Text

Final After Action Report/Improvement Plan for the Clinton Power Station Radiological Emergency Preparedness Exercise Held on November 1, 2017
	ML18037A708
Person / Time
Site:	Clinton
Issue date:	01/16/2018
From:	; Federal Emergency Management Agency
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML18037A708 (69)
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After Action Report/

Irnprovernent Plan Exercis_e Date - November 1, 2017 Radiological Emergency Preparedness (REP) Program Clinton Power Station Published January 16, 2018

Unclassified Radiological Emergency Preparedness (REP) Program After Action ReporUimprovement Plan Clinton Power Station This page is intentionally blank.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station After Action Report/Improvement Plan Published January 16, 2018 Table of Contents EXECUTIVE

SUMMARY

..........................*......... *................................. :................................... 4 SECTION 1: INTRODUCTION ........................................ ;..................................................... 5 1.1 Exercise Basis ................................................................................................................... 5 1.2 Emergency Planning Zone Description .......... ;................................................................... 7

1. 3 Exercise Purpose and Design .................................. :............ :............................................. 7 1.4 Exercise Objectives, Capabilities, and Activities ................................................................ 8 1.5 Scenario Summary ...................................... :..................._**********************:****************************8 SECTION 2: EXERCISE OVERVIEW ................................................................................... 9 2.1 Exercise Details ..... *............................................................................................................ 9 2.2 Exercise Planning Team Leadership ............................ :..................................................... 9 2.3 Participating Organizations ....................................... :...................................................... 11 SECTION 3: ANALYSIS OF CAPABILITIES ......................................................*........... '. ... 12 3.1 Exercise Evaluation and Results ............................ :......................................................... 12 3.2 Summary Results of Exercise Evaluation ......................................................................... 12 3.3 Criteria Evaluation Summaries ........................................................................................ 19 3.3.1 State Jurisdictions ............................... :............................................................. ,....... 19 3.3.2 Risk Jurisdiction .................................................................................... :................... 19 3.3.3 Support Jurisdictions ......................... ;................................................. :.......... :.......... 19 SECTION 4: CONCLUSION ................................................................................................. 20 APPENDIX A: IMPROVEMENT PLAN .............................................................................. 21 APPENDIX B: EXERCISE TIMELINE ................................................................. '. ............. 22 APPENDIX C: EXERCISE EVALUATION TEAM ....................................... ;.................... 23 APPENDIX D: ACRONYMS AND ABBREVIATIONS ...................................................... 25 APPENDIX E: EXTENT-OF-PLAY .................................................................................. :.. 28 APPENDIX F: SCENARIO TIMELINES ............................... :............................................ 57 3

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station EXECUTIVE

SUMMARY

On November 1, 2017, Radiological Emergency Preparedness (REP) Partial-Participation Plume Exposure Pathway Exercise was evaluated by the U.S. Department of Homeland Security/Federal Emergency Management Agency (DHS/FEMA) for the 10-mile Emergency Planning Zone around the Clinton Power Station. The purpose of this exercise was to assess the capabilities of the State and local preparedness in responding to a radiological emergency. This exercise was held in accordance with DHS/FEMA's policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERPs) and procedures.

The previous exercise at this site was conducted on November 18, 2015. The qualifying emergency preparedness exercise was conducted on January 13, 1987..

The DHS/FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise. DeWitt, McLean, Macon, and Piatt Counties participated along with the State of Illinois Emergency Management Agency.

Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities.

Cooperation and teamwork on the part of all the participants wer~ .evident during this exercise.

This Final After Action Report/Improvement Plan contains the evaluation of the biennial exercise and the evaluation of the following out-of-sequence interviews and activities:

Illinois State Police District 6 Headquarters Dosimetry Control Officer Briefing and Traffic and Access Control Post Interview;

Medical Services Drill Transportation and Hospital evaluation at St. Mary's Hospital;

Protective Actions for Schools (EV-2) for Clinton School District #15; and

Clinton Police Department Dosimetry Control Officer Briefing and Traffic and Access Control Post interview. .

Sections 3 and 4 of this report provide detailed information regarding any Level 1 or Level 2 Findings, Plan Issues, and Schedule of Corrective Actions.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station SECTION 1: INTRODUCTION 1.1 Exercise Basis On December 7, 1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. The DHS/FEMA activities are conducted pursuant to Title 44 of the Code of Federal Regulations (CFR) Parts 350 "Review and Approval of State and Local Radiological Emergency Plans and Preparedness," 351 "Radiological Emergency Planning and Preparedness" and 352 "Commercial Nuclear Power Plants: Emergency Preparedness Planning." These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

FEMA Regulation 44 CFR 350 establishes the policies and procedures for the DHS/FEMA initial and continued approval of State and local governments' radiological emergency planning and preparedness for commercial nuclear power plants. This approval is contingent, in part, on State and local governments' participation in joint exercises with licensee.

The DHS/FEMA responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

Taking the lead in offsite emergency planning and in the review and evaluation of Radiological Emergency Response Plan and procedures developed by State and local governments;

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

Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated October 1, 2015, and* *

Coordinating the activities of Federal agencies with responsibilities in the radiological emergency planning process:

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

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Representatives from these agencies serve on the DHS/FEMA Region V Regional Assistance Committee (RAC), which is chaired by the DHS/FEMA.

Formal submission of the Radiological Emergency Response Plans (RERP) for Clinton Power Station to FEMA Region V by the state of Illinois and involved local jurisdictions occurred on November 25, 1986. Formal approval of these RERP was granted by FEMA on August 5, 1987, under 44 CPR 350.

A REP Partial-Participation Plume Exposure Pathway'Exercise was conducted on November 1, 2017, and evaluated by the DHS/FEMA to assess the capabilities of State and local offsite emergency preparedness organizations in implementing their RERP and procedures to protect the public health and safety during a radiological emergency involving the Clinton Power Station. The purpose of this After Action Review/Improvement Plan (AAR/IP) is to present the exercise results and findings based on the performance of the offsite response organizations during a simulated radiological emergency.

The findings presented in this Final AAR/IP are based on the evaluations of the federal evaluation team, with final determinations made by the DHS/FEMA Region V RAC Chair, and approved by the DHS/FEMA Headquarters.

The criteria utilized in the FEMA evaluation process are contained in:

NUREG-0654/FEMA-REP-1, R~v. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980;

FEMA Radiological Emergency Preparedness: Exercise Evaluation Methodology, as published in the FEMA Radiological Emergency Preparedness Manual, dated January 2016.

Section 2 of this report, entitled Exercise Overview, presents exercise details, exercise planning team leadership, and participation organizations.

Section 3 of this report, entitled Analysis of Capabilities, contains the exercise evaluation and results, summary results of the exercise evaluation, and criteria evaluation summaries.

Section 4 of this report, entitled Conclusion, presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all Level 1, Level 2, and Plan Issues if any, assessed during this exercise, recommended corrective actions, and the State and local governments' schedule of corrective actions, if applicable, for each identified exercise issue; and (2) descriptions of unresolved Level 2 assessed during previous exercises and the status of the offsite response organization (ORO) efforts to resolve them.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action ReporUlmprovement Plan Clinton Power Station 1.2 Emergency Planning Zone Description The Clinton Power Station (CPS) is located approximately seven miles northeast of the City of Clinton in Harp Township, within DeWitt County, Illinois. DeWitt County is located near the geographical center of the State of Illinois. The topography of the area is predominantly rolling prairies.

The Emergency Planning Zone (EPZ) for the CPS is an area approximately the area of a ten-mile radius with the CPS as the center point. The EPZ extends approximately ten miles outward in all directions from the CPS for the plume exposure pathway planning zone and fifty miles outward for the ingestion exposure pathway planning zone. In the event of a serious accident at the CPS, the plume exposure EPZ will be the area in which intensive efforts will be made to notify and protect residents and transient population from exposure to radiation. The 10-mile EPZ contains a total population of 12,702 (2010 census) within the risk county of DeWitt, and the support counties of Macon, McLean, and Piatt. Nearly two-thirds of the total 10-mile EPZ population (8,422) resides in the communities of Clinton, Weldon, Wapella, and DeWitt. The land use within the 10-mile EPZ is predominantly agricultural, with cash grain crops of corn and soybeans. The closest industries are located in the community of Clinton.

Recreational facilities outside the municipalities include the Clinton Lake State Recreation Area and the Weldon Springs State Park. The park encompasses approximately 370 acres and contains a 28-acre lake with camping, fishing, and picnicking facilities. Weldon Springs is one of the two sizable lakes within 10 miles of the site. Clinton Lake is a 4,895 acre man-made cooling lake within the CPS property lines. Recreational facilities accommodate camping, boating, hunting, fishing, and hiking.

The nearest major highways are State Highways 54, 10, and 48, all of which intersect the plant location. Other major thoroughfares are U.S. Highway 51, located about six miles west of the plant and Interstate Highway 74, and located about 11 miles northeast of the plant. The nearest railroad is the Canadian National Railway (CN), which crosses the site east to west and comes within about three-fourths of a mile to the north of the reactor centerline. Another CN track is located approximately three and a half miles south of the CPS.

