during a radiological emergency involving CPS. 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 Exercise objectives and identified Capabilities/REP Criteria selected to be demonstrated are discussed in Appendix E "Exercise Plan."

2.3 Scenario Summary Appendix F "Scenario Details," contains a summary of the Exercise Scenario, a simulated sequence of events, that was used as the basis for invoking emergency response actions by Offsite Response Organizations (OROs) in the Clinton Power Station REP Partial Participation Plume Exposure Pathway exercise on November 18, 2009.

This exercise scenario was submitted by the State of Illinois and Exelon Nuclear and accepted by DHS/FEMA Region V on October 21, 2009.

During the exercise, in addition to information and data provided through the CPS onsite scenario, controllers from the State of Illinois 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.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After.Action Report/lnmprovement Plan Clinton Power Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the November 18, 2009, REP Partial Participation Plume Exposure Pathway Exercise conducted to test the offsite emergency response capabilities of State and local governments in the EPZ surrounding the CPS.

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 infonrmation on the exercise criteria and the extent-of-plýy agreements used in this-exercise are found in Appendix E "Exercise Plan" of this report.

Presented below are definitions of the terms 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 perfonriance 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.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station

P - Plan Issue - An observed or identified inadequacy in the ORO'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.

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

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

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of all exercise criteria from 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 information on the evaluation of each participating jurisdiction and functional entity in a jurisdiction-based, issues-only format.

The DHS has developed a standardized system for numbering exercise issues. This system is used to achieve consistency in numbering exercise issues among DHS Regions and site-specific exercise reports within each Region. It also is used to expedite tracking of exercise issues on a nationwide basis.

The identifying number of Deficiencies, ARCAs, and Plan 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 (13 for Clinton Power Station).

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station

Criterion Number - An alpha and two-digit number corresponding to the criteria numbers 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 = Plan Issue).

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

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' ' " Uirinassified Radiological Emergency. Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Table 3.1 - Summary of Exercise Evaluation (3 pages)

DATE: 2009-11-18 SITE: Clinton Power Station, IL U >

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

Demonstrated - U .a I M Mobilization Ial M M M M M M Facilities IbI Direction and Control lIl MIMIMIM M M M M M Communications Equipment Idl M MI M M M Equip & Supplies to support operations ei M M M M M M Emergency Worker Exposure Control 2al M M M Radiological Assessment and PARs 2b) M M Decisions for the Plume Phase -PADs 2b2 M M M M PADs for protection of special populations 2cl M M M Rad Assessment and Decision makingfor the Ingestion Exposure Pathway 2d]

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

-rtctv M ci Im~mnain~I

*.j I~* -T Implementation of emergency worker exposure control 3al M Implementation of KI decision 3bl M Implementation of protective actions for special populations - EOCs 3cl Implementation of protective actions for Schools 3c2 Implementation of traffic and access control 3d] M Impediments to evacuation are identified and resolved 3d2 M Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions 3fl Adequate Equipment for Plume Phase Field Measurements 4al Field'Tcams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4bl Laboratory operations 4c _

Emergency Natification system 5 'M M Activation of the prompt alert and notification system r 5aFatBe 5M M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5b, M P M M M Mon I decon of evacuees and emergency workers, and registration of 6al evacuees Mon / decon of emergency worker equipment 6b]

Temporary care of evacuees 6c I Transportation and treatment of contaminated injured individuals 6d]

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvemenw Plan Clinton Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/3)

DATE: 2009-11-18 U (

SITE: Clinton Power Station, IL i , CA M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not C ( u. ,-

Demonstrated U)n LO- cU U U

ýEidrcgeciiy'Operatmons MNilagenmenvi ,C .

Mobilization lal M M Facilities lbl I1 A1 Direction and Control Communications Equipment Idl _ M M M M M Equip & Supplies to support operations lel M M M M M P otective Actmoný1)66 wakn.4t4~~:

i,.,. CC. > > CVCn' C Emergency Worker Exposure Control 2a I Radiological Assessment and PARs 2b)

Decisions for the Plume Phase -PADs 2b2 M PADs for protection of special populations 2cl M I Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assess/Decision making concerning Relocation, Reentry, and Return 2e I Implementation of emergency worker exposure control 3al M ' MM M Implementation of KI decision 3b] M M M Implementation of protective actions for special populations - EOCs 3cl M Implementation of protective actions for Schools 3c2 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 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions 3fl Adequate Equipment for Plume Phase Field Measurements 4a I Pcild Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laboratory operations 4c I Activation of the prompt alert and notification system 5al M M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5bl M M e-Ay S'uppbrulli'upatiO's/F'acililL m M. 1 CC~ 1-1.7(('C>C'CC4CCC>

Mon / decon of evacuees and emergency workers, and registration of 6al M M M evacuees Mon / decon of emergency worker equipment 6b I M Temporary care of evacuees 6cl M Transportation and treatment of contaminated injured individuals 6dlw_ M M 20

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/3)

C DATE: 2009-11-18 *" c-SITE: Clinton Power Station, IL M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not , , - *u Demonstrated r' U 0 U _ U U 1urec ertoSManag'ement .. _

Mobilization lal MM M MM M M Facilities Ibi Direction and Control Icl M M M Communications Equipment Idl M M M M M MI M M M M Equip & Supplies to support operations lel M M M M MIMI M M PrOt&~tive Action DecisionMaking Emergency Worker Exposure Control 2a1 Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cI Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assess/Decision making concerning Relocation, Reentry, and Return 2e I Implementation of emergency worker exposure control 3al M M M M M M M M Implementation of KI decision 3bl M M MM MM M M Implementation of protective actions for special populations - EOCs 3cl Implementation of protective actions for Schools 3c2 M Implementation of traffic and access control 3d] M M M _ M M M M Impediments to evacuation are identified and resolved 3d2 M M M Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions 3f1`1 Fii lauuwtadAnalysis> ~ . . / .~ . .

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 ]

,EmergencyNotificat.ion and Pulic Info Activation of the prompt alert and notification system 5al Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5b)

Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bO Temporary care of evacuees 6c I Transportation and treatment of contaminated injured individuals 6dI 21

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station 3.3 Criteria Evaluation Summaries 3.3.1 Illinois Jurisdictions 3.3.1.1 State Initial Warning Point

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

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 3.3.1.2 SEOC/SIRC

a. M ET: .a. 1, 1.c. 1, I.d. 1, 1.e. 1, 2.a. 1, 2.b. 1,2.b.2, 2.c. 1, 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 3.3.1.3 Radiological Emergency Assessment Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 5.b.1.

ISSUE NO.: 13-09-5b]-P-01 CRITERION: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5., 7., G.3.a, G.4.a.b.c)

CONDITION: Residents of the Clinton I 0-mile EPZ were not notified that they may need to ingest KI after such a recommendation was made for emergency workers and 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station immobile persons.

POSSIBLE CAUSE: The Overview Section of the Illinois Plan for Radiological Accidents (IPRA, rev. Nov 2007) notes that "REAC will also recommend...that members of the general public with KI in their possession for such a contingency are advised to consider use of the drug through the JIC." Procedure RTF-PARS-2, "Potassium Iodide (KI) Recommendations," notes at Step 4.2.C that the REAC Manager is to "remind the Joint Information Center Radiological Liaison that the media should be advised to infonn the public that those with KI in their possession should consider consuming the drug at this time." The REAC Manager notified the JIC; however, no subsequent action was taken, nor was contemplated, by the JIC staff.

REFERENCE:

NUREG-0654/FEMA-REP-1, Planning Standard J. 10.e EFFECT: Members of the public who may have had KI in their possession would not have been notified that they should consume it.

RECOMMENDATION: Review the information contained within the IPRA and RTF-PARS-2 regafding KI information that is provided to the public and revise the procedures as required to ensure that they contain the same information and direction.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.4 Unified Area Command

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: 2.b.2.

ISSUE NO.: 13-09-2b2-D-0I CRITERION: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make PADs for the general public 23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station including KI if ORO policy.

CONDITION: CPS is centrally located within Sub-Area 1, which includes the entire 5-mile radius around the plant. The initial wind direction was from the west at 260 degrees, so any release would travel in the direction of IL Route 54, the designated evacuation route to the reception center at Parkland College. During the evacuation the wind shifted from 260 degrees to 228 degrees, thus drifting the plume directly over IL Route 54. People to the west of CPS were advised to evacuate Sub-Area 1 via IL 54 East or IL 10 East to Parkland College. TACPs were located around the perimeter of the three (1, 3, and 4) affected Sub-Areas, but not within them, and therefore would have been ineffective as a means of preventing public exposure to radioactive material as people evacuated Sub-Area 1 via the designated evacuation routes. Anyone traveling along IL 54 East would have been traversing through the plume pathway, would have been immersed within the plume, and would have been accumulating unnecessary radiological exposure.

