ML19169A168

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FEMA - Radiological Emergency Preparedness Final Report for the Grand Gulf Biennial Exercise Evaluated on 03/13/2019
ML19169A168
Person / Time
Site: Grand Gulf  Entergy icon.png
Issue date: 06/04/2019
From:
US Dept of Homeland Security, Federal Emergency Management Agency
To:
Office of Nuclear Reactor Regulation
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Download: ML19169A168 (44)
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After Action Report Grand Gulf Nuclear Station Radiological Emergency Preparedness Exercise Exercise Date: March 13, 2019 Published: June 4, 2019

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Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Table of Contents Page Table of Contents............................................................................................................................. 3 Executive Summary......................................................................................................................... 5 Section 1: Exercise Overview......................................................................................................... 7 1.1 Exercise Details............................................................................................................. 7 1.2 Exercise Planning Team Leadership.............................................................................. 8 1.3 Participating Organizations............................................................................................ 9 Section 2: Exercise Design Summary........................................................................................... 10 2.1 Exercise Purpose and Design....................................................................................... 10 2.2 Exercise Core Capabilities and Objectives.................................................................. 10 Section 3: Analysis of Capabilities............................................................................................... 11 3.1 Exercise Evaluation and Results.................................................................................. 11 3.2 Summary Results of Exercise Evaluation....................................................................12 3.3 Criteria Evaluation Summaries.................................................................................... 14 3.3.1 State Jurisdictions........................................................................................................ 14 3.3.1.1 Joint Information Center.................................................................................. 14 3.3.l.2 Emergency Operations Facility........................................................................ 14 3.3.1.3 LDEQ Headquarters......................................................................................... 14 3.3.1.4 LDEQ Field Monitoring Team 1..................................................................... 15 3.3.1.5 LDEQ Field Monitoring Team 2.....................................................................15 3.3.1.6 Louisiana State EOC........................................................................................ 15 3.3.2 Risk Jurisdictions......................................................................................................... 16 3.3.2.1 Tensas Parish EOC................................................................. :........................ 16 3.3.2.2 Tensas Parish School Board............................................................................. 16 3.3.3 Private Jurisdictions.............................................................................-......................... 16 3.3.3.1 KNOE Radio Station........................................................................................ 16 Section 4: Conclusion................................................................................................................... 18 Appendix A: Exercise Timeline.................................................................................................... 20 Appendix B:. Exercise Key Leaders and Evaluators..................................................................... 22 Appendix C: Acronyms................................................................................................................ 24 Appendix D: Extent of Play Agreements...................................................................................... 26 3

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Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Executive Summary On March 13, 2019, a Plume Phase Radiological Emergency Preparedness (REP) exercise was conducted in the plume exposure pathway emergency planning zone (EPZ) around the Grand Gulf Nuclear Station (GGNS) located in Port Gibson, Mississippi.

Personnel from the U.S. Department of Homeland Security/Federal Emergency Management Agency (DHS/FEMA), Region VI, evaluated the exercise. The purpose was to assess the level of preparedness of state and local responders to react to a simulated radiological emergency at GGNS. This exercise was held in accordance with DHS/FEMA policies and guidance concerning the implementation of state and local radiological emergency preparedness plans and procedures. The previous exercise at this site was conducted on March 29, 2017. The qualifying emergency preparedness exercise was conducted in November 1981. There have been 19 evaluated exercises, including the exercise on March 13, 2019, plus several drills conducted since that time.

The DHS/FEMA Region VI Office wishes to acknowledge the efforts of the many individuals in the State of Louisiana, Tensas Parish, and surrounding jurisdictions who participated in this exercise. 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 of all the participants was evident during this exercise.

This report includes the identification of any exercise findings and recommendations for corrective action, where appropriate. All state and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no issues or findings assessed as a result of this exercise.

5

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Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Section 1: Exercise Overview 1.1 Exercise Details Exercise Name 2019 GGNS Plume Evaluated Exercise R6 Type of Exercise Plume Exercise Date March 13, 2019 Locations See the extent-of-play agreement in Appendix D for exercise locations.

Program United States Department of Homeland Security, Federal Emergency Management Agency, Radiological Emergency Preparedness Program Scenario Type Rapid Escalation 7

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Radiological Emergency Preparedness Program After Action Report 1.2 Exercise Planning Team Leadership Denise Bordelon Technological Hazards Branch Chief/RAC Chair FEMA Region VI 800 N Loop 288 Denton, TX 76209 (940) 383-7387 denise.bordelon@fema.dhs.gov Nan Williams Senior Site Specialist FEMA Region VI 800 N Loop 288 Denton, TX 76209 (940) 898-5398 nan.calhoun@fema.dhs.gov Michael McMahon Environmental Scientist Louisiana Department of Environmental Quality 602 N 5th Street Baton Rouge, LA 70802 (225) 219-3630 michael.d.mcmahon@la.gov Amy Denise Perkins Senior Emergency Planner Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 (601) 437-7830 aperki l@entergy.com 8

Grand Gulf Nuclear Station

Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the exercise:

State Jurisdictions Risk Jurisdictions Louisiana Public Service Commission Louisiana State Police Louisiana Governor's Office of Homeland Security and Emergency Preparedness Louisiana Department of Environmental Quality Louisiana Department of Health Louisiana Department of Transportation and Development Louisiana Department of Wildlife and Fisheries Louisiana Depaiiment of Agriculture and Forestry Louisiana Department of Corrections Louisiana Department of Children and Family Services Tensas Parish Office of Homeland Security and Emergency Preparedness Department of Children and Family Services (DCFS)

LSU Agricultural Extension Services Tensas Parish School Board Tensas Parish Fire Depatiment Tensas Parish Sheriffs Office Tensas Parish Police Jury Tensas Parish Office of Public Health Department of Public Works Tensas Parish Maintenance Department Tensas Parish Council on Aging Private Organizations Entergy, Inc.