1.3 Exercise Purpose and Design The DHS/FEMA Region V Office evaluated the Clinton Station REP Partial-Participation Plume Exposure Pathway Exercise on November 1, 2017 to assess the capabilities of local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the Clinton Station. The purpose of this report is to present the results and findings on the performance of the ORO during a simulated radiological emergency.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station 1.4 Exercise Objectives, Capabilities, and Activities Exercise objectives and identified capabilities/REP criteria selected to be demonstrated are discussed in Appendix E "Extent-of-Play." The Exercise Planning Team (EPT) selected objectives that focus on evaluating emergency response procedures, identifying areas for improvement, and fostering collaboration between the various OROs and stakeholders. This exercise focused on the following objectives:

ORO demonstration of effective Emergency Operations Management;

ORO demonstration of effective Protective Action Decision Making;

ORO demonstration of effective Protective Action Implementation;

ORO demonstration of effoctive Emergency Notification and Public Information; and

ORO demonstration of effective Support Operations and Facilities.

1.5 Scenario Summary Appendix F, Scenario Timelines, contains a summary of the exercise scenario, and a simulated sequence of events that was used as the basis for invoking emergency response actions by OROs during the Clinton Power Station REP Partial-Participation Plume Exposure Pathway Exercise on November 1, 2017.

Results of a technical review of the scenario, submitted on August 31, 2017, indicate that the scenario was adequate to support demonstration of the DHS/FEMA requirements, as well as criteria selected by the ORO provided in the State's June 22, 2017; August 3, 2017; and September 1, 2017, extent-of-play submissions.

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

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station SECTION 2: EXERCISE OVERVIEW 2.1 Exercise Details Exercise Name Clinton Power Station 2017 Partial-Participation Radiation Emergency Preparedness Exercise Type of Exercise Plume Exposure Pathway Exercise Date November 1, 2017 Program DHS/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 2.2 Exercise Planning Team Leadership Sean O'Leary Chair, Regional Assistance Committee Chief, Technological Hazards Branch DHS/FEMA Region V 536 South Clark Street Chicago, Illinois 60605 312-408-5389 sean.oleary@fema.dhs.gov Stephen E. Tulley Exercise Director DHS/FEMA Region V 536 South Clark Street Chicago, Illinois 60605 312-408-4425 stephen. tulley@fema.dhs.gov 9

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Dwaine K. Warren Deputy Exercise Director DHS/FEMA Region V 536 South Clark Street Chicago, Illinois 60605 312-408-5342 dwaine. warren@fema.dhs.gov David Ortman Site Specialist DHS/FEMA Region V 536 South Clark Street Chicago, Illinois 60605 312-408-4429 david.ortman@fema.dhs.gov William Conway REP Program Manager Bureau of Nuclear Facility Safety Illinois Emergency Management Agency 2200 South Dirksen Parkway Springfield, Illinois 62703 217-785-9886 william.conway~ illinois. gov Jerry DeYoung Offsite Programs Exelon Corporation 4300 Winfield Road Warrenville, Illinois 60555 630-657-4666 gerald.deyourig@Exeloncorp.com Mike Muth Offsite Programs Exelon Corporation 4300 Winfield Road Warrenville, Illinois 60555 630-657-4674 mike.muth@Exeloncorp.com Randy Mika Corporate Drill and Exercise Coordinator Exelon Corporation 10

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station 4300 Winfield Road Warrenville, Illinois 60555 630-657-4662 randy.mika@Exeloncorp.com 2.3 Participating Organizations Agencies and organizations of the follow1ng jurisdictions participated in the exercise:

State Jurisdictions Illinois Emergency Management Agency Illinois State Police District #6 Mutual Aid Box Alarm System (MABAS)

Risk Jurisdictions DeWitt County Board Chairman DeWitt County Emergency Management Agency DeWitt County Sheriffs Department Support Jurisdictions Clinton School District #15 Clinton Police Department McLean County Board Chairman McLean County Emergency Management Agency McLean County Sheriffs Department Macon County Board Chairman Macon County Emergency Management Agency Macon County Sheriffs Department Piatt County Board Chairman Piatt County Emergency Management Agency Piatt County Sheriffs Department Private Organizations American Red Cross Exelon Nuclear Saint Mary's Hospital Radio Station WBNQ/WBWN/WJBC Federal Jurisdictions Federal Emergency Management Agency United States Nuclear Regulatory Commission 11

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the November 1, 2017, Clinton Power Station (CPS)

Radiological Emergency Preparedness (REP) Partial-Participation Plume Exposure Pathway Exercise. The exercise was conducted to test the offsite emergency response capabilities of State and local governments in the 10-mile Emergency Planning Zone surrounding the CPS.

Each jurisdiction and functional entity was evaluated based on its demonstration of exercise criteria delineated in the FEMA REP Program Manual, dated January 2016. Appendix E, Extent-of-Play, contains detailed information on the selected exercise criteria and the extent-of-play agreements used for this exercise. Presented below are definitions of the terms used in this report relative to the criteria demonstration status.

M - Met: The status of a REP exercise evaluation area criterion indicating that the participating OROs demonstrated all demonstration criteria for the evaluation area criterion to the level required in the extent-of-play agreement with no Level 1 Findings, Level 2 Findings or Plan Issues assessed in the current exercise and no unresolved prior Level 2 Findings.

1 - Level 1 Finding: 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.

2 - Level 2 Finding - An observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.

P - Plan Issue - An observed or identified inadequacy in the offsite response organization (ORO's) emergency plan or implementing procedures, rather than in the ORO's performance.

N -Not Demonstrated-Exercise criteria that were not demonstrated as scheduled during this exercise and the reason(s) they were not demonstrated.

3.2 Summary Results of Exercise Evaluation Tables 3.1-3.3, Summary of Exercise Evaluation, on the following pages, presents the status of all exercise criteria from the FEMA REP Program Manual, dated January 2016, which were 12

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. '

This subsection provides information on the evaluation of each participating jurisdiction and functional entity in a jurisdiction-based, issues-only format.

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

The identifying number of Level 1 Findings, Level 2 Findings, and .Plan Issues includes the following elements, with each element separated by a hyphen (-).

Plant Site Identifier - A two-digit number, corresponding to the Utility Billable Plant Site Code (13* for CPS).

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

Criterion Number - An alpha and two-digit number corresponding to the criteria numbers in the six Exercise Evaluation Areas described in the FEMA REP Program Manual, dated January 2016.

Issue Classification Identifier- (1 =Level 1 Finding, 2 = Level 2 Finding, P =Plan Issue)

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

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/hnprovement Plan Clinton Power Station Table 3.1 - Summary of Exercise Evaluation - State of Illinois DATE: November 1, 2017 0 0 c

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Table 3.2 - Summary of Exercise Evaluation - DeWitt County DATE: November 1, 2017 u 0

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EW Exposure Control Implementation 3a1 M M M KI Public/Institutionalized 3bl PAD Implementation Disabled/Functional Needs 3cl PAD Implementation Schools 3c2 TACP Establishment 3dl M M Impediments 3d2 M Implement Ingestion PADs 3e1 Ingestion Pathway Decisions 3e2 Implementation of RRR Decisions 3fl ..

Field Measur.ement and Analysis ' . 1, RESERVED 4al Field Team Management 4a2 Field Team Operations 4a3 Field Team Sampling 4bl Laboratory Operations 4cl Emergeric;y,Notification anc;l Eublic InfQ * .* . ....; *c,_1-:

Initial Alert & Notification Sal RESERVED 5a2 Backup Alert & Notification 5a3 Exception Area Alerting 5a4 Subsequent Information & Instructions 5bl Support Ope,:i;ations and Facili4es ' .* . .>, . .

Reception Center Operations 6al EW Monitoring & Decontamination 6bl Congregate Care 6c1 Contaminated Injured 6dl 16

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Table 3.4 - Summary of Exercise Evaluation - McLean County DATE: November 1, 2017 SITE: Clinton Power Station M:Met L1 : Level 1 Finding L2: Level 2 Finding P: Plan Issue

Mobilization lal M M Facilities 1hl Direction and Control lcl M Communications Equipment ldl M M M Equipment and Supplies to Support Operations 1el M M M EW Exposure Control Decisions 2al PARs 2h1 PADs 2b2 PADs for Disabled/Functional Needs 2cl Ingestion P ADs 2d1 RRR Decisions 2el EW Exposure Control Implementation 3a1 M M M KI Public/Institutionalized 3bl PAD Implementation Disabled/Functional Needs 3cl PAD Implementation Schools 3c2 TACP Establishment 3dl M M Impediments 3d2 M Implement Ingestion PADs 3e1 Ingestion Pathway Decisions 3e2 Implementation of RRR Decisions 3fl RESERVED 4al Field Team Management 4a2 Field Team Operations 4a3 Field Team Sampling 4bl Laboratory Operations 4cl Initial Alert & Notification 5al RESERVED 5a2 Backup Alert & Notification 5a3 Exception Area Alerting 5a4 Subsequent Information & Instructions 5bl Reception Center Operations 6al EW Monitoring & Decontamination 6bl Congregate Care 6c 1 Contaminated Injured 6dl 17

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station 3.3 Criteria Evaluation Summaries 3.3.1 State of Illinois In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

a. LEVEL 1 FINDINGS: NONE

b. LEVEL 2 FINDINGS: NONE

c. PLAN ISSUES: NONE

d. PRIOR ISSUES - RESOLVED: NONE

e. PRIOR ISSUES - UNRESOLVED: NONE 3.3.2 DeWitt County In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. LEVEL 1 FINDINGS: NONE

b. LEVEL 2 FINDINGS: NONE

c. PLAN ISSUES: NONE

d. PRIOR ISSUES - RESOLVED: NONE

e. PRIOR ISSUES - UNRESOLVED: NONE 3.3.3 Macon, McLean, and Piatt Counties In summary, the status of DHS/FEMA criteria for the Support jurisdictions is as follows:

a. LEVEL 1 FINDINGS: NONE

b. LEVEL 2 FINDINGS: 13-17-3al-L2-01 (Piatt County)

c. PLAN ISSUES: NONE

d. PRIOR ISSUES - RESOLVED: NONE

e. PRIOR ISSUES - UNRESOLVED: NONE 19

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station SECTION 4: CONCLUSION There were no Level 1 or Level 2 findings or plan issues identified for the state oflllinois or DeWitt, McLean, and Macon Counties.

