ML13191A911

After Action Report/Improvement Plan

ML13191A911
Person / Time
Site:	Palo Verde
Issue date:	06/17/2013
From:	Ward N Federal Emergency Management Agency
To:	Collins E Region 4 Administrator
References
Download: ML13191A911 (43)

Text

U.S. Department of Homeland Security Region IX I1II Broadway, Suite 1200 Oakland, CA 94607-4052 o

FEMA JUN 17 2013 Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd, Suite 400 Arlington, Texas 76011-8064

Dear Mr. Collins:

I am forwarding a copy of the Final After Action Report for the biennial Plume Phase Exercise held on March 6, 2013, for the Palo Verde Nuclear Generating Station (PVNGS). The purpose of this exercise was to assess the level of state and local preparedness in responding to a radiological emergency. This final exercise report and improvement plan was prepared in coordination with the PVNGS Offsite Response Organizations.

Based on the evaluation of the March 6, 2013 exercise, the offsite radiological emergency response plans for the state of Arizona and the affected local jurisdictions, site-specific to PVNGS, can be implemented, and are adequate to provide reasonable assurance that appropriate measures can be taken off-site to protect the health and safety of the public in the event of a radiological emergency at PVNGS.

Therefore, the Code of Federal Regulations, Title 44 § 350 approval of the offsite radiological emergency response plans and preparedness for the state of Arizona, site-specific to PVNGS, will remain in effect.

I would also like to take this opportunity to acknowledge the many individuals that participated in this successful exercise. Their dedication to this program was clearly evident.

www.fema.gov

Mr. Elmo E. Colfins, Jr.

Page 2 If you have any questions c1t.need, a~ddftional iaformation, please contact me at (510) 627-71004; Your staff may also contact Paul Adersori, PVNGS Site Specialist, at (510) 627-7093 or Richard Grundstrom, Regional Assistance Committee Chair, at (510) 627-7240.

Sincerely, Nancy Ward Regional Administrator FEMA Region IX Enclosure cc: NRC Headquarters Document Control Desk US Nuclear Regulatory Commission Washington, DC 205'55-0001 Vanessa Quinn, Chief Radiological Emergency Preparedness Branch FEMA Headquarters

Palo Verde Nuclear Generating Station After Action Report/

Improvement Plan Exercise Date - March 06, 2013 Radiological Emergency Preparedness (REP) Program FEMA Published May 16, 2013

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station This page is intentionally blank.

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station Palo Verde Nuclear Generating Station After Action Report/Improvement Plan Contents EX EC U TIV E SU M M A R Y.............................................................................................................................

1 SEC TIO N 1: EX ER C ISE O VE R V IE W...................................................................................................

2 1.1 Exercise Details.......................................................................................................................................................

2 1.2 Exercise Planning Team Leadership..............................................................................................................

2 1.3 Participating Organizations....................................................................................................................................

2 SECTION 2: EXERCISE DESIGN

SUMMARY

4 2.1 Exercise Purpose and Design..................................................................................................................................

4 2.2 Exercise Objectives, Capabilities and Activities...............................................................................................

4 2.3 Scenario Sum m ary..................................................................................................................................................

7 SECTION 3: ANALYSIS OF CAPABILITIES.........................................................................................

8 3.1 Exercise Evaluation and Results.............................................................................................................................

8 3.2 Sum m ary Results of Exercise Evaluation...............................................................................................................

8 3.3 Criteria Evaluation Sum m aries.............................................................................................................................

12 3.3.1 Arizona Jurisdictions......................................................................................................................................

12 3.3.1.1 Field M onitoring Team -Alpha............................................................................................................

12 3.3.1.2 Field M onitoring Team -Bravo............................................................................................................

12 3.3.1.3 Field M onitoring Team -Charlie.........................................................................................................

13 3.3.1.4 Arizona Departm ent of Agriculture Com m and Post.......................................................................

13 3.3.1.5 Palo Verde Nuclear Generating Station Joint Inform ation Center..................................................

14 3.3.1.6 State of Arizona Em ergency Operations Center.............................................................................

15 3.3.1.7 Technical Operations Center.............................................................................................................

16 3.3.1.8 Radiological Em ergency Assessm ent Team -Forw ard.......................................................................

17 3.3.1.9 Em ergency W orker Decontam ination...............................................................................................

18 3.3.2 Risk Jurisdictions............................................................................................................................................

18 3.3.2.1 M aricopa County Sheriff's Office On-scene Com m and Post...........................................................

18 3.3.2.2 M aricopa County Em ergency Operations Center............................................................................

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Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear. Generating Station 3.3.2.3 M aricopa County Sheriff's Office W arning Center..........................................................................

21 3.3.2.4 Paloe Verde School...................................................................................................................................

21 3.3.2.5 Back-up Route-alerting...........................................................................................................................

23 3.3.2.6 Special-needs Population Evacuation................................................................................................

23 3.3.2.7 M aricopa County Sheriffs Office Roadblock....................................................................................

24 3.3.2.8 M aricopa County Sheriffs Offi ce....................................................................................................

24 3.3.3 Support Jurisdictions.....................................................................................................................................

24 3.3.3.1 National W eather Service Radio.......................................................................................................

24 3.3.4 Private Organizations.....................................................................................................................................

25 3.3.4.1 KTAR EAS Radio Station..........................................................................................................................

25 SECTIO N 4: CO N CLU SIO N.......................................................................................................................

27 APPENDIX A : IM PR O VEM ENT PLAN...............................................................................................

28 APPEND IX B: EXER CISE TIM ELIN E.....................................................................................................

30 APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS...............................................

32 APPEND IX D : A CR O NY M S.......................................................................................................................

33 APPEND IX E: EXTENT O F PLAY............................................................................................................

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Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station This page is intentionally blank.

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/hImprovement Plan Palo Verde Nuclear Generating Station EXECUTIVE

SUMMARY

The U.S. Department of Homeland Security (DHS) Federal Emergency Management Agency (FEMA)

Region IX evaluated a Plume Pathway Exercise on March 6, 2013 for the 10-mile emergency planning zone (EPZ) around the Palo Verde Nuclear Generating Station (PVNGS). The purpose of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency. The exercise followed FEMA's policies and guidance for exercising State and local radiological emergency response plans (RERP) and procedures.

The most recent biennial exercise at this site occurred on March 1-3, 2011 and March 15, 2011. The qualifying emergency preparedness exercise was conducted on April 1, 1981.

FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise.

Protecting the public health and safety is the full-time job of some of the exercise participants and an additionally assigned responsibility for others. Still, others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities. Cooperation and teamwork was evident among all the participants during this exercise.

The local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them during the exercise. There was one Area Requiring Corrective Action (ARCA) identified and corrected by redemonstration as a result of this exercise. There were no uncorrected ARCAs from previous exercises. Two Plan Issues from the previous exercise were corrected and successfully demonstrated. Two new Plan Issues were identified in this exercise as areas for improvement.

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Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station SECTION 1: EXERCISE OVERVIEW.

