ML20036E051

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After Action Report, Comanche Peak Nuclear Power Plant - Tx Radiological Emergency Preparedness Exercise, Exercise Date: 11/06/2019
ML20036E051
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/06/2020
From:
US Dept of Homeland Security, Federal Emergency Management Agency
To:
Office of Nuclear Reactor Regulation, NRC Region 4
References
Download: ML20036E051 (41)
v • d • e


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I After Action Report Comanche Peak Nuclear Power.Plant - TX Radiological Emergency Preparedness Exercise Exercise Date: 11/06/2019 02/06/20

.Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX This page is intentionally blank 2

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I Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX 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..................,................,................................... :..................... 8 Section 2: Exercise Design Summary........................................................................................... 10 2.1 Exercise Purpose and Design....................................................................................... 10 2.2 Exercise Core Capabilities and Objectives.................................................................. 10 2.3 Exercise Scenario.......................................................................................................... 10

  • Section 3: Analysis of Capabilities............................................................................................... 11 3.1 Exercise Evaluation and Results.................................................................................. 11 3.2 Summary Results of Exercise Evaluation............................................................ :....... 11 Section 4: Conclusion................................................................................................................... 20 Appendix A: Exercise Timeline.................................................................................................... 22 Appendix B: Exercise Key Leaders and Evaluators.............................. :............ ;....... ;.................. 23 Appendix C: Improvement Plan............................................................ ;.............. 25 Appendix D: Extent of Play Agreements...................................................................................... 28 3

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX Executive Summary On November 6, 2019 a Radiological Emergency Preparedness (REP) exercise was conducted at.

Comanche Peak Nuclear Power Plant (CPNPP) located near Glen Rose, Texas. The purpose of the exercise was to assess the level of preparedness of state and local responders to a simulated emergency at CPNPP. This exercise was conducted in accordance with U.S. Department of Homeland Security/Federal Emergency Management Agency (DHS/FEMA) policy and guidance concerning implementation of state and local emergency preparedness plans and procedures.

The qualifying exercise to satisfy FEMA rule 44 Code of Federal Regulations (CFR) 350 requirements for Nuclear Regulatory Commission (NRC) licensing to operate the facility was conducted in July 1989. Including the exercise on November 6, 2019, there have been sixteen FEMA Region VI evaluated exercises and several drills conducted since that time.

FEMA Region VI wishes to acknowledge the dedicated participation of many individuals in the State of Texas and Somervell and Hood Counties. Some of these participants are paid civil servants whose full-time job, is to protect the health and safety of the public within the jurisdictions they serve. Many more are volunteers who make themselves available to perform a service to the community in which they live. Their participation is particularly noteworthy..

This report contains the final written evaluation of the biennial exercise. The state and local organizations except where noted in this report demonstrated knowledge of the emergency plans and procedures and properly implemented them. There were no Level 1. or Level 2 Findings and four plan issues identified during this exercise.

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Radiological Emergency Preparedness Program After Action Report*

Comanche Peak Nuclear Power Plant - TX I.

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I Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX 1.1 Section 1: Exercise Overview Exercise Details Exercise Name 2019 Comanche Peak Plume Exercise Type of Exercise Plume Exercise Date 11/06/2019

.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 Mission National Preparedness 7

Radiological Emergency Preparedness Program After Action Report 1.2 Exercise Planning Team Leadership Lisa Hammond 1.3 Acting RAC Chair FEMA Region VI 800 N Loop 288 Denton, TX 76209 (940) 898-5199 lisa.hammond@fema.dhs.gov Brad DeKorte Federal Lead Planner FEMA Region VI 800 N Loop 288 Denton, TX 76209 (940) 383-7304 brad.dekorte@fema.dhs.gov Glenn Corbin State Emergency Planner Texas Department of State Health Services P.O. Box 149347 Austin, TX, 78714 (512) 834-6770 ext. 2028 glenn.corbin@dshs.texas.gov Kelly Faver Licensee Emergency Planner Comanche Peak Nuclear Power Plant P.O. Box 1002 Glen Rose, TX, 76042 254-897-5628 kelly.faver@luminent.com Participating Organizations State Texas Department of Public Safety Texas Department of State Health Services Texas Division of Emergency Management 8

Comanche Peak Nuclear Power Plant - TX I

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Radiological Emergency Preparedness Program After Action Report Risk Jurisdictions Hood County Somervell County City of Glen Rose City of Granbury Private Organizations American Red Cross Comanche Peak Nuclear Power Plant - TX Comanche Peak Nuclear Power Plant (Luminant)

Radio Station WBAP 9

Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX Section 2: Exercise Design Summary 2.1 Exercise Purpose and Design 2.2 2.3 The DHS/FEMA Region VI Office evaluated the exercise on November 6, 2019 to assess the capabilities of the local emergency preparedness organizations in implementing their *

. Radiological,Emergency Response Plans and Procedures to protect the public health and safety during a radiological emergency involving Comanche Peak Nuclear Power Plant (CPNPP). The purpose of this report is to represent the results of the findings on the

  • performance of the off site response organizations during a simulated radiological emergency.

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 a:nd encompass the emergency preparedness evaluation areas.

Exercise Scenario The exercise scenario was developed to evaluate the response of the exercise participants to an incident requiring response to a simulated emergency at the Comanche Peak Nuclear Power Plant (CPNPP). The scenario provided for the evaluation of the Texas Division of Emergency Management (TDEM), Texas Department of State Health Services-Radiation Control Program.(DSHS-RCP), and Hood and Somervell Counties to the emergency at CPNPP.