There were no Level 1 or plan issues identified for Piatt County. There was one Level 2 finding with the Piatt County Traffic and Access Control Post Dosimetry Briefing regarding Assessment Area 3, Protective Action Implementation. The specific criterion was successfully redemonstrated on November 1, 2017. Further details may be found in Appendix A, Improvement Plan.

There were no plan issues identified for the state of Illinois or DeWitt, McLean, Macon, and Piatt Counties.

Based on the results of the exercise, the planning and preparedness for the state of Illinois and affected local jurisdictions provide reasonable assurance that appropriate measures can be taken to protect public health and safety. Therefore, Title 44 CPR Part 350, approval of the offsite radiological emergency response plans and preparedness for the state of Illinois, remains in effect.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/hnprovement Plan Clinton Power Station APPENDIX A: IMPROVEMENT PLAN This section summarizes the findings from the of the evaluation of all jurisdictions and functional entities that participated in the November 1, 2017, Radiological Emergency Preparedness Partial-Participation Plume Exposure Pathway Exercise to test the offsite emergency response capabilities of State and local governments in the 10-mile Emergency Planning Zone surrounding the Clinton Power Station, recommended corrective actions, and a schedule of corrective actions for the identified primary responsible agency.

Finding: 13-17-3al-L2-1 Piatt County-.EOC Criterion: 3.a.1 ISSUE:

During the Emergency Worker Exposure Control briefing the DCO used the Radiation Exposure Record card to brief a Sheriffs deputy assigned to a Traffic and Access Control Post (TACP). Section "Direct Read Dosimeter (DRD), Item Number 9 was not fully covered, "If the DRD reading(s) total 1 R or more turn around, contact your DCO immediately" this was covered clearly, the last section of this sentence "and go to a location designated by the DCO."

was not briefed to the Deputy. In addition, not covered in the DCO's briefing was item Number 11 "Return the DRD and Radiation Exposure Record card to your DCO when

instructed. Also, under the section "Potassium Iodide (KI) - Voluntary" item Number 2 "Take only upon the recommendations of IEMA." "Your DCO will inform you of the recommendation." was not briefed out.

RECOMMENDATION:

Dosimetry Control.Officer should maintain training and familiarity with Dosimetry Guidelines to insure complete and thorough briefings for emergency workers.

CORRECTIVE ACTION DESCRIPTION:

Redemonstration was successfully conducted on November 1, 2017.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Responder Safety and Health Piatt County Emergency Management Agency CAPABILITY ELEMENT: START DATE:

Emergency Operations Center November 1, 2017 AGENCYPOC: COMPLETION DATE:

Jim Donaldson 217-762-9482 November 1, 2017 21 L______ '

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station APPENDIX B: EXERCISE TIMELINE All times are Central Daylight Time.

Emergency", , ,,

,; Time

(::lassificatiQn Utility DeWitt Macon McLean Piatt REAC Lev~l Qr Jj;ye:µf ,l!~cll;lred County County County County Unusual Event (end of verification call for ECLs)

NIA NIA NIA NIA NIA NIA Alert 0820 0835 0859 0902 0907 0908 Site Area Emergency 1000 1009 1029 1035 1037 1038 General Emergency 1108 1118 1137 1140 1142 1145 Release of Radioactive Material Started 1108 1108 NIA NIA NIA NIA Release of Radioactive Material Terminated NIA NIA NIA NIA NIA NIA Facility Declared Operational 0918 0932 1012 0940 0935 Declaration of State/Local Emergency NIA NIA NIA NIA NIA Exercise Termination 1211 1253 1243 1312 1246 Early Precautionary Action Decision: <The State issued an order to evacuate state parks.>

1140 NIA NIA NIA NIA Early Precautionary Action Decision: <The State issued a Livestock Advisory: All livestock are to be sheltered and placed on stored feed and water 1025 1135 NIA NIA 1101 within the 10-mile EPZ. >

Early Precautionary Action Decision: <The state issued water restrictions within 5/10 miles of CPS.>

1140 NIA NIA 1202 NIA Early Precautionary Action Decision: <Evacuate Schools and/or Special Populations.>

NIA NIA NIA NIA NIA General Information Message:

Siren Activation: NIA NIA NIA NIA NIA EAS Message: NIA NIA NIA NIA NIA Protective Action Recommendation Evacuation of Sub-Areas: 1 1124 1137 NIA NIA NIA Protective Action Decision: 1 NIA 1141 1144 1142 1145 Siren Activation: NIA 1150 1150 1150 1150 EAS Message: NIA 1155 1155 1155 1155 Protective Action Recommendation Evacuation of Sub-Areas:

NIA NIA NIA NIA NIA Protective Action Decision: NIA NIA NIA NIA NIA Siren Activation: NIA NIA NIA NIA NIA EAS Message: NIA NIA NIA NIA NIA KI Administration Emergency Workers and Immobile Populations Decision NIA NIA NIA NIA NIA (SEOC/REAC)/lmplementation (UACICounties) 22

I

' Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station APPENDIX C: EXERCISE EVALUATION TEAM DATE: November 1, 2017 SITE: Clinton Power Station

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State of Illinois - Initial Warning Point Curtis Williams FEMA Region V State of Illinois - BOC Carol Shepard ICF State of Illinois - REAC John Wills ICFRC State of Illinois - REAC Cheryl Weaver ICF State of Illinois - JIC Kim Alahmadi FEMA Region V Illinois State Police District 6 HQ - DCO Briefing Carol Shepard ICF FEMARegion Illinois State Police District 6 HQ - T ACP Dan Kanakeres VII MS-1 Saint Mary's Hospital Brian Reinhart FEMA Region V MS-1 Saint Mary's Hospital Michael Petullo ICF DeWitt County - Initial Warning Point Jim King FEMA Region V DeWitt County - BOC Gary Bolender ICF DeWitt County - BOC Brian Reinhart FEMA Region V DeWitt County - BOC John Wiecjorek ICF DeWitt County - BOC Meg Swearingen ICF DeWitt County - State Rad Advisor David Ortman FEMA Region V DeWitt County - IEMA Liaison David Ortman FEMA Region V DeWitt County:_ DCO Brief Meg Swearingen ICF DeWitt County - T ACP Meg Swearingen ICF DeWitt County - T ACP - DCO Brief Jim King FEMA Region V Radio Station WBNQ/WBWN/WJBC Michael Petullo ICF Clinton Police Department - DCO Briefing Curtis Williams FEMA Region V Clinton Police Department - T ACP David Ortman FEMA Region V EV-2 School Interview - Clinton School District 15 Kim Alahmadi FEMA Region V Piatt County - Initial Warning Point Thomas Gahan ICF Piatt County - BOC Kevin Reed ICF Piatt County - BOC Todd Lawson FEMA Region V Piatt County - IEMA Liaison Clint Crackel FEMA Region V Piatt County - DCO Brief Kevin Reed ICF Piatt County - TACP Thomas Gahan ICF McLean County - Initial Warning Point Marcy Campbell ICF McLean County - BOC Al Blake FEMA Region V McLean County - BOC David Kayen ICF McLean County - IEMA Liaison Todd Gemskie FEMA Region V 23 L

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/hnprovement Plan Clinton Power Station

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McLean County - DCO Brief Al Blake FEMA Region V McLean County - T ACP Marcy Campbell ICF FEMARegion Macon County - Initial Warning Point Dan Kanakeres VII Macon County - BOC Robert Lemeshka ICF Macon County - BOC Paul Ringheiser ICF Macon County - IEMA Liaison David Persaud FEMA Region V Macon County - DCO Brief Robert Lemeshka ICF Macon County - T ACP Michael Meshenberg ICF

24

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station APPENDIX D: ACRONYMS AND ABBREVIATIONS ACRONYM < ,,,