POSSIBLE CAUSE: There was insufficient coordination between the UAC and the Radiological Emergency Assessment Center (REAC) in determining which designated facility would be utilized as the reception center.

REFERENCE:

NUREG-0654/FEMA-REP- 1, J.9, 10.m EFFECT: A portion of the public in Sub-Area I was being directed to use evacuation routes along the same path that the plume was traveling thereby receiving unnecessary radiological exposure,thus compromising health & safety.

RECOMMENDATION: Review the decision-making process for the selection of the reception centers that would minimize or eliminate unnecessary radiological exposure to the general public.

CORRECTIVE ACTION DEMONSTRATED: The Illinois Unified Area Command (UAC) successfully demonstrated its capability to use a decision-making process in a timely manner including considering appropriate factors to activate Reception Centers and provide evacuation routes. The successful demonstration occurred during the re-demonstration drill to rectify the Deficiency detected during the Clinton 24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Power Station (CPS) Radiological Emergency Preparedness Exercise conducted on Wednesday, November 18, 2009. The re-demonstration drill was held on January 28, 2010 at the Illinois State Emergency Operations Center (State EOC).

The state of Illinois had the necessary staff pre-positioned and activated at the State Incident Response Center (SIRC), Radiological Emergency Assessment Center (REAC) and the UAC which was staged in a separate area of the State EOC. The Illinois Emergency Management Agency (IEMA) controller provided a briefing and hand-out containing general information regarding the situation and the actions taken up to the point of play just prior to the re-demonstration drill. This information included Nuclear Accident Reporting System (NARS) forms of State Message No. 1, Site Area Emergency (SAE) and State Message No. 2, General Emergency (GE).

The GE NARS information included: the GE declared by CPS at 1008, radioactive gas release occurring, wind direction from 100 degrees with a speed of 6.0 mph, Protective Action Recommendations (PARs) of evacuation for Sub-Areas 1, 7 and 8 as well as the recommendation to administer Potassium Iodide (KI) per procedures.

The re-demonstration drill commenced at 1020 hours0.0118 days 0.283 hours 0.00169 weeks 3.8811e-4 months .

The UAC Incident Commander (IC) held a briefing with the UAC staff to communicate the conditions of the emergency. The brief included discussion of Sub-Areas 1, 7 and 8 to be evacuated and the possibility of Sub-Areas 2 and 6 could be affected should the wind shift. The IC further stated that the IEMA Radiological Assessment Field Teams (RAFT) staging area was Maroa, IL, the need for the UAC to plan for evacuation of the affected Sub-Areas, establish communication with Department of Transportation (DOT) to evaluate any impedirments to evacuation and request that Illinois State Police (ISP) and the affected counties prepare to post Traffic Access and Control Posts (TACPs).

The UAC team, consisting of the IC, Planning Chief (PC) and Radiological Response Chief (RRC) discussed the possible evacuation routes for Sub-Area I and which reception centers should be designated to receive the public. They noted that the public located in Sub-Area 8 and Sub-Area I west and north of Clinton would evacuate north to Horton Field House, public located in Sub-Area 7.and Sub-Area I west and south of Clinton, would evacuate south to Stephen-Decatur Middle School and public located in Sub'-Area I east of Clinton would evacuate east to Parkland 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvernent Plan Clinton Power Station College. The discussion then focused the evacuation routes and based on plume travel and reception center locations, the IC determined that Parkland College would not be needed. This was challenged by the RRC noting that all three should be opened so no evacuees would traverse the plume. The RRC suggested that they should direct Parkland College to be designated as a reception center so that evacuees east of Clinton would travel east to Parkland College and be traveling in the opposite direction of the projected plume. The PC was asked to contact ISP and verify that all evacuation routes were clear and passable and that no routes were restricted.

At 1036 hours0.012 days 0.288 hours 0.00171 weeks 3.94198e-4 months , the IC contacted the REAC Manager for a briefing of radiological conditions and discussed the UAC plan for evacuating the public from Sub-Areas 1, 7, and 8. The briefing included current and projected radiological conditions, division of Sub-Area 1 for evacuation, the designation of Highway 54 as the dividing line between north and south in Clinton, the thought process by which the IC chose which facilities to be activated as reception centers, directing RAFT to open the designated reception centers, and that-Emergency Workers within the 10-mile Emergency Planning Zone (EPZ) to take KI. During discussions with the REAC.

Manager the IC reaffirmed that Parkland College would not be required to be activated as a reception center.

At 1044 hours0.0121 days 0.29 hours 0.00173 weeks 3.97242e-4 months , the State EOC Manager called the IC and discussed actions being directed from the State EOC. The area around the CPS was restricted as ano-fly zone, rail traffic had been restricted and not allowed in the CPS EPZ and local recreational areas had been evacuated. The IC and State EOC Manager also discussed weather conditions, possible effects if weather conditions changed and ensuring that there had been contact with the National Weather Service for the most recent weather pattern predictions.

At 1057 hours0.0122 days 0.294 hours 0.00175 weeks 4.021885e-4 months , the IC held another UAC briefing to discuss current conditions and contingency planning. The RCC again suggested that Parkland College should be activated as a reception center and the PC agreed based on his calculation of the number of evacuees and the capacity of Horton Field House and Stephen-Decatur Middle School as reception centers. At 1058 hours0.0122 days 0.294 hours 0.00175 weeks 4.02569e-4 months , considering current conditions, evacuation routes and reception center capacities, the IC made the decision to activate Parkland College as a reception .center. The IC directed DOT and ISP to 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvemnent Plan Clinton Power Station have signs put in place to help direct traffic to Parkland College. He then called the State EOC Manager and updated him on the current actions in place as directed by the UAC.

At 1104 hours0.0128 days 0.307 hours 0.00183 weeks 4.20072e-4 months , the IC called the REAC Manager and verified radiological conditions and that the actions being taken to activate all three reception centers was in line with current radiological conditions, plume dispersion and does projections. At 1107 hours0.0128 days 0.308 hours 0.00183 weeks 4.212135e-4 months the IC called the State EOC Manager and explained the current plan for evacuation including an update of evacuation routes disseminated to the public. The State EOC Manager concurred with/the assessment of evacuation and informed the IC that the evacuation message would be disseminated to the public through DeWitt County EOC. As the call ended, the RRC asked what the current conditions were and noted that he did not have the understanding that Parkland College had been directed to activate as a reception center. He concurred with activation of Parkland College and stated that evacuation routes need to be evaluated as to not direct evacuees to traverse through the plume. The UAC staff then discussed the current evacuation plan, routes of travel and verification that no impediments to evacuation existed.

At 1112 hours0.0129 days 0.309 hours 0.00184 weeks 4.23116e-4 months , the SEOC Manager called the IC and notified him that DeWitt County had broadcast to the public the current evacuation routes and directions.

They'discussed the status of the CPS and that weather conditions were stable and expected to remain so for the immediate future.

The drill was terminated at 1115 hours0.0129 days 0.31 hours 0.00184 weeks 4.242575e-4 months .

All activities described in the re-demonstration criterion were carried out in accordance with the plan, procedures and extent-of-play agreement.

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inprovement Plan Clinton Power Station 3.3.1.5 Emergency Operations Facility

a. MET: 1.a., I.c.i, le.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 3.3.1.6 Joint Information Center

a. M ET: 1.a.1, I.c., .d.1, l.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 3.3.1.7 Illinois State Radiological Advisor - DeWitt County

a. MET: 2.a.1,2.b.2,2.c.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 3.3.1.8 Illinois State Liaison - DeWitt County

a. MET: 1.c.1,5.a.1,5.b.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 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station 3.3.1.9 Illinois State Liaison - Macon County

a. MET: i.c..

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 3.3.1.10 Illinois State Liaison - McLean County

a. MET: 1.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 3.3.1.11 Illinois State Liaison - Piatt County

a. MET: 1.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 3.3.1.12 DCO Briefing - ISP District 6 Headquarters

a. MET: 1.e.1, 3.a.1,.3.b.].

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 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Clinton Power Station 3.3.1.13 TACP at the ISP District 6 Headquarters

a. MET: 1.e.],3.a.1,3.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 3.3.1.14 Medical Services (MS-i) Transport - St Marys Hosp

a. MET: Id., l.e.l, 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 3.3.1.15 Medical Services (MS-i) Hospital - St Marys Hosp

a. M ET: 1.d.l,l.e.l,3.a.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 3.3.1.16 Monitoring of Evacuees and Emergency Workers - Parkland College

a. MET: 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 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvernent Plan Clinton Power Station 3.3.1.17 Decontamination of Evacuees and Emergency Workers - Parkland College

a. MET: 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 3.3.1.18 Monitoring and Decontamination of Emergency Worker Equipment - Parkland College

a. MET: 6.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 3.3.1.19 Public Registration - Parkland College

a. MET: 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 Risk Jurisdictions 3.3.2.1 Congregate Care Center - Parkland College

a. MET: 6.c.I.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 Dewitt County - Initial Warning Point

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

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 Dewitt County - Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: I.c.1.

