2022 Austin Energy Emergency Operations Plan Filing

Austin Energy Emergency Operations Plan
May 26, 2022

Emergency Operations Plan
EOP-00 – Table of Contents v2022.05
EMERGENCY OPERATIONS PLAN

EOP-00 EOP Cover Sheet, Approval Page, Table of Contents
EOP-01 EOP Executive Summary
EOP-02 Emergency Operations Response Overview
EOP-03 EOP Record of Revisions
EOP-04 EOP Record of Distribution
EOP-05 AE Emergency Contact List
APPENDICES
Incident Command Structure Annexes
ICS-01 AE ICS Defined
ICS-02 IC Headquarters
ICS-03 Incident Commander
ICS-04 The Safety Officer
ICS-05 The Liaison Officer
ICS-06 The Public Information Officer
ICS-07 Customer Care Branch
ICS-08 The Emergency Management Coordinator
ICS-09 Operations - Power Production
ICS-10 Operations - Electric Service Delivery
ICS-11 Operations - Technology
ICS-12 Planning
ICS-13 Logistics
ICS-14 Finance
Austin Energy Annexes

AE-01 AE Implementation Guide for Emergency Operation
AE-02 AE Emergency Communications Plan
AE-03 AE Business Continuity Plan
AE-04 AE Pandemic and Epidemic Plan
AE-05 AE Hurricane Response Plan
AE-06 AE Cyber Security Incident Response Plan
AE-07 AE Physical Security Incident Response Plan
AE-08 AE Event Reporting Plan
T&D Annexes
TD-01 AE T&D Weather Emergency Plan
TD-02 AE Load Shed Plan
TD-03 AE Wildfire Plan
TD-04 AE Black Start and System Restoration Plan
Generation Annexes
GEN-01 AE Power Production Weather Emergency Plan
GEN-02 AE Power Production Water Shortage Plan
GEN-03 AE Power Production Restoration of Service Plan
Austin Energy
THIS DOCUMENT, WHEN PRINTED, IS UNCONTROLLED AND FOR REFERENCE PURPOSES ONLY.
EOP-01 – Executive Summary v2022.05
Executive Summary of the Emergency Operations

Plan for Austin Energy
Contents and Policies
The City of Austin d/b/a Austin Energy (Austin Energy or AE) files this document as an Emergency
Operations Plan (EOP) in accordance with Public Utility Commission of Texas (Commission or PUCT)
rule 16 TAC §25.53. Austin Energy is a municipally owned utility that owns and manages generation
resources, operates as a transmission and distribution utility, and provides retail electric service to over
500,000 customers.
AE’s emergency procedures are based around the Incident Command System (ICS), a standardized
management tool for pivoting from normal operations to emergency response mode. ICS ensures that AE
can flexibly and decisively command, control, and coordinate emergency response efforts to protect our
infrastructure and customers during emergency conditions. AE’s ICS procedures follow the Federal
Emergency Management Agency’s standardized National Incident Management System (NIMS),
considered the national and international standard for emergency management. This EOP was prepared
primarily by compiling and revising AE’s existing ICS plan, Continuity of Operations Plan, Emergency
Communications Plan, and workgroup emergency response procedures into a single document that
meets the requirements of 16 TAC §25.53. Additionally, AE had key personnel complete the latest NIMS
training as well as AE emergency operations training. AE ICS personnel completed an operations-based
annual drill to test its Emergency Operations Plan pursuant to 16 TAC §25.53(f) on May 26, 2022. This
was timely noticed on April 25, 2022 to the Commission and the Texas Department of Emergency
Management.
This EOP provides procedures for effectively responding to an emergency event and strategies for
recovery after an event. The ICS framework is intended to be specific enough to ensure AE is effective in
a wide variety of emergencies while being sufficiently flexible to recognize that pre-established plans
cannot foresee all possible emergency circumstances. AE’s objective is to mitigate the emergency and
return to normal conditions in a safe and secure manner as soon as possible. The EOP is organized into
the following sections:
• A base plan including the executive summary, overview of emergency operations response,
revision control summary, distribution record, and emergency contact list.
• An annex overviewing AE’s ICS structure and procedures.
• Annexes that apply across all areas of Austin Energy’s operations.
• Annexes that apply only to AE’s transmission and distribution (T&D) operations or only to
AE’s generation operations.
This EOP applies to all of Austin Energy’s operations and facilities, with the exception of the South Texas
Project Electric Generating Station (STPEGS), Fayette Power Project (FPP), and Nacogdoches
Generating Facility (Nacogdoches). These facilities are operated and managed by other entities.
AE is a joint owner of the South Texas Project Electric Generation Station (STPEGS), along with CPS
Energy and NRG Energy. The South Texas Project Nuclear Operating Company (STPNOC) is the NRC-
licensed operator of STPEGS and manages and utilizes its own EOP to address emergencies for that
facility. NRG Energy, as a co-owner of STPEGS, has filed a copy of the EOPs that STPNOC has
developed with the PUCT in accordance with 16 TAC §25.53.
Austin Energy Page 1 of 4

AE is a joint owner of units 1 and 2 of FPP, along with the Lower Colorado River Authority (LCRA). LCRA
wholly operates FPP and manages and utilizes its own emergency operations plan to address
emergencies for that facility.
NAES Corporation (NAES) operates Nacogdoches and manages and utilizes its own emergency
operations plan to address emergencies for that facility. As the owner of Nacogdoches, AE is filing the
NAES plan in accordance with 16 TAC §25.53.
AE is submitting its EOP and the NAES plan, both with confidential portions removed. Unredacted copies
will be made available to commission staff on request. Concurrent with submission to the PUCT, AE will
submit unredacted copy of this EOP and the NAES plan to ERCOT per 16 TAC §25.53(c)(1)(B).
Rule Reference Index

The below table maps the requirements of 16 TAC §25.53 to corresponding sections and page numbers
of AE’s EOP per Subsection (c)(A)(i)(II). Some annexes that apply of to all of AE’s operations (ICS-02
through ICS-12, ICS-14, AE-01, and AE-08) do not correspond to a specific rule requirement and thus are
not included in this table.
Rule Section
Requirement Section Location
(16 TAC §25.53)
(c)(1)(A)(i) Executive Summary EOP-01: Executive Summary All pages
(c)(1)(A)(i)(I) Contents and Policies EOP-01: Executive Summary Pages 1-2
(c)(1)(A)(i)(II) Rule References EOP-01: Executive Summary Pages 2-4

(c)(1)(A)(i)(III) &
Record of Distribution EOP-04: Record of Distribution All pages
(c)(4)(A)
(c)(1)(A)(i)(IV) &
Affidavit EOP-01: Executive Summary Page 5-6
(c)(4)(C)
(c)(1)(A)(ii) Complete EOP Entire document
EOP-05: Emergency Contact

(c)(4)(B) Emergency Contacts All pages
List
AE-03: AE Enterprise Continuity
(c)(4)(C)(v) Business Continuity Plan All pages
of Operations Plan
EOP-02: Emergency Operations
(d)(1)(A) Introduction and Applicability Page 1
Response Overview
EOP Responsibility for EOP-02: Emergency Operations
(d)(1)(B) Pages 2-3
Maintenance and Implementation Response Overview
(d)(1)(C) Revision Control Summary EOP-03: Record of Revisions All pages
(d)(1)(D) Current EOP Statement EOP-04: Record of Revisions All pages
(d)(1)(E) Date of Approval EOP-00: AE EOP Cover All pages