DESCIUPTION c

AAR After Action Report ALS Advanced Life Support ARC American Red Cross cc Contamination Control CCC Congregate Care Center ccs Contamination Control Supervisor CEDE Combined Effective Dose Equivalent CEO County Elected Official CERT Community Emergency Response Team CIT Critical Incident Team CPD Clinton Police Department CPIO County Public Information Officer CPS Clinton Power Station CST Civil Support Team DAS Decatur Ambulance Service DCL Dosimetry Control Log DCO Dosimetry Control Officer DRD Direct Reading Dosimeter BAS Emergency Alert System ECL Emergency Classification Level ED Emergency Department EMA Emergency Management Agency EMAC Emergency Management Agency Coordinator EMC Emergency Management Coordinator EMD Emergency Management Director EMS Emergency Medical Service EMT Emergency Medical Technician BOC Emergency Operation Center EOF Emergency Operations Facility EPZ Emergency Planning Zone ERT Emergency Response Telecommunicator EW Emergency Worker FEMA Federal Emergency Management Agency GE General Emergency GIS Geographical Information System GM Geiger- Mueller 25

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station ACRONYM DESCRIPTION HP Health Physics IAP Incident Action Plan IC Incident Commander ICS Incident Command System IEMA Illinois Emergency Management Agency

!LEAS Illinois Law Enforcement Alarm System IP Improvement Plan ISP Illinois State Police IWIN Illinois Wireless Information Network IWP Initial Warning Point JIC Joint Information Center LD Luminescent Dosimeter LEADS Law Enforcement Agency Data System LEC Law Enforcement Center LSC Liquid Scintillation Counter MRT Medical Radiation Technician NARS Nuclear Accident Reporting System NIMS National Incident Management System NRC Nuclear Regulatory Commission ORO Offsite Response Organizations OSL Optically Stimulated Luminescence PAD Protective Action Decision PAR Protective Action Recommendations PC Piatt County PDP Personal Dosimetry Packet PIO Public Information Officer PPE Personal Protective Equipment PRD Permanent Record Dosimeter PSAP Public Safety Answering Point RA Radiological Advisor RAC Regional Assistance Committee RAFf Radiological Assessment Field Team RC Reception Center RCS Reactor Coolant System RCW Registration Case Worker RD Radio Dispatch RDO Radiological Duty Officer REA Radiation Emergency Area REAC Radiological Emergency Assistance Center REP Radiological Emergency Preparedness 26

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station i~~;{?:'tI~lt~NY-:M:\:* /, 1*~ t~;J:'.;,~;{,;:~fcrf>,;,. /;ii!}::,;. :;:/Q,ESQR):f~!JQJS': i;.;tt!:t :.***! ;rr;t .~::.f .....<.

RFf Radiological Field Team RRC Radiological Response Chief RSM Registration Station Manager RT Radiation Technologist RTF Radiological Task Force SAE Site Area Emergency SAM Staging Area Manager SEOC State Emergency Operations Center SIRC State Incident Response Center SOP Standard Operating Procedure TEDE Total Effective Dose Equivalent UAC Unified Area Command UE Unusual Event URI Unified RASCAL Interface 27

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station APPENDIX E: EXTENT-OF-PLAY This appendix lists the exercise criteria which were scheduled for demonstration in the Clinton Power Station Radiological Emergency Preparedness Partial-Participation Plume Exposure Pathway Exercise on November 1, 2017, and the offsite Extent-of-Play agreement accepted by DHS/FEMA Region Von September 29, 2017. The exercise criteria, contained in the FEMA Radiological Emergency Preparedness (REP) Program Manual (January 2016), represent a functional translation of the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Revl, "Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980. Because the exercise criteria are intended for use at all nuclear power plant sites, and because of variations among offsite plans and procedures, an Extent-of-Play agreement is prepared by the State and accepted by DHS/FEMA to provide Evaluators with guidance on expected actual demonstration of the criteria.

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

28

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station STATE OF ILLINOIS EXTENT-OF~PLAY AGREEMENT FOR THE CLINTON STATION EXERCISE November 1, 2017 Criteria that can be re-demonstrated immediately for credit, at the discretion of the evaluator, include the following: 3.a.1, 3.b.1, 3.d.1, 6.a.l, 6.b.l, 6.c.l and 6.d.l. Criteria that may be re-demonstrated, as approved on a case-by-'case basis by the Chair of the Regional Assistance Committee, include the following: 2.a.l, 2.b.l, 2.b.2, 3.d.2, 5.a.l and 5.b.l.

NOTE: If the exercise scenario, or related exercise play, does not prompt specific criteria-related actions, individual criteria may be addressed through a functional interview or alternative scenario-driven task demonstration. When utilized, this process will be done in a manner not fo disrupt or interfere with normal exercise play.

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

The State Emergency Operations Center (SEOC), including the IEMA Communications Center (Initial Warning Point), will be partially activated to support county-level exercise play and for training purposes only. The Radiological Emergency Assessment Center (REAC) will be fully activated and will continue to be evaluated as previously. Rosters will be provided to demonstrate 24-hour staffing *of REAC. The roster will be available for review; however, it will not be removed from the facility. The State Unified Area Command (UAC) will not be activated. The Radiological Response Group (RRG) will participate for training purposes only but they will not be evaluated, however, they request a FEMA observer for a critique of their training.

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

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

This criterion will not be demonstrated during this exercise.

Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

29

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station The ability to direct and control emergency response activities will be demonstrated at the SEOC, REAC, RRG, and the IlC for State & county-level exercise play and training purposes but will not be evaluated. Coordination will be demonstrated between the SEOC, UAC, the REAC, RRG, the IlC, the EOF and the county EOCs for State & county-level exercise play and for training purposes but will not be evaluated. REAC will demonstrate the ability to direct & control emergency response activities and coordination with SEOC, RRG, the nc and county EOCs.

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.

This criterion has been successfully demonstrated at the SEOC, REAC, UAC, IlC and RRG in the last two years, and as such, will not be evaluated during this exercise.

This criterion will be demonstrated during the out-of-sequence ISP DCO briefingff AC interview on Tuesday, October 31 at 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months (tentative), at the Illinois State Police District 6 Headquarters in Pontiac.

Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (Kl) and other supplies are sufficient to support emergency operations.

This criterion has been success.fully demonstrated in the last two years, and as such, will not be evaluated during this exercise.

Dosimetry Control Officer (DCO) logs will be available in each County EOC to support county-level exercise play and evaluation.

A DCO .briefingffraffic and Access Control (TAC) interview will be conducted by the Illinois State Police on Tuesday, October 31 at 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months , (tentativ~) at the ISP District 6 Headquarters in Pontiac. During this event, the availability of dosimetry will be demonstrated.

EVALUATION AREA 2 - PROTECTIVE ACTION DECISION MAKING Criterion 2.a.1: OROs use a decision-making process, consid.ering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of Kl, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

This criterion has been successfully demonstrated in the last two years, and as such, will not be evaluated during this exercise.

Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and.licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

30

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station The REAC will evaluate the licensee information and complete independent dose projections based on that information and simulated field monitoring data. REAC will make an evaluation of the data and make a protective action recommendation to the SEOC.

SEOC will participate to the level to support REAC and county-level exercise play but will not be evaluated.

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).

The coordination to determine protective action recommendations (PARs) based upon available shelters, evacuation time estimates and other relevant factors will be demonstrated between the SEOC and REAC. The State PAR will be transmitted to the DeWitt County BOC via N ARS.

SEOC will participate to the level needed to support REAC and county-level exercise play but will not be evaluated.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of people with disabilities and those with access/functional needs.

The ability to make the decision to recommend the use of KI to institutionalized persons will be demonstrated in REAC. SEOC will participate to the level needed to support REAC and county-level exercise play but will not be evaluated.

Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO's planning criteria.

This criterion was successfully demonstrated in 2013, it will not be demonstrated during this exercise.

Criterion 2.e.1: Timely post-plume phase re-location, re-entry and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the OROs plan and/or procedures.

This criterion was successfully demonstrated in 2013, it will not be demonstrated during this exercise.

EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plan and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency work~rs is maintained.

31

Unclassified Radiological Emergency Preparedness (REP) Program After Action ReporUimprovement Plan Clinton Power Station This will be demonstrated during the out-of-sequence ISP DCO briefing/TAC interview on Tuesday, October 31 at 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months (tentative), at the Illinois State Police District 6 Headquarters in'Pontiac.

Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals is maintained.

This criterion will not be evaluated for the state of Illinois during this exercise.

Criterion 3.c.1: Protective action decisions are implemented for people with disabilities and those with access/functional needs other than schools within areas subject to protective actions.

This criterion does not apply to the state of Illinois.

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

This criterion does not apply to the state of Illinois.

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

This will be demonstrated during the out-of-sequence ISP DCO briefing/TAC interview on Tuesday, October 31 at 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months (tentative), at the Illinois State Police District 6 Headquarters in Pontiac.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.

This criterion will not be demonstrated during this exercise.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions.

This criterion will not be demonstrated during this exercise.

Criterion 3.e.2: Appropriate measures, strategies and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk and agricultural production.

This criterion will not be demonstrated during this exercise.

Criterion 3.f.1: Decisions regarding controlled re-entry, relocation, and return of individuals during the post-plume phase are coordinated with appropriate organizations and implemented.

This criterion will not be demonstrated during this exercise.

32

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station EVALUATION AREA 4 - FIELD MEASUREMENT AND ANALYSIS Criterion 4.a.1: [RESERVED]

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.

RRG may elect to demonstrate this criterion for training purposes only, but they will not be evaluated. A FEMA observer is requested to critique RRG training.

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.

RRG may elect to demonstrate this criterion for training purposes only, but they will not be evaluated. A FEMA observer is requested to critique RRG training.