Grand Gulf Nuclear Station KNOE Radio Station Federal Organizations US Nuclear Regulatory Commission 9

Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Section 2: Exercise Design Summary 2.1 Exercise Purpose and Design The DHS/FEMA Region VI Radiological Emergency Preparedness staff evaluated a Plume Phase exercise on March 13, 2019 to assess the capabilities of state and local emergency preparedness organizations in implementing their Radiological Emergency Response Plans and procedures to protect the public health and safety during a radiological emergency involving GGNS. The purpose of this report is to present the results and findings on the performance of the offsite response organizations during a simulated radiological emergency.

2.2 Exercise Core Capabilities and Objectives Core capabilities-based planning allows for exercise planning teams to develop exercise objectives and observe exercise outcomes through a framework of specific action items.

Using the Homeland Security Exercise and Evaluation Program methodology, the exercise objectives meet the Radiological Emergency Preparedness Program requirements and encompass the emergency preparedness evaluation areas.

The core capabilities demonstrated during this exercise were:

Operational Coordination Operational Communications Public Information and Warning Situational Assessment Critical Transportation Environmental Response/Health and Safety Access Control and Identity Verification 2.3 Exercise Scenario The exercise scenario was developed to evaluate the response of exercise participants to an incident involving a radiological release at the site, requiring evacuation of the public from the Louisiana p01tion of the 10-mile Emergency Planning Zone surrounding the Grand Gulf Nuclear Station. The exercise scenario provided for the evaluation of Tensas Parish, Louisiana Department of Environmental Quality and the Governor's Office of Homeland Security and Emergency Preparedness to test the ability of participants to formulate and implement protective action decisions.

10

Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Section 3: Analysis of Capabilities 3.1 Exercise Evaluation and Results This section contains the results and findings of the evaluation of all jurisdictions and functional entities that participated in the March 13, 2019 GGNS Plume Evaluated Exercise.

Each jurisdiction and functional entity was evaluated based on the demonstration of core capabilities, capability targets, critical tasks, and the underlying Radiological Emergency Preparedness criteria as delineated in the Federal Emergency Management Agency Radiological Emergency Preparedness Program Manual dated January 2016. Exercise criteria are listed by number, and the demonstration status of those criteria are indicated by the use of the following terms:

Met (M): No Findings assessed and no unresolved Findings from prior exercises.

Level 1 (L 1) Finding: An observed or identified inadequacy of organizational performance in an exercise that could cause a determination 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 (NPP).

Level 2 (L2) 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.

Plan (P) Issue: An observed or identified inadequacy in the offsite response organizations' (ORO's) emergency plan/implementing procedures, rather tha:n that of the ORO's performance.

N: Not demonstrated 11

Radiological Emergency Preparedness Program After Action Report 3.2 Summary Results of Exercise Evaluation DATE: March 13, 2019 SITE: Grand Gulf Nuclear Station - LA-MS M: Met, L1: Level 1 Issue, L2: Level 2 Issue, P: Plan Issue, N:

Not Demonstrated Emergency Ooeratiims Mariagement Tensas Parish EOC LDEQ Headquarters JIC Emergency Operations Facility Louisiana State EOC Field Monitoring Team 2 Field Monitoring Team I DATE: March 13, 2019 SITE: Grand Gulf Nuclear Station - LA-MS M: Met, L 1: Level 1 Issue, L2: Level 2 Issue, P: Plan-Issue, N: Not Demonstrated Protictive Action Decision~Making *.

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Radiological Emergency Preparedness Program After Action Report DATE: March 13, 2019 SITE: Grand Gulf Nuclear Station - LA-MS M: Met, L 1: Level 1 Issue, L2:

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DATE: March 13, 2019 SITE: Grand Gulf Nuclear Station - LA-MS M: Met, L 1: Level 1 Issue, L2: Level 2 Issue, P: Plan Issue, N:

Not Demonstrated

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DATE: March 13, 2019 SITE: Grand Gulf Nuclear Station - LA-MS M: Met, Ll: Level 1 Issue, L2: Level 2 Issue, P: Plan Issue, N:

Not Demonstrated Erilergencv Notifit:atioh and Public Iriformatio~.:ft:

JIC M

Tensas Parish EOC M

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KNOE Radio Station M

13

Radiological Emergency Preparedness Program After Action Report 3.3 Criteria Evaluation Summaries 3.3.1 State Jurisdictions 3.3.1.1 Joint Information Center Grand Gulf Nuclear Station For this venue the following Radiological Emergency Preparedness.criteria were MET: I.a. I, I.d. I, l.e.1, 5.b.l.

a.

Level I Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: None

e.