Rule Section
(16 TAC §25.53)
AE-02: AE Emergency
(d)(2)(A) T&D Communications Plan All pages
Communications Plan
AE-02: AE Emergency
(d)(2)(B) Generation Communications Plan All pages
Communications Plan
(d)(2)(C) REP Communications Plan Not Applicable (REPs only)
(d)(2)(D) ERCOT Communications Plan Not Applicable (ERCOT only)

EOP-02: Emergency Operations Page 5
(d)(3) Emergency Supplies Plan Response Overview
ICS-13: Logistics All pages
EOP-02: Emergency Operations Pages 3-4
(d)(4) Emergency Staffing Plan Response Overview
ICS-01: AE ICS Defined All pages
EOP-02: Emergency Operations
(d)(5) Weather and Activation Plan Pages 4-5
Response Overview
(d)(6) Relevant Annexes All Subsequent Sections
TD-01: AE T&D Weather

(e)(1)(A) T&D Weather Emergency Annex All pages
Emergency Plan
(e)(1)(B) T&D Load Shed Annex TD-02: AE Load Shed Plan All pages
T&D Pandemic and Epidemic AE-04: AE Pandemic and

(e)(1)(C) All pages
Annex Epidemic Plan
TD-03: AE Wildfire Management
(e)(1)(D) T&D Wildfire Annex All pages
Plan
AE-05: AE Hurricane Response
(e)(1)(E) T&D Hurricane Annex All pages
Plan
AE-06: AE Cyber Security
(e)(1)(F) T&D Cyber Security Annex All pages
Incident Response Plan
AE-07: AE Physical Security
(e)(1)(G) T&D Physical Security Annex All pages
(e)(1)(H) T&D Black Start Annex Not Applicable (TDUs only)
TD-04: AE Black Start and

(e)(1)(I) T&D Additional Annexes All pages
System Restoration Plan
Generation Weather Emergency GEN-01: AE Power Production
(e)(2)(A) All pages
Annex Weather Emergency Plan
Generation Water Shortage GEN-02: AE Power Production
(e)(2)(B) All pages
Annex Water Shortage Plan
Generation Restoration of Service GEN-03: AE Power Production
(e)(2)(C) All pages
Annex Restoration of Service Plan
Generation Pandemic and AE-04: AE Pandemic and
(e)(2)(D) All pages
Epidemic Annex Epidemic Plan

Rule Section
(16 TAC §25.53)
AE-05: AE Hurricane Response

(e)(2)(E) Generation Hurricane Annex All pages
Plan
AE-06: AE Cyber Security
(e)(2)(F) Generation Cyber Security Annex All pages
Generation Physical Security AE-07: AE Physical Security
(e)(2)(G) All pages
Annex Incident Response Plan
(e)(2)(H) Generation Additional Annexes No Additional Generation Annexes
(e)(3) REP Annexes Not Applicable (REPs only)
(e)(4) ERCOT Annexes Not Applicable (ERCOT only)
Record of Distribution
The record of distribution can be found in section EOP-04.
Affidavit
The affidavit can be found subsequently in this section, EOP-01.

EOP-02 – Emergency Operations Response Overview v2022.05
Introduction and Applicability

City of Austin d/b/a Austin Energy’s (Austin Energy or AE) Emergency Operations Plan (EOP) documents
AE’s plans for responding to emergency events and for restoring electric service following disruptions. The
EOP addresses both common operational functions that are relevant across emergency types and
annexes that outline the AE’s response to specific types of emergencies. As such, the EOP comprises a
series of emergency response plans, some of which speak to emergency response in general and others
that focus on specific contingencies that could impact continuity of service. The EOP is designed to flex
and grow to meet new demands as warranted by changing conditions, both on the local and global scale.
Austin Energy is a vertically-integrated, municipally owned utility registered as multiple functions (including
Generator Owner, Generator Operator, Transmission Owner, Transmission Operator, Transmission
Planner, and Distribution Provider) in accordance with the North American Electric Reliability Corporation
(NERC) Rules of Procedure, and as multiple market participant types (including Resource Entity, Qualified
Scheduling Entity, Load Serving Entity, and Transmission and Distribution Service Provider) in accordance
with the Electric Reliability Council of Texas (ERCOT) Nodal Protocols. AE owns and manages generation
resources, operates as a transmission and distribution utility, and provides retail electric service to over
500,000 customers. As a municipally owned utility, AE is an entity subject to Public Utility Commission of
Texas (PUCT) rule 16 TAC §25.53.
This EOP applies to all of Austin Energy’s operations for its transmission and distribution facilities and its
generation resources except as specified below.
Fayette Power Project

Austin Energy and the Lower Colorado River Authority (LCRA) jointly own units 1 and 2 of the Fayette
Power Project (FPP). Under the FPP Participation Agreement entered in 1974 and as amended, Austin
Energy and LCRA co-own units 1 and 2, LCRA solely owns unit 3, and LCRA wholly operates all of
FPP. LCRA has established and filed with the PUCT the Lower Colorado River Authority & GenTex Power
Corporation's Emergency Operations Plan (LCRA EOP) as required under 16 TAC §25.53. The LCRA
EOP includes FPP. Austin Energy is not the operator of this generation resource, and in accordance with
§25.53(e)(2), Austin Energy’s EOP does not include generation annexes related to FPP.
South Texas Project

AE is part owner of the South Texas Project Electric Generating Station (STP). STP is a nuclear power
plant operated and managed by the STP Nuclear Operating Company (STPNOC), acting as project
manager on behalf of the owners under the South Texas Project Operating Agreement dated November
17, 1997. STPNOC has established the STPNOC Electric Service Emergency Operations Plan (ESEOP)
as required under 16 TAC §25.53. The STPNOC ESEOP is maintained separately from AE’s EOP. As
such, AE’s EOP does not include generation annexes related to STP.
Nacogdoches Generating Facility

AE owns the Nacogdoches Generating Facility (Nacogdoches). Nacogdoches is a bio-mass power plant
operated by NAES Corporation (NAES) under the O&M Services Agreement between the City of Austin
d/b/a Austin Energy and NAES Corporation for the Nacogdoches Generating Facility dated June 13, 2019.
NAES has established the Emergency Operations Plans for Nacogdoches Generating Facility
(Nacogdoches EOP) as required under 16 TAC §25.53. The Nacogdoches EOP is maintained separately
from AE’s EOP. As such, AE’s EOP does not include generation annexes related to Nacogdoches.
Austin Energy Values

