ML20087J672

FEMA - Final Report for the March 13, 2019, Grand Gulf Nuclear Station Radiological Emergency Preparedness Plume Exercise

ML20087J672
Person / Time
Site:	Grand Gulf
Issue date:	03/16/2020
From:	US Dept of Homeland Security, Federal Emergency Management Agency
To:	Office of Nuclear Reactor Regulation, NRC Region 4
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ML20087J954	List: ML20087J672 ML20087J693
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Download: ML20087J672 (92)

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l 1 Final After Action Report Grand Gulf Nuclear Station I Radiological Emergency Preparedness Exercise I Exercise Date: March 13, 2019 I March 16, 2020 I

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,i 1 Final After Action Report Grand Gulf Nuclear Station I l3adiological Emergency Preparedness Exercise I Exercise Date: rvlarch 13, 2019 I March 16, 2020

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

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I Radiological Eme_rgency Preparedness Program After Action Report

• 2019 Grand Gulf Nuclear Station I

Table of Contents I Page Table of Contents .......................... *..................*................................................................................ 3 I Executive Summary ......................................................................................................................... 5 Section 1: Exercise Overview ......................................................................................................... 7 I 1.1 1.2 Exercise Details ............................................................................................................. 7 Exercise Planning Team Leadership ....... ;......... :... ,....................................................... 7 1.3 Participating Organizations .......................................................................... ,................ 8 I Section 2: Exercise Design Summary ........................................................................................... 11 2.1 Exercise Purpose and Design ....................................................................................... 11 I 2.2 2.3 Exercise Core Capabilities and Objectives .................................................................. 11 Exercise Scenario Summary ........................................................................................ 15 I Section 3: Analysis of Capabilities ............................................................................................... 17 3.1 Exercise Evaluation and Results ....................... ;........................................................... 17 3.2 Summary Results of Exercise Evaluation .................. ,................................................. 17 I 3.3 Jurisdictional Summary Results of Exercise Evaluation ............................................. 19 3.3.1 State of Mississippi .......................................................................................... 19 I 3.3.1.1 3.3.1.2 State Emergency Operations Center .............................................. 19 Joint Information Center ................................................................ 21 3.3.2 Mississippi Department of Radiological Health .............................................. 22 I 3.3.2.1 Department of Radiological Health/ Dose Assessment.. .............. 22 3.3.2.2 Field Team Management ................................................... ~ ........... 25 I 3.3.2.3 3.3.2.4 Division of Radiological Health Field Team ................................. 29 Emergency Operations Facility Dose Assessment ......... :.............. 32 3.3.3 Claiborne County ............................................................................................. 33 I 3.3.3.1 3.3.3.2 Emergency Operations Center ....................................................... 33 Emergency Worker and Decontamination ..................................... 37 II I

3.3.3.3 3.3.4 Traffic Control Point.. ................. :.................................................. 38 Adams County ................................................................................................. 39 3.3.4.1 Emergency Operations Center ....................................................... 39 I 3.3.4.2 Reception Center and Congregate Care ........................................ .40 3.3.5 Copiah County ................................................................................................. 41 I 3. 3.5 .1 3.3.5.2 Emergency Operations Center ...................................................... .41 Reception Center and Congregate Care ................ ,....................... .43 I 3.3.6 Hinds County ................................................................................................... 44 3.3.6.1 Emergency Operations Center ...................................................... .44 3.3.6.2 Reception Center and Congregate Care ........................................ .45 I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station 3.3.7 Warren County ..... :....... :-: ....... *......... .- ..*;,_J..*.................................*........................ 47 I

3.3.7.1

• 3.3,7.2 Emergency Operations Center ...................................................... .47 Reception Center and CongregateCare .... :.: ............................ ;.: .. .48 I

• • 3:3.7:3 Medical Drill:* Vicksburg FireT>epartmeht& Ambulance Service 49 3.3.7.4 , Medical Drill: The Merit Health River Region Medical Center .... :53 Section. 4: ..Conclusion ............ ,......................................... ,.......... ,......,. ..*...... ,.................................... 55 I

Appendix A: Exercise Timeline .,.................... ,...... ,....... J.s, ***.**......****** , ******** : ****..*.....***** .:.......*.**.*** 57 Appendix B: Exercise Evaluators and Team Leaders ::.: ....... :: .................... :................................ 59 I

Appendix C: .Grand Gulf Extent of Play Agreement.. .'..... :****:*:*******************: ............,. .. '. ........ ~ ......... 61 I

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station Executive Summary***

I On March 13, 2019, the U.S. Departtp.{?i:tt of Homeland Security/Federal Emergency Management Agency Region IV, Radiolog~cal Emerge,ncy .Pr,eparedness Program staff evaluated I a.full participation plume exercise for (1:i.y Grand Gulf Nuclear Station.

The Grand Gulf Nuclear Station, operated by the Entergy Corporation is located in Claiborne I County, 29 miles south of Vicksburg and seven miles north of Port Gibson.* The 10-mile emergency planning zone encompasses portions of Claiborne County, _ Mississippi and Tensas Parish, Louisiana; it also includes a small-unpopulated portion of Warren County, Mississippi, I which is managed by Claiborne County. FEMARegion VI issues a separate report ori the evaluation of the Grand Gulf Nuclear Station exercise for Louisiana and Tensas Parish.

I The evaluation of out of sequence activities during the weeks of February 14 and February 25, 2019 is included in this report. These activities included: traffic control interviews; reception centers; congregate care and sheltering; emergency worker decontamination; and a medical I service drill. An evaluation of the demonstration for the correction of level 2 findings by the Mississippi State Department of Health on August 8, 2019 is also included in this report.*

I Federal Emergency Management Agency's overall objective of the exercise was to assess the level of State and local preparedness in coordinating and responding to a radiological emergency at the Grand Gulf Nuclear Station. The purpose of this report is to analyze exercise I results, identify strengths to be maintained and built upon, identify potential areas for improvement, and support development of corrective actions.

I This exercise was held in accordance with Federal Emergency Management Agency's policies and guidance concerning the exercise of State and local radiological emergency response plans I and procedures. The evaluation team conducted this exercise using Homeland Security Exercise and Evaluation Program methodology. The previous Federal evaluated exercise was conducted on March 29, 2017. The qualifying joint emergency preparedness exercise was I conducted on November 4-5, 1981.

Officials and representatives from the State of Mississippi; the risk county of Claiborne; the host I counties of Adams, Copiah, Hinds and W arre11; and numerous volunteers and other agencies participated in this exercise. These organizations demonstrated knowledge of their emergency response plans and procedures and implemented them I The Federal Emergency Management Agency did not identify any level 1 findings; however, five level 2 findings were identified. .

I Mississippi State Department of Health/Division of Radiological Health, finding 028-19-2.b. l-L2-0l. Current and accurate information on plant and environmental conditions was not always I available or used by Division of Radiological Health personnel when providing situational assessments and recommendations to decision makers. This finding was successfully resolved during the redemonstration on August 8, 2019;

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

Mississippi State Department of Health/Division of Radiological Health, finding 028-19-3.a.l-L2-02. Radiological emergency response team members received radiation doses higher than I necessary to perform tasks necessary to characterize the radiological plume. This finding was successfully resolved during the redemonstration on August 8, 2019; I

Claiborne County, finding 028-19-5.b.l-L2-03, Claiborne Comity news releases were not observed-to be coordinated with the Claiborne County Emergency Manag-ement Agency, the Mississippi Emergency Management Agency Emergency Operations Center, and the Joint I lnform~tion Center. Nor were the news releases reviewed and approved by Claiborne County Emergency Management Agency Director prior to release to the public and news media; I

Warren County, finding 028-19-3.a.l-L2-04. During the Medical Services Drill, the ambulance crew did not receive an emergency worker briefing prior to responding to a potentially, :

contaminated patient; I

Warren County, finding 028-19-6.d.l-L2-05. During the Medical Services Drill,the ambulance crew failed-to implementproper contamination cop.trol processes.- This led to the possible I

unnecessary spread of contamination ont0.th~;cre:'w,andpatient. **

During the 2017 exercise the Federal Emergency Management Agency identified three level 2 I

findings and two plan issu~s. During this exercise and August redemonstrations, findings 028-17-4.a.2-L2-03, 028-17-2.b.l-L2-02, and 028-17-5.b.1-L2-01; and issues 028-17-4.a.3-P-02 and 028-17-1.e.l-P-01 were resolved.

I The Federal Emergency Management Agency will provide an hnprovement Plan to the State of Mississippi that details the Strengths and Areas for hnprovement observed during the* exercise I

and explain the above findings in more depth. The hnprovement Plan is publishedunder a separate cover and classified "For Official Use Only" in compliance with Homeland Security Exercise and Evaluation Program_standards.

I The Federal Emergency Management Agency wishes to acknowledge the efforts of the many individuals who participated in the exercise and made it a success. The professionalism and I

teamwork of the participants was evident throughout all phases of the exercise.

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I Radi9Jogical Emergency Preparedness P;rogram After Action Report 2019 Grand Gulf Nuclear Station I Section 1: Exercise Overview I 1.1

• Exercise Details*

I Exercise Name .

2019 Grand Gulf Nuclear Station Radiological Emergency Preparedness Exercise I Type of Exercise***.

• Full-Scale Exercise I Exercise Date March 13, 2019 I Exercise Off-Scenario/Out-of-Sequence Dates February 14, 25-28, 2019 I

• Program*

. U.S; Department of Homeland Security, Federal Emergency Management Agencyi*

Radiological Emergency Preparedness'iBrogram ., . *.

I Mission

Response

I Locations Various, see Appendix C, extent-of-play agreement for exercise locations.

I Scenario Type Plume-Phase Radiological Emergency Preparedness Exercise I J.2 Exercise Planning Team Leadership I Robert Spence South Section Chief Federal Emergency Management Agency, Region IV I 3003 Chamblee-Tucker Road Atlanta, Georgia 30341 I robert.spence@fema.dhs.gov I

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Radiological Emergency Preparedness Program I After Action Report Gerald McLemore ' ' *' i '

2019 Grand Gulf Nuclear Station I

Emergency Management Specialist Federal Emergency Management Agency, Region IV *,

• 3003 Chamblee-Tucker Road

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Atlanta, Georgia 30341 gerald.mclemore@fema.dhs.gov I David Huttie Deputy Administrator I Mississippi Emergency Management Agency

1. lMEMA Drive Pearl, Mississippi 39208 I dhuttie@mema.ms.gov Robert Goldsmith I Office of Radiological Emergency Preparedness Mississippi Emergency Management Agency

1. lMEMA Drive

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I Pearl, Mississippi 39208 'a*:-.;,;

rgoldsmith@mema.ms.gov ... * '

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I Karl Barber Exercise Controller Mississippi State Department of Health/Division of Radiological Health I

570 E. Woodrow Wilson Dr.

Jackson, MS 39216 kbarber@msdh.ms.gov I

1.3 Participating Organizations I Agencies and organizations of the following jurisdictions participated in the 2019 Grand Gulf Nuclear Station Radiological Emergency Preparedness Exercise. I State Jurisdictions:

Mississippi Emergency Manageinent Agency I

Mississippi State Department of Health, Division of Radiological Health Mississippi State Department of Health, State Health Officer Mississippi Department of Public Safety .*'

I Mississippi Department of Transportation Mississippi Department of Agriculture and Commerce .

Mississippi Department of Environmental Quality' . :.

I Mississippi Department of Finance ;and Administration

• Mississippi Department of Human Services .

• Mississippi Fire Marshal's Office.

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I Radiological Emergency Preparedness. Program After Action Report 2019 Grand Gulf Nuclear Station I Mississippi Association of Public Works I Mississippi Public Utilities Staff Mississippi Military Department/National Guard Mississippi Office of Homeland Security I Risk Jurisdiction:

I Claiborne County Claiborne County Emergency Management Agency Claiborne County Board of Supervisors .

I Claiborne County Public Information Officer Claiborne County Fire Department Claiborne County Health Department I Claiborne County Hospital Claiborne County Public Transportation Claiborne County Road Department ,

I Claiborne County Schools Claiborne County Sheriffs Office Claiborne County Welfare Department .

I Claiborne County* Cooperative Service/Regional Coordinator.

Port Gibson Mayor's Office Port Gibson Police Department I Port Gibson Street Department Hermanville Fire Department I Host Jurisdictions:

Adams County I Adams County Department of Emergency Management Adams County Department of Human Services Adams County Department of Health I Adams County Fire Department City of Natchez Police Department City of Natchez Fire Department I Natchez Regional Hospital Natchez Fire and Rescue Department I Copiah County Copiah County Emergency Management Agency . .

Copiah County Board of Supervisors I

I' Copiah County Department of Transportation

• Copiah CountyFire Department ..

Copiah: County Health Department*:

I Copiah County Sheriffs Office ,

Crystal Springs Mayor's Office I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station

. Hazlehurst Mayor's Office  :. f I

- Hazlehurst Emergency Medical Services Hazlehurst Police Department I Hazlehurst School Districts Hinds County * > ... I

Hinds County Department of Emergency Management .

. . Hinds County Emergen~y Operati.ons Center Hinds County Community Coll~ge Police DepartIIlent I

• Hinds Co11nty-Utica Volunteer J<JreDepartment Hinds County Public Works Hinds Couf\ty Public School District I

Hinds County Health Department Hinds,County Sheriffs Offi.ce ,

Jackson. Police Department I

Jaok;son Fire Department ..

Raymond F.ire DepartII1ent

.. Clinton Police Department . '. ...:,

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Warren County Warren County Department of Emergency Management I

• . Warren County Volunteer Fire Department Warren County Sheriffs Office Warren County Police Department I

Warren.County Department of Human Services Merit Health River Region Hospital Vicksburg Police Department I

Vicksburg Fire Department Vicksburg Fire & Emergency Medical Services I Private Organizations:

-Alcorn State University I

American. Red Cross, Southwest and Mississippi Region Salvation Army.

Entergy Incorporated ,.

I AMR Ambulance Federal Agencies:

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. U.S, C:oast.Guard U.S. Nuclear Regulatory Commission; R~gion IV . * , j *

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I Radiological Emergency Preparedness f>rogram After Action Report 2019 Grand Gulf Nuclear.Station I Section 2: Exercise Design Summary I 2.1 Exercise Purpose and Design I The Federal Emergency Management Agency administers the Radiological Emergency Preparedness Program pursuant to the regulations found in Title 44 Code'of Federal Regulations parts 350,351; 352; 353 and 354.* Title 44 Code of Federal Regulations part I 350 codifies sixteen planning standards that form the basis* for radiological emergency response planning for state,.tribal;*and local governments impacted by the emergency planning zones established for'.each nuclear power plant site in the.United States.

I Nuclear Regulatory Commission regulations also codifythe'sixteen planning standards for the licensee. Title 44 Code' of Federal Re*gulations.part 350 sets forth the mechanisms for the formal review and approval of-state~ tribal, and local *government radiological I emergency response plans and procedures by the*Federal Emergency Management Agency. One of the Radiological Emergency Pt~paredness Program cornerstones established by these regulations is the biennial exercise of offsite;tesponse capabilities.

I During these exercises, affected state, tribal, and focal, governments demonstrate their abilities to implement their plans and procedures to :protect the health and safety of the public in the event of a radiological emergency at the nuclear plant.

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The results of this exercise, together witli review- bf the radiological emergency response plans, and verification of the periodic requirements set forth in NUREG-0654/FEMA-I REP-1, along with supplements through *the annual letter of certification and staff assistance visits, enabled the Federal Emergency Management Agency to provide a statement with the transmission of this final after action report to the United States I Nuclear Regulatory Commission, that the affected state, tribal, and local plans and preparedness are: (1) adequate to protectthe health and safety of the public living in the vicinity of the nuclear power facility by providing reasonable assurance that appropriate I protective measures can be taken offsite in the event of a radiological emergency; and (2) capable of being implemented.

I The State of Mississippi formally submitted the Radiological Emergency Response Plans for the Grand Gulf Nuclear Station to the Federal Emergency Management Agency, Region IV on May 22, 1981. The Federal Emergency Management Agency approved the I plans pursuant to 44 Code of Federal Regulations 350 on June 23; 1983. The qualifying joint emergency preparedness exercise was conducted on November 4-5, 1981.

I 2.2 Exercise Core Capabilities and Objectives I 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 I exercise objectives meet the Radiological Emergency Preparedness Program requirements and encompass the programs emergency preparedness evaluation areas.

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Radiological Emergency Pryparedness Program I After Action Report 2019 Grand Gulf Nuclear Station

• The critical tasks* to be demonstrated were negotiated with .the State of Mississippi and I

the counties of Claiborne, Warren, Hinds, Adams, and Copiah: The core capabilities scheduled for demonstration during this exercise were:

I Operational Coordination: Establish and maintain* a: unified and '-Coordinated .

• operational structure and process that appropriately .integrates all critical stakeholders and supports the execution of Core Capabilities.

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• Operational Communications: Ensure the capacity for timely communications in I support of security, situational awareness, and*operations by any and all means'available, among and between affected communities in the impact area and all response forces.

I Situational Assessment: Provide all decision makers with decision-relevant information regarding the nature and extent of hazards, any cascading effects, and status* of response.

I Public Information and Warning: . Deliver coordinated,. prompt, reliable, :and*

actionable information to the whole comr,nunity through.the use of clear, consistent, accessible, and culturally and linguistically appropriate methods to effectively relay I

information regarding any threat or hazard and, as appropriate, the actions being taken

'and the* assistance*,being *made available:*, *

' ' . ~ . I Environmental Response/Health and Safety: Ensure the availability of guidance and resources to address all hazards including hazardous materials, acts of terrorism, and natural disasters in support of the responder operations and the affected communities.

I On Scene Security, Protection and Law Enforcement: Ensure a safe and secure environment through law enforcement and related security and protection operations for I

people and communities located within the affected areas and also for response personnel performing lifesaving and life-sustaining operations . I

. Critical Transportation: Provide transportation (including infrastructure access and accessible transportation services) for response priority objectives, including the evacuation of people and animals, and the delivery of vital response personnel, I

equipment, and services into the affected areas.*

Mass Care: Provide life"'."sustaining services to the affected population with a focus on I

• hydration, feeding, and sheltering to those who have the most need, as well as support for reunifying families. I

• Public Health, Healthcare; and Emergency Medical Services: ,Provide lifesaving

• medical treatment via Emergency Medical Services and related operations and avoid additional disease and injury by providing targeted public health; m~dical and behavioral I

health support, and products to all affected populations.

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I I Radiological Emergency Preparedness Program After Action Report 2019 Grand Gulf Nuclear Station I The Federal Emergency Management Agency radiological emergency preparedness I , :objectives for this exercise w.ere..as follows:, ,

Objective 1: Demonstrate the ability to provide direction and control and make I protective action decisions through the state emergency operations centers; county emergency operations centers:, and field activities by exercise play and 'discussion of plans and procedures.

I Objective 2:

• Demonstrate the. ability to provide protective action decisions affecting state and county emergency workers and ;public through exercise play and discussions of plans .

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• and procedures.

Objective 3: Demonstrate the ability to implement protective actions for.state and county I ** emergency workers and pµblic, through, exercise demons.tration. _ _._

Objective .4: Demonstrate the- ability to* perform, plmne-'-phase field measurements and I

• analysis. utilizing* State fie14: teams _through exercise play. and discussion of plans.. and

_ procedures.. . .* , : .*, .-. .i.

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I Objective 5: Demonstrate the ability to activate the.:prompt alert and notification_ system utilizing the prompt notification system and emergency alert system through exercise play.

I Objective 6: Demonstrate the effectiveness of plans, policies, and procedures-in the joint information center for joint (public and private sectors) emergency information

-1 communications.

Objective 7:. Demonstrate the ability to monitor, decontaminate, register, and shelter I evacuees and emergency workers,,

Objective 8:, Demonstrate the ability to provide dose projection and protective action I decision making for the plume phase.

Objective 9: Demonstrate the ability to provide transport, monitoring, decon,tamination I and medical services to contaminated injured patient.

The state of Mississippi radiological emergency program objectives for this exercise were I as follows:

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.,Objective. 1: *Demonstrate emergency operations management through mobilization, direction and control,.communicatioiis processes and equipment and.supplies to support emergency.operations utilizing plans and procedures.

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station Objective 2: Demonstrate protective action decision making by employing emergency I

worker exposure control, dose assessment, protective a.ction recommendations, protective action decisions, and consideration for the protection of persons with disabilities and

.a~ces~/fqQ~tional needs. for the emergency eyent ~Q. ~pordination with decision makers.

I Objective 3: Demonstrate protective action implementation with implementation of I emergency worker exposure control, implementat,ioµ of a potassium iodide decision for institutionalized individuals and the public, implementation of protective actions for persons with disabilities and access/functional needs, and the implementation of traffic I

.and acc~ss control as prescribed by plans and procedures.

Objective 4: Demonstrate field measurement and analyses by means of plume phase I field measurements and analyses and post-plume ph~se field :µieasuremeqts and sampling as the situation dictates and in accordance with plans and procedures.

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I Objective 5: Demonstrate emergency notification/public infopnatjon through activation of th~ prompt .alert and notification .system .and emergency 1nforrµation and instructions for the public and meq.iain r,elatio,n;to, ~~t~'1lished plans, al}d pro~~dures ..

I Objective 6: Demonstrate support operations/facilities by means of monitoring, decontamination, and registration of evacuees, monitoring and decontamination of I

emergencyworkers and their equipment and vehicles, temporary care of evacuees and transportation and treatment of contaminated injured individual*s in accordance with established guidelines.

I Additionally, each capability is linked to several corresponding capability targets and critical tasks to provide additional detail. Specific targets and tasks are listed in the I

Exercise Evaluation Guides. Th,e objectives align with the listed capabilities as indicated below: ' I

• Objective 1: Core Capability - Operational Coordination, Operational Communications. . I

• Objective 2: Core Capabilities - Operational Coordination and Situational

. Assessment. I 3:

• Objective Core Capability - Environmental Response/Safety and Health, On-Scene Security, Protection, and Law Enforcement, Critical Transportation, Mass Cq.I"e, and Public Health, Healthcare, and Emergency Medical Service~.*.

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• .. Objectivei Core Capabilities - Situational Assessmep.t, Eiwironni~niaf Response/Safety and Health. * * ,* * '

• Objective 5: Core Capabilities - Operational Coordination and Public Information I and Warning.

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Objective 6: *Core Capability-Public Information and Warning.

• Objective*7: Core Capability.:_ Environmental Re*sponse/Safety and Health*and Mass I Care.

• Objective 8: *Corn Capability_: Situational Assessment and Environmental I Response/Safety and Health.'***

• Objective 9: Core Capability--:'Public Health, Healthcare, and Emetg'ency Medical I Services.

2.3 'Exercise Scenario Summary .

• I The following is a summary of the licensee's formal scenario submitted to the Federal Ernergency Management Agency on December 13, 2019 an*d*approved on February 7, I 201 9; The s*cenario and supporting doci.mients. were ac:foquate for the demonstration of*

the exercise objectives and associated technical crit~ria identified in the extent of play agreement.

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Ke Time~'

I 0730 0814 Exercise be ins Notification of Unusual Event Erner enc Classification Level declared 0848 Alert Erner enc Classification Level declared I 0954 0944 I 1141 1347 Exercise terminated I The exercise begins at 0730. At 0800, a tornado passes through the switchyard, causing a reactor scram with not all controls rods inserting. Due to the scram, a small crack develops on the feedwater line. At 0803, Claiborne County Emergency Management is I called to inspect the roadways. By 0825, an Unusual Event should.be de<::lar~d based on Emergency Action Level Sierra Uniform 1 for loss of offsite power. At 0830, Claiborne County Emergency Management informs the licensee that all mads are_ clear to the site.

I At 0840, the diesel generator trips due to an oil leak and th~'feed~ater leak rate increases.

By 0855, an Alert should be declared based on Emergency Action Level Sierra Alpha 1 I for the single power source faih~re. By approximately 0945, the Joint Information Center will becbtne operational. . . . .* . . .. .

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

At 1005, a Reactor Core Isolation Cooling steam leak ,eccl.irs with failure of the isolation valves to close. A seal failure on the access door causes it to malfunction and an offsite radiological release begins from the auxiliary bujJdin.g*through tpe. Standby Gas I Treatment system. By 1020, a Site Area Emergency should be declared based on Emergency Action Level Foxtrot Sierra 1 for the l9s_s*of two fission barriers.