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX 3.1 3.2 Section 3: Analysis of Capabilities Exercise Evaluation and Results This section contains the results and findings of the evaluation of all jurisdictions and functional entities that participated in the 11/06/2019 Comanche Peak Plume 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 (LI) Finding: An ob.served 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 than that of the ORO's performance.

N: Not demonstrated Summary Results of Exercise Evaluation DATE: 11/06/2019 SITE: Comanche Peak Nuclear Power Plant - TX M: Met, LI: Level 1 Issue, L2: Level 2 Issue, P: Plan Issue, N:

Not Demonstrated

.. *lal Jb1 Jc1 DSHS EOF M

M M

M DSHS Field Monitoring Team 2 M

M DSHS Field Monitoring Team 1 M

M Hurst DOC M

M M

M Somervell County EOC M

M M

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX I

Hood County EOC

  • JIC DATE: 11/06/2019 SITE: Comanche Peak Nuclear Power Plant - TX M: Met, Ll: Level 1 Issue, L2: Level 2 Issue, P: Plan Issue, N: Not Demonstrated DATE: 11/06/2019 SITE: Comanche Peak Nuclear Power Plant -

TX M: Met, Ll: Level 1 Issue, L2:

Level 2 Issue, P: Plan Issue, N: Not Demonstrated DSHS EOF M

DSHS Field Monitoring Team 2 M

DSHS Field Monitoring Team l M

Somervell County EOC M

Hood County EOC M

DATE: 11/06/2019 M

M p

SITE: Comanche Peak Nuclear Power Plant - TX M

M M

M: Met, Ll: Level 1 Issue, L2: Level 2 Issue, P: Plan Issue, N:

Not Demonstrated DSHS EOF DSHS Field Monitoring Team 2 DSHS Field Monitoring Team I 12

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!I 11 Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX DATE: 11/06/2019 SITE: Comanche Peak Nuclear Power Plant -TX M: Met, Ll: Level 1 Issue, L2: Level 2 Issue, P: Plan Issue, N:

Not Demonstrated EOC Hood Coun JIC DATE: 11/06/2019 SITE: Comanche Peak Nuclear Power Plant - TX M: Met, Ll: Level 1 Issue, L2: Level 2 Issue, P: Plan Issue, N: Not Demonstrated 13 M

M M

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX 3.2.1 DSHS EOF For this venue the following Radiological Emergency Preparedness criteria were MET:

l.a.l, l.c.l, 1.d.l, l.e.l, 2.a.l, 2.b.l, 3.a.l, 4.a.2.

a. Level 1 Finding: None
b. Level 2 Finding: None
c. Plan Issues: None 3.2.1 DSHs* Field Monitoring Team 2 For this venue the following Radiological Emergency Preparedness criteria were MET:

l.d.l, Le.I, 3.a. l.

a. Level 1 Finding: None
b. Level 2 Finding: None c: Plan Issues: 1 ISSUE 14--4a3-P-004
  • CONDITION: Field teams set samplers to draw air samples at flow rates in excess of2 cubic feet per minute (cfm).

POSSIBLE CAUSE:

Flow rates to collect air samples for particulates and iodines were not designated in the air sampling procedures.

REFERENCE:

NUREG-0656/FEMA REP-1, Planning Standard I.9 FEMAREP-2 EFFECT:

Iodine collection efficiencies provided by silver zeolite cartridge manufacturers show that collection efficiencies for methyl iodide drop off significantly at flow rates in ~xcess of 2 cfm. Texas iodine concentration calculations assume an 80% collection efficiency for iodine concentration calculations using a silver zeolite cartridge. If the collection 14 I

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I Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX efficiency is less than 80% for iodines, the concentration calculations will be lower than actual concentrations. Also, the system may not be capable of detecting and measuring radioiodine concentrations in air as low as 10-7 µCi/cc under field conditions.

As additional notes, particulate filters have high collection efficiencies, as long as the collection flow rate is at 1 cfm or greater to effect impingement. Most systems assume a collection efficiency of 90% for iodine and 99% for particulates.

RECOMMENDATION:

The Field Team Coordinator corrected the condition by briefing that air samples would be collected at 2 cfm. However, no edit was made to the procedures.

The procedures should be edited to document that air samples will be collected using a flow rate between 1 and 2 cubic feet per minute.

3.2.1 DSHS Field Monitoring Team 1 For this venue the following Radiological Emergency Preparedness criteria were MET:

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

a. Level 1 Finding: None *
b. Level 2 Finding: None
c. Plan Issues: None 3.2.1 Hurst DDC For this venue the following Radiological Emergency Preparedness criteria were MET:

l.a.1, l.c.l, l.d.1, l.e. l.

a.. Level 1 Finding: None b; Level 2 Finding: None
c. Plan Issues: None 3.2.1 Somervell County EOC For this venue the following Radiological Emergency Preparedness criteria were MET:

l.a.l, l.c.l, l.d.l, 2.a.l, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.l, 5.b.l.

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX

a. Level 1 Finding: None
b. Level 2 Finding: None
c. Plan Issues: 1 ISSUE 14--lel-P-003 CONDITION: The Somervell County Radiological Officer did not adequately perform an operability check on the SAIC Canberra Model Number PPM-2000A Portal Monitor before putting it into operation.

POSSIBLE CAUSE:

The Radiological Officer may not have been sufficiently trained and did not have a documented procedure to follow.