Criterion 4.b.l: The field teams demonstrate the capability to make appropriate measurements and to collect samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making.

RRG may elect to demonstrate this criterion for training purposes only, but they will not be evaluated. A FEMA observer is requested to critique RRG training.

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions.

RRG may elect to demonstrate this criterion for training purposes only, *but they will not be evaluated. A FEMA observer is requested to critique RRG training.

EVALUATION AREA 5 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by ~uthorized 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.

The State's role in demonstrating this criterion is limited to transmitting the State's protective action recommendation (PAR) -to the counties and monitoring the instructional messages provided to the public by the counties. This monitoring will be accomplisµed by IEMA representatives in the DeWitt County BOC, however the state will not be evaluated for this criterion.

Criterion 5.a.2: [RESERVED]

33

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station 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.

This criterion does not apply to the State of Illinois.

Criterion 5.a.4: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

This criterion does not apply to the State of Illinois.

Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.

The nc will be activated in Warrenville and Springfield for training purposes and to the level necessary to support state, county and utility-level exercise play, however the state

~Wr&~t ~~ evaluated for this criterion. ~ ,ffiM~{§lis,e'i:~~t;;N~~i~HH~~fa,4:~l~c!g~ifici~~IIlQ EVALUATIONAREA 6 - SUPPORT OPERATION/FACILITIES Criterion 6.a.1: The reception center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees.

All reception center facilities have been evaluated within the last 8 years. This criterion will not be evaluated during this exercise.

Criterion 6.b.1: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles.

This criterion will not be evaluated during this exercise.

Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines.

Managers demonstrate the procedures to assure that evacuees have .been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities.

This criterion will not be evaluated during this exercise.

Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

This criterion will be demonstrated during an out of sequence drill conducted at St. Mary's Hospital in Decatur on.Tuesday, October 31 at 0900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months , (Tentative).

34

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station DEWITT COUNTY EXTENT-OF-PLAY AGREEMENT FOR THE CLINTON STATION EXERCISE November 1, 2017 Criteria that can be re-demonstrated immediately for credit, at the discretion of the evaluator, include the following: 3.a.l, 3.b.l, 3.d.l, 6.a.l, 6.b.l, 6.c.l and 6.d.l. Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chair of the Regional Assistance Committee, include the following: 2.a.l, 2.b.l, 2.b.2, 3.d.2, 5.a.l and 5.b.l.

NOTE: If the exercise scenario, or related exercise play, does not prompt specific criteria-related actions, individual criteria may be addressed through a functional interview or alternative scenario-driven task demonstration. When utilized, this process will be done in a manner not to disrupt or interfere with normal exercise play. .

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

DeWitt County will fully activate the Emergency Operations Center (EOC) in Clinton, Illinois. The County will implement notification procedures as defmed in IPRA-Clinton.

Representatives from the EPZ municipalities, IEMA and Exelon will staff the County EOC but will not be pre-positioned in the EOC. A roster will be provided to demonstrate a 24-hour staffing of the EOC.

Evaluators will not be allowed to remove the roster from the EOC.

An evaluator will be positioned at the County Sheriffs Communications Center (initial warning point) at the start of the exercise Criterion 1.b.1: Facilities are sufficient to support the emergency response.

This criterion will not be demonstrated during this exercise.

Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

Decision making will be demonstrated at the DeWitt County EOC. Coordination of decisions and emergency activities will be demonstrated between DeWitt County, the 35

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station

SEOC, and the JIC, . and between the County and municipalities within the EPZ.

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

Criterion l.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.

DeWitt County will utilize multiple communication systems to communicate with departments and agencies at other locations. Possible systems include commercial telephone, cell phone, radio, electronic mail, internet-based systems (such as WebEOC) and/or telefax.

This criterion will also be demonstrated at the out-of-sequence activities on Monday, October 30th, including the traffic and access control demonstration at the Clinton Police Department at (Time TBD), and at the Clinton School Distric;t #15 school interview at (Time TBD);

Criterion 1.e.1: Equipment, maps, displays, dosimetr'y, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

DeWitt County will demonstrate the ability to support operations through the use _of maps, status boards and other displays as appropriate. DCO logs will be available from the IEMA Radiological Advisor in the DeWitt County BOC. The availability of dosimetry and KI will be demonstrated during the traffic and access control demonstration and the school interview.

The DCO briefing for the DeWitt County deputy demonstrating traffic and access control will be conducted at the DeWitt County BOC during the exercise. The DCO briefing for the Clinton Polite officer demonstrating traffic and access control will be conducted on Monday, October 30, at TBD (tentative) at the Clinton Police Department.

The DeWitt County DCO will conduct a.dosimetry briefing for the DeWitt County BOC staff. Dosimetry kits will be distributed in the BOC to all participants; however, the physical wearing of dosimetry will be simulated to avoid misplacing actual equipment.

After the briefing, two participants will be evaluated on the use of dosimetry.

EVALUATION AREA 2 - PROTECTIVE ACTION DECISION MAKING Criterion 2.a.1: 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.

This criterion does not apply to DeWitt County.

36

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

This criterion does not apply to DeWitt County.

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).

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

Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of people with disabilities and those with access/functional needs.

The State of Illinois will make protective action recommendations to DeWitt County officials in the County BOC. The DeWitt County officials will make the final decision regarding what protective actions will be recommended for groups of people with disabilities and those with access/functional needs.

Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO's planning criteria.

This criterion does not apply to DeWitt County.

Criterion 2.e.1: Timely post-plume phase re-location, re-entry and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the OROs plan and/or procedures.

This criterion will not be demonstrated during this exercise.

EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plan and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

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

37

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station This criterion will also be demonstrated during the sheriffs & Clinton PD traffic and access control demonstrations and the school interview (EV-2). The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the DeWitt County EOC. The DCO briefing for the Clinton Police officer demonstrating traffic and access control will be conducted at the Clinton Police Department on Monday, October 30, at TBD (tentative)

The DeWitt County DCO will conduct a dosimetry briefing for the_ DeWitt County EOC staff. Dosimetry kits will be distributed in the EOC to all participants; however, the physical wearing of dosimetry will be simulated to avoid misplacing actual equipment.

After the briefing, two participants will be evaluated on the use of dosimetry.

Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals is maintained.

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

The State of Illinois will make an announcement through the JIC of the appropriate time for the public to consider voluntarily taking KI. However, the JIC will not be evaluated during this exercise.

Criterion 3.c.1: Protective action decisions .are implemented for people with disabilities and those with access/functional needs other than schools within areas subject to protective actions.

This will be demonstrated by DeWitt County through the simulated implementation of the appropriate procedures. The appropriate officials will coordinate transportation and receiving facilities for people with disabilities and those with access/functional needs other than schools within areas subject to protective actions'. One of each type of special facility will be contacted during the exercise. One of each type of transportation provider (ambulance/bus) will be contacted during the exercise. The public will not be involved in the demonstration.

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

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

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

A School interview (EV-2) will be conducted with the Clinton School District #15 on Monday, October 30 at TBD (tentative). At the interview, the District Superintendent, a 38

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Principal, a Teacher, the transportation coordinator (DCO), bus driver and the maintenance supervisor will be present, as well as a representative from the Regional Office of Education.

Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.

Coordination between DeWitt County agencies designated to provide traffic and access control will be exhibited in the County BOC. A Sheriffs deputy will be available during the exercise to simulate the staffing of one post. The post for the demonstration will be selected by DeWitt County during the exercise based on exercise play. The deputy will not be asked to drive to the selected post location for the demonstration; the selected post will be simulated. The staffing of the remaining posts will be simulated.

A T AC/DCO Demonstration will take place at the Clinton Police Department on October 30 at 11 :00 am (tentative). An officer will not be asked to drive to a selected post, however may be described during the formal interview.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.

The DeWitt County BOC staff will demonstrate the capability to identify and take appropriate actions concerning impediments to evacuation. A message will be injected by the Controller that will drive this demonstration. County personnel will address the impediment by identifying the equipment needed, discussing its estimated time of arrival, etc. Actual contacts with resource providers will be made and logged. The impediment information will also be coordinated into public messaging (i.e., via media briefing, notifying the JIC, etc.) to communicate alternative routes to potential evacuees.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions.

This criterion does not apply to DeWitt County.

Criterion 3.e.2: Appr<Jpriate measures, strategies and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk and agricultural production.

This criterion does not apply to DeWitt County.

Criterion 3.f.1: Decisions regarding controlled re-entry, relocation, and return of individuals during the post-plume phase are coordinated with appropriate organizations and implemented.

This criterion will not be demonstrated during this exercise.

EVALUATION AREA 4 - FIELD MJEASUREMENT AND ANALYSIS 39

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station This evaluation area does not apply to DeWitt County.

EVALUATION AREA 5 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Criterion 5.a.1: 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.

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

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

The ability to provide instructions to the public will be demonstrated through the simulated activation of the local radio station. The local radio station (WBNQ/WBWN/WJBC) will be contacted during the first, and possibly the second, alert and notification sequence. An evaluator and a controller will be positioned at the radio station during the exercise to monitor the initial alert and notification sequence message. An evaluator and controller will be positioned at the radio station during the exercise to monitor for a message containing a PAR.

