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Submittal of Radiological Emergency Preparedness Final Report, Plume Exposure Pathway Hostile Action Based Exercise Evaluation
	ML15027A424
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/12/2014
From:	Gary Robinson; US Dept of Homeland Security, Federal Emergency Management Agency
To:	Dapas M; Region 4 Administrator
References
	Download: ML15027A424 (57)
	v • d • e

U.S. Department of Homeland Security FEMA Region VI FRC 800 North Loop 288 Denton, TX 76209-3698 KFEMA December 12, 2014 Mr. Marc Dapas Regional Administrator U.S. NRC, Region A i 600 East Lamar Boulevard Arlington, TX 76011-4511

Dear Mr. Dapas:

Enclosed is a copy of the radiologicai emergency preparedness final report for the Arkansas Nuclear One Plume Exposure Pathway Hostile Action Based exercise evaluated on September 17, 2014. FEMA Region 6 staff evaluated the Arkansas Department of Health, Pope, Yell, Logan, and Jo1-mson Counties, National Oceanic and Atmospheric Administration Forecast Office, and KXRJ Radio Station. There were no Defic'encies, one Area Requairing Corrective Action (ARCA), which was corrected d.rLng the exercise, and one Plan Issue identified during the exercise. In addition, one previous AwCA was resolved. dui'ring the exercise.

Based on the results of this exercise, the planning and preparedness for the State of Arkansas and affected local jurisdictions provide reasonable assurarice that appropriate measures can be taken to protect public health and safety ki th:; event of a ra&dological emergency. Therefore, 44 CFR Part 350 approval of the offsite radioloeical emergency response plans and preparedness for the State of Arkansas, specific to Arkansas Nucl.ear COre, wili remain in effect.

A copy of this repoy-r was mailed to the NRC Headquarters Document Control Desk and a copy was transmitted electronically to RIV FEMADistribution@nrc.gov as specified in the FEMA REP Program Manual dated Jume 2017. Should you have questions, please contact Lisa Hammond, Regional Assistance Committee Chair, at (940) 898-5199, or Elsa Lopez, Senior Site Specialist for Arkansas Nuclear One, at (940) 898-5308.

Sincereiy, George A. Robinson Regional Administrator Enclosure cc: DHS/FEMA Headquarters - Vanessa Quinn, Jesse King ADH - Bernard Bevill ADEM - David Maxwell ANO - Richard E. Harris www.tema.gov

fax: (940) 898-5325

Arkansas Nuclear One After Action Report/

Improvement Plan Exercise Date - September 17, 2014 Radiological Emergency Preparedness (REP) Program (3) FEMA Published

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After Action Report/Improvement Plan Arkansas Nuclear One Arkansas Nuclear One After Action Report/Improvement Plan Contents Executive Summary 4 Section 1: Exercise Overview 5 1.1 Exercise Details 5 1.2 Exercise Planning Team Leadership 5 1.3 Participating Organizations 6 Section 2: Exercise Design Summary 8 2.1 Exercise Purpose and Design 8 2.2 Exercise Objectives, Capabilities and Activities 8 2.3 Scenario Summary 8 Section 3: Analysis of Capabilities 9 3.1 Exercise Evaluation and Results 9 3.2 Summary Results of Exercise Evaluation 9 3.3 Criteria Evaluation Summaries 13 3.3.1 Arkansas Jurisdictions 13 3.3.1.1 Arkansas State Emergency Operations Center 13 3.3.1.2 Arkansas Department of Health, Little Rock 13 Emergency Communications Center 3.3.1.3 Arkansas Department of Health at the Site 13 Emergency Operations Facility 3.3.1.4 Arkansas Field Radiological Monitoring Team One 14 3.3.1.5 Arkansas Field Radiological Monitoring Team Two 14 3.3.1.6 Alternate Joint Information Center 15 3.3.1.7 Arkansas Department of Health - Freeway Medical 15 3.3.1.8 Emergency News Center NP&RP 15 3.3.2 Risk Jurisdictions 16 3.3.2.1 Johnson County Emergency Operations Center 16 3.3.2.2 Logan County Emergency Operations Center 18 3.3.2.3 Pope County Emergency Operations Center 18 1

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After Action Report/Improvement Plan Arkansas Nuclear One 3.3.2.4 Pope County Incident Command Post 19 3.3.2.5 Yell County Emergency Operations Center 20 3.3.3 Private Organizations 20 3.3.3.1 ENS Radio Station KXRJ 20 3.3.4 Federal Jurisdictions 21 3.3.4.1 NOAA North Little Rock 21 Section 4: Conclusion 22 Appendix A: Improvement Plan 23 Appendix B: Exercise Timeline 24 Appendix C: Exercise Evaluators and Team Leaders 26 Appendix D: Acronyms and Abbreviations 27 Appendix E: Exercise Plan 30 2

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After Action ReportfImprovement Plan Arkansas Nuclear One EXECUTIVE

SUMMARY

On September 17, 2014, a biennial Radiological Emergency Preparedness (REP) Hostile Action Based Exercise was conducted in the plume exposure pathway emergency planning zone (EPZ) around Arkansas Nuclear One (ANO) located near Russellville, Pope County, Arkansas. The U.S. Department of Homeland Security/Federal Emergency Management Agency (DHS/FEMA)

Region VI evaluated the exercise. The purpose was to assess the level of preparedness of State and local responders to react to a simulated radiological emergency at ANO. This exercise was held in accordance with DHS/FEMA policies and guidance concerning the implementation of State and local radiological emergency preparedness plans and procedures.

The previous exercise at this site was a Plume Exercise conducted on April 11, 2012. The qualifying emergency preparedness exercise was conducted on October 1, 1980. There have been twenty-three evaluated exercises, including the exercise on September 17, 2014, plus several drills conducted since 1984.

DHS/FEMA Region VI wishes to acknowledge the efforts of the many individuals in the State of Arkansas, Pope, Yell, Logan, Johnson, and Conway Counties, National Oceanic and Atmospheric Administration (NOAA) Forecast Office, KXRJ Radio Station, and surrounding jurisdictions who participated in this exercise. Protecting the public health and safety is the fulltime job of some of the exercise participants and an additional assigned responsibility for others. Still they have willingly sought this responsibility by volunteering to provide vital emergency services to their communities. Cooperation and teamwork of all the participants was evident during this exercise.

This report contains the final written evaluation of the biennial exercise. The state and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies, one Area Requiring Corrective Action (ARCA), which was corrected during the exercise, and one Plan Issue identified during the exercise. Also, one previous ARCA was resolved during the exercise.

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After Action Report/Improvement Plan Arkansas Nuclear One SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Arkansas Nuclear One Type of Exercise Plume Exercise Date September 17, 2014 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 N. Loop 288 Denton, Texas, 76209 940-898-5199 lisa.hammond@dhs.gov Elsa Lopez Federal Planning Team Lead FEMA Region VI Technological Hazards Program Specialist 800 N. Loop 288 5

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After Action Report/Improvement Plan Arkansas Nuclear One Denton, Texas, 76209 940-898-5308 elsa.lopez@fema.dhs.gov Don Greene State Planning Team Lead Arkansas Department of Health Health Physicist 4815 West Markham Street Slot 30 Little Rock, Arkansas, 72205 501-661-2808 donald.greene@arkansas.gov 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Arkansas Nuclear One exercise:

State Jurisdictions Arkansas Department of Emergency Management Arkansas Department of Health Arkansas Department of Social Services Arkansas Game and Fish Commission Arkansas National Guard Arkansas State Police Risk Jurisdictions City of Danville City of Danville Police Department City of Dardanelle Fire Department City of Dardanelle Police Department City of Russellville Mayor Johnson County Emergency Managment Johnson County Sheriffs Office Logan County Emergency Medical Service 6

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After Action Report/lInprovemcnt Plan Arkansas Nuclear One Logan County Health Unit - Arkansas Department of Health Logan County Office of Emergency Management Logan County Sheriffs Office London Fire Department Pope County Emergency Medical Services Pope County Fire Coordinator Pope County Health Department Pope County Judge Pope County Office of Emergency Management Pope County Sheriffs Office Russellville Fire Department Russellville Police Department Yell County Emergency Medical Services Yell County Judge Yell County Judge's Office Yell County Office of Emergency Management Yell County Sherrifs Office Private Organizations American Red Cross Arkansas Nuclear One Power Plant Arkansas Tech University Federal Jurisdictions Federal Bureau of Investigation National Oceanic and Atmospheric Administration 7

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After Action Report/Improvement Plan Arkansas Nuclear One SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design The DHS/FEMA Region VI Office evaluated the first qualifying Hostile Action Based Exercise on September 17, 2014 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 hostile action and radiological emergency involving Arkansas Nuclear One (ANO). 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 E.