I At 1135, offsite field monitoring teams will dete.ct the release with, a magnitude greater than protective action guide beyond the site boundary, which is approximately at a half of a mile. By 1150, a General Emergency will be. .dedared. based on Emergency Action I

Level Alpha Golf 1.2 for doses greater than 1 :rem tqtal effective dose equivalent .or 5

.roentgen equivalent man tliy:roid committed dose e:quiv,alent beyond the site bo.u.ndary.

Tp.e criteriawill be met for a rapidly progressing severe accident.with resultant protective I

• action :recommendations to evacuate all sectors. out to 2 miles and the downwind sectors of Alpha, Bravo, and Charlie out to 10 mile.s ap.d consider use of potassium iodide.

These sectors correspond to Protective Action Areas 1, 2 alphas, and 7 in Mississippi.

I At 1215, the Operations crew will depressurize tp.e re~ctor and the.driving force for the release will be reduced. At 1240, the leak willb,e isolated, t.errajnating the rel.ease. At I

. 130q, t~e-ex~rc;;ise .\Y~ll be. t~p'1,in~te.d; '. . , L :, , .*. ...

I Meteorological conditions at the. beginning of the exercise reflect the tornado conditions and are wind direction from 185 degrees, wind speed of 27 miles per hour, and stability class of "Delta". At 0850, the wind speed peaks at 40 miles per hour with a wind direction from 235 degrees. Meteorological conditions *around the time of relea~e I

• indicate a wind speed of 7 miles per ho'ur with a wind direction from 197 degrees with *a "Delta". stability class. These conditions remain constant throughout the remainder of the exercise.

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• The dose proj~ctions indicate protectiye action guides are exc~eded beyond the site boundary. Field team surveys will reach a maximum value of 43 nµlliroentgen during I

the exercise. .Radioiodine is present in the field monitoring sample data. Dose projections indicated a projected thyroid dose greater thari 5 roentgen equivalent man be.yond the site boundary. Radioiodine levels in this scenario are sufficient to prompt I

q.iscus~ion of_potassium iodide for emergency workers and the general public.

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station

• Section 3: Analysis of Capabilities I 3.1 Exercise Evaluation and :Results I This section contains the results and findings of the evaluation of all jurisdictions and functional entities that participated in the March 13, 2019 plume pathway exercise and out-of-sequence activities of February 14 and*February 25-28, 2019. **

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• Ea'.chjurisdictiori and functionalentitywere evaluated based on the demonstration of

• Core Capabilities; capability targets and critical tasks andthe underlying radiological I

• emergency preparedness criteria'asdelirieated 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 I indicated by the use of the.following terms:

~. *-~-  :

• M: Met (no unresolved level 1 or level 2 findings assessed and no unresolved I findings from prior exercises) *

• ~*, ' 1: ' Level, ffinding assessed' ;. *.. * * '

• 2: Level 2 finding assessed or an unresdlvecffovel i finding(s) froin ~ prior I exercise

• P: Plan issue I ** N: Not demonstrated 3.2 Summary Results of Exercise Evaluation I The Homeland Secutity Exercise and Evaluation Program evaluation methodology is an analytical process used to assess the demonstration of specific capabilities during an I exercise. A capability provides a means to perform one or more critical tasks under specified *conditions and to specific performance standards'. Core Capabilities form the foundation of the Federal Emergency Management Agency Region. TV Radiological I Emergency Preparedness Program evaluations. The Core *capability summaries below provide an overall combined assessment of state and local jurisdictions ba~ed.upon their collective demonstrated performance as it relates to the specific Core Capability'. Each I jurisdiction's standalone capability summaries are listed in Section 3:3 of this report.

Operational Coordination: Key leadership personnel from the State of Mississippi and I affected counties established and maintained a unified and coordinated operational structure. This enabled the unified command to provide effective and responsive direction and control over the incident. The decision-making process integrated critical I stakeholders, enabling protective actions and subsequent decisions to be made in a timely manner. The Homeland Security Information Network video.conference line provided a I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

platform for face-to-face discussions. This netw0rk allowed.for real-timeinterface and enhanced the*coordinatiort between-the different'a:gencies;' Placing a dedicated liaison froin the Lou'isiana' s Governor's Office of Homeland*Security' ahd Emergency, I Preparedness in the unified command may strengthen- the response between the two states. -' ' * "'* 1

• I CriticalTransportation: Government officials from Claiborne County demonstrated the ability to implement protective actions for the four schools located within the 10-mile emergency-planning zone of the Grand Gulf Nuclear Station. The .officials explained I

through interview the process and procedures' for*safeguarding students, staff, and faculty at these schools. * * ' ;,.

I Situational Assessment: State dose assessment personnel exhibited *challenges in performance while assessing radiological and plant conditions when providing protective action recommendations to decision makers. The 'specific challenges. are further"detailed I

in section 3 of this report> The decision makers were eventually provided' with relevant information regarding assessed radiological and plant conditions*. This information allowed the decision makers to make inquiries* to understand the extent -of the.hazards and I

to make the appropriate*prote:ctive adticm decisions., *  :*

Operational Communications: Muitiple communications systems-were demonstrated I

throughout the exercise. Primary and secondary systems along with web-based incident management software aided the multiple jurisdictions in Mississippi to maintain a unified operational response. These systems ensured the capacity for timely communications in I

support of a coordinated response without' failure. Utilization of these systems were not demonstrated with the State of Louisiana. I Environmental Response/Health and Safety: State Radiological Health personnel demonstrated with significant challenges their ability to assess radiological' and plant condi.tions and make recommendations and decisions. Challenges with field team I

procedures, field, team management, and knowledge of radiological sampling and survey processes were observed. These problems lead to challenges in assessing radiological conditions and providing recommendations. Risk and host county emergency workers I

successfully demonstrated their ability to perform radiological monitoring and decontamination bf emergency workers and evacuees during out-of-sequence activities. I

, Public Information and Warning: Alert and notification of the public was successfully achieved by simulated siren activation in conjunction with the activati<;m of the -

emergency alert system. Supplemental news releases and formal media briefin*gs in the I

joint information center provided detailed instructions on what protective actions the public needed to take. Soine challenges exist with the Claiborne County news release I approval and coordination process and are further detailed in section 3 of this report.

I I

• l,8 I

I Radiological Emergency Preparedness .Program I After Action Report 2019 Grand Gulf Nuclear Station On Scene Security, Protection:and Law Enforcement: Claiborne County law I .. enforcement and roctd depru:tmel):t emergency workers effectively demonstrat.ed the ability to establish traffic and acc.ess control points in support of the Grand Gulf Nuclear Station. Their coordinated support of the precautionary and .protective action decisions I by the local emergency management directors followed established procedures ..

Mass Care:. Host Counties;Adams, Copiah, Hinds and Warren, demonstrated the ability I

• to provide services and accommodations for evacuees during out-of-sequence activities .

. These activities included evacuee r¢ception and. registration of evacuees at designated facilities. Representatives from the, Departmentof Human Resources and volunteers I from the American Red Cross aided in the demonstrations.

Public Health, Healthcare, and Emergency Medical Services: :Puring .out of.sequence I activities, Vicksburg Fire Department Ambulance Service responders in conjunction with Merit Health River Region Medical Center staff demonstrated.that they can transport and

. treat a contaminated injured individual. Some challenges W(?re observed with the I ambulance service. with contalllination control: Following e.stablished protocols, the.

.. .Hospital: staff demonstrated the..capability to access, monitor, and decontaminate the; patient without delay while treating his:*injuties .andprev~nting_cro~s-contamination.

I 3.3 Jurisdictional. Summary Results .of Exercise Evaluation*

I 3.3.1 State of Mississippi 3.3.1.1 State Emergency Operations Center.

I Operational Coordination Capability Summary: The Mississippi State Emergency Operations Center staff demonstrated the ability to mobilize, establish, and maintain a I unified operational response to a simulated radiological incident at the Grand Gulf Nuclear Station. Coordination with supporting state agencies and Claiborne, Hinds, Adam, Copiah, and Warren counties was observed during the exercise. Available equipment and supplies were enough to support emergency operations. Communications were operational without fail as well.

The Mississippi State Warning Point staff received notifications ofan emergency classification at the Grand Gulf Nuclear Station and quickly provided accurate information to both state and local offsite response organizations. The systems,usedto send and receive I messages were efficient and effective. State emergency operations center support staff were mobilized using an electronic notification system that provided an accurate picture. of I * .*.available and responding personnel.

I I

'1;9 I

Radiological Emergency Preparedness Program I After Action Report . 2019 Grand Gulf Nuclear Station I

The Operations Chief kept state emergency operatioris center personnel informed of the incident status by conducting frequent staff briefings. Protective action recommendations were provided from the licensee and verified by Mississippi State, Department of Health, I Division of Radiological Health staff. Other state, federal, and utility representatives participatedih coII1IJ1and. meetings to provide guidarice on protective actions including the use of potassium iodide. The Governor's Authorizetl"Representative presented*this I information to ill Mississippi stakeholders forconsideration and concurrence in the protective action decisions. Responsible agencies worked together effectively to implement

• • precautionary and protective measures for the public and emergency workers. Emergency I

• operatidhs center staff and leadership used plans and procedures to guide theirresponse.

This kept them on track and helped to avoid missing response actions.; Senior leadership

• . maintained a proactive approach to the response by consistently reviewing and discussing I

actions that would be taken if conditions worsened. Incident status and response actions were well coordinated with all Mississippi stakeholders. I For this capability the>following Ra:diolb'gical Emergency.Preparedness criteria were MET:

'La.1, l.c.l, l.d.l, l.e.1/2:b:2.. *

• I

a. Level 1 Finding: None

\' /.

b. Level 2 Finding: None I

c. Not Demonstrated: None I

d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findirigs - Unresolved:, None I

Operational Communication: Mississippi Emergency Management Agency ensured timely communications in support of operations among the *affected risk and host counties I

• for the Grand Gulf Nuclear Station. Multiple communication systems were available and demonstrated during the exercise and no failures were observed. Coordinating actions with other stakeholders was primarily accomplished over the Homeland Security Information I

Network via video teleconference. Communication of response actions with the State of Louisiana and Tensas Parish was observed in the Joint Information Center: I

.

• Forthis capability the following Radiological Emergency Preparedness criteria were MET:

l.d.L * . . I

a. Level 1 Finding: None

h. Lev~l 2 Finding:' 'None. I

c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I

I I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station

~. *Prior Level 2 Fin~ings-: Un,resolved: ,None I 3.3.1.2 Joint Information Center; ,. ... , _ ,,,*; \"'

I Public Inform~tion and Wa,rning *Capability Summary: :The ability t.o provide coordinated ei;nergency information and instructions to the public and media was demonstrated at the Mississippi E111ergency Management Agency's Joint Information I Center. Representatives from the States of Mississippi and Louisiana, Entergy, Claiborne County, and 'rensas Parish, were present. These representatives provided a unified effort by

. establishing a joint information system for delivery .of emergencyinformation to the public I and media. The Mississippi Emergency Management Agency Director of Ex,temal Affairs served as the lead spokespei:son for the state.and the public information officei:,served as the

• .. state's joint information center manager.

I The joint information center is collocated with the state emergency operations center and served as the official dissemination point. for information -regarding the response to this I emergency. Activation was accomplished in accordan.ce,withjurisdictional plans following the declaration of an Alert.

• : ., , . ~ .* * ** i I Message preparation, including emergency alert system and supplemental news releases, were consistent with information disseminated during news meclia briefings, Three formal media briefings were held and a total of three news releases were distributed during the I exercise.

The rumor control function was performed by personnel f{om the utility and the state and I operated in the confines of the joint information center. Rumors and trends were handled with a sense of urgency, though no trends were identified that warranted being brought to the attention of the external affairs director.

I Ample space, redundant communications and sufficient equipment and supplies to support emergency operations were tested and used during the exercise. Primary and backup I communications systems were fully functional and there were no failures during the exercise.

I The combined effort of multiple agencies led to the successful demonstration of this core capability through the coordination, development, and dissemination of emergency public I information. The successful demonstration .of events fully. met this critical task (criterion 5.b.l). Therefore, level 2 finding 028-17-5.b.l-L2-01 is resolved for the Mississippi Emergency Management Agency, Joint Information Center.

I ' ~- * 'I For this capability the following Radiological Emergency Preparedness_.criteria were MET:

l.a.l, l.d.l, l.e.l, 5.a.l, 5.b.l * ,, * *

• I i .*i, I

,21

~

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

a. Level 1 Finding: None

b. L~vel2 Fin~ing~

.. : ' . ~ . . . . None I

c.

• Not Demonstrated: -None * 'I l 0 2

d. Prior Level Finding - Resolved. I Issue Number: 028-17-5.b. l-L2-0l

• Core-Capability/Criterion: Public lnforniatiOil' and W arning/5.b: 1 I

Condition: Message development protocols were not completely followed by the Jbint Information Center during the exercise,*whieh could have confused the public I

regarding the actions they-were to take.,

Resolution: The combined public information effort of multiple agencies artd levels I

of management, led to the successful demonstration of this core capability through the coordination, development, and* dissemination :of emergency public information.

• Mississippi newsreleases w~re*ptepared*bythe,M.ississippi Emergency Management I

Agency public-infoimation officer an:d approved in the state emergency operations

.center-following-set protocols* as *dutlined. in the, exterrtal affairs,.standard operating procedure.

• I

e. Prior Level 2 Findings - Unresolved: None I 3.3.2 Mississippi Department of Radiological Health 3.3.2.1 Department of Radiological Health/ Dose Assessment I

Situational Assessment Capability Summary: I The Mississippi State Department of Health, Division of Radiological Health personnel demonstrated, with significant challenges, the ability to assess radiological and plant conditions and to provide protective action recommendations to decision makers in response I

to a radiological incident at the Grand Gulf Nuclear Statiori. Personnel arrived at the state emergency operations center when notified of the Alert. The Grand Gulf Nuclear Station maps were displayed on the walls and individual work stations were available for each I

person, including a computer, references, and office supplies. The state emergency operations center had sufficient equipment, communications, and supplies to support emergency operations. * -

I Dose assessments were performed at the emergency operations f<lcility ~d then verbally passed to the State Radiological Accident Assessment Officer ~t th~ stkte emergency I

operations center. The dose assessment team gathered the information for changing plant conditions to assess the radiological release. The dose assessment results compared closely I with utility dose projections.

I

22 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I Based on the meteorological conditions, rapidly progressing event, degrading plant conditions, and the onset of a radiological release, the State'Radiological :Accident Assessment Officer recommended the evacuation of Mississippi populations two miles I around and 10 miles downwind of the plant, prior to tbe General Emergei;i.cy declaration and licensee protective action recommendations. ** ** * * * * * '**. * * * * **

I The State Radiological Accident Assessment Officer evaluated the subsequent dose assessments to validate the protectiye. action recommendations and assess* the potassium iodide ingestion for emergency workers. However, the current Food and Drug I Administration guidance for emergency worker potassium iodide ingestion was not included in the plans or procedures. In addition, there was no method to document protective action recommendations or potassium iodide authorization from the State Health Officer.

I *Public doses Wt'?r.e also calculated by the radiological assessment system for consequence analysis software on the five-source term runs. The RadiologicaLDose Assessment I .,Coordinator received the results of dose assessments performed by Grand Gulf staff,

• -entered the pertinent release and; meteorol9gical data into the radiological assessment system.for.consequence,.analysis .software,: and;produce.d dose estimates within 15 I minutes that agreed within a factor of lO .relative to those provided by the Grand Gulf staff. Although not warranted by the dose assessment calculations provided, by the Mississippi Department of Health staff assigned to the emergency operations facility, the I State Radiological Accident Assessment Officer (located in the State emergency operations center) recommended a precautionary evacuation of Areas 1, 7, 2A, and 2B at 1046, following the onset of the radioactive material release .. At the time this I recommendation was made in the state emergency operations center, the staff in the Grand Gulf emergency operations facility had not recommended any such protective actions and were not aware (at the time) that the State had made such a recommendation.

I The sequence of events did not fully meet. the critic;al task (criterion 2.b. l)., Therefore, level 2 finding 028-19-2.b.l-L2-01 is assigned to the dose activity at the state emergency operations center. This finding was later resolved during a limited redemonstration on I August.8, 2019.

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

I 1.a.l, l.c.l,J.d.l, l.e.l; 2.a.l, 2.b.1,2.b.2.

a. Level 1 Finding: None

• I ,'

b. Level 2 Finding:

Issue Number: 028-19-2.b.l-L2-0l Resolved I ' Co~e Capability/Criteritm: Situational* Assessment/2,b.1'

, . . :. . '. *. ' ';* .. ! . *, . ' l ** . - *  :' .- '

I I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

Condition: Current and accurate information on plant and environmental conditions

'was not always available or used by Division of Radiological Health personnel when providing' situational assessments and recommendations to*decision makers. I

, *Analysis:* During the exercise, Division of RadiologicaLHealth personnel performed the following actions which, when taken together, resulted in incomplete information I being provided to decision makers.

1. Radiological emergency response teams took unnecessary measurements and air I

samples while deployed in the plume. Thatresulted in a: delay in obtaining, communicating., and analyzing the results.-of appropriate measurements and samples.

I

2. When field counting results of air samples were provided to Division of Radiological Health dose assessment personnel, they did not understand that only analysis *of the silver zeolite cartridge (and *not the charcoal *cartridge) would I

provideusefulinformation to characterize theplume.

3. Division of Radiological' Health staff in the emergency operations: facility used a Dose Assessment Fo'rm to conveyradiologjcal assessment data. *This form was I

submitted to the state radiological acciden:vassessment officer at the State Emergency.Operations Cen:ter,with several key ,items 6n the form incomplete.

4. When utility staff at the emergency operations facility-announced that an action I

had been taken to mitigate the radiological release, this information was not promptly communicated by,the emergency operations facility* coordinator to the state radiological accident assessment officer. The state radiological accident I

assessment officer informed decision makers that radiological release was '

increasing when it had actually been mitigated. I Possible Cause:

1. The radiological emergency response team procedure. provided insufficient detail on appropriate radiation measurements.to take while traversing the plume.

I

2. The radiological emergency response team procedure called for taking two air samples in a given location-one using a silver zeolite cartridge and one using a

. charcoal cartridge ;

I 3 .. Enough emphasis was not placed on completing the Dose Assessment Form and

• promptly forwarding information on changing plant conditions.*. I

Reference:

1'. State of Mississippi, Procedures for Radiological Emergency Response Team, Function Annex 17, Revision #13, January 20, 2019 I

2. NUREG-0654/FEMA REP-1; C.6;f;K.3 .a;K.4

3. Mississippi Radiological Emergency Preparedness Plan, Revision 18, October 2018, Annex E I

I I

I' 24 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gul{Nuclear Station Effect:,  : * *.(.* ;-

• I *. 1. The initial protective* action .decision to eyacuate certain protective action areas in the emergency planning zone was- made based on:plant condit.ions. For this incident, no additional protective actions were necessary to protect the health and I . safety of the public.. ,However, in an actual event, providing outdat~d, incomplete, or incorrect informatiorHo decision makers could result in proper protective actions not being taken.

I Resolution:. . ,...:*,.

1.

• Following the exercise;,Division of Radiological, Health personnel revised their I procedures to provide appropriate detail on radiation measurements to be taken while traversing the plume, to modify the air sampling process to take only one sample with a silver zeolite cartridge, and to add checklists for the emergency I operafams facility coordinator .and state radiological: accident assessment officer to ensure appropriate i.nformationjs shared in .a timely manner..

2. Several days of training on the updated procedures-were provided to Division of I Radiological He.althipersonnel and .other:Misstssippi St.ate Department of Health

• *. ,personnel who may respond to an incident at Grand Gulf. ,

3. During.a limited redemonstration:on,A:ugust 8, :2019; personnel.on two I radiofogical emergency response;teams suce,essfuHy demon_strated the ability to take appropriate radiationmeasµrements and air samples. Division of Radiological Health personnel also. successfully demonstrated collecting, I analyzing, and providing current and accurate information to decision makers.

3.3.2.2 Field Team Management I Environmental Response/Health & Safety Capability Summary: The Mississippi State Department of Health, Division of Radiological Health personnel demonstrated, with I significant challenges, the ability to manage and control field teams to obtain sufficient information to help. characterize the release and to control radiation-exposure.

I The Field Team Coordinator arrived at the State Emergency Operations Center after receiving an alert notification. The Grand Gulf Nuclear Station maps were displayed on I the walls of the facility,. However, the field team coordinator only had small five-mile and ten-mile maps located at the coordinator's work area for tracking field team locations and activities. These maps were too small to display team locations and track radiological survey activities. The field team coordinator had a radio for communicating I with the field teams and did not experience, any problems with cofnmunications throughout the exercise.

I ' i **

I I

25 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

The field team coordinator provided the field teams with direction concerning sampling locations and driving directions. Although the coordinator was aware that the field teams

• were in the -plume, the coordinator did not advise the teams to minimize time in the area I or monitor the time they spent in the plume. This could result in field team members receiving imnecessary radiological exposure or even getting over* exposed. Therefore, level: 2 finding 028-19-3. a.. l-L2-02 *is assigned. *The field team coordinator logged all I radiological survey results and dosimeter readings from the 'field teams.

The fieldteam_coordinator and licensee's emergency operations facility coordinator I

worked together on where field teams should be located. However, when it was necessary for .field teams to obtain air samples the** field team coordinator and emergency operations coordinator did not know whattype of air sample cartridgethe field teams I

should use to collect the sample: Instead*ofinquiring with the Grand Gulf radiological staff the coordinator chose to have the field teams take air samples with both types of cartridges.

• Neither'wa.s sure* what type should be Used -nor why a Certain type of cartridge I

would be better-than the other type. When asked which sampl'e cartridge 'results they

• would use for determining 'the radiological content of:the release they were not sure and

, provided the.results* of both samples- fd:r do*se assessment without any clarification. The I

• 'use of incorrect air saniple da;ta could resulVin erroneous protective actiori.

recommendations, for the :public. 1lhe :sequence of events did not fully meet this Critical task (criterion4.a.2). Therefore, the previous level 2 finding 028-l 7-4.a.2-L2-03 remains I

open.

During a limited redemonstration on August 8, 2019 both finding 028-19-3.a.l-L2-02 and I

finding 028-17-4,a.2-L2-03 were resolved.

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

I l.a.l, l.d.l, l.e.l, 3.a.l, 4.a.2.

a. Level 1 Finding: None I

b. Level 2 Finding:

Issue Number: 028-19-3.a.l-L2-02 Resolved I

Cor~ C~pability/Criterion: Environmental Response/Health and Safety/3.a. l I

Condition: Radiological emergency response team members received radiation doses .higher than necessary to perform tasks necess.ary to characterize the radiolo'gical' plume. . . . .

I Analysis: During the exercise, Division of Radiological Health personnel performed the following actions which, when taken together, resulted in radiological emergency I

response teams spending significant unnecessary time in the radiological plume.

Team members also were not directed, to ingest potassium iodide, resulting in higher thyroid radiation doses.

I I

26 I

I *Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I . 1. Radiological emergency. respc;mse teams took unnece~sary radiation measurements while traversing the plume .. One team stopped frequently while traversing to obtain dosed-window and open-:-wjndow rapiationmeasurements.

I While taking open-.anct closed-windowxeadings at selected-points (e.g.

centerline, air sampling location) is. important, stopping to talce additional readings is not.

I 2. When directed to take air samples, radiological emergency response teams took one air sample- using a*silv_er zeolit~ cartridge and one using a charcoal cartridge.

Qne team only,had.one,operational.air sample pump, ,resulting i.n.the team waiting I for the.first sample to. be completed before starting the secqnd sample .. For a nuclear power plant incident, taking an air sample using a charcoal cartridge in

• addition. to one using a sjlver zeolite cartridge provides no additional useful I information: *

• . 3. The radiological emergen.cy response team coordina,tor occasionally spent long

• . periods (greater than :30 minutes) without coptacting, a team. ,

I i.,

. .4. Division of Radiological Health pr9cedures only ,called for team members to

.ingest.potassium iodide ifp,i;ojectedthyroid.doses were aboye25 rem .. Therefore, team members were .not instructed,to:ingestpotassimn iodide.* However, that dose I level exceeqs current Food: andJ;)rug Administration guidelines;,

Possible Cause:

I 1. The radiological emergency response team procedure provided insufficient detail on appropriate racliation*measurements to take while traversing the plume.

2. The radiological emergency response team procedure called for taking two air I samples in a given location-one using a silver zeolite cartridge and one using a charcoal cartridge.