Prior Level 2 Findings -Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Public Information and Warning, Operational Communication 3.3.1.2 Emergency Operations Facility For this venue the following Radiological Emergency Preparedness criteria were MET: I.a.I, l.c.1, l.d.1, l.e.1, 2.a.1, 2.b.1, 3.a.1, 4.a.2.

a.

Level 1 Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: None

e.

Prior Level 2 Findings - Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Operational Coordination, Operational Communications, Environmental Response/Health and Safety, Situational Assessment 3.3.1.3 LDEQ Headquarters For this venue the following Radiological Emergency Preparedness criteria were MET: I.a. I, l.c.1, l.d. l, I.e. I.

a.

Level 1 Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: None

e.

Prior Level 2 Findings - Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Operational Communications, Operational Coordination 14

Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station 3.3.1.4 LDEQ Field Monitoring Team 1 For this venue the following Radiological Emergency Preparedness criteria were MET: 1.d.1, 1.e. l, 3.a.1, 4.a.3.

a.

Level 1 Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: None

e.

Prior Level 2 Findings - Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Operational Communications, Environmental Response/Health and Safety, Situational Assessment 3.3.1.5 LDEQ Field Monitoring Team 2 For this venue the following Radiological Emergency Preparedness criteria were MET: 1.d. l, 1.e. l, 3.a.l, 4.a.3.

a.

Level 1 Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: None

e.

Prior Level 2 Findings - Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Operational Communications, Environmental Response/Health and Safety, Situational Assessment 3.3.1.6 Louisiana State EOC For this venue the following Radiological Emergency Preparedness criteria were MET: 1.a.1, 1.c. l, l.d.l, Le.I, 2.a.l, 2.b.l, 2.b.2.

a.

Level 1 Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: Nohe

e.

Prior Level 2 Findings - Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Operational Coordination, Operational Communication, 15

________ __J

Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station 3.3.2 Risk Jurisdictions 3.3.2.1 Tensas Parish EOC For this venue the following Radiological Emergency Preparedness criteria were MET: l.a. l, l.c. l, l.d.l, l.e.l, 2.a.l, 2.b.2, 2.c.1, 2.e.l, 3.a.l, 3.b.l, 3.d.l, 3.d.2, 3.f.l, 5.a.l, 5.a.3, 5.b.l.

a.

Level 1 Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: None

e.

Prior Level 2 Findings - Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Operational Coordination, Operational Communication, Access Control and Identity Verification 3.3.2.2 Tensas Parish School Board For this venue the following Radiological Emergency Preparedness criteria were MET: 3.c.2.

a.

Level 1 Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: None

e.

Prior Level 2 Findings - Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Operational Communications, Operational Coordination, Critical Transportation 3.3.3 Private Jurisdictions 3.3.3.1 KNOE Radio Station For this venue the following Radiological Emergency Preparedness criteria were MET: 5.a.l.

a.

Level 1 Finding: None

b.

Level 2 Finding: None

c.

Plan Issues: None

d.

Not Demonstrated: None

e.

Prior Level 2 Findings - Resolved: None

f.

Prior Level 2 Findings - Unresolved: None Core Capabilities: Public Information and Warning 16

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Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Section 4: Conclusion Based on exercise results, the offsite radiological emergency preparedness for the State of Louisiana and the affected local jurisdictions are deemed adequate to provide reasonable assurance that appropriate measures can be taken to protect the health and safety of the public in the event of a radiological emergency. Therefore, 44 CFR Part 350 approval of the offsite plans and preparedness for the State of Louisiana, site-specific to Grand Gulf Nuclear Station, will remain in effect.

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Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station This page is intentionally blank 19

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Unusual Event 0814 0824 0823 0830 0824 Alert 0848 0857 0904 0904 0848 Site Area Emen!encv 0954 1010 1011 1010 1011 General EmerJiencv 1141 1156 1143 1155 1158 Simulated Rad. Release Started 0944 1010 1011 1000 Simulated Rad. Release Terminated Facilitv Declared Ooerational 912 1020 0904 0917 Declaration of State of EmerJiencv 1020 1020 0917 Exercise Terminated 1254 1251 1320 1345 Early Precautionary Action:

1020 Schools moved to reception center I st Protective Action Decision:

1230 1230 Evac: PAS 12 Nfonitor and Prepare remainder OJ DP7 I st Siren Activation 1245 1245 I st EAS or EBS MessaJ!e 1246 1246 2nd Protective Action Decision:

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2nd Siren Activation 2nd EAS or EBS Message Kl Administration Decision:

1220 1211 1220 20

Radiological Emergency Preparedness Program After Action Repor Grand Gulf Nuclear Station This page is intentionally blank 21 I

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Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Appendix B: Exercise Evaluation Team Regional Assistance Committee (RAC) Chair: Denise Bordelon Site Specialist: NAN WILLIAMS Location / Venue..