REFERENCE:

NUREG-0654/FEMA-REPl, H.10 EFFECT:

The portal monitor was not functioning properly reading extremely high counts per second. Emergency workers passing though the portal monitor to enter the EOC would potentially be found to have high levels of contamination, not allowing them to enter the EOC to perform necessary response functions.

RECOMMENDATION:

Revise the Somervell County Radiological Emergency Response Plan and supporting procedures to include instructions on performing an operability check on portal monitors priorto use and procedures on troubleshooting the portal monitor when not functioning properly.

3.2.1 Hood County EOC For this venue the following Radiological Emergency Preparedness criteria were MET:

1.a.l, 1.c.l, 1.d.l, 2.a.l, 2.b.2, 2.c.l, 3.a.l, 3.d.1, 3.d.2, 5.a.l, 5.b.1.

a. Level 1 Finding: None
b. Level 2 Finding: None 16 I

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I Radiological.Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX

c. Plan Issues: 2 ISSUE 14--lel-P-001 CONDITION: The Hood County Radiological Officer did hot perform an operational

. check on the PPM-2000 portal monitor before putting it into operation.

POSSIBLE CAUSE:

The Radiological Officer may not have been sufficiently trained and did not have a doctimented procedure to follow.

REFERENCE:

  • NUREG-0654/FEMA-REPl, H.10 EFFECT:

The portal monitor may not have been functioning properly, but without conducting an operational check prior to use, this would riot be identified. Emergency workers entering the EOC through the portal monitor could have been found to be free of contamination, but actually be contaminated.. Contamination could have then been spread throughout the EOC resulting in unnecessary exposure.

RECOMMENDATION:

Revise the Hood County Radiological Emergency Response Plan and supporting procedures to include instructions on performing an operational check on portal monitors prior to use.

ISSUE 14--3bl-P-002 CONDITION: There are no provisions to provide KI to the Care Givers for Institutionalized Individuals.

POSSIBLE CAUSE:

There are no provisions in the Hood County Manual of Emergency Procedures (May 2013) to provide KI to the Care Givers for Institutionalized Individuals..

REFERENCE:

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

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear.Power Plant - TX EFFECT:

Care Givers that remain with institutionalized individuals do n~t receive the benefits of administering a radioprotective drug as an exposure control meathod.

RECOMMENDATION:.

Update the Hood County Manual of Emergency Procedures to provide provisions to distribute KI to these individuals.

3.2.1 JIC.

For this venue the following Radiological Emergency Preparedness criteria were MET:

I.a.I, l.d.1, l.e.1, 5.b.1.

a. Level 1 Finding: None
b. Level 2 Finding: None
c. Plan Issues: None 3.2.1 WBAP Radio For this venue the following Radiologkal Emergency Preparedness criteria were MET:

5.a.l.

a. Level 1 Finding: None
b. Level 2 Finding: None
c. Plan Issues: None 3.2.1 Bosque County Shelter For this venue the following Radiological Emergency Preparedness criteria were MET:

6.c.l.

a.
  • Level 1 Finding: None
b. Level 2 Finding: None
c. Plan Issues: None 18 I

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I After Action Report Radiological Emergency Preparedness Program Comanche Peak Nuclear Power Plant - TX This page is intentionally blank 19

Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX Section 4: Con~lusion Based on the results of the drill, the off site radiological emergency response plans and preparedness for the State of Texas and the affected local jurisdictions are deemed adequate to provide reasonable assurance that appropriate measures can be taken to protect the health and safety of the public in the event of a radiological emergency. Therefore, 44 CFR Part 350 approval of the off site radiological emergency response plans and preparedness for the State of Texas site-specific to Comanche Peak Nuclear Power Plant will remain in effect.

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I After Action Report Radiological Emergency Preparedness Program Comanche Peak Nuclear Power Plant - TX This page is intentionally blank 21

Radiological Emergency Preparedness Program After Action Report*

Nuclear Power Plant - TX Emergency Classification Level or Event 1st Protective Action Decision:

Evac:.

Shelter:

2nd Protective Action Decision:

Evac:

Shelter:

2nd Siren Activation.

2nd EAS or EBS Message Kl Administration Decision:

3rd Siren Activation 3rd EAS Message A

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX Appendix B: Exercise Key Leaders and Evaluators*

Regiorial Assistance Committee (RAC) Chair: Lisa Hammond Site Specialist: Brad Dekorte (Acting)

tb'catf4it':/Ye_iiii:~- : -_ :: / '.~i~1:Uatti/u,tiim;~,:_-,'., *-1::,.:3, DSHSEOF Timothy Pflieger, Nan Williams DSHS Field Monitoring George Brozowski Team2 DSHS Field Monitoring Michael Howe Team 1 Hurst DOC Joseph Suders Somervell County EOC Lee Torres, Christopher Nemcheck, Alonzo Mcswain, Alfred Hickman Jr.

Hood County EOC Linda Gee, Jennifer Greene, Matthew Celia, LaShawn Halsey JIC Taneeka Hollins, Janet Hlavaty laposa WBAPRadio Elsa Lopez Bosque County Shelter Linda Gee 23

Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX APPENDIX C: IMPROVEMENT PLAN CONDITION: The Radiological Officer did not perform an operational check on the PPM-000 portal monitor before putting it into operation.

FERENCE:

UREG-0654/FEMA-REPl, H.10 RECOMMENDATION:

-1) Revise the Hood County Radiqlogical Emergency Response Plan and supporting procedures to include instructions on performing an operational check on portal monitors prior to use.