The development and implementation of an Emergency Operations Plan is consistent with and supportive
of the value system that guides Austin Energy. Several of our values highlight the importance of
maintaining a guidebook for the quick response during an emergency and restoration of unexpected
service disruptions:
• Austin Energy provides a critical service to the citizens of Austin and surrounding communities
• The mission of Austin Energy is to safely provide clean, affordable, and reliable energy and
excellent customer service
The comfort, safety, convenience, time and productivity made possible by electricity is foundational to
quality of life. In order to remain successful, Austin Energy must be viewed by its customers as a reliable
supplier of high-quality electricity. To that end, this EOP exists to provide comprehensive and specific
direction for responding to the emergency and restoring the electric system to full operation in a timely and
efficient manner.
EOP Purpose
The purpose of this EOP is to establish procedures for event response and the restoration of service in a
systematic and efficient manner by utilizing all of AE’s human and physical resources and, if necessary, by
securing and utilizing off-system resources. The EOP serves to:
• Provide an organized document that outlines the process for responding to an emergency and
restoring the electric system under different levels of emergency conditions;
• Shift the responsibility of disaster recovery from a few key individuals into structured processes
shared by the entire AE organization;
• Produce a process designed to streamline the restoration of services and provide better
restoration information to customers;
• Identify and assign roles and accountability applicable to a wide variety of emergency types to
facilitate an orderly emergency response;
• Provide a feedback mechanism to assess AE performance following an emergency event or
service disruption and continuously adjust and improve future response effort; and
• Develop a process that complements a larger City-wide effort that addresses public emergencies.
Emergency Operations Plan Contents

Austin Energy’s EOP is comprised of a series of documents, many of which have been used by AE to
respond to emergency events for many years. The EOP documents are organized into logical groupings
for ease of identification. Some documents are part of the main EOP and others are part of the EOP
annexes.
The main body of the EOP uses the reference identifier “EOP-##” and contains
• An executive summary and requirements mapping
• Emergency operations response overview (this document)
• Record of revisions
• Record of distribution
• Emergency contact list
There are four annex categories:

• Incident Command System (ICS-##)
• Austin Energy-wide emergency procedures (AE-##)
• Transmission and Distribution procedures (TD-##)
• Generation procedures (GEN-##)
EOP Maintenance and Implementation

Overall maintenance and implementation of the EOP is the responsibility of AE’s Emergency Management
Coordinator (EMC), with the support of Corporate Compliance Programs. The signatories of the EOP are
AE’s General Manager and the General Manager’s direct reports (i.e. Deputy General Managers and
SVP).
Many individuals contribute to the maintenance and implementation of the EOP. Each document within the
EOP has an identified owner, associated stakeholders, and signatory(ies). As the subject matter experts
(SMEs), owners and stakeholders are responsible for reviewing and updating the information within their
assigned documents on an annual basis. If the annual review results in revisions, the document is
reviewed by the signatory(ies) and approved or revised prior to approval. In most cases, signatories are
first line executives over the responsible SMEs. In some cases, the Incident Commander is a signatory.

Activating AE’s EOP and Incident Command System

AE’s EOP will be activated as conditions warrant. An event may cause AE to follow one or more
documents within this EOP depending on the nature and severity of the emergency. When an event is
forecasted or has been determined to need the organized response of ICS, the Incident Commander will
instruct the Emergency Management Coordinator to activate ICS.
Employee Responsibilities
Many AE employees are considered part of the ICS and restoration teams.
Many employees with ICS roles have responsibilities that differ from their day-to-day job. Some are
identified for roles similar to their usual job but called upon to serve during emergency operations when
others on their team may not be. Employees with ICS roles are required to:
• Cease normal operations work (notifying appropriate backups if necessary) and respond to their
storm or emergency assignment when called upon by their Incident Command authority
• Maintain knowledge of the roles and responsibilities of their ICS position
• Complete required training associated with their ICS role
• Participate in storm and/or emergency drills and dry-run exercises
• Communicate to their ICS authority availability and methods of contact
Employees whose regular job responsibilities include storm restoration may be called upon during an
emergency response event. Employees on the restoration teams are required to:
• Respond to their storm or emergency assignment when called upon by their Incident Command
authority
• Respond appropriately to every event level, as assigned and per AE policy
• Fulfill the responsibilities of these emergency or storm response assignments is a condition of
employment.
Response to Weather-Related Hazards

Austin Energy’s Emergency Management Coordinator (EMC) subscribes to various weather services and
monitors the weather for potential threat to AE’s service territory. The EMC communicates weather
forecasts and alerts to ICS personnel and other stakeholders to help maintain situational awareness.
Additionally, AE control centers and control rooms monitor weather for potential impacts to their respective
facilities.
The ICS structure and this EOP may be activated as necessary to respond to any potential or actual
weather-related hazard. Additionally, the following guidelines apply to the specific weather-related
conditions listed below.
• Tornadoes – Although somewhat rare in AE’s service territory, tornados can sustain severe
damage, especially to transmission, distribution, and generation infrastructure within the tornado’s
path. AE’s ICS may be used to address system restoration after a tornado, depending on how
widespread the damage is. The glossary at the end of this document contains several terms
specific to tornadoes.
• Hurricanes – A majority of AE’s service territory is too far inland to receive a direct hit from a
hurricane, but associated winds and rain can create damaging conditions to AE infrastructure and
wide-spread outages to customers. Hurricanes may also lead to flooding which can impact
facilities in low-lying areas. During a hurricane, AE follows its storm response procedures
contained throughout this EOP, especially within the ICS Annex documents. AE’s Hurricane
Response Plan, AE-05, provides additional detail regarding hurricane evacuation zones. Annually,
prior to hurricane season, AE receives area-specific forecasts of potential hurricane activity. The
glossary at the end of this document contains several terms specific to hurricanes.

• Extreme Cold Weather – AE has weather preparedness and weather response plans for extreme
cold weather conditions. See ICS-08, Emergency Management Coordinator; TD-01 AE T-D
Weather Emergency Plan; and GEN-01 AE Power Production Weather Emergency Plan. Further,
AE established a detailed After Action Report following Winter Storm Uri in 2021 and incorporated
lessons learned into its EOP.
• Extreme Hot Weather – AE has weather preparedness and weather response plans for extreme
hot weather conditions. See ICS-08, Emergency Management Coordinator; TD-01 AE T-D
Weather Emergency Plan; and GEN-01 AE Power Production Weather Emergency Plan. Further,
AE conducts a summer readiness drill and workgroup-specific trainings (e.g. load shed training) to
prepare for the impacts of an extreme hot weather emergency.
• Drought – Drought conditions could have a variety of effects on AE facilities. AE has a Wildfire
Management Plan, TD-03, which may be necessitated due to dry conditions brought on by
drought. AE generation facilities could also be impacted by drought. See GEN-02, AE Power
Production Water Shortage Plan.
• Flooding – A flooding emergency may be brought on by a sudden storm, persistent rain, or

hurricane conditions. AE takes steps to monitor low-lying areas and make capital improvements to
facilities in areas most prone to flood. AE’s ICS may be used to address a flood-related
emergency. The glossary at the end of this document contains several terms specific to flood
conditions.
Maintaining Supplies for Emergency Response

Austin Energy’s Emergency Management Coordinator (EMC) maintains inventories of several types of
supplies used during emergency response activations. Pre-identified supplies include shelf stable meals
ready to eat (MREs), shelf stable water, mattresses, pillows, bed linens, masks, and more. AE routinely
assesses its inventory and establishes plans to acquire additional supplies as needed. For example, AE is
currently working to increase its inventory of handheld communication devices and station service
generators.
In coordination with and in addition to the EMC, AE’s ICS Logistics Section prepares lists of hotel and food
vendor options and refreshes them when a potential event is forecasted. They coordinate with Facilities
and Finance to maintain adequate supplies in warehouses, food and lodging facilities for emergency
response crews and ICS personnel and other supplies and services as needed. AE also maintains credit
cards with higher credit limits that AE can activate during emergency situations. Further, AE maintains
contracts with external vendors who can provide support services and supplies if the severity of an
emergency extends beyond internal capabilities. This document, supplemented by the Austin Energy ICS
Annex document (ICS-13 Logistics), contains AE’s plan to maintain pre-identified supplies for emergency
response.
Training and Accessibility of the EOP