2.3 Scenario Summary The no-release exercise scenario was developed to evaluate the response of exercise participants to an incident requiring evacuation of the public from the 10-mile Emergency Planning Zone surrounding Arkansas Nuclear One (ANO). The exercise scenario provided for the evaluation of the Arkansas Department of Emergency Management (ADEM), Arkansas Department of Health (ADH), Johnson, Logan, Pope, and Yell Counties, and Local Emergency Services to manage emergency operations, provide and implement protective action decisions, provide field measurement and analysis, alert and notify the public, and provide support operations and facilities.

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After Action Report/Improvement Plan Arkansas Nuclear One SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities, which participated in the Arkansas Nuclear One (ANO) Hostile Action Based exercise to test the off-site emergency response capabilities of State and local governments in the 10-mile Emergency Planning Zone (EPZ) surrounding ANO.

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 exercise are found in Appendix E of this report.

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3. 1, on the following page(s), presents the status of all exercise evaluation area criteria from the REP Program Manual that were scheduled for demonstration during this exercise by all 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 Deficiency 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)

P - Plan Issue N - Not Demonstrated 9

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After Action Report/Improvement Plan Ajrkansas Nuclear One Table 3.1 - Summnary of Exercise Evaluation (2 pages)

DATE: 2014-09-17 SITE: Arkansas Nuclear One, AR -

= UC 0 0 M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not =: * *~ W ~-

":" 0 t r*ý C)

C)

Demonstrated < 0 Emergency Operations Management Mobilization lal M M M M M M M Facilities lbl Direction and Control Ic M M M M M Communications Equipment Idl M M M M M M M M M Equipment and Supplies lel M M M M M M MIM M Protective Action Decision Making EW Exp. Control Decisions 2al M M M PARs 2b I PADs *2b2 M M M PADs for Disabled/Functional Needs 2cl M M M Ingestion PADs 2d1 RRR Decisions 2e I Protective Action Implementation EW Exp. Control Implementation 3al _ M M M M M P KI Public/Institutionalized 3bl M M M PAD Imp. Disabled/Functional Needs 3cl M M M PAD Imp. Schools 3c2 TACP Establishment 3d] _ _M M M Impediments to Evacuation 3d2 M M M Implementation of Ingestion PADs 3e 1 Ingestion Strategies and Information 3e2 Imp. of RRR Decisions 3fl Field Measurement and Analysis RESERVED 4al Field Team Management 4a2 Field Team Operations 4a3 M M Field Team Sampling 4b I Laboratory Operations 4c I Emergency Notification and Public Info Initial Alert & Notification 5al M Backup Alert & Notification 5a3 Exception Area Alerting 5a4 Subsequent Public Information 5bl M Support Operations/Facilities Reception Center Operations 6al EW Monitoring & Decon 6bI Congregate Care 6cl Contaminated Inured Transport & Care 6d I 10

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After Action Report/Improvement Plan Arkansas Nuclear One Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/2)

DATE: 2014-09-17 SITE: Arkansas Nuclear One, AR M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated Emergency Operations Management Mobilization lal M M M Facilities IbI M M Direction and Control lc.1 M M Communications Equipment Idl M M M Equipment and Supplies lel M M M Protective Action Decision Making EW Exp. Control Decisions 2al M M PARs 2bl M PADs 2b2 M PADs forDisabled/Functional Needs 2cl M Ingestion PADs 2d 1 RRR Decisions 2el Protective Action Implementation EW Exp. Control Implementation 3a] M M KI Public/Institutionalized 3bl M PAD Imp. Disabled/Functional Needs 3cl M PAD Imp. Schools Rc2 TACP Establishment 3d] M Impediments to Evacuation 3d2 M Implementation of Ingestion PADs 3e 1 Ingestion Strategies and Information 3e2 Imp. of RRR Decisions 3fl Field Measurement and Analysis RESERVED 4al Field Team Management 4a2 M Field Team Operations 4a3 Field Team Sampling 4b1 Laboratory Operations 4c1 Emergency Notification and Public Info Initial Alert & Notification 5al* M M Backup Alert & Notification 5a3 Exception Area Alerting 5a4 Subsequent Public Information 5bl M Support Operations/Facilities Reception Center Operations 6al EW Monitoring & Decon 6b]

Congregate Care 6c ]

Contaminated Injured Transport & Care 6d]

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After Action Report/Improvement Plan Arkansas Nuclear One 3.3 Criteria Evaluation Summaries 3.3.1 Arkansas Jurisdictions 3.3.1.1 Arkansas State Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: l.a. 1, 1.c. 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 3.3.1.2 Arkansas Department of Health, Little Rock Emergency Communications Center In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a. 1, I.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 3.3.1.3 Arkansas Department of Health at the Site Emergency Operations Facility In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 5.a;1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

.d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None 13

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g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.4 Arkansas Field Radiological Monitoring Team One In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: l.d.1, 1.e.l, 3.a.l, 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 3.3.1.5 Arkansas Field Radiological Monitoring Team Two In summary, the status of DHS/FEMA criteria for this location is a3 follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: I.e.1.

ISSUE NO.: 01-12-1eI-A-0I ISSUE: The potassium iodide (KI) for use by Arkansas Department of Health Field Teams is stored in a trailer behind the Arkansas Department of Health, Nuclear Planning & Response Program office in Russellville, AR. The trailer is not climate controlled. This storage location does not meet the iOSAT manufacturer's storage instructions to store the potassium iodide at 68-77 degrees Fahrenheit.

CORRECTIVE ACTION DEMONSTRATED: The Potassium Iodide is now appropriately stored within the air conditioned work area of the Nuclear Planning and Response Program Office located in Russellville. This area is climate controlled in accordance with the manufacturer's requirements.

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g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.6 Alternate Joint Information Center 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, 5.b. 1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.7 Arkansas Department of Health - Freeway Medical In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.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 3.3.1.8 Emergency News Center NP&RP In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a.1, 1.b.1, 1.d.1, 1.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 15

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After Action Report/Improvement Plan Arkansas Nuclear One 3.3.2 Risk Jurisdictions 3.3.2.1 Johnson County Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

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

ISSUE NO.: 01-14-3aI-A-01 CRITERION: 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. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

CONDITION: The emergency worker radiological briefing was inadequate.

POSSIBLE CAUSE: Possibly inadequate training of the County Radiological Officer and lack of procedural guidance for conducting radiological briefings

REFERENCE:

NUREG-0654/FEMA REP-1:

Planning Standard J. 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 NUREG-0654/FEMA REP-1i:

Planning Standard 0.5. 5. Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.

Johnson County Radiological Emergency Response Plan Chapter 12:

12.A. 1. Responsibilities of Nuclear Planning and Response:

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b. Develop and conduct training classes for all potential emergency workers. This training for emergency workers shall include, but not necessarily be limited to:

radiological monitoring procedures and methods, biological effects of radiation, anti-contamination procedures, contamination "hot line" procedures and personnel and equipment decontamination.

c. Provide annual training to the County Judge, EOC staffs, and warning point staffs EFFECT: Failure to conduct adequate radiological briefings to emergency workers, to include information on methods to minimize radiation exposure and information on the potential benefits and risks associated with radioprotective drugs, could result in increased risk to those workers due to excessive radiation dose or radioprotective drug reactions.

CORRECTIVE ACTION DEMONSTRATED: The performance deficiency was immediately corrected by radiological training provided by the Controller followed by a successful re-demonstration by the County Radiological Officer.