CORRECTIVE ACTION DESCRIPTION:

enue Assessed: Hood County EOC AGENCYPOC:

PRIMARY RESPONSIBLE AGENCY: Hood Coun START DATE:

ESTIMATED COMPLETION DATE:

CONDITION: There are no provisions to provide KI to the Care Givers for Institutionalized Individuals FERENCE:*

UREG-0654/FEMA-REP-1, J.(10.e, f RECOMMENDATION:

1) Update the Hood County Manual of Emergency Procedures to add provisions to provide KI for the Care Givers of these individuals residing and working at the Assisted Living Facilities that would shelter.

CORRECTNE ACTION DESCRIPTION:

enue Assessed: Hood County _EOC 24 PRIMARY RESPONSIBLE AGENCY: Hood Count START DATE:

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I Radiological Emergency Prepare~ness Program After Action Report Comanche Peak Nuclear Power Plant - TX I AGENCY POC:

!ESTIMATED COMPLETION DATE:

!flflfl~t~!~it\\,i'f CONDITION: The Radiological Officer did not adequately perform an operability check on he SAIC Canberra Model Number PPM-2000A Portal Monitor before putting it into operation.

lthough the staff were aware the portal monitor was not functioning correctly, they were not ware of how to troubleshoot the portal to reset readings from counts per second to count per FERENCE:

. UREG-0654/FEMA-REPl, H.10 RECOMMENDATION:

1) Revise the Somervell County Radiological Emergency Response Plan and supporting
  • procedures to inciude instructions ori performing an operability check on portal monitors prior to use and procedures on troubleshooting the portal monitor when not functioning properly.

CORRECTIVE ACTION DESCRIPTION:

enue Assessed: Somervell County EOC AGENCYPOC:

PRIMARY RESPONSIBLE AGENCY: Somervell Coun START DATE:

ESTIMATED COMPLETION DATE:

CONDITION: Field teams set samplers to draw air samples at flow rates in excess of 2 cubic eet per minute (cfm).

FERENCE:

UREG-0656/FEMA REP-1, 1.9 EMAREP-2 RECOMMENDATION:

.1) The Field Team Coordinator corrected the condition by briefing that air samples would be collected at 2 cfm. However, no edit was made to the procedures.

2) The procedures should be edited to document that air samples will be collected using a flow rate between 1 and 2 cubic feet per minute.

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX CORRECTIVE ACTION DESCRIPTION:

PRIMARY RESPONSIBLE AGENCY: DSHS Venue Assessed: DSHS Field Monitoring Teams START DATE:

AGENCY POC: Glenn Corbin, DSHS ESTIMATED COMPLETION DATE:

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I After Action Report Radiological Emergency Preparedness Program Comanche Peak Nuclear Power Plant - TX This page is intentionally blank 27

Radiological Emergency Preparedness Program After Action Report

  • Comanche Peak Nuclear Power Plant - TX Appendix D: Extent of Play Agreements EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.a - Mobilization Criterion 1.a.1:

FEMA REP:

Criterion 1.a.1: Off-site Response Organizations (OROs) use effective Sub-element 1.a -

procedures to alert, notify, and mobilize emergency Mobilization persorinel and activate facilities in a timely manner.

(NUREG-0654/FEMA-REP-1, A.1.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; H.3, 4}

CORE CAPABILITY:

Objective 1:

Mobilize key emergency perscrnnel in a timelymanner.

Operational Objective 2:

Demonstrate the ability to maintain and staff 24-hour Coordination operations (provide a roster).

CORE CAPABILITY:

Objective 1:

Receive notification of an incident from STP & verify the Operational notification in a timely manner.

  • Communications Objective 2:

Contact and alert key emergency personnel in a timely ma.nner.

Locations:

Disaster District 4A Hurst (Hurst DOC 4A) / Fort Worth JEOC DSHS RCP Emergency Operation Facility (EOF).

Joint Information Center (JIC}

Hood County Emergency Operation Center (EOC), and Somervell County EOC Extent of Play: DSHS personnel will pre-stage at the DSHS staging located at the Coman.che Peak (CP} Visitor Center Auditorium located at 6322 North FM 56 Glen Rose TX 76043-1002.

Regardless ofthe scenario, no facilities/activities will relocate during this exercise. The DSHS Radiological Mobile Lab will riot be evaluated during this exercise. Two (2) DSHS Field Monitoring Teams (FMTs) will be deployed and evaluated by FEMA.. Both DSHS FMTs will have Department of Public Safety (DP~) escorts. Drill evaluators and controllers may be required to travel in separate vehicles due to space restrictions. Disaster District Committee personnel not stationed at Hurst DOC 4A/ Fort Worth JEOC located at 275 West 13th Street Fort Worth TX, 76102-6333, may be pre-staged. The DSHS Austin Headquarters is located at the Exchange Building 8407 Wall Street 78754 Austin TX (512) 834-6770. To allow for maximum amount of play, DSHS JIC staff will pre-stage in the area. The JIC is located at the Granbury City Hall; 116

. West Bridge Street, Granbury TX 76048. An extra dispatcher will be placed on duty at the Hood and Somervell County Sheriff's office to handle the regular workload.

Findings: NONE 28 I

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I Radiological Emergency Preparedness Program After Action Report Sub:element 1.c - Direction and Control Criterion 1.c.1:

FEMA REP:

Criterion 1.c.1:

Sub-element 1.c -

Direction and Control CORE CAPABILITY:

Objective 1:

Operational Communications Objective 1:

CORE CAPABILITY:

Objective 1:

Situational Assessment Objective 2:

Locations:

Comanche Peak Nuclear Power Plant - TX 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}

Leadership personnel demonstrate the ability to carry out essential management functions in accordance to plans and procedures.