1.1 Exercise Details Exercise Name Palo Verde Nuclear Generating Station Type of Exercise Plume Phase Exercise Date March 06, 2013 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Arizona Division of Emergency Management Jan Lindner, State Exercise Officer Bill Wolfe, Radiological Emergency Preparedness Program Coordinator

• Arizona Radiation Regulatory Agency Toby Morales, Emergency Response Program Manager Maricopa County Department of Emergency Management John Padilla, Emergency Services Planner Arizona Public Service, Palo Verde Nuclear Generating Station David Crozier, Emergency Preparedness Senior Coordinator Todd Williams, Emergency Planning Senior Coordinator 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the PVNGS exercise:

State Jurisdictions Arizona Corporation Commission Arizona Department of Administration Arizona Department of Agriculture Arizona Department of Corrections Arizona Department of Economic Security Arizona Department of Environmental Quality Arizona Department of Health Services Arizona Department of Homeland Security Arizona Department of Public Safety Arizona Department of Transportation Arizona Department of Water Resources Arizona Division of Emergency and Military Affairs 2

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station Arizona Division of Emergency Management Arizona Governor's Office of Energy Assurance Arizona National Guard Arizona Radiation Regulatory Agency Arizona Wing, Civil Air Patrol Risk Jurisdictions Maricopa County Department of Emergency Management Maricopa County Department of Environmental Services Maricopa County Department of Public Health Maricopa County Department of Transportation Maricopa County Sheriff's Office Palo Verde Elementary School District Private Organizations American Red Cross, Grand Canyon Chapter Palo Verde Nuclear Generating Station Radio Amateur Civil Emergency Service Radio Station KTAR University. of Arizona Federal Jurisdictions Department of Energy Department of Homeland Security, Federal Emergency Management Agency Environmental Protection Agency National Oceanic and Atmospheric Administration, National Weather Service Nuclear Regulatory Commission Department of Agriculture 3

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design FEMA Region IX evaluated the plume pathway exercise to assess the capabilities of the offsite response organizations (OROs) to protect public health and safety in the event of a radiological emergency at PVNGS. Participant actions were evaluated against current response plans and capabilities related to the release of radiological materials from PVNGS. Exercise play included emergency response actions to a radiological release. A public school demonstrated its response plan by interview; outside of the exercise sequence of activities.

2.2 Exercise Objectives, Capabilities and Activities The exercise was designed to demonstrate the ORO's capability to respond in accordance with evaluation area criteria listed in the FEMA Radiological Emergency Preparedness (REP) Program Manual, April 2012.

The objectives of this exercise are as follows:

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

Criterion 1.b.1: Facilities are sufficient to support the emergency response. (NUREG-0654/FEMA-REP-1, H.3; G.3.a; J.0O.h; J.12; K.5.b)

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. (NUREG-0654/FEMA-REP-1, A.1.d; A.2.a, b; A.3; C.4, 6)

Criterion 1.d. 1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations. (NUREG-0654/FEMA REP-1, F.1.2)

Criterion I.e. 1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654/FEMA REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b)

Criterion 2.a.]: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers, including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654/FEMA-REP-1, C.6; J.10.e, f; K.4) 4

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station Criterion2.b.1: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge olf onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, 1.10 and Supplement 3)

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). (NUREG 0654/FEMA-REP-1, A.3; C.4, 6; D.4; J.9; J.10.f, m)

Criterion 2.c. 1: Protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs. (NUREG-0654/FEMA-REP-1, D.4; J.9; J.10.d, e)

Criterion 3.a. 1: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to emergency workers (NUREG-0654/FEMA-REP-], J.10.e; K.3.a, b; K.4)

Criterion 3.b. 1: KI and appropriate instructions are available if a decision to recommend use of KI is made.

Appropriate record-keeping of the administration of KI for institutionalized individuals is maintained.

(NUREG-0654/FEMA-REP-1, J.10.e, f)

Criterion 3.c. 1: Protective action decisions are implemented for persons with disabilities and access/functional needs other than schools within areas subject to protective actions. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

Criterion 3.c.2: OROs/School officials implement protective actions for schools. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

Criterion 3.d.l: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654/FEMA-REP-1, A.3; C.1.4; J.10.g,j)

Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654/FEMA-REP-1, J.10.k)

Criterion 4.a.2: Field teams (2 or more) are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654/FEMA-REP-1, C.1; H.12; 1.7, 8, 11; J.10.a)

Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654/FEMA-REP-1, C.1; H.12; 1.8, 9; J.10.a) 5

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station 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 REP guidance. (NUREG-0654/FEMA-REP-1, E.5, 6, 7)

Criterion 5.a.3: Backup alert and notification of the public is completed within a reasonable time following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-654/FEMA-REP-1, E.6, Appendix 3.B.2.c)

Criterion 5.b.1: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c)

Criterion 6.b.1: The-facility/ORO has adequate proceduresand resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles. (NUREG-0654/FEMA-REP-1, K.5.a.b)

The core capabilities listed below were selected by the 2013 PVNGS exercise planning team based on a cross-walk with corresponding REP Program criteria. Please note that minor discrepancies between the Homeland Security Exercise and Evaluation Program and REP terminology may be present, but that these present no significant issues.. Elements.of the following capabilities provide the foundation for the integration of the REP Program objectives and the development of the exercise scenario.

Critical Transportation Citizen Evacuation and Shelter-in-Place Environmental Protective Action Decision-making Protective Action Implementation Response Health and Safety Responder Health and Safety WMD and Hazardous Materials Response and Decontamination Mass Care Services Mass Care (Shelter, Feeding and Related Services)

On-Scene Security and Protection Emergency Public Safety and Security Response Operational Coordination Emergency Operations Center (EOC) Management On Site Incident Management Public Health and Medical Services Mass Prophylaxis Public Information and Warning Emergency Public Information and Warning Supply Chain Integrity and Security Food and Agriculture Safety and Defense 6

Unclassified Radiological Emergency Preparedness Program (RFPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station 2.3 Scenario Summary The 2013 Palo Verde Nuclear Generating Station Plume Phase Full Scale Exercise (2013 PVNGS Exercise) involved both onsite and offsite response to a release of radiological materials from PVNGS.

A summary of the PVNGS scenario is as follows:

At 0730, a SEISMIC EVENT occurred. Unit 1 control room staff felt ground motion and received a Seismic Alarm which by procedure directs the control room staff to 'validate' the alann. The control roomn staff contacted the U.S. Geological Survey for further information. Following validation, at approximately 0736 an Unusual Event was declared. There was no release in progress and no Protective Action Recommendations or Decisions were made. Offsite notifications were initiated. The State and county received the notification but no further actions were taken.

At 0758, an aftershock shock occurred resulting in a steam generator tube rupture and an unisolatable leak of radioactive materials to the environment was initiated. There was a loss of offsite power and a subsequent reactor trip. At approximately 0828, a Site Area Emergency was declared. This event initiated a minor release of radioactive materials that exceeded federally approved limits but did not exceed protective action guides. The utility initiated notifications to the offsite response organizations and made an initial Protective Action Recommendation to Shelter to a 2-mile radius. The State, in response to the declaration of a Site Area Emergency, alerted, notified and mobilized their emergency response organizations and activated all the offsite emergency response facilities. The State concurred with the utility's protective action recotnmendation but also added shelter-in-place from two to ten miles in downwind sectors E, F and G and evacuate Arlington School to the Reception and Congregate care center at Wickenburg High School.

A series of events occur onsite further degrading plant conditions and increasing the release rate. At approximately 1030, a second aftershock occurred. The release rate increased. Dose projections indicated Protective Action Guides were exceeded. A dose assessment revealed that doses greater than 5,000 mrem Thyroid CDE were at or beyond the site boundary. The utility made a recommendation to evacuate a 2-mile radius and 2-5 miles in Sectors E, F & G. The State, following concurrence with the County EOC, made a Protective Action Decision (PAD) to evacuate the 2-mile radius and Sectors E, F & G to 10 miles.

After the PADs were implemented and field sampling activities were completed the exercise terminated at approximately 1400.

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Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results This section contains the results and findings of the evaluation of the OROs that participated in, the PVNGS plume phase exercise on March 6, 2013. This exercise tested the offsite emergency response capabilities of state and local governments in the EPZ surrounding PVNGS. The OROs were evaluated on their demonstration of criteria delineated in the exercise evaluation areas in the April 2012, REP Program Manual. Detailed information on the extent of play agreement used for this exercise is found in Appendix E of this report.

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, presents the status of all exercise evaluation area criteria which were scheduled for demonstration during this exercise by the participating jurisdictions and functional entities.