For long-term corrective action:

The individual(s) performing as the Johnson County Radiological Officer should be trained in the theoretical and practical aspects of radiological exposure control listed in Chapter 12 (Radiological Emergency Response Training) of the Johnson County Radiological Emergency Response Plan, to include the subject matter listed in Appendix 6 (Training Guidelines) to the Plan The Johnson County Standard Operating Procedures should include a procedure for the County Radiological Officer with a checklist for conducting radiological briefing of emergency workers who would deploy to the emergency planning zone. The checklist should include the following points as a minimum:

-Zeroing direct-reading dosimeters,

-Checking the direct-reading dosimeters periodically during an emergency response(e.g., every 15 to 30 minutes),

-Recording the readings of the direct-reading dosimeters on exposure record(s),

-Reporting radiation exposure limits and turn-back values,'

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-Workers undertaking life-saving missions or protecting valuable property or large populations may face increased risk from radiation,

-Proper use of permanent record dosimeters,

-Dosing and documentation of KI ingestion,

-Why KI is administered and any adverse effects,

-Where to report for monitoring and decontamination, and

-Where and to whom to return their dosimetry at the conclusion of the emergency or mission

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 Logan County Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 Pope County Emergency Operations Center.

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

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None 18

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g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.4 Pope County Incident Command Post 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.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.a.1.

ISSUE NO.: 01-14-3al-P-02 CRITERION: 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. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

CONDITION: Pope County Annex 1 and the provided "Dosimeter Reading" cards incorrectly state onsite emergency responder exposure limits in rem instead of Roentgen (R).

POSSIBLE CAUSE: The error may have been an oversight or the individual responsible for Pope County Annex 1 and developing the "Dosimeter Reading" cards may not have been aware of the 5x conversion factor used to convert radiation exposure to radiation dose. The offsite radiation exposure limits on the "Dosimeter Reading" card were correctly provided in terms of mR.

REFERENCE:

NUREG 0654 K.3.a; Pope County Annex 1, Rev. 5.1; Arkansas Department of Health, Emergency Response Procedures, ER 2.5, Personnel Dosimetry and Exposure Guideline, Dated April 2014; Dosimeter Reading cards included in dosimetry kits.

EFFECT: Emergency workers and supervisors may be confused regarding the worker's radiation dose limit. The offsite exposure limits were provided in mR, the 19

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After Action Report/Improvement Plan Arkansas Nuclear One onsite limits provided in R.

If the Arkansas Department of Health exposure to dose conversion factor (5x) was used for onsite dose, the emergency worker would utilize a lower radiation exposure limit than intended. Because this would result in a conservative radiation dose limit, the emergency responder may not be able to complete his/her assigned task if they believe the 2 rem limit on the "Dosimeter Reading" card is to be adjusted for dose (by using an exposure limit of 400 rnR).

RECOMMENDATION: Update Annex 1 and Dosimeter Reading cards to correctly reflect the limits in terms of radiation exposure as read on the emergency worker's dosimeter and correctly stated in Arkansas Department of Health procedures.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.5 Yell County Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as.follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3 Private Organizations 3.3.3.1 ENS Radio Station KXRJ In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 5.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None 20

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c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4 Federal Jurisdictions 3.3.4.1 NOAA North Little Rock In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 5.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 21

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After Action Report/Improvement Plan Arkansas Nuclear One SECTION 4: CONCLUSION Based on the results of the exercise, the offsite radiological emergency response plans and preparedness for the State of Arkansas 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 Arkansas site-specific to Arkansas Nuclear One will remain in effect.

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After Action Report/Improvement Plan Arkansas Nuclear One APPENDIX A: IMPROVEMENT PLAN I. NuIsu br 01143a 0 Critein ISSUE: Pope County Annex I and the provided "Dosimeter Reading" cards incorrectly state onsite emergency responder exposure limits in rem instead of Roentgen (R).

RECOMMENDATION: Update Annex 1 and Dosimeter Reading cards to correctly reflect the limits in terms of radiation exposure as read on the emergency worker's dosimeter and correctly stated in Arkansas Department of Health procedures.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

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After Action Report/]mprovement Plan Arkansas Nuclear One APPENDIX B: EXERCISE TIMELINE Table I presents the times at which key events and activities occurred during the ANO Hostile Action Based Exercise held on September 17, 2014.

Table 1 - Exercise Timeline DATE: 2014-09-17, SITE: Arkansas Nuclear One, AR 0

515 Emergency Classification Level or ::-

Event -U (U) o

") 02o ooo U 0 00 0 Unusual Event 0744 0758 0754 0812 0815 081]

Alert 0813 0832 0824 0837 0829 0830 0828 Site Area Emergency 1009 1020 1014 1012 1035 1035 1035 General Emergency Simulated Rad. Release Started Simulated Rad. Release Terminated Facility Declared Operational 0827 0857 0836 0830 0810 Declaration of State of Emergency 0846 0822 Exercise Terminated 1215 1236 1214 1225 1214 1225 Early Precautionary Actions:

Protective Action Advisory 1st Protectdive Action Decision 1st Siren Activation 1st EAS or EBS Message KI Administration Decision:

24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Rcport/Improvement Plan Arkansas Nuclear One Table 1 - Exercise Timeline DATE: 2014-09-17, SITE: Arkansas Nuclear One, AR Emergency Classification Level or Event o o I Z 0 z Unusual Event 0744 0801 0810 0800 0817 Alert 0813 0831 0829 0826 0843 Site Area Emergency 1009 1017 1035 1019 1035 General Emergency Simulated Rad. Release Started Simulated Rad. Release Terminated Facility Declared Operational 0758 0911 0830 0820 Declaration of State of Emergency Exercise Terminated 1214 1214 1215 1220 Early Precautionary Actions: 0810; 0938; 0945 Protective Action Advisory 0825 0920 1st Protectdive Action Decision 1st Siren Activation Ist EAS or EBS Message KI Administration Decision:

25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/] mprovemnent Plan Arkansas Nuclear One APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS DATE: 2014-09-17, SITE: Arkansas Nuclear One, AR LOCATION EVALUATOR AGENCY Arkansas State Emergency Operations Center *Joseph Suders FEMA RIIl Arkansas Department of Health, Little Rock Emergency *Paul Anderson FEMA RIX Communications Center Arkansas Department of Health at the Site Emergency Operations *Elsa Lopez FEMA RVI Facility Arkansas Field Radiological Monitoring Team One George Brozowski EPA-R6 Arkansas Field Radiological Monitoring Team Two *Scott Flowerday FEMA RVI Alternate Joint Information Center *Cara Christianson-Riley FEMA RVII Brenda Rembert ICFI Arkansas Department of Health - Freeway Medical Jesse King FEMA REPP Robert Neff FEMA RIII

Martin Vyenielo FEMA RIII Emergency News Center NP&RP Robert Alvey DHS

Meg Swearingen ICFI Johnson County Emergency Operations Center *Nan Calhoun FEMA RVI LaShawn Halsey FEMA HQ William Maier NRC Logan County Emergency Operations Center *Chad Johnston FEMA RVI Daniel Kanakares FEMA RVII Pope County Emergency Operations Center *Brad DeKorte FEMA RVI James Greer ICFI Elsa Lopez FEMA RVI Carolyn Sturghill FEMA RV Pope County Incident Command Post Marcy Campbell ICFI

Timothy Pflieger FEMA RVI Yell County Emergency Operations Center *Barton Freeman FEMA RIII John Zeidler ICFI ENS Radio Station KXRJ *Elsa Lopez FEMA RVI NOAA North Little Rock *Paul Anderson FEMA RIX

Team Leader 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One APPENDIX D: ACRONYMS AND ABBREVIATIONS ADEM Arkansas Department of Emergency Management ADH Arkansas Department of Health AJIC Alternate Joint Information Center ANO Arkansas Nuclear One ARCA Area Requiring Corrective Action AWIN Arkansas Wireless Information Network CAD Computer Aided Dispatch DEF/VS Dedicated Emergency Facsimile/Voice System DRD Direct Reading Dosimeter EAD Electronic Alarming Dosimeter EAL Emergency Action Level EAS Emergency Alert System ECC Emergency Communications Center ECL Emergency Classification Level EMC Emergency Management Coordinator EMS Emergency Medical Services ENC Emergency News Center EOC Emergency Operations Center EOF Emergency Operations Facility EOP Entent of Play EPA Environmental Protection Agency EPZ Emergency Planning Zone ER Emergency Response ESF Emergency Support Function EW Emergency Worker EWS Emergency Warning System FMT Field Monitoring Team FMTC Field Monitoring Team Coordinator FRS Family Radio Service FTC Field Team Controller GIS Geographic Information System GPS Global Positioning System HAB Hostile Action Base HP Health Physicist 27