ISSUE NO.: 13-09-1cl-A-01 CRITERION: Key personnel with functional roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

CONDITION: At 1229 hours0.0142 days 0.341 hours 0.00203 weeks 4.676345e-4 months , the CBC, ESDA Coordinator, and two IEMA representatives departed the EOC to attend a media briefing located down the hall away from the EOC. There was no one delegated to provide direction and control during their absence, nor was anyone tasked with bringing important messages to them at the media briefing room if necessitated. At 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months , the CBC, ESDA Coordinator, and two IEMA representatives returned to the EOC. During the time they were out of the EOC (31 minutes), State NARS Message No.4 arrived, stating that a wind direction change had occurred, and the State did not recommend that Sub-area 2 be evacuated. Since the decision-makers were out of the room when this message arrived, and no delegate was present, the message sat on the desk and not acknowledged. The Mayor of Clinton noticed the message approximately 10 minutes after the forn arrived, and informed the Clinton Police Chief of the message, and that evacuation of Sub-area No.2 was not recommended. No other discussion concerning the wind direction change and its affect on Sub-area No.2 was identified or addressed 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station as a concern, even when the decision-makers returned fromthe media briefing.

POSSIBLE CAUSE: No one was delegated.to provide direction and/or control of the EOC operation during the absence of key personnel.

REFERENCE:

NURGEG-0654/FEMA-REP-1, Rev 1, A. 1.d; A.2.a; b Direction and Control EFFECT: Not having a decision-making process in the EOC for any amount of time could allow for missed PADs and/or delay in PADs being created and forwarded to the public. A delay in decision-making can result in putting the public's health and safety at risk.

RECOMMENDATION: Provide for delegation of authority during times that key decision-makers are not available in the EOC.

c. DEFICIENCY: None

d. PLAN ISSUES: None

.e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.4 Dewitt County - Traffic and Access Control Post

a. M ET: l.d.l, le.l, 3.a.1, 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 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportIlmprovement Plan Clinton Power Station 3.3.2.5 Dewitt County - Emergency Broadcast Stations

a. MET: 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 3.3.2.6 DeWitt County EV-2 Interview - Deland-Weldon

a. MET: 1.d.1, I.e.], 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 3.3.2.7 Traffic and Access Control Post - Clinton PD

a. MET: 1Le. 1, 3.a. 1, 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 3.3.2.8 Macon County - Initial Warning Point

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

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 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station 3.3.2.9 Macon County - Emergency Operations Center

a. M ET: Loa.1, l.c.1, l.d., le.l, 3.a.1, 3.b.1, 3.d.1, 3.d.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 3.3.2.10 Macon County - Traffic and Access Control Post

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

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 McLean County - Initial Warning Point

a. MET: 1.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 3.3.2.12 McLean County - Emergency Operations Center

a. M ET: l.a.], I.c., I.d., L.e.1,3.a.],3.b.1,3.d.A ,3.d.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 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station 3.3.2.13 McLean County - Traffic and Access Control Post

a. M ET: I.d.1, le.1, 3.a.1, 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 3.3.2.14 Piatt County - Initial Warning Point

a. MET: 1.a.1, I.d.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 3.3.2.15 Piatt County - Emergency Operations Center

a. M ET: 1.a.1, i.c., I.d., le.l, 3.a., 3.b.1, 3.d.1, 3.d.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 3.3.2.16 Piatt County - Traffic and Access Control Post

a. M ET: 1.d.1,].e.l,3.a.1,3.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 36

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lInprovernent Plan Clinton Power Station SECTION 4: CONCLUSION The U.S. Department of Homeland Security/Federal Emergency Management Agency identified a Deficiency finding during the Clinton Power Station's Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise, conducted on November 18, 2009.

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

The State received a Deficiency finding under Protective Action Decision-Making 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 use of KI if Offsite Response Organization (ORO) policy.

The Deficiency assessed was based on our findings that both the performance and the decision-making processes used by the Unified Area Command (UAC) in the selectionof Parkland College as the sole Reception Center resulted in a portion of the public in Sub-Area I being directed to use evacuation routes along the same path the plume was traveling, where they could have received unnecessary radiological exposure, thus compromising health & safety.

Because of the potential impact this finding has on public health and safety, a remedial exercise was conducted and successfully completed by the State on January 28, 2010.

37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action R~port/lmprovement Plan Clinton Power Station APPENDIX A: IMPROVEMENT PLAN Issu Numer 130 cl 0 CieonId ISSUE: At 1229 hours0.0142 days 0.341 hours 0.00203 weeks 4.676345e-4 months , the CBC, ESDA Coordinator, and two IEMA representatives departed the EOC to attend a media briefing located down the hall away from the EOC. There was no one delegated to provide direction and control during their absence, nor was anyone tasked with bringing important messages to them at the media briefing room if necessitated. At 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months , the CBC, ESDA Coordinator, and two IEMA representatives returned to the EOC. During the time they were out of the EOC (31 minutes), State NARS Message No.4 arrived, stating that a wind direction change had occurred, and the State did not recommend that Sub-area 2 be evacuated. Since the decision-makers were out of the room when this message, arrived, and no delegate was present, the message sat on the desk and not acknowledged. The Mayor of Clinton noticed the message approximately 10 minutes after the form arrived, and informed the Clinton Police Chief of the message, and that evacuation of Sub-area No.2 was not recommended. No other discussion concerning the wind direction, change and its'affect on Sub-area No.2 was identified or addressed as a concern, even when the decision-makers returned from the media briefing.

RECOMMENDATION: Provide for delegation of authority during times that key decision-makers are not available in the EOC.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: COMPLETION DATE:

ISSUE: Residents of the Clinton 10-mile EPZ were not notified that they may need to ingest KI after such a recommendation was made for emergency workers and immobile persons.

RECOMMENDATION: Review the information contained within the IPRA and RTF-PARS-2 regarding KI infonnation that is provided to the public and revise the procedures as required to ensure that they contain the same information and direction.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: COMPLETION DATE:*

38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station APPENDIX B: LESSONS LEARNED

1. Contraindications for the issuance of KI for ingestion Summary: During the Clinton Power Station Exercise conducted November 17, 2009, a controller inject message was given to a law enforcement representative located in the EOC. The inject stated that a law enforcement deputy in the field had concern regarding the order to ingest Potassium Iodide (KI), specifically 1OSAT TM. The deputy in the field had a known allergy to shellfish and the deputy was pregnant. The law enforcement representative in the EOC reviewed the Issuance of KI to Emergency Workers procedure, and then reaffirmed the recommendation for the deputy to ingest the KI tablet.

==

Description:==

The exercise evaluator questioned if the response that was provided by the EOC law enforcement representative was accurate. The exercise evaluator conferred with the EOC exercise controller who indicated that the response provided by the law enforcement representative was incorrect. Both the evaluator and the controller were under the assumption that the ingestion of KI with a known allergy to shellfish or a known pregnancy was contraindicated. Their assumption was based on training that they had previously received in their careers.

FEMA staff reviewed the Consumer Package Insert from the manufacturer of iOSAT TM. The review determined that it is not contraindicated toingest KI if one has a known allergy to shellfish or if one is pregnant.

Upon further investigation, the following information was obtained from the Food and Drug Administration (FDA), Center for Disease Control (CDC) and the three FDA approved manufacturers of KI (iOSAT TM, ThyroSafe TM, ThyroShield TM).

Who needs to take potassium iodide?

Infants (no. repeat dosing) and children

Pregnant & nursing females (no repeat dosing)

All ages 18-40

Over 40 ONLY if predicted exposure is high enough to destroy thyroid & induce lifelong hypothyroidism (this group also has greater change of having allergic reaction) 39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Who should not take potassium iodide?

Persons with known iodine sensitivity/allergies (not necessarily shellfish allergy)

Persons with certain skin disorders (dermatitis herpetiforrnis, hypocomplementemic vasculitis, Urticaria vasulitis)

Persons with thyroid disease (multinodular goiter, Graves disease, autoimmune thyroiditis)

LESSON LEARNED Contrary to the assumption made by the evaluator and controller, pregnant and nursing females may take one dose of KI. Additionally, a shellfish allergy does not necessarily indicate a known sensitivity or allergy to iodine.

Individuals that should not take KI include those with, persons with certain skin disorders, and persons with thyroid disease.

RECOMMENDATION To ensure compliance with the manufacturer recommendation for the ingestion of KI:

1. Review and update all training materials.

2. If applicable, supply updated information .to all affected personnel such as, but not limited to:

Instructors

Emergency Responders

General Public

Exercise scenario developers, controllers, and evaluators.