Exercise evaluation area criteria are listed by number and the demonstration status of those evaluation area criteria is indicated by the use of the following letters:

M - Met (No deficiencies or ARCAs assessed and no unresolved ARCAs from prior exercises)

D - Deficiency assessed A - ARCA(s) assessed or unresolved ARCA(s) from prior exercise(s)

N - Not Demonstrated (Reason explained in Appendix E, extent of play agreement)

P - Plan issue Presented below are definitions of the terms used in this section relative to criteria demonstration status.

a. Met - Listing of the demonstrated exercise evaluation area driteriA under which no Deficiencies or ARCAs were assessed during this exercise and under which no ARCAs assessed during prior exercises remain unresolved.

b. Deficiency - Listing of the demonstrated exercise evaluation area criteria under which one or more Deficiencies were assessed during this exercise. Included is a description of each Deficiency and recommended corrective actions.

c. Area Requiring Corrective Action - Listing of the demonstrated exercise evaluation area criteria under which one or more ARCAs were assessed during the current exercise. Included is a description of the ARCAs assessed during this exercise and the recommended corrective actions to be demonstrated before or during the next biennial plume phase exercise.

d. Not Demonstrated - Listing of the exercise evaluation area criteria that were scheduled to be demonstrated during this exercise, but were not demonstrated and the reason they were not demonstrated.

The following are classifications of the types of issues that are discussed in this report:

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Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station A Deficiency is defined in the FEMA April 2012, REP Program Manual 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."

An ARCA is defined in the FEMA April 2012, REP Program Manual as "An observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety."

A Plan Issue is defined in the FEMA April 2012, REP Program Manual as "An observed or identified inadequacy in the ORO's emergency plan/procedures, rather than in the ORO's performance."

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

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

a. Plant Site Identifier - A two-digit number corresponding to the Utility Billable Plant Site Codes.

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

c. Evaluation Area Criterion - A letter and number corresponding to the criteria in the FEMA REP Exercise Evaluation Methodology.

d. Issue Classification Identifier - (D = Deficiency, A ARCA, P = Plan)

e. Exercise Issue Identification Number - A separate two digit indexing number assigned to each issue identified in the exercise.

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Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/improvement Plan Palo Verde Nuclear Generating Station Table 3.1 - Summary of Exercise Evaluation. Plume Phase (2 ages)

DATE: 2013-03-06 SITE: Palo Verde Nuclear Generating Station, AZ U

U M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not 0

w o

Demonstrated C-U w

V)

S U w

0 U

Emeegeni~y iperati...

ag ent..

Mobilization lal M

M M

M M

M M

M M

Facilities lb]

M Direction and Control lIl M

M M

M M

M Communications Equipment Idl M

M M

M M

M M

M M

M Equipment and Supplies to Support Operations let M

M M

M M

M M

M M,

Pr.

o t e Actio."D:ci*s.onM*.

.a:,.ii.ig.*

Emergency Worker Exposure Control 2al P

Dose Assessment PARs for the Emergency Event 2b]

M Dose Assessment PADs for the Emergency Event 2b2 M

M M

PADs for Protection of persons with access/functional needs 2cl M

Radiological Assessment and Decision making - Ingestion 2dl Radiological Assessment and Decision making concerning Post-Plume 2el Phase Relocation, Reentry, and Return Protectii e Action-luimp ementati&".................

Implementation of emergency worker exposure control 3al M

M M

M M

Implementation of KI decision for institutionalized & Public 3b]

M Implementation of protective actions for access/functional needs 3cl M

Implementation of protective actions for Schools 3c2 P

Implementation.of traffic and access control 3dl M

Impediments to evacuation are identified and resolved 3d2 M

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

3fl Field Mesisurement and Analycis 4.w RESERVED 4al Field Teams managed to obtain sufficient information 4a2 M

Field Teams manage sample collection appropriately 4a3 M

M M

Post plume phase field measurements and sampling 4b1 Laboratory operations 4cl Emergency"N6tification and Public'info.:...

Activation of the prompt alert and notification system 5al M

M RESERVED 5a2 Backup alert and notification 5a3 Activation of the prompt alert and notification system - Exception 5a4 Emergency information and instructions for the public and the media 5bl M

M M

M

.pp.rt pe

.a

tions, Mon / decon of evacuees, and registration of evacuees 6al Mon / decon of emergency workers and equipment 6bl Temporary care of evacuees 6cI Transportation and treatment of contaminated injured individuals 6dl 10

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station Table 3.1 - Summary of Exercise Evaluation, Plume Phase (Continued, age 2 of 2)

• 0 DATE: 2013-03-06 SITE: Palo Verde Nuclear Generating Station, AZ U

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

'0 0

Demonstrated z

Mobilization lal M

M Facilities lbl Direction and Control Icl M

Communications Equipment Id1 M

M M

M Equipment and Supplies to Support Operations lel M

M M

M M

M M

M Emergency Worker Exposure Control 2al Dose Assessment PARs for the Emergency Event 2bl Dose Assessment PADs for the Emergency Event 2b2 PADs for Protection of persons with access/functional needs 2cl Radiological Assessment and Decision making - Ingestion 2dl Radiological Assessment and Decision making concerning Post-Plume 2el Phase Relocation, Reentry, and Return Implementation of emergency worker exposure control 3al M

M M

M M

Implementation of KI decision for institutionalized & Public 3bl A

M M

Implementation of protective actions for access/functional needs 3cl M

Implementation of protective actions for Schools 3c2 M

Implementation of traffic and access control 3d]

M Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions.

31`1 RESERVED 4al Field Teams managed to obtain sufficient information 4a2 M

Field Teams manage sample collection appropriately 4a3 Post plume phase field measurements and sampling 4bl Laboratory operations 4c I Activation of the prompt alert and notification system 5al M

RESERVED 5a)

Backup alert and notification 5a3 M

Activation of the prompt alert and notification system - Exception 5a4 Emergency information and instructions for the public and the media 5b]

M Mon / decon of evacuees, and registration of evacuees 6al Mon / decon of emergency workers and equipment 6b]

M Temporary care of evacuees 6cl Transportation and treatment of contaminated injured individuals 6dl 11

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 Arizona Jurisdictions 3.3.1.1 Field Monitoring Team-Alpha Field Monitoring Teamn (FMT) - Alpha demonstrated the National Preparedness Goal Core Capabilities for Environmental Response, Health and Safety and Operational Coordination. FMT - Alpha effectively mobilized their response team, demonstrated multiple methods of communication with field team management at Radiological Emergency Assessment Team - Forword (REAT-F), had adequate dosimetry and monitoring equipment, and managed emergency worker radiological exposure and decontamination procedures.

FMT - Alpha successfully demonstrated the ability to make and record ambient radiation measurements at appropriate locations and collect air samples for radioiodine and particulates. The team completed all assignments, exposure was monitored throughout the exercise and communications were maintained with the REAT Forward Captain at Buckeye Airport. Proper survey methods were used and the field survey data was promptly transmitted to the staff at REAT Forward for review and forwarded to the Technical Operations Center. The team worked very well together in demonstrating the required capabilities.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: L.a.1, 1.d.1, L.e.1, 3al, 4.a.3.

b. AREASREQUIRING CORRECTIVE ACTION: None.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 Field Monitoring Team-Bravo FMT - Bravo demonstrated the National Preparedness Goal Core Capabilities for Environmental Response, Health and Safety and Operational Coordination. FMT Bravo effectively mobilized their response team, demonstrated multiple methods of communication with field team management at REAT-F, had adequate dosimetry and monitoring equipment, and managed emergency worker radiological exposure and decontamination procedures..

