ML120170535
| ML120170535 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/14/2011 |
| From: | Lawrence Hammond US Dept of Homeland Security, Federal Emergency Management Agency |
| To: | Collins E NRC Region 4 |
| Cecere, Bethanny NSIR/DPR 415-6754 | |
| References | |
| Download: ML120170535 (28) | |
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Comanche Peak Nuclear Power Plant Drill Date - November 15, 2011 Radiological Emergency Preparedness (REP) Program After Action Report/
Improvement Plan Published December 15, 2011
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Comanche Peak Nuclear Power Plant This page is intentionally blank.
Comanche Peak Nuclear Power Plant After Action Report/Improvement Plan Published December 15, 2011 Contents Executive Summary 3
Section 1: Exercise Overview 4
1.1 Exercise Details 4
1.2 Exercise Planning Team Leadership 4
1.3 Participating Organizations 5
Section 2: Exercise Design Summary 7
2.1 Exercise Purpose and Design 7
2.2 Exercise Objectives, Capabilities and Activities 7
2.3 Scenario Summary 7
Section 3: Analysis of Capabilities 8
3.1 Drill Evaluation and Results 8
3.2 Summary Results of Drill Evaluation 8
3.3 Criteria Evaluation Summaries 10 3.3.1 Texas Jurisdictions 10 3.3.1.1 Granbury Emergency Worker Monitoring/Decontamination Station 10 Section 4: Conclusion 13 Appendix A: Improvement Plan 14 Appendix B: Drill Evaluators and Team Leaders 15 Appendix C: Exercise Plan 16 1
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EXECUTIVE
SUMMARY
On November 15, 2011, an Emergency Worker Monitoring and Decontamination drill was conducted for the Comanche Peak Nuclear Power Plant (CPNPP), located near Glen Rose, Texas. Personnel from the U.S. Department of Homeland Security/Federal Emergency Management Agency (DHS/FEMA) Region VI, evaluated all activities. The purpose of the drill was to assess the level of preparedness of local responders to react to a simulated radiological emergency at the CPNPP.
Personnel from Indian Harbor Volunteer Fire Department, Granbury Volunteer Fire Department, Hood County Sheriff's Office, and CPNPP participated in the drill. Evaluation Areas demonstrated included: Emergency Operations Management, Portective Action Implementation, and Support Operations/Facilities. Cooperation and teamwork of all participants was evident during the drill, and DHS/FEMA Region VI wishes to acknowledge these efforts.
This report contains the final evaluation of the out-of-sequence drill. The participants demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies and one Areas Requiring Corrective Action (ARCAs), corrected during the drill. In addition, one Plan Issue was identified as a result of the drill.
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SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Comanche Peak Nuclear Power Plant Type of Exercise Drill Exercise Date November 15, 2011 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Lisa Hammond RAC Chair FEMA Region VI Technological Hazards Branch Chief 800 North Loop 288 Denton, Texas, 76209 940-898-5199 lisa.hammond@dhs.gov Linda Gee Federal Planning Team Lead FEMA Region VI Techological Hazards Program Specialist 800 N. Loop 288 4
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Denton, Texas, 76209 940-898-5368 linda.gee@fema.dhs.gov Glenn Corbin State Planning Team Lead Texas Department of State Health Services State Health Emergency Planner Radiation Control Program, Environmental Monitoring P. O. Box 149347 Austin, Texas, 78714 512-834-6770 glenn.corbin@dshs.state.tx.us James "Jim" Ogden Utility Exercise Planner Comanche Peak Nuclear Power Plant Offsite Emergency Planner P. O. Box 1002 Glen Rose, Texas, 76042 254-897-6470 jogden2@luminant.com 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Comanche Peak Nuclear Power Plant drill:
Risk Jurisdictions Granbury Volunteer Fire Department Hood County Fire Marshall l Emergency Management Office Hood County Sheriff's Office Support Jurisdictions Indian Harbor Volunteer Fire Department 5
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Private Organizations Comanche Peak Nuclear Power Plant 6
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SECTION 2: EXERCISE DESIGN
SUMMARY
2.1 Exercise Purpose and Design The DHS/FEMA Region VI Office evaluated the drill on November 15, 2011 to assess the capabilities of local emergency preparedness organizations in implementing their Radiological Emergency Response Plans and procedures to protect the public health and safety during a radiological emergency involving Comanche Peak Nuclear Power Plant (CPNPP). The purpose of this report is to present the results and findings on the performance of the offsite response organizations during a simulated radiological emergency.
2.2 Exercise Objectives, Capabilities and Activities Exercise objectives and identified Capabilities/REP Criteria selected to be exercised are discussed in the Exercise Plan (EXPLAN), Appendix C.