Unclassified Radiological Emergency Preparedness Program (REP)

Aftcr Action Report/]mprovement Plan Arkansas Nuclear One IC Incident Commander ICP Incident Conmnand Post JIC Joint Information Center KI Potassium Iodide LGL Local Government Liaison MAC Mutual Aid Channel NERN Nuclear Emergency Radio Network NOAA National Oceanic and Atmospheric Administration NP&RP Nuclear Planning and Response Program ORO Ofifsite Response Organization OSD Optically Stimulated Dosimeters OSL Optically Stimulated Luminescent PAA Protective Action Advisory PAD Protective Action Decision PAG Protective Action Guide PAR Protective Action Recommendation PCSO Pope County Sheriffs Office PDF Portable Document Format P1O Public Information Officer PIT Public Information Team PNM Public Notification Messages PRD Permanent Record Dosimeter RACES Radio Amateur Civil Emergency Service REP Radiological Emergency Preparedness RFD Russellville Fire Department RO Radiological Officer RPD Russellville Police Department RRTL Radiological Response Team Leader RSO Radiation Safety Officer SAE Site Area Emergency SDO Staff Duty Officer SEOC State Emergency Operations Center SEOF State Emergency Operations Facility T/ACP Traffic and Access Control Point TEDE Total Effective Dose Equivalent TLD Thermoluminescent Permanent Record Dosimeter TOCD Technical Operations Control Director UE Unusual Event UPS Uninterruptible Power Supply VHF Very High Frequency 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One VOIP WO Voice Over Internet Protocol Watch Officer I 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One APPENDIX E: EXERCISE PLAN 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One Arkansas Nuclear One 2014 Biennial Exercise September 17, 2014 Extent-of-Play (EOP) Agreement Between The Arkansas Department of Health, representing the Off-Site Response Organizations, and FEMA Region VI EVALUATION AREA I Emergency Operations Management Sub-element 1.a - Mobilization INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

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-.,.A.I.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3, 4)

Locations: State EOC ADEM, Camp Robinson; ADH Emergency Communications Center, Little Rock; Pope County EOC, Russellville; Johnson County EOC, Clarksville; Logan County EOC, Paris; Yell County EOC, Danville. Incident Command Post, Russellville; Emergency News Center (NP&RP), Russellville; ADH EOC at Freeway Medical, Little Rock; Alternate Joint Information Center (AJIC), Little Rock EOP 1. ANO will notify the law enforcement agencies lAW ANO Security Plans and the HAB Annex to the Pope County Radiological Plan

2. The remainder of the OROs will be notified of ECLs lAW existing plans and procedures.

3. The ADH Radiological Response Team will report to the ADH EOC at Freeway Medical. Nuclear Planning and Response Program staff will report to their offices in Russellville.

4. Two (2) FRMTs will pre-stage at the NP&RP office. The Armory will not be used for this exercise.

5. No shift change will be performed. A list of second shift Key Personnel will be available for review. A shift change briefing will either be demonstrated by the OROs or the evaluator will interview the ORO to determine the content of the briefing.

6. The 1 st shift may be over staffed for training purposes. Some staff identified on the 2nd shift roster will play with the 1 st team. In an actual emergency this over staffing would not be used.

(Rex -14 Final August 12, 2014) 31

Unclassified Radiological Emergency Preparedness Progiram (REP)

After Action Report/Improvement Plan Arkansas Nuclear One

7. If OROs receive information from alternate sources; the OROs will contact the licensee. The licensee will make additional notification as appropriate.

8. Resources required to respond to the event will be demonstrated. The ability to identify and request additional resources and the role of mutual aid in the response will be demonstrated through interview.

9. Protocols for requesting Federal Support will be demonstrated through interview at the ADH EOC.

10. Incident Command Post tactical operations will not be evaluated. Once coordination among the incident command, the utility, and all appropriate support agencies have been demonstrated, the evaluation of the ICP terminates. Response operations may continue, but are not subject to evaluation.

11. The following locations will pre-stage:

a. Incident Command Post at 7975 HWY 64 West, Russellville, AR

b. Field Teams

c. Alternate JIC

d. Emergency News Center/Media Briefing Location

e. ADH EOC at Freeway Medical

f. Pope County EOC.

ARCA: NONE Sub-element 1.b- Facilities INTENT This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have facilities to support the emergency response.

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

Locations: Emergency News Center (NP&RP), Russellville; ADH EOC at Freeway Medical, Little Rock.

EOP: The above locations are new to support HAB events. They- have not been evaluated previously .-

ARCA: None 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One Sub-element 1.c - Direction and Control INTENT This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to control their overall response to an emergency.

Criterion 1.c. 1: Key personnel with leadershiproles for the ORO provide direction and controlto that part of the overall response effort for which they are responsible.(NUREG-O654IFEMA-REP-1, A. 1.d; A.2.a, b; A.3; C.4, 6)

Locations: State EOC ADEM, Camp Robinson; ADH EOC at Freeway Medical, Little Rock; Pope County EOC, Russellville; Logan County EOC, Paris; Yell County EOC, Danville; Johnson County EOC, Clarksville; Incident Command Post, Russellville EOP: 1. Incident Command will be establish at the ICP lAW existing plans and procedures. The incident commander will direct and control ORO response at the event location.

2. The TOCD will direct and control the ADH Radiological Response Team (RRT).

3. The RRT will provide recommendations related to the radiation aspect of the response and will assess the radiation environment as required.

4. The TOCDIRRT will be located at the ADH EOC in Freeway Medical.

5. ANO will notify the ADH ECC per established procedures. The ECC will follow the instructions of the RSDO and/or the TOCD ARCA: None

Sub-element'l.d - Communications Equipment INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the EPZ, Federal emergency response organizations, the licensee and its facilities, EOCs, Incident Command Posts, and FMTs.

Criterion I.d.1: At least two communicationsystems are available,at least one operatesproperly, and communication links are establishedand maintainedwith appropriatelocations.

Communications capabilitiesare managed in support of emergency operations.(NUREG-0654/FEMA-REP-I, F.1, 2)

Locations: State EOC ADEM, Camp Robinson; ADH ECC, Little Rock; ADH EOC at Freeway Medical, Little Rock; Emergency News Center (NP&RP), Russellville; Alternate Joint Information Center, Little Rock; Pope County EOC, Russellville; Johnson County EOC, Clarksville; Logan County EOC, Paris; Yell County EOC, Danville; Incident Command Post, Russellville; State FRMT 1, Russellville; State FRMT 2, Russellville 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One EOP: Each location will demonstrate the use of one primary and one backup communications system and be prepared to discuss backup alternate communication systems. Each location will identify a communications system that is independent of the commercial telephone system.

ARCA: None Sub-element I.e - Equipment and Supplies to Support Operations INTENT This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have emergency equipment and supplies adequate to support the emergency response.

Criterion I.e.1: Equipment, maps, displays, monitoring instruments, 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.lO.a, b, e; J.11, 12; K.3.a; K.5.b)

Locations: State EOC ADEM, Camp Robinson; ADH ECC, Little Rock; ADH EOC at Freeway Medical, Little Rock; Emergency News Center (NP&RP), Russellville; Alternate Joint Information Center, Little Rock; Pope County EOC, Russellville; Johnson County EOC, Clarksville; Logan County EOC, Paris; Yell County EOC, Danville; Incident Command Post, Russellville; State FRMT 1, Russellville; State FRMT 2, Russellville.

EOP: 1. The staging area will not be activated. Through interview the NP&RP manager will demonstrate the procedures, when required, for providing dosimetry, KI and just in time-training to specialized responding resources.

2. Meters or DRDs that have "bar code" labels can have their calibration and quarterly operational check dates verified with the master database maintained by the NP&RP HP. Operational checks of meters will be performed before use, using range of readings stickers on the meters.

3. The quantities of Dosimetry and the quantities and expiration of KI will be confirmed by evaluators at locations identified in plans.