AE provides training to relevant operating personnel so they are familiar with the applicable contents and
execution of the EOP. AE defines relevant operating personnel as those assigned to an ICS role. Such
personnel are instructed to follow the applicable portions of the EOP except to the extent deviations are
appropriate as a result of specific circumstances during an emergency.
AE ensures its emergency management personnel who are designated to interact with local, state, and
federal emergency management officials during emergency events have received the latest IS-100, IS-
200, IS-700, and IS-800 National Incident Management System (NIMS) training each year prior to AE’s
submittal of the EOP to regulatory bodies. AE defines these emergency management personnel as those
assigned to an ICS role in the Control and Command Section. More specifically, the latest NIMS training
for those courses is required of the following roles:
• Incident Commander
• Emergency Management Coordinator
• Liaison Officer
• Public Information Officer
• Safety Officer
The EOP is available in hard copy in the Incident Command Center located at AE’s System Control
Center. The EOP is also available and distributed electronically. Whenever possible, additional distribution
occurs as AE assigns new personnel to ICS roles but no later than the next annual distribution. Training is
conducted and required annually.
Drills and Notifications

AE conducts and participates in at least one drill each calendar year to test its EOP. Following the annual
drill, AE assesses the effectiveness of its emergency response and revises its EOP as needed.
Notwithstanding the above, AE is not required to conduct or participate in a drill in the calendar year in
which the EOP was activated. As described further in AE-05 AE Hurricane Response Plan, AE’s facilities
are not known to be located within a Texas Division of Emergency Management (TDEM) hurricane
evacuation zone.
For at least one drill each calendar year, AE provides 30-day notice to PUCT staff and the appropriate
TDEM District Coordinators, by email or other written form, of the date, time, and location of the drill.
Reporting
Upon request by PUCT staff during an activation of the State Operations Center by TDEM, AE will provide
updates on the status of operations, outages, and restoration efforts. Updates must continue until all
incident-related outages of customers able to take service are restored or unless otherwise notified by
PUCT staff. After an emergency, PUCT staff may require AE to provide an after action or lessons learned
report and file it with the commission by a date specified by PUCT staff. AE will respond timely to PUCT
reporting requirements and request additional time if needed and conditions warrant.

Glossary of Terms
and Definitions
The fields of Emergency Management, Business Continuity, and related service areas are expansive and
thus terms and definitions are constantly changing and evolving.
The following terms and definitions are commonly used in the context of emergency management. Other
variations of each term may exist; however, the compilation below is a general guide produced and widely
accepted by the emergency management community.
The set of words and definitions presented here was taken from the All Hands Community Glossary
Project, originally found at All-Hands.net. This glossary will remain under review and change as
terminology in the field expands, evolves, and becomes standardized in the emergency management
community.
A
After-Action Report (AAR)- A method of identifying and tracking correction of important problems and carrying out
best work practices in an operation or exercise after it has been completed. An AAR may be structured to contain
statements of Lessons Learned and recommended changes in plans, training, and resources.
Alternate Command Center or Alternate Emergency Operations Center- A location, other than the normal facility,
used to host the emergency command center.
Alternate Site- A location, other than the normal facility, used to process data and/or conduct critical business
functions in the event of a disaster.
Area Command- An organization established to 1) oversee the management of multiple incidents 2) to oversee the
management of a very large incident that has multiple incident management teams assigned to it.
B
Backup Power- Backup Power is normally provided by generators and Uninterruptible Power Supply (UPS) units, to
prevent system failure as a result of power failure.
Bioterrorism (BT)- BT is the use or threatened use of biological agents to achieve political, religious, ideological, or
social goals.
Business Continuity Plan (BCP)- A BCP defines and ranks key business functions according to vulnerability and risk,
assigns priorities to those functions, and defines procedures to continue priority functions to ensure continuation of an
organization, public or private, as a going concern in the event of a disaster. A responsive BCP depends on an
adequate Business Impact Analysis (BIA) and Risk Assessment (RA). Computer system and data recovery, under an
IT disaster recovery plan, is a subordinate but important part of a BCP. A BCP includes safeguards for personnel and
families, business assets and reputation, customers/clients/citizens, vendors, communications, and access to critical
resources. It involves training, periodic exercises, post-exercise reviews, and plan updates with special attention to
media relations. A BCP is a major factor in an overall risk management program. A BCP is also known as a business
recovery plan, business resumption plan, and business contingency plan. Under U.S. laws and regulations, private
for-profit companies should ensure a capacity to meet obligations to shareholders as well as under the Sarbanes-
Oxley Act (SOA). Public sector entities have a duty to meet a standard of care with respect to public health and
safety.
Business Impact Analysis (BIA)- A systematic method of determining the cost of risk by identifying the impact of
business or service disruptions which allows targeting operations and processes which require recovery planning. A
BIA is the process of analyzing all business functions and the effect that a specific hazard(s) may have upon them. Its
purpose is to define the operational and financial impacts of an interruption to your mission critical business functions.