FMT - Bravo successfully demonstrated the ability to make and record ambient radiation measurements at appropriate locations and collect air samples for radioiodine and particulates. The team completed all assignments, exposure was monitored throughout the exercise and communications were maintained with the REAT Forward Captain at Buckeye Airport. Proper survey methods were used and the field survey data was promptly transmitted to the staff at REAT Forward for review and forwarded to the Technical Operations Center. The team worked very well together in demonstrating the required capabilities.

12

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a.l, 1.d.1, L.e.1, 3a1, 4.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 Field Monitoring Team-Charlie FMT - Charlie demonstrated the National Preparedness Goal Core Capabilities for Environmental Response, Health and Safety and Operational Coordination. FMT - Charlie effectively mobilized their response team, demonstrated multiple methods of communication with field team management at REAT-F, had adequate dosimetry and monitoring equipment, and managed emergency worker radiological exposure and decontamination procedures.

FMT - Charlie successfuilly demonstrated the ability to make and record ambient radiation measurements at appropriate locations and collect air samples for radioiodineand particulates. The team completed all assignments, exposure was monitored throughout the exercise and communications were maintained with the REAT Forward Captain at Buckeye Airport. Proper survey methods were used and the field survey data.

was promptly transmitted to the staff at REAT Forward for review and forwarded to the Technical Operations Center. The team worked very well together in demonstrating the required capabilities.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a.1, 1.d.l, 1.e.1, 3al, 4.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.4 Arizona Department of Agriculture Command Post The Arizona Department of Agriculture (ADA) Command Post (CP) demonstrated the National Preparedness Goal Core Capabilities for Operational Coordination with protective action decision making by implementing the ADA response plan for agricultural advisories. ADA CP staff used the emergency management software program WebEOC, in coordination with the State Emergency Operations Center (SEOC), to monitor the PVNGS incident, including ECLs and emergency response PADs. The ADA has authority to issue agricultural PADs. Agricultural PADs were coordinated with the Joint Information Center (JIC) and incorporated into public emergency notification messages. The ADA CP also coordinated with agricultural liaisons in California, Nevada, Utah, Colorado and New Mexico to advise them of the impacts of agricultural PADs in response to the PVNGS incident.

13

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station The ADA CP coordinated all of its decisions with the SEOC. It was prepared to support the SEOC in managing the household pets and farm animals that may be affected in a public evacuation. Veterinarians and equipment would be provided to assist in decontamination. The AG CP executed its plans and procedures in response to the agricultural impacts of an incident at PVNGS efficiently in coordination with State emergency managers. The ADA CP demonstrated Operational Coordination appropriately for the incident response, in concert with other OROs.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2b2.

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 3.3.1.5 Palo Verde Nuclear Generating Station Joint Information Center The PVNGS Joint Information Center (JIC) demonstrated the National Preparedness Goal Core Capability for Public Information and Warning in coordination with the State, local government, voluntary agencies and private industry. The JIC was designed as the focal point for the distribution of media statements and presentation of media briefings by the utility and jurisdictions. Representatives from the State of Arizona, Maricopa County, PVNGS,: and the American Red Cross located at the JIC provided coordinated emergency information and instructions to the media and public.

State and local JIC representatives confirmed that all news releases were prepared, coordinated and approved according to respective procedures. All releases conformed to protective action decisions and precautionary measures instituted by the jurisdictions. Five media briefings were conducted during the exercise. Prior to each briefing the spokespersons gathered to discuss and coordinate their message for the briefing. They discussed who would say what, and in which order the briefing would be conducted. A post Media Briefing was also conducted to discuss any needed follow up actions. The Public Inquiry hotlines were staffed in the State of Arizona SEOC, and in PVNGS spaces. Rumors and/or trends of misinformation were reported to the JIC for correction in media briefings and/or media statements. JIC performance was adequate and appropriate in response to the incident and the requirement for public warning and information. The facility was adequate to meet the necessary space and furnishings required for conducting operations.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: l.a.1, 1.b.1, 1.c.1, I.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 14

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station 3.3.1.6 State of Arizona Emergency Operations Center Arizona's Departmnent of Emergency Management (ADEM) SEOC demonstrated the National Preparedness Goal Core Capabilities for Operational Coordination and Environmental Response Health and Safety. It successfully demonstrated the effective use of plans and procedures to alert, notify, and mobilize emergency personnel, activate facilities in a timely manner and successfully demonstrate that key personnel with leadership roles could successfully provide direction and control. Multiple communications systems which included the use of the dedicated NAN phone line, commercial phone lines, ceil phones and radio communications through Radio Amateur Civil Emergency Services (RACES) were also demonstrated. The SEOC contained sufficient equipment, maps and displays to support operations.

The Policy Director and command staff demonstrated Environmental Response Health and Safety by the development of PADs for the general public as well as for persons who were confined or needed access and functional needs support. Additionally, the Policy Director and command staff which included the Arizona Regulatory Radiation Agency (ARRA) Director issued PADs for Emergency Workers to ingest Potassium Iodide (KI) and made recommendations to Maricopa County Public Health to recommend KI for the general public. SEOC successfully demonstrated the dissemination of public information by a rumor control hotline cell that identified areas of public interest for the JIC. The SEOC demonstrated the Core Capabilities for Operational Coordination, Environmental Response Health and Safety effectively and appropriately in response to the requirements for incident management.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

ISSUE NO.: 45-11-2b2-P-2 ISSUE: Inconsistent direction regarding implementation of the directive for Emergency Workers to ingest KI was provided to REAT-Forward.

CORRECTIVE ACTION DEMONSTRATED: Issue 45-11-2b2-P-2 is cleared. This issue was previously assigned to criterion 2b2 for the SEOC. In accordance with the Radiological Emergency Preparedness Program Manual, April 2012 edition, exposure control decision making for emergency workers, including the use of KI, is now under criterion 2al. The Technical Director and staff of the TOC successfully communicated clear KI directions to the REAT Forward.

g. PRIOR ISSUES - RESOLVED: None 15

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station 3.3.1.7 Technical Operations Center The Arizona Technical Operations Center (TOC) demonstrated the National Preparedness Goal Core Capabilities for Environmental Response, Health and Safety and Operational Coordination. Components of these Core Capabilities include directing field measurement and analysis of the release of hazardous materials, communication with the nuclear power plant, field operations and advising State emergency management. The TOC Director protected the health and safety of emergency responders by making decisions based on modeling, field measurement and analysis. TOC staff analyzed the threat to the public based on nuclear power plant conditions, predictive modeling and field analysis. The TOC Director made recommendations to the ADEM State Policy Chief for citizen evacuation and shelter in place, also based on the TOC's analysis.

The TOC Director functions as the State's specialist and subject matter expert in the area of radiation safety.

Input from the TOC Director was critical to formulate and implement a proper response to the incident. The TOC successfully demonstrated the required Core Capabilities.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: I.a. 1, 1.c. 1, 1.d. 1, L.e. 1, 2.b. 1, 4.a.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 2.a.1.

ISSUE NO.: 45-13-2al-P-02 CRITERION: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including use of KI, is in place for emergency workers, including provisions to authorize radiation exposure in excess of administrative limits or PAGs.

CONDITION: The TOC SOP, Technical Director Procedure/Responsibilities calls for the Technical Director to direct the administration of potassium iodide (KI) to emergency workers when projections indicate that the emergency worker thyroid PAG will be exceeded.

The initial models predicted that the administrative dose limit to emergency workers would not be exceeded, while the protective action guide (PAG) to the general public would be exceeded. There was reluctance by the staff to issue conflicting KI guidance to the general public and to emergency workers.

POSSIBLE CAUSE: Procedures called for KI decisions to be made based upon dose projection calculations. There was no wording specifically addressing a more conservative decision for emergency workers who would be intentionally directed to enter an active plume.

The specific wording is: "Direct the administration of KI to emergency workers when projections indicate that the emergency worker thyroid PAG will be exceeded."