,I 3. Division of Radiological Health procedures did not include a requirement for the radiological emergency response team coordinator to contact teams on a regular basis.

4. Division of Radiological Health procedures had not been ,updated to reflect I current Food and Drug Administration guidelines.

Reference:

I 1. State of Mississippi, Procedure*s for Radiological Emergency R~spon~e Team, Function Annex 17, Revision #13, January 20, 2019 . .

2. NUREG-0654/FEMA REP-1; C.l; ff12; I.7,8;11; J.10.a; K.3.a; o;'K.4; I 3. Mississippi Radiological Emergency Preparedness Plan, Revision 18~ October 2018, Annex E.

I I! ..,

I I

... 27 I

Radiological Emergency Pre,paredness Program I After Action Report Effect: * . , . , ..

2019 Grand Gulf Nuclear Station I

• 1. *The members of the radiological emerge*ncy*response teams received additional radiation doses while performing unnecessary;fasks in the.plume. Also, thyroid I doses to team members could easily have-been:reducedbyingestion of potassium iodide.

• In the short term, higher doses could result in team members reaching administrative dose limits and therefore not being able to perform vital functions I

• in characterizing the plume .. In the longer-term, higher dqses could result in adverse health effects for some team members.

I Resolution:

1. Following the exercise, Division ofRadiologicalHealth personnel revised their

• procedures to provide appr.opriate. detail on radiation measurements tci be taken I

while traversing the plume, to modify.,the air sampling process to take only one sample with.a silver zeolite cartridge,.and to ensure regular communication between the teams and the radiological emergency response. team coordinator.

I

• 2 .. Several days,of training on the updated procedures were pn)vided to Division of

• Radiological "Health personnel and other Mississippi -State' :O~partment of Health personnel who may.respond to an.incident at Grand Gulf.

I

3. During a limited redemonstration on August 8, 2019, personnel on two radiological emergency response teams successfully deinonstrated the' ability to take appropriate radiation measurements and air samples. The teams maintained I

frequent contact with the radiological emergency response team coordinator.

.4. The state health officer issued a letter authorizing radiological emergency response team members to ingest potassium iodide prior to deployment, I

• regardless of the projected thyroid dose. Division of Radiological Health procedures were revised to instruct team members to ingest potassium iodide prior to deployment. During the redemonstration, team members ingested I

potassium iodide in accordance with the revised procedures.

c. Not Demonstrated: None I

d. Prior Level 2 Fin~gs - Resolved: I IssueNumber.: 028-17-4.a.2-L2-03 ,

Core Capability/Criterion: Environmental Response/Health & Safety /4.a.2.

I Condition: *The.Mississippi Radiological Emergency Response Team Coordinator failed to instruct the field teams to utilize a silver: zeolite cartridge for obtaining an air I

sample. The Radiological Emergency Response Team Coordinator never instructed

• either field-team to make an attempt to locate the centerline of the plume. The

. coordinator also allowed sigrtificanttime to pass before finalizing _airbor:Q.e activity I

.. *calculations and providing that data to dose assessment for confirmation of projected dose. The Radiological Emergency Response Team Coordinator was unprepared and I I

1 28 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station had little knowledge on how to perform the activity calculations on the field Estimate I of Airborne Activity Form. Shortly after the release, a field team*coriducted an air sample in the plume. Thatteam was then sent to low background area to stage and await further instruction instead of obtaining more data*or locating the centerline.

I Resolution:

1. Following the .exercise; Division of Radiological Health personnel revised their I procedures to provide appropriate detail on radiation measurements to be taken while traversing the plume, to modify the air sampling process to take only one sample with a silver .zeolite cartridge, and to ensure regular corn.Iilunication I *between the teams and theradiological emergency response team coordinator.

2.

• Several days of training .on the updated procedures were provided to Division of

• • Radiological Health personnel and other Mississippi .State Department of Health I .

• personnel who may respond to,an incident at Grand Gulf.

3. During a limitedredel,Ilonstration on August 8, 2019, personnel on two

. radiological*emergency. response teams successfully*dem.onstrated the. ability to I take. appropriate radiation measurements and ~r: samples. The teams maintained frequent contact with the radiological.emergency. response team coordinator.

,,:i,,,,. :, *_;j -_,

.,.,i::1.,*.1,.

I e. Prior Level 2 Findings '"" Unresolved: None * - , * ,

• 3.3.2.3 Division of Radiological Health Field Team, I Environmental Response/Health &Safety Capability Summary:

I .. The Mississippi State Department of Health Division of Radiological Health Field Teams demonstrated with major challenges the ability to locate a plume using ambient radiation surveys and obtain air samples that would be used for dose assessment and protective I action decisions in response to the Grand Gulf Nuclear Station.

I Plan Issue 028-17-1.e.l-P-Ol was corrected by providing appropriate and sufficient radiation survey and air monitoring equipmentto support emergency operations.

Plan Issue 028-17-4.a.3-P-02 was partly corrected during the exercise but remained open due to incorrect methods for traversal of the plume and air sample collection. These I planning issues were fully resolved during a limited redemonstration on August 8, 2019.

I Procedures to alert, notify and mobilize emergency personnel were performed in a timely manner., For this exercise, field team staff were pre-positioned per the .extent of play

_ agreement from the field team facility.

I At least two communication systems were available and operable for field team activities.

The primary, means 'of communications was by the iMississippi Wireless Information I Network radios. The.secondary.means of communicaticms was Global-Star satellite

.phones and/or conventional cellular phones. , All primary and backup methods of communications worked throughout the exercise I

• 29 I

Radiological Emergency Preparedness Program I After Action Report

.. 1- ~ '!~- '* *_

2019 Grand Gulf Nuclear Station I

All field team members were issued appropriate dosimetry, potassium iodide and radiological survey instruments, along with procedures*to mariage'their radiological I exposure and monitor their reporting limit and administrative dose limits. All dosimetry and survey instruments were within calibration and; successfully*passed. source check requirements. The teams received appropriate radiological and safety briefings prior to I

deployment.

The field teams were correctly positioned to accurately characterize the plume. Ambient I

radiation measurements were made and recorded at appropriate locations and air samples were c0llected. The procedural method to traverse'theplume was not, specified, therefore, 'both field, team 'incorrectly took open* and dosed readings* along the. plume I

traverse; . Additionally, both teams were requested to take two samples, charcoal and silver zeolite,-ata satnple.location. This doubled the stay time for both the traversal and

, the air* sample in the plume and* resulted in unnecessary :exposure to the field team I

workers. The sequence of events resulted in unnecessary doses to field team members and did not fully meet this Critical task (criterion 3;a.l). Therefore, level 2 finding 028-19-3.a.l-L2-02 is assigned under Field Team Management above.:However;;this finding I

was resolved during a limited redemonstration on August 8, 2019.

I * ~' *

• The field teams were moved to an appropriate low-background location to determine the I

amount of radioactivity that had been collected on the air samples. The procedure did not specify how to count the air filter media with a fixed geometry so that readings would be reproducible.* This could result in inaccurate readings. * ,

• I Transfer of samples for analysis was not specifically addressed in the procedure, nor were couriers identified to expedite the transfer of the air samples. This would result in I

extensive delays of air sampling results for decision makers.

The Field teams :followed good practices to prevent cross contamination of samples and I

equipment. *Dosimetry was read, recorded and transmitted every 30 minutes to the field team coordinator.* I For this capability the following Radiological Emergency Preparedness criteria were MET: l.a.1, l.d.l; Le.l, '3.a.l, 4.a.3 I

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

• c. Not Demonstrated:* *None .

, cl.. Pri~r Level 2 Findings -R~solved: None I

I

')

e. Prior Level 2 Findings - Unresolved: None,

f. Prior Plan Issue - Resolved.

I 130 I

I Radiological Emergency Preparedness Program I After Action Report Issue Number: 028-17-1.e.1-P-01 2019 Grand Gulf.Nuclear Station I Core CapabHity/Critedon: Environmental Response Health & Safety /1.e. l I Condition:. Radiation monitoring equipment was not appropriate or in sufficient supply to support emergency operations . Field monitoring teams were not.

sufficiently equipped to monitor radiation levels in a high gamma radiation field. The I teams did not have backup supplies of calibrated low-level radiation survey instruments and calibratedl'.charged air pumps for Gollecting an air sample.

I Resolution: Appropriate. dosimetry, potassium iodide m;id radiological survey instrµments, along with procedures to manage their radiological,exposure,and monitor their reporting limit and administrative dose limits were successfully issued I .to field team personnel. Plan fasue 028-17-1.e. l-P-O 1*is corre~ted by providing appropriate and suffici~nt radiation survey and air monitoring equipment to support emergency operations<*

I .* I~sue Number:. 028-17~4.a.3,,P-02.

~ . . . .

• i '

I Core Capability/Criterion: Environmental Response Health & Safety /4.a.3 Condition: The Department of Radiological Health procedure needs revision to I clarify methodology for air sampling to .ensure that proper methodology is followed for collecting and analyzing *a quality air sample to use for making dose assessment calculations and making protective actions for the public. Personnel also need to I have additional training on air sample procedures and why certain steps are vital to taking a valid air sample.

I Resolution:

1. Following the exercise, Division of Radiological Health personnel revised their

• procedures to provide appropriate detail on radiation measurements to be taken I while traversing the plume, to modify the air sampling process to take. only one sample with a silver zeolite cartridge, and to ensure regular communication between the teams and the radiological emergency response team coordinator.

I 2. Several days of training on the updated procedures were provided to Division of Radiological Health personnel and other Mississippi State Department of Health I personnel who may respond to an incident at Grand Gulf.

3. During a limited redemonstration on August 8, 2019, personnel on two radiological emergency response teams successfully demonstrated the ability to I take appropriate radiation measurements and air samples. The teams maintained frequent contact with the radiological emergency response team. coordinator.

I g. Prior Plan Issue- Unresolved: None I

,31 I

Radiological*Emergency Preparedness Program I After Action Report 33.2.4 Emergency Operations Facility Dose Assessment .

• 2019 Grand Gulf Nuclear Station I

Situational Assessment Summary: I The Mississippi Division of Radiological Health :within the Department of Health demonstrated, with significant challenges, that it could activate and deploy dose I assessment staff to the Grand Gulf Nuclear Station's* emergency operations facility in a timely manner, perform timely and accurate dose assessrµ~nt activities, and coordinate with the state emergency operations center. Voice communications.equipment operated I satisfactorily; however, the facsimile equipment was out of service. This necessitated a successful work-around where photos of do_cu~_ents that were to be faxed to the state emergency operations center were taken and sent v1."a mobile phone. . .

1 I

Principal .equ,ipmen,t used _by the dose assessment staff consistecl, of a lap-top ~omputer with dose calculation software loaded on it. The computer and the radiological I

assessment system for, *consequence* analysi~ .software,worked satisfactorily. to generate timely and accurate dose assessments. ; . I Emergency worker .doses wern.contrnlled through use of direct:;reading *dosimeters and a

.. provision for the .issuance 'ofpotassiumiodide'forthyroid protection; The dosimeters

• were read approximately every 30 minutes and reported to the Radiological Emergency I

Response-Team Coordinator. No significant-exposures were experienced. Thyroid dose calculations were performed on five ,occasions using the source-term-to-dose model contained in dose assessment software and on two occasions usingthefield-I measurement-to-dose model contained in the same software. All estimates showed that the 25 R thyroid dose criterion used by the Mississippi-Division of Radiological Health to recommend the use of potassium iodide for workers was not exceeded. There was some I

confusion based on the air sample results that would serve as input to the field-

• measurement-to-dose model. Both charcoal and silver zeolite were used in spite of it not being necessary or appropriate to do so. Both sample media were used because the state.

I assessment staff did not appear to understand the difference between the two media; however, the results did not show that the threshold for potassium iodide use was exceeded. The delay of field team results caused by taking both charcoal and silver I

.zedlite air samples contributed to the assignment of finding 028-19-2. b.l-L2-01 described in section J.3.2J' above. This delay, along with the use of the outdated 25 rem thyroid

. dose criterion also contributed to finding 028-19-3.a.l-L2-02 described in section 3.3.2.2 I

above.

The revised dose assessment procedure used by Division of Radiological Health staff I

required a comparison with the Grand Gulf dose .calculations and to, determine that the results were:within a, factor of 10 of each other: This wasi true in all five dose assessment comparisons., All dose.assessments were completed by the Radiological Dose I

AssessmentCoordinator)within 15 minutes of receipt of.the input parameter from the Grand Gulf dose assessor. Level 2 finding, 028-17-2.b;l,-L2-02 is considered resolved, I based on the accurate and timely dose assessments that were observed to be provided by I

.32 I

Radiological:Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station the emergency operations facility;;based Division of Radiological Health ,staff.to the state I emergency operations center .

For this capability, the following Radiological Emergency Preparedness criterion were I MET: l.a;l; J.d.1, J.e.l, 2.bd, 3,.a.l.

a. Level 1 Finding: None I .b~ ~evel 2 Finding: Norie

, c.

• Not Demonstrated: N0ne *.

I *. d. Prior Level 2 Findi~gs*-Resolved.

Issue Number: 028-17-2.b.l-L2-02 I Core Capability/Criterioii: K Enviroiunerital Response Healtlt & Safety i2.b. l Condition: The State of Mississippi dose asses~ment team did not provide the state I emergency operations center staff with accurate results ih a timely manner. .

• Resolu_tion: :The. finding* was .resolved~ :based. on the*,accurate and timely: dose I

• assessments*that were observed tb be provided by the emergency operations facility-based Division of Radiological'Health staffto the* state emergency operations center .

More specifically, the revised dose assessment.procedure used by Division of I Radiological Health staff required a.comparison with the Grand Gulf dose calculations. and to determine that the results were within a factor of 10.

I e. Prior Level 2 Findings - Unresolved: None .

3.3.3 Claiborne County I 3.3.3.1 Emergency Operations Center I Operational Coordination Capability Summary:

I .Claiborne County emergency management staff successfully demonstrated the ability to respond to a radiological emergency. The initial notification of a Notification ofUnusual Event was received over the dedicated notification system in the communications room.

The emergency manager further notified key personnel followed by the emergency I operations center staff. The emergency operations center staff were capable of responding in a timely manner upon initial notification and rapidly assumed their duties. The.director I .effectively gathered relevant.emergency iriformation and analyzed it with*county, officials.

Suitable decisions were based on feedback and concurrence from eounty stakeholders.

Periodic staff briefings kept the staff informed of emergency conditions .and plant status.

I * . The briefings were.followed by discussions with emergency operations center key staff to identify. actions they were taking.

I

.. .33 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

of The emergency operations center had a robust means communications, to include internet access, electronic mail, commercial land lines and cell.ph0nes: Backup communications also included a dedicated line to the plant, facsimile machines and satellite phones. An I electronic 'incident management system was used to maintain situational awareness and track resource requests. Conference calls updating the status and discussions among the risk and host counties and State concerning protective actions were coordinated using dedicated I video conferences. '

The director and the emergency management staff were knowledgeable of the I

communication flow and ensuring everyone had :situational awareness to complete their duties. The affected access/functional needs population were identified and relocated to a reception center through coordination with county public transit and the county emergency I

medical services. All staff members were knowledgeable and effectively used county plans to ensure the safety of the public and emergency workers. I Claiborne County emergency management staff demonstrated the capability to implement emergency worker exposure control. .. The caIJ,aqility ~nclude1. th~ issuance of ~ppr~priate dosimetry, potassium iodide, and usage procedures. Radiological exposure was managed I

for emergency workers in accordance with,the;plans and procedures; The Port"Gibson Police Department demonstrated that appropriate traffic control was established and that accurate instructions were providedto'traffic control personnel. Impediments ori evacuating I

traffic routes were quickly identified. Re-routing was determined and conveyed to the public directly at the impediment site; by usage of fire-lanes adjacent to the highway, until the impediment wreckage could be removed.

I For this capability the following Radiological Emergency Preparedn.ess criteria were MET:

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

I

a. Level 1 Finding:* None I

b. Level 2 Finding: None

c. Not Demonstrated: None I d.' Prior Levef 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I Critical Transportation. Capability Summary:

The Claiborne County School District followed current plans and procedures to effectively I

respond to*an emergency at Grand Gulf Nuclear-Station. Host locations for students were contacted early to alert them of a possible precautionary transfer of students to designated I Reception Centers. Buses and personnel were put on alert and staged.. At site area emergency, execution of the procedures was efficient in transferring the* students. Parents were kept informed as to where, when, and how to pick up their children. Alcorn State I University successfully described how they would evacuate students when the general I

• 34 I

I Radiological Eme,rgency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station public evacuates. The Port Gibson Police Department implemented a transfer of jail I inmates to an Adams County jail..

Claiborne County SchoolDistrict successfully demonstrated communications with county, I city, and school district officials. AlLsystems operated in accordance with plans and procedures. Primary and backup communkations systems were functional without failure.

The Claiborne County School District could also call on other county resources should they I have been needed.

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

I ' . l.d.l, 3.c.2. 1,

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

• c; Not Demonstrated: None

• I

• d.. Prior Level 2 Findings - Resolved:' None '

r , ,

• , I. I e.*. Prior Leyel 2 Findings ... Unresolved: ;Nene ... *.,

I Public Information and Warning Capability, Summary:

1.1*

I Claiborne County public information staff successfully demonstrated the ability to perform primary alerting and notification to the public and backup route alerting following the failure of the primary alert and notification system. Multiple communications systems were I available to support emergency operations and operated properly without failures.

A public information officer was mobilized to the Joint Information Center in accordance I with the approved extent of play. Communication between emergency management staff and the public information officer was established early and maintai1:1,ed throughout the I event to support emergency operations. All Claiborne county news releases were prepared by the public information officer and distributed from the Joint Information Center.

Coordination of message releases with the director of emergency management was not I observed. The sequence of events did not fuHy meet the Critical task (criterion 5.b.1).

Therefore, level 2 finding 028-19-5.b.l-L2-05 was assigned. . * * -

I The siren system was activated to alert the public in a timely manner following the*

coordinated decision between county and state officials to alert the public. Backup route alerting was promptly and successfully initiated upon detection of the failure of a siren.

I Route alerting teams were provided appropriate instructions, training, personal protective equipment; and field equipment to accomplish* the. route while managing emergency worker exposure control.. Route alerting teams had access to radios and cell phones. Radio checks I to confirm operability were conducted prior to beginning route alerting.

I

35 I

Radiological Emergency Preparedness Program I After Action Report

• 2019 Grand Gulf Nuclear Station For this capability the following Radiological Emergency Preparedness criteria were MET:

I

• 1.a:l, I~d.1, 5.a:.'I, 5.a.:3. * * * ,.: .. i_

I For'this capability the following Radiological Emergency Preparedness criteria were not MET: 5.b. l. , .

I

a. Level 1 Finding: None

b. Level 2 Finding: *

• ' 1 ., -

I

• . Issue Number: 028-Ji9-5.b.l-L2-03.

• Co~e CapabHity/Criterion: Public lnfo~~Hori and Warning/5.b.l

' 0 , * r *., ** '*

• I "*

• I

. Condition: The Claiborne County public information officer improperly prepared

• • . and disseminated*news releases from the Joint Information Center.

I Analysis: The Claiborne County public information officer prepared and disseminated three news releases from the Joint Information Center without coordinating their content with Claiborne County Emergency Management officials.

I

• .Claiborne.County News.Release* #1 'irlcorrectly stated school childrerhwete being

, transferred-, requiring a.*correctedhews release to be issued clarifying that schools were not in sessiofffor*spring break. Claibc:)Ine County News Release #3, released at I

1028, erroneously stated that a General 'Emergency had been declared by the utility at HHO and the Emergency Alert.System had been activated at 1024. The sections of the news release de~cribing the actionsthe public were to take and identification of I

the Protective Action Areas that were ordered to evacuate or monitor and prepare were left blank. At the time Claiborne County News Release #3 was disseminated to the public and news media, the l!tility remained at Site Area Emergency (a General I

Emergency would not be declared until 1225) and the Emergency Alert System had not been activated. The Emergency Alert System was activated at 1045 based on a protective action decision made at 1030 to evacuate Protective Action Areas 1, 2a, 2b, I

and 7, and for all remaining areas to monitor .and prepare. No corrected or subsequent news releases were prepared and disseminated by Claiborne County. I Possible Cause: The Claiborne County public information officer at the joint information center did not seek qpproval of. the content of the news releases from the Claiborne County Emergency Management Director prior to issuing them to the new I

. media ai:J.dthe public, The public information officer did not coordinate. with the

• Mississippi Emergency Management Agency official in charge of the joint information center.

I

' ~: ..

I I

I

'36 I

I Radiological Emergency Preparedness Program I After Action Report

• 2019 Grand Gulf Nuclear Station

References:

., * . n:-

• I 1. Claiborne County Radiological Emergency Preparedness Plan, Revisio.n 18, October 2018, Section H- Public Information, pages 24-25.

2. Mississippi RadiologiqalEmergency Preparedness Plan, Revision l8; October I 2018, Section I- Public Information, page 24

3. NUREG-0654/FEMA-REP-1; E.5, 7 I Effect: The public received conflicting information from county and state officials.

a At 10:28 am the county stated that the nuclear plant was at General Emergency classification level and did not provide any instructions for evacuatibn or nther I protective .action. Near the same time the county new release was sent, the state reached i(coordinated decision to activate the prompt alert *and notification system to order the evacuation.of.some,areas and monitor.,and prepareJor all the*others. The I system was activated at 10:45 am,. The public would have been confused*as to the actual utility conditions and associated threat, and confused as to whether they should do nothing, evacuate, or monitor: and*prepare, I , ., Recommendation: ,r ; , ,. t ,, 1

.1

. Review and revise as necessary. Claiberne *G:ounty'plans and procedures to ensure I *.that ajl media releases ,are approved, bythe* Claiborne Coun~y .emergency management director or apptbpriate designee and consistent.with the.coordinated decisions reached by Claiborne County and State .officials.

I .* 2. Ensure that all Claiborne County emergency information and instructions to the

. public and the news media are properly approved prior to release.

I . c. Not Demonstrated: None

d. Prior Level 2 Findings...: Resolved: Norte I e. Prior Level 2 Findings~ Unresolved: None 3.3.3.2 Emergency Worker and Decontamination I Environmental Response/Health and Safety Capability Summary:

I *,.*','

Monitoring and decontamination of emergency workers and their vehicles was successfully demonstrated by members of the Claiborne County Fire Department,atthe Hermanville Fire

.I Station. Emergency workers at the station demonstrated they were sufficiently .trained, and that their procedures and available resources were sufficient to ensure the.safe monitoring and decontamination of emergency workers, their vehicles and *equipment. *Emergency I workers received a safety briefing, exposure control guidance, and were issued personal and permanent-record dosimetry at the start of the demonstration. Radiological survey instruments were properly inspected and put into operation by those who were using them.

I I

.37 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

Emergency workers at the station demonstrated appropriate*survey and decontamination techniques while processing both workers and vehicles {llld ex!vbited good teflill work during the drill. The success of drill validates that the.county.has the.procedures and I resources to accomplish monitoring ahd decontamination :ofemergency workers and their equipment.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.e.l, 3.a.l, 6.b.l.

I

a. Level 1 Finding: None

b. Level 2 Finding: None . I

c. Not Demonstrated: None

d. Prior'Level 2 Findings'- Resolved: None

• I

e. . Prior L~vel 2 Findm,s ~ Unreso~ved: None

• 3.3.3.3 Traffic Control Point I

• . , * * * *, 1* *" , * ~ I ;_'. f : < '. f * * . ,~ I '

On-Scene Sec,urJty, Protection,. and :Law Enforcement Capability Summary:

. ' . . . .. ' \ .  ; . ~.

" t, 1 *'

\ *....: : ' ' **~

'

• I ' ,'

• ' I The Port Gibson Police Department and Port Gibson Street Department demonstrated their ability to establish and maintain critical traffic/access control points in support of an emergency response to an incident at Grand Gulf Nuclear Station. Police officers and street I

department employees who were interviewed discuss.ed their ability to establish traffic control, identify and resolve impediments to evacuation, manage radiological exposure to emergency worker~, primary and alten:iate means of communications .and provide accurate I

instructions.to the evacuating pu,blic. All necessary equipment used in establishing traffic control points is maintained by the two dep~ments. Additional traffi~'control point equipment needs would be coordinated with individual agenci~s or the emergency I

operations center as necessary.

The county radiological emergency control officer provided a briefing to the three law I

enforcement officers and four street department representatives that addressed radiological response operations, dosimeter use, required forms, and potassium iodide instructions.