Leadership personnel coordinate with other OROs, to ensure completion of requirements and requests.

Leadership personnel demonstrate the ability to prioritize resource tasking and replacement/supplement resources.

Lea.dership personnel demonstrate the ability to keep staff informed through periodic briefings and/or other means.

Hurst DDC 4A / Fort Worth JEOC, Hood County EOC, Somervell County EOC Extent of Play: None Findings: None Sub-element 1.d - Communications Equipment*

Criterion 1.d.1:

FEMA REP:

Criterion 1.d.1: At least two communication systems are available, at least Sub-element 1.d -

one operates properly, and communication links are Communications established.and maintained with appropriate locations.

Equipment Communicatio~s capabilities are m*anaged in support of emergency operations. (NUREG-0654/FEMA-REP-1, F.1, 2}

CORE CAPABILITY:

Objective 1:

Demonstrate that a primary system and at least one Operational backup system are fully functional at all times.

Communications Objective 2:

Communications equipment and procedures for facilities and field units are used as needed for transmission and receipt ofexercise messages Objective 3:

Demonstrate the capability to manage the communications systems and ensure that all message traffic is handled without delays that might disrupt emergency operations.

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Radiological Emergency Preparedness Prngram After Action Report Comanche Peak Nuclear Power Plant - TX Locations:

Hurst DOC 4A / Fort Worth JEOC, DSHS EOF, DSHS Field Teams (FMTs), JIC, Hood County EOC, Somervell County EOC Extent of Play: A controller phone cell will be established by TDEM to ensure appropriate communications are accomplished and to ensure fluid exercise play.

Findings: None Sub-element 1.e - Equipment and Supplies to Support Operations Criterion 1.e.1:

FEMA REP:

Criterion 1.e.1: Equipment, maps, displays, monitoring instruments, Sub-element 1.e -

dosimetry, potassium iodide (Kl), and other supplies are Equipment and sufficient to support emergency operations. (NUREG-Supplies to Support

  • 0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9;1.10.a, b, e; J.11, Operations 12; K.3.a; K.5.b}

CORE CAPABILITY:

Objective 1:

Demonstrate sufficient inventories of Kl for use by Environmental emergency workers and as stipulated by plans and Response/ Health and procedures. (A physical inspection will be done to

_Safety verify quantity and expiration date.)

Objective 2:

Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers are available for issuance to all emergency *workers dispatched to conduct activities in areas where potential exposure is possible (including bus drivers evacuating schools, first responders, and persons re-entering a traffic access control point).

Objective 3:

Monitoring instruments are inspected, inventoried, and operationally checked before use. Instruments are calibrated in accordance with the manufacturer's recommendations and a range-of-reading label/sticker is affixed to the instrument.

Objective 4:

  • All responders have sufficient equipment, maps, displays and other su_pplies to support emergency operations at their deployed location.

Locations:

Hurst DOC 4A / Fort Worth JEOC, DSHS EOF, DSHS FMTs, JIC, Hood County EOC, Somervell County EOC Extent of Play: Instrument calibration will be specific to each manufacturer's specification.

Equipment not required for demonstrating exercise evaluation criterion may be left at the staging area to allow for additional space within the vehicles. The availability of silver zeolite 30 I

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX cartridges will be demonstrated. However, charcoal filters are authorized in lieu of silver zeolite cartridges for exercise purposes. Access to Personal Protective Equipment (PPE) clothing will be demonstrated, however will n.ot be worn during the exercise demonstration. The use of PPE will be demonstrated out of sequence in accordance with applicable procedures, so that donning and doffing of anti-e's can be demonstrated at the staging area in the air conditioning. Field Team PPE requirements will consist of booties and gloves. *Request the option to correct issues immediately (Correction-on-the-spot).

Findings: None EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Criterion 2.a.1~

FEMA REP:

Criterion 2.a.1: OROs use a decision-making process, considering relevant Sub-element 2.a -

factors and appropriate coordination, to insure that an Emergency Worker exposure control system, including the use of Kl, is in Exposure Control 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,t K.4}

CORE CAPABILITY:

Objective 1:

Demonstrate a capability to comply with emergency Environmental worker exposure limits based on emergency plans and Response/Health and procedures.

Safety Objective 2:

Demonstrate the distribution and administration of Kl as a protective measure for emergency worker~.

CORE CAPABILITY:

Objective 1:

Leadership personnel demonstrate the capability to Situational Assessment make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the numbers of emergency workers receiving radiation doses above pre-authorized levels.

Objective 2:

Leadership personnel demonstrate the capability to make decisions on the distribution of Kl based on projected thyroid dose compared with the established PAGs for Kl administration.

CORE CAPABILITY:

Objective 1:

Demonstrate delivery/transmission of recommendation Operational to administer Kl to all OROs impacted by this decision.

Communications Locations:

DSHS EOF, Hood County EOC, Somervell County EOC Extent of Play: If the scenario does not warrant a discussion on either the authorization to administer Kl or Emergency Worker (EW) exposure exceeding administrative limits, then the criterion will be accomplished through an inject at the EOF. Decision making for Kl and EW 31

Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX exposure level above administrative limits is done at the EOF and the local EOC.