Sources

U.S. Food and Drug Administration, http://www.fda.gov

Centers for Disease Control and Prevention, http://www.bt.cdc.gov

Anbex Inc., manufacturers of iOSAT TM, http://www.anbex.comn

ThyroSafe TM, http://www.thyrosafe.com

ThyroShield TM, http://www.thyroshield.com/

40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station APPENDIX C: EXERCISE TIMELINE Table 1, on the following page, presents the times at which key events and activities occurred during the Clinton Power Station REP Partial Participation Plume Exposure Pathway exercise conducted on November 18, 2009. Also included are times notifications were made to the participating jurisdictions/functional entities.

Table 1 - Exercise Timeline DATE: 2009-11-18, SITE: Clinton Power Station, IL Unusual Event NA NA NA NA NA NA NA Alert 0834 0854 0855 0910 0904 0905 0908 Site Area Emergency 0942 0958 0952 1006 1005 1011 1015 General Emergency 1111 1127 1111 1140 1119 1138 1138 Simulated Rad. Release Started 1107 1127 1107 1140 1119 1138 1145 Simulated Rad. Release NA NA NA NA NA NA NA Terminated Facility Declared Operational 0900 0912 0915 0945 0950 1040 Declaration of State of Emergency 1116 NA NA NA NA 1232 Early Precautionary Action: The State issued 1007 1001 1045 NA NA NA order to evacuate state parks and hunting areas.

Early Precautionary Action: The State issued a 1016 0955 1023 NA NA NA Llivestock Advisory: All livestock to be sheltered adn placed on stored feed and water within 10-mile EPZ Early Precautionary Action: Air and rail traffic 1046 NA 1041 NA NA NA within 5 miles of CPS restricted G6teaislIlnformation Message: Public advised of NA NA NA NA 1020 NA incident at Clinton Power Station Siren Activation for General Information NA NA NA NA 1024 NA Message General Information EBS Complete NA NA NA NA 1025 NA Protective Action Recommendation to Evacuate 1127 1121 NA NA NA NA Sub-Areas 1, 3, and 4 1st Protective Action Decision: Evacuation of NA NA NA NA 1138 NA Sub-Areas 1,3, and 4 Siren Activation for Protective Action Decision NA NA NA NA 1140 NA 1st EBS Message Complete NA NA NA NA 1200 NA KI Administration Decision 1127 1114 1140 NA. 1140 1150 (SEOC/REAC)/Implemented (UAC/Counties):

Exercise Terminated 1330 1330 1406 1344 1333 1315 41

Unclassified Radiological Emergency PreparednessProgram (REP)

After Action Report/Improvement Plan Clinton Power Station Table 1 - Exercise Timeline DATE: 2009-11-18, SITE: Clinton Power Station, IL Emiergeney, kLast-iýcatios~O IEv-nt V

K.~

~A Unusual Event NA NA NA Alert 0834 0916 0904 Site Area Emergency 0942 1016 1005 General Emergency 1111 1146 1119 Simulated Rad. Release Started 1107 1146 1119 Simulated Rad. Release Terminated NA NA NA Facility Declared Operational 1014 0945 Declaration of State of Emergency NA 1138 Early Precautionary Action: The State issued order NA NA to evacuate state parks and hunting areas.

Early Precautionary Action: The State issued a NA NA Llivestock Advisory: All livestock to be sheltered adn placed on stored feed and water within I 0-mile EPZ Early Precautionary Action: Air and rail traffic NA NA within 5 miles of CPS restricted General Information Message: Public advised of NA NA incident at Clinton Power Station Siren Activation for General Information Message NA NA General Information EBS Complete NA NA Protective Action Recommendation to Evacuate NA NA Sub-Areas 1, 3, and 4 I st Protective Action Decision: Evacuation of Sub- NA NA Areas 1,3, and 4 Siren Activation for Protective Action Decision NA NA 1st EBS Message Complete NA NA KI Administration Decision 1149 1143 (SEOC/REAC)/Implemented (UAC/Counties):

Exercise Terminated 1136 1344 42

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station APPENDIX D: EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel that evaluated the Clinton Power Station REP Partial Participation Plume Exposure Pathway Exercise on November 18, 2009. The list includes the evaluation team leadership and all evaluators. The organization each evaluator represents is indicated by the following abbreviations:

DHS/FEMA Dept of Homeland Security/Federal Emergency Management Agency ICF Consulting Title Name Organization Radiological Assistance Committee, Chainnan William E. King DHS/FEMA Exercise Director Stephen Tulley DHS/FEMA Senior Specialist Gary Naskrent DHS/FEMA Site Specialist Todd M. Gemskie DHS/FEMA Team Leader - Illinois Deborah Fulk DHS/FEMA Team Leader - DeWitt County Bridget Ahlgrim DHS/FEMA Team Leader - Macon County James King DHS/FEMA Team Leader - McLean County Ed Golinski DHS/FEMA Team Leader - Piatt County Ed Diaz DHS/FEMA 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton .Power Station DATE: 2009-11-18, SITE: Clinton Power Station, IL State Initial Warning Point Robert Black ICF SEOC/SIRC Robert Black ICF William Sulinckas DHS/FEMA Radiological Emergency Assessment Center Thomas Essig ICF Garianne Howard ICF Unified Area Command Simon Guereca ICF Wes Ryals ICF Emergency Operations Facility Deborah Bell ICF Joint Information Center Deborah Bell ICF George R MacDonald ICF Illinois State Radiological Advisor - DeWitt County Clinton Crackel DHS/FEMA Illinois State Liaison - DeWitt County David Ortman DHS/FEMA Illinois State Liaison - Macon County Kara Scott DHS/FEMA Illinois State Liaison - McLean County Carl Bebrich DHS/FEMA Illinois State Liaison - Piatt County Carolyn Sturghill DHS/FEMA DCO Briefing - ISP District 6 Headquarters Simon Guereca ICF TACP at the ISP District 6 Headquarters David Petta ICF Medical Services (MS-I) Transport - St Marys Hosp Richard Grundstrom ICF Medical Services (MS-I) Hospital - St Marys Hosp Deborah Bell ICF Monitoring of Evacuees and Emergency Workers - Parkland College Wes Ryals ICF Decontamination of Evacuees and Emergency Workers - Parkland Wes Ryals ICF College Monitoring and Decontamination of Emergency WorkerEquipment - Wes Ryals. ICF Parkland College Public Registration - Parkland College Wes Ryals ICF Congregate Care Center - Parkland College Todd Gemskie DHS/FEMA Dewitt County - Initial Warning Point David Petta ICF Dewitt County - Emergency Operations Center Gary Bolender ICF Clinton Crackel DHS/FEMA Todd Davidson ICF.

Todd Gemskie DHS/FEMA Dewitt County - Traffic and Access Control Post David Ortman DHS/FEMA Dewitt County - Emergency Broadcast Stations David Petta ICF DeWitt County EV-2 Interview - Deland-Weldon George R MacDonald ICF Traffic and Access Control Post - Clinton PD Gary Bolender ICF Macon County - Initial Warning Point Kara Scott DHS/FEMA Macon County - Emergency Operations Center Sonia Eischen ICF

Jamnes King DHS/FEMA Kara Scott DHS/FEMA Macon County - Traffic and Access Control Post Sonia Eischen ICF McLean County - Initial Warning Point Carl Bcbrich DHS/FEMA McLean County - Emergency Operations Center Carl Bebrich DHIS/FEMA

Edward Golinski DHS/FEMA Todd Sniffin ICF McLean County - Traffic and Access Control Post Todd Sniffin ICF Piatt County - Initial Warning Point Carolyn Sturghill DI-S/FEMA 44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan I Clinton Power Station Piatt County - Emergency Operations Center *Edward Diaz DHS/FEMA Richard Smith ICF Carolyn Sturghill DHS/FEMA Piatt County - Traffic and Access Control Post Richard Smith ICF 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Clinton Power Station APPENDIX E: ACRONYMS AND ABBREVIATIONS ACA Assistant County Administrator ARC American Red Cross ARCA Area Requiring Corrective Action ARES Amateur Radio Emergency Services CBC County Board Chairman CCC Congregate Care Centers CDE Committed Dose Equivalent CPS Clinton Power Station CUSD Consolidated Unit School District DCO Dosimetry Control Officer DHS Department of Homeland Security EAL Emergency Action Level EBS Emergency Broadcast System ECL Emergency Classification Level EMA Emergency Management Agency EMAC Emergency Management Agency Coordinator EMC Emergency Management Coordinator EOC Emergency Operations Center EOF Emergency Operations Facility EPZ Emergency Planning Zone ERT Emergency Response Telecommunicators ESDA _ Emergency Services Disaster Agency FEMA Federal Emergency Management Agency GE General Emergency GEMS Gaseous Effluent Monitoring System IC Incident Commander ICC Illinois Commerce Commission JEMA Illinois Emergency Management Agency IEPA Illinois Environmental Protection Agency ISP Illinois State Police ISU Illinois State University ITECS Illinois Transportable Emergency Communication System IWP Initial Warning Point JIC Joint Information Center 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station LD Luminescent Dosimeter MDC Mobile Data Computer NARS Nuclear Accident Reporting System NMT Nuclear Med Techs NRC Nuclear Regulatory Commission NWS National Weather Service ORO Offsite Response Organization OSL Optically Stimulated Luminescence PAD Protective Action Decision PAR Protective Action Recommendation PD Police Department PIO Public Information Officer RAC Regional Assistance Committee RAFT Radiological Assessment Field Team REA Radiological Emergency Area REAC Radiological Emergency Assistance Center REP Radiological Emergency Preparedness RN Registered Nurse RO Radiological Officer RRC Radiological Response Chief SAE Site Area Emergency SEOC State Emergency Operations Center SGTS Standby Gas Treatment System SOP Standard Operating Procedure TACP Traffic Access Control Post TCO TACP Coordination Officer TEDE Total Effective Dose Equivalent