  • Evaluation Team

. Core Caoabilities

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Tensas Parish EOC John Rice, Linda Gee, Operational Coordination, Operational LaShawn Halsev, Lisa Rink Communication LDEQ Headquarters Andrew Chancellor Operational Communication, Operational Coordination JIC Barbara Thomas, Taneeka Public Information and Warning, Operational Hollins Communication Emergency Operations Nan Williams, John Operational Communication, Operational Facility Wiecjorek Coordination, Environmental Response/Health and Safetv, Situational Assessment Louisiana State EOC Elsa Lopez, Gregory Voss Operational Coordination, Operational Communication Field Monitoring Team Michael DeBonis Operational Communication, Environmental 2

Response/Health and Safety, Situational Assessment Field Monitoring Team George Brozowski Operational Communication, Environmental 1

Response/Health and Safetv, Situational Assessment KNOE Radio Station Lisa Rink Public Information and Warning Tensas Parish School Lisa Rink Operational Coordination, Operational Board Communication, Critical Transportation 22

Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station I

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Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Appendix C: Acronyms Acronym Description AAC Accident Assessment Coordinator ANI American Nuclear Insurers AMS Aerial Measurement Surveys ORD Direct Reading Dosimeter EAS Emergency Alert System ECL Emergency Classification Level EMD Emergency Management Director EOC Emergency Operations Center EOF Emergency Operations Facility EPA United States Environmental Protection Agency EPC Emergency Preparedness Coordinator EPD Electronic Personal Dosimeter EPZ Emergency Planning Zone EW Emergency Worker FEMA Federal Emergency Management Agency FMT Field Monitoring Team FTC Field Team Coordinator GE General Emergency GGNS Grand Gulf Nuclear Station GOHSEP Governor's Office of Homeland Security HSEPD Tensas Parish Homeland Security Emergency Preparedness Director HOO Headquarters Opera,tions Officer nc Joint Information Center KI Potassium Iodide LDEQ Louisiana Department of Environmental Quality LOH Louisiana Department of Health MEMA Mississippi Emergency Management Agency mg milligrams mR milliroentgen/millirem mRem millirem MS Mississippi MSDRH Mississippi Department of Radiological Health NOUE Notification of Unusual Event NRC U.S. Nuclear Regulatory Commission NPP Nuclear Power Plant ORO Off-site Response Organizations OSL Optically Stimulated Luminescent PAD Protective Action Decision PAO Protective Action Guide PAR Protective Action Recommendation 24

Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Acronym Description PAS Protective Action Section PIO Public Information Officer R

Roentgen RAC Regional Assistance Committee RADEF Radiological Defense Officer RASCAL U.S. Nuclear Regulatory Commission's Radiological Assessment Systems for Consequence Analysis REP Radiological Emergency Preparedness REP&R LDEQ Radiological Emergency Planning & Response RO Radiological Officer RRR Relocation, Reentry, & Return SAE Site Area Emergency SEC LDEQ's Secretary's Designee SEL LDEQ Senior EOF Liaison T/ACP Traffic/ Access Control Points TEDE Total Effective Dose Equivalent TLD Thermo luminescent Dosimeter URI Uniform RASCAL Interface 25

Radiological Emergency Preparedness Program After Action Report Grand Gulf Nuclear Station Appendix D: Extent of Play Agreements Grand Gulf Nuclear Station Extent of Play 2019 Revision 1 March 1, 2019 26 j

0 1

RevO STA TE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 REVISION LOG Date Revision 12/07/201 Initial Release 8

Remove reference to FMTs beginning operational checks early under Criterion 1.a.1; Remove reference to demonstrating Criterion 2.c.1 via interview; Specify that actual TLDs will be available for inspection under Criterion 03/01/201 3.a.1; State that backup method of sending EAS messages 9

via fax rather than automatically will be demonstrated during SAV at KNOE, but not on day of exercise, when only automatic intercept method will be demonstrated; Specify River of Life Church under Criterion 6.c.1 Page 2 of 19 12/07/2018

STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EV ALU A TED EXERCISE March 13, 2019 DISCLAIMER Real life emergencies take precedence over this demonstration. In case of an emergency, demonstration will be rescheduled for a later date.

RevO Page 3 of 19 12/07/2018

STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 ASSESSMENT AREA 1: EMERGENCY OPERATIONS MANAGEMENT RevO A.

Sub-element 1.a - Mobilization Criterion 1.a.1: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654/FEMA-REP-1, A.1.a, e; A.3, 4; C.1, 4, 6; 0.4; E.1, 2; H.3, 4)

I.

Locations Louisiana State Emergency Operations Center (SEOC), Louisiana Departmentof Environmental Quality (LDEQ) Headquarters (LDEQ HQ), LDEQ Emergency Operations Facility (EOF), Joint Information Center (JIG), Tensas Parish EOG, Tensas Parish Emergency Worker Monitoring &

Decontamination Center(Tensas EWMDS), Franklin Parish Reception Center

2.

Extent of Play a

LDEQ players will be pre-staged at the Hampton Inn and Suites m Vicksburg, Mississippi or at LDEQ Headquarters.

b.

Subject to scenario and time constraints, LDEQ will begin fully mobilizing as early as NOUE and begin deploying as early as ALERT.

c.

The LDEQ Public Information Officer (PIO), LDEQ PIO Support, GOHSEP PIO, and Tensas Parish PIO may be pre-deployed or en route to the JIC at the Mississippi Emergency Management Agency (MEMA) prior to receipt of the first message.

d.

Upon completion of operational checks, LDEQ Field Teams will proceed to Tensas Parish EOC Parking lot, from which they will be deployed remotely, as if at the LDEQ Northeast Regional Office.

e.

Tensas Parish players will be pre-staged at the Tensas EWMDS, and Franklin Parish players at the Franklin Parish Reception Center, prior to the inception of the demonstrations.