2.3 Scenario Summary The drill scenario was developed to evaluate the response of drill participants to an incident requiring evacuation of the public from the 10-mile Emergency Planning Zone surrounding Comanche Peak Nuclear Power Plant. The drill scenario provided for the evaluation of the Hood County Emergency Worker Monitoring and Decontamination operation and the ability to test monitoring, decontamination of emergency workers, vehicles and equipment.
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SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Drill 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 August 15, 2011, drill evaluation to test the offsite emergency response capabilities of local governments in the 10-mile Emergency Planning Zone surrounding Comanche Peak Nuclear Power Plant.
Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria delineated in the exercise evaluation areas as outlined in the April 25, 2002, Federal Register, Radiological Emergency Preparedness: Evaluation Methodology. Detailed information on the exercise evaluation area criteria and the extent of play agreement used in this drill are found in Appendix C of this report.
3.2 Summary Results of Drill Evaluation The matrix presented in Table 3.1 on the following page, presents the status of all exercise evaluation area criteria that were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise criteria are listed by number and the demonstration status is indicated by the use of the following letters:
M - Met (No Deficiency or ARCAs assessed and no unresolved ARCAs from prior exercise)
D - Deficiency assessed A - ARCAs assessed or unresolved ARCAs from previous exercises P - Plan Issue N - Not Demonstrated 8
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Table 3.1 - Summary of Drill Evaluation DATE: 2011-11-15 SITE: Comanche Peak Nuclear Power Plant, TX M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated Granbury EW Decon Emergency Operations Management Mobilization 1a1 Facilities 1b1 Direction and Control 1c1 Communications Equipment 1d1 Equip & Supplies to support operations 1e1 M
Protective Action Decision Making Emergency Worker Exposure Control 2a1 Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 Rad Assessment and Decision making concerning Relocation, Reentry, and Return 2e1 Protective Action Implementation Implementation of emergency worker exposure control 3a1 M
Implementation of KI decision 3b1 Implementation of protective actions for special populations - EOCs 3c1 Implementation of protective actions for Schools 3c2 Implementation of traffic and access control 3d1 Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3e1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions.
3f1 Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4a1 Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laboratory operations 4c1 Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1 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 5b1 Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6a1 M
Mon / decon of emergency worker equipment 6b1 P
Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d1 9
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a.
b.
c.
3.3 Criteria Evaluation Summaries 3.3.1 Texas Jurisdictions 3.3.1.1 Granbury Emergency Worker Monitoring/Decontamination Station In summary, the status of DHS/FEMA criteria for this location is as follows:
MET: 1.e.1, 3.a.1, 6.a.1.
AREAS REQUIRING CORRECTIVE ACTION: 6.b.1.
ISSUE NO.: 14-11-6b1-A-01 CRITERION: Facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles. (NUREG_0654, K.5.b)
CONDITION: The vehicle monitor held probe with the window facing away from the area to be monitored, the probe was moved too quickly, and the survey meter cord and probe cover were dragged across the vehicles surface.
POSSIBLE CAUSE: The monitor did not follow procedures concerning proper survey technique or lacked proper survey technique training.
REFERENCE:
NUREG-0654, K.5.b EFFECT: Any contamination present might not be detected by moving the probe too quickly over the surface and having the probe window face away from the surface.
Also, any contamination present would be spread to uncontaminated areas by dragging the survey meter cord and probe cover across the vehicle surface.
CORRECTIVE ACTION DEMONSTRATED: The vehicle monitor demonstrated proper survey technique procedures after additional training was provided.
DEFICIENCY: None 10 Unclassified Radiological Emergency Preparedness Program (REP)
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d.
PLAN ISSUES: 6.b.1.
ISSUE NO.: 14-11-6b1-P-02 CRITERION: Facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles. (NUREG_0654, K.5.b)
CONDITION: There are no provisions provided in the Hood Countys procedure (Annex W/Tab E/Appendix 4) for vehicles and equipment that cannot be decontaminated; specifically a designated controlled area for vehicles and equipment found to be contaminated.
Additionally, the procedure does not include a method for record keeping or documenting contamination found on emergency workers, and emergency worker vehicles and equipment.
POSSIBLE CAUSE: The vehicle monitoring and decontamination team members did not have a procedure to follow for handling contaminated emergency worker vehicles and equipment. The procedure also did not include a reference to a body survey form or a vehicle summary form, or some other type of record keeping method to document contamination.
REFERENCE:
NUREG-0654, K.5.b EFFECT: Since theres no provision for handling contaminated vehicles in the procedure (Hood County Annex W/Tab E/Appendix 4), its unclear as to where a designated parking location will be set up and how emergency workers manage this.