,UAC Unified Area Command VOIP Voice Over Internet Protocol 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station APPENDIX F: EXERCISE PLAN This appendix lists the exercise criteria, which were scheduled for demonstration in the Clinton Power Station Radiological Emergency Preparedness Partial Participation Plume Exposure Pathway Exercise on November 18, 2009.and the offsite extent-of-play agreement accepted by DHS/FEMA Region V on October 21, 2009. The exercise criteria, contained in the FEMA "Radiological Emergency Preparedness Exercise Evaluation Methodology; Notice," as published in the Federal Register Notice/Vol. 67, dated April 25, 2002, represent'a functional translation of the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Rev], "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 accepted by DHS/FEMA to provide evaluators with guidance on expected actual demonstration of the criteria.

Exercise Criteria Listed on the following pages are the specific radiological emergency preparedness criteria that were scheduled for demonstration during this exercise.

48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 Criteria that can be re-demonstrated immediately for credit, at the discretion of the evaluator, include the following: 3.a.], 3.d.], 3.d.2, 6.a.1, 6.b.1, 6.c.1 and 6.d.1 (Note criterion are italicized). Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chairperson of the Regional Assistance Committee, include the following: 2.a. l, 2.b. l, 2.b.2, 5.a.1 and 5.b. 1.

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

State of Illinois: The State Emergency Operations Center (SEOC), which houses the IEMA Communications Center (Initial Warning Point), the State of Illinois Response Center (SIRC) and the Radiological Emergency Assessment Center (REAC), will be activated. The IEMA Emergency Response Telecommunicator will implement procedures for notification of IEMA staff as defined in IEMA SOPs. The SIRC will be partially activated with IEMA personnel.

REAC will be fully activated. Rosters will be provided to demonstrate 24-hour staffing of the SIRC and REAC. The evaluator will not be allowed to remove the rosters.

The Unified Area Command (UAC) will be activated with State district and regional personnel at the Central Illinois Regional Airport in Bloomington. Radiological Assessment Field Team (RAFT) will be activated for training purposes. IEMA personnel will be prepositioned in the local'area and dispatched to the County EOCs, UAC, EOF, Technical Support Center (TSC) and the JIC. FEMA will not evaluate the TSC.

An actual phone call will be made to the FEMA duty officer advising them of the situation at Clinton Station. Follow up calls to FEMA will be simulated.

The prepositioned State staff will begin exercise play no earlier than the Alert.

Dewitt County: DeWitt County intends to fully activate the Emergency Operations Center (EOC) in Clinton, Illinois. The County will implement notification procedures as defined in IPRA-Clinton. Representatives from the EPZ municipalities, IEMA and Exelon will staff the County EOC but will not be pre-positioned in the EOC. A roster will be provided to demonstrate 24-hour staffing of the EOC. Evaluators will not be allowed to remove the roster from the EOC.

An evaluator will be positioned at the County Sheriff s- Communications Center (initial warning point) at the start of the exercise..

Macon County: Macon County intends to activate the Emergency Operations Center (EOC) in Decatur, Illinois, to the appropriate level. The County will implement notification procedures as defined in IPRA-Clinton. The EOC will be staffed with representatives from the County Board, EMA, and the Sheriffs Department. If the scenario does not drive proteýive actions in Macon County, the County may decide to down staff the EOC to minimum staffing. A roster will be 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 provided to demonstrate 24-hour County staffing of the EOC. Evaluators will not be allowed to remove the roster from the EOC.

An evaluator will be positioned at the County Sheriffs Communications Center (initial warning point) at the start of the exercise.

McLean County: McLean County intends to activate the Emergency Operations Center (EOC.)

in Bloomington, Illinois, to the appropriate level. The County will implement notification procedures as defined in IPRA-Clinton. The EOC will be staffed with representatives from the County Administrator's Office, EMA, and the Sheriffs Department. If the scenario does not drive protective actions in McLean County, the County may decide to down staff the EOC to minimum staffing. A roster will be provided to demonstrate 24-hour County staffing of the EOC. Evaluators will not be allowed to remove the roster from the EOC.

An evaluator will be positioned at the County Sheriffs Communications Center (initial warning point) at the start of the exercise.

Piatt County: Piatt County intends to activate the Emergency Operations Center (EOC) in Monticello, Illinois, to the appropriate level. The County will implement notification procedures as defined in IPRA-Clinton. The EOC will be staffed with representatives from the County Board, EMA and the Sheriffs Department. If the scenario does not drive protective actions in Piatt County, the County may decide to down staff the EOC to minimum staffing. A roster will be provided to demonstrate 24-hour County staffing of the EOC. Evaluators will not be allowed to remove the roster from the EOC.

An evaluator will be positioned at the County Sheriffs Communications Center (initial warning point) at the start of the exercise.

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

This criterion will not be demonstrated during this exercise.

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.

State of Illinois: The ability to direct and control emergency response activities will be demonstrated at the SIRC, REAC, the UAC and the JIC. Coordination will be demonstrated between the SIRC, the REAC, the UAC, the JIC, the EOF and the county EOCs.

Dewitt County: Decision making will be demonstrated at the DeWitt County EOC.

Coordination of decisions and emergency activities will be demonstrated between DeWitt 50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 County, the SIRC, UAC and the JIC, and between the County and municipalities within the EPZ.

Coordination between DeWitt County and the support counties will be demonstrated.

Macon County: Coordination of decisions and emergency activities will be demonstrated between Macon County and DeWitt County..

McLean County: Coordination of decisions, and emergency activities will be demonstrated between McLean County and DeWitt County.

Piatt County: Coordination of decisions and emergency activities will be demonstrated between Piatt County and DeWitt County.

Criterion L.d.l: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency'operations.

State of Illinois: IEMA will use a variety of communication systems [Nuclear Accident Reporting System (NARS), telefax, commercial telephone, cellular phone, radio] to communicate with other organizations and locations.

Dewitt County: DeWitt County will use NARS, commercialtelephone, radio and telefax to communicate with departments and agencies at other locations.

Macon County: Macon County will use commercial telephone, radio and telefax to communicate with departments and agencies at other locations.

McLean County: McLean County will use commercial telephone, radio and telefax to communicate with departments and agencies at other locations.

Piatt County: Piatt County will use commercial telephone, radio and telefax to communicate with departments and agencies at other locations.

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

State of Illinois:

The State of Illinois will demonstrate the use of equipment, maps and displays to support emergency operations. Dosimetry Control Officer (DCO) logs will be available in each County EOC.

A DCO briefing/Traffic and Access Control (TAC) interview will be conducted by the Illinois State Police on November 17, 11 a.m. (confirmed) at the ISP District 6 Headquarters in Pontiac.

51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 During this event, the availability of dosimetry will be demonstrated. No more than 10% of the ISP District 6 dosimetry kits will be inspected during the interview to confirm serial numbers.

Dewitt County: DeWitt County will demonstrate the ability to support operations through the use of maps, status boards and other displays as appropriate. DCO logs will be available from the IEMA Radiological Advisor in the DeWitt County EOC. The availability of dosimetry and KI will be demonstrated during the traffic and access control demonstration and the school interview. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the DeWitt County EOC. The DCO briefing for the Clinton Police officer demonstrating traffic and access control will be conducted-at the Clinton Police Department.

Macon County: Macon County will adequately demonstrate the ability to support operations through the use of maps, status boards and other displays as appropriate. The availability of dosimetry and KI will be demonstrated during the traffic and access control demonstration. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC.

