ML092540145

2009 Waterford 3 FEMA Exercise Final Report

ML092540145
Person / Time
Site:	Waterford
Issue date:	08/25/2009
From:	Federal Emergency Management Agency
To:	Office of Nuclear Security and Incident Response
References
Download: ML092540145 (40)

Text

Waterford 3 Steam Electric Station Exercise Report - 2009-06-24 Final Report - Radiological Emergency Preparedness (REP) Program 2009-08-25

Exercise Report Waterford 3 Steam Electric Station Exercise Date: 2009-06-24 Report Date: 2009-08-25 U.S. DEPARTMENT OF HOMELAND SECURITY Federal Emergency Management Agency REP Program 800 North Loop 288 Denton, TX 76209 Table of Contents Chapter 1 Executive Summary Chapter 2 Introduction Chapter 3 Exercise Overview Section 3.1 EPZ Description Section 3.2 Exercise Participants Section 3.3 Exercise Timeline Chapter 4 Exercise Evaluation and Results Section 4.1 Summary Results of Exercise Evaluation Section 4.2 Status of Jurisdictions Evaluated

4.2.1 Louisiana

Jurisdictions 4.2.1.1 Governor's Office of Homeland Security and Emergency Preparedness 4.2.1.2 Louisiana Department of Environmental Quality Headquarters 4.2.1.3 Louisiana Department of Environmental Quality EOF 4.2.1.4 Waterford 3 Emergency News Center 4.2.2 Risk Jurisdictions 4.2.2.1 St. Charles Parish Emergency Operations Center and Traffic/Access Control Point 4.2.2.2 St. Charles Parish School Board 4.2.2.3 St. John the Baptist Parish Emergency Operations Center and Traffic/Access Control Point

4.2.3 Private

Jurisdictions 4.2.3.1 EAS Radio Station WWL Appendices Appendix 1 - Acronyms and Abbreviations Appendix 2 - Exercise Evaluators and Team Leaders Appendix 3 - Exercise Evaluation Areas and Extent of Play Agreement Appendix 4 - Exercise Scenario and Timeline

1. Executive Summary On June 24, 2009, a biennial Radiological Emergency Preparedness (REP) exercise was conducted in the plume exposure pathway emergency planning zone (EPZ) around the Waterford 3 Steam Electric Station (W 3) located near Taft, St. Charles Parish, Louisiana. The U.S. Department of Homeland Security/Federal Emergency Management Agency (DHS/FEMA) Region VI Office, evaluated the exercise. The purpose was to assess the level of preparedness of state and local responders to react to a simulated radiological emergency at Waterford 3. This exercise was held in accordance with DHS/FEMA policies and guidance concerning the implementation of state and local radiological emergency preparedness plans and procedures.

The previous exercise at this site was a Plume Exercise conducted on December 5, 2007. The qualifying emergency preparedness exercise was conducted on February 8, 1984. There have been seventeen evaluated exercises, including the exercise on June 24, 2009, plus several drills conducted since 1984.DHS/FEMA Region VI Office, wishes to acknowledge the efforts of the many individuals in the State of Louisiana, St. Charles Parish, St. John the Baptist Parish, and surrounding jurisdictions who participated in this exercise. Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities. Cooperation and teamwork of all the participants was evident during this exercise.

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

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2. Introduction On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume the lead responsibility for all offsite nuclear planning and response. FEMAs activities under the REP Program, which are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

Rule 44 CFR 350 establishes the policies and procedures for the DHS/FEMA Region VI Office's initial and continued approval of tribal, state and local governments radiological emergency planning and preparedness for commercial nuclear power plants. This approval is contingent, in part, on state and local government participation in joint exercises with licensees.