16

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station

REFERENCE:

ARRA Procedure, TOC Operations and Responsibilities, Enclosure 1, Technical Director Procedures/Responsibilities. NUREG 0659/FEMA REP 1, C6, J1O e and f, K.4 EFFECT: There was no negative effect observed, but employing the following recommendation would help eliminate the potential for inconsistent messages and may ease implementation.

RECOMMENDATION: It maybe prudent to alter the language in the SOP to contain a mechanism to eliminate conflicting KI guidance and to perhaps consider administering KI to any emergency worker directed to enter a known or suspected plume when a release is in progress without waiting for a thyroid Committed Dose Equivalent detennination. This would provide a relatively low risk protection to those emergency workers should the plume be inaccurately characterized or if deteriorating plant conditions cause the characteristics of the plume to change rapidly while monitoring teams are downwind in the plume.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.8 Radiological Emergency Assessment Team-Forward REAT-F demonstrated the National Preparedness Goal Core Capabilities for Operational Coordination by effectively managing FMTs in Field Measurement and Analysis. REAT-F demonstrated effective response to the information needs of the Technical Operations Center by managing FMTs to obtain field measurements of ambient radiation levels at appropriate locations and to collect air samples for radioiodine and particulates.

The Team Captain provided a thorough pre-deployment safety briefing to the field teams that were being managed. Communications were maintained throughout the exercise and teams were able to transmit their field monitoring survey results by email and to communicate with REAT-F Field Team Controllers by radio with no communication disruption. The REAT-F effectively demonstrated its capability for Operational Coordination in managing FMT data collection and emergency worker exposure control.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a. 1, 1.c. 1, 1.d. 1, 1.e. 1, 3.a. 1, 4.a.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 17

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station 3.3.1.9 Emergency Worker Decontamination Emergency Worker Monitoring and Decontamination at REAT-F demonstrated the National Preparedness Goal Core Capability for Enviromnental Response Health and Safety. While no actual decontamination was observed, the hotline for monitoring radiological contamination of emergency workers, their equipment and their vehicles was established.

Emergency workers were surveyed for contamination. The decontamination process was demonstrated by interview. The capability for Environmental Response Health and Safety was effectively demonstrated in emergency worker, equipment and vehicle decontamination.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2 Risk Jurisdictions 3.3.2.1 Maricopa County Sheriff's Office On-scene Command Post The Maricopa Sheriff's Office On-scene Command Post (MCSO OSCP) demonstrated the National Preparedness Goal Core Capabilities for Operational Coordination, Public Information and Warning, Critical Transportation and Environmental Response Health and Safety. The MCSO OSCP coordinated with the Maricopa County Emergency Operations Center (MCEOC) to implement emergency management PADs. It directed implementation of PADs for public warning through backup route alerting, facilitated public evacuation by assisting people who need additional assistance with accessible bus transportation and controlled traffic flow including staffing roadblocks. All command and control activity between MCSO and MCDOT was coordinated through the MCSO-OSCP.

Officers and Maricopa County Department of Transportation (MCDOT) responders implementing these PADs received instruction and equipment to monitor their radiological exposure in the performance of their duties. The MCSO-OSCP Staging Area Supervisor provided a radiation safety briefing to all emergency response personnel. All personnel were directed to return dosimetry at the end of their mission and to complete the radiation exposure form. Emergency workers located at the MCSO-OSCP were provided copies of procedures, checklists, and maps. The deputies were provided with a detailed briefing on proper set-up and establishment of traffic and access control roadblocks. A roadblock was set up to divert traffic when an impediment to evacuation was identified. The MCSO OSCP provided operational coordination effectively and appropriately in response to the requirements to implement PADs.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a.1, l.c.1, l.d.1, L.e.1, 3.a.1, 3.d.1, 3.d.2.

18

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 Maricopa County Emergency Operations Center The Maricopa County Department of Emergency Management (MCDEM) Emergency Operations Center (EOC) demonstrated the National Preparedness Goal Core Capability for Operational Coordination. EOC staff members assisted in implementing protective measures for the general public and emergency workers in response to an incident at PVNGS. These measures included access and control to affected areas, dosimietry for emergency workers, potassium iodide (KI) for institutionalized persons and for the evacuating public, shelter-in-place and evacuation PADs, assisting with transportation needs, emergency information for the public through the JIC and by establishing a reception and care center for evacuees.

The MCDEM EOC Director participated in PAD decisions as a member of the policy group via conference calls. The Maricopa County Department of Public Health Director also participated in the policy group conference calls. This process recognizes that the governor makes the PAD, the Chairman of the Maricopa County Board of Supervisors is responsible for decision making at the county level, and the Director of the Maricopa County Department of Public Health (MCDPH) is responsible for making the decision to dispense potassium iodide (KI) to the general public. In this exercise, the governor delegated her authority to the Policy Chief at the SEOC. The Chairman of the Maricopa County Board of Supervisors delegated his authority to the MCDEM Director.

The Director clearly and concisely communicated all PADs to the EOC staff and kept them informed of actions to be taken. The Director worked closely with the EOC Manager and the JIC on emergency notification and public information messages. The MCDEM coordinated PAD implementation through the MCSO OSCP, with the affected schools and with the evacuee Reception and Care Center (RCC). The MCDEM EOC provided operational coordination effectively and appropriately in response to the requirements for incident management.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: L.a.1, l.c.1, 1.d.1, L.e.1, 2.b.2, 3.a.1, 3.b.1, 3.c.1, 5.a.1, 5.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.c.2.

ISSUE NO.: 45-13-3c2-P-01 CRITERION: OROs/school officials implement protective actions for schools.

19

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station CONDITION: The information flow between schools within the 10-mile EPZ and the Maricopa County Emergency Operations Center (MCEOC) is limited and does not provide a feedback mechanism to ensure the MCEOC remains apprised of the situation at individual.

schools. As described in the duty position emergency classification level checklists, the MCEOC Planning Section Chief (PSC), appropriately contacted the four schools'in the 10-mile emergency planning zone (EPZ) and apprised them of the Palo Verde Nuclear Generating Station (PVNGS) status and off-site protective action decisions (PAD). The PSC provided the same information to two schools outside the EPZ, which have students living within the EPZ. During the initiating calls (0837) the PSC informed the schools of the site area emergency. at PVNGS and obtained current school census data. At 0926, in conjunction with the public notification of the PAD directing the evacuation of Arlington Elementary School, the PSC informed the Arlington Elementary School contact that the, school would evacuate to Wickenburg High School. There was no procedure for the school to authenticate this directive. Current procedures do not reflect any requirement for recurring coordination, school reporting, or checklist guidance to monitor the progress of the evacuation, arrival at the reception center, processing of students, and release to parents and/or guardians. This issue was validated during the out-of-sequence schools interview at the Palo Verde Elementary School when it was noted that neither school nor county procedures included an authentication procedure to validate PADs requiring emergency response actions by the schools or a feedback system to inform the MCEOC of the school status.

Best practices demonstrated by school districts in other parts of the Country provide these types, of procedures as additional assurance that schools receive accurate information from an official source and reduce the probability of a false or misleading PAD being received by the, school as well as providing the ORO with confirmation of evacuation departure.

POSSIBLE CAUSE: The PSC followed the steps in the established checklists which did not identify a need to monitor school evacuation progress. Similarly, a review of available Arlington Elementary and Palo Verde School PVNGS procedures did not indicate a requirement for the schools to provide status updates to MCEOC. The absence of established authentication and reporting protocols in MCEOC emergency checklists and individual school procedures is an underlying cause.

REFERENCE:

a. NUREG-0654/FEMA-REP-1, J.10.c, d, e, g

b. MCEOC Planning Section Chief PVNGS Checklists

c. Arlington and Palo Verde Elementary Schools' PVNGS procedures EFFECT: These conditions not only expose schools to the potential of initiating unwarranted emergency actions, but also preclude the state and county from maintaining visibility over the safety of school children and their timely and efficient reunification with family members as emergency actions are implemented.