The IEMA Controller will terminate the demonstration if the demonstration interferes with the radio station's daily operations.

Criterion 5.a.2: [RESERVED]

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.

This criterion will not be demonstrated in this exercise.

Criterion 5.a.4: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

This criterion does not apply to DeWitt County.

Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.

40

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station DeWitt County will demonstrate this criterion by using pre-scripted messages as indicated in IPRA-Clinton. Contact with the radio station will be simulated for each alert and notification sequence following the sequence issuing the initial PAR.

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

The ability to deal with rumors will be demonstrated by DeWitt County through coordination between the County BOC and the ITC. The DeWitt County BOC controller will inject exercise messages that will ensure the opportunity to demonstrate this criterion.

.county officials will investigate and address rumors. If appropriate, the rumors will be

coordinated between State and County officials in the County BOC and the ITC. Rumors identified will be shared with the ITC.

County emergency broadcast messages and news releases, if issued, will be provided to the ITC.

EVALUATION AREA 6 - SUPPORT OPERATION/FACILITIES This evaluation area does not applyto DeWitt County.

41

Unclassified Radiological Emergency Preparedness (REP) Program

. After Action Report/Improvement Plan Clinton Power Station MCLEAN COUNTY EXTENT-OF-PLAY AGREEMENT FOR THE CLINTON STATION EXERCISE

November 1, 2017 Criteria that can be re-demonstrated immediately for credit, at the discretion of the evaluator, include the following: 3.a.l, 3.b.l, 3.d.l, 6.a.1, 6.b.l, 6.c.l and 6.d.l. Criteria that inay be re-demonstrated, as approved* on a case-by-case basis by the Chair of the Regional Assistance Committee, include the following: 2.a.l, 2.b.1, 2.b.2, 3.d.2, 5.a.l and 5.b.l.

NOTE: If the exercise scenario, or related exercise play, does not prompt specific criteria-related actions, individual criteria may be addressed through a functional interview or alternative scenario-driven task demonstration. When utilized, this process will be done in a manner not to disrupt or interfere with normal exercise play.

EVALUATION AREA 1 - EMERGENCY OPERATIONS MANAGEMENT Criterion 1.a.1: OROs use effective procedures to alert, notify and mobilize emergency personnel .

and activate facilities in a timely manner.

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

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

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

This criterion will not be demonstrated during this exercise.

Criterion 1.c.1: Key personnel with leadership roles for t_he ORO provide direction and control to that part of the overall response effort for which they are responsible.

Coordination of decisions and emergency activities will b~ demonstrated between McLean County and DeWitt County.

42

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Criterion l.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.

McLean County win utilize multiple communication systems to communicate with departments and agencies at other locations. Possible systems include commercial telephone, cell phone, radio, electronic mail, internet-based systems (such as WebEOC) and/or telefax.

This criterion will also be evaluated during the TAC/DCO demonstration by the McLean County Sheriffs Department at the county EOC during the exercise.

Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

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

EVALUATION AREA 2 - PROTECTIVE ACTION DECISION MAKING Criterion 2.a.1: 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.

This criterion does not apply to McLean County.

Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

This criterion does not apply to McLean County.

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).

'* This criterion does not apply to McLean County. This function is the responsibility of DeWitt County.

43

Unclassified Radiological Emergency Preparedness (REP) Program After Action ReporUimprovement Plan Clinton Power Station Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of people with disabilities and those with access/functional needs.

This criterion does not apply to McLean County. This function is the responsibility of DeWitt County.

Criterion 2.d.1: Radiological coµsequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO's planning criteria.

This criterion does not apply to McLean County.

Criterion 2.e.1: Timely post-plume phase re-location, re-entry and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the OROs plan and/or procedures.

This criterion will not be demonstrated during this exercise.

EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers. in accordance with the plan and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

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

This criterion will also be demonstrated during the traffic and access control demonstration.

The Sheriffs deputy will obtain dosimetry from the DCO in the County EOC. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the CountyEOC.

Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals is maintained.

DeWitt County, as the primary county is responsible for coordination of KI to immobile populations. The State of Illinois will make an announcement through the JIC of the appropriate time for the public to consider voluntarily taking KI. However, the JIC will not be evaluated during this exercise. McLean County is not responsible for either function.

44

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Criterion 3.c.1: Protective action decisions are implemented for people with disabilities and those with access/functional needs other than schools within areas subject to protective actions.

This criterion does not apply to McLean County. This function is the responsibility of DeWitt County.

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

This criterion does not apply to McLean County.

Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.

Coordination between McLean County and DeWitt County will be demonstrated. The Sheriff's Deputy will be available to staff one post. The post for the demonstration will be selected by McLean County during the exercise based on exercise play if the scenario causes McLean County to staff posts. If it does not, the post will be selected by the controller.

The deputy will not be asked to drive to the selected post location for the demonstration; however, this may be discussed during the interview. The staffing of the remaining posts will be simulated.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.

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

Actual contacts with resource providers will be made and logged. The impediment information will also be coordinated into public messaging (i.e., via media briefing, notifying the JIC, etc.) to communicate alternative routes to potential evacuees. If the exercise scenario does not drive this criterion to be demonstrated, the exercise controller will inject a message to facilitate McLean County's demonstration or discussion.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions.

This criterion does not apply to McLean County.

Criterion 3.e.2: Appropriate measures, strategies and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk and agricultural production.

45

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station This criterion does not apply to Mclean County.

Criterion 3.f.1: Decisions regarding controlled re-entry, relocation, and return of individuals during the post-plume phase are coordinated with appropriate organizations and implemented.

This criterion does not apply to McLean County. This function is the responsibility of DeWitt County.

EVALUATION AREA 4- FIELD MEASUREMENT AND ANALYSIS This evaluation area does not apply to McLean County.

EVALUATION AREA 5 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Criterion 5.a.1: 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.

This criterion does not apply. to McLean County. This function is the responsibility of DeWitt County.

Criterion 5.a.2: [RESERVED]

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.

This criterion does not apply to McLean County.

Criterion 5.a.4: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

This criterion does not apply to McLean County.

Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.

This criterion does not apply to McLean County. This function is the responsibility of DeyVitt County.

EVALUATION AREA 6 - SUPPORT OPERATION/FACILITIES This evaluation area does not apply to DeWitt County.

46

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station MACON COUNTY EXTENT-OF-PLAY AGREEMENT FOR THE CLINTON STATION EXERCISE November 1, 2017 Criteria that can be re-demonstrated immediately for credit, at the discretion of the evaluator, include the following: 3.a.1, 3.b.l, 3.d.l, 6.a.l, 6.b.l, 6.c.l and 6.d.l. Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chair of the Regional Assistance Committee, include the following: 2.a.l, 2.b.1, 2.b.2, 3.d.2, 5.a.l and 5.b.l. ,

NOTE: If the exercise scenario, or related exercise play, does not prompt specific criteria-related actions, individual criteria may be addressed through a functional interview or alternative scenario-driven task demonstration. When utilized, this process will be done in a manner not to disrupt or interfere with normal exercise play.

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

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

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

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

This criterion will be evaluated demonstrated during this exercise.

Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

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

47

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station 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.

Macon County will utilize multiple communication systems to communicate with departments and agencies at other locations. Possible systems include commercial telephone, cell phone, radio, electronic mail, internet-based systems (such as WebEOC) and/or telefax.

This criterion will also be evaluated during the TAC/DCO demonstration by the Macon County Sheriffs Department at the county EOC during the exercise.

Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

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

EVALUATION AREA 2 - PROTECTIVE ACTION DECISION MAKING Criterion 2.a.1: 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.

This criterion does not apply to Macon County.

Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

This criterion does not apply to Macon County.

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).

This criterion does not apply to Macon County. This function is the responsibility of DeWitt County.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of people with disabilities and those with access/functional needs.

48

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station This criterion does not apply to Macon County. This function is the responsibility of DeWitt County.

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

This criterion does not apply to Macon County.

Criterion 2.e.1: Timely post-plume phase re-location, re-entry and return decisions are ma~e and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the OROs plan and/or procedures.

This criterion will not be demonstrated during this exercise.

EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plan and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

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

This criterion will also be demonstrated during the traffic and access control demonstration.

The Sheriffs deputy will obtain dosimetry from the DCO in the County BOC. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the County BOC.

Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals is maintained.

DeWitt County, as the primary county is responsible for coordination of KI to immobile populations. The State of Illinois will make an announcement through the JIC of the appropriate time for the public to consider voluntarily taking KI. However, the JIC will not be evaluated during this exercise. Macon County is not responsible for either function.

Criterion 3.c.1: Protective action decisions are implemented for people with disabilities and those with access/functional needs other than schools within areas subject to protective actions.

This criterion does not apply to Macon County. This function is the responsibility of DeWitt County.

49

Unclassified Radiologi,cal Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Criterion 3.c~2: OR.Os/School officials decide upon and implement protective actions for schools.

This criterion does not apply to Macon County.

Criterion 3.d.1: Appropriate traffic and acc~ss control is established.. Accurate instruc.tions are provided to traffic and access control personnel.

Coordination between Macon County and DeWitt County will be demonstrated. The Sheriffs Deputy will be available to staff one post. The post for the demonstration will be selected by Macon County during the exercise based on exercise play if the scenario causes Macon County to staff posts. If it does not, the post will be selected by the.

controller.