In addition, the BIA reveals recovery time objectives and interdependencies needed to develop effective strategies for
recovery.
Business Impact Assessment- A business impact assessment is a management level analysis by which an
organization assesses the quantitative (financial) and qualitative (non-financial) impact and loss that might result if the
organization were to suffer a business continuity event, incident, or crisis. Also, the business impact assessment is
the first phase of Disaster Recovery’s four phases; the process (or action) of analyzing all business functions and the
effect that a specific disaster may have upon them.
Business Interruption- Any event, whether anticipated (i.e. public service strike) or unanticipated (i.e. blackout) which
disrupts the normal course of business operations at a corporate location.
C
Call Tree- A call tree is a document that graphically depicts the calling duties and the calling sequences used to
contact management, staff, customers, vendors, and other key contacts in the event of an emergency, disaster, major
power outage, or other crisis condition.
Catastrophic Disaster- An event that results in large number of deaths and injuries; causes extensive damage or
destruction of facilities that provide and sustain human needs; produces an overwhelming demand on State and local
response resources and mechanisms; causes a severe long-term effect on general economic activity; and severely
affects State, local, and private-sector capabilities to begin and sustain response activities.
CERT- Community Emergency Response Team. A team of local citizens, with or without an organizational affiliation,
trained in a range or basic emergency response skills and techniques to assist their community in times of disaster or
other emergency. CERT training is local to national standards that are available from the Federal Emergency
Management Agency (FEMA). Regional and local varietal names may apply, such as NEST, NEEAT, NERT, DERT,
sometimes with different training standards. Intermediate and advanced CERT training has been initiated. CERT is
one of the Citizen Corps programs designated to help fulfill the President’s call for community service.
Command Center- A facility used for command and control of response and recovery operations.
Comprehensive Emergency Management Plan (CEM Plan)- A CEM Plan contains policies, authorities, concept or
operations, legal constraints, responsibilities, and emergency functions to be performed. Agency response plans,
responder Standard Operating Procedures (SOPs), and specific incident action plans are developed from this
strategic document.
Consortium Agreement- An agreement made by a group of organizations to share processing facilities and/or office
facilities, if one member of the group suffers a disaster (also known as a Reciprocal Agreement).
Contamination- The deposit of hazardous material (radioactive, chemical, or biologic) on the surfaces of structures,
areas, objects, animals, or people following an incident causing the release and distribution of such material.
Crisis- An unplanned event that triggers a real, perceived, or possible threat to safety, health, the environment, or to
the organizations’ reputation or credibility. A crisis has the potential to significantly impact the organization’s
operations or to pose a significant environmental, economic, or legal liability.
D
Damage Assessment- The process of assessing the physical damages resulting from a disaster or emergency and
the resulting recovery time and cost estimates.
Decontamination- The reduction or removal of hazardous material (radioactive, chemical, or biologic) from a
structure, area, object, animal, or person. Appropriate decontamination practice may be simple of complex. When
complex, the need is for teams with specialized skills, equipment and supplies. Decontamination may be
accomplished by: 1) treating the contaminated surfaces so as to remove or decrease the potency of the
contaminating material, 2) letting the material stay in place until radioactivity is decreased as a result of natural decay,
or until adverse chemical or biological properties naturally dissipate or dilute, 3) covering the contaminated surfaces,
4) flushing with water. Poor management of decontamination may result in wide spread contamination. A
decontamination procedure that physically removes hazardous material should not transfer that same material to
another critical site or object in concentrated form.
Disaster- Any occurrence of widespread or severe damage, injury, or loss of life or property resulting from a natural,
technological, or manmade incident, including but not limited to earthquake, explosion, fire, flood, high water, hostile
actions, hurricanes, landslide, mudslide, storms, tidal wave, tornado, wind-driven water, or other disasters. An event
in which a community or organization undergoes severe danger and incurs, or is threatened to incur, such losses to
persons and/or property that the resources available are exceeded.
Disaster Plan- Written policies, practices, procedures, and resource lists intended to prevent or minimize damage to
human resources and physical infrastructure and to organizational records resulting from disasters.
Disaster Prevention- Measures employed to prevent, detect, or contain incidents, which, if unchecked, could result in
disaster.
E
Emergency- An emergency is any unplanned event that can cause deaths or significant injuries to employees,
customers or the public; or that can shut down a business, disrupt operations, cause physical or environmental
damage, or threaten financial standing or public image. Such events require immediate action due to the potential
threat.
Emergency Alert System (EAS)- The national public warning system for emergencies. EAS allows satellite,
broadcast, and cable to send and receive alerting information. EAS has multiple-source monitoring for emergency
alerts and a standard protocol for messages.
Emergency Management (EM)- EM is the preparation for and carrying out of all emergency functions, other than
military functions, to minimize injury and to repair damage resulting from disasters caused by fire, flood, storm,
earthquake, or other natural causes, or by technological events, or by enemy attack, sabotage, or other hostile action,
and to provide support for rescue operations for persons and property in distress and for humanitarian aid.
Emergency management includes mitigation against, preparedness for, response to, and recovery from disasters or
emergencies.
Emergency Operations Center (EOC)- A facility which management officials exercise direction and control in an
emergency or disaster. It is equipped and staffed to provide support in coordinating and guiding emergency/disaster
operations. EOCs are activated on an as needed basis.
Employee Assistance Program (EAP)- An EAP is a part of a business recovery plan or a business continuity plan
which serves as a resource to mitigate the short- and long-term effects of trauma and crisis upon employees and their
households.
Employee Relief Center (ERC)- A predetermined location for employees and their families to obtain food, supplies,
financial assistance, etc. in the event of a catastrophic disaster.
Extended Outage- A lengthy, unplanned interruption in system availability due to computer hardware or software
problems, power outage, or communication failures.
F
Fallout, Radioactive- The process or phenomenon of the fallback to the earth’s surface of particles contaminated with
radioactive materials from the cloud formed by a nuclear burst. The term is also applied in a collective sense to the
contaminated particulate matter itself. Early (or local) fallout is defined, somewhat arbitrarily, as those particles that
reach the earth’s surface within 24 hours after a nuclear burst. The delayed (or worldwide) fallout consists of smaller
particles, which rise into the upper troposphere and into the stratosphere, and are carried by winds to all parts of the
earth. Delayed fallout descends to the earth’s surface, mainly in rain or snow over extended periods, ranging from
months to years.
Fujita Scale- System developed by Dr. Theodore Fujita to classify tornadoes based on wind damage. Scale ranges
from F0 for the weakest to F5 for the strongest tornadoes.
Fujita-Pearson Scale (FPP Scale)- A 3-digit scale for measuring the strength of tornadoes devised by Fujita (F scale)
and Pearson (PP scale) to indicate the tornado intensity (0-5), path length (0-5), and path width (0-7).

Geiger Counter- An instrument that measures the dose rate of gamma radiation. Used in nuclear and radiological
emergencies to determine hazardous conditions. Some instruments also measure beta radiation. The dose rate may
be indicated by an analog dial or digital readout as well as audio output. Geiger counters come in many architectural
styles with many names.
Global Positioning System (GPS)- GPS is a worldwide radio-navigation system formed from a constellation of 24
satellites and their ground stations. The satellites are reference points to calculate positions accurate to a matter of
meters. By using advanced forms of GPS, measurements are better than a centimeter. In effect, each square meter
on the planet has a unique address.
H
Hazard- A situation or condition that presents the potential for causing damage to life, property, and/or the
environment; an event or physical condition that has the potential to cause fatalities, injuries, property damage,
infrastructure damage, agricultural loss, damage to the environment, interruption of business, or other types of harm
or loss. May be biological, chemical, or physical agents capable of causing adverse health effects or property
damage given a particular environment or location.
Hazard Assessment or Hazard Vulnerability Analysis- The process of estimating, for defined areas, the probabilities
of the occurrence of potentially-damaging phenomenon of given magnitudes within a specified period of time. A
systematic approach used to analyze the effectiveness of the overall (current or proposed) security and safety
systems at a particular facility. Hazard assessment involves analysis of formal and informal historical records, and
skilled interpretation of existing topographical, geological, geomorphological, hydrological, and land-use maps. The
analysis first determines the objectives of the facility’s physical protection system. Next, it identifies the physical
protection elements in place (or proposed) to prevent or mitigate security concerns. Finally, it analyzes the system
design against the objectives in a systematic, quantitative manner in order to determine if the physical protection
system is effective and acceptable for that facility. Similar terms: Vulnerability Analysis, Risk Assessment, Threat
Assessment.
Hazard Mitigation- the process of alleviating hazards or reducing the risk of hazards by the use of proactive
measures. Any sustained action taken to reduce or eliminate the long-term risk to human life and property from
hazards.
Hazardous Material (HAZMAT)- Any material which is explosive, flammable, poisonous, corrosive, reactive, or
radioactive (or any combination), and requires special care in handling because of the hazards posed to public
health, safety, and/or the environment.
Hot Zone- The zone of highest contamination. Only personnel in appropriate personal protective equipment will enter
this zone following a dynamic risk assessment.
Hurricane Advisory- A method for disseminating hurricane and storm data to the public every six hours.
Hurricane Eye- The relatively calm area near the center of the storm. In this area, winds are light and the sky is often
partly covered by clouds.
Hurricane Season- The portion of the year having relatively high incidence of hurricanes. In the Atlantic, Caribbean,
and Gulf of Mexico it is usually regarded as the period from June 1 through November 30.
Hurricane Warning- A warning that one or both of the following dangerous effects of a hurricane are expected in a
specified coastal area in 24 hours or less (a) sustained winds of 74 miles per hour (64 knots) or higher; (b)
dangerously high water or a combination of dangerously high water and exceptionally high waves, even though winds
expected may be less than hurricane force.
Hurricane Watch- An announcement for specific areas that a hurricane or an incipient hurricane condition poses a
threat to coastal and inland communities. All people in the indicated areas should take stock of their preparedness
requirements, keep abreast of the latest advisories and bulletins, and be ready for quick action in case a warning is
issued for their areas.