McLean County: McLean County will adequately demonstrate the ability to support operations through the use of maps, status boards and other displays as appropriate. The availability of dosimetry and KI will be demonstrated during the traffic and access control demonstration. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC.

Piatt County: Piatt County will adequately demonstrate the ability to support operations through the use of maps, status boards and other displays as appropriate. The availability of dosimetry and KI will be demonstrated during the traffic and access control demonstration. The DCO briefing for the deputy, demonstrating traffic and access control will be conducted at the County EOC.

EVALUATION AREA 2 - PROTECTIVE ACTION DECISION MAKING Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of K1, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

State of Illinois: The ability to make the decision to recommend the use of KI to emergency workers will be demonstrated in REAC.

A message will be injected to the IEMA Radiological Advisor in the DeWitt County EOC to drive the decision to authorize exposure in excess of administrative limits.

52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 This criterion does not apply to the counties.

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.

State of Illinois: The REAC will evaluate the licensee information and complete independent dose projections based on that information and simulated field monitoring data. REAC will make an evaluation of the data and make a protective action recommendation to the SIRC.

This criterion does not apply to the counties.

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).

State of Illinois: The coordination to determine protective action recommendations (PARs) based upon available shelters, evacuation time estimates and other relevant factors will be demonstrated between the SIRC and REAC. The State PAR will be transmitted to DeWitt County via NARS.

The capability to determine which centers should be activated for monitoring, decontamination, registration reception and congregate care will be demonstrated at UAC, with input from the SIRC and REAC.

Dewitt County: The State of Illinois will provide protective action recommendations to DeWitt County officials in the County EOC. The DeWitt County officials will make the final decision regarding what protective actions will be recommended to the public.

This function is responsibility of DeWitt County and this criterion does not apply to Macon, McLean or Piatt counties.

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

State of Illinois: The coordination to determine protective action recommendations (PARs) based upon available shelters, evacuation time estimates and other relevant factors will be demonstrated between the SIRC and REAC. The State PAR will be transmitted to DeWitt County via NARS.

53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 The ability to make the decision to recommend the use of KI to institutionalized persons will be demonstrated in REAC.

Dewitt County: The State of Illinois will provide protective action recommendations to DeWitt County officials in the County EOC. The DeWitt County officials will make the final decision regarding what protective actions will be recommended for special population groups.

This function is responsibility of DeWitt County and this criterion does not apply to Macon, McLean or Piatt counties.

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

This criterion will not be demonstrated during this exercise.

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 OROs plan and/or procedures.

This criterion will not be demonstrated during this exercise.

54

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 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.

State of Illinois: This will be demonstrated during the ISP DCO briefing/TAC interview will be conducted on November 17, 11 a.m. (confirmed), at the ISP District 6 Headquarters in Pontiac.

Dewitt County: DeWitt County will demonstrate this criterion by close coordination with the IEMA Radiological Advisor and timely dissemination and exchange of information within the County Dosimetry Control Officer network. Exercise messages will be injected which will ensure the opportunity to demonstrate this criterion in the County EOC.

This criterion will also be demonstrated during the traffic and access control demonstrations and the school interview. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the DeWitt County EOC. The DCO briefing for the Clinton -Police officer demonstrating traffic and access control will be conducted at the Clinton Police Department.

Macon County: Macon County will demonstrate this criterion by close coordination with IEMA and timely dissemination and exchange of information within the County Dosimetry Control Officer network.

This criterion will also be demonstrated during the traffic and access control demonstration. The Sheriffs deputy will obtain dosimetry from the DCO in the County EOC. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC.

McLean County: McLean County will demonstrate this criterion by close coordination with IEMA and timely dissemination and exchange of information within the County Dosimetry Control Officer network.

This criterion will also be demonstrated during the traffic and access control demonstration. The Sheriffs deputy will obtain dosimetry from the DCO in the County EOC. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC.

Piatt County: Piatt County will demonstrate this criterion by close coordination with IEMA and timely dissemination and exchange of information within the County Dosimetry Control Officer network.

55

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 This criterion will also be demonstrated during the traffic and access control demonstration. The Sheriff's deputy will obtain dosimetry from the DCO in the County EOC. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC.

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.

State of Illinois: This will be demonstrated during the ISP DCO briefing/TAC interview will be conducted on November 17, 11 a.m. (confirmed), at the ISP District 6 Headquarters in Pontiac.

Dewitt County: When notified by the State of Illinois to distribute and administer KI, DeWitt County officials will discuss the issuance of KI to emergency workers and immobile populations, as a voluntary measure, and will notify the municipalities of the State's recommendation.

This criterion will also be demonstrated during the traffic control demonstrations and the school interview. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the DeWitt County EOC. The DCO briefing for the Clinton Police officer demonstrating traffic and access control will be conducted at the Clinton Police Department.

Macon County: When notified by the State of Illinois to distribute and administer KI, Macon County officials will discuss the issuance of KI to emergency workers and immobile populations, as a voluntary measure. This criterion will also be demonstrated during the traffic and access control demonstration. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC.

McLean County: When notified by the State of Illinois to distribute and administer KI, McLean County officials will discuss the issuance of KI to emergency workers and, immobile populations, as a voluntary measure. This criterion will also be demonstrated during the traffic and access control demonstration. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC.

Piatt County: When notified by the State of Illinois to distribute and administer KI, Piatt County officials will discuss the issuance of KI to emergency workers and immobile populations, as a voluntary measure. This criterion will also be demonstrated during the traffic and access control demonstration. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC..

This criterion will also be demonstrated during the traffic and access control demonstration. The Sheriffs deputy will obtain dosimetry from the DCO in the County EOC. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County EOC.

56

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 Criterion 3.c.1: Protective action decisions are implemented for special population groups within areas subject to protective actions.

State of Illinois: This criterion does not apply to the State of Illinois.

Dewitt County: This will be demonstrated by DeWitt County through the simulated implementation of the appropriate procedures. The appropriate officials will coordinate transportation and receiving facilities for special populations. One of each type of special facility will be contacted during the exercise. One of each type of transportation provider (ambulance/bus) will be contacted during the exercise. The public will not be involved in the demonstration.

The Mobility Impaired List will be available for inspection in the County EOC during the exercise. The evaluator will not be allowed to remove the list from the EOC.

This function is responsibility of DeWitt County and this criterion does not apply to Macon, McLean or Piatt counties.

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

State of Illinois: This criterion does not apply to the State of Illinois.

Dewitt County: DeWitt County officials will demonstrate this capability through the simulated implementation of the appropriate procedures in the county EOC. The EPZ schools and transportation providers will be contacted during the exercise.

A school interview will be conducted with the Deland-Weldon School District on November 17, 9 a.m. (confirmed), in the District Office. The District Superintendent, a Principal, a Teacher, the transportation coordinator (DCO), the maintenance supervisor and a bus driver will be present at the interview.

This function is responsibility of DeWitt County and this criterion does not apply to Macon, McLean or Piatt counties.

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

State of Illinois: This will be demonstrated by the State through coordination between the UAC and the County EOCs, in accordance with the Clinton Station EPZ Traffic and Access Control procedures. The staffing of the State posts will be simulated during the exercise.

57

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 A TAC demonstration will be conducted in conjunction with the DCO briefing on November 17, 11 a.m. (confirmed), at the ISP District 6 Headquarters in Pontiac.

Dewitt County: Coordination between DeWitt County agencies designated to provide traffic and access control will be exhibited in the County EOC. A Sheriffs deputy will be available during the exercise to demonstrate the staffing of one post. The post for the demonstration will be selected by DeWitt County during the exercise based on exercise play. The deputy will drive to the selected post location for the demonstration. The staffing of the remaining posts will be simulated.

A Clinton Police officer will be available to demonstrate the staffing of one post. The post for the demonstration will be selected by the Clinton Police Department during the exercise based on exercise play if the scenario causes Clinton to staff posts. If it does not, the post will be selected by the evaluator.

Macon County: Coordination between Macon County and DeWitt County will be demonstrated. A Sheriffs deputy will be available during the exercise to demonstrate the staffing of one post. The post for the demonstration will be selected by Macon County during the exercise based on exercise play if the scenario causes Macon County to staff posts. If it does not, the post will be selected by the evaluator. The deputy will drive to the selected post location for the demonstration. The staffing of the remaining posts will be simulated.

McLean County: Coordination between McLean County and DeWitt County will be demonstrated. A Sheriffs deputy will be available during the exercise to demonstrate the staffing of one post. The post for the demonstration will be selected by McLean County during the exercise based on exercise play if the scenario causes McLean County to staff posts. If it does not, the post will be selected by the evaluator. The deputy will drive to the selected post location for the demonstration. The staffing of the remaining posts will be simulated.

Piatt County: Coordination between Piatt County and DeWitt County will be demonstrated. A Sheriffs deputy will be available during the exercise to demonstrate the staffing of one post.