Impediments to evacuation would: be cleared immediately by street department personnel.

I If impedilllep.t removal was outside of their ability, assistance would be requested and coordinated through the county emergency operations center. Other organizations available I.

to assist with impediment removal would include additional county and state resources.

. For this capability the following Radiological Emergency P~eparedn~ss crit~ria were MET:

l.d.l, l.e.l, 3.a.1, 3.d.l, 3.d.2. * -*

I

a. Level 1 Finding: None I I

38 I

I Radiological Ernerge11cy Preparedness Program I After Action Report

. b. ,Level 2.Finding: None. , ,, ,,

2019 Grand Gulf Nuclear Station I c. .Not Demonstrated: . None *,,.,.,

d. Prior Level 2 Findings 7""*R~Qlved: None I e. Prior Level 2 Findings - Unresolved: None 3.3.4 Adams County '

I 3.3.4.1 Emergency Operations Center I Operational Coordination Capability Summary:

I Personnel staffing the Adams County emergency operatioils center successfully demonstrated the ability to coordinate (i:ounty .activities in response.to a radiological incident at the Grand Gulf Nuclear Station. The primary responsibility of Adams County was to I establish and operate a reception center and :shelters to assist evacuees :froi:n Clrubome County. ~ . .

I Following notification from the staty wjlIDing point that an eni~rg~ncy had been dec.lared at Grand Gui( the Adams County Emergency Mariagemertt Agency 'di'rector prompti texted key staff members to respond .. He al~o explained how the county's blast notification system y

I could also be used to notify.staff. The emergency operations center was fully staffed and operational in a timelymatmer. *. * * *

• I The d1recfor ensured all staff members maintained accurate situ~tional awareness through briefings, discussions, and monitoring of the coordination conference line. A v.1deo conferencing system was also displayed:. Staff members Were knowledgeable of their I procedures and their respective organizational responsibilities during the response, and efficiently carried out .their duties. The director and staff ensured that the reception center was operational in time to support evacuees'. Staff also frequently discussed potential I problems that could arise and brainstormed possible solutions. The director*described emergency worker exposure control procedures for personnel staffing the reception center and explained the reporting process. ' * * ' * * *'

• I , ,

The emergency operations center had sufficient equipment, displays, ancl supplies t9 support the emergency response. Staff used cellular telephones, handheld radios, 'voice..:over-I intemet-protocol telephones, email, and a web-based emergericy management system to communicate with personnel outside of the emergency operations center.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.a.1, Lc.'l, l.d.l,1.e.l,*2.a.l, 3.aJ'. . . . . . .

I a. Level 1 Finding: None

b. Level 2 Finding: None I

• 39 I

, Radiological Emergency Preparedness Program I After Action Report

c. Not Demonstrated: None ~; *., ,

2019 Grand Gulf Nuclear" Station I

. d. Prior Level 2 Findings

/*': . . *:

- Resolved:

,' '/ .. None .I

e. Prior ]:,evel 2 Findings - Unresolved: None *

• 3.3.4.2 Reception Center and Congregate Care I Environmental Response/Health and Safety Capability Summary:

I Emergency Services personnel and volunteers from Adams County successfully demonstrated_theirabilities to provide monitoring, decontamination and registration of evacuees at the Adams*CountyLouis GunninR Community Safe Room in Natchez;.

I Mississippi. Participating agencies included* the Adams County Emergency Management Agency, Natchez Fire & Rescue, Kingston Volunteer Fire Department, ,and the Natchez Police Department. ..... .

I The county reception center had sufficient space, resources; and trained personnel t6 provide for the evacuating public. The evacuees were able to easily maneuver the well-laid out I

reception center area with the assistance of attentive escorts. Facilities were set up and demonstrated as they, would.bdn,an*actual emergency and in accordance with comity plans

• and procedures. Operational checks of the radiological monitoring and survey instruments I

were properly completed, and personal dosimetry was issued.

Emergency workers were knowledgeable of exposure and contamination limits and the need I

to read their dosimeters frequently. Emergency workers in the decontamination stations were knowledgeable of how to place instruments into service and how to use them to perform surveys. Signage and plans were well placed in the decontamination areas to help I

emergency workers perform their tasks .

• Evacuees were processed through the primary and secondary screening at the monitoring station and decontaminated as applicable. I For this capability the following Radiological Emergency Preparedness criteria were MET:

1.e.l, 3.a.l, 6.a.l.

• I

a. Level 1 Finding: None

• b~ Leyei 2 Finding:, None I

c. Not Demonstrated: None

. d! Prior Level 2 Findings-Resolved: None I

e. Prior Level 2 Findings - Unresolved: None I

I I

40 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station Mass Care Capability Summary:

I Adams County, Mississippi Departmenf of Human 'S~rvices', and Department bf Health personnel along with the Southwest Mississippi Chapter ofsthe American Red Cross I successfully demonstrated their ability to provide temporary care of evacuees in the event of a nuclear incident. The demonstration occurred at the Adams County Louis Gunning Community Safe Room in Natchez, Mississippi.

I

• Under the guidance of the county emergency management staff, county employees and volunteers competently worked together as a team and demonstrated shared responsibilities I in meeting the needs of evacuees. '.fhey were well:-versed in the emergency plans and procedures and displayed positive attitudes to meet the physical. and mental needs of evacuees. The community safe room is:primarily used to temporarily 'shelter arriving I . evacuees after.they have been monitored for radiological contamination and; if necessary, decontaminated. For this demonstration six people were processed into the inass care facility, which was well-equipped and staffed to successfully-provide support. Agency I leaders were knowledgeable and professional, and worked together.as a team throughout the exercise.

I For this capability.the following Radiological Emergency Preparedness criteria,were MET:

• l.d.l, l.e.l, 3.b.1, 6.c.l.

I a. Level 1 Finding: None

b. Level2 Finding: None I c.. Not Demonstrated: None

d. Prior Level 2 Findings - Res,olved: None I e. Prior Level 2 Findings - Unresolved: None, 3.3.5 Copiah County I 3.3.5.1 Emergency Operations Center I Operational Coordination Capability Summary: Copiah County Emergency Management Agency successfully demonstrated their ability to manage emergency operations in support I of Grand Gulf Nuclear Station. The Copiah County Emergency Management Agency Director and his staff operated in the e.mergency operations center.which was co-located with the 911 Communications Center in Hazlehurst, Mississippi. The' County effectively I demonstrated the receiving and dissemination of notifications concerning Grand Gulf Nuclear Station emergency classification levels, and effectively demonstrated mobilization of emergency operations center staff, in a timely manner. The emergency operations center I was activated at the appropriate time and level during the exercise.

I

,*41 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

Redundant communications capabilities were demtHistrated using wireless internet email, specialized software, cellular phones, and landline phones. A crisis communication and mass notification tool fordelivery of emergency,eventihotificatioiis was used to transmit I emergency classification levels to the emergency operations center. Although each of these

• systems perforrrted as expected; staff explained the .ability to establish ,satellite communication to support internet *and email should the*cellular system fail m become I

overwhelmed. No communication failures were observed during the exercise.

The Copiah County emergency operations center had sufficient equipment to facilitate I

support operations. Dedicated computer monitors throughout the emergency operations

• *center* allowed for the simultaneous display of event logs, press :releases, links to event

,documents* and niap libraries, protective action area maps, emergency chat logs, the I

Mississippi Emergency Management Agency situation room camera feed and other participating county emergency operations' center camera feeds.

• I The Copiah County Emergency Management Director and his leadership staff were knowledgeable and worked effectively together. Both the deputy director and. the

• administrative assistant effectively managed information and personnel allowing-the director I

to focus on coordination and,decisiort rnal<lng,:A: Mississippi Emergency Management

• Agency Liaison* also added value >to the county's* emergency operations by assisting' in coordination arid information gathering. The*director attended all conference calls and I

involved his staff on each.

Copiah County leadership staff took appropriate steps to manage activation of their primary I

reception center in support of the Claiborne county evacuation order. Although not demonstrated, the director discussed that the county could conduct proper coordination with the State and other host counties to insure proper dosimetry ~nd potassium iodide and I

survey equipment were available if needed.

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

I l.a.l, l.c.1, l.d.l, l.e.1, 2.a.l, 3.a.l.

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings - Resolved: None *

e. Prior Level 2 Findings - Unresolved: None I

I I

I

'42 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station 3.3.5.2 Reception Center and Congregat.e Care .-.

I * , EnvironmentaLRespo~e/Health and Safety -Capability Summary:

I Copiah county emergency _manag~ment officials and supporting agencies successfully demonstrated the ability to perform radiological monitoring and decontamination of evacuees at the Joe L Johnson ,Cl'.>rnrnunity Safe Room in.Hazlehurst, Mississippi. The I reception center had appropriate space, adequate resources, and trained personnel to provide

rp,onitoring; decontamination, and;registration of evacuees; In the event @f inclement weatper (thunder, lightning, extreme. cold/heat, and significant weather ph~nomena) that is I not conducive to radiological*decontaminatic;m; Copiah County Emergency Management has developed a process to ensure the safety and continued decontamination ofevacuees.

Participating agencies included-the Copiah County Emergency M_anagement, Copiah I County Department of Human Services, the American Red Cross and Mississippi ,

Emergency Management Agency.

I Emergency workers. received a safety.and radiological bl"iefing concerning equipment,

. ,potassium io:dide distribution, dosimetry, prefo~ 307".rninute dosimeter checks,,*. , ?:

• communication channels, ,no* eating/drinking,on pos,ts; emergency workers relief/breaks, turn I back value, and to practice cpntamination avoid~ce: Em~rgency: workers wore appropriate protective clothing and dosimetry, were familiar with.dosimeter:reading and recording requirements, dose limits, and contamination limits. Workers properly set up and used their I dosimetry, handheld instruments, portal monitors, gross decontamination, portal monitoring, personnel monitoring and individual decontamination stations. Individuals received a green "NotContarninated" card once an individual was considered decontaminated. They I demonstrated excellent monitoring techniques and decontamination methods.

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

I l.e.l., 3.a.l., 6.a.l.

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

c. Not Demonstrated: None I d. Prior Level 2 Findings - Resolved: None I e. Prior Level 2 Findings - Unresolved: None Mass Care Services:

I The ability of Copiah county to provide temporary care of evacuees/students from Claiborne county was successfully demonstrated by representatives of the Mississippi Department of I Human Services. Mass care services were set up in accordance with county and American Red Cross shelter procedures. The facility had ample space and accommodations for the expected evacuee/student population.

I 43 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

,The facility was sufficient to liouse evacuees, with,adequate. restroom and shower facilities, as well as a feeding .area if necessary. The primary 1Iieans of communication'would be cell I phones, with a radio issued by county emergency management as a backup means to communicate With incident command. The staff and volunteers were knowledgeable in their duties, forms,* equipment and displayed a commendable dedication to the health and I welfare ofthe.public*and demonstrated shared responsibilities in meeting the needs of evacuees.

.. t I

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

l.d.1; Le.1,3 . b.1, 6.c.l.

I

a. *Level 1 Finding: None b: Level 2 Finding:

None t

I

c. Not Demonstrated:. None; * *'*

d. Prior Level 2 Fi~dings ....: Resolved: 'Na'de .

I

e. Prior Level 2 Findings - Unresolved: None 3.3.6 Hinds County I

3.3.6.1 Emergency Operations Center I Operational Coordination Capability Summary:

During the Grand Gulf Nuclear Station Exercise the .Hinds County Department of I

Emergency Management Director, Ass1stant Director and emergency operations center staff demonstrated their capability to respond effectively to an event at the Grand Gulf Nuclear Station. The director and his assistants demonstrated effective direction and control in the I

timely alert, notification and mobilization of personnel and support staff. The staff in the emergency operations center were well-trained and familiar with their roles and responsibilities. ,Their plans and procedures were up-to-date and complete; The County I

Emergency Management Director was proactive in demonstrating his expertise and experience, performing and:coordinating with other agencies both within the emergency operations center and externally ..

I The em:ergericy operations center had redundant means of. communication including: a

. dedicatedtelephoneline; Mississippi Wireless Information Network and a television I

conferencing system (Homeland Security Information Network) that operated successfully during the exercise. The dedicated telephone system was used to initially notify the county

• . of the Alert Emergency Classification Level at Grand Gulf Nuclear Station and was used for I

I I

'44 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand GulfNuclear Station the other notifications throughout the exercise. Backup communications were provided by I . email, fax machine,.cell phones and two-way radios. ,Hinds county was involved in calls

• • that helped maintain situational awareness of what was occurringjn 'the.coordination of relief efforts that involved those living in the emergency'. planning zone. : .

I Sufficient supplies;* space and equipment were available. *Space inside the facility was

, adequate for personnel who were.~ssignedto .operate from the facility .. Map boards, I information screens and lists of data were present, as were television monitors .. All emergency support function staff had adequate communications (cell phones) and office supplies available at their work stations. Because Hinds was a host .county; there was not a I need for personnel inside the emergency operations center to wear dosimetry since they were outside the 10-mile emergency planning zone. There was enough dosimetry within calibration stored on-site that would be delivered to the county rt!ception center for all I emergency workers that would have been activated in the coµnty .. 'I,'her~ was enough up-to-date potassium iodide stored at the County Health Department to ensure all emergency workers would have an adequate supply during an emergency:* Consideration was given to I resources that might have been impacted duri~g this ~ver:1J necessary.

~' ** J, ' ' : ,. * -'

a.n~.

tli~i,r replacement if *..

'),' .~* *. *_,,: l . *.. .;: *, );, '.' *; , " ...... ., t."

I For this capability the following Radiological Emergency Preparedness criteria were MET:

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

• I a. Level 1 Finding: None

b. Level 2 Finding: None I c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I e. Prior Level 2 Findings - Unresolved: Non~

3.3.6.2 Reception Center and Congregate Care I Environmental Response/Health and Safety Capability Summary:

I Hinds county emergency management officials and supporting agericies successfully demonstrated the ability to perform radiological monitoring and dec_ontamination of I evacuees at the Hinds Community College campus reception and congregate care center in Utica, Mississippi. Participating agencies included the Hinds County Departmenfof Emergency Management, Hinds County Sheriffs Office, Jackson.Fire Department,and the I Clinton Police Department.

Vehicles were routed oii traffic-controlled streets to the site~ and after driving through a I gross decontamination shower the vehicles proceeded to a designated space for parking.

Emergency workers then provided transportation to move evacuees from the parking area to the monitoring and decontamination areas. The designated walk paths were clearly I

45 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station controlled using barriers and safety cones which followed* a logical flow path and process I

that optimized the facility's layout. The reception center h~d the appropria~e space as well as sufficient resources to include trained personnel to provide racffological monitoring, I decontamination and registration of evacuees. * * *' * : *-

Emergency workers received a safety and radfologicJ brief~g- b~fcire starti~g ~perations I and were provided a Radiological Emergency Preparedness worker handbook as a reference, with dosimetry and reporting directions. Emergency workers wore appropriate protective clothing and dosimetry, were familiar with dosimeter reading and recording I requirements, dose limits, and contamination limits. Workers properly set up and used their dosimetry, portal monitors and handheld instruments. They demonstrated good monitoring.

techniques and decontamination methods.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

1.e.l, 3.a~l~,6*.a.1.* *r I

• a~ -Levell Finding: None b .. ,Lev~l 2 fincµng; N;~>ne ,,*!,'

• I

c. Not Demonstrated: None

d. ,Pri<<;>r Level 2 Findings - Resolv~d: None I

e. Prior Level 2 Findings - Unresolved: None I Mass Care Services Capability Summary:

The ability of Hinds county' to provide temporary care of evacuees from Claiborne county I

was successfully demonstrated by representatives of the Southwest Mississippi Chapter of

-the American Red Cross, Mississippi Department of Human Services and Mississippi

• Department ofHealth. Mass care services were set up in accordance with county and I

American Red Cross shelter procedures. The facility had ample space and reasonable

• '. accommodations for the expected evacuee population. I The primary-means of communication were cell phones, with a radio issued by county

• erriergency management as- a means to communicate with incident command. Potassium iodide-was stored at the county health departm~nt and-Hinds County Emergency I

Management Agency;, The county health department held the stockpile for the general public *and the county emergency management office held supplies for emergency workers. The staff and volunteers were knowledgeable in their duties and displayed a I

commendable dedication to the health and welfare of the public, worked together as a team,

• and demonstrated shared responsibilities in meeting the needs of evacuees.

• i * , I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.d.1, l.e.l, 3.b.1, 6.c.l. I I

46 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station a., Level 1 Finding: None:,,

I b. Level2 Finding_: Notik i.'

c. Not Demonstrated: None I d. Prior Level 2 Findings-Resolved:

! . * * '. * ~ l . . .

None

e. PriorLevel 2 Findings- Unresolved: None' I 3.3.7 Warren County ,.

I 3.3;7.l Emergency-Operations Center Operational Coordination Capability Summary:

I Warren County emergency operations center staff successfully demcmstrated the ability to support emergency radiological response in the event of an incident at Grand Gulf Nuclear I Station. The director provided clear guidance and direction to t4e ell;lergency operations center staff. He led periodic briefings as the situation dictaty~- Th,e ei:nergency operations center staff responded in a timely manner upon receipt of initial 'rioti:t'icatfon vfa: a crisis I communication and mass notification tool. ., ,-*,_

• The emergency operations center had ri:mltiple mearts ofcommunications, to include I personal computer Internet access, electronic mail, coinmercial land lines, cell phones, and other hand-held electronic devices. Backup communications also included facsimile machines, low band 700 and 800 megahertz radios, and satellite phones. There were no communication failures during the event. An electronic incident management system was used to maintain situational awareness and track assistance ,requests.

Warren County is a host county with the mission*of providing a reception and congregate care center for the general public evacuating from at.-risk areas. Warren County dosimetry is transported to the Warren Central High School reception (:;enter when tbe situation I dictates. Dosimetry, monitoring equipment, and pDtassium iodide was_ verified with proper operational response during out of sequence activities on February 27, 2019. Warren County is outside of the 10-mile Protective Action Area, but prepared to issue appropriate I dosimetry, potassium iodide, and manage radiological exposure in accordan~e with the plans and procedures for emergency workers. The knowledgeable and professional; I emergency operations center staff,composed of a variety of supporting-county agencies, demonstrated their ability. to plan and conduct emergency response actions to perform that mission.

I '

For this capability the following Radiological En1ergency Preparedness criteria were MET:

l.a.1, l.c.1, l.d.1, l.e.l, 2.a.l, 3.a.l. -

I a. Level 1 Finding: None

b. Level 2 Finding: None I

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Radiological Emergency Preparedness Program I After Action Report

c. Not Demonstrated: None 2019 Grand Gulf Nuclear Station I

d. .:PriorL~vel 2Findings .:...Re~olved: No~e

. 1 *,

' I '..

I

• , ' e. Prior Level 2 Findings - Unresolved: None': .

• 3.3.7.2 Reception Center and Congregate Care I Environmental Response/Health and Safety -Capability Summary:

I

Warren County emergency management officials and the supporting emergency services, law enforcement, fire service, and emergency medical service agencies successfully demonstrated their ability.to monitor, decontaminate, and register evacuees. Participating I

agencies included the Warren County Emergency Management, Warren County Emergency Services, Warren County Sheriffs Office, the Culkin; Fisher Ferry, N ortheastWarren County Volunteer Fire Departments, and the Vicksburg Fire Department.

I The Warren County reception center had the necessary space, sufficient equipment; . and

. trained personnel to provide radiological monitoring, appropriate decontamination, and I

registration of evacuees in the event of a radiological emergency: ' :' ' * * **." * * '

Operational checks of the radiological monitoring and survey i11struments were properly completed, and personal dosimetry was issued in 'accordance' with plans and procedures.

Emergency workers were knowledgeable of potassium iodide, exposure and contamination limits and the need to read their dosimeters frequently; Emergency workers in the I

decontamination stations were knowledgeable of how to place instruments into service and how to use them to perform surveys. Signage and plans were well placed in the decontamination areas to help emergency-workers perform their-tasks.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.e.1, 3.a;l,,6.a.l.

I

a. Levell Finding: None I

b. Level 2 Finding: None

• c. Not Demonstrated: None.

I

d. 'Prior Level 2 Findings '.'"" Resolved: None

e.

• Prior Level 2 Findings - Unresolved: None I

. .Mass Care Services Capability Summary:

Representatives from the Southwest Mississippi Chapter ,of the America Red Cross *and I

. Mississippi Department of Human Services successfully demonstrated the ..registration and temporary care of evacuees at the Warren County Central High School reception center. I The facility had ample space and reasonable.accommodations for its assigned purpose. The I

'48 I

I Radiological Emernency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station personnel demonstrated their ability to confirm evacuee. survey stc;ttus, conduct *evacuee I registration and to establish and maintain a shelter to meet the congregate care i:ieeds of evacuees in the event of a nuclear incident. S~rvice ~nimals' ~ould be* allowed *within the facility in an area separate from the.general population,with.a pet relief area available I outside with supervision of reception center staff.

?t" The employees and volunteers were well-versed in the emergency plans and procedures and I displayed positive attitudes* td meet:the physical and mental needs, of evacuees .. The equipment and supplies were sufficient and consistent with the assigned role. The facility

• .: was wellJaid-out, and .although*intended for only temporary*care, could expand if necessary, I to accommodate evacuees for several d;iys. Agency leaders were knowledgeable and

'; ., professional; and worked together .as: a team throughout the,exercise. * , .

• I *. For this capability the following Radiological Emergency Preparedness criteria were MET:

l.d.l, 1.e.l, 3.b.l, 6.c;l. .'!

I * * ,.a.

• LevellFindm:g: None .

b.

• L~vJl 2Finding: Nc:m~  :.*.,*.l.,.

I*

' 1' * . :"'.: ,*, -~ ' ,:. : :

. :r.

I c. Not Demonstrated: None

,,-*:,1 .'V.

cl.. Prior Level 2 Findings.-Restilved:

None I e.

• Prior Level 2 Findings -* Unresolved: .None 3.3.7.3 Medical Drill: Vicksburg Fire Departm~nt & Ambulance Service I Public Health, Healthcare, and Emergency Medical Services Capability Summary:

I Ori February 27; 2019 Vicksburg Fire Department Ambulance Service responders demonstrated the ability to provide medical treatment and transportation to an injured, radiologically contaminated individual with challenges. Their pick up and transport of the radiologically contaminated patient were conducted in a mariner that eould potentially spread contamination. '

I Vicksburg Fire Department Ambulance Service leadership did not conduc:t an emergency worker briefing for the ambulance service crew members. Tp.e protective clothing worn by I crew members consisted of coveralls-, with fciot co~ers attathed; hiultiple layers of nitrile surgical gloves; and a facemask. The attached foot covers led.to confusi6Ii.when entering the ambulance in preparing for patient transport. The responders were knowledgeable of the I operation of monitoring equipment and dosimetry. Dosimetry was wom*in the correct place for dose recording, and the responders were aware of their administrative dose limits; however, the dosimetryi was not read or recorded at intervals established by local .

• I , procedures.. ,.

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Radiological Emergency Preparedness Program I After Action Report

,* Ground cover was used to control the spread of contamination; however, glove changes 2019 Grand Gulf Nuclear Station I

were not performed at-appropriate intervals: The handling and* disposal of potentially contaminated materials* was done in a manner that could enable cross contamination. I

• In.side the ambulance, the responders demonstrated*,the'ability to provide' medical care to a potentially contaminated patient.. The responders demonstrated good teamwork and I excellent Communication.

• For this capability the following*Radiological Emergency Preparedness criteria were MET:

l.e.l. . .

I

a. Level tFinding: None

• I

b. Level 2 Finding:. 1 Issue Number: 028-19-3.a.1-L2-04 , :*

I Core Capability/Criterion: Public Health, Healthcare & Emergency Medical Service~/3.a11 .. , . . , .. , . * ** I

, ,*,  : : '*., _ ' ~; ' I , ~

• i ". '. ,. ' * * * *; : '* l *, ' J ' ! , ' _' * '* ; . '. . , . , ' .

Condition: Vicksburg fire Depiµtrp.ent Arpbularice Servic~ lead,ership did not fully provide einergency ~orkers w.hh:the appropriate instrudions ~n the'use of direct- I reading and permanent-record dosi:µietty, dosimeter chargers or potassium iodide.