Hurricane Category (Category 1-5)- A large cyclone storm accompanied by high winds, extreme rainfall and storm
surge. Winds: Category 1 (74-95 M.P.H.); Category 2 (96-110 M.P.H.); Category 3 (111-130 M.P.H.); Category 4
(131-155 M.P.H.); Category 5 (155+ M.P.H.).
I
Incident- A definite and separate occurrence, usually a minor event or condition that is a result of a human error,
technical failure, or environmental condition. An incident or event typically interrupts normal activities. Note: Incidents
may or may not lead to accidents, events, or disasters.
Incident Base- Under the National Incident Management System (NIMS), an incident base is the location at which
primary support activities are conducted. A single incident base is established to house all equipment and personnel
support operations, including, for example, food and a sleeping area. The incident logistics section, which orders all
resources and supplies, is also located at this base. The base should be designed to be able to support multiple
incident sites.
Incident Command Post (ICP)- Under the national Incident Management System (NIMS), the ICP signifies the
location of the on-scene incident management organization comprised of the Incident Commander (IC), other
designated incident management officials and responders form local, state, tribal, and federal agencies, as well as
private and nongovernmental organizations. Typically, the ICP is located at or in the immediate vicinity of the incident
site and is the locus for the conduct of direct, on-scene control of tactical operations. Incident planning is also
conducted at the ICP; an incident communications center also would normally be established at this location. The ICP
may be co-located with the incident base, if the communications requirements can be met. The ICP may serve as the
local EOC in the context of smaller jurisdictions or less complex incident scenarios, at which the primary command
functions are executed.
Incident Command System (ICS)- ICS is a structured system of organizing for and managing emergency response
and recovery. ICS has the combination of facilities, equipment, personnel, procedures, and communications
operating within a common organization structure with responsibility for the management of assigned resources to
effectively accomplish stated objectives pertaining to an incident. ICS has five essential management functions
applicable to any emergency: command, operations, planning/intelligence, logistics, and finance/administration. Other
basic principles include: organizational flexibility- modular organization; organizational unity and hierarchy of
command or management; action planning; management by objectives; common terminology; integrated
communications; resources management; and span of control.
Incident Commander- An individual charged with directing emergency operations to mitigate a situation that presents
the possibility of harm, injury, and/or destruction. Individuals designated to assume the role of the incident
commander may be the senior Emergency Response Team (ERT) member, the senior fire officer at the scene, or the
senior law enforcement official at the scene, depending on the incident.
Information Officer/PIO- Under the Incident Command System (ICS), a member of the Command Staff responsible
for interfacing with the public, media, and other agencies requiring information directly from the incident.
J
Joint Command- Two agencies working an incident both with jurisdictional authority. Each agency has an Incident
Commander. Both Incident Commanders stay co-located, developing one common list.
L
Local Area Network (LAN)- Computing equipment, in close proximity to each other; connected to a server which
houses software that can be accessed by the users.
LAN Recovery- The component of disaster recovery which deals specifically with the replacement of LAN equipment
in the event of a disaster, and the restoration of essential data software.
Liaison/Liaison Officer- An agent or representative. Typically an agency official sent to another agency to facilitate
interagency communications and coordination. Liaison and Liaison Officer are sometimes used interchangeably.
Under the National Incident Management System (NIMS) the term for the person on the Command Staff is Liaison
Officer. For emergency exercises and in disasters, a number of liaisons from other agencies, commerce and industry,

various non-governmental organizations, jurisdictions, and other parties should be assigned to (or seated or present)
and in direct communication with Emergency Operations Centers to meet the need for linkages for effective strategy
and use of resources in an incident.
Logistics- Logistics is the procurement, maintenance, distribution, and transportation of material, facilities, services,
and personnel.
Loss- The unrecoverable business resources that are redirected or removed as a result of a disaster. Such losses
may be loss of life, revenue, market share, competitive stature, public image, facilities, or operational capability.
Loss Reduction- The technique of instituting mechanisms to lessen the exposure to a particular risk. Loss reduction is
intended to react to an event and limit its effect. Examples of Loss Reduction include sprinkler systems, insurance
policies, and evacuation procedures.
M
Major Damage- This term is used by the Federal Emergency Management Agency (FEMA) to categorize an item or a
building that has been damaged to the extent that it is no longer usable and may be returned to service only with
extensive repairs.
Major Incident- A major incident can be defined as “an emergency that requires the implementation of special
arrangements by one or more of the Emergency Services.”
Minor- FEMA category where an item or building is damaged and may only be used under limited conditions, but may
be restored with minor repairs.
Mitigation- Mitigation is any action of a long-term, permanent nature that reduces the actual or potential risk of loss of
life or property from a hazardous event.
Multi-Jurisdiction Incident- An incident requiring action from multiple agencies that have a statutory responsibility for
incident mitigation. Under ICS, these incidents will be managed under Unified Command.
Mutual Aid- As between two or more entities, public and/or private, the pre-arranged rendering of services in terms of
human and material resources when essential resources of one party are not adequate to meet the needs of a
disaster or other emergency.
Mutual Aid Agreement (MAA)- A pre-arranged agreement between two or more entities, public and/or private, to
render services in terms of human, material, and data resources when essential resources of one party are not
adequate to meet the needs of a disaster or other emergency. Financial aspects for post-disaster or post-incident
reimbursements may be incorporated into the agreement. Many functional needs other than those of first responders
may be served such as state-to-state lending of building officials to assess damages or of prison guards, city-to-city
lending of accounting personnel, NGOs engaged in animal welfare management, blood banks, or newspapers as to
printing and distribution.
N
National Hurricane Center (NHC)- The office of the National Weather Service (NWS) in Miami that is responsible for
tracking and forecasting tropical cyclones.
National Incident Management System (NIMS)- As the operational arm of the National Response Plan (NRP), NIMS
provides a consistent nationwide approach for governments at all levels, commerce and industry, and non-
governmental organizations to work effectively and efficiently together to prepare for, respond to, and recover from
domestic incidents regardless of cause, size, or complexity. To provide for interoperability and compatibility among
governmental and private sector capabilities, NIMS includes: a core set of concepts, principles, terminology, and
technologies covering the incident command system (ICS); multiagency coordination systems (MACS); unified
command; training; identification and management of resources (including systems for classifying types of
resources); personnel qualifications and certification; and the collection, tracking, and reporting of incident information
and incident resources.