3.

Level 2 Findings-None Page 4 of 19 12/07/2018 J

RevO STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 B.

Sub-element 1.b - Facilities (Note: This sub-element and associated criteria was postponed and will be documented in a separate after action report)

Criterion 1.b.1: Facilities are sufficient to support the emergency response. (NUREG- 0654/FEMA-REP-1, G.3.a; H.3; J.10.h; k.5.b)

1.

Locations Tensas Parish EWMDS Tensas Parish Fire District Station 1104 Plank Road StJoseph, LA 71366 Franklin Parish Reception Center Franklin Parish High School 1600 Glover Drive Winnsboro, LA 71295

2.

Extent of Play

3.

Level 2 Findings-None C.

Sub-element 1.c - Direction and Control Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible. (NUREG-0654/FEMA-REP-1, A.1.d; A.2.a, b; A.3; C.4, 6)

1.

Locations

2.

Louisiana SEOC, LDEQ HQ, LDEQ EOF, Tensas Parish EOG Extent of Play Offsite Response Organizations in Louisiana will not be evaluated for mobilization and response to simulated events in Mississippi other than a nuclear power plant accident, such as WIPP or PRND related events.

3.

Level 2 Findings-None Page 5 of 19 12/07/2018

RevO ST ATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 D.

Sub-element 1.d - Communications Equipment Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations.

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

1.

Locations Louisiana SEOC, LDEQ HQ, LDEQ EOF, LDEQ Field Monitoring Team 1 (FMT 1), LDEQ FMT 2, JIC, Tensas Parish EOC

2.

Extent of Play a

The LDEQ Contract Radiation Laboratory will not be evaluated in this exercise, and any communication with it will be simulated.

b.
c.

Communications to the Southern Mutual Radiation Assistance Plan (SMRAP) states, except for TX and AR, will be simulated.

Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to ensure that exercise play is not interrupted.

Correction-on-the-spot at the Tensas EOC is limited to areas outside the operations area (i.e., emergency worker briefings and issue of dosimetry in other rooms).

3.

Level 2 Findings - None E.

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

1.

Locations

2.

Louisiana SEOC, LDEQ HQ, LDEQ EOF, LDEQ FMT 1, LDEQ FMT 2, JIC, Tensas Parish EOC, Tensas Parish T!ACP, Tensas Parish EWMDS, Franklin Parish Reception Center (demonstration at these locations was postponed and will be documented in a separate report)

Extent of Play a

LDEQ FMTs will not don anti-contamination suits during the exercise.

Anti-contamination suits are available in field team kits. Proper donning and doffing techniques will be demonstrated by one member of each team either prior to deployment or following termination of the exercise. FMTs will don gloves and booties during the exercise.

Page 6 of 19 12/07/2018

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STATE OF LOUISIANA I GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019

b.

Used charcoal cartridges will be utilized instead of silver zeolite cartridges for air sampling.

c.

Survey meters, dosimetry, and KI are not applicable at the JIC or Louisiana SEOC.

d Simulated TLDs will be used in place of spare OSL or TLD badges when applicable.

e.

Only one portal monitor will be set up during the Franklin Parish Reception Center Demonstration.

f Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to ensure that exercise play is not interrupted.

Correction-on-the-spot at the Tensas Parish EOC is limited to areas outside the operations area (i.e., emergency worker briefings and issue of dosimetry in other rooms).

3.

Level 2 Findings-None II.

ASSESSMENT AREA 2: PROTECTIVE ACTION DECISION-MAKING RevO A.

Sub-element 2.a - Emergency Worker Exposure Control 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 Kl, is in place for emergency workers, including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG- 0654/FEMA-REP-1, C.6; J.10.e, f; K.3, 4)

1.

Locations Louisiana SEOC, LDEQ EOF, Tensas Parish EOG

2.

Extent of Play a

If the scenario does not warrant a discussion on the authorization to administer KI, then the criteria shall be accomplished through an interview with the evaluator.

b.

If the scenario does not warrant a discussion on emergency worker (EW) exposure exceeding administrative limits, then the criteria shall be accomplished through an interview with the evaluator.

Note: Parish decision-makers receive recommendations for Kl and EW exposure from the Louisiana SEOC.

3.

Level 2 Findings"'"' None Page 7 of 19 12/07/2018 i

RevO STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 B.

Sub-element 2.b. - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.1: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, I. 10 and Supplement 3)

I.

Locations

2.

Louisiana SEOC, LDEQ EOF Extent of Play The LDEQ EOF controller may inject simulated field monitoring data to the Dose Assessment Coordinator for the purpose of dose projection validation and verification through back calculations.

3.

Level 2 Findings - None 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 Kl, if ORO policy). (NUREG-0654/FEMA-REP-1, A.3; C.4, 6; D.4; J.9; J.10.e, f, m)

1.

Locations Louisiana SEOC, Tensas Parish EOG

2.

Extent of Play According to the State of Louisiana's policy, Kl is not considered for the general public.

3.

Level 2 Findings-None C.

Sub-element 2.c. - PAD Consideration for the Protection of Persons with Disabilities and Access/Functional Needs Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs. (NUREG-0654/FEMA-REP-1, D.4; J.9; J.10.d, e)

I.

Locations Tensas Parish EOG Page 8 of 19 12/07/2018

STA TE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019

2.