Findings: None Sub-element 2.b. - Radiological Assessment and Protective Action Criterion 2.b.1:

FEMA REP:

Criterion 2.b.1: Appropriate protective action recommendations (PARs)

Sub-element 2.b -

are based on available information on plant conditions; Radiological field monitoring data, and licensee and ORO dose Assessment and projections, as well as knowledge of on-site and off-site Protective Action environmental conditions. (NUREG-0654/FEMA-REP-l, Recommendations and 1.10; Supp.3)

Decisions for the Plume Phase of the Emergency CORE CAPABILITY:

Objective 1:

Demonstrate the capability to use appropriate means Environmental described in plans*and procedures to develop Response/Health and

. protective action recommendations (PARs) for decision-Safety makers based on available information provided by the licensee, as well as field monitoring data, if available.

CORE CAPABILITY:

Objective 1:

Demonstrate a reliable capability to independently Situational Assessment validate plant (source term) assessments by calculating dose projections related to quantities and units ofthe PAG to which they are being compared.

Objective 2:

Demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise associated PARs.

Objective 3:

If licensee and ORO projected doses differ by more than a factor of 10, the source of the difference must be determined.

CORE CAPABILITY:

Objective 1:

. Demonstrate delivery/transmission of protective action Operat.ional recommendations to all ORO decision-makers in a Communications timely manner.

Locations:

DSHS EOF Extent of Play: DSHS RCP Headquarters is located in Austin, TX on the third floor of the Exchange Building Room N301 at 8407 Wall Street Austin TX,. 78754. DSHS HQ will provide Accident Assessment while the team is in route to the incident site, and will remain in contact until they arrive. If the Comanche Peak (CP) EOF has been staffed by DSHS prior to declaration 32 I

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I Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX of a General Emergency (GE), it will be the only facility evaluated for this criterion.

Findings: None Criterion 2.b.2:

FEMAREP:

Criterion 2.b.2: A decision-making process involving consideration of Sub-element 2.b -

appropriate factors and necessary co.ordination is used Radiological to make protective action decisions (PADs) for the Assessment and general public. (NUREG-0654/FEMA-REP-1, A.3; C.4, 6;.

. Protective Action

. D.4; J.9; J.10.f, m)

Recommendations and Decisions for the Plume Phase of the Emergency CORE CAPABILITY:

Objective 1:

Dem.onstrate the capability to provide strategic Operational direction by use of appropriate means described in Coordination plans and procedures to make both initial and subsequent precautionary and/or protective action decisions for the general public.

CORE CAPABILITY:

Objective 1:

Consider information from the licensee, assessment of Situational Assessment plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities, and PA~s from the utility and ORO staff when making protective action decisions for the general public.

CORE CAPABILITY:

Objective 1:

Demonstrate delivery/transmission of protective action Operational decisions to the general public (residents, transients, Communications and emergency responders) in a timely manner.

  • Locations:

Hood County EOC, Somervell County EOC Extent of Play: The protective action decisions that result from this decision-making process will not be implemented. No member of the public will be relocated. According to the State policy, Kl is not considered for the general public. If the scenario is not sufficient to drive the decision to recommend Kl for EW, the criteria will be demonstrated in both counties by interview and injects at the* end of the exercise. *Request the option to correct issues immediately (Correction-on-the-spot).

Findings: None Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Special Populations Criterion 2.c.1:

33

Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX FEMA REP:

Criterion 2.c.1: Protective action decisions are made, as appropriate, for Sub-element 2.c -

groups of persons with disabilities and Precautionary and/or access/functional needs. (NUREG-0654/FEMA-REP-1, Protective Action D.4; J.9; J.10.d, e)

Decision Consideration for the Protection of Persons with

\\

  • Disabilities and Access/Functional Needs CORE CAPABILITY:

Objective 1:

Demonstrate the capability to provide strategic Operational

  • direction by use of appropriate means described in Coordination plans and procedures to make both initial and subsequent precautionary and/or protective action decisions for persons with disabilities and access/functional needs.

CORE CAPABILITY:

Objective 1:

Consider information from the licensee, assessment of Situational Assessment plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities, and PARs from the utility and ORO staff when making protective action decisions for persons with disabilities and access/functional needs.

CORE CAPABILITY:

Objective 1:

Demonstrate delivery/transmission of protective action Operational decisions to persons with disabilities and Communications access/functional needs in a timely manner.

Locations:

Hood County EOC, Somervell County EOC Extent of Play: Protective action decisions for special needs individuals will be considered at the County EOCs; however, actual demonstration of protective actions will not be performed: Hood and Somervell County EOC staff will demonstrate this evaluation area through discussion and showing the evaluator a roster of special needs individui;!IS within the 10-mile emergency planning zone.

Findings: None EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1:

FEMA REP:

Sub-element 3.a -

Implementation of Criterion 3.a.1: The OROs issue appropriate dosimetry, Kl, and procedures, and manage radiological exposure to emergency workers in accordance with the 34 I

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Radiological Emergency Preparedn~ss Program After Action Report Comanche Peak Nuclear Power Plant - TX

  • - Emergency*Worker----~------------- plans/procedures:-1:mergency-workers*p~riodically-and-Exposure Control at the end of each mission read their *dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of Kl to emergency workers.

{NUREG-0654/FEMA-REP-l, K.3.a, b; K.4}

CORE CAPABILITY:

Objective 1:

Demonstrate the issuance of appropriate dosimetry, Kl, Environmental and procedures.