4. The availability of TACP equipment will be described through interview at the Counties. TACP personnel will not go TACP locations.

5. Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller. Caution should be exercised to ensure that exercise play is not interrupted.

ARCA: 01-12-1el-A-01 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One EVALUATION AREA 2 Protective Action Decision-Making Sub-element 2.a - Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans/procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.

Criterion2.a. 1: OROs use a decision-making process, consideringrelevant 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 authorizeradiationexposure in excess of administrative limits or protective action guides. (NUREG-O654IFEMA-REP-1, C. 6; J. 10. e, f; K.4)

Locations: ADH EOC at Freeway Medical, Little Rock; Pope County EOC, Russellville; Logan County EOC, Paris; Yell County EOC, Danville; Johnson County EOC, Clarksville.

EOP: 1. Exposure control is lAW existing plans and procedures. The ADH EOC at Freeway Medical will advise the Incident Commander and EOCs of any change in Dose Projection

2. It is Arkansas policy to issue KI only to Emergency Workers (EW) and institutionalized individuals. County EWs who decline to take KI are not identified in advance. If they decline to take KI at their duty stations, they will not be placed in positions that would expose them to radiation. KI is not issued to the general public

3. If the scenario dGes not require a KI decision, OROs can satisfy this EA by interview.

4. The State of Arkansas may not consider the termination of Emergency Worker exposure control to be at the end of the "plume phase".

ARCA: None Sub-element 2.b. - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency INTENT This Sub-element is derived from NUREG-0654IFEMA.REP-1, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PAGs. OROs must have the capability to choose, among a range of protective actions, those most appropriate in a given emergency. OROs base these choices on PAGs from their plans/procedures or EPA's Manual of Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria, such as plant.conditions, licensee PARs, coordination of PADs with other political jurisdictions (e.g., other affected OROs and incident command), availability of in-place shelter, weather conditions, and situations, to include HAB incidents, the threat posed by the specific hostile action, the affiliated response, and the effect of an evacuation on the threat response effort, that create higher than normal risk from general population evacuation.

35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One Criterion2.b. 1: Appropriate protective action recommendations(PARs) are basedon available information on plant conditions, field monitoring data, and licensee and ORO dose projections,as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, .10 and Supplement 3)

Locations: ADH EOC at Freeway Medical.

EOP:

1. Protective actions related to radiation events will be made lAW existing plans and procedures. If the scenario does not result in a GE declaration and the requirement for a protective action, the TOCD will demonstrate the process for making a decision not to make a PAA. This decision will be communicated to the County EOCs. The EOCs will demonstrate the process for agreeing with this decision. The decision not to make any protective action meets the requirement of this criterion.

2. The State's Dose-Asses'sment Team will make projections based on plant conditions andlor source terms, when available. The Team will be operational at the ADH EOC at Freeway Medical. If the scenario does not result in a release, a controller inject with a source term and a RDACS projection will be given to the Dose Assessment Team. They will calculate a dose projection and compare results.

3. Protective Action Advisories issued by the-State may differ from the ANO Protective Action Recommendations and may not reflect the logic identified in NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Guidance for Protective Action Strategies (October2011)

ARCA: None Criterion 2.b.2: A decision-makingprocess involving considerationof appropriatefactors and necessary coordinationis used to make protective action decisions (PADs) for the generalpublic (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)

Locations: Pope County EOC, Russellville; Johnson County EOC, Clarksville; Logan County EOC, Paris; Yell County, EOC, Danville; Incident Command Post, Russellville.

EOP: 1. It is Arkansas policy to issue KI only to Emergency Workers (EW) and institutionalized individuals. KI is not issued to the general public.

2. Protective actions related to radiation' events will be made lAW existing plans and procedures. If the scenario does not result in a GE declaration and the requirement for a protective action, the TOCD will demonstrate the process for making a decision not to make a PAA. This decision will be communicated to the County EOCs. The EOCs will demonstrate the process for agreeing with this' decision. The decision not to make any protective action meets the requirement of this criterion.

36

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One

3. The State issues Protective Action Advisories (PAAs) and ANO issues Protective Action Recommendations (PARs). A PAA and/or PAR becomes a PAD when all County Judges concur.

4. Protective actions related to tactical operations, non radiation, will be made by the Incident Commander lAW existing plans and procedures and law enforcement protocols.

5. The Incident Commander will advise EOCs of the magnitude of the threat, the response, and/or site conditions that would require changing Protective Action Decisions.

ARCA: None Sub-element 2.c - PAD Consideration for the Protection of Persons with Disabilities and Access/Functional Needs INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to determine'PADs, including evacuation, sheltering, and use of KI, if applicable, for groups of persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed daycare centers, mobility-impaired individuals, and transportation-dependent individuals). The focus is on those groups of persons with disabilities and access/functional needs that are, or potentially will be, affected by a radiological release from an NPP.

Criterion2.c. 1: Protective action decisions are made, as appropriate,for groups of persons with disabilitiesand access/functionalneeds. (NUREG-0654/FEMA-REP-1,D.4;J.9; J. 1O.d, e)

Locations: Pope County EOC, Russellville; Johnson County EOC, Clarksville; Logan County EOC, Paris; Yell County EOC, Danville.

EOP: 1. Lists and procedures will be demonstrated for supporting "groups of persons with disabilities and access/functional needs". These lists will be reviewed by evaluators but will not be given to evaluators because of HIPPA requirements. Actions will be simulated

2. If the scenario does not result in a GE requiring a PAD, a controller inject will be inserted to all the EOCs to demonstrate this criterion through interview.

3. County EOCs will actually notify all public school systems/districts one time during the drill lAW with their procedures, if the systems/districts are in session.

ARCA: None 37

Unclassified Radiological Emergency Preparedness Program (REP)

After ActionReport/Improvemcnit Plan Arkansas Nuclear One EVALUATION AREA 3 Protective Action Implementation Sub-element 3.a - Implementation of Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KI for emergency workers, always applying the -as low as is reasonably achievablell principle as appropriate.

Criterion3.a. 1: The OROs issue appropriatedosimetryKI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures.Emergency workers periodicallyand at the end of each mission read their dosimetersand record the readings on the appropriateexposure recordor chart. OROs maintainappropriaterecord-keeping of the administrationof KI to emergency workers. (NUREG-O654IFEMA-REP-1, J. IO.e; K.3.a, b; K.4)"

Locations: ADH EOC at Freeway Medical, Little Rock; Pope County EOC, Russellville; Logan County EOC, Paris; Yell County EOC*. Danville- Johnson County EOC, Clarksville; Incident Command Post, Russellville; State FRMT 1, Russellville; State FRMT 2, Russellville.

EOP: 1. Exposure control is lAW existing plans and procedures. The ADH EOC at Freeway Medical will advise the Incident Commander and EOCs of any change in Dose Projection

2. County ROs will demonstrate the EW briefing, record keeping, and procedures for issuing and returning dosimetry and KI.

4. It is Arkansas policy to issue KI only to-Emergency Workers (EW) and institutionalized individuals. KI is not issued to the general public.

5. If the scenario does not require a KI decision, OROs can satisfy this EA by interview.

6. The State of Arkansas may not consider the termination of Emergency Worker exposure control to be at the end of the "plumephase".

7. The listing of EWs who have ingested KI would be developed after the exposure forms are turned in. Because of the length of this exercise, this requirement will not be demonstrated. Each EW who simulates taking KI will have a form documenting when it was taken. These forms would be the basis for developing this list. Forms will be available for evaluator review.

8. Responding resources that do not have proper dosimetry or KI will be issued dosimetry or KI at the ICP. Just in time training will be provided as required.

38.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Rcport/Improvement Plan Arkansas Nuclear One

9. The staging area will not be activated. Through interview the NP&RP manager will demonstrate the procedures, when required, for providing dosimetry, KI and just in time training to specialized responding resources

10. Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller. Caution should be exercised to ensure that exercise play is not interrupted.

ARCA: None Sub-element 3.b - Implementation of KI Decision for Institutional individuals and the General Public INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide KI for institutionalized individuals, and, if in the plans/procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide KI to institutionalized individuals, providing KI to the general public is an ORO option and must be reflected as such in ORO plans/procedures. Provisions must include the availability of adequate quantities, storage, and means of distributing KI.