Extent of Play

3.

Level 2 Findings -None D.

Sub-element 2.e. - Radiological Assessment and Decision Making ConcerningPost-Plume Phase Relocation, Reentry, and Return Criterion 2.e.1: Timely post-plume phase relocation, reentry, and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and/or procedures. (NUREG-0654/FEMAREP-1, 1.10; J.9; K.3.a; M.1)

1.

Locations Tensas Parish EOG

2.

Extent of Play

3.

Out of Sequence -

This demonstration will occur following the conclusion of the plume phase portion of the exercise. Players will be presented with a scenario, maps of dispersion data, and protective action recommendations from the LDEQ. This demonstration will take place in the form of a tabletop discussion.

Level 2 Findings-None III.

ASSESSMENT AREA 3: PROTECTIVE ACTION IMPLEMENTATION RevO A.

Sub-element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OR Os issue appropriate dosimetry, Kl, and procedures, and manage radiological exposure to emergency workers in accordance with the plans! procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintc;iin appropriate record-keeping of the administration of Kl to emergency workers.

(NUREG- 0654/FEMA-REP-1, K.3.a, b; K.4)

1.

Locations LDEQ EOF, LDEQ FMT 1, LDEQ FMT 2, Tensas Parish EOG, Tensas Parish T/ACP, Tensas Parish School Board, Tensas Parish EWMDS, Franklin Parish Reception Center (demonstration at these locations was postponed and will be documented in a separate report)

2.

Extent of Play Page 9 of 19 12/07/2018

RevO STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 a

TLD/OSLs will be available for all emergency workers and available for inspection. Simulated TLDs will be used in place of spare OSL or TLD badges when applicable.

b.

Traffic and Access Control Points personnel will be located at the Tensas Parish EOC, where they will demonstrate the criteria via interview. No travel to Traffic and Access Points will be performed.

c.

Area dosimetry may be used at the Tensas Parish EOC, Tensas Parish EWMDS and Franklin Parish Reception Center.

d.

Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to insure that exercise play is not interrupted.

Correction-on-the-spot at the Tensas EOC is limited to areas outside the operations area (i.e., emergency worker briefings and issue of dosimetry in other rooms).

3.

Level 2 Findings - None B.

Sub-element 3.b. - Implementation of KI Decision for Institutionalized Individuals and the General Public Criterion 3.b.1: Kl and appropriate instructions are available if a decision to recommend use of Kl is made.

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

(NUREG-065_4/FEMA-REP-1, J.10.e, f)

1.

Locations

2.

Tensas Parish EOG Extent of Play a

If the scenario does not warrant a discussion on protective action decisions for the protection of special populations, then the criteria shall be accomplished through an interview with the evaluator.

b.

If the scenario does not warrant a discussion on KI decisions, then the criteria will be accomplished through an interview with the evaluator.

c.

According to the State of Louisiana's policy, KI is not considered for the general public.

Page 10 of 19 12/07/2018

RevO

3.

STATE OF LOUISIANA/ GRAND GULF NUCLEAR ST A TION 2019 EVALUATED EXERCISE

d.

March 13, 2019 Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to insure that exercise play is not interrupted.

Correction-on-the-spot at the Tensas EOC is limited to areas outside the operations area (i.e., emergency worker briefings and issue of dosimetry in other rooms).

Level 2 Findings - None C.

Sub-element 3.c. - Implementation of Precautionary and/or Protective Actions for Persons with Disabilities and Access/Functional Needs Criterion 3.c.2: OROs!School officials implement precautionary and/or protective actions for schools. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

1.

Locations Tensas Parish EOG, Tensas Parish School Board

2.

Extent of Play

3.

a

b.

Criterion will be demonstrated by discussion with the school official at the Tensas Parish EOC or nearby location. A bus driver will also be available for interview. Discussion may also include a transportation official.

Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to ensure that exercise play is not interrupted.

Correction-on-the-spot at the Tensas EOC is limited to areas outside the operations area (i.e., emergency worker briefings and issue of dosimetry in other rooms).

Level 2 Findings - None D.

Sub-element 3.d. - Implementation of Traffic Access Control Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654/FEMA-REP-1, A.3; G.1, 4; J.10.g, j)

1.

Locations Tensas Parish EOG, Tensas Parish T!AGP Page 11 of 19 12/07/2018

RevO

2.

STA TE OF LOUISIANA/ GRAND GULF NUCLEAR ST A TION 2019 EVALUATED EXERCISE March 13, 2019 Extent of Play a

This may be demonstrated out of sequence.

b.

One traffic and access control staff will demonstrate knowledge of their roles and responsibility by discussion with the evaluator. The discussion will be at or near the EOC. Travel to the traffic and access control point will not be demonstrated.

c.

If the scenario does not warrant this discussion, the controller will inject data to simulate a discussion.

d.

Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to insure that exercise play is not interrupted.

Correction-on-the-spot at the Tensas EOC is limited to areas outside the operations area (i.e., emergency worker briefings and issue of dosimetry in other rooms).

3.

Level 2 Findings - None Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG- 0654/FEMA-REP-1, J.10.k)

1.

Locations Tensas Parish EOG, Tensas Parish TIAGP, JIG

2.

Extent of Play

3.
a.