FEMA's Region VI responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

Taking the lead in offsite emergency planning and in the review and evaluation of radiological emergency response plans (RERPs) and procedures developed by state and local governments; Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by state and local governments; Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, September 14, 1993); and Coordinating the activities of Federal agencies with responsibilities in the radiological emergency planning process:- U.S. Department of Agriculture- U.S. Department of Commerce- U.S. Department of Defense- U.S. Department of Energy- U.S. Department of Health and Human Services 2

- U.S. Department of Homeland Security/FEMA- U.S. Department of Housing and Urban Development- U.S. Department of the Interior- U.S. Department of Transportation- U.S. Department of Veterans Affairs- U.S. Environmental Protection Agency- U.S. Federal Communications Commission- U.S. Food and Drug Administration- U.S. Nuclear Regulatory Commission- General Services Administration- National Communications System.

Representatives of these agencies serve on the Regional Assistance Committee (RAC), which is chaired by the Branch Chief of the DHS/FEMA Region VI Office. Formal approval of the Waterford 3 plans was granted by FEMA on April 25, 1988 under 44 CFR 350. A REP exercise was evaluated on June 24, 2009, by DHS/FEMA Region VI Office to assess the capabilities of state and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Waterford 3. The purpose of this exercise report is to present the exercise results and findings on the performance of the offsite response organizations (OROs) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the federal evaluation team, with final determinations made by the DHS/FEMA Region VI Office RAC Chair. The criteria utilized in the evaluation process are contained in:

NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980; and Interim REP Program Manual, including the Radiological Emergency Preparedness Exercise Evaluation Methodology (August 2002).

Section 3 of this report, entitled "Exercise Overview," presents basic information and data relevant to the exercise. This section of the report contains a description of the plume and ingestion pathway EPZs, a listing of all participating jurisdictions and 3

functional entities that were evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities.

Section 4 of this report, entitled "Exercise Evaluation and Results," presents detailed information on the demonstration of applicable exercise evaluation areas at each jurisdiction or functional entity. If applicable, this section also contains: (1) descriptions of all Deficiencies and Areas Requiring Corrective Action (ARCAs) assessed during this exercise and recommended corrective actions and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the OROs efforts to resolve them.

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3. Exercise Overview This section contains data and basic information relevant to the June 24, 2009, exercise to test the offsite emergency response capabilities in the area surrounding Waterford 3. This section of the exercise report includes a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of the times of actual occurrence of key exercise events and activities.

3.1. EPZ Description The area within 10-mile EPZ of Waterford 3 is entirely in the State of Louisiana. The most prominent natural feature in the EPZ is the Mississippi River running from west-northwest to east-southeast through the middle of the area. The Waterford 3 EPZ involves two parishes, St. John the Baptist Parish and St. Charles Parish. There are several communities near the site within the 10-mile EPZ. These include Killona, Montz, Norco, Destrehan, Hahnville, Luling, LaPlace, Edgard, Reserve, and Garyville.

The 2000 census estimated the population of the EPZ to be 91,116 persons mainly concentrated in towns along the Mississippi River. There are two hospitals, two nursing homes, and two incarceration facilities in the EPZ.

The major highways include I-10, I-310, I-55, U.S. Highways 61, 51, and 90, and Louisiana Highways 18 and 3127. There are four railways in the EPZ, which are the Canadian National Railroad, Kansas City Southern Railroad, Union Pacific Railroad, and Burlington Northern Railroad. The Waterford 3 EPZ is divided into 16 Protective Action Sections for the purpose of emergency response and implementation of protective actions.

The area within 50 miles of Waterford 3 is entirely in the State of Louisiana. The principal exposure from this pathway would be from ingestion of contaminated water or foods such as milk, fresh vegetables or aquatic foodstuffs. The Ingestion Pathway (IPZ) consists of the parishes contained within the 10-mile EPZ plus the following parishes:

Ascension, Assumption, East Baton Rouge, Iberia, Iberville, Jefferson, Orleans, Lafourche, Livingston, Plaquemine, St. Charles, St. Bernard, St. James, St. Helena, St.

John the Baptist, St. Martin, St. Mary, St. Tammany, Tangipahoa, Terrebonne, and West Baton Rouge. The 50-mile IPZ contains two large metropolitan areas: New 5

Orleans and Baton Rouge. The 2000 census reports approximately 2,503,073 persons in the parishes making up the 50-mile IPZ.