Criterion 3.b. 1: KI and appropriateinstructions are available if a decision to recommend use of KI is made. Appropriate record-keepingof the administrationof KI for institutionalizedindividuals and the generalpublic is maintained.(NUREG-0654/FEMA-REP-1, J.IO.e, t)

Locations: Pope County EOC, Russellville; Logan County EOC, Paris; Yell County EOC, Danville; Johnson County EOC, Clarksville.

EOP: 1. It is Arkansas policy to issue KI only to Emergency Workers (EW) and institutionalized individuals. KI is not issued to the general public.

2. If the scenario does not require a KI decision, the County EOCs can satisfy this EA by interview.

3. Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller. Caution should be exercised to ensure that exercise play is not interrupted.

ARCA: None Sub-element 3.c - Implementation of Protective Actions for Persons With Disabilities and AccesslFunctional Needs.

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement PADs, including evacuation and/or sheltering, for all -personswith disabilities and access/functional needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological release from an NPP 39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/]Improvement Plan Arkansas Nuclear One Criterion3.c. 1: Protectiveaction decisions are implemented for persons with disabilitiesand access/functionalneeds other than schools within areassubject to protective actions. (NUREG-0654/FEMA-REP-1, J.lO.c, d, e, g)

Locations: Pope County EOC, Russellville; Johnson County EOC, Clarksville; Logan County EOC, Paris; Yell County EOC, Danville.

EOP: 1. Lists and procedures will be demonstrated for supporting "groups of persons with disabilities and access/functional needs", if required by the scenario. Actions will be simulated. -

2. If the scenario does not result in a GE requiring a PAD, a controllerinject will be inserted to all the EOCs to demonstrate this criterion through interview.

3. If contacting a transportation provider is not demonstrated, a controller inject will be provided. Only one provider will be actually contacted at each EOC.

ARCA: None Sub-element 3.d. - Implementation of Traffic and Access Control INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic and access control points, and removal of impediments to the flow of evacuation traffic.

Criterion3.d.1: Appropriate traffic and access control is established.Accurate instructionsare provided to traffic and access controlpersonnel.(NUREG-0654/FEMA-REP-I, A.3; C. 1,4; J. 1O.g, j)

Locations: Pope County EOC, Russellville; Logan County EOC, Paris; Yell County EOC, Danville; Johnson County EOC, Clarksville.

EOP: 1. The RO will issue Dosimetry, KI and brief the Deputy assigned to the T/ACP as appropriate. The Deputy will not drive to the location. The Deputy will talk through the T/ACP, monitoring, and EW exposure control procedures.

2. If the scenario does not result in a GE declaration requiring a PAD; a controller inject will be inserted to demonstrate this criterion.

3. Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller. Caution should be exercised to ensure that exercise play is not interrupted.

ARCA: None 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One Criterion3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654/FEMA-REP-1, J.lO.k)

Locations: Pope County EOC, Russellville; Logan County EOC, Paris; Yell County EOC, Danville; Johnson County EOC, Clarksville.

EOP: 1. The EOC representative will talk through the procedures that demonstrate the capability to identify and take appropriate actions concerning impediments to evacuation.

2. An inject will be inserted after the evacuation has started. The inject will require the re-routing of traffic.

3. If a GE has not been declared and evacuations have not been ordered, this inject will be inserted out of sequence.

4. All EOCs will discuss how this road closing information and re-routing information will get to the public. Providing this information to the AJIC will be simulated.

5. Actual dispatch of resources will not take place.

ARCA: None EVALUATION AREA 4 Field Measurement and Analysis Sub-element 4.a - Plume Phase Field Measurements and Analyses INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to deploy FMTs with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the .ground from an airborne plume. In addition, NUREG-0654/FEMA-REP-1 indicates that OROs must have the capability to use FMTs within the plume exposure pathway EPZ to detect airborne radioiodine in the presence of noble gases and radioactive particulate material in the airborne plume. In an incident at an NPP, the possible release of radioactive material may pose a risk to the nearby population and environment. Although incident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an incident, it is important to collect field radiological data to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

4.a.2: Fieldteams (2 or more) are managedto obtain sufficient information to help characterizethe release and to control radiationexposure. (NUREG-0654/FEMA-REP-1,C. I; H. 12; 1.7, 8, 11; J. lO.a)

Locations: ADH EOC, Little Rock at Freeway Medical EOP: 1. State FRMTs will follow the ALARA Policy of the Arkansas Department of Health. Teams will not routinely traverse a plume. State Teams will define the edge of the plume. Air samples will be taken in areas reading near 20 mRlhr or as directed.

41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One

2. Air samples will not be transported.

3. Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller. Caution should be exercised to ensure that exercise play is not interrupted.

4. Coordination concerning transfer of sample, including chain of custody form, to a laboratorywill be discussed. It is not the intent of the State of Arkansas to deliver air samples to the lab within four (4) hours.

5. If the scenario does not result in a release, a controller inject will be inserted with radiological data. FRMT members will demonstrate taking radiation readings and air samples. Results will be communicated to field team control lAW procedures.

ARCA: None Criterion4.a.3: Ambient radiationmeasurements are made and recordedat appropriatelocations, and radioiodineand particulatesamples are collected. Teams will move to an appropriatelow backgroundlocation to determine whether any significant(as specified in the plan and/or procedures)amount of radioactivityhas been collected on the sampling media. (NUREG-0654/FEMA-REP-1, C.1; H.12: 1.8, 9; J.IO.a)

Locations: State FRMT 1, Russellville; State FRMT 2, Russellville EOP: 1. State FRMTs will follow the ALARA Policy of the Arkansas Department of Health. Teams will not routinely traverse a plume. State Teams will define the edge of the plume. Air samples will be taken in areas reading near 20 mR/hr or as directed.

2. Air samples will not be transported.

3. Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller. Caution should be exercised to ensure that exercise play is not interrupted.

4. Coordination concerning transfer of sample, including chain of custody form, to a laboratory will be discussed. It is not the intent of the State of Arkansas to deliver air samples to the lab within four (4)'hours.

5. If the scenario does not result in a release, a controller inject will be inserted with radiological data. FRMT members will demonstrate taking radiation readings'and air samples. Results will be communicated to field team control lAW procedures.

6. Air samplers will not be purged.

7. FFRMTs may be asked to describe all procedures not demonstrated.

42

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One

8. Charcoal canisters will be used instead of Silver Zeolite. Silver Zeolite canisters will be available for evaluator review.

9. Sealed kits do not have to be inventoried. However, FRMTs can inventory them if they want.

10. Two teams will be deployed to the field

11. State FRMTs will use gloves as necessary. Access to "anti-C's" will be demonstrated; however, they will not be worn. After the termination of the exercise FRMT.members will be prepared to demonstrate the donning and removal of "anti-C's" at the NP&RP office. A hot line will not be established and monitoring of team member will not be demonstrated. Respiratory protection will NOT be used.

ARCA: None EVALUATION AREA 5 Emergency Notification and Public Information Sub-element 5.a - Activation of the Prompt Alert and Notification System INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability toprovide prompt instructions to the public within the plume exposure pathway EPZ. Specific provisions addressed in this Sub-element are derived from the Guide for the Evaluation of Alert and Notification Systems for Nuclear PowerPlants, FEMA-REP-1 0 (November 1985).

Criterion 5.a.1: Activities associatedwith primaryalertingand notification of the public are completed in a timely mannerfollowing the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initialinstructionalmessage to the public must include as a minimum the elements requiredby currentREP guidance. (NUREG-0654/FEMA-REP-1, E.5, 6, 7)

Locations: NP&RP, Russellville: NOAA. North Little Rock; Station KXRJ, Russellville.

EOP:

1. The EAS is not used for ANO alert and notification. The alerting is accompiished by the activation of.the siren system and the tone on the NOAA radio. The notification will be demonstrated by the simulated broadcast of the message on NOAA radio and simulated, remote takeover of KXRJ's transmitter and the re-broadcast of the NOAA message.