Analysis: The Vicksburg Frie Department Ambulan~e crew did not d~monstrate I appropriate radiolog;ical exposure c~mtrol measures. An emergel).cy worker briefing was not provided to tlie crew members. Warren County Emergency Medical ServicesNicksburg Fire Department Procedure for Response to Radiological I Emergencies (2013)' checklists were not used by the crew members.. The lack of a briefing myant'that tp.e.f~llowing items were not discussed with the ambulance crew prior to dispatch: Potassium iodide was not provided, or its use discussed, use of I personal protective equipment, direct-reading dosimeters, thermolµminescent dosimeters, and Ludlum Model 14C; call back and tum back values. Protective clothing ~om, was inco~sistent withprocedures. The protective clothing consisted of I coveralls; with foot covers attached; multiple layers of nitrile surgical gloves; and a

faceriiask; th~ attached foot covers led to .confusion when entering the ambulance in preparjhg for patient transpor:t. During the demoristration, glove changes nor reading I

of direct~readl.ng dosim~ters were observed until the controller advised the workers.

According; t9 Warren County procedures, emergency workers are to read their direct-reading dosimeters every 30 minutes and record on their Exposure Control Card, I

which was not observed being used. ' - * *.

• After patient transfer occurred at the hospital, the ambulartde crew*members were I

unaware of the next actions to take. The controller 'was *requited to pause exercise

.play al).d provide jµst-in;-time training tQ.direct the workers on monitoring of the ambulance and themsel~es. Further, when d6ffi.ng his petsciri.al protective gear, I

I

• 50 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station

• improper*measures were,observed, as theworker removed his arms from the suit I rather than r~moving the itape and gloves first. This m~thodis not a recognized standard within the Radiological Emergency Preparedness Program.

I Possible Cau~e: Lack*of.an emergency worker.briefing prior to preparing to respond

• .

• to a potentially contaminated patient potentially contributed to emergency worker hazards.and poor contamination avoidance measures by the.emergency workers. It I was verbalized by the controller that the emergency workers had "left training early" the day that:training was provided. Improper training of the workers, coupled with the lack of an emergency worker briefing, could have attributed to the poor I emergency worker exposure and contamination avoidance efforts demonstrated. A stand-alone extent of play agreement which specified "correction_ on the spot" was not integrated into the primary extent of play agreement between Federal Em,ergency I Management Agency and the State. Excessive retraining during a graded event is conducive to negative training and reduced performance.

I *

• Referenc~: ~

• I. Warren County Emergency Medical ServicesNicksburg' Fire Department.

'~ ,,

• Procedure for Respon&e to Radiological,Emergencies. . .

I 2.

• NUREG-06'.541FEMA~REP~*1;F'.i; H)d;"i<::f:i;:K.5.a;

. . ~ '

b; L:t, 4.. ' .*"

Effect: Lack of art emergency worker briefing*pdor to response to the potentially I contaminated patient directly affected the performance of the emergency workers.

The offsite response organization;s lack of a formal briefing omitted critical I . * * . . . .

.. information such as appropriate dosimetry, potassium iodide, and procedures, as well I as management of raqiological exposure to' the _wo~k'ed an,d the patient. Lack of information regarding potassium iodide artddirect-re'acling dosiniet'ry c6uld directly affect the p.ealth and s,afety of the emergency wotk~rs? as potential exposure would I not be monitored, and the' guidelines for pbtassilu~

~ ' ' ' .I ' . ' '

• I '. i

• iodide' use would riot be known.

4 , ,

Recommendation: ' ' **

I 1. :J{eview and revise.curre~t procedures as needed to _include the use of an emergency worker briefing. Items for the briefing should include* key aspects of radiological safety such as: contamination control/avoidance, radiation exposure I to emergency workers, potassium iodide/i~smince insttucti<;ms,' in'stritctions for emergency workers after p~tient transfer, and donning/doffing procedures I 2. Review and revise the' annual training program to ensure 'that the crews are trained on the items contained in the briefing, so they are fal111liar with procedures and can properly execute their mission. . ' " ' '

I .c~ Level _2 Finding:

Issue,Number: .028-19:-6:d.l '-L2:..05 I Core Ca~abilityiCriterfon: Public Hehlth, Heahhc~e & E~ergency Medical services/6.d.1 . **' : , * * . * * * : ' . * ** * * -

I

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Radiological Emergency Preparedness Program I After Action Report

• 2019 Grand Gulf Nuclear Station Condition: Activities conducted in a mann'er,that could*potentially spread I

contamination to a patient.

I Analysis: The Vicksburg Fire Department Ambulance Service responders conducted activities in a manner*that could potentially*spread contamination to a patient. Upon

• ' arrival to the patient, one responder approached.her, carrying the medical I monitor/defibrillator and survey meter, and.the medical equipment and meter were

• • placed directly on the ground. Controllef'inject was necessary to advise the emergency workers to monitor the equipment prior to leaving the scene. One I responder was aware of the need to monitor open' wounds*; however, he did not survey

• the entire patierltforcontaminationcin accordance with procedure. In preparing the

patient for loading,: the sheets were incorrectly placed on the backboard, which I

hindered proper cover of the patient. In attempting to cover the patient, a sheet that .

was directly on the ground was used to cover the patient. Again, controller interjectl.on was necessary to correct the workers on proper contamination avoidance.

I Possible Cause: Lack,of an emergency worketbriefihg' and just in time*training prior to preparing to respond to a potentia:lly contaminated patient potentially I

\contributed to emergencywotker,hazards:and poor contamination*avoida,nce

• measures by the emerg'ertcy*workers. I

Reference:

1; Warren County Emergency Medical ServicesNicksburg Fire Department Procedure for Response to Radiological Emergencies I

2. NUREG-0654/FEMA-REP-1, F:2; H.10; K.a.3, K.4, K.5.a, b; L.1, 4 Effect: Poor contamination avoidance measures could directly affect the health and I

safety of the patient, as contamination could potentially be spread, and possibly delay urgent medical care for the patient. I Recommendation:

1. Current procedures should be updated to include the use of an emergency worker briefing. Items for consideration should include key aspects of radiological safety I

such as: contamination control/avoidance, radiation exposure to emergen,cy workers, potassium*iodide/issuance instructions, instructions for emergency workers after patient transfer; and donning/doffing procedures.

I

2. A more rigorous training program for emergency workers with State oversight and/or primarily conducted by Mississippi Emergency Management Agency, Radiological Emergency Preparedness Training. Additionally; updating written I

procedures to provide greater detail for contamination control/avoidance with additional practice demonstrations may be in order. I

d. Not Demonstrated: None

e. Prior Level 2 Findings-Resolved: None I

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I Radiological Emergency Preparedness Program I After Action Report

f. Prior Level 2 Findings - Unresolved: None 2019 Grand Gulf Nuclear Station I 3.3.7.4 Medical Drill: The Merit Health River Region Medical Center I The Merit Health River RegiqnMedical Center staff successfully performed the core capability of public health, health~are, and emergency medical servic,es of a contaminated injured patient. The Merit Health.River Region Medical Center had two operational I communications systemsavailabk, sufficient equipment and personn~l protective equipment to support emergency operations .. Hospital staff were issued appropriate dosimetry and procedure$ to manage radiological exposure in accordance with their plan I and procedures. The hospital,staff read their dosimetry every 15 IUinutes and recorded their readings on their Dosimetry Jss?e Sheet. Based on the locatio,n of the medical center,

• . potassium iodide would not be needed. , ,

I , .,:The medical center had sufficient space, adequate resources and trail)ed personnel to monitor, decontaminate and provide medical services to contaminated individuals. There I was a dedicated decontamination roomcj_ttachedto the Ewergency E.,oom_area. Proper contai:nination .control was performe<;t .ThejnstrQcti,qns of the lead buf{er zqne nurse,,in charge and a;radiation accidentpatienttrea,t:rnen.t.flow,chart,provided guidance for the I personnel in the decontamination room. The Radiati9I1 ~merge11cy Assi&tarice ;

Center/Training Site was contacted by telephone for additional guidance. Hospital staff followed procedures for donning and doffing personnel protective equipment, removing I contaminated clothing from patients, decontaminating the wounds, contamination control of radiation emergency area and samples, and the proper use of their dosimetry and radiological instrumentation.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.d.l, l.e.l, 3.b.l, 6.c.l.

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

c. Not Demonstrated: None I d. Prior Level 2 Findings-:- Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station Section 4: Conclusion I Overall, the exercise was a success. Officials and representatives from the State of Mississippi; the risk county of Claiborne; the host counties of Adams, Copiah, Hinds and Warren; and I numerous other organizations participated in the exercise. The co.operation and teamwork of the participants was evident throughout all phases of the exercise.

I The Federal Emergency Management Agency identified a total of five new level 2 findings during this exercise, leaving one level 2 finding and one planning issue unresolved from the 2017 exercise. The Federal Emergency Management Agency in agreement with the Mississippi State I Department of Health, Division of Radiological Health successfully resolved all outstanding level 2 findings and planning issues attributed to them during the redemonstratfons on August 8, 2019.

I The corrective actions of the remaining level 2 findings for Claiborne County and Warren County will occur during the 2021 Grand Gulf Exercise in accordance with the current program I policy.

The Federal Emergency Management Agency wishes to acknowledge the efforts of the many I individuals who participated and made this exercise a success. 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 I provide vital emergency services to their communities. State and local emergency response organizations demonstrated knowledge of their emergency response plans and procedures and I successfully implemented them.

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Radiological Emergency Preparedness Program After Action Report 2019 Grand Gulf Nuclear Station Appendix A: Exercise Timeline Emergency Time Time That Notification Was Made or Action Was Taken Classification Utility Field Claiborne Adams Hinds Copiah Warren Level or Event Declared SEOC nc DOSE EOF Team County County County County County Unusual Event 0814 0825 0825 - 0824 0827 0827 0839 0827 Alert 0848 0859 0859 0859 - 0855 0857 0857 0857 0857 0956/ 0957/ 0956/ 0956/ 0956/ 0956/

Site Area Emergency 0954 0959 0956 - 1011 101 1 1009 1009 1011 1011 1144/ 1144/ 1144/ 1144/

General Emergency 1141 1157 1143 1157

- 1157 1158 1144 1157 1144 Simulated Rad. Release 0944 1009 1041 1009 1009 1009 1033 1033 1033 1033 Started Simulated Rad. Release 1345 Ongoing Ongoing Ongoing 1201 Ongoing Ongoing Ongoing Ongoing Ongoing Terminated Facility Declared Operational 0915 0945 0915 0901 IOOO 0910 1027 0907 0930 Declaration of State of State !022 1022 1022 - - - - - -

Emergency Local - - - - !025 0957 0930 10 11 1141 Exercise Terminated 1347 1347 1347 1252 1345 1346 1346 1346 1346 Early Precautionary Actions:

Access and functional needs, nursing home, and 0935 hospital transfer Initial opening of Warren Countv RCCC 1027 1 Protective Action Decision:

Evacuate: l , 2a, 2b, 7 1027 1041 1027 - 1030 1030 1030 1030 1030 Monitor and Prepare: Remainder 1st Siren Activation 1045 1045 1045 - 1045 1045 1045 1045 1045 1st EAS Message: # 1 1045 1045 1045 - 1045 1045 1045 1045 1045 2"" Protective Action Decision:

GE/No PAD change 1205 - 1205 - 1205 1205 1205 1205 1205 2"d Siren Activation 1220 1220 1220 - 1220 1220 1220 1220 1220 2"" EAS Message: #2 1225 1225 1225 - 1225 1225 1225 1225 1225 KI Administration Decision: EWs Ingest 1257/ 1257/

1305 1305

- 1300* 1257 1257 1257 1257 57

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station Appendix B: Exercise Evaluators and Team Leaders I Regional Assistance Committee Chair: Randall Hecht I Section Chief: Robert Spence Site Specialist: Gerald McLemore Location Evaluation Team Core Capabilities I Mississippi Emer2ency Mana2ement A2ency I MEMASEOC Matt Bradley Paul Nied Operational Coordination Operational Communications I TomHegele Linda Gee/FEMARVI I MEMAJIC Taneeka Hollins /

FEMARI Public Information and W aming I MEMA TCP (OOS) FEMA Mississippi Devartment of Radiolo2ical Health On Scene Security Protection I DRH SEOC Dose Jill Leatherman Situational Assessment I DRHEOFDose Tom Essig Situational Assessment I DRH Laboratory John Fill Field Team Jim Harworth Environmental Response/Health and Safety I Management DRH Field Team 1 Kent Tosch Environmental Response/Health and Safety I DRH Field Team 2 Claiborne County Debora Blunt I EOC Glenda Bryson Deshun Lowery Henry Christensen Operational Coordination I Backup Route Alerting Glenda Bryson Public Information and W aming I Schools EWD (OOS)

Glenda Bryson FEMA Critical Transportation Environmental Response/Health and Safety I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

Location Evaluation Team Core Capabilities TCP (OOS) FEMA On Scene Sefurity Protection I Adams County EOC John Fill Jim Greer Operational Coordination I Reception Center I Congregate Care FEMA Environmental Response/Health and Safety I Mass Care* Services (OOS)

Copiah County , I Quintin Ivy EOC Marynette Herndon Operat)onal Coordtnation I

Reception Center /

Congregate Care (OOS)

FEMA Environ_ment~ I,lesponse/Health and Sa(ety Mass Care Services I Hinds Countv Lorenzo Lewis I

EOC Operational Coordination Daniel Loomis Reception Center /

I Environmental Response/Health and Safety Congregate Care FEMA (OOS) I Mass Care Services I

Warren County EOC Michael Dolder Meg Swearingen .Operational Coordination I

. Charles Williams. (OJT)

I Reception Center / . 'Enviro~entai Response/Health and Safety Congregate Care *

(OOS)

FEMA Mass Care Services I MSD.(OQS)

FEMA FEMA t

Public Health, Healthcare & Emergency Medical Services

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I Radiological* Emergency Preparedness Program I .After Action Report 2019 Grand Gulf Nuclear Station Appendix C: Grand Gulf Extent of Play Agreement*

I 2019 PLUME

- PHASE .FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE *.1.* ,,, . .

I All activities will be denionstrated fully in accordance with respective:plans and procedures as .

they would be in an actual emergency (Federal Emergency Management Agency must receive I these plans, guides and procedures no later than 60 days before the exercise). This Extent e>f Play agreement is written by exception. Ifit is not listed as an excyption it will.be demonstr~ted as described in the plans, standard operating guides and/or procedures. Any issue or discrepancy I arising during exercise play may be re-demon*strated if allowed by the Radiological Assistance Chairman or as listed herein. This allowance may be granted if it is not disruptive to 'ex~rcise

• play and is mutually agreed to by the Lead off-site response orga,n;ization controller and Lead.

I Federal Emergency Management Agetic'yevaluator. '

1. Core Capability: Operational Coordination- State Emergency Operations Center,**

I Claibo~ne .. A.dams; Copiah, Hinds and Warren Counties

. l '* " / : \ ,; J i

• Definition: Establish and maintain a unified- and coordinated operational structure ai:id proc~ss I :or that appropriately integrates all critical stakeholders and supports the execution cdre ; '*_.. ' ',

capabilities.

I 1.1 Capability Target: Emergency Operations Management I Critical Task 1.1.1: Off-Site,response organizations use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG.0654

• A.I.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.3.a.i H.3; 4; Criterion lal). Radiological Program Manual Pg. 180 .* ,,.

• I Performance Measure: (1) Off-Site response organizations must demonstrate the capability to I receive notification of an incident from the licensee;. (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must.demonstrate the ability to receive and/or initiate notification to the licensees or other respectiye-,emerge1;1cy I management organizations of an inddent i_n* a timely manner when they receive information. (5)

Demonstrate the ability to maintain and staff 24-hour operations. (6) Off-Site response . *.

organization must demonstrate the activation of facilities for immediate.use by mobilized I personnel upon their amval-(7) Thelocation and contact information for facilities in~luqed in the incident command must be available to all. appropriate responding agencies and the nuclear*

power plant. (8) The ability to identify and request additional resources or identify I compensatory measures must be demonstrated.

Off-Site response organization exception: Agreed I Critical Task 1.1.2: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

I

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Comniunications :capabilities are* managed in support of emergency -operations (NUREG .0654 F.l, 2; Criterion ldl). 'RadiologicalPrograrn,Manual Pg:.f8t.* i *.

... . . ; ~ ' *.' I.*! ( I Performance Measure: (1) Off-Site response organization must;demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, field monitoring teams, and incident command must have the capability to access at least one communication I system that is independent of the commercial telephone system. (3) Responsible Off-Site response organization must deinonstrate the capability to manage the c0mmunication systems and ensure that all message traffic is handled without delays that might disrupt emergency I operations. (4) Off-Site response organizations must ensure that*a coordinated communication link for fixed and mobile medical support facilities exists>

I Off-Site response organizations exception: Agreed Critical Task l'.13:* Equipment, maps; displays, monitoring instruments, dosimetry, potassium I

iodide, andothet suppli~sare,sufficient to support emergency operations (NUREG.06~4 H.7; *10; I.7; 8,* 9;-J:'10.a, b;*e;* J.ll, '12;* K3:a;K:.5.:b; Criterioirlel). ,Radiological'Program ManuaLPg. -. .

182 ,. :'*:.:*

1

_ * - .... ,*,.* i *. , : * ,'*./.,* *: .. *,*. ..*.*;

I

',*-,:'. I l . ,

Performance Measure':* (it)* A pattfoular fability's.eqµipment and*supplies must be sufficient and consistent-with that facility's,assigned;rolein.the off-site response organization's emergency I

operations plans. (2) For non:..facility-:hased operations;-the equipment and supplies must be sufficient and consistent with the assigned operational role. (3). At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic I

cones, and signs) must be available: (4) Responsible Off-Site response organizations must demonstrate the capability to maintain inventories of potassium iodide sufficient for use by: (a) emergency workers, ancillary groups as identified'in plans or specialized response teams (e.g.,

I civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must'indude the forms to be used for documenting emergency worker ingestion of potassium iodide:(6) Off-Site response organizations physical inspection at the I

storage location(s) or through documentation of quantities of dosimetry and potassium iodide available and storage locations(s) will be confirmed by current inventory submitted during the exercise;-proVided in the annual letter' of certification submission; and/or verified during an Staff I

Assistance Visit ::.(7} Off..;Site response organizations must demonstrate the capability to

• maintain inventories of appropriate direct-reading and: permanent-record ,dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary, groups as identified in plans or I

specializedresportseteams: (8) Appropriate direct-reading dosimetrymust allow an individrtal(s)-to rea&the administrativerepoiting limits and maximum exposure.limits contained in the.Off-Site response:organization's plans/procedures. (9) All monitoring instruments must be I

inspected, and* operationally* checked before each use. *Instruments must be* calibrated in** ,

accordance with the manufacturer's recommendations. (10) A label:indrcating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must I

have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate I when it is response-checked using a standard test source. (12) In areas where portal monitors are I

I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Oulf Nuclear Station used, the Off-Site response organizations-must set up and operationally.check the monitor(s),

I The monitor(s) must conform to the stanc:lards set forth in the. Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA.REP.21 (March 1995) or in accordance with the manufacturer' s*.recommendations.

I '.

Off-Site response*organizations exception: *Agreed.

I 1.2 Capability Target: Precautionary aQd/or Pr9teciir,e Action Decision M;aking Critical Task.1,2.1: Key personnel witbJeadership roles for the, off-site response organizations I provide direction and control to that part of the overall response ,effort for whi9l;i. they are responsible (NUREG.0654 A.l.d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Radiological Program Manual Pg. 181 I Performa1'ce Measure: (1) Leadership personnel mµst deITionstr~te the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through I periodic briefings and/or other means, coordinating with other Off-Sjte response organizations, . ,.

• and ensuring completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through I memorandum of understanping ,or other .agreements) Wben f~ced with. competing' demands. for finite resources. Any resour.ces identified through. letter o~ .agre.ement/memorandum of , ...

understanding must be on the off-site response organization's mobilization list, so .they may be I contacted during an incident if needed. * .. ,.

Off-Site response organizations exception:* Agreed I Critical Task 1.2.2: Off-Site response organiZations*use a decjsion.-making process, considering relevant factors and apprbpriate coordination; to ensure that an1 exposure control system,

• including the use of potassium iodide, is in place for emergency workers ine_luding provisions to authorize radiation exposure in excess of administrative limits*,or protection.action guides (NUREG.0654 C.6; F; K.3.a; K.4 Criterion 2al). Radiological Program, Manual Pg,, 184-:-185 ..

1 Performance Measure:_ (l).Off-Site response organizations authorized to sen.d:~erge]).cy workers into the plume exposure. pathway emergency planning zone must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures\ * (2) *Off-Site response organizations must also ~einonstrate the capability to .

• make decisions concerning authorization of exposure levels iu *excess of pre-authorized levels I and the number of emergency workers receiving radiatioRdoses above pre-a_uthorized levels.: .(3)

This would include providing potassium iodide and dosimetry in a timely, mal,lller to*emergency I workers dispatched onsite to support,plant incident assessment a,nd.rnitiga~ing,a,ction,s, in accordance with respective; plans/procedures.

l '!.

I Off-Site response organizations exceptiom Agreed r ,* ,,1 I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

Critical Task 1: 2. 3: . A decision-making process* involving *consideration* of appropriate. factors and necessary 'Coordination is used to make protection action*decisions for the general public.*-. *

(including the recotnniendation for the use 'of potassium iodide, if offc.site response' otganizations I policy)'(NUREG:0654 A.3: C:4;* 6: DA; J,9; J.10.e.f; m Criterion 2b2). Radiological Program .

Manual Pg.185 * . *

• . 1 :i/' :, . ,

I Performance* Measure:. (1) *Off-Site response organizatfon*s* must have the capability to make both initial and subsequent precautionary* and/or protective *a:otion decisions in a tiinely manner.

appropriate to the incident,*based ori information from the licensee,, assessment of plant status I

and potential or actual releases, other available information related to the incident, inputJrom

• appropriate off-site response organizations authorities (e.g., incident command), and protection action recommendations from the utility and off-site response organizations staff. (2) In I

addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an hostile action ba:sed incident, weather, release timing and magnitude). pose undue risk to an evacuation or if evacuation may disrupt the efforts to I

respond to a hostile action.(3) Off-Site response:orgartizations* must demonstrate the ability to obtain supplemental resources (e:'gi, mutual* aid) necessary to implement a precautio11ary and/or

• protective action decision if focal law enforcement;fire service*, hazardous materia:l,,arid I

emergency medical resources *are *used-to: m;igment response to the nuclear* power plant site or* * ,

other key infrastructure., (4)4fthe !off-site r~sj:>onse organizations: has determined that potassium iodidewill*be used *as a protective measure:for the general public under offsite plans/procedures, I

then it must demonstrate the capability to make decisions on the distribution and administration of potassium iodide to supplement sheltering and evacuation. This decision must be based on the off-site response organization's plans/procedures or projected thyroid dose compared with the I

established protection action guide for potassium iodide' administration. The potassium iodide deti'sion-making process must involve close coordination with,appropriate assessment and decision-making :staff. * (5) If more than one *off-site response organizations is involved in I

decision making, all appropriate Off-Site response organizations must communicate and coordinate precautionary, and/or protective action decisions with each other. , (6) In addition, decisions must be coordinated/communicated with.incident command. Off-Site response .

I organizations must d.emohstrate*the capability-to connnuriicate the results of decisions to all the affected*locations: *--  ;

• I Off-Bite *res'ponse- 01:'ganiz'ations exception: Agreed

• <, :. ' 'i_.'

Critical Task 1.2.4: Protective action decisions are,made, as appropriate, for *groµps of persons I

with disa:bilities*and access/functional needs (NUREG.0654 D.4; J.9; J;lO.d, e; Criterion 2cl).

Radiological Progtam"Martual Bg. 186

. ;,_)

I Performance,Measures: '(l}Usu.tlly it is appropriate to implement evacuation in areas where doses are projected to exceed the 'lower end ofthe range of protection ,action guides, exceptJor

• I incidents . wheie there* is a high-risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are irtvolved: (2} In these cases, factors that must be considered include weather 'cbrtditions, shelter availability ,1 availability of transportation as~ets; risk of evacuation. I versus* risk from the avoided *dose, and,precautionary school ,evacuations., In, addition, decisions I

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station must be coordinated/communica,ted witµ the incident.command.- In situations where an

• I institutionalized population cannot' be evacuated, the off""'.site response organizations must .

consider use of potassium iodide. {3) Off-Site response. organizations must demonstrate the capability to alert and.notify all public school systems/districts of emergency conditions that are .