The deputy will not be asked to drive to the selected post location for the demonstration; however, this may be discussed during the interview. The staffing of the remaining posts will be simulated.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.

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

Actual contacts with resource providers will be made and logged. The impediment information will also be coordinated into public messaging (i.e., via media briefing, notifying the JIC, etc.) to communicate alternative routes to potential evacuees. If the exercise scenario does not drive this criterion to be demonstrated, the exercise controller will inject a message to facilitate Macon County's demonstration or discussion.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions .

. This criterion does not apply to Macon County.

Criterion 3.e.2: Appropriate measures, strategies and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk and agricultural production.

This criterion does not apply to Macon County.

Criterion 3.f.1: Decisions regarding controlled re-entry, relocation, and return of individuals during the .post-plume phase are coordinated with appropriate organizations and implemented.

50

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station This criterion does not apply to Macon County. This function is the responsibility of DeWitt County.

EVALUATION AREA 4 - FIELD MEASUREMENT AND ANALYSIS This evaluation area does not apply to Macon County.

EVALUATION AREA 5 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Criterion 5.a.1: 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.

This criterion does not apply to Macon County. This function is the responsibility of DeWitt County.

Criterion 5.a.2: [RESERVED]

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.

This criterion does not apply to Macon County.

Criterion 5.a.4: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

This criterion does not apply to Macon County.

Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.

This criterion does not apply to Macon County. This function is the responsibility of DeWitt County.

EVALUATION AREA 6 - SUPPORT OPERATION/FACILITIES This evaluation area does not apply to DeWitt County.

51

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report&nprovement Plan Clinton Power Station PIATT COUNTY EXTENT-OF-PLAY AGREEMENT FOR THE CLINTON STATION EXERCISE November 1, 2017 Criteria that can be re-demonstrated immediately for credit, at the discretion of the evaluator, include the following: 3.a.l, 3.b.l, 3.d.l, 6.a.l, 6.b.l, 6.c.l and 6.d.l. Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chair of the Regional Assistance Committee, include the following: 2.a.l, 2.b.l, 2.b.2, 3.d.2, 5.a.l and 5.b.1.

NOTE: If the exercise scenario, or related exercise play, does not prompt specific criteria-related actions, individual criteria may be addressed through a functional interview or alternative scenario-driven task demonstration. When utilized, this process will be done in a manner not to disrupt or interfere with normal exercise play.

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

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

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

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

This criterion will not be demonstrated during this exercise.

Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

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

52

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Criterion 1.d.l: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations.

Piatt County will utilize multiple communication systems to communicate with departments and agencies at other locations. Possible systems include commercial telephone, cell phone, radio, electronic mail, internet-based systems (such as WebEOC) and/or telefax.

This criterion will also be evaluated during the TAC/DCO demonstration by the Piatt County Sheriffs Department at the county BOC during the exercise.

Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

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

EVALUATION AREA 2 - PROTECTIVE ACTION DECISION MAKING Criterion 2.a.1: 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.

This criterion does not apply to Piatt County.

Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

This criterion does not apply to Piatt County.

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).

This criterion does not apply to Piatt County. This function is the responsibility of DeWitt County.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of people with disabilities and those with access/functional needs.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station This criterion does not apply to Piatt County. This function is the responsibility of DeWitt County.

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

This criterion does not apply to Piatt County.

Criterion 2.e.1: Timely post-plume phase re-location, re-entry and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the OROs plan and/or procedures.

This criterion will not be demonstrated during this exercise.

EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plan and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administ~ation of KI for emergency workers is maintained.

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

This criterion will also be demonstrated during the traffic and access control demonstration.

The Sheriffs deputy will obtain dosimetry from the DCO in the County EOC. The DCO briefing for the deputy demonstrating traffic and access control will be conducted at the CountyEOC.

Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of KI is made. Appropriate record keeping of the administration. of KI for institutionalized individuals is maintained.

DeWitt County, as the primary county is responsible for coordination of KI to immobile populations. The State of Illinois will make an announcement through the nc of the appropriate time for the public to consider voluntarily taking KI. However, the nc will not be evaluated during this exercise. Piatt County is not responsible for either function.

Criterion 3.c.1: Protective action decisions are implemented for people with disabilities and those with access/functional needs other than schools within areas subject to protective actions.

This criterion does not apply to Piatt County. This function is the responsibility of DeWitt County.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Criterion 3.c.2: OROs/School officials decide upon and implement protective actions for schools.

This criterion does not apply to Piatt County.

Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.

Coordination between Piatt County and DeWitt County will be demonstrated. The Sheriffs Deputy will be available to staff one post. The post for the demonstration will be selected by Piatt County during the exercise based on exercise play if the scenario causes Piatt County to staff posts. If it does not, the post will be selected by the controller.

The deputy will not be asked to drive to the selected post location for the demonstration; however, this may be discussed during the interview. The staffing of the remaining posts will be simulated.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.

The Piatt County BOC staff will demonstrate the capability to identify and take appropriate actions concerning impediments to evacuation. A message will be injected by the Controller that will drive this demonstration. County personnel will deal with the impediment by identifying the equipment needed, discussing its estimated time of arrival, etc. Actual contacts with resource providers will be made and logged. The impediment information will also be coordinated into public messaging (i.e., via media briefing, notifying the ITC, etc.) to communicate alternative routes to potential evacuees. If the exercise scenario does not drive this criterion to be demonstrated, the exercise controller will inject a message to facilitate Piatt County's demonstration or discussion.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions.

This criterion does not apply to Piatt County.

Criterion 3.e.2: Appropriate measures, strategies and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk and agricultural production.

This criterion does not apply to Piatt County.

Criterion 3.f.1: Decisions regarding controlled re-entry, relocation, and return of individuals during the post-plume phase are coordinated with appropriate organizations and implemented.

This criterion does not apply to Piatt County. This function is the responsibility of DeWitt County.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station EVALUATION AREA 4 - FIELD MEASUREMENT ANDANALYSIS This evaluation area does not apply to Piatt County.

EVALUATION AREA 5 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Criterion 5.a.1: 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.

This criterion does not apply to Piatt County. This function is the responsibility of DeWitt County.

Criterion 5.a.2: [RESERVED]

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.

. This criterion does not apply to Piatt County.

Criterion 5.a.4: Activities associat~d with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

This criterion does not apply to Piatt County.

Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.

This criterion does not apply to Piatt County. This function is the responsibility of DeWitt County.

EVALUATION AREA 6 - SUPPORT OPERATION/FACILITIES This evaluation area does not apply to DeWitt County.

56

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station APPENDIX F: SCENARIO TIMELINES This Appendix presents the Off-Site Scenario Timelines for the State of Illinois and the Counties of DeWitt, McLean, Macon, and Piatt that drove the Clinton Power Station Radiological Emergency Preparedness, Partial Participation Plume Exposure Pathway Exercise conducted on November 1, 2017. The timelines include both on-site events and comments and expected off-

I site response actions.

57

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station OFFSITE EXERCISE TIMELINE Approx. Time Event/Anticipated Response 0800 CDT Initial conditions/weather forecast message to players.

0810CDT An ALERT is declared at C Station.

Exelon notifies the IEMA Telecommunicator of the ALERT via NARS.

IEMA Telecommunicator verifies the NARS message.

An IEMA Duty Officer contacts the Clinton Station Shift Engineer.

IEMA Telecommunicator notifies IEMA personnel of the ALERT per SOP.

IEMA may activate the State Emergency Operations Center (SEOC) and Radiological Emergency Assessment Center (REAC), if appropriate.

0825 CDT IEMA may dispatch liaisons to the County EOCs, Unified Area Command (UAC), Radiological Response Group (RRG), Joint Information Center (JIC),

Technical Support Center (TSC) and Emergency Operations Facility (EOF),

if appropriate.

IEMA notifies Governor's Office of the ALERT. (Simulated)

IEMA Telecommunicator notifies appropriate State agencies of the ALERT.

IEMA notifies FEMA of the ALERT. (Simulated)

IEMA Telecommunicator notifies DeWitt County of the ALERT via NARS.

DeWitt County Telecommunicator completes and verifies the NARS message.

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

0840CDT Support county anq municipal telecommunicators complete and verify the NARS message.

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

Counties may activate the BOC, if appropriate.

0955 CDT A SITE AREA EMERGENCY is declared at Clinton Station.

Exelon notifies the IEMA Telecommunicator of the SITE AREA 1010CDT EMERGENCY via NARS.

58

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station IEMA Telecommunicator verifies the NARS message.

REAC contacts the Clinton Station Shift Engineer.

SEOC is activated if not previously activated.

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

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

SEOC notifies FEMA of conditions.

IEMA notifies State agencies (Simulated):

Illinois State Police

!DOT/Division of Highways

!DOT/Division of Aeronautics IDNR Illinois National Guard ICC American Red Cross IDPH IEPA IDOC IDHS IDOA Office of the State Fire Marshal Others as appropriate REAC contacts Federal agencies. (Simulated)

REAC provides an update to the SEOC and county BOC Liaisons.

REAC provides an update to the JIC.

59

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station IEMA notifies DeWitt County of the SITE AREA EMERGENCY via NARS.

DeWitt County Telecommunicator completes and verifies the NARS message.

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

DeWitt County implements public notification procedures, if appropriate.