Transfer of information to the JIC is demonstrated to evaluator at Tensas Parish EOC

b.

A controller inject will be used to initiate the demonstration for this criterion. The inject will occur during the evacuation and it will be on an evacuation route. It will trigger the re-routing with the JIC in order to communicate the alternate route to evacuees that are leaving the area. No implementation will actually occur; the situation and solution will be discussed in the Tensas Parish EOC.

Level 2 Findings - None Page 12 of 19 12/07/2018

STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 E.

Sub-element 3.f. - Implementation of Post-Plume Phase Relocation, Reentry, and Return Decisions Criterion 3.f.1: Decisions regarding controlled reentry, relocation, and return of individuals during the post-plume phase are coordinated with appropriate organizations and implemented. (NUREG-0654/FEMA-REP-1, E. 7; J.10.j; J.12; K.5.b; M.1, 3)

3.

Locations Tensas Parish EOG

4.

Extent of Play Out of Sequence -

This demonstration will occur following the conclusion of the plume phase portion of the exercise. Players will be presented with a scenario, maps of dispersion data, and protective action recommendations from LDEQ. This demonstration will take place in the form of a tabletop discussion.

5.

Level 2 Findings -None IV.

ASSESSMENT AREA 4: FIELD MEASURMENT AND ANALYSES RevO A.

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

1.

Locations LDEQ EOF

2.

Extent of Play a

LDEQ FMTs, Dose Assessors, and other LDEQ EOF personnel may be presented with controller injects as needed them to characterize the release.

b.

The LDEQ EOF controller may inject simulated field monitoring data to the Dose Assessment Coordinator for the purpose of dose projection validation and verification through back calculations.

3.

Level 2 Findings - None Page 13 of 19 12/07/2018

STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EV AL UA TED EXERCISE March 13, 2019 Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654/FEMA-REP-1, C.1; H.12; 1.8, 9; J.10.a)

1.

Locations LDEQ FMT 1, LDEQ FMT 2

2.

Extent of Play

a.

Used charcoal cartridges instead of silver zeolite will be used for air sampling.

b.

Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to ensure that exercise play is not interrupted.

3.

Level 2 Findings - None V.

ASSESSMENT AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION RevO A.

Sub-element 5.a - Activation of the Prompt Alert and Notification System 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. (NUREG-0654/FEMA-REP-1, E.5, 6, 7)

1.

Locations

2.
3.

Tensas Parish EOG KNOE Radio Station, 1109 Hudson Lane, Suite C, Monroe, LA 71201 Extent of Play a

The alert and notification system (ANS) activation procedure will be demonstrated up to the point of activation. The siren activation will be simulated.

b.

The mutual capability of Tensas Parish and Claiborne County to activate each other's sirens will not be demonstrated during this exercise.

c.

Out of Sequence - A Staff Assisted Visit (SA V) to the KNOE Radio Station will be performed at 11 :00 AM on March 12, 2019.

d.

Backup method of sending EAS messages via Fax will be demonstrated during SAV at KNOE but not on the day of the exercise itself.

Level 2 Findings - None Page 14 of 19 12/07/2018

RevO STA TE OF LOUISIANA/ GRAND GULF NUCLEAR ST A TION 2019 EVALUATED EXERCISE March 13, 2019 Criterion 5.a.3: Backup alert and notification of the public is completed within a reasonable time following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654/FEMA-REP-1, E.6, Appendix 3.8.2.c)

1.

Locations Tensas Parish

2.

Extent of Play Out of Sequence - This demonstration will occur following the conclusion of the plume phase portion of the exercise, concurrently with demonstration of criteria 2.e.1 and 3.f.1. This will require one evaluator and controller to accompany the backup alert route and the remaining evaluators and controllers to remain in the Tensas Parish EOG for the demonstration of criteria 2.e.1 and 3.f.1.

3.

Level 2 Findings - None B.

Sub-element 5.b - Subsequent Emergency Information and Instructions for the Public and the Media Criterion 5.b.1: OR Os provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c)

1.

Locations

2.

JIG, Tensas Parish EOG Extent of Play a

Utility, State, and Parish representatives will demonstrate the ability to provide emergency information and instructions to the public consistent with the scenario.

b.

News media will not be present. Selected persqnnel will simulate the role of reporters asking questions during briefings.

c.

Controllers will inject public phone team messages, media phone team messages and news briefing messages.

d.

Rumor control will be demonstrated at the JIC.

e.

All subsequent messages disseminated by the Louisiana SEOC will be announced by the GOHSEP representative at the JIC.

3.

Level 2 Findings-None Page 15 of 19 12/07/2018

STA TE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 VI.

ASSESSMENT AREA 6: SUPPORT OPERATIONS/FACILITIES RevO A. Sub-element 6.a-Monitoring, Decontamination, and Registration of Evacuees Criterion 6.a.1: The reception center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees. (NUREG-0654/FEMA-REP-1, A.3; C.4; J.10.h; J.12)

1.

Location

2.

Franklin Parish Reception Center Franklin Parish High School 1600 Glover Drive Winnsboro, LA 71295 (demonstration at this locations was postponed and will be documented in a separate report)

Extent of Play a

Demonstration of criteria will be performed out of sequence at the Concordia Parish Reception Center at 6:30 PM on March 21, 2019.

b.

Participants will be pre-staged at or near the reception center.

c.