3.2. Exercise

Participants Agencies and organizations of the following jurisdictions participated in the Waterford 3 Steam Electric Station exercise:

State Jurisdictions Louisiana Governor's Office of Homeland Security and Emergency Preparedness Louisiana Department of Environmental Quality Louisiana State Police Louisiana Department of Health and Hospitals Louisiana Department of Agriculture and Forestry Louisiana Department of Corrections Louisiana Department of Justice Louisiana Department of Social Services Louisiana Department of Transportation and Development Louisiana Department of Wildlife and Fisheries Louisiana Workforce Commission Risk Jurisdictions St. Charles Parish Department of Homeland Security & Emergency Preparedness St. Charles Parish Fire Department St. Charles Sheriff Department St. Charles Parish Hospital/Medical Services St. Charles Parish School Board St. Charles Public Works St. John the Baptist Office of Homeland Security & Emergency Preparedness St. John the Baptist Parish Fire Department St. John the Baptist Parish Sheriff Department St. John the Baptist School Services St. John the Baptist Parish Public Works Private Jurisdictions Entergy Operations, Inc.

WWL Radio 870-AM 6

3.3. Exercise

Timeline Table 1 presents the time at which key events and activities occured during the Waterford-3 Steam Electric Station exercise on June 24, 2009.

Table 1 - Exercise Timeline DATE: 2009-06-24, SITE: Waterford 3 Steam Electric Station, LA Emergency Classification Level or Event Time Utility Declared GOHSEP EOC LDEQ HQ LDEQ EOF W3 ENC St. Charles EOC & T/ACP St. John the Baptist EOC & T/ACP Unusual Event N/A N/A N/A N/A N/A N/A N/A Alert 0817 0823 0826 0826 0823 0825 0826 Site Area Emergency 1040 1054 1102 1102 1040 1052 1054 General Emergency 1255 1310 1256 1256 1255 1307 1310 Simulated Rad. Release Started 1241 1250 1243 1243 1251 1246 1247 Simulated Rad. Release Terminated N/A N/A N/A N/A N/A N/A N/A Facility Declared Operational 0843 0840 1139 0940 0859 0854 Declaration of State of Emergency 1230 1055 0920 Exercise Terminated 1430 1418 1418 1420 1419 1st Protective Action Decision: Evacuate response areas A1, B1, C1, D1, A2, C2 and shelter all remaining response areas 1331 1331 1st Siren Activation 1340 1340 1st EAS or EBS Message 1342 1342 KI Administration Decision:

1325 1321 1340 1343 7 Table 1 - Exercise Timeline DATE: 2009-06-24, SITE: Waterford 3 Steam Electric Station, LA Emergency Classification Level or Event Time Utility Declared WWL Unusual Event N/A Alert 0817 Site Area Emergency 1040 General Emergency 1255 Simulated Rad. Release Started 1241 Simulated Rad. Release Terminated N/A Facility Declared Operational Declaration of State of Emergency Exercise Terminated 1st Protective Action Decision: Evacuate response areas A1, B1, C1, D1, A2, C2 and shelter all remaining response areas 1st Siren Activation 1st EAS or EBS Message 1342 KI Administration Decision:

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4. Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities which participated in the June 24, 2009, exercise evaluation to test the offsite emergency response capabilities of local governments in the 10-mile Emergency Planning Zone surrounding the Waterford 3 Steam Electric Station.

Each jurisdiction and functional entity was evaluated on its demonstration of criteria contained in the exercise evaluation areas as outlined in the Federal Register, Vol. 67, No. 80, "FEMA - Radiological Emergency Preparedness: Exercise Evaluation Methodology" (April 25, 2002). Detailed information on the evaluation area criteria and the extent-of-play agreement for this excercise is included as an appendix to this report.