I expected to or may necessitate protective actions for students. Demonstration requires that the Off-Site response organizations actually contact public school systems/districts during the exercise. (4) Off-Site respcmse organizations m:ust.demcmstrate hqw the decision-making I process takes those with disabilities and acc,ess/functional ipeeds.( e ..g., nursing. bomes,

• correctional facilities, licensed-day c,ares, mobility,,impaired individuals, and transportation-dependent:individuals) into account., ",. .. .. . , ,...

I Off-Site response .organizations except.ion:. Agreed. 'i I 1.3 Capability. Target: Protective Actio.n Implementation

' ! ~ !... I (j ,J I'~ ' , I . * ' '. ~* -  ;: ',,*,*, ,*':!

Critical Task.li.3.1: . Off~Site response:organizationsissue approprif!t6 dosimetry, potassium I iodide; ,and,procedures,.and manage radiological ~xposure t0 .eNJ.ergeucy,workers in ac:cord.ance .*

• with the plans/p"rocedures ..*Emergency workers perjodkally~,c;lo*d, at ~he en<d.-of e.ach.mission read.

their, dosimeters *and record.the readings,011-the: ap~ropriate,exposure._r_ecord or. chart . Off-Site I response organi!lations maintain appropria,te .record"ke~ping :of the1admini,1,tration of potass1.urn., ,

iodide to emergency workers (NUREG..Q654J.10.e~-K~J.a1 b, K.4; Criterion 3al) .. Radiological Program.Manual Pg. 189-190.  ;, ,..

• I Performance :M;easures: (1) Off-Site response organizations umst demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-I reading and permanent-record dosimetry, dosimeter chargers; potassium iodide, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that I are pre-established at a level low enough to consider subsequent calculatio*n of total effective dose equivalent and. maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the off-site response organization's plans/prncedures .. (2) Each I emergency worker must have basic knowledge of radiation exposure limits as specifiedin the.

off-site response organization's plans/ procedures. If supplemental resources are used, they must I be provided with just-in-time training to ensure basic knowledge of radiation exposure control.

Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers I must demonstrate the procedures to, be followed when administrative,exposure limits, and turn-back values are reached. (4) Off-Site response organizations must demonstrate the actions described in the plans/procedures by determining whether to replace the worker, authorize the I worker to incur additional. exposures,, or take other actions .. (5) If exercise play does not .require.

emergency workers to -seek authorizations. for additional. exposure, ev:alua.to.rs must, interview at least two w0rkers to determine their knowledge;. (6) Although itis*desirable*for all emergency I workers to each have a direct-:-reading*dosimeter, there*may be situations where team members will be in close proximity to,each other during the*entire mission and can share a direct read.

• dosimeter. Each teani member-must still have.and maintain.his or her,ow.n penmanent-record '.

• I

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dosimetry. (7) Off-Site response organizations must ensure thatthe process used to seek authorization for exceeding dose limits does not negatively'impact the capability to respond to an incident where lifesaving and/or protection of valuable* property may require an urgent response. I (8) Off-Site response organizations must demonstrate the capability to accomplish distribution of potassium iodide to emergency workers consistent with decisions made. Off-Site response organizations must have the capability to develop and maintain lists of emergency workers who I have ingested potassium iodide, including documentation of the date( s) and time( s) they did so.

(9) Emergency workers must demonstrate basic knowledge of procedures for using potassium iodide. If exercise play does not require emergency workers to consume potassium iodide, I

evaluators must interview at least two workers to determine their knowledge.

Off-Site response organizations exception: Agreed I

Critical Task 1.3.2,' potassium iodide;and appropriate instructions are available if a decision to recommend use of potassium iodide is made; Appropriaterecmd-keeping of.the administration I

of potassium iodide for institutionalized individuals and the general public is maintained (NUREG.06541.10.e, f; Criterion 3bl). Radiological Program Manual Pg. 190 I Performance Measures: (1) Off~Site response organizations must demonstrate the*capability to make potassium iodide available to institutionalized individuals and, where provided for in their plans/procedures, to members* ofthe general* public. :(2). Off-Site response organizations must I

demonstrate the capability to accomplish distribution of potassium iodide consistent with decisions made. (3} Off-Site response organizations must have the capabilityto develop and maintain lists of institutionalized individuals who have ingested potassium iodide, including I

documentation of the date(s) and time(s) they were instructed to ingest potassium iodide. Off-Site response organizations must demonstrate the capability to formulate and disseminate instructions on using potassium iodide for those advised to take it. (4) If a recommendation is

• I made for the general public to take potassium iodide, appropriate information must be provided to the public by the means of:notification specified in the off-site response organization's plans/

procedures; *

• I Off-SiteTeiponse organizations exception: *Agreed

. I ( \ I I t ~ *' ' ' I I

Criiical Task 1.33: ; Appropriate traffic and access ,control.is established. Accurate instructions are provided to traffic:and:access *control personnel (NUREG.0654 A.3; C.1, 4; J.10.g, j; Criterion 3dl) Radiological Program Manual Pg.191-192 I

Performance Me*asures: * (1) Off-Site response organizations must demonstrate the capability to select; establish, and staff appropriate traffic and access control points consistent with current I

conditions' and protection* action decisions (e.g.; evacuating, sheltering, and relocation) in a timely niamier: *(2) Off-Site response organizations'must demonstrate the capability to provide in:struciionsto traffic and acce&s control sta'.ff on actions to takewhen*modifications in.protective I

action strategies* necessitate, changes in evacuation patterns odn *the area(s) where* aceess.is ,

controlled. (3) Traffic and access control staff must demonstrate accurate knowledge .of their I roles and responsibilities, including verifying emergency worker identification and access I

I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station authorization to the affected areas.; (4) 1Ininstances where off-:site response ,organizations lack I authority necessary to, control access .by certain types of traffi.c (e,g., rail, water, l:l.Ild,air traffic),

they must demonstrate the.capability ,~o. contact the State,orFederal agencies that have the needed authority. , . . , . .* .*.. *, ( :., . ,

I * ,.~ \ j . ",* : *. ; ; ' ... '~, ,i Off-site response ,organizations .exception:* Agreed j

. { :, ,*

I Critical Task 1.3.4: Impedimentsto evacuation are identified and.resolved (NUREG.0654.

J.10.k; Criterion 3d2). Radiological Program Manual Pg. 192 -1 ,

**:* ;1 ' * .

I Performance Measures: (1) off-site response organizations must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in place during the evacuation long enough that rerouting of traffic is I required and (3) must also result in demonstration of decision-making.and coordination with the Joint information Center to communicate the alternate route to evacuees. .

• I Off-site response organizaticms exceptiom Agreed.*

2~ Core (apability:, Critical Transportation ..-:-:- Claibopne County: . *: I ~ ** '

I Definition: Provide transportation '(including infrastructure access and accessible transportation services) for response priority objectives, including the. evacuation of people and animals, and I the delivery of vital response personnel,.equipment,:and services into the affected areas.

2.1.: Capability Target: Protective Action Implementation I Critical Task 2.1.1: off-site response organi,zations/School officials implement protective actions for schools (NUREG .0654 J, 1O.c, d,. e, g; .Criterion 3c2) .. Radiologicaly Program Manual J;>g..191 I Performance Measure: (1) School systems/districts (these include public and private schools, kindergartens, and preschools) must demonstrate the ability to implement precautionary and/or I protective action decisions for students. (2) Each school system/district within the 10-mile emergency planning zone must demonstrate implementation of protective actions. At least one I school per affected system/* district must participate in the demonstration .. (3) Which protective action is implemented (evacuation to reception centers, relocation to host schools, .cancel the school day, early dismissal, shelter in place), all activities to coordinate and complete the process should be evaluated. (4) School personnel including decision-making officials (e.g., schools' superintendent/principals and transportation director/bus dispatchers) and* at least one bus driver (and the bus driver.'s escort, if applicable) must be available to demo:p.strate knowledge.of their I role( s) in the evacuation of school children. * (5), Communications capabilities between school officials and the.buses, if required by the plans/procedures, must be verified. (6) Officials of the school system(s).must demonstrate the capability to develop and provide-timely information to I Off-Site response organizations/parents for use in messages to parents, the general public, and the media on the status of protective actions for schools.

I I

Radiological Emergency Preparedness Program I After Action Report off..:site response organizations exception: Agreed: . ' . *,,. ,.;;:, i; .

2019 Grand Gulf Nuclear Station I*.

I

3. Core Capability: Sifoational Assessment .;,;.Dose Assessment, Emergency-Operations,

• Facility * *, ' ' , :, , . * , , * **.1 ,: ; i :i * -: .

I I

1;,,,i._:*:c * *  ; * ** ' { :* ,*. ~ ** j : ) ; ;  : ** l.:; . :

Definition': 'Provide* all decision 'makers with decision-relevant information regarding the nature and extent oft~e' haz~rd;* any' cascading** effects; and the status- of the response. *

• \ .'::'.i ' .:'.; *,

3.1. *Capability' Target:: 'Precautionary and/ot Protective' Action Decision *Making:' .. ,, I

) .

Critical Task 3.1.1: Off-Site response organizations use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system,:

I ihchiding the:use of potassium iodide,, is in place fot emergency workers,.including*provisions to authorize radiati6n*exposure in excess of administrative limits'or protective action guides.

(NUREG.0654/FEMA REP.1, C.6; f; K.3.a; K.4; Criterion 2.a.l). Radiological Program Manual I

Pg. 184 Performance Measures: (1) Off-Site response organizations authorized to send emergency I

workers into the plume exp6sure'pathway emetgehcy-planning zone -must demonstrate a*.

• capability to 'comply ,with emergency worker exposure limits tfased on their emergency plans/procedures. (2) Off-Site response organizations must also demonstrate the capability*to I

make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number -of emergency workers,teceiving radiation doses above pre-authorized levels<. (3)

This would include providing potassium iodide 'and dosimetry in a timely manner to emergency I

workers* dispatched onsite to support plant incident assessment and mitigating actions, in

• accordance with respective plans/procedures. I Off-Site response organizations exception:- Agreed

• Critical Task*3.l.2: Appropriate protective action recommendations (protection action I

recommendations) are based on available information on plant conditions, field monitoring data, and licensee and off-site response organizations dose' projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG.0654/FEMA.REP.l, 1.10 and Supplement 3; I

Criterion 2~bll) Radiological Program Manual Pg. 184-185 *

. ~. -: ' : i : ' r; ' .~ .

Performance Measures: (t) The off-site response organizations must demonstrate the I

capabilitfto*:use'the,.appropriate means described in the plans/procedures to develop protection action *retoirtrii.eridatioils for. decisi01t-makers based on available information and recomrtlendations'p'tovided-by the licensee, as' well'as field monitoring data if available.

I Workers must also*:d:msider artytelease and,meteorological data provided1by the licensee. (2) .*

The off-site response organizations must demonstrate a reliable' capability to .independently I validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the protection action recommendations must be appropriate to the scenario. In all cases, calculation of projected dose must be demonstrated. I I

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I Radiological Emergency Preparedness Program After Action Report 2019 Grand Gulf Nuclear Station I

Projected doses must be related to quantities and units of the protection action guide to which I they will be compared. (3) Protection action recommendations must be promptly transmitted to decision-makers in a prearranged format. (4) When tbe licensee ;md off,site response organizations projected doses differ by more than a factor of 10, the off-site response I organizations and licensee must determine the source of the difference by discussing input data and assumptions, using different model~, or exploring possible reasons.. Resqlution of Jhese . . ,

differences must be incorporated into the protection .a.ction recommendations jf timely .an.ct I appropriate. (5) The off-site response organizations must demonstrate the capability to use any additional data to refine projected doses .and exposure rates c;tpd revjse, the associated prot~ction.

action recommendations. * .*

• I Requires .correction: ,. ij *.* , , , 1*.* , ,, * , ., -.. * ,c.;: .,-; .. .

.: -Condition:* (028.17 ;2.b.1-L2!02). :(he. State of Mississippi ,dose a.ssyssment team did ,not I pro:vide the.State Emergeucy Operations Center sta(f with c1,ccurat~ res1,1,lts in ,a timely,*** 1.,

.* manner. C ** -~)

• f I Off-Site response organizations exception: Agreed

. .' ....... ~.; : j .* *. .* ,,: ; ',~:

4. Core Capability:, Dperational Com,munfcatirn,§ *-:- Stflte; Erp.ergency Open1.tjon;s C(mter, Field I Teams, Laboratory ,Emergency Operations Faciljty, ,Cl~J.jqorne,-Adam,s,, Copiah;- Hinds and Warren Counties

• I Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I 4.1 Capability Target: Emergency Operations Management I Critical Task 4.1.1: At least 2 communications systems are available, at least 1 operates properly, and communication links,a,re establisheq . and maintajned with appropriatelo~ations.

Communications capabilities are managed insµpport of emergency op~ratjqns (NURE:Q,0654-F.1, 2; Criterion ldl). Radiological Program Manual Pg. 180 .. ," .

Performance Measure: (1) Off-Site response organizations must demot1strate that a primary system and at least one backup system are fully functional. (2) All faciiities, field monitoring team's, and incident.command must have the capability to access at least one communication system that is independent of the commercial telephone ,system.. (3) ~e~pcmsible ..o,ff,.site i I response organizations must demons tr.ate the capabilityJo rpanageJh~* co~unic;~tign systenis ..

and ensure that all mess*age. traffic is han.dled without delays th~t mjght:disrvpt eme.rgency., ,

I operations. ,(4) Off-Site ,response organiiations must epsµre. tbat, a ~oo,rdinate9. c9mnn.mic;ation link for .fixed and mobile medical *support facilitie& -ex:ists. .

11' I Off-Site resp0ns~ organizations exception: Agree~

' '\ ~

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

5. Core Capability: Public Information and Warning-Joint information Center/Joint information System, and :Clp,iborne: Couniy, . , *,

IJ : ' *:,, .**\*'

,< **. t' < *: ;. *.

• I Definition: Deliyer.*coordinated; :prompt; reliable, and actionable information to the whole, community through the use of clear, consistent:, accessible; ,and culrurally and linguistically ,

• appropriate methods to effectively relay information regarding any threat or hazard and, as I appropriate, the actions being taken and the assistance being made available.

5.1 Capability Target: Emergency Notification and Public Information I Critical Task 5.1.1: Off-Site response organizations use effective procedures to alert, notify, and mobilize emergene::y persorinel and activate facilities i11:a timely manner(NUREG.0654 A.La, e; I

A.3, 4; C.1, 4, 6; D.4; Ed,i2; G.3.a; H:3;4;. Criterion lal,).. Radiological Prqgram ManuarPg.

180* *,, '.,,.*'..,,*,,

• 1* *1* :,

.* (-**.

• • • 1 ' ( **:

Ii ',." *,,

' :.1.

I Performance Measure:, *(1) Off.. Siteresponse organizatioris must demonstrate the capability.(2) 1 contact, alert, and mobilize key emergency personnel in a timely manner, (3) Demonstrate the ability to maintain and staff 24-hour operations. (4) Off-Site response organizations must I

demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival'. (5) The location and:contact'information for facilities included in the incident command must be available to all appropriate responding agencies and the nuclear power plant. (6} The **

I ability to identify and request additional resources or identify compensatory measures must be demonstrated. I Off-Site response organizations exception: Agreed Critical Task 5.1.2: At least 2 communications systems are available, at least 1 operates I

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

Communications capabilities. are managed in support of emergency operations (NUREG .0654 F.1, 2; Criterion ldl}. Radiological;Prograni Manual*Pg. 180 I

Performanqe-Measure: (1) Off-SiteTesponse organizations must demonstrate that a pf<i.mary system*and at least one *backup system are fully functioiiaL (2) All facilities, field monitoring I

team"s, and incident command must ,have the capability to access at least one .communication system thatis)ndependentof the commercial telephone system. (3) Responsible off-site.

response organizations must 1demonstrate the capability to manage the communication systems I

and ensure that all message. traffic is handled without delays that might disrupt emergency operations .. I Off-Site response- organizations exception: Agreed

'  :... , t r.. . *.. ~ * .1 *** ! * * !

Critical Task 5,J'.J.:* Equipment; maps; displays, ;monitoring instruments, dosimetry, potassium

• I iodide; and other supplies are:sufficrent to support.emergency operations (NUREG;0654* H.7, 10; 17, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Radiological Program ManuaLPg,, I 182 I

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I Radiological, Emergency Preparedness Program I After Action Report

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I 2019 Grand Gulf Nuclear Station I Performance Measure: (1) A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the off-site response organization's emergency operations plans., (2) For non,.facility-based operations, the equipment and.supplies must be.

I sufficient and.consistent.with the 'assigned operational role .

. *' ~: . f ' 'i Off-Site response organizations exception: Agreed I Critical Task 5.1.4: hnpediments tci evacuation are identified andresolved (NUREG.0654 *

. J.10.k; Criterion 3d2). Radiological Program Manual Pg. 192 I Performance Measures:. (1) Off-Site response *organizations must-demonstrate, t)le capability to identify and take appropriate actions concerning.impediments to evacuations. (2) The . .

I impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the Joint information Center to communicate the alternate route to evacuees~: , .

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Off-Site response O:rgarnizations e.xicepUoit.. Agreed *;11 L:"; .;, ;- , r,.,; ;

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Critical Task5. l. 5:. Activities associat,ad with priinarydjbfrtingt and; notification of the'public are 1 comp1eted in a timely manner* following the ,initial clecision by authorized offsite emergency .

• officials to notify the public of an emergency situation., The initial :instructional message to the I public must include as a minimum the elements required by current Federal Emergency ,*

Management Agency Radiological Emergency Preparedness Guidance (Timely: The responsible off-site response organizations personnel/representatives demonstrate actions to disseminate the I appropriate information/instructions with a sense of urgency and without undue delay)

(NUREG.0654 E.5, 6, 7;, Criterion Sal). Radiological Program Manual Pg. 198-199

• I Performance Measure: *(l) Responsible off-site response organizations must demonstrate the capability to sequentially provide an alert signal followed by .aninttial instructional message to populated areas throughout the 10-mile plume exposure pathway emergency planning zone.

I Following the decision to activate the alert and notification system,,(2) Off-Site'response *

• organizations must complete system activation.for primary alert/notification and disseminate the I information/instructions in a timely manner. For exercise purposes, timely is ,defined as "with a sense of urgency and without undue.delay." (3) Procedures to broadcast-the message must be fully demonstrated as they would in an actual emergency up to the point of transmission.

I Broadcast of the message(s) or test message(s)'is not required.;The.pr9cedures must be - .

demonstrated up to the point of actual activation. The alert signal activation should be*

simulated, not performed. Evaluations of emergency alert system broadcast stations may also be I accomplished through Staff Assistance Visit s. (4) The capability of the primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview with appropriate personnel from the primary notification ,system, including verification I of provisions for backup power or an alternate station. (5) The initial messa,ge must include at a minimum the following elements: - '

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Radiological Emergency Preparedness Program I After*Action Report 2019 Grand Gulf Nuclear* Station I

• Identification of the off-site response organizatiQns .responsible and the official with authority for providing the alert signal-and instrudiortal*message;

• .**Identification 6fthe commercial nuclear power plant and a Statement that.an emergency I exists there; ' ' , * * : , , ;'

• • Refetenceto REP-specific emergency informatibri (e.g:, brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and I

• A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population: tune to another station for ..

• additional ,information.. ' I

( 6) If route alerting is demonstrated as a *primary method of alert and notification,it must be done in accordance with the off..:sfre response organization's plans/proceduresi Off-Site response organizations iimst demonstrate the capability to accomplish the primary route*alertingin a I

timely manner (not subject:to specific time requirements). At least one route needs to be *

• demonstrated and evaluated. The selected route(s) mu.st-vary.from*exercise to exercise: .* ..

• However, the mo*st difficult-rbute(s) niustbe demonstrated*rio less than once every eight years.:

I (7) All alert and ilotificatioira:ctivities alongthe.route(s) must be simulated (i.e., the message that would actually be used is read for the evaluator, butnot actually broadcast: (8) Actual testing of the mobile public address:systemwill:be-conductedat *ail agreed-uponfocation... *: .. , *: * * * * * ,1*

I Off-Site.1:espbnse *organizati611s exception: Agreed;

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I Criticdl Task 5.1. 6: Backup alert and notification of the public is completed within a-reasonable time following the detection by the *off-site response organizations of a failure of the primary alert and notification system (NUREG.0654E.6; Appendix 3.B.2.c; Cdterioh 5a3). Radiological I

Program Manual Pg. 199 Performance Measure: (1) Backup alert and notification procedures that could be implemented I

in multiple stages mtist be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first.*. The populations farther away and downwind of any potential radiologicalrelease would be covered sequentially (e.g., 2 to 5 miles, followed by downwind 5 I

to 10 miles, and finally the remaining population as directed by authorities). (2) Although circumstances may not allow this for all situations, Federal Emergency Management Agency and the NRCrecbmmend.that off-site response organizations and operators attempt to establish I

backup means that'will reach those in the plume exposure pathway emergency planning zone within: a reasonable,time of failure of the primary alert and notification system, with a of recommended goal 45*ininntes.*(3) The backup alert message must, at a minimum, include:

I (a) a statement that an emergency exists;at the plant and (b) instructions regarding where to obtain additional information*.:When*backup route alerting is demonstrated,.only one route needs to be selected.and demonstrated. All alert and notification activities along the route(s)*must be

• I simulated (Le:*; 'the message that would actually be used is read for :the evaluator, but not actually broadcast); as negotiated ,iJi the extent of play. (4) Actual testing of the mobile public address*

system will be conducted*at an agreed-upon location.

I Off-Site: response.organizations exception: Agreed .

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station Critical Task.5.1.7.: Ensure off-sjte,response organizations,provide accurate emergency I I information and instructionstothe1public ancl the news media in a timely manner (The*

• responsible off~site respons.e organizations personnel/representatjves demonstra.te actions to disseminate the appropriate information/instructions with a sense of urgency and :without undue I delay} (NUREG.0654 E.5, 7i G._3.a~- G.4.a, c; Criterion Sbl). Radiological Prograrp_ Manual Pg.

200-201.

I Performance Measure: .( 1) The responsible off-site response organizations personnel/representatives must demonstrate actions to provide emergency information al)d instructions to the public and media in a :timely mann¢r following ,t4e initial,al~r_t; anq. 11otification I (not subject to specific time-require,me_nt&;) .. For exercise. pm:poses,-:timely i~ defi_ned as "with a .

sense of urgency;and without ,undu'~ delay:: Message elements;* (2) The o:ff'-_site; responsy organizations must ensure thatemergency:information and instru<;:tions ate;<::.onsistent with._ .-; :

I protection- action deeisions madeiby appropriate ,officiaJs..- .(3) The'.emergency inforruati9n.must contain:all necessary- and applicable* instructions.-(e.g.-,.evacuation, jnstrue:tions,, evacuation routes, reception center location.s;:what tG'. tak:e,when .evacuating;, sheJter:.iP:'.:place,- instrµctiq_ns, I infopnation.concemjng :protective *actions for; schooJsJmd-persons with dis_abilities,and, access/functional ne_eds,:-and publiG* inquiry, hotline* telephon~ -nurnber). to.as:sist the public -in, carrying out the protection action decisions provided (4) The off-site response organizations I must also be prepared to disclose and explain the emergency classification level of the incident.

At a minimum, this information must be included in media briefings and/or media releases. (5)

Off-Site response organizations must demonstrate the capability to use language that is clear and I understandableto the public within both the plume and ingestion exposure pathway emergency planning zones. (6) This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas. (7) The emergency information*must be all-.

I inclusive by including the four items specified under exercise Demonstration Criterion 5.a.1 and previously identified protective action areas that are still valid, as well as new areas. (8)

Information about any rerouting of evacuation routes due to impediments should also be , .

I included. (9) The Off-Site response organizations must demonstrate the capabjlity to ensure that emergency -information that is no longer valid is rescinded and not repeated by broadcast media.

(10) Off-Site response organizations must demonstrate the capability to ensure that current I emergency information is repeated at pre-established intervals in accordance with the .

plans/procedures. ( 11) Off-Site response organizations must_ demonstrate the capabjlity to ..*

I develop emergency information in a non:-English language when required by the._.

plans/procedures. Media information: (12) Off-Site response organizations IP-l:1St demonstrate the capability to provide timely, accurate, concise, and coordinated information tC? the news I media for subsequent dissemination to the public. (13) This .would in,clude demonstration of the capability to conduct timely and pertinent media briefings and distribute media; releases:as the incident warrants. (14) The off-site response organizations must demonstrate the capability J0 I respond appropriately to inquiries from the news media_. (15) All information presented in media briefings and releases must be consistent with protection action- decisions and other emergency .

information provided to the public. (16) Copies.of pertinent emergency information (e_.g.,.