2. No sirens will sound and local radio messages and National Oceanic and Atmospheric Administration (NOAA) messages will NOT BE BROADCAST. The siren activation-will be simulated. However, the procedures should be demonstratedup to the point of actualactivation. In Arkansas the County 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Arkansas Nuclear One Judge is the decision maker for protective actions. The TOCD only recommends actions. Since the State does the "alert and notification", the State must wait until the final Judge makes a decision to agree with the recommendation before the "alert and notification" begins.

3. Local radio message simulation will be demonstrated at radio station KXRJ in Russellville. A site visit will be made to check equipment. The remote takeover of the KXRJ will be simulated at either the NP&RP office or the communications trailer.

4. NOAA message simulation will be demonstrated at the National Weather Service Forecast Office, North Little Rock. Any real emergency will take precedence. Procedures to broadcast the message will be fully demonstrated as they would in an actual emergency up to the point of transmission.

Broadcast of the message(s) or test messages is not required.

5. Route Alerting is not a Primary ANS method. It will not be demonstrated.

6. The demonstration of the ANS activation will be after the drill terminates.

ARCA: None Sub-element 5.b - Emergency Information and Instructions for the Public and the Media INTENT This Sub-element is derived from'NUREG-0654/FEMA-REP-1, which-requires that OROs have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUREG-0654/FEMA-REP-1 requires OROs to ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency. NUREG-0654/FEMA-REP-1 also provides that a system must be available for dealing with rumors. This system will hereafter be known as the -public inquiry hotline.II Criterion5.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)

Locations: Emergency News Center (NP&RP), Russellville; Alternate Joint Information Center, Little Rock.

EOP:

.1. Media kits will be provided by Entergy at the AJIC.

2. Rumor Control activity is-staffed by ANO employees lAW Entergy plans and procedures:.

3. The JIC and Rumor Control will be in Little Rock. They will pre-stage!

4. County representation at the JIC will be through the ENC Liaison position.

.County personnel will not be at the JIC.

44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One

5. If the primary JIC and Rumor Control is not available at the training center because of the hostile action, the following Joint Information System will be established:

a. State Emergency News Center will be established at the NP&RP offices.

b. The Alternate JIC will be established at the Entergy building in Little Rock.

c. The media briefing Location will be established at the Hughes Center in Russellville.

6. The Incident Commander or his representative will approve all news releases related to the security incident. News releases related to the radiation event will be approved lAW plans and procedures.

7. State News Release will be written at the ENC.

8. Media briefings will be presented at the Media Briefing Location in the Hughes Center. This location is an extension of the ENC.

ARCA: None 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Rcport/Improvement Plan Arkansas Nuclear One SCENARIO NARRATIVE

SUMMARY

46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One September 17, 2014 Hostile Action Based Exercise Initial Conditions Exercise will be conducted in real time. Exercise will commence at 0730 hours0.00845 days 0.203 hours 0.00121 weeks 2.77765e-4 months on Wednesday, September 17, 2014, a normal working day.

Unit 1 The Unit 1 Simulator will not participate in the Exercise. There will be no communications with the Simulator crew other than the Unit 1 Shift Manager.

Unit 1 is operating at 100% power and has been operating at this power level for 360 days. There are no Technical Specification Limiting Conditions.

Unit 1 has no apparent problems.

0 A Unit 1 Shift Manager and Control Room Communicator will be available to support Unit 2.

Unit 2 Initial plant conditions on Unit 2 are as follows:

Unit 2 is operating at 100% power and has been operating at this power level for 47 days.

" Unit 2 Reactor Coolant Pump, 2P-32B has a failed lower seal stage.

Unit 2 'A' Main Feedwater Control system (FWCS) Master controller will not transfer to manual on the Hand Indicating Controller. The 'A' FWCS Master controller is in Soft panel mode.

The following facilities will participate in this Exercise: Unit 2 Simulator, EOF, Alternate TSC, Alternate OSC,' Alternate JIC and ICP. The Incident Command Post (ICP) and Alternate JIC will be pre-staged.

A Unit 1 Shift Manager and a Unit 1 Control Room Communicator will participate in this Exercise to support the Unit 2 Operations crew. The Unit 1 Shift Manager has responsibility for their own unit if an abnormal condition exists on that unit.

The Unit 1 Simulator will not participate in this Exercise and no actions will be taken by Unit 1 personnel during the Exercise. If any.Unit I actions need to be taken during the Exercise, they will be simulated and documented in the scenario.

The Unit I and Unit 2 actual controls rooms will not be participating in this Exercise except to sound the plant evacuation alarm if necessary.

47

Unclassifled Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkans.s Nuclear One September 17, 2014 Full Scale ERO Drill NARRATIVE

SUMMARY

The exercise will begin when the crew accepts responsibility for Unit 2 at approximately 0730 hours0.00845 days 0.203 hours 0.00121 weeks 2.77765e-4 months on September 17, 2014.

Airliner leaves Atlanta At 0720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months , Delta Airline Flight DL 1272 (Boeing 737) departed from the Hartsfield-Jackson Atlanta International Airport heading for the Kansas City International Airport carrying 211 passengers. The airliner has not been on the planned flight path since takeoff. The captain was contacted by air traffic control at 0725 hours0.00839 days 0.201 hours 0.0012 weeks 2.758625e-4 months where the captain stated that there is trouble with one of the engines. Traffic Control directed the captain to change course to the Memphis International Airport. Memphis International Airport has been;notified to prepare for an emergency landing.

Crew Assumes Watch At -0730 hours, both Unit 1 and Unit 2 reactor power will be 100%. The operations crew will have received turnover briefing and have walked down panels. Shift Manager should take the watch.

Credible Airliner Threat (NUE Criteria Met)

At 0735 hours0.00851 days 0.204 hours 0.00122 weeks 2.796675e-4 months , the NRC will call the Unit 2 Control-Room and inform the Shift Manager that a credible airliner threat to ANO exists. The NRC will request that an open (continuous) line of communications be maintained. (1203.048 Section 2, Step 3)

The current airliner position is approximately 60 minutes (450 miles) from the site. Since the 0725 hour0.00839 days 0.201 hours 0.0012 weeks 2.758625e-4 months communication, authorities have not been able to contact the airliner. The airliner has not changed course, has not reduced speed, or lowered altitude as directed, in order to land at Memphis International Airport. Current course takes the airliner near Arkansas Nuclear One.

EAL Criteria Met IC HUI - Confirmed SECURITY CONDITION orthreat which indicates a potential degradation in the level of safety of the plant.

Plant Evacuation At -0740 hours, the Unit 2 Shift Manager will evacuate the protected area due to the airliner threat (1203.048 Section 2, Step 3.A.). Site personnel willevacuate to the Emergency Operations Facility (EOF) or the Generation Support Building. (Only drill participants -will evacuate) 48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One NUE Declared Approximately 0740 hours0.00856 days 0.206 hours 0.00122 weeks 2.8157e-4 months , the Unit 2 Shift Manager should.declare a Notification of Unusual Event (NUE) based on the following condition:

IC HU1, "Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant" EAL 3 - A validated notification from NRC providing information of an aircraft threat The Shift Manager will notify the NRC and Offsite Response Organization in accordance with Procedure 1203.048, Security Events. The Emergency Response Organization (ERO) will be notified via pager in accordance with Procedure 1203.048, Security Events.

State and local authorities should* be notified of the NUE. declaration and that there are no protective actions recommended for the general public.

Security should contact Pope County 911 office to inform them of the credible threat.

ICP Staffing Approximately 0800 hours0.00926 days 0.222 hours 0.00132 weeks 3.044e-4 months , Local Law Enforcement may begin to staff the Incident Command Post (ICP) due to the credible airliner threat.

Airliner Crash At 0802 hours0.00928 days 0.223 hours 0.00133 weeks 3.05161e-4 months , the NRC informs the Unit 2 Control Room that the airliner has crashed approximately 250 miles east of the site.

Hostages Taken at GSB (Alert Criteria Met)

At 0805 hours0.00932 days 0.224 hours 0.00133 weeks 3.063025e-4 months , a Security Officer in the Generation Support Building (GSB) on a personal cell phone will contact CAS/SAS and inform them that personnel in the GSB have been taken hostage. At least 2 armed individuals, dressed in military-type uniforms have taken over the GSB. Adversaries have forced all personnel to move to the cafeteria area and lie down. At least 2 individuals have been shot; but it appears they are still alive. Security Officer will report he believes that the adversaries were talking with additional conspirators at a different location.