The post for the demonstration will be selected by Piatt County during the exercise based on exercise play if the scenario causes Piatt County to staff posts. If it does not, the post will be selected by the evaluator. The deputy will drive to the selected post location for the demonstration. The staffing of the remaining posts will be simulated.

Criterion3.d.2: Impediments to evacuation are identified and resolved.

State of Illinois: This will be demonstrated through discussions at the UAC between the Illinois State Police and Illinois Department of Transportation. A message will be injected at the UAC that will drive this demonstration. State personnel will deal with the impediment by discussing 58

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY' AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 the need for equipment, and its estimated time of arrival, etc. Actual contacts with resource providers will be made and logged.

Dewitt County: The DeWitt County EOC staff will demonstrate the capability to identify and take appropriate actions concerning impediments to evacuation. A message will be injected by the Controller that will drive this demonstration. County personnel will deal with the impediment by identifying the equipment needed, discussing its estimated time of arrival, etc.

Actual contacts with resource providers will be made and logged.

Macon County: The Macon County EOC staff will demonstrate the capability to identify and take appropriate actions concerning impediments to evacuation. A message will be injected by the Controller that will drive this demonstration. County personnel will deal with the impediment by identifying the equipment needed, discussing its estimated time of arrival, etc.

Actual contacts with resource providers will be made and logged.

McLean County: The McLean County EOC staff will demonstrate the capability to identify and take appropriate actions concerning impediments to evacuation. A message will be injected by the Controller that will drive this demonstration. County personnel will deal with the impediment by identifying the equipment needed, discussing its estimated time of arrival, etc.

Actual contacts with resource providers will be made and logged.

Piatt County: The Piatt County EOC staff will demonstrate the capability to identify and take appropriate actions concerning impediments to evacuation. A message will be injected by the Controller that will drive this demonstration. County personnel will deal with the impediment by identifying the equipment needed, discussing its estimated time of arrival, etc. Actual contacts with resource providers will be made and logged.

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.

This criterion will not be demonstrated during this 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.

This criterion will not be demonstrated during this exercise.

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.

This criterion will not be demonstrated during this exercise.

59

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 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.

This criterion will not be demonstrated during this exercise.

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

This criterion will not be demonstrated during this exercise.

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.

This criterion will not be demonstrated during this exercise.

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.

This criterion will not be demonstrated during this exercise.

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

This criterion will not be demonstrated during this exercise.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 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 offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current DHS REP guidance.

State of Illinois: The State's role in demonstrating this criterion is. limited to transmitting the State's protective action recommendation (PAR) to the counties and monitoring the instructional messages provided to the public by the counties. This monitoring will be accomplished, by IEMA representatives in the DeWitt County EOC.

Dewitt County: DeWitt County will demonstrate the capability to provide both an alert signal and an initial instructional message to populated areas throughout the 10-mile plume pathway EPZ .in a timely manner after their decision to activate the alert and notification system to implement protective action recommendations (PAR).

This capability will be demonstrated through the simulated activation of the Clinton Station EPZ Siren Warning System as defined in IPRA-Clinton. The Siren Warning System (outdoor warning sirens) will not be activated during the exercise.

The ability to provide instructions to the public will be demonstrated through the simulated activation of the local radio station (WBNQ/WBWN/WJBC). The local radio station will be contacted during the first, and possibly the second, alert and notification sequence. An evaluator and a controller will be positioned at the radio station during the exercise to monitor for a message containing a PAR. If the initial message does not contain a PAR, the evaluator and controller will stay at the radio station for the second message.

This function is responsibility of DeWitt County and this criterion does not apply to Macon, McLean or Piatt counties.

Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Activities associated with DHS 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.

State of Illinois: This criterion does not apply to the State of Illinois.

61

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 Dewitt County: This criterion is not selected.

This function is responsibility of DeWitt County and this criterion does not apply to Macon, McLean or Piatt counties.

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

State of Illinois: This will be demonstrated at the JIC in coordination with the SIRC, REAC, UAC and the DeWitt County EOC. IEMA personnel will be present at the JIC to coordinate with the Exelon staff. Media briefings will be conducted at the JIC. A livestock advisory will be issued to the media from the JIC or the SIRC when appropriate.

A rumor control phone bank for public inquiries will not be operated by the State during the exercise.

Dewitt County: DeWitt.County will demonstrate this criterion by using pre-scripted messages as indicated in IPRA-Clinton. Contact with the radio station will be simulated for each alert and notification sequence following the sequence issuing the initial PAR.

The ability to provide information to the media will be demonstrated by DeWitt County through briefings held at the DeWitt County media briefing location. If real media are not present for the briefings, the controller and observers will serve as mock media. Evaluators will not serve as mock media.

The ability to deal with rumors will be demonstrated by DeWitt County through coordination between the County EOC and the JIC. The DeWitt County EOC controller will inject exercise messages that will ensure the opportunity to demonstrate this criterion. County officials will investigate and address "rumors." If appropriate, the "rumors" will be coordinated between State and County officials in the County EOC and the JIC.

County emergency broadcast messages and news releases, if issued, will be faxed to the JIC.

This function is responsibility of DeWitt County and this criterion does not apply to Macon, McLean or Piatt counties.

62

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station COMBINED EXTENT-OF-PLAY AGREEMENTS BY CRITERION CLINTON STATION EXERCISE November 18, 2009 EVALUATION AREA 6 - SUPPORT OPERATION/FACILITIES This evaluation area does not apply to the counties.

Criterion 6.a.]: 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.

An interview of State and local officials and inspection of Parkland College will be conducted on November 17, at 9 a.m. (tentative). The following organizations will be represented at the interview: local EMA, Police and Fire Departments, American Red Cross and IEMA. Evacuees will not be processed. The supply list and monitoring equipment will not be available at the interview/inspection. A dosimetry briefing will not be conducted during the interview/inspection.

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

An interview of State and local officials and inspection of Parkland College will be conducted on November 17, at 9 a.m. (tentative). The following organizations will be represented at the interview: local EMA, Police and Fire Departments and IEMA. Emergency worker equipment will not be processed. The supply list and monitoring equipment will not be available at the interview/inspection. A dosimetry briefing will not be conducted during the interview/inspection.

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.

An interview of local officials and inspection of Parkland College will be conducted on November 17, at 9 a.m. (tentative). Representatives of the American Red Cross will be present for the interview. Evacuees will not be processed. Equipment will not be available at the interview/inspection.

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.

This criterion will be demonstrated during an out of sequence drill conducted at St. Mary's Hospital in Decatur on November 17, 1:00 p.m. (confirmed).

63

UnClassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station APPENDIX G: SCENARIO DETAILS This appendix contains a summary of the Exercise Scenario, a simulated sequence of events, that was used as the basis for invoking emergency response actions by Offsite Response Organizations (OROs) in the Clinton Power Station REP Partial Participation Plume Exposure Pathway exercise on November 18, 2009.

Results of a technical review of the scenario, submitted by the State of Illinois and Exelon Nuclear on September 17, 2009, indicated that the scenario was adequate to support demonstration of Department of Homeland Security's requirements, as well as criteria selected by the Offsite Response Organizations provided in the State's July 18, 2009, extent-of-play submission.

This exercise scenario was accepted by DHS/FEMA Region V on October 21, 2009.

During the exercise, in addition to information and data provided through the CPS onsite scenario, controllers from the State of Illinois gave "inject messages" containing scenario events and/or relevant data to those persons or locations who would normally receive notification of such events. The inject messages were the method used for invoking additional specific response actions by OROs.

DHS/FEMA concurred with the offsite scenario and extent-of-play submission for the State of Illinois, DeWitt, Macon, McLean and Piatt Counties for the November 18, 2009 Biennial Radiological Emergency Preparedness Exercise for the Clinton Station.

Clinton Power Station ALERT ScenarioSummary 0810-0934 Anticipated Trip Without Scram (ATWS)

The Clinton Power Station (CPS) is operating at 100% power when a Turbine Trip results in an automatic scram (shutdown) initiation. An Anticipated Trip Without Scram (ATWS) occurs as automatic Reactor Protection System (RPS) actions fail to result in a reactor scram. The Control Room Operating Crew responds to the scram signal by recognizing that all control rods did not insert into the reactor core. Actions are initiated to address the ATWS and the appropriate emergency procedures are entered to address the situation. Manual intervention results in a reactor scram and the reactor is shutdown. The Emergency Director declares an Alert based on MA3 (Automatic scram signal failing to initiate a reactor scram). CPS notifies the state through the Nuclear Accident Reporting System (NARS).

At 0850, Air in-leakage results in low condenser vacuum. Additionally, an inadvertent Group 1 Isolation occurs and the Main Steam Isolation Valves close. The Operationscrew uses Safety Relief Valves (SRVs) to remove decay heat from the reactor. By 0910, Drywell Radiation monitor readings increase to greater than 260 R/hr and Containment Radiation monitor readings increase to greater than 45 R/hr indicating developing fuel failure.