20

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station RECOMMENDATION: MCDEM, in conjunction with the four individual schools and their three school districts, should re-evaluate current MCEOC and school PVNGS procedures and develop a common authentication and reporting system that will ensure the schools' receipt of valid decisions and enable visibility of emergency actions undertaken to safeguard student populations during a PVNGS incident.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 Maricopa County Sheriff's Office Warning Center The MCSO Warning Center demonstrated the National Preparedness Goal Core. Capability for Operational Communications. The Warning Center is the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 911 emergency call center. The initial notification of an emergency incident at PVNGS came into the Warning Center from PVNGS over the dedicated NAN.

phone line. The Communications Supervisor entered the information into the Computer Aided Dispatch and into the Alpha Paging System at her work station, which broadcasted the information to all personnel in a designated PVNGS incident notification group. The Communications Supervisor then began making notifications by telephone to personnel designated for individual notification. Subsequent notifications were implemented in the same way.

The Officer in Charge at the Warning Center determines when to dispatch a mobile command truck and designated patrol units to the MCSO OSCP in Buckeye. State and County emergency management receive NAN messages and assume operational control of the incident response when they are activated. The Warning Center provided operational communications appropriate to the requirements of the incident.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a. 1, 1.d. 1, 1.e. 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 3.3.2.4 Palo Verde School The Palo Verde School demonstrated the National Preparedness Goal Core Capabilities for On-scene Security and Protection and Operational Coordination by an interview with school officials out of the exercise sequence of activities. School officials explained how they would implement protective actions to protect school children and staff in the event of an incident at PVNGS.

The planning section in the MCDEM EOC notifies the school by telephone when a decision for students to shelter in place or relocate them to a Reception and Care Center (RCC) has been made by the Chairman of 21

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station the Maricopa County Board of Supervisors. The school responds to whatever protective, action is directed by the MCDEM planning section, which identifies the RCC that the school should relocate to. The school relocates students and staff in seven buses maintained ready for emergency-transportation. The number of buses available was adequate to support the relocation of all 422 students and 75 school staff. The school staff maintained call trees to notify parents of the status of their children in the event of a relocation or other protective action taken. Teachers would maintain custody of their students until properly identified parents arrived at the RCC to take them. The Palo Verde School officials successfully demonstrated their commitment to On-scene Security and Protection and Operational Coordination.

a. MET: 1.e.1, 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: 3.b. 1.

ISSUE NO.: 45-13-3bl-A-04 CRITERION: KI and appropriate instructions are made available in case a decision to recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals and the general public is maintained.

CONDITION: Palo Verde Elementary School staff members were unfamiliar with the dosage required for blocking radioiodine in adult thyroid glands. They. also were unfamiliar with the dosage required for blocking radioiodine in thyroid glands of adolescent students above a certain weight.

POSSIBLE CAUSE: The Palo Verde Elementary School Emergency Response Plan has.

inadequate procedural guidance for school staff members who may be required to administer' potassium iodide (KI) to students.

REFERENCE:

Planning Standard J.10.e of NUREG-0654/FEMA REP-i states, in part: 10.

The organization's plans to implement protective measures for the plume exposure pathway shall include: e. Provisions for the use of radioprotective drugs, particularly for emergency workers and institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult, including quantities, storage, and means of distribution.

EFFECT: Improper administration of potassium iodide thyroid blocking agent to adult staff and to students above the threshold weight could result in inadequate thyroid protection against harmful radioiodine.

CORRECTIVE ACTION DEMONSTRATED: The exercise controller administered on-the-spot training and showed the school officials where in the carton inserts the dosage administration guidance was written. Subsequent discussion indicated that the school officials understood the need for varying doses of KI to different types of individuals.

c. DEFICIENCY: None 22

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Reportilmprovement Plan Palo Verde Nuclear Generating Station

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.5 Back-up Route-alerting The Maricopa Sheriff's Office On-scene Command Post (MCSO OSCP) demonstrated the National Preparedness Goal Core Capabilities for Public Information and Warning through Back-up Route-alerting.

MCSO deputies would use patrol cars with speaker systems to warn residents if a siren failed. Patrol car computer systems are equipped with maps of the area designated for warning. A helicopter, equipped with a speaker system, is also available for public warning. Officers had a script to read and demonstrated that they could complete public warning within 45 minutes. The capability of public information and warning was successfully demonstrated.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.e. 1, 3.a. 1, 5.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None*

3.3.2.6 Special-needs Population Evacuation The Maricopa Sheriff s Office On-scene Command Post (MCSO OSCP) demonstrated the National Preparedness Goal Core Capability for Critical Transportation by responding to requests from people who needed additional assistance to evacuate. MCSO maintains a voluntary registry of persons with functional needs who are transportation dependent. MCSO had accessible vehicles available when transportation requests came in. Deputies received appropriate training and personal dosimetry to complete the requested transportation request. Critical transportation was successfully demonstrated.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.e.1, 3.a.1, 3.b.l, 3.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 23

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station 3.3.2.7 Maricopa County Sheriff's Office Roadblock The MCSO OSCP demonstrated the National Preparedness Goal Core Capability for Critical Transportation by controlling traffic flow on the collector streets used for vehicle evacuation. The MCSO has identified traffic and access control points (TCP) in its operating plan. Traffic cones and barracades were available to establish a roadblock to control traffic flow. The Maricopa County Department of Transportation, the Arizona National Guard and the Arizona Highway Patrol could be called to assist in staffing these TCPs.

The Critical Transportation Capability was successfully demonstrated.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.8 Maricopa County Sheriff's Office The MCSO demonstrated the National Preparedness Goal Core Capability for Public Health and Medical Services by maintaining a supply of Potassium Iodide (KI) for distribution to institutionalized persons and to the general public. The KI was warehoused in a controlled environment and was within the current expiration date. If the Maricopa County Health Officer determined that KI should be made available to the public, MCSO deputies would transport KI from its stockpile at the Avondale substation to designated.

evacuee Reception and Care Centers. MCSO maintains more than twice the supply needed to provide KI to every person living in the 10-mile EPZ. The capability for Public Health and Medical Services was successfully demonstrated.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.e.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 3.3.3 Support Jurisdictions 3.3.3.1 National Weather Service Radio The National Weather Service (NWS) radio station demonstrated the National Preparedness Goal Core Capability for Public Information and Warning in coordination with the State, local government. As part of 24

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station the Emergency Alert System (EAS), the NWS radio station is responsible to broadcast primary alert messages. NWS is a manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and serves as a backup to radio station KTAR (92.3 FM/620 AM) which is designated as the Local Primary I (LPl) EAS broadcast point for providing EAS messages.

Primary alert EAS messages are ordered by State and local government authorities. The NWS radio station demonstrated that it could receive an order to broadcast a pre-scripted warning message, verify the authenticity of the order and to repeat the warning broadcast on a predetermined schedule. The NWS radio station demonstration successful met the requirement for public warning and information.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.d.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 3.3.4 Private Organizations 3.3.4.1 KTAR EAS Radio Station The KTAR EAS radio station demonstrated the National Preparedness Goal Core Capability for Public Information and Warning in coordination with State and local government authorities. KTAR (92.3 FM/620 AM) is the designated EAS notification station for Maricopa County. It broadcasts continuously, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week, 365 days a year. A minimum of one staff member is on duty at all times.

KTAR has both a primary transmitter and a backup transmitter; both transmitter sites have generators with adequate fuel supplies to allow for uninterrupted broadcast and communication capability. To ensure that information provided to the public is correct and completed in a timely manner, the radio station has a direct telephone line with Maricopa County as primary and commercial telephone, as secondary. Both were tested early in the exercise. The message was received, verified, recorded and broadcast as directed. The KTAR broadcast signal in conjunction with other stations has a radius covering the entire state of Arizona. Issue 45-11-5Al-P-1 from the exercise in 2011, was corrected. A new checklist was designed and the procedure was followed as written.