The capability to monitor 20% of Protective Action Sections 8, 9, 10, 11 and 12 of the 10-mile EPZ over a 12-hour period will be demonstrated.

The population of these sections is 3213. Twenty percent of this population is 643. To meet 20% requires a monitoring capability of 1 evacuee per minute. This will be demonstrated although Franklin Parish is an overflow Reception Center 8:nd unlikely to have this many evacuees.

d.

One vehicle will be monitored for contamination. A combination of low-activity live sources planted on the vehicle and/or controller data interjected via cue card will be used to simulate contamination on the vehicle. The vehicle will not proceed to the segregated parking area after monitoring. The segregated parking area will not be set up to receive vehicles, but will be available for viewing and discussion.

e.

Per the REP Manual, a minimum of six evacuees need to be monitored.

Six people will simulate evacuees for the demonstration. At least one portal monitor will be set up and the six evacuees processed. One of the six will be simulated as contaminated. Low-activity live sources will be used to simulated contamination on the clothing and personal items of the evacuee. After surveying is complete, the controller will interject data via cue card indicating that an additional area of the evacuee's skin or hair was found to be contaminated, to be entered on the Personnel Contamination Survey Report form.

Page 16 of 19 12/07/2018

RevO STA TE OF LOUISIANA/ GRAND GULF NUCLEAR ST A TION 2019 EVALUATED EXERCISE March 13, 2019 f

One monitoring station for contaminated evacuees will be set up and the contaminated individual will be processed to the decontamination station.

A combination of low-activity live sources planted on the evacuee and controller data interjected via cue card will be used to simulate contamination on the evacuee. Decontamination will be evaluated by demonstration and further discussion.

g.

A roster indicating 24-hour coverage for the reception center will be available. A shift change will not be demonstrated at this location, but may be discussed out of sequence with the Emergency Manager/Officer-in-Charge.

h.

Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to insure that exercise play is not interrupted.

2.

Level 2 Findings - None B.

Sub-element 6.b. -Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles Criterion 6.b.1: 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. (NUREG-0654/FEMA-REP-1, K.5.a, b)

1.

Location

2.

Tensas Parish EWMDS Tensas Parish Fire District Station 1104 Plank Road StJoseph, LA 71366 (demonstration at this locations was postponed and will be documented in a separate report)

Extent of Play a

Demonstration of criteria will be performed out of sequence on March 21, 2018 at a time TBD.

b.

Participants will be pre-staged at or near the Tensas Parish Emergency Worker Monitoring & Decontamination Center (EWMDS).

c.

One emergency worker vehicle will be monitored for contamination.

Either a low activity live source will be used, or a controller will interject data for a simulated contamination level for one vehicle. The vehicle will not proceed to the segregated parking area after monitoring. The segregated parking area will not be set up to receive vehicles, but will be available for viewing and discussion.

Page 17 of 19 12/07/2018

RevO

3.

STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019

d.

One emergency worker will be monitored for contamination. Either a small live source will be used, or a controller will interject data for a simulated contamination level for the emergency worker.

e.

Procedures regarding a vehicle on which exterior contamination was not detected, after one of the vehicle's occupants is found to be contaminated at the Personnel Monitoring Station, will not be demonstrated.

f A roster indicating 24-hour coverage for the reception center will be available. A shift change will not be demonstrated at this location, but may be discussed out of sequence with the Emergency Manager/Officer-in-Charge.

g.

Correction-on-the-spot will be considered at these locations at the discretion of and concurrence between the evaluator and the controller.

Caution should be exercised to insure that exercise play is not interrupted.

Level 2 Findings -None C. Sub-element 6.c -Temporary Care of Evacuees Criterion 6.c.1: Managers of congregate care facilities demonstrate that the care centers have resources to provide services and accommodations consistent with Louisiana Unified Shelter Plan. 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. (NUREG-0654/FEMA-REP-1; J.10.h; J.12)

1.

Location River of Life Church 127 Ellis Lane Winnsboro, LA 71295 (demonstration at this locations was postponed and will be documented in a separate report)

2.

Extent of Play A Staff Assisted Visit (SA V) will be performed for congregate facility on March 21 at 4:30 PM.

3.

Level 2 Findings -None Page 18 of 19 12/07/2018

~I

STATE OF LOUISIANA/ GRAND GULF NUCLEAR STATION 2019 EVALUATED EXERCISE March 13, 2019 VII.

GENERAL EXTENT-OF-PLAY (EOP):

A.

With regard to last minute additions or changes to any previously approved Extent-of-Play, all suggested changes must be forwarded to the RAC Chair for approval.

B.

The goal of all offsite response organizations (ORO) is to protect the health and safety of the public. This goal is achieved through the execution of appropriate plans and procedures. It is recognized that situations may arise that could limit the organizations in the exact execution of these plans and procedures.

C.

In the event of an unanticipated situation, OROs are permitted to exercise flexibility in the implementation of their plans and procedures in order to successfully achieve the objective of protection of public health and safety and protection of the environment.

D.

As a statement of fact, no ORO will deliberately deviate from its plans and procedures with the intent of avoiding responsibility.

VIII.

REFERENCES:

Radiological Emergency Preparedness Program Manual - FEMA P-1028 I January 2016 RevO Page 19 of 19 12/07/2018

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