National Oceanic and Atmospheric Administration (NOAA)- NOAA is a major component of the U.S. Department of
Commerce. It engages in wide-ranging scientific and technical programs on matters such as: charts and navigation;
climate; coasts; fisheries; oceans; research; satellites, and weather.
National Weather Service (NWS)- A part of the National Oceanic and Atmospheric Administration (NOAA). NWS
provides weather, hydrologic, and climate forecasts and warnings for the United States, its territories, adjacent waters
and ocean areas. NWS data and products form a national information database, which can be used by other
governmental agencies, the private sector, the public, and the global community. NWS has a program to select and
train volunteers as official spotters.
Non-Governmental Organization (NGO)- Any non-profit, voluntary citizens’ group which is organized on a local,
national, or international level. Task-oriented and driven by people with a common interest, NGOs perform a variety
of services and humanitarian functions, bring citizen’s concerns to Governments, monitor policies, and encourage
political participation at the community level. They provide analysis and expertise, serve as early warning
mechanisms, and help monitor and implement international agreements. Some are organized around specific issues,
such as human rights, the environment, or health.
O
Operations Section- Under the Incident Command System (ICS), the operations section is responsible for tactical
operations at an incident. Includes: branches, divisions and/or groups, task forces, strike teams, single resources,
and staging areas.
Overhead Personnel- Personnel assigned to supervisory positions. Includes Incident Commander, Command Staff,
General Staff, Directors, Supervisors, and Unit Leaders.
P
Physical Safeguards- Physical measures taken to prevent a disaster, such as fire suppression systems, alarm
systems, power backup and conditioning systems, access control systems, etc.
Preliminary Damage Assessment (PDA)- Early post-disaster surveys and reports on the physical results of a disaster.
Preparedness- Those activities, programs, and systems that exist prior to an emergency that are used to support and
enhance response to an emergency or disaster. Preparedness also refers to the ability to respond in case of
emergency to protect human lives and property, and developing capabilities and programs that contribute to a more
effective response.
Prevention- The positioning of those measures and activities that will lessen the possibility or the impact of an
adverse incident in an organization. The primary goals and objectives of prevention are to protect an organization’s
assets and to manage risk. “Prevention” is a term commonly used in crisis management and is analogous to the term
“mitigation” as used in the emergency management context.
Public Assistance- Financial or other aid provided to political subdivisions and Indian tribes to facilitate restoration of
public facilities to pre-disaster functions and capabilities.
Public Facility- Any flood control, navigation, irrigation reclamation, public power, sewage treatment and collection,
water supply and distribution, watershed development, airport facility, non-federal aid street, road or highway, and
any other public building, structure or system including those used exclusively for recreation purposes.
Public Information Officer (PIO)- Under the Incident Command System (ICS), a member of the command staff
responsible for interfacing with the public, media, and others as to information about an incident.
R
Radiation, Initial Nuclear- Nuclear radiation composed mainly of neutrons and gamma rays that are emitted from the
fireball and the cloud column during the first one minute after a nuclear burst.

Rapid Response Teams (RRT)- Teams comprised of trained individuals in specific fields (law enforcement, fire,
public works, building officials, etc.). RRT’s are organized from local governments when activated, operates under the
state as an operating unit of the State Emergency Response Team.
Reciprocal Agreement- A mutual agreement between two or more departments, divisions, or companies, to provide
backup processing capabilities in the even of a disaster.
Recovery- Disaster recovery is the socio-economic rebuilding toward normalcy of communities so that individuals,
families, households, neighborhoods, other groups, governmental and commercial/industrial infrastructures, and
private organizations can function on their own, return to pre-disaster conditions, and are resistant against future
hazards.
Resilience- A capacity to easily adjust to change. Resilience rests in maximizing the capacity of systems and
processes to effectively support a range of critical functions, as in a business, under adverse, fast changing, or
unexpected conditions. While recognizing that change is a constant, resilience is more than just recovery and
continuity; resilience means being flexible enough to adapt to both positive and negative influences.
Response- The efforts to minimize the risks created in an emergency by protecting the people, the environment,
property, and the efforts to return the scene to normal pre-emergency conditions; The reaction to an incident or
emergency to assess the damage or impact and to ascertain the level of containment and control activity required. In
addition to addressing matters of life safety, response also addresses the policies, procedures, and actions to be
followed in the even of an emergency.
Restoration- The process of planning for and/or implementing procedures for the repair or relocation of the primary
site and its contents, and for the restoration of normal operations at the primary site. Expanded to include
consideration and implementation of necessary changes designed to improve preparedness for and mitigate the
impact of future emergencies.
Risk Management- The process of intervening to reduce risk and reduce the threat to life, property, and the
environment posed by hazards.
S
Safety Officer- Under the National Incident Management System (NIMS) and the Incident Command System (ICS), a
member of the Command Staff responsible for monitoring and assessing safety hazards or unsafe situations, and for
developing measures for ensuring personnel safety. The Safety Officer, when acting on behalf of the Incident
Commander, may enforce best practices for personal safety in the conduct of a response to an incident. The Safety
Officer may have assistants. In other venues a Safety Officer is responsible for identifying and giving notice on undue
risks.
Saffir-Simpson Hurricane Wind Scale- A 1 to 5 categorization based on the hurricane's intensity at the indicated time
(See Hurricane Category). The storm surge ranges, flooding impact and central pressure statements have been
removed from the scale and only peak winds are employed in this revised version
Sarbanes-Oxley Act (SOA)- SOA is a legal driver for Business Continuity Management. High profile corporate failures
resulted in the Sarbanes-Oxley Act. Under SOA, the approach to compliance may be compelling to those responsible
for business continuity. Aside from requiring corporate officers to take greater responsibility for the accuracy of
financial reports, SOA mandates that organizations understand the risks that may impact the financial reporting
process. A proper assessment of this risk environment would likely include lesser know operational and IT risks
resulting from, among other things, inadequate disaster recovery or business continuity plans.
Secondary Device- A device designed to harm responders to the initial incident by exploding close by or
contaminating them.
Severe Thunderstorm- A strong thunderstorm with wind gusts in excess of 58 mph (50 knots) and/or hail with a
diameter of 3/4 inch or more. A thunderstorm with winds greater than 39 mph (35 knots) and/or hail greater than a ½
inch is defined as approaching severe.
Shelter in Place (SIP)- A sometimes preferred alternative to early evacuation (EVAC). Shelter in place is a response
to chemical, biological, or radiological contaminants released accidentally or intentionally into the environment.
Shelter in place is a precaution to be safe from such hazardous materials by remaining indoors rather than
evacuating an area at risk of contamination. At work, home or play, SIP means taking refuge in a relatively small
room, preferably in the interior of a building and with no or few windows. SIP does not mean sealing off an entire
building. While shelter in place should be considered as protection for a short time, the room or rooms should be
selected in advance. Survival supplies should be handy. Ultimately, an evacuation to designated sites (hopefully pre-
planned) may be indicated.
Skills Inventory- A listing of employees and/or volunteers that lists their skills as they apply to response and recovery.
Span of Control- A basic principle of the Incident Command System (ICS). Managing with a reasonable span of
control is the responsibility of each supervisor at all levels of ICS. ICS development established a one to seven ratio
as the maximum span of control under emergency response conditions. A one to five ratio was established as an
optimum. In an emergency response organization, one supervisor should have direct supervisory authority over no
more than five subordinate positions. For greatest management efficiency, span of control should be routine in day-
to-day staffing patterns for an easy adaptation to emergency or crisis conditions.
Squall- A sudden increase of wind speed by at least 18 miles per hour (15 knots) and rising to 25 miles per hour (22
knots) or more and lasting for at least one minute.
Staging Area- A temporary site, often outside of but proximate to a disaster area, for the gathering, assembly, and
subsequent dispatch and movement of essential human and/or material resources to specific operational functions
and arenas. In a particular disaster there may be many staging areas, each serving special needs. Preferred sites
have well-functioning transportation and communication facilities as well as nearby accommodations for site staffs.
Sometimes known as Logistical Staging Area (LSA).
Straight-line winds - Very strong winds that can produce damage, demonstrating a lack of a rotational damage
pattern. The winds can reach 80 M.P.H. or more and can last for periods of twenty minutes or longer. Such straight-
line wind events are most common during the spring when instability is highest and weather fronts routinely cross the
country.
T
Task Force- A combination of single resources assembled for a particular tactical need, with common
communications and a leader.
Technological Hazard or Technical Threats- A hazard or threat that may cause an emergency event regardless of
any human elements. This includes critical system failures, hazardous chemical releases, explosions, data or system
failures, etc.
Terrorism- The Federal Emergency Management Agency (FEMA) defines terrorism as “the use of force or violence
against persons or property in violation of the criminal laws of the United States for purposes of intimidation, coercion,
or ransom. Terrorists often use threats to create fear among the public, to try to convince citizens that their
government is powerless to prevent terrorism, and to get immediate publicity for their causes.” While the federal
government has defined Terrorism by statute, few of the states have done so. Thus, federal law appears to be
controlling.
Threat- Threat is a first stage, before Alert and Warning, in an escalating scale of official terms used by government
agencies in describing the security situation to the public as a generalized need for awareness.
Tornado- A violent rotating column of air forming a pendant reaching the ground. When not reaching the ground, it is
called a funnel cloud. A tornado may be accompanied by a loud roaring noise. On the local scale, it is the most
physically destructive of all atmospheric phenomena.
Tornado Warning- Indicates a tornado has been sighted or is spotted on radar. Warnings will give the location of the
tornado and the area immediately affected by the warning.
Tornado Watch- Indicates that the weather conditions are favorable for a tornado to develop and that the sky should
be watched.
Tropical Cyclone- A non-frontal cyclone of synoptic scale, developing over tropical or sub-tropical waters and having
a definite organized circulation.
Tropical Depression- A tropical cyclone in which the maximum sustained surface wind of 38 mph (33 knots) or less.