The KTAR radio station demonstrated that it could receive an order to broadcast a pre-scripted warning message, verify the authenticity of the order and to repeat the warning broadcast on a predetermined schedule. The KTAR radio station demonstration successfully met the requirement for public warning and information.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None 25

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station

c. DEFICIENCY: None

d. PLAN ISSUES:.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 5.a.1 ISSUE NO.: 45-11-5al-P-1.

ISSUE: The KTAR Checklist for Palo VerdeEAS Messages lists a procedure that is out of order pertaining to how the message is developed at KTAR.

CORRECTIVE ACTION DEMONSTRATED: ISSUE 45-11-5Al-P-1 from the exercise in 2011, was corrected. A new checklist was designed and the procedure was followed as written.

g. PRIOR ISSUES - UNRESOLVED: None 26

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station

.SECTION 4: CONCLUSION FEMA evaluated an off-site plume pathway exercise for the affected jurisdictions on March 6, 2013 in the 10-mile EPZ around the PVNGS. The purpose of the exercise was to assess the level of state and local preparedness in response to a radiological emergency. This exercise was held in accordance with FEMA's policies and guidance concerning the exercise of state and local RERPs and procedures.

The exercise participants demonstrated knowledge of their emergency response plans and procedures and adequately demonstrated the ability to follow those plans to protect the health and safety of the public.

There were no Deficiencies and no uncorrected ARCAs identified during the course of the exercise. One ARCA was successfully corrected by redemonstration.

Two Plan Issues were identified during this exercise. Recommendations to correct these Plan Issues are contained in the Improvement Plan, Appendix A.

Based on our evaluation of the March 6, 2013, biennial plume phase exercise and out of sequence demonstrations, the offsite radiological emergency response plans for the State of Arizona and the affected local jurisdictions, site-specific to PVNGS, can be implemented, and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at PVNGS.

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Unclassified Radiological Emergency Preparedness Program (REPP)

Afte& Action Report/Improvement Plan Palo Verde Nuclear Generating Station APPENDIX A: IMPROVEMENT PLAN I

,.n iber: 45-1 3--P0 '-iro 3_2 I

ISSUE: The information flow between schools within the 1 0-mile EPZ and the Maricopa County Emergency Operations Center (MCEOC) is limited and does not provide a feedback mechanism to ensure the MCEOC remains apprised of the situation at individual schools. As described in the duty position emergency classification level checklists, the MCEOC Planning Section Chief (PSC), appropriately contacted the four schools in the 10-mile emergency planning zone (EPZ) and apprised them of the Palo Verde Nuclear Generating Station (PVNGS) status and off-site protective action decisions (PAD). The PSC provided the same information to two schools outside the EPZ, which have students living within the EPZ. During the initiating calls (0837) the PSC informed the schools of the site area emergency at PVNGS and obtained current school cerlsus data. At 0926, in conjunction with the public notification of the PAD directing the evacuation of Arlington Elementary School, the PSC informed the Arlington Elementary School contact that the school would evacuate to Wickenburg High School. There was no procedure for the school to authenticate this directive. Current procedures do not reflect any requirement for recurring coordination, school reporting, or checklist guidance to monitor the progress of the evacuation, arrival at the reception center, processing of students and release to parents and/or guardians. This issue was validated during the out-of-sequence schools interview at the Palo Verde Elementary School when it was noted that neither school nor count)y procedures included an authentication procedure to validate PADs requiring emergency response actions by the schools or a feedback system to inform the MCEOC of the school status.

Best practices demonstrated by school districts in other parts of the Country provide these types of procedures as additional assurance that schools receive accurate information from an official source and reduce the probability of a false or misleading PAD being received by the school as well as providing the ORO with confirmation of evacuation departure.

RECOMMENDATION: MCDEM, in conjunction with the four individual schools and their three school districts, should re-evaluate current MCEOC and school PVNGS procedures and develop a common authentication and reporting system that will ensure the schools' receipt of valid decisions and enable visibility of emergency actions undertaken to safeguard student populations during a PVNGS incident.

CORRECTIVE ACTION DESCRIPTION: The Maricopa County Department of Emergency Management will work with the School Districts within the 10-mile Emergency Planning Zone to develop procedures addressing PAD message authentication as well as evacuation completion notification to the MCEOC.

The procedures will be part of the School's Emergency Response Plans specifically dealing with Palo Verde emergency response operations.

CAPABILITY: Environmental PRIMARY RESPONSIBLE AGENCY:

Maricopa County Department of Emergency Management CAPABILITY ELEMENT: Protective Action START DATE: May 20, 2013 Implementation AGENCY POC: John Padilla, Emergency Services ESTIMATED COMPLETION DATE:

Planner November 1, 2013 28

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvemeni Plan Palo Verde Nuclear Generating Station I isu NL-br4 -'-)

P02 Crtro :2 ISSUE: The TOC SOP, Technical Director Procedure/Responsibilities calls for the Technical Director to direct the administration of potassium iodide (KI) to emergency workers when projections indicate that the emergency worker thyroid PAG will be exceeded. The initial models predicted that the administrative dose limit to emergency workers would not be exceeded, while the protective action guide (PAG) to the general public would be exceeded. There was reluctance by the staff to issue conflicting KI guidance to the general public and to emergency workers.

RECOMMENDATION: It may be prudent to alter the language in the SOP to contain a mechanism to eliminate conflicting KI guidance and to perhaps consider administering KI to any emergency worker directed to enter a known or suspected plume when a release is in progress without waiting for a thyroid Committed Dose Equivalent determination. This would provide a relatively low risk protection to those emergency workers should the plume be inaccurately characterized or if deteriorating plant conditions cause the characteristics of the plume to change rapidly while monitoring teams are downwind in the plume.

CORRECTIVE ACTION DESCRIPTION: Arizona Radiation Regulatory Agency is considering revising procedures to indicate KI would be recommended for emergency workers and general public at a projected 5 rem child thyroid CDE or at the discretion of the Technical Operations Center Director based on the risk or if the analyzed threat indicates the need for this protection. This recommendation would be discussed with the Department of Health for making a protective action decision for the general public. Tile revision will be decided upon and made as appropriate following guidance in the issuance of the revised EPA EPGs.

CAPABILITY: Response Health and Safety PRIMARY RESPONSIBLE AGENCY:

Arizona Radiation Regulatory Agency CAPABILITY ELEMENT: Responder Health START DATE: May 20. 2013 and Safety AGENCY POC: Toby Morales., ER Response ESTIMATED COMPLETION DATE:

Manager December 31, 2013 29

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station APPENDIX B: EXERCISE TIMELINE Table 1 -Exercise Timeline DATE: 2013-03-06, SITE: Palo Verde Nuclear Generating Station, AZ Emeirgency.Classtfication Level 7."c, Unusual Event 0736 N/A N/A N/A 0742 0742 0741 Alert N/A N/A N/A N/A N/A N/A N/A Site Area Emergency 0828 0847 0850 0939 0835 0835 0836 General Emergency 1108 1142 1112 1114 1115 1116 1118 Simulated Rad. Release Started 0806 N/A N/A 0939 0814 0814 0848 Simulated Rad. Release Ongoing Ongoing Ongoing Ongoing 1430 1430 Ongoing Terminated Facility Declared Operational 0920 0900 0939 0940 0912 0855 Declaration of Emergency: State N/A N/A 1145 1012 N/A N/A Declaration of Emergency: Local N/A N/A N/A N/A N/A 0920 Exercise Terminated 1428 1408 1410 1405 1404 1405 1st Protective Action Decision: Shelter.0-2 1042 N/A 0939 0909 N/A 0909 mile radius and Sectors E. F, G to 10 miles; Evacuate Arlington School 1st Siren Activation N/A N/A N/A N/A NAA 0927 I st EAS Message N/A N/A N/A N/A N/A 0930 2nd Protective Action Decision: Evacuate 0-2 1128 N/A 1130 1126 N/A 1126 mile radius and Sectors E. F, G 2nd Siren Activation N/A N/A N/A N/A N/A 1140 2nd EAS Message N/A N/A N/A N/A N/A 1142 3rd Protective Action Decision: KI for General 1225:

N/A 1128 1220 N/A 1220 Public 3rd Siren Activation N/A N/A N/A N/A N/A 1241 3rd EAS Message N/A N/A N/A N/A N/A 1243 4th Protective Action Decision: Evacuate to N/A N/A 1345 1332 1325 1332 include Sector D 4th Siren Activation N/A N/A N/A N/A N/A 1353 4th EAS Message N/A N/A N/A N/A N/A 1355 30

Unclassified Radiological. Emergency Preparedness Program (REPP)

After Action Report/limprovement Plan Palo Verde Nuclear Generating Station Table 1 -Exercise Timeline DATE: 2013-03-06, SITE: Palo Verde Nuclear Generating Station, AZ Unusual Event 0736 N/A N/A 0742 0803 Alert N/A N/A N/A N/A N/A Site Area Emergency 0828 N/A 0921 0835 0911 General Emergency 1108 N/A 1124 N/A 1134 Simulated Rad. Release Started 0806 N/A N/A N/A N/A Simulated Rad. Release Ongoing Ongoing Ongoing Ongoing Ongoing Terminated Facility Declared Operational N/A N/A N/A 0834 Declaration of Emergency: State N/A N/A N/A N/A Declaration of Emergency: Local N/A N/A N/A N/A Exercise Terminated 1406 1407 N/A 1330 1st Protective Action Decision: Shelter 0-2 mile N/A N/A N/A N/A radius and Sectors E, F, G to 10 miles; Evacuate Arlington School I st Siren Activation N/A N/A N/A N/A 1st EAS Message N/A N/A N/A N/A 2nd Protective Action Decision: Evacuate 0-2 N/A N/A N/A N/A mile radius and Sectors E, F, G 2nd Siren Activation 1144 N/A N/A N/A 2nd EAS Message 1144 N/A N/A N/A 3rd Protective Action Decision: KI for General N/A N/A N/A N/A Public 3rd Siren Activation N/A N/A N/A N/A 3rd EAS Message N/A 1233 N/A N/A KI Administration Decision: Emergency N/A N/A N/A N/A Workers 4th Protective Action Decision: Evacuate to N/A N/A N/A N/A include Sector D 4th Siren Activation N/A N/A N/A 1330 4th EAS Message N/A 1347 N/A N/A 31

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS DATE: 2013-03-06, SITE: Palo Verde Nuclear Generating Station, AZ LOCATION A

E LATORW AGEN.CY.

Field Monitoring Team-Alpha Alan Bevan ICFI Field Monitoring Team-Beta Jill Leatherman ICFI Field Monitoring Team-Charlie Cheryl Weaver ICFI Arizona Department of Agriculture Command Post

• Todd Smith USDA Palo Verde Nuclear Generating Station Joint Information Center

• Henry Christiansen, Thomas Hegele ICFI, ICFI State of Arizona Emergency Operations Center

• Johanna Berkey, FEMA RX.,

Elena Joyner, FEMA, RIX, Roy Smith,

ICFI, Meg Swearingen ICFI Technical Operations Center

• Michael Howe, FEMA HQ Daryl Thome ICFI

• Scott Flowerday, FEMA RIV, Radiological Emergency Assessment Team-Forward Elsa Lopez FEMA RIV Emergency Worker Decontamination Dennis Wilford ICFI Maricopa County Sheriffs Office On-scene Command Post

• Alberto Sifuentes, FEMA RIX, Barton Freeman, FEMA RIII, Bonnie Sheffield FEMA RVIII Maricop'a County Emergency Operations Center

• Brad DeKorte, FEMA RVI, Ryan Jones, FEMA RI, Willis Larrabee ICFI Maricopa County Sheriffs Office Warning Center Barton.Freeman FEMA RIII Palo Verde School William Maier NRC Back-up Route-alerting Bonnie Sheffield FEMA RVIII Special-needs Population Evacuation Quirino lannazzo ICFI MCSO Roadblock Quirino Iannazzo ICFI National Weather Service Radio Jesse King FEMA HQ KTAR EAS Radio Station Carl Wentzell ICFI

• Tea'm Leader 32

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station APPENDIX D: ACRONYMS APS Arizona Public Service ARC American Red Cross ARCA Areas Requiring Corrective Action ARRA Arizona Radiation Regulatory Agency CAD Computer Aided Dispatch CDE Committed Dose Equivalent CP Command Post DCD Dispatch Center Director DHS U.S. Department of Homeland Security DRD Direct Reading Dosimeter EAS Emergency Alert System ECL Emergency Classification Level EOC Emergency Operations Center EOF Emergency Operations Facility EPA Environmental Protection Agency EPZ Emergency Planning Zone FEMA Federal Emergency Management Agency FMT Field Monitoring Team GE General Emergency IC Incident Commander JIC Joint Information Center KI Potassium Iodide LCD Liquid Crystal Display MC Maricopa County MCDEM Maricopa County Department of Emergency Management MCDOT Maricopa County Department of Transportation MCDPH Maricopa County' Department of Public Health MCEOC Maricopa County' Emergency Operations Center MCSO Maricopa County' Sheriff's Office mrem milli-rem, roentgen equivalent man (rem)

NAN Notification and Alert Network NIMS National Incident Management System NRC Nuclear Regulatory Commission NWS National Weather Service OROs Offsite Response Organizations OSC Operations Section Chief OSCP On-scene Command Post OSL Optically Stimulated Luminescence (Dosimeters)

PAD Protective Action Decision PAR Protective Action Recommendation PC Policy Chief P1O Public Information Officer PRD Permanent Record Dosimeter PSC Planning Section Chief PVNGS Palo Verde Nuclear Generating Station R

Roentgen,. tR - micro-Roentgen, mR - milli-Roentgen RACES Radio Amateur Civil Emergency Services 33

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station RAP Radiological Assistance Program RCC Reception and Care Center REAT-F Radiological Emergency Assistance Team - Forward REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RML Radiation Measurement Laboratory SAE Site Area Emergency SEOC Arizona State Emergency Operations Center SOP Standard Operating Procedure T/ACP Traffic and Access Control Point TD Technical Director TEDE Total Effective Dose Equivalent TLD Thermoluminescent Dosimeter TOC Technical Operations Center UE Unusual Event URM Ultra Radiac Monitors USDA U.S. Department of Agriculture WC Warning Center 34

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Palo Verde Nuclear Generating Station APPENDIX E: EXTENT OF PLAY The Extent-of-Play (EOP) agreement for the PVNGS Plume Phase Exercise held March 6, 2013, was submitted to the Federal Emergency Management Agency (FEMA) by the Arizona Division of Emergency Management on October 24, 2012. The FEMA Region IX, Technological Hazards Branch approved the EOP agreement on January 14, 2013.

A copy of the EOP is maintained by FEMA Region IX and the Arizona Division of Emergency Management, and is herein incorporated by reference. The EOP is available by written request to FEMA Region IX, National Preparedness Division, Technological Hazards Branch, 1111 Broadway, Suite 1200, Oakland, CA 94607-4052 or the Arizona Division of Emergency Management, 5636 East McDowell Road, Phoenix, AZ 85008.

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Unclassified Radiological Emergency Preparedness Program (REPP)

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