4.1. Summary

Results of Exercise Evaluation The matrix presented in the table on the following page presents the status of all exercise evaluation area criteria which were scheduled for demonstration during the drill by all participating jurisdictions and functional entities. Exercise criterion are listed by number and the demonstration status of those criterion are indicated by the use of the following letters:

M - Met (No Deficiency or ARCAs assessed and no unresolved ARCAs from prior exercises)

D - Deficiency assessed A - ARCAs assessed or unresolved ARCAs from previous exercises P - Planning Issue N - Not Demonstrated 9

Table 2 - Summary of Exercise Evaluation DATE: 2009-06-24 SITE: Waterford 3 Steam Electric Station, LA A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated GOHSEP EOC LDEQ HQ LDEQ EOF W3 ENC St. Charles EOC & T/ACP St. Charles School Board St. John the Baptist EOC & T/ACP WWL Emergency Operations Management Mobilization 1a1M MMFacilities 1b1 Direction and Control 1c1 M M MMMCommunications Equipment 1d1 M M M M MMEquip & Supplies to support operations 1e1M MMProtective Action Decision Making Emergency Worker Exposure Control 2a1MMRadiological Assessment and PARs 2b1 MMDecisions for the Plume Phase -PADs 2b2 MMMPADs for protection of special populations 2c1MMRad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 Rad Assessment and Decision making concerning Relocation, Reentry, and Return 2e1 Protective Action Implementation Implementation of emergency worker exposure control 3a1M M MImplementation of KI decision 3b1MMImplementation of protective actions for special populations - EOCs 3c1 Implementation of protective actions for Schools 3c2MImplementation of traffic and access control 3d1MMImpediments to evacuation are identified and resolved 3d2MMImplementation of ingestion pathway decisions - availability/use of info 3e1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions.

3f1 Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4a1 Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laboratory operations 4c1 Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1MM M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3MMEmergency information and instructions for the public and the media 5b1M MMMon / decon of evacuees and emergency workers, and registration of evacuees 6a1 Mon / decon of emergency worker equipment 6b1 Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d1 10

4.2. Status

of Jurisdictions Evaluated This section provides information on the evaluation of each participating jurisdiction and functional entity, in a jurisdiction-based, issues only format. Presented below is a definition of the terms used in this subsection relative to demonstration status.

Met - Listing of the demonstrated exercise evaluation area criteria under which no Deficiencies or ARCAs were assessed during this exercise and under which no ARCAs assessed during prior exercises remain unresolved.

Deficiency - Listing of the demonstrated exercise evaluation area criteria under which one or more Deficiencies were assessed during this exercise. Included is a description of each Deficiency and recommended corrective actions.

Areas Requiring Corrective Action - Listing of the demonstrated exercise evaluation area criteria under which one or more ARCAs were assessed during the current exercise or ARCAs assessed during prior exercises that remain unresolved. Included is a description of the ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise.

Not Demonstrated - Listing of the exercise evaluation area criteria which were not demonstrated as scheduled during this exercise and the reason they were not demonstrated.

Prior ARCAs - Resolved - Description of ARCAs assessed during previous exercises that were resolved in this exercise and the corrective actions demonstrated.

Prior ARCAs - Unresolved - Description of ARCAs assessed during prior exercises that were not resolved during this exercise. Included is the reason the ARCA remains unresolved and the recommended corrective action to be demonstrated before or during the next biennial exercise.

The following are definitions of the exercise issues, which are discussed in this report.

A Deficiency is defined in FEMA-REP-14 as "an observed or identified inadequacy of organizational performance in an exercise that could cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that 11 appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant." An ARCA is defined in FEMA-REP-14 as "an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety." The Department of Homeland Security/Federal Emergency Management Agency (DHS/FEMA) has developed a standardized system for numbering exercise issues (Deficiencies and ARCAs). This system is used to achieve consistency in numbering exercise issues among FEMA Regions and site-specific exercise reports within each Region. It is also used to expedite tracking of exercise issues on a nationwide basis.

The identifying number for Deficiencies, ARCAs, and Planning Issues includes the following elements, with each element separated by a hyphen (-).

Plant Site Identifier - A two-digit number corresponding to the Utility Billable Plant Site Code. Exercise Year - The last two digits of the year the exercise was conducted.