(Simulated) 1025 CDT Support county and municipal telecommunicators complete and verify the NARS message.

Support county and municipal telecommunicators notify officials per SOP.

County EOCs are activated if not previously activated.

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

1101 CDT A GENERAL EMERGENCY is declared at Clinton Station.

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

IEMA Telecommunicator verifies the NARS message.

SEOC and REAC evaluate the protective action recommendation.

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

1116 CDT SEOC staff is advised of the situation.

SEOC advises UAC, the county EOC liaisons and JIC staff of the situation.

SEOC notifies FEMA of conditions. (Simulated)

REAC provides an update to the SEOC and county EOC lifiisons.

REAC provides an update to the JIC.

SEOC notifies DeWitt County of the GENERAL EMERGENCY and the 1131 CDT recommended protective actions via NARS.

60

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station DeWitt County Telecommunicator completes and verifies the NARS message.

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

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

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

Support county and municipal telecommunicators notify EOC staff.

1230 CDT Terminate exercise play.

61

Unclassified Radiological Emergency Preparedness (REP) Program After Action ReporUimprovement Plan Clinton Power Station Onsite Exercise Timeline Scenario Timeline Exercise vs. Clock Time Narrative Summary Summary of Expected EALs and PARs Meteorology Release Information INITIAL CONDITIONS Weather Conditions Partly cloudy skies, 190° and winds out of the south System Load The Ameren/CornEd transmission system is normal, no MISO* issued alerts or warnings.

MISO - Midwest Independent Transmission System Operator Unit Status

1090 MWe -97% Power

On Line 298 days

OLR-GREEN Major Evolutions: DIV 2 EDG Surveillances in progress (Online Risk Level YELLOW during prestarts) DIV 1 EDG Protected 62

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station This page is intentionally blank.

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Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station NARRATIVE

SUMMARY

Initial Conditions - 0800-0809 CDT The Operating Crew will be briefed at 0715 and is expected to take the shift by 0800. They will be expected to continue operations at full power. [Initial Wind Direction from 190°]

ALERT - MAS 0810-0954 CDT Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.

Division 2 Emergency Diesel Generator Explodes during performa1;1ce testing (No Fire).

The occurrence of ANY of the following hazardous events: EXPLOSION AND EITHER of the following: a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.

NLO in area for DG surveillance run reports explosion (CM-2) along with associated alarms in MCR [T=O for the Alert]

No Security event (CM-3: No tampering or cyber-attack)

(0810) Loss of DC DIV 2 bus - causes loss/trip of 'B' Reactor Recirculation pump

Power reduction to -60% Reactor power Expected Actions

1. Shift ED will declare MAS and activate ERO staffing via Everbridge

2. Fire Brigade is dispatched to DIV 2 EDG - No Fire

3. CM-4 issued directing the use ofEverbridge

4. PA announcements for ALERT and ERO activation

5. Ops Crew will make NA.RS and ENS notifications

6. Command and Control will be performed Equipment Malfunctions - 0918 CDT Trip of B CRD pump.

Expected Actions Ops crew will investigate failure.

SITE AREA EMERGENCY - MS2 0955-1100 CDT (0949) DC Division 1 Ground Annunciator comes in and clears after 10 seconds and then comes back in solid.

64

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station (0955) - DC Division 1 Bus deenergizes - Loss of all Vital DC power - Loss of all Vital DC power for 15 minutes [T=O for starting 15-minute clock for SAE] SED may declare <15 min

Reactor SCRAM - Automatic Scram is successful (No ATWS)

RCS Leak/LOCA due to 'A' Reactor Recirculation Pump seal failure

Spurious CLOSURE of MSIVs

Drywell Radiation and Containment Radiation increasing Expected Actions

1. TSC should declare MS2.

2. Initiate (Actual) Assembly and Accountability.

3. Complete all State, Local, and NRC notifications.

4. Site Evacuation Simulated.

CONCURRENT ALERT- -1015 CDT (1015) LOSS of RCS - RC3 (1. Drywell pressure >l.68 psig AND 2. Drywell pressure rise is due to RCS leakage).

Expected Actions ERO will identify the Loss of RCS barrier.

CONCURRENT SITE AREA EMERGENCY - -1030 CDT (1030) LOSS of RCS - RC5 (>100 R/hr@ 1015) and RC3 (>l.68 psig in DW due to LOCA) and LOSS of Fuel Clad - FC5 (Drywell Radiation rises to >260 R/hr).

Expected Actions ERO will identify the Loss of the Fuel Barrier along with the Loss of RCS barrier. This results in a concurrent Site Area Emergency FS 1.

GENERAL EMERGENCY - 1101-1215 CDT GENERAL EMERGENCY (FG 1): UNPLANNED rapid drop in primary containment pressure following primary containment pressure rise.

LOSS of Containment CT.3.1 OR CT.3.2 [T=O for GE] - With previous LOSS of RCS (RC3 and RC5) AND LOSS of Fuel Clad (FC5).

CT3 .1. UNPLANNED rapid drop in primary containment pressure following primary containment pressure rise.

OR 65

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station CT3.2. Primary containment pressure response not consistent with LOCA conditions.

ERO may identify LOSS of Containment (CT6. l) UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.

Failure of Containment Penetration - Release In Progress starts - Peak Release Rate 7.8E7 µCi/sec

Control Message (CM-12) issued- audible sound heard in Aux, Fuel and Control Buildings (due to penetration leak from Containment)

VG train 'B' Trips on auto start (motor shaft shear will prevent it from performing its intended function)

Expected Actions

1. TSC will declare General Emergency FG 1

2. ERO should identify Release Path URI S - <RCS><DW><PRI CONT><SEC CONT><SGTS><STACK><ENV>

3. TSC should declare FG 1 with a Release in Progress - Plant based P ARs EV AC subarea 1 (Wind Direction from 190°)

4. PA announcements will be made by Control Room or TSC

5. EOF will make NARS and ENS notifications Exercise Termination - -1215 CDT The Clinton Exercise will terminate after concurrence from the State of Illinois has been received. All facilities will terminate exercise participation and conduct self-critiques of their performance.

66

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station '

EXPECTED EALs AND PARs EALs:

ALERT (MAS): Hazardous event affecting a SAFETY SYSTEM 0810 MAS required for the current operating mode. DIV 2 Emergency Diesel (T=lO) Generator Explodes during performance testing (No Fire)

SITE AREA EMERGENCY (MS2): Loss of all Vital DC power for 15 minutes or longer Voltage is <108 VDC on 125 VDC battery busses lA and lB for >15 minutes 0955 1030 (T=150) - CONCURRENT SITE AREA EMERGENCY (FSl):

(T=l15) Loss or Potential Loss of ANY two barriers - LOCA MS2

[Alert LOSS of RCS (RCS) - DW Radiation rises to >100 R/hr

+105]

OR (RC3) - 1. Drywell pressure > 1.68 psig AND 2. Drywell pressure rise is due to RCS leakage AND LOSS of Fuel Clad (FC5) - DW Radiation rises to >260 R/hr GENERAL EMERGENCY (FGl): Loss of any two barriers AND Loss or Potential Loss of third barrier.

LOSS of Containment Barrier on containment penetration failure and Release in Progress Initiation 1101 (T=181) (CT3) - 1. UNPLANNED rapid drop in primary containment pressure FGl following primary containment pressure rise.

[SAE+

76] OR 2. Primary containment pressure response not consistent with LOCA conditions.

OR (CT6.1) - UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal (with Previous LOSS of RCS and LOSS of Fuel Clad) 1215 Anticipated Termination 67

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station Time. .EAL#;:** . . . Description. .*

(T=255)

[GE+

74]

PARs: Wind from 190°

. 'J;'ime: :Event >*:*** *:Release 1

.* . *.. "::* *.. ::A:ffectedCdu,11ties I Sub;;A,fea:

0810 MAS-ALERT None None 0955 MS2 - SITE AREA EMERGENCY None None FGl-GENERALEMERGENCY 1101 Protective Action Recommendation Occurring DeWitt County - 1 (PARs) 1215 Anticipated Termination

METEOROLOGY Wind from 190° Wind Speed 14 mph Stability Class D Air Temperature 58°F Precipitation Raining None RELEASE INFORMATION All Dose-Based PARs are bounded by Plant-Based PARs.

URI Release Path (S) - <RCS><DW><PRI CONT><SEC CONT><SGTS><STACK><ENV> is from the RCS to the Drywell to Primary Containment to Secondary Containment to SGTS to the Stack and to the Environment.

DOSE PROJECTIONS The following peak dose projections are based on the data from the 1130 dose kernel found in Section 8:

Core Damage:

7% Clad Damage based on Containment Radiation 54 R/hr 3% Clad Damage based on Drywell Radiation of 285 R/hr PRF: 6.40E-05 when release starts Time After Shutdown: 1:35 Release Duration: 1:00 (Weekday, Day Time) 68

Unclassified Radiological Emergency Preparedness (REP) Program After Action Report/Improvement Plan Clinton Power Station S.B. 2.58E+Ol l.OOE+Ol 2 miles 4.44E+OO 9.24E-01 5 miles l.14E+OO l.47E-01 10 miles 4.02E-01 O.OOE+OO 69

ML18037A708

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SUMMARY

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