I emergency alert system messages and media releases) and media information kits must be available for dissemination to the media. Public Inquiry (17) Off-Site response organizations must demonstrate that an effective system is in place for dealing with calls received via the I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I

public inquiry hotline. ( 18) Hotline staff niust demonsti-atethe dapabiiity to provide ot obtain accurate information for callers or refer them to an appropriate information source. (19)

Information *from the hotline staff, includin'g information that corrects false or inaccurate

• I information'When: trends are noted, must be included, as appto'priate; iri emergency information*

provid~d to the public, media briefings, and/or media releases*. . ' .'

I Requires correction:

'Condition: (028~175.b.1-L2.0l) Message preparation*, including emerg~ncy alert

. system and supplemental*rtews releases, were irt conflict between the State and Claiborne I

County; Established protocols for the Exe*cutive* Director (ot his designee) and the

• Director of External Affairs both* approving messaging was notobserved. These ' . *

• messages. did* not adequately 'relay the protective action: decisions of the Sta'.te and County I

leadership. Particularly, the initial Emetgericy Alert Message issued a*"Moriitor arid*

.Prepare" order and the fdrirth supplementary news release modified the order to ".Shelter in Place." During media briefings, the State Lead Public Information Officer did not fully I

explain the protective actions of "Monitor and Prepare," Shelter in Place," and "Evacuate" as it pertains to what the public should do to comply with these actions. The geographical boundaries provided to the public in press releases were in sync with the I

safety calendar, however, they'did:not meet'the inforit'ofthe leadership's prbt6ctive

• action dedsion-to evacuate only;to 'the 5-b:iile boundary of the Protective Action Area.

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Off-Site response organizations exception: Agreed

6. Core Capability:- Environmental Response/Health and Safety - Dose Assessment, Field I

Teams,*Laboratory, emergency operations facility, Claiborne, Adams, Copiah, Hinds and Warren Counties I Definition: Conduct appropriate measures tO' ensure the protection of the health and safety of the public and workers, *as well as the environment, from all-hazards in support of responder operations and the affected communities.

I LOCATION Out-of-Sequence Scheduled Activities ACTIVITY MONTH DATE TIME I

Copiah County **

Hirids* County '

RCCC Rcet Feb Feb 14th 25th 6:00 PM - 10:00 PM 6:00 PM - 10:00 PM I Claiborne County Ewn* Feb 26th 9:00 AM - 12:00 PM Claiborne County Adams County TCP/ A3 RCCC Feb Feb 26th 26th 2:00 PM - 3:00 PM 6:00 PM - 10:00 PM I Warren CountY. MSD Feb 27th 8:00 AM - 1:00 PM W arreri *county MEMA RCCC SAY .

Feb Fyb * >

27th 23th 6:UO PM - 10:00 PM 9:00 AM~ 10:00 AM I

MSbH/DRH SAV. Feb ... 28th' 10:~0 AM~ 11:00 AM I

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I Radiological Emergency Preparedness Program After Action Report 2019 Grand Gulf Nuclear Station I 6.1 Capability Target: Field ;l\1e~sµf_~µi~nt and Analysis I

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Critical Ta_sk 6).1: Off-Site re~ppnse organizations use ~ffective proc~dure_s to _alert, notify, ap.d mobil~ze em~rgencr per~onne.l fin<;:tactjvate facilities i11,a tirp.ely mc).nner (NlJ~Q.0654 A. l.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.a.3;,.H.3, 4; Criterion)al). Radiological,Progr!lrµ}.Ylanual Pg ..

I 180 I Performance Measure:. (1) Off-Site r~sponse organizations must demonst~ate.the capability to, (2) contact1 alert, and mobiliz~ key ern"ergepc;y_ persc;mnel in a timely. manner, (:3)° D~monstrate the ability to maintain and staff 24..,hour, operatio_ns. (4) Off-Site .response organizations must I demonstrate. the activa_tion of, facilitie~ f9r immediate µse b.y mobHized personnel upon their arriy<1,L. (5).The location ~nd contac.t infoi:mation.for facili,ties included in the.incident command must be available to all appropriate responding agencies and tl;le nucle~r p~wer plant.; (6) The I ability to identify a.nd request addit~on.al i:esourc;es _or i4entify compensatory i;neasures must be demo11~trat~d. . _ .. ,

I Off-Site,rewons~ qrgqnizations exc;ep.tiqn;. Agi;eecl.

2 CriticaJ Task 6.1.2: At._ least- ~QIPlll~~catio~s ~yste~s '.ru;~. a,;ailable,_ at _least .1. ope;ates I properly, and communication links are .established aqd.i;nai~{air1ed with appropric.tte.locaf~ons.

Communications capabilities are managed in support of emergency operations (NUREG.0654 F.1, 2; Criterion ldl). Radiological Program Manual Pg. 181 I Performance Measure: (1) Off-Sjte response; organizations must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, field monitoring I teams, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible off-~ite response organizations must demonstrate the capability to m~age the communication systems I and ensure that all message traffic is handled without delays that.might disrupt emergency operations.

I Off-Site response organizations exception:. Agreed Critical Task 6.1.3: Equipment, maps, displays, monitoring instruments, µosime~ry, potassium I iodide, and other supplies are sufficient to support emergency operations (NUREG.0~54 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Radiological Program Manual Pg.

182 . . . *, ..

I Performance Measure: (1) A particular facility's equipment and sqppli~s must be'sufficient.

I and consistent with that facility's assigned role in the off-site response org£1.nizatioA's emergency operations plans. (2),-For non-fadlity-based operations, the equipment and:supplies must be sufficient and consistent with the assigned operational role. (3) Responsi~le off-site response '

• I organizations must demonstrate the capability to rriaintain inventories of potassium iodide.*'.

sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) members of the general public, (4) The I

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station plans/procedures must include the forms to be used for documenting emergency worker I

ingestion of potassium iodide. (5) Off..:Site response organizations. physical inspection at the.

storagefocation(s) or through documentation of quantities of dosimetry and potassium iodide ,

available and storage loeations(s)will be confirmed by current:inventory submitted during the I

exercise, provided in the annual letter of.certification submission, and/or verified during a Staff Assistance-Visit . *( 6) Off-Site response organizations must demonstrate the capability to maintain inventories of appropriate'direct read and permanent-record dosimeters in sufficient I

quantities for use by: {a) emergency workers, ancillary groups' as identified in plans or specialized response teams*. (7) Appropriate direct-reading dosimetry must allow an I individual(s) to read the administrative reporting limits and maximum exposure limits contained in the off-site respornie organization's plans/procedures. {8) All monitoring instruments must be inspected,- and operationally checked before each use. Instruments must be calibrated in ;_ I accordance with the manufacturer's reconunendations" (9) A label indicating such calibration must be on each instrument. (10) In addition, instruments being used to,measure activity must.

have a sticker-affixed to their. sides indicating the effective:Tange of the readings. The range of I readings, documentation specifies the acceptable range.of readings that the meter should indicate when it is response-checked using a standard test source. ( 11) In areas where portal monitors. are used, the off-site response.organizations must setup and operationally check the,monitor(s). Tbe I monit.or(s} must conform to .the* standards Bet forth in the Contaminatio°: Monitoring Standard for

a Portal Monitor Used for Emergency Re*sponse, FEMA.REP .21 (March .1995) or in accordance with the manufacturer's recommendations.

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. Recommended for correction: ** ,

Condition: (028.17.1.e.1.P.Ol) Radiation monitoring equipment was not appropriate or I

in sufficient supply to support emergency operations. Field monitoring teams were not*

sufficiently equipped to monitor radiation levels in a high gamma radiation field. The teams did not have backup supplies of calibrated low.:.Ievel radiation survey instruments I

and calibrated/charged air pumps for collecting an air sample.

Off-Site response organizations exception: Agreed .

I Critical Task 6.1.4: Off-Site response organizations issue appropriate dosimetry, potassium iodide, and procedures, and manage radiological exposure to emergency workers in accordance I

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. Off-Site response organizations maintain appropriate record-keeping of the administration of potassium I

iodide to emergency,workers (NUREG.0654 K.3.a, b, K.4; Criterion 3al). Radiological Program Manual Pg. 189

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. Performance Measures: (1) Off-Site response- organizations must demonstrate the capability to provide emergency workers (including supplemental resources)with the appropriate direct-reading and permanent-record dosimetry, dosimeter chargers, potassium iodide, and instructions I

on the use of these items, For evaluation purposes, appropriate direct,.reading_dosimetiy is defined as dosimetry that allows an individual(s) to read the administrativ:e reporting li!I)its .that are pre-established at a level low -enough to. consider subsequent calculation of total effective *: .

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station dose equivalent and maximu,m exposure liniits, for those emergency workers involved in I lifesaving activities, contained in the.off-'site response organization's plans/procedures. , (2) Each emergency worker must have basic knowledge of radiation exposure limits as specified in the off-site response organization'.s plans/procedures. If supplemental resources are used, they must I be provided with just-in-lime otraining,to :ensure basic knowledge of radiatioll'expcisure control. .

Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure controL, (3) During a plume phase exercise, emergency workers I must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. (4) Off-Site response organizations must demonstrate the actions described in the plans/procedures* by determining whether to replace the worker, authorize the .

I Worker to incur additional exposures\ or take other actions. * (5) If exercise play does not require*

emergency workers to ,seek authorizations for additional exposure, evaluators, must interview. at least two workers to determine their knowledge. (6) Although it is desirable for.all emergency* .

I workers to each have a direct-reading' dosimeter, there may be situations where team members will be in close proximity to each other ,during the entire mission and can share a direct read dosimeter ... Each team member must *still *have and maintain. his or; her, own .permanent- record

• I dosimetry. (7) Off~Site.response organizations must ensure tha,t.the process used to seekr*

authorization f0r exceeding 1dose limits d0es not'negatively impactthe capability.to respond to an inddei:itiWhere :l1fesaving and/or. protectiori of ;valuable property may require ,an urgent response:

I (8) Off-Site response organizations'mustdemonstrate the'capabtHty to accomplish distribution of potassium iodide to emergency workers consistent with:deci'sions *made. Off-Site response organizations must have the capability to develop and maintain lists of emergency workers who.

I have ingested potassium iodide, including documentation of the date(s) and time(s) they.did so. *

(9) Emergency workers must demonstrate basic knowledge of procedures for using'potassium iodide. If exercise play does not require emergency workers to consume potassium iodide, I evaluators must interview at least two workers to determine their knowledge.

Off-Site response organizations* exception: Agreed I Critical Task 6.1.5: Field teams (two or more) are managed to obtain sufficient information to help characterize the release and to control radiation.exposure (NUREG C.l; H.12; I.7, 8, 11; I J.10.a; Criterion 4a2). Radiological ProgramManual Pg: 195 Performance Measure: (1) Responsible off-site response organizations must d~monstrate the I capability to brief field monitoring teams on predicted plume location. and direction, plume travel speed, and exposure control procedures before deployment. (2) Teams must be directed to take measurements at such locations and times as nece*ssary to provide sufficientinformation to. *.

• I characterize the plume and its impacts. If the responsibility for obtaining peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from off-site response .organizations, there is no requirement* for these measurements to be: repeated by off-site response organizations monitoring teams. (3) If the licensee 'field monitoringteams do not .

obtain peak measurements in the plume, it is the off-site response organization's decision as to

• whether *peak measurements are necessary to. sufficiently characterize the plume. ( 4) The sharing and coordination of plume,measurement information among all field monitoring teains s (licensee, Federal; and off-site response organizations) is essential: ,

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Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station Requires correction:

I Condition: (028-l 7-4.a.2-L2.03) The Mississippi Radiological Emergency Response Team Coordinator failed to instruct the field teams to utilize a silver zeolite cartridge for obtaining an -air :sample. -* The Radiological Emergency* Response Team Coordinator. never I

instructed either field team to make an aitempt'to locatethe-cei1terline of the plume. The coordinator also allowed significant time to pass before finalizing airborne activity calculations and providing that data to dose assessment for confirmation of projected I

dose. The Radiological Emergency Response Team Coordinator was unprepared and had little knowledge on how to perform the activity:calculations on the Field Estimate of I Airborne Activity Form. Shortly *after the release, *a field team conducted an air sample

• in the plume. That tearri wa:s then sent to low background area to stage and* await further instructioh jnstead of obtaining more data or locating the centerline.

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I Off-Site response organizations exception: Agreed I

Critical Task 6.1. 6: *Ambient radiation measurements are made and ,recorded at appropriatfi **

locations, and tadioiodine and particulate samples are collected. -Teams will move to .an ..

appropriate low-background location to- determine whether any significant(as specified in the. *. I plan and/dr procedures} amount:oftadi:oactivity has bee*n collected on the sampling media. *

(NUREGC.1; I8,' 9; H:12; J,10.a;*Ci1iterion4a3). Radiological ProgramManual Pg. 195-

,,. ,, . ' I Performance Measure:* ( 1) Two* or more field monitoring teams must demonstrate the capability to make and report measurements of ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority. (2) Field monitoring teams must also I

demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and to provide the appropriate authority with field data pertaining to measurement.

(3) If samples have radioactivity significantly above background, the authority must consider the I

need for expedited laboratory analyses of these samples. (4) Coordination concerning transfer of samples, including a chain-of-custody form(s), to a radiological laboratory(ies) must be demonstrated. (5) 0 ROS must share data in a timely manner with all other appropriate off-site I

response organizations.* All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form(s) for transfer to a laboratory(ies), will be in accordance with the off-site response organization's plans/procedures.

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Recommended for correction:

-Condition:** (028.17.4.a.3.P.02) The Department of Radiological Health procedure needs I

revision to clarify methodology for air sampling to ensure that proper methodology is

• followed for collecting and*analyzing a quality air sample to use for making dose assessment calculations and making protective actions for the public. Personnel also I

need to have additional training on air sample procedures and why certain steps are vital to trucing *a vaHd air sample. I I

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station I Off-Site response organiiatio~1s ,exception: Agreed. , , , . : . ,

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Critical Task 6.1.7: The*laboratory is capable of performing required radiological analyses to

• I support protection.action decisions,:(NUREG.0654 C.l; 3; J.11; Criterion;4cl}. Radiological Program Manual Pg. -197 , , ,,: ,

I Performance Measure:** (1) The laboratory staff must ,demonstrate the .capability to follow appropriate procedures for receiving,samples,.including logging informati9n, preventing cont_amination of the laboratory(ies), preventing buildup of background radiation due to stored I samples, preventing cross contamination of samples, preserving samples: that may spoil ( e.g.,

milk), and keeping track of sample identity. (2) In addition, the laboratory staff. Illl)St ..

demonstrate the capability to prepare samples for conducting measurements. (3) The I laboratory(ies) must be appropriately equipped to provide, upon request, timely analyses of media of sufficient quality and sensitivity to support assessments and decisions anticipated in the off-site.response organization'.s plans/procedures. (4) The laporatory instrument calibrations I must be traceable to standards provided.by the National Institute of Standards and Technology.

Laboratory methods. used.to analyzetypical,radi*onuclides rele.a.sed in a r.eaqtorincident Illi;tst be as described in .th~ plans/procedures: . New or.revised, metbods may: be. u&e~:ltq analyze atypical I radiomicli'dereleases (e.g.,, transuranic or as a result ofAtei:r9rist incident) or if warranted by .

incident circumstances. Analysis may require resources beyond those of the off-site response organizations ... (5) The laboratory staff must be qualj.fied, in radio analytical. techniques a1,1d *..

I contamination control procedures.

Off-Site response organizations exception: Agreed I 6.2 Capability Target: Support .Operations and Facilities

• I Critical Task 6.2.1: Equipment, maps,displays, monitoringinstrµments, dosiJlletry, potassium iodide, and other supplies.are sufficient to support emergency operations (NUR,EG.0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Radiological Program Manual Pg.,

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Performance Measure: (1) A particular facility's equipment and supplies must be sufficient I and consistent with that facility's assigned role in the off-site response organization's emergency operations plans. (2) For non-facility-based operations, the.equipm_ent and supplies must be I sufficient and consistent with the assigned operational role: (3) Responsible off-site response organizations must demonstrate the capability to maintain inventories* ofpota.ssium iodide sufficient for use by:. (a) emergency workers, ancillary groups*as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized indiyiduals and (c)

I members of the general public, (4) The plans/procedures must iµclude the forms to be used for documenting emergency worker ingestion of potassium iodide. (5) Off-Site response I organizations must demonstrate the capability to maintain inventories of appropriate direct read and permanent- record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or.specialized response teams. (6) Appropriate direct-I "79 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station

. reading dosimetry must allow an individual(s).to readtbe,administrative reporting limits and I

maximum exposure lin;uts contained in the off,site response,organization' s plans/proce,dures., (7)

All monitoring instrum~nts must be inspected, and operationally checked. before .each use ..

Instruments mustbe*calibrated in accordance with the,manufactun;~r?s recommen~ations. (8) A_

I label indicating such: calibration.must be pn each instrument: ,,(9) In.addition, instruments being used to measure activity must have a sticker-affixed to their :Sides indicating the effective range .

of the readings.*The range of readings documentation sp~i{ies the acceptable range of readings I

thatthemeter should indicate when iti~ response-checked.using a standard test source. (lO)In areas where portal monitors are used, the off-siteresponse,organizations i:nust set up and I operationally check the monitor(s). The monitor(s) must conform to the standards set forth ~n the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA.REP.21 (March 1995) or in accordance with the manufacturer's recommendations. I Off-Site response organizations exception: Agreed . *: , ,.

I

• Critical Task 6.2.2: Off-Site response organizations issue appropriate dosim~try, potassium iodide, 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 I

.theic~osimeters. and record the readings. on ,the ~ppmpriate exposure record or cbart.: Off-Site ,.

• response organizations maintain. appropriate record-keeping ofahe administration. of potassi1,1m iodide to emergency workers (NUREG.0654-K.3,a; b, K.4,; Criterion 3al). Radiological I

Program Manual Pg. 189 .*

Performance Measures: (1) Off-Site response organizations must demonstrate the 9apability to I

provide*emergency workers (including supplemental resources) with the appropriate direct-reading and permanent- record dosimetry, dosimeter chargers, potassium iodide, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dQsimetry -is I

defined a.s dosimetry.that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of total effective dose equivalent and. maximum exposure.limit~, for those emergency workers involved in I

lifesaving activities, contained in the off-site response organization's plans/procedures. (2) Each emergency worker must have basic knowledge of radiation exposure limits as specified in the off-:site._response organization's plans/procedures. If supplemental re~;ources are used, they must I

be provided with just-in-time training to ,ensure basic knowledge of radiation exposure control.**

Emergency wm:kers must demonstrate procedures to monitor and re.cord dosimeter readings and manage radiological exposure.control: .-(3) During a plume phase exercise, emergency workers I

must demonstratethe procedures to be followed when administrative exposure limits and turn-back-values are reached. {4) Off-Site response organiz,ations must pemonsti;ate tbe actions described in the plans/procedures by determining whether to replace the worker, authorize the

• I

• worker to incur additional exposures, or take other.actions. (5) If exercise play does not require emergency workers to ,seek authorizations for additional exposure, evaluators must il;lterview at least two. workers to determine their know ledge. (6) Although .it is desjrable for all emergency I

workers to each have a direct-reading dosimeter, there may be situations where _team members .*

will be in close proximity to each other. during the ,entjre _missiqn and, can share a direct read dosimeter. Each team.member must still hay~ and maint5"-n his .or her, .0,wn permanent- record I

,.;80 I

I

I RadiologicaI*Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station dosimetry: (7) Off-Site tesponse'organizations mustensure that the process used to seek . * .

I authorization for exceeding dose limits,does not negatively* i'mpact the capability to respond to,an incident-where lifesaving'and/or,protection of valuable property may require an-urgent response.

(8) Off-Site response* organizations* must* demonstrate the capability to accomplish distribution of I pbtass:iuin iodide to.emergency workers*corisistent with decisions made: Off-Site:response organizations must have the capability to' develop* and maintain lists of emergency workers who.

have ingested.potassium iodide~ including documentation of the date(s) and time(s) they did so ..

I (9) Emergency workers *must *demonstrate basic knowledge oLprocedures, for using potassium iodide. If exercise play does not require emergency workers to-consume potas'.sium-iodide, evaluators must interview at least twn workers to ,determine their knowledge. i ,

I Off-Site response organizations exception: Agreed .

I Critical Task 6.2.3: The reception center facilityhas appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees (NUREG:0654 A.3; C.4; J.10.h;*J.12; Criterion 6al}. Radiological P.rogta:m Marnia! Pg. 202.203 I ~ C' ~

• Petforma:itce Measure:

, . :* ,, * ' ; ** ) ,*

• t ~ *, ** ! } .: ',.:' , * : 1 ' , ~

(1)' Ratliological' monitoring, deconta_mination,, and registration ... ,:*! .

facilities for eva'.cuees must be set up and *demonstrated as, they .would be -in an actual emergency.

I (2) Off-Site response organizations conducting this detnonsti;ation* must have (a) one:cthird of the resources (e.g., monitoring teams/instrumentation/portalriiorlitors) available at the facilit'.Y(ies) as necessary to monitor (b) 20 percent of the population within a 12-hour period; (c) This would * '

I -- - .. --- - -- --- include adequate space~for evacm~es.:.--vehicles,-(3}-Availabi-lity- ef resources- ean-be demonstrated- -

with valid documentation (e.g., memorandum of understanding/letter of agreement, etc.)

reflecting how necessary equipment would be procured for the location. (4) Plans/procedures*

I must indicate provisions for service animals. (5) Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (6)

Staff responsible for the radiological monitoring of evacuees must demonstrate the capability to I attain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to -

monitor the 20 percent emergency planning zone population planning .base, Adams County estimated evacuees is 3710; Copiah County estimated evacuees is: 4029; Hinds County .

I estimated evacuees is: 851; and Warren County estimated evacuees is: 1859. (7).'fhe .*

monitoring productivity rate per hour is the number of evacuees that can be monitored, per hour, I by the total complement of monitors using an appropriate procedure. Adams County '.

productivity rate per one monitors per hour is 309; Copiah County productivity,rate per one monitors per hour is: 336; Hinds County productivity rate per one monitors per:hour is:* 71; and Warren County productivity rate per one monitors per hour is: 155; (8):FOF*demonstration of I monitoring; decontamination, and registration capabilities, a minimum ofsix,evacuees must be monitored per station using equipment and procedures specified inthe1 plans/ procedures.* (9) '

I The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators to determine whether the I:2-hour requirement can be*met. -(10) Off-Site response organizations must demonstrate the capability to register-evacuees, upon completion of I the monitoring and decontamination aotivities. ( 11) The activities forrecording radiological*

monitoring ,and, if necessary, decontamination niust include establishing a registration Tecord consisting of the(a)evacuee's name, (b)address,-(c) re'sults of monitoring, and(d) time of ,

I ';,81 I

Radiological Emergency Preparedness Program I After Action Report

• 2019 Grand Gulf Nuclear Station decontamination (if any), or as otherwise designated in the plan andlor,procedures:. Audio I

recorders, camcorders, or'written records-are all acceptable:mean:s for registration. (12) *

• Monitoring'activities' shall-not be simulated: (13) Monitoring personnel must.explain,use of.

trigger/action levels for' determining the need for decontamination:; ( 14) They must also explain I

the procedures for: referring any .evacuees who* caimcit' be* adequately decontaminated for assessment and follow-'l'.ip' in *accordance with the off-siteTesponse.organization' s, I plans/procedures.* All activities must be based on the off-site Tesponse organization's **.

plans/procedures and* completed as they would be in ari actual emergency. Decontamination of evacuees may be* simulated arid conducted by interview: ( 15) Provisions for separate showering I and 'same-sex decontamination must be demonstrated or explained.: ( 16) The staff must demonstrate provisions for limiting the- spread of contamination. Provisions could include floor coverings, signs; and appropriate means (e.g.; partitions; roped-off areas) to*separate I uncontaminated from potentially contaminated areas. (17) Provisions must also exist to (a) *

• separate contaminated and uncontaminated evacuee~; (b) provide changes of clothing for .those

• with contaminated clothingr and (c) store contaminated clothing and personal belongings;to.