Response/Health and Objective 2:

Demonstrate the ability to mc1nage radiological Safety

  • exposure to emergency workers in accordance with
  • plans and procedures.

Objective 3:

Demonstrate emergency worker's ability to periodically and at the end of each mission read.their dosimeters and record the readings on the appropriate exposure*

record or chart.

Objective 4:

Maintain appropriate rec(?rd-keeping ofthe administration of Kl to emergency workers.

Locations:

DSHS EOF, DSHS FMTs, Hood County EOC, Somervell County EOC Extent of Play: Personnel located at facilities outside the 10-mile EPZ and not reporting to a location within the 10-mile EPZ will not be issued dosimetry per County Plans and Procedures.

Exercise TLDs will be used for the exercise. Access to TLDs for real events will be demonstrated.

The evaluation for these criteria will be conducted by an interview at an agreed upon time.

Distribution of Kl to EW will be simulated by using copies of the Patient Packet lnsertto represent actual Kl supplies. EW will simulate actual ingestion of Kl. The use of Kl by the generai public is not recommended in the State of Texas. *Request the option to correct issues immediately (Correction-on-the-spot).

Findings: None Sub-element 3.b - Implementation of Kl Decision for Institutionalized Individuals and the General Public Criterion 3.b.1:

FEMA REP:

Sub-element 3.b..;,

Implementation of Kl Decision for Institutionalized Individuals and the General Public CORE CAPABILITY:

Environmental Criterion 3.b.1: Kl and appropriate instructions are avi3ilable should a Objective 1:

. decision to recommend use of Kl is made. Appropriate record-keeping of the administration of Kl for institutionalized individuals is maintained. (NUREG-0654, J.10.e, f.)

Demonstrate the capability to make Kl available to institutionalized individuals, and, where provided for in 35

Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX Response/Health and their plans and procedures.

Safety

\\

Locations:

Hood County EOC, Somervell County EOC Extent of Play: None Findings: None Sub-element 3.d. - Implementation of Traffic and Access Control Criterion 3.d.1:

FEMA REP:.

Criterion 3.d.1: Appropriate traffic and access control is established.

Sub-element 3.d -

Accurate instructions are provided to traffic and access Implementation of control personnel. (NUREG-0654/FEMA-REP-1, A.3; Traffic and Access C.1,4; J.10.g, j)

Control CORE CAPABILITY:

Objective 1:

Demonstrate the capability to select, establish, and Operational*

staff appropriate traffic and access control points Coordination consistent with current conditions and PADs in a tiniely manner.

Objective 2:

Provide accurate instructions to traffic and access control staff on actions to take when modifications are

} made to traffic patterns.

CORE CAPABILITY: On-Objective 1:

Demonstrate roles and responsibilities, including Scene Security and verifying emergency worker identification and access Protection authorization to the affected areas (by interview)

Locations:

Hood County EOC, So_mervell County EOC Extent of Play: The T/ACP decision-making process will be demonstrated in real-time sequence; however, travel to the T/ACP will be simulated. The T/ACP demonstration will be simulated. A law enforcement officer representing each county and assigned to the T/ACP will discuss their knowledge of their role and responsibilities by interview with the evaluator prior to leaving the Hood and Somervell County EOCs. This interview can occur out of sequence of the exercise scenario, but during the exercise, at a time agreed upon by the Hood and Somervell controller and FEMA evaluator.

  • Request the option to correct issues immediately (Correction-on-the-spot).

Findings:

  • None Criterion 3.d.2:

I FEMA REP:

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

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Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX Sub-element 3:d -

{NUREG-0654/FEMA-REP-1, 1.10.-k)

Implementation of Traffic and Access Control CORE CAPABILITY:

Operational Coordination Objective 1:

Objective 2:

CORE CAPABILITY:

Objective 1:

Infrastructure Systems Locations:

Demonstrate the capability to identify impediments to evacuations and take appropriate actions by re-routing traffic.

Coordinate with the JIC to communicate the alternate route to evacuees.

Demonstrate the capability to dispatch resources used to support clearing of roadways.

Hood County EOC, Somervell County EOC Extent of Play: A controller inject will be used to initiate the demonstration for this criterion.

The inject will occu~ during the evacuation and it will be on an evacuation route. No impediment will actually occur, however, the situation and solutjon will be discussed in the appropriate EOC. Clearing of the impediment will not occur prior to demonstration of the re-routing process that includes coordination with the JIC.

Findings: None EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Criterion 4.a.2:

FEMA REP:

Criterion 4.a.2:

Sub-element 4.a-Plume Phase Field Measurements and Analysis CORE CAPABILITY:

Objective 1:

Situational Assessment Objective 2:

Locations:

DSHS EOF Field teams (2 or more) are managed to obtain sufficient information to help characterize the release and to control radiation exposure. {NUREG-0654, C.1; H.12; 1.7,8,11; 1.10.a}

Demonstrate a field team briefing that includes the predicted plume location and direction, plume travel speed, and exposure control procedures prior to deployment.

Demonstrate the ability for teams to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts.

Extent of Play: Field monitoring activities may be out-of-sequence demonstrations, as agreed 37

Radiological Emergency Preparedness Program After Action Report Comanche Peak Nuclear Power Plant - TX -

upon by the controller and evaluator at the time of the exercise.