Therefore, theres a potential that contamination could be spread from the contaminated vehicles and equipment.
In addition, the current procedure doesnt provide any record keeping method for processing contaminated emergency workers, vehicles and equipment. This could result in delays and confusion while processing potentially contaminated emergency workers, vehicles and equipment.
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e.
f.
g.
RECOMMENDATION: Revise the procedure to include specific details for handling contaminated vehicles and equipment; specifically a designated controlled area for vehicles and equipment found to be contaminated. In addition, include a record keeping method to document contaminated emergency workers, vehicles and equipment.
NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 12 Unclassified Radiological Emergency Preparedness Program (REP)
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SECTION 4: CONCLUSION Based on the results of the drill, the offsite radiological emergency response plans and preparedness for the State of Texas and the affected local jurisdictions are deemed adequate to provide reasonable assurance that appropriate measures can be taken to protect the health and safety of the public in the event of a radiological emergency. Therefore, 44 CFR Part 350 approval of the offsite radiological emergency response plans and preparedness for the State of Texas site-specific to Comanche Peak Nuclear Power Plant will remain in effect.
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APPENDIX A: IMPROVEMENT PLAN Issue Number: 14-11-6b1-P-02 Criterion: 6b1 ISSUE: There are no provisions provided in the Hood Countys procedure (Annex W/Tab E/Appendix 4) for vehicles and equipment that cannot be decontaminated; specifically a designated controlled area for vehicles and equipment found to be contaminated.
Additionally, the procedure does not include a method for record keeping or documenting contamination found on emergency workers, and emergency worker vehicles and equipment.
RECOMMENDATION: Revise the procedure to include specific details for handling contaminated vehicles and equipment; specifically a designated controlled area for vehicles and equipment found to be contaminated. In addition, include a record keeping method to document contaminated emergency workers, vehicles and equipment.
CORRECTIVE ACTION DESCRIPTION:
CAPABILITY:
PRIMARY RESPONSIBLE AGENCY:
CAPABILITY ELEMENT:
START DATE:
AGENCY POC:
ESTIMATED COMPLETION DATE:
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APPENDIX B: DRILL EVALUATORS AND TEAM LEADERS DATE: 2011-11-15, SITE: Comanche Peak Nuclear Power Plant, TX LOCATION EVALUATOR AGENCY Granbury Emergency Worker Monitoring/Decontamination Station Scott Flowerday
- Team Leader 15 Unclassified Radiological Emergency Preparedness Program (REP)
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APPENDIX C: EXERCISE PLAN 16 Unclassified Radiological Emergency Preparedness Program (REP)
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STATE OF TEXAS & COMANCHE PEAK FEMA EVALUATED EXERCISE - November 15, 2011 EMERGENCY WORKER DECONTAMINATION EVALUATION AREAS AND EXTENT-OF-PLAY (EOP) AGREEMENT EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.e - Equipment and Supplies to Support Operations Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations.
(NUREG-0654, H.7, J.10.a, b, e; J. 11; K.3.a)
Locations:
Granbury City Park Pool Extent of Play: Instrument calibration will be specific to each manufacturers specification. Equipment not required for demonstrating exercise evaluation criterion may be left at the staging area to allow for additional space within the vehicles. Access to Personal Protective Equipment (PPE) clothing will be demonstrated; however it will not be worn. The use of PPE will be demonstrated in accordance with applicable procedures. Request the option to correct issues immediately (Correction-on-the-spot).
ARCA: None EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3.a, 3.b)
Locations:
Granbury City Park Pool Extent of Play: Request the option to correct issues immediately (Correction-on-the-spot).
ARCA: None EVALUATION AREA 6: Support Operation/Facilities Sub-Element 6.a - Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees Criterion 6.a.1: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers. (NUREG-0654, J.10.h.; K.5.b)
Locations:
Granbury City Park Pool 17 Unclassified Radiological Emergency Preparedness Program (REP)
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Extent of Play: Request the option to correct issues immediately (Correction-on-the-spot).None ARCA: None Sub-Element 6.b -Monitoring and Decontamination of Emergency Worker Equipment Criterion 6.b.1: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles. (NUREG-0654, K.5.b)
Locations:
Granbury City Park Pool Extent of Play: The designated emergency worker decontamination location will be setup at the Granbury City Park Pool located at 400 North Park Street Granbury, TX 76048. All personnel and equipment decontamination measures will be simulated. All contamination levels will be via controller injects. Free play of this activity is not permitted. Request the option to correct issues immediately (Correction-on-the-spot).
ARCA: None 18 Unclassified Radiological Emergency Preparedness Program (REP)
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