• I prevent further contamination of evacuees or facilities.- *{18)In addition; for any evacuee found to'be contaminated; procedures must be discussed coneerning handling of potential contamination of vehicles -and personal belongings.-. Waste water from.decontamination .*

I operations, does not need to be coltected:; .( 19) Individuals .who *have coniple,ted monitoring and*,

decontaniin'ation if needed, 'Inust have.themeans(e:g.; hand stamp, sticker,,bracelet, form, etc.)

indicating that'(a)they,arid their service animals and vehicles, where applicable, have been I

monitored, cleared, arid found to have no contamination or (b) contamination below the trigger/action level or (c) have beeri placed in a secure area until they can be monitored and*

decontaminated,if necessary. In accordance with plans/procedures, individuals found to be I

clean after monitoring do not need to have their vehicle monitored. These individuals do not require confirmation that their vehicle is free from contamination prior to entering the congregate care areas. (20) However; those individuals who are found to be contaminated and are then .

I decontaminated will have their .vehicles,.(a) held in a,secure area or (b) monitored and decontaminated (if applicable) and do requite confirmation that their vehicle is being (c) held in a secure area ori (d) 'free from contamination prior. to entering the congregate care areas.

I Off-Site response organizations exception: Agreed I Critical Task 6.2.4: The facility/off-site response organizations has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles (NUREG.0654 K.5.a, b; Criterion 6bl). Radiological Program Manual Pg. 203.204 Performance Measure:* (1) The* monitoring staff must demonstrate the.capability to monitor emergency worker personnel*and their equipment and vehicles for contamination in accordance; with the off-site response organization's plans/procedures. Specific attention must be given to equipment, including any vehicles that were in contact with contamination. -(2) The monitoring I

staff must demonstrate the capability to make decisions on the need for decontamination of personnel;,equipment, and vehicles based on trigger/action levels and procedures stated in the

• off-site* response organizations plans/procedures*.' MC>nitoring ofemergency workers ,does no,t *.*

I

82 I

I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclem; Station have to meet the 12-hour requirement. ,(3) However; appropriate monitoring procedures must be I demonstrated for a minimum of.two emergency workers and ,their yquipment and vehicles .. (4)

Before using monitoring instrument_(s),themonitor(s)mu:st demonstrate the process of checking the instrument(s) fo~ proper operation. (5).The area:to be used for monJtoring:and I decontamination must be set np as jtwould be in an actual emergency, with: aJl route markings; instrumentation, record. keeping, and contamination control measures. in place. * (6) Monitoring procedures must be demonstrated for a minimum*of one veh,icle. It is generally not. necessary to, I monitor the entire surface of vehicles. *Cl) However, the capability to monitor areas. such as.

radiator grills; bumpers,. wheel wells, tires, and door handles .must be demonstrated. (8) Interior*

surfaces of vehicles that were in contact with contaminated individuals must.also be checked.

I Decontamination of emergency workers may be simulated andtccinductedviainterview. (9)

Provisions for separate showering*and same-sex decontamination:mu_st be demonstrated.or, explained. (10) The staff must demonstrate provisions, for limiting the spr,ead ofi;ontaminc:1Jiqn,.

I Provisions could include Jloor coverings; signs1 and appropriate means (e.g., partitions, roped:-off areas),to separate uncontaminated from potentially*contaminated areas, .(11) .Provisions mµst also exist to separate contaminated 1and uncontaminated individuals. Where ;applicable, provide I changes of clothing for those with contaminated clothingi, and store co,ntaminat~cl clothing, and personal belongings to prevent further contamigation. bf-emergency workers or f&cilities., :( 12)

Offi-Site,response. organizations musLdemortstFate tbe capability tQ.register; emergency wqrJcer$

• I upon;c0mpletion ofthe monitoring and;decontaminationiae.tiv.ities. **The activities'Jor recpr;ding *,

radiological monitoring.and if necessary, decontamination:must include,establishing a ,

registration record consisting of the (a) emergency worker's name, (b) address, (c) results of .

I monitoririg; and, (d) time of decontamination (if any), or as otherwise designated in the.

• plans/procedures. Audio recorders, camcorders, or written records are all acceptable. means. for*

registration.,_ Monitoring activities shall not be simulated. (13) Monitoring personnel must .

I explain use of trigger/action levels for determining the need for decontamination. ( 14) They must also explain the procedures for referring any emergency workers. who cannot be agequately decontaminated for assessment and follow-up in accordance with the off.site response . * ..

I organization'.s plans/procedures. Decontamination capabilities-and provisions for vehicles and .

equipment that cannot be successfully decontaminated may be, simulated and conducted by interview. Waste water from decontamination operations does not need to be collected.

I Off-Site response organizations exception: Agreed I 7. Core Capability: On-Scene Security, Protection*, and Law Enforceui~nt-:-- Cl_aibom~ ,

County : *, ,,

I Definition: Ensure a safe and secure environment through law enforcement and related security and prote~tion operations for people and communities located within affected* areas .and. also for I response personnel engaged in lifesaving andJife-sustaining operations.

7~1 Capability Target: Protective Action Implementation .....

I Critical Task 7. L 1: *At least 2 communications .systems are;available; at.least 1 op~rates" properly,. and* communication;. links are. established *and maintained with .appropriateJocations.

I

'83 I

Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station Communications capabilities are managed in support of emergency operations (NUREG.0654 I

F.l, 2; Criterion ldl). Radiological Program Manual Pg:* 180*>. ".* .

Performance Mea'.sur~: .(,1) Off:;Site response organizations ,nmstdemonstrate that a primary*

I

. system and atleast one backup system are fully functionaL (2}All'. facilities,. field monitoring teams, and incident command must have the capability to access at least one *communication ,* I system that is independent of the commercial telephone system. (3) Responsible off-site .

response organizations must demoristrate the Capability to manage the communication systems and ensure that all* message traffic is handled without delays that might disrupt emergency I operations.

Off-Site response organizations exception: Agreed , I Critical Task 7. l.2: Equipment .(to include commuriications), maps, displays, m~mitoring .:

instruments, dosimetry, potassiumiodide, *and other supplies are sufficient to support emergeqcy I

operations (NUREG.0654 H;7,,1Q;J.7, 8, 9; J.10.a, b;e;.J.11/12; K.3.a;.K.5.b; Criterion lel):

Radiological Program Manual Pgi.

• 182 .

• I Performance Measure: (1) A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the off-site response organization's emergency operations plans. (2) For non-facility-based operations, the equipment and supplies must be I

sufficient and consistent with the assigned operational role. '(3) At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) The plans/procedures must include the forms to be used I

for documenting emergency worker ingestion of potassium iodide .. (5) Appropriate direct-reading dosimetry must allow an individual(s) to read the adµrinistrative reporting limits and maximum exposure limits contained in the off-siteresponse organization's plans/procedures.

I Off-Site response organizations exception: Agreed I Critical Task 7.1.3: Off-Site response organizations issue appropriate dosimetry; potassium iodide, and procedures, and manage radiological exposure to emergency workers in accordance with tlie plans/procedures. **Emergency workers periodically and.at the end of each mission read I

their dosimeters and record the readings on the appropriate exposure record or chart. Off-Site.

• response organizations maintain appropriate record-keeping of the administration. of potassium iodide to*emergency workers (NUREG.0654 K.3.a, b, K.4; Criterion 3al). Radiological I

Program: Manual Pg: 189 Performance Measures: (1) Off-Site response organizations must demonstrate the capability to I

provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent- record dosimetry, dosimeter chargers, potassium iodide, and instructions on the use *of these items. For evaluation purposes, appropriate direct..reading dosimetry is I

defined as dosimetry that allows an individual(s) to read the administrative.reporting limits that are pre-established at a level low enough to consider subsequent calculation of total effective dose equivalent and maximum exposure limits, for those emergency workers involved in I

I I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station lifesaving activities, contained in tq.e.off-site response organization's plans/pro.cedures .. (2) Each I emergency worker must have basic, knowledge of radiation exposure limits as specified in the off-site response organization's plans/procedures. Emergency workers must demonstrate procedures to monitor and;record,dosimeterreadings and manage radiologicalexposure control..

I (3) During*a plume phase exercise,'..emergency workers must demonstrate the procedures to be followed when :administrative exposure limits and tum-'back values are reached. *(A-) If exercis.e .

play does*not require: emergency workers to seek authorizations for additional exposure, ;

I evaluators must interview at least two workers to determine their knowledge., (5) Although.it is desirable for all emergency.workers to each have a direct-reading'dosimeter,.there.may be situations where team members will be in close proximity to each other during the entire mission I and can share a direct read dosimeter. Each team member must still have and maintain his or her

. own permanent- record dosimetry. (6) Off-Site response organizations must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the I capability to respond to an incident where lifesaving and/or protection; of valuable property may' require.an urgent response. (7) .Emergency workers must demonstrate basic knowledge of procedures for using ,potassium iodide. *If exercise .play does* not require emergency workers to I consume potassium iodide, evaluators must interview at le'ast t'Yb workers to determine their

• knowledge.

-~ ! ,* .* i * ,; ; f. I .

• I Off.::Site *response organizations*exceptidn:.- Agreed,. , i,_

Critical Task 7 .1.4: Appropriate traffic and access e:ontrnl :is established; . Accur.ate instructions I are provided to traffic and access control personnel (NUREG.0654 A.3; C.l, 4; J.10.g, j;.

Criterion 3dl). Radiological Program Manual Pg. 191.192 I Risk County: An out of sequence County Traffic Control Point demonstration will be conducted on Feb 26th, 2019, 2:00 PM- 3:00 PM. Claiborne County traffic control point A3 (Rodney Road at City Limits) will be demonstrated on location.

I Risk County: Traffic control point coordination and deployment will be discussed in

• relation to the exercise scen;rrio.

I Performance Measures: (1) Off-Site response organizations must demonstrate the.capability to establish, and staff appropriate traffic and access control points consistent with .current I conditions and protection action decisions (e.g., evacuating, sheltering;.and.relocation) in a .

timely mann_er'. (2) Traffic and access control staff must derrioiistiate accurate knowledge of

• their roles and responsibilities, including verifying emergency worker identification, and access I authorization to the affected areas.

I Off-Site response organizations exception: Agreed* .

Critical Task 7.L5: Impediments to evacu~tion are identified'and resblved (NUREG.0654,

• I J.10.k; Criterion3d2). Radiological Program Manual Pg. 192

• • ,,t ..

I I

Radiological Emergency Preparedness.Program I After Action Report 2019 Grand Gulf Nuclear Station Performance Measures: (1) Off-Site response organizations inust demonstrate the capability to I

identify and take appropriate*actions concerning inipedimelit"s' to.evacuations. (2) The impediment m_ust remain in place during the evacuation long enough that re-routing of traffic is tequ:fred. * * * <. ** * *:'

I

-.r1 1 \i ** {** ... '

I

~ I ., ~ _'. '.

Off-Bite respori~e drganizations exception: Agreed

8. Core Capability: 'Mass Care Services';__Adams;' Copiah;*Htnds and Warren Counties I

Definition: Provide life-sustaining and human services'to the affected population, to include hydration, feeding~ Sheltedrig, temporary' -housing, evacuee support, reunification, and **

distribution Ofemergency*supplie'S'. *

' * ,: .* [ 1*

\  ;

• 1 *' I 8.1 Capability Target: Support Operations and Facilities*

I Critical Task 8.1; 1: At least 2 communications systems are available, at least 1 operates .

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

Communications capabilities are managed in support of emergency operations (NUREG.0654 I

F.1, 2;Crit:erion ldl} Ra:diologicaI,ProgramManualPg1*l8l * * '***'

• re.*-',*- 1 (_ '*: ( , **

Performance' Measure: (1) Off:-:Site respons<{ organizations must demonstrate that a primary I

system and at least one backup system are fully functional. (2} All facilities, field monitoring teams, and inciderit command must have the capability to access at least one comrirnnication system that is independent of the commercial telephone system. (3) Responsible Off-Site I

response organizations must demonstrate the capability to mariage the communication system~

and ensure that all message traffic is handled without delays that might disrupt emergency operations'. .

I Off-Site response organizations exception: Agreed I Critical-Task 8.1.2: Equipment (to include communications), maps, displays, monitoring instruments, dosimetry; potassium iodide; and other supplies are.sufficientto support emergency operaticins'(NUREG.0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12.;,K.3.a; K.5.b; Criterion lel).

I Radiological Program Manual Pg. 182 Performance Measure: (1) A particular facility's equipment and supplies must be sufficient I

and consistent with that facility's* assigned role in the off-site response organization's emergency operatio:ns'plans. (2) For non-facility-based operations, the equipment and supplies must be sufficient and consistent with'the assigned operational role.

I Off-Site response organizations exception: Agreed I Critical Task 8.1.:J: potassium iodide and appropriateinstructions*arema:de available in*case a*

of decision to-recommend use potassium iodide is-made. Appropriate record keeping of the I

I 86 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station administration of potassium iodide fo_r, instjtµtionalized. individuals and the general p11b~ic is.*

maintained. (NUREG.0654 J, 10.e, f;, .~riterion 3b 1)., ,Rt!diologicql Program Manual Pg. J 90 I t ~ ' ' .' ,' ,'

• Performance Measures: (1) Off-Site response organizations must demonstrate the capab~lity.to I make potassium iodide available to institutionalized individuals and, where provided for in their plans/procedures, to members of the general public. (2) Off-Site response organizations must demonstrate the capability to accomplish distribution of potassium iodide consistent with decisions made. (3) Off-Site response organizations must have the capability to develop and I maintain lists of institutionalized individuals who have ingested potassium iodide, includi.ng documentation of the.date(s) and time(s) they werejµstructed to ingest pot!lssium.iodide. Off- ...

I Site response organizations must demonstn1te tp.e capabiUty to formulate.and diss~minate ...

instructions on using potassium iodide for those advised to take it. (4) If,a recommendation is made for the general public to take potassium iodide, appropriate information must be provided I to the public by the means of notification .specified in the o(.f.:-site J<?~ponse organization's pl;i:o.sl procedures.

I Off-Site response organizations- exception:. Agreed.

Critical i~si s: 1.4: lVI;~agers of cortgrega~~:~~e* f~cniti_~si4~~9nst~~t; thc!-1: th~ :~~nte,rs h~ye:

I resources to provide services and accommodations consistent with planning guidelines.

Managers demonstrate the procedures to assµre thatevacue,.es have been monitored for contamination and have been decontaminated as f1ppropriate* before entering cpngreg;ite care I facilities.(NUREG.0654; J.10.h; J.-12; Criterion 6cl). Radiological Program Manual Pg:,204 Performance Measure: (1) Off-Site response organizations must plan for a sufficient number I of congregate care centers in host/support jurisdictions based on their all-hazard sheltering experience and what is historically relevant for that particular area. In this simulation, .it is not necessary to set up operations as they would be in an actual emergency. Alternatively, (2)

I capabilities may be demonstrated by setting up stations for various services and providing .those services to simulated evacuees. Given the substantial differences between demonstration and.

simulation of this criterion, exercise demonstration expectations must be clea{ly specified in.

I Extent-of-Play Agreements. Congregate care staff must also (3) demonstrate the ,capabUity. to :.

ensure that (a) evacuees, service animals, and vehicles have been monitored for cont'1mination,.

(b) decontaminated as appropriate, and (c) registered before entering th.efacility. ;(4) Individuals I arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, ~here applicable,J)ave been (a) placed in a secured area or (b) monitored, cleared, andfound 1to have.no contamination or (c)

I contamination below the trigger/action level. In,accordancewith plans/p~oced1;1re,s, individuals found to be*clean after monitoring do not*need to have their vehicle mcmitored. These.

I individuals do not need confirmation that their vehicle is free from contamination prior to entering the congregate care areas. (5) However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles held in a secure area until I they can be monitored and decontaminated (if applicable) and do .need confirmation thattheir vehicle is being held in*a secure area or fr:ee from contamination:prior to entering the ,congregate care areas. This capability may be determined through an interview process. If operations at the I

.":.87 I

Radiological Emergency Preparedness Program I After Action Report, 2019 Grand Gulf Nuclear Station center are demonstrated, material that wquld 9e difficu~t o~, ~xpensive to transport (e.g., cots, I

blankets, sundries, and_ large-scale food .sµpplies) need ,not be p~ysi_c:ally available at tµe facility(ies). (6) Howeyeri availability .of ~wjh,items,mt1st ti~ verified by proviqing the yvaluator a list of sources with locations and estimat~s ,of quantities. * * * *

• I Off-Site response.organizations exception:. Agreed I

9. Core Capability: Public Health, Healthcare, and Emergency Medical Services- Warren County I Definition: .Provide* lifesaving IQ.edical tr~atment via,EQ1ergency' M.e~ical Serv:ices and related operatio:µs, a11d ayoiq additional disease and injury by proy;iding targeted_public health, medical.

and behavioral health support, and products to all affecte_d popufa.tions.

I 9.1 Capability Target: Support Operations and l'a~iliii~~,.

• , ,.r ,. - '. . .

...

• j ; ; .

I I

. . *~ . . * . . !

• Critical '(ask 9_.1.1,.* Equipme11t,.m~ps 1displays, monitor,ing instrqments, ~osimy.try, pot'!-ssimn iodide, ancla,ther sµpplies are suff'i~ie11t,to support.emergenqy qperafions (NUREG.06.54 H.,7, :10; 17, 8,,.9; J..10.a, b, e;,r11~1i; K;.~i~)<~\1; (;~iteri~n)el). Radiolog1~al,Prograw Manual,l~g.

L~2  : .,," '-'!i  : '.i'**.

• '; .* :*:_..-*11'"( :I I

Performance Measure: (1) Aparticu}ar facility's equipment and supplies must be sufficient and consistent with that facility's assigned role.in the off-site response organization's emergency operations plans., {2) For non-facility-based operations, the equipment and supplies mustbe I

sufficientand consistent with the assigned operational role. (3) The plans/procedures must include the forms to qe used for documenting emergency worker.ingestion of potassium ~odide.

(4) Off-Site response organizations.mu.st demonstrate the capability to maintain inventories of I

appr,opriate dire.ct re.ad and permanep.t- record dosimeters in sufficient quantities for use by emergency workers, ancillary groups as identified in plans or specialized response teams. (5).

Appropriate direct-reading dosimetry mµst allow. an individual(s) to read the administrative I

reporting limits and maximum exposure.limits cont.f1inedin the off-site re_sponse organization's plans/prqcedures. (6) All monitoring instruments mµst_be inspected, and operationally checked before e.ach use .* lnstrumentsmust be calibrated in accordanqe with the manufacturer's I

recommendations . {7). A label indicating such calibration must be on ea~h instrument. (8) In addition, instruments bein,g t1sed to measure activity must have a sticker-affixed to their sides indicating the effective range of t~e readings. The range of readings documentation specifies the I

acceptable range of ret1.dings that the 1;11eter shouldindicate when it is response-checked using a standard test source. (9) In areas where portal rn9nitors are used,.the off-site response organiz~tions must setup and operationally check tl).e monitor(s). The monitor(s) must conform I

to the standards set fqrtb in the Contamination Monito,ring Standard for a Pprtal Monitor Used for Emergency Response, FEMA.REP.21 (March 1995) or in accordance with the manufacturer's recommendations.

I Off-site response orgat}izations; exception: Agrre;g ,.

• I:

I

.:,88 I

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I Radiological Emergency Preparedness *Program

.I After Action Report 2019 Grand Gulf Nuclear Station Critical Task 9.1.2: Off:-Site response orgat11za:tioris issue appropriate dosimetry; potassium II iodide, and procedures; and maiiage i1adiofogica1*exposifre to emergency workers in accordance, with the plans/procedures: ;Enieigency workers periodically' and at the end 6f each mission read their dosimeters and record the readings on the appropriate exposure* record dr chart; Off-Site I response organizations maintain appropriate record-keeping of the administration of potassium iodide to emergency workers (NUREG.0654 K.3.a, b, K.4; Criterion 3al). *Radiological Program Manual Pg. 189 I Performance Measures: (1) Off-Site response organizations must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-I reading* and permanent-record dosimetry, dosimeter chargers; potassium iodide; *and instructions on the use of these items. *:For eval~atiori purposes*, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read*the administrative-reporting limits that I are pre-established at a level low enough to consider subsequent calculation of total effective dose equivalent and maximum exposure"limit~r;for those emetgertcYworkers'invdlved in*

lifesaving activities, contained in the off-site response organization's plans/procedures. (2) Each I emer'gei1cyiworkfrmu:St Have basic: knowledge of radiation-exposure limits a:S specified in the

• tlff"~ite tesp'opse orga11:izaticin's'plans/pr6cedures. If suppl~mental resources are used, tl!ey must be provided'with just~frHime training to 'ensure basic knowledge 'ofradiatitm exposure Obnfrol. .

I Emergency workers must demonstrate procedures to monitor and record dosimeter readings manage radiological exposure control. (3) During a plume phase exercise, emergency workers and must demonstrate the procedures to be followed when administrative

. exposure limits and turn~*.

I back values are reached. (4) Off-Site response organizations must demonstrate the*actiorts described in the plans/procedures by determining whether to replace the worker, authorize the workerto incur additional exposures, or take other actions. (5) If exercise play does nofrequire I emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may'be situations where tea:m members I a will be in close proximity to each other d~ring' the entire missi6ri *and can share' direct read dosimeter. Each team member must still have arid maintain his ot her own permanent- record dosimetry. (7) Off-Site response organizations musterisure that the process used to seek I authorization for exceeding dose limits does*not negatively impact the capability tb reSporid:to' an incident where lifesaving and/of protection of valuable property may require an urgent response.

(8) Off-Site response.organizations must demonstrate the capability to accomplish distribution of I potassium iodide to emergency workers consistent with. decisions made~ ()ff~Site response**:

organizations must have the capability to develop and maintain lists of emergency workers who I have ingested potassium iodide, including documentation*ofthe date(s) ahdtime(s) they did*so.

• (9) Emergency workers must demonstrate basic knowledge of procedures for' using potassium iodide. If exercise play does not require' emergency workers to consume potassium iodide,.

I evaluators must interview at least two workers to determine their knowledge.'

Off-Site response organizations exception: Agreed

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I Critical Task 9.1.3: The facility/off-site response organizations has the appropriate space, II adequate resources, and trained personnel to provide transport, monitoring, decontamination, and

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Radiological Emergency Preparedness Program I After Action Report

• 2019 Grand Gulf Nuclear Station medical services to *contaminated injured individuals (NUREG.0.654 F.2; H.10; K.5.a, b; L.1, 4; I

Criterion 6dl).

• Radiological Program Manual Pg. 204.205,' * ; ; *: ,: .

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Performance' Measure: (l) All hospitals listed "in* the plan as m~dical *services hospitals must be I

evaluated,' with a transportation provider, every 2 years .. (2).Additional .transportation provic;lers will be rotated through the drills in the 8-year exercise cycle ..

• For ambulance providers who do not participate in an evaluated drill during the two-year cycle, training will be provided. This I

training will be documented in the annual letter of certification. (3) Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the I victim. (4) Off-Site response organizations must demonstrate the capability to monitor/

decontaminate and transport contaminated, injured individuals to medical facilities. (5) An ambulance must be used for response to the victim. However, to avoid taking an ambulance out I of service for an extended time, Off-Site response organizations may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility. It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized I vehicle transport the "victim(s)" to the medical facility. This option is used in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests of the community, (6) Normal communications between the I

ambulance/dispatcher and the receiving medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation I

monitoring results, if available. (7) In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information. (8) Monitoring of the I

victim may be performed before transport or en route, or may be deferred tb the medical facility.

(9) Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and I

radiological status of the individual(s). (10) However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and

• demonstrate appropriate contamination controls until the patient(s) is monitored. (11) Before I

using monitoring instruments, the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (12) All monitoring activities must be completed as they would be in an actual emergency. (13) Appropriate contamination control measures must be I

demonstrated before and during transport and at the receiving medical facility. ( 14) The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment. (15) Medical facilities are expected to have at least one trained physician and one I

trained nurse to perform and supervise treatment of contaminated injured individuals. (16)

Equipment and supplies must be available for treatment of contaminated injured individuals. I I

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I Radiological Emergency Preparedness Program I After Action Report 2019 Grand Gulf Nuclear Station (17) The medical facility rnust:demonsttate the*capability to (a) make decisi.ons on the need for I decontamination of the individual, (b )' follow appropriate decontamination procedur~s, and (d) maintain records of all survey measurements and samples taken. (18) All procedures for

• collection and analysis of samples and decontamination of the individual n::mst .be demonstrated.

I or described to the,evaluator: Waste. Water from decontamination operatio~s must be handle9 ..

according to facility plans/procedures.

I Off-Site response organizations exception:* Agreed I

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