Evaluation Area Criterion - A number and letter combination that corresponds with the criteria in the FEMA Evaluation Areas.

Issue Classification Identifier - (D = Deficiency, A = ARCA, P = Planning Issue).

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

4.2.1. Louisiana

Jurisdictions 4.2.1.1. Governor's Office of Homeland Security and Emergency Preparedness 12 a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.MET: 1.c.1, 1.d.1, 2.b.1, 2.b.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.2. Louisiana Department of Environmental Quality Headquarters MET: 1.c.1, 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.3. Louisiana Department of Environmental Quality EOF MET: 1.c.1, 1.d.1, 2.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.4. Waterford 3 Emergency News Center MET: 1.a.1, 1.d.1, 1.e.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 13 a.b.c.d.e.f.a.b.c.d.e.f.a.b.c.d.e.f.4.2.2. Risk Jurisdictions 4.2.2.1. St. Charles Parish Emergency Operations Center and Traffic/Access Control Point MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.2. St. Charles Parish School Board MET: 3.a.1, 3.c.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.3. St. John the Baptist Parish Emergency Operations Center and Traffic/Access Control Point MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None

4.2.3. Private

Jurisdictions 14 a.b.c.d.e.f.4.2.3.1. EAS Radio Station WWL MET: 5.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 15 APPENDIX 1 ACRONYMS AND ABBREVIATIONS AAC Accident Assessment Coordinator ACP Access Control Point ALARA As Low As Reasonably Achievable ANS Alert Notification System ARCA Areas Requiring Corrective Action DAC Dose Assessment Coordinator EAD Electronic Alerting Dosimeters EAS Emergency Alert System ECL Emergency Classification Level ENC Emergency News Center EOC Emergency Operations Center EOF Emergency Operations Facility EPA Environmental Protection Agency EPZ Emergency Planning Zone ESF Emergency Support Function EW Emergency Workers FEMA Federal Emergency Management Agency FMT Field Monitoring Team GE General Emergency GOHSEP Governor's Office of Homeland Security and Emergency Preparedness HOO Headquarters Operations Officer LC Logistics Coordinator LDEQ Louisiana Department of Environmental Quality LE Law Enforcement NRC Nuclear Regulatory Commission OM Operations Manager PAD Protective Action Decision PAR Protective Action Recommendations PAS Protective Action Section PEP Primary Entry Point PIO Public Information Officer PVDRC Plantation Volunteer District Radio Club RAC Regional Assistance Committee REP Radiological Emergency Preparedness RO Radiological Officer RPT Radiation Protection Technicians SAE Site Area Emergency SEC Secretary Designee SEL Senior EOF Liaison SEOC State Emergency Operations Center SHO State Health Officer SO Senior Officer SOP Standard Operating Procedure 16 TCP Traffic Control Point TEDE Total Effective Dose Equivalent TLD Thermo-Luminescent Dosimeter TR Technical Representative UCG Unified Command Group 17 APPENDIX 2 EXERCISE EVALUATORS AND TEAM LEADERS DATE: 2009-06-24, SITE: Waterford 3 Steam Electric Station, LA LOCATION EVALUATOR AGENCY Governor's Office of Homeland Security and Emergency Preparedness Ernie Boaze

• James Hickey ICF ICF Louisiana Department of Environmental Quality Headquarters Ernie Boaze ICF Louisiana Department of Environmental Quality EOF

• Nan Calhoun DHS/FEMA Waterford 3 Emergency News Center

• Bill Bischof Tim Pflieger DHS/FEMA DHS/FEMA St. Charles Parish Emergency Operations Center and Traffic/Access Control Point Linda Gee*Al Lookabaugh Bill Maier DHS/FEMA ICF NRC St. Charles Parish School Board Linda Gee DHS/FEMA St. John the Baptist Parish Emergency Operations Center and Traffic/Access Control Point Bill George

• Mike Goldsworthy Cherie Kittle Sam Williams DHS/FEMA DHS-FEMA Dept. of Transportatio n FEMA Region 6 EAS Radio Station WWL

• Carl McCoy ICF* Team Leader 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37