64

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Approx.

Time Event/Anticipated Offsite Response 0750 Initial conditions/weather forecast message to players.

0810 An Alert is declared at Clinton Station.

0825 Exelon notifies the IEMA Telecommunicator of the ALERT via NARS.

IEMA Telecommunicator verifies the NARS message.

An IEMA Duty Officer contacts the Clinton Station Shift Engineer.

IEMA Telecommunicator notifies IEMA personnel of the ALERT per Standard Operating Procedure (SOP).

IEMA may activate the State of Illinois Response Center (SIRC) and Radiological Emergency Assessment Center (REAC), if appropriate.

IEMA may dispatch liaisons to the County Emergency Operations Centers (EOCs), Unified Area Command (UAC), Radiological Assessment Field Team (RAFT), Joint Information Center (JIC), Technical Support Center (TSC) and Emergency Operations Facility (EOF), if appropriate. IEMA notifies Governor's Office of the ALERT. (Simulated)

IEMA Telecommunicator notifies appropriate State agencies of the ALERT.

IEMA notifies FEMA of the ALERT. (Simulated) 0840 IEMA Telecommunicator notifies DeWitt County of the ALERT via NARS.

DeWitt County telecommunicator completes and verifies the NARS message.

DeWitt County telecommunicator notifies County officials, support counties and municipalities of the ALERT per SOP.

Support county and municipal telecommunicators complete and verify the NARS message.

Support county and municipal telecommunicators notify officials of the ALERT per SOP.

Counties may activate the EOC, if appropriate.

65

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Clinton Power Station SITE AREA EMERGENCY (SAE) Scenario Summary 0935- 1104 Loss Of Coolant Accident (LOCA) to the Containment FS Loss or Potential Loss of Two Fission Product Barriers At 0935, a Loss of Coolant Accident (LOCA) to the Containment results in the Loss of the Reactor Coolant System (RCS) Fission Product Barrier. Drywell pressure rises due to the leak.

Loss of the Fuel Clad barrier results in the declaration of a SITE AREA EMERGENCY - FS1

- Loss or Potential Loss of ANY two barriers. At this time there is no radioactive material release path to the environment and no release is in progress. This is relayed to the state via a new NARS form.

At 10:35, the Clinton Power Station Emergency Response Organization (ERO) receives an.

Engineering report (Control Message) that the charcoal adsorbers as installed on both trains of Standby Gas Treatment System (SGTS) have been de-certified by the manufacturer as the wrong filter media. The SGTS filters are ineffective for purposes of filtering and hold up of particulates.

Fuel clad damage continues to escalate as indications of fuel damage show rising Drywell and Containment radiation levels.

Approx.

Time Event/Anticipated Offsite Response 0935 A SITE AREA EMERGENCY is declared at Clinton Station.

0950 Exelon notifies the IEMA Telecommunicator of the SITE AREA EMERGENCY via NARS.

IEMA Telecommunicator verifies the NARS message.

REAC contacts the Clinton Station Shift Engineer.

SIRC is activated if not previously activated.

SIRC notifies the Governor's Office and requests that a representative report to the State EOC. (Simulated)

State dispatches liaisons to the County EOCs, UAC, RAFT, JIC, TSC and EOF, if not previously dispatched.

SIRC notifies FEMA of conditions..

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Approx.

Time Event/Anticipated Offsite Response 0950 IEMA notifies State agencies (Simulated):

" Illinois State Police

IDOT/Division of Highways

" IDOT/Division of Aeronautics

IDNR

Illinois National Guard

ICC

" American Red Cross

IDPH

IEPA

IDOC

IDHS

IDOA

Office of the State Fire Marshal

others as appropriate REAC contacts Federal agencies. (Simulated)

REAC provides an update to the SIRC and County EOC Liaisons.

REAC provides an update to the JIC.

1005 IEMA notifies DeWitt County of the SITE AREA EMERGENCY via NARS.

DeWitt County telecommunicator completes and verifies the NARS message.

DeWitt County telecommunicator notifies County officials, support counties and municipalities of the SITE AREA EMERGENCY per SOP.

DeWitt County implements public notification procedures, if appropriate.

(Simulated)

Support county and municipal telecommunicators complete and verify the NARS message.

Support county and municipal telecommunicators notify officials per SOP.

County EOCs are activated if not previously activated.

Dosimetry is issued to emergency personnel, EOC staff and exposure records are completed.

67

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station GENERAL EMERGENCY (GE) - Maximum Protective Action Recommendations (PARs) 1105- 1240 FG1 Loss of Two Fission Product Barriers with Loss / Potential loss of the Third A Reactor Core Isolation Cooling (RCIC) steam supply line failure into the Auxiliary Building (secondary containment) and the steam supply fails to isolate. This results in a pathway to the environment in the steam tunnel/RCIC area. Temperatures and radiation levels increase throughout these areas. A monitored release initiates from the RCS to the Auxiliary Building to Standby Gas Treatment System (SGTS). The unisolable primary system leakage with a path to the environment results in GENERAL EMERGENCY - FG1.

At 1130, release parameters indicate that a concurrent RG1 classification exists. Projected offsite Total Effective Dose Equivalent (TEDE) >1 R/hr, and Protective Action Guides (PAGs) are exceeded at 5-miles beyond the Clinton Power Station.

Protective Action Recommendations (PARs) for the public are developed to evacuate up to a five-mile radius around Clinton Power Station and downwind Sub-Areas from five to ten miles (Max PARs). The wind direction (from 260 degrees) induces the plant to recommend via the NARS form the evacuation of Sub-Areas 1, 3 and 4.

Approx.

Time Event/Anticipated Offsite Response 1105 A GENERAL EMERGENCY is declared at Clinton Station.

1120 Exelon notifies the IEMA Telecommunicator of the GENERAL EMERGENCY via NARS. Protective actions are'recommended.

IEMA Telecommunicator verifies the NARS message.

SIRC and REAC evaluate the protective action recommendation.

A recommendation is made to the Governor. The Governor recommends that protective actions be implemented.

SIRC staff is advised of the situation.

SIRC advises UAC, the County EOC liaisons and JIC staff of the situation.

SIRC notifies FEMA of conditions. (Simulated)

REAC provides an update to the SIRC and County EOC liaisons.

REAC provides an update to the JIC.

68

Unclassified Radiological Emergency Preparedness Program (REP).

After Action Report/Improvement Plan Clinton Power Station Approx.

Time Event/Anticipated Offsite Response 1135 SIRC notifies DeWitt County of the GENERAL EMERGENCY and the recommended protective actions via NARS.

DeWitt County telecommunicator completes and verifies the NARS message.

DeWitt County telecommunicator notifies County officials, support counties and municipalities per SOP.

DeWitt County implements public notification procedures and traffic and access control per SOPs, as applicable.

Support county and municipal telecommunicators complete and verify and the NARS message.

Support county and municipal telecommunicators notify EOC staff.

Wind Shift - New PAR

-1210 At 1210, the wind direction shifts from 260 degrees to 228 degrees and stabilizes at 220 degrees.

Based on the wind direction change causing the radioactive plume to shift, the plant develops and issues to the state a new PAR and NARS form to evacuate up to a five-mile radius and downwind Sub-Areas 1, 2, 3 and 4 from five to ten miles (Max PARs). After actions for the new PARs are complete, the exercise will be terminated.

Approx.

Time Event/Anticipated Offsite Response 1205 The GENERAL EMERGENCY continues at Clinton Power Station. A wind shift has occurred.

1220 Exelon notifies the 1EMA Telecommunicator of the wind shift via NARS.

Additional protective actions are recommended.

IEMA Telecommunicator verifies the NARS message.

The SIRC and REAC evaluate the PAR.

69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Clinton Power Station Approx.

Time Event/Anticipated Offsite Response 1220 A recommendation is made to the Governor. The Governor recommends that protective actions be implemented.

SIRC staff is advised of the situation.

SIRC advises UAC, the County EOC liaisons and JIC staff of the situation.

SIRC notifies DHS/FEMA of conditions. (Simulated)

REAC provides an update to the SIRC and County EOC liaisons.

REAC provides an update to the J1C.

1235 SIRC notifies DeWitt County of the wind shift and the recommended protective actions via NARS.

DeWitt County telecommunicator completes and verifies the NARS message.

DeWitt County telecommunicator advises County officials, support counties and municipalities per SOP.

DeWitt County implements public notification procedures and traffic and access control per SOPs, as applicable.

Support counties and municipal telecommunicators complete and verify and the NARS message.

Support counties and municipal telecommunicators advise EOC staff.

1300. Terminate exercise play.

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ML100850453

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