Tropical Disturbance- A moving area of thunderstorms in the tropics.
Tropical Storm- A warm core tropical cyclone in which the maximum sustained surface wind is in the range of 39 to
73 mph (34-63 knots) inclusive.
Tropical Storm Warning- A warning of sustained winds in the average of 39-73 mph (34-63 knots) inclusive.
Tropical Wave- A westward moving trough of low pressure embedded in the deep easterly current. It tends to
organize low-level circulation and may travel thousands of miles with little change in shape, sometimes producing
significant shower and thundershower activity along its path.
U
Unified Command- An application of the Incident Command System (ICS) used when there is more than one agency
with incident jurisdiction. Agencies work together through their designated Incident Commanders (ICs) at a single
Incident Command Post (ICP) to establish a common set of objectives and strategies, and a single Incident Action
Plan.
V
Vulnerability Analysis - A determination of possible hazards that may cause harm. Should be a systematic approach
used to analyze the effectiveness of the overall (current or proposed) emergency management, security, and safety
systems at a particular facility.
W
Warning- Dissemination of a message signaling an imminent hazard, which may include advice on protective
measures. A warning is issued by the National Weather Service to let people know that a severe weather event is
already occurring or is imminent. People should take immediate safety action.
Watch- A watch is issued by the National Weather Service to let people know that conditions are right for a potential
disaster to occur. It does not mean that an even will necessarily occur. People should listen to their radio or TV to
keep informed about changing weather conditions. A watch is issued for specific geographic areas, such as counties,
for phenomena such as hurricanes, tornadoes, floods, flash floods, severe thunderstorms, and winter storms.
Weapons of Mass Destruction (WMD)- WMD are those with “…capabilities to inflict mass casualties and destruction:
nuclear, biological, and chemical (NBC) weapons or the means to deliver them.”

EOP-03 - Record of Revisions
The AE Emergency Operations Plan (EOP) is reviewed annually in its entirety prior to annual submittal to the PUCT. During the annual review, AE
compiles a list of material revisions that occurred since the previous annual submittal. This Record of Revisions reflects changes to the EOP that
materially affect how AE would respond to an emergency. Refer to the Revision History tables within each document that comprises the EOP for a full
list of changes (material and non-material) made since the initial EOP filing deadline of June 1, 2022.
EOP Version EOP Reference Date of Document

Description of Revision
# # Revision Version #
- Example description of change
2022.05 AE-02 4/12/2022 2022.04
- Updated procedures for response to incident
2022.05 Entire Document 5/26/2022 n/a Initial version compiled in accordance with 16 TAC § 25.53
Page 1 of 1
EOP-04 - Record of Distribution v2022.05
The AE Emergency Operations Plan (EOP) is available in hard copy in the Incident Command Center located at
SCC. The EOP has been distributed electronically to the following individuals and training has been provided on
the dates reflected. Additional distribution is provided as new employees join related groups whenever possible but
no later than the next annual distribution. AE provides EOP training annually.
Date of
Name Title Date of Training
Distribution
Coord, Line Clearance 5/25/2022 5/17/2022
IT Systems Administrator Sr 5/25/2022 5/11/2022
Distrib Electrician Crew Ldr 5/25/2022 5/11/2022
Inventory Control Spec II 5/25/2022 5/24/2022
Power Control System Tech III 5/25/2022 5/12/2022
Financial Analyst IV 5/25/2022 5/13/2022
Coord, Ocuptnl Health & Safety 5/25/2022 5/11/2022
Dir, Employee Development 5/25/2022 5/12/2022
Supv, Distribution Electrician 5/25/2022 5/17/2022
Scheduler Analyst 5/25/2022 5/12/2022
Supt, Electrical Maintenance 5/25/2022 5/11/2022
Distribution Electrician III 5/25/2022 5/13/2022
Dir, Electr System Field Ops 5/25/2022 5/17/2022
Prgm Mgr, AE Craft&Fld Staff D 5/25/2022 5/11/2022
SCADA/EMS Analyst Senior 5/25/2022 5/13/2022
Supt, Line Clearance 5/25/2022 5/17/2022
IT Manager 5/25/2022 5/13/2022
Utility Process Consultant 5/25/2022 5/16/2022
Dir, Smart Grid & Syst Operton 5/25/2022 5/20/2022
Distribution Constr Coord I 5/25/2022 5/16/2022
Supv, Customer Service 5/25/2022 5/17/2022
Prgm Mgr, AE Quality/Complnc 5/25/2022 5/16/2022
Mgr II, Inventory Control 5/25/2022 5/17/2022
Distribution Constr Coord III 5/25/2022 5/11/2022
Power System Mgng Engineer 5/25/2022 5/11/2022
Human Resources Advisor Sr 5/25/2022 5/23/2022
Page 2 of 8
Date of
Distribution
Contract Mngmt Specialist IV 5/25/2022 5/11/2022
Power System Engineer Sr 5/25/2022 5/10/2022
VP, Customer Acct Mgmt 5/25/2022 5/16/2022
Prgm Mgr, Envrnmtl Policy 5/