Findings: None Criterion 4;a.3:

FEIVIA REP:

Criterion 4.a.3:

Ambient radiation measurements are made and Sub-element 4.a-Plume recorded at appropriate locations, and radio iodine and Phase Field particulate samples are collected. Teams should move Measurements and to an appropriate low background location to Analysis determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sample media. (NU REG-0654/FEMA-REP-1, C.1; H.12; 1.8, 9; J.10.a)

CORE CAPABILITY:

Objective 1:

Demonstrate the capability to make and report Environmental measurements of ambient radiation to the field teani Response/ Health and coordinator, dose assessment team, or other Safety appropriate authority.

Objective 2:

Demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and move to an appropriate low background location to pe~form a field analysis in accordance to DSHS RCP FMT procedure.

  • Locations:

DSHS FMTs Extent of Play: Equipment not required for demonstrating exercise evaluation criterion may be left at the staging area to allow for additional space within the vehicle. Charcoal filters are -

authorized in lieu of silver zeolite cartridges for exercise purposes but availability of silver zeolite cartridges will be demonstrated. If the scenario is not sufficient to drive demonstration of the

_ air sampling criteria an inject will be provided by the FT controller at the end of the exercise

. allowing the FTs to take an air sample. In addition, the controller will inject the need for a Field Analysis for 1-131 with 5,000 net cpm on the filter and 600,000 net cpm on the cartridge as the result of the measurement. *Request the option to correct issues immediately (Correction-on-the-spot).

Findings: None EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.a - Activation of the Prompt Alert ari-d Notification System Criterion 5.a.1:

FEMA REP:

Sub-element 5.a-Activation of the Prompt Alert and 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 off-site emergency officials to notify the public of an emergel')cy 38 I

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Radiological Emergency Preparedness Program.

After Action Report Comanche Peak Nuclear Power Plant - TX

-Notification-system------------ ---situation-:-The in itia 1-i nstructiona 1-message-to-the-pu blic-must include as a minimum the elements required by current REP guidance. (NUREG-0654/FEMA-REP-1, E.5, 6, 7) c;oRE CAPABILITY:

Objective 1:

Demonstrate the 24-hour capability to provide an alert Public Information and signal followed by an initial instructional message to Warning populated areas (permanent resident and transient) throughout the 10-mile in a timely manner.

Locations:

Hood County EOC, Somervell County EOC, EAS Radio Station WBAP Extent of Play: Siren activation will be simulated. Simulation ofthe siren activation will be in real time sequence with the transmission of the EAS message. The sirens will be sounded at the appropriate time in the exercise in accordance with the deeision and the EAS, message will follow the siren sounding. Emergency Alert System (EAS) message content will be determined and communicated to the EAS stations; however, the broadcasts will be simulated. WBAP News/Talk 820 AM 3090 Olive Street, West Victory Plaza, Suite 400, Dallas, TX 75219, Operations Manager: Tyler Cox 214-520-4365. Route alerting-will not be demonstrated.

Findings: None Sub-element 5.b - Emergeno/ Information and Instructions for the Public and the Media Criterion 5.b.1:

FEMA REP:

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

Instructions for the Public and Media CORE CAPABILITY:

Objective 1:

Demonstrate coordination to ensure that emergency Operational information and instructions are consistent with PADs Coordination made by appropriate officials and contains all necessary instructions.

CORE CAPABILITY:

Objective 1:

Demonstrate tlJe ability to provide emergency Public Information and information and instructions to the public and media in Warning a timely manner following the initial alert and notification.

Objective 2:

Demonstrate the ability to provide ingestion pathway information to pre-determined individuals and businesses in accordance with plans and procedures.

Objective 3:

Demonstrate the.ability to provide media information kits to the media.

39

Ra~iological Emergency Preparedness Program After Action Report Objective 4:

Locations:

Comanche Peak Nuclear Power Plant-TX Demonstrate that an effective system is in place for dealing with calls received Via the public inquiry hotline.

JIC, Hood County EOC, Somervell County EOC Extent of Play: Messages will not be broadcast over commercial radio or television. Four (4) telephones will be staffed at the JIC for the public inquiry demonstration. A phone cell and mock media will inject rumors. The Texas Division of Emergency Management (TDEM) will not make any emergency information releases.

Findings: None GENERAL EXTENT-OF~PLAY (EOP):

1. 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.
2.

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.

3.

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

4. Federal involvement will not be evaluated.
5. The exercise may be suspended or terminated due to a real emergency situation.
6.
  • Correction-on-the-spot - will be requested for all applicable criteria.
7. No protective action decisions impacting the general public will be made beyond the 10-mile EPZ regardless of the scenario.

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After Action Report Radiological Emergency Preparedness Program Comanche Peak Nuclear Power Plant - TX 1--- --------------- ------ ------------------

-- *--- ---Acronyms---------- -- ----- -------- -------- --

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I ARC CP DPS DSHS EAS EW EOC EOF EOP EPZ FEMA FMT HQ ICP JIC Kl LLEA ORO PPE RAC SJ\\E T/ACP TDEM

- American Red Cross

- Comanche Peak Nuclear Power Plant

- Department of Public Safety

- Department of State Health Services

- Emergency Alert System

- Emergency Worker

- Emergency Operations Center

- Emergency Operations Facility

- Extent of Play

- Emergency Planning Zone

- Federal Emergency Management Agency

~ Field Monitoring Team

- Headquarters

- Incident Command Post

- Joint Information Center

- Potassium Iodide

- Local Law Enforcement Agencies

- Offsite Response Organization

- Personnel Protective Equipment

- Regional Assistance Committee

- Site Area Emergency

- Traffic and Access Control Point

- Texas Division of Emergency Management 41

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