Adversaries will confiscate all cell phones and not allow any outside communication by hostages.

Security should contact the Shift Manager.

EAL Criteria Met IC HAI - HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat.

49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/l]mprovemcnt Plan Arkansas Nuclear One Incident Command Post Established At approximately 0815 hours0.00943 days 0.226 hours 0.00135 weeks 3.101075e-4 months , Pope County Sheriff s Office personnel should be responding to the site and begin establishing an Incident Command Post (ICP). Security should be communicating with the responding officers.

ALERT Declared By 0820 hours0.00949 days 0.228 hours 0.00136 weeks 3.1201e-4 months , the Shift Manager / Emergency Director should declare an ALERT emergency class based upon the following EAL:

IC - HA l - HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat.

EAL I - A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by ANO Security Shift Supervision.

The Shift Manager will use Procedure 1203.048, Security Event, to notify members of the Emergency Response Organization (ERO) and initiate offsite notifications for the ALERT. State and local authorities will be notified of the Alert and that there are no protective actions recommended for members of the general public.

Facilities- Staffed By 0835 hours0.00966 days 0.232 hours 0.00138 weeks 3.177175e-4 months , the EOF, Alternate TSC, and Alternate OSC may be staffed. ED&C may be transferred by this time, depending on the security situation.

SOCA Alarm At 0835 hours0.00966 days 0.232 hours 0.00138 weeks 3.177175e-4 months , Security will receive a SOCA alarm on the switchyard fence.

Loss of Offsite Power (NUE Criteria Met)

At 0840 hours0.00972 days 0.233 hours 0.00139 weeks 3.1962e-4 months , two adversaries have made their way into the switchyard. An explosive charge

[Improvised Explosive Device (lED)] is set offat the Phase B auto transformer.

The 500kV ring bus trips and locks out on imbalanced phases. Both units will trip.

The auto-transformer oil ignites and a large, smoky fire ensues.-

After the Unit 1 reactor trip, the Unit 1 Emergency liiesel'.Generator, K-4B, Will auto-start and energize Bus A-4 without incident.

After the Unit 2 reactor trip, the Unit 2 Emergency Diesel Generator, 2K-4B will auto-start, but will not load onto bus 2A-4 due to a malfunction of EDG output breaker 2A-408.

50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One At 0843 hours0.00976 days 0.234 hours 0.00139 weeks 3.207615e-4 months a second explosive device (IED) detonates on the Start-Up #2 (SU2) voltage regulator which supplies power to SU2. The 161kV ring bus trips and locks out. The station is now without any offsite power.

The Unit 1 Emergency Diesel Generator, K-4A, will auto start and energize Bus A-3 without incident.

The Unit 2 Emergency Diesel Generator, 2K-4A will auto-start and energize Bus 2A-3 without incident.

EAL Criteria Met (Plant should already be in an Alert due to Security Event)

IC SUI - Loss of all offsite AC power to Vital 4.16 KV busses > 15 minutes Adversary Neutralized At 0848 hours0.00981 days 0.236 hours 0.0014 weeks 3.22664e-4 months , one of the adversaries in the switchyard will be neutralized at the 161 kV ring bus (after the explosive charge has been set off).

Unit 2 Emergency Diesel Generator, 2K-4A Trips (Alert Criteria Met)

At 0918 hours0.0106 days 0.255 hours 0.00152 weeks 3.49299e-4 months , the Unit 2 Emergency Diesel Generator, 2K-4A will trip due to low lube oil pressure. Strainer gasket has failed, allowing a loss of lube oil pressure.

EAL Criteria Met (Plant should already be in an Alert due to Security Event)

IC SAL - AC power capability to Vital 4.16 KV busses reduced to a single power source >

15 minutes such that any additional single power source failure would result in station blackout. (AAC is the single source).

Alternate AC Generator Low Pressure Alarm Approximately 5 minutes after starting the Alternate AC Generator, (-A921 hours), the Alternate AC Generator Low Starting Air Pressure alarm is received. If starting air pressure drops too low the fuel racks will close, stopping the diesel generator. This malfunction is to ensure urgency on repairs to DG #1 and DG#2.

Unidentified Individual In PA By this time all plant personnel should have been evacuated from the protected area except for operations and security personnel.

At 0950 hours0.011 days 0.264 hours 0.00157 weeks 3.61475e-4 months , SOCA Monitoring Center (SMC) sees an individual, acting suspicious; enter the train bay from behind the Unit 2 main transformer yard, carrying a backpack.

51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One Gun Fire in Turbine Buildine (SAE criteria met)

At 1015 hours0.0117 days 0.282 hours 0.00168 weeks 3.862075e-4 months , a security officer is dispatched to ascertain the identity of the individual. When the Security Officer orders the individual to "HALT", he is fired upon. The security officer returns fire, killing the individual. When the flap of the backpack is lifted, it is discovered that a third [ED is contained within.

EAL Criteria Met IC HS 1 - Hostile Action within the Protected Area EAL 1 A'Hostile Action is occurringoor has occurred within. the Protected Area as reported by ANO Security Shift Supervision Site Area Emergency Declared At approximately 1015 hours0.0117 days 0.282 hours 0.00168 weeks 3.862075e-4 months , the Emergency Director should declare a SAE emergency class based'upon the following IC:

IC HSI - Hostile Action within the Protected Area EAL 1 - A Hostile Action is occurring or has occurred within the Protected Area

.as reported by ANO Security Shift Supervision The Shift Manager or Emergency Director, whoever has ED&C, will enter. Procedure 1203.048, Security Event, to notify members of the Emergency Response Organization (ERO) and initiate offsite notifications for the SITE AREA EMERGENCY. State and local authorities will be notified of the Site Area Emergency and that there are no protective actions recommended for the members of the general public. " *,

' 1 GSB Adversaries Captured By approximately 1030 hours0.0119 days 0.286 hours 0.0017 weeks 3.91915e-4 months GSB and Switchyard Adversaries should be captured.in accordance with the plan developed by the ICP.

FBI assumes responsibility for bomb At -1030 the FBI will assume responsibility for the unexploded IED and disposition of the remains of the hostiles/adversaries. The ICP should develop a plan to address the IED.

The FBI should notify the ICP of restrictions related to post-attack environment and coordination of on-site activities.

52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One Post Attack Environment At approximately 1040 hours0.012 days 0.289 hours 0.00172 weeks 3.9572e-4 months , the ICP should have knowledge that all known adversaries have been neutralized or captured, the ICP should prepare to deal with the plant fire (switchyard) and medical conditions (GSB).

FBI should begin preparations to make the site a crime scene Fire Support Dispatched to Site Approximately 1115 hours0.0129 days 0.31 hours 0.00184 weeks 4.242575e-4 months , the London Fire Department, with support from other supporting fire departments, will be dispatched on-site to address the auto-transformer fire. The extent of play for this activity will consist of developing plans, simulating issuance of appropriate dosimetry and radiological equipment, and briefing teams. Once complete, the remainder of the fire support will be simulated.

Medical Support Dispatched to Site Approximately 1115 hours0.0129 days 0.31 hours 0.00184 weeks 4.242575e-4 months , Pope County Emergency Medical Services will be dispatched to the site and GSB to address the injured. The extent of play for this activity will consist of developing plans, simulating issuance of appropriate dosimetry and radiological equipment, and briefing teams. Once complete, the remainder of the EMS support will be simulated.

OSC Team Dispatched Approximately 1115 hours0.0129 days 0.31 hours 0.00184 weeks 4.242575e-4 months , once the site is in the post attack environment, or if teams are escorted by Local Law Enforcement personnel, the OSC will dispatch Repair and Corrective Action Teams to repair plant equipment.

Drill Terminated At -1230 hours, once electrical power is restored to Unit 2, the Lead Drill Controller will terminate the drill.

53

Unclassified Radiological EmergencyPreparedness Program (REP)

After Action Report/Improvement Plan Arkansas Nuclear One This page is intentionally blank.

54

ML15027A424

Text

Dear Mr. Dapas:

SUMMARY

SUMMARY

REFERENCE:

REFERENCE:

SUMMARY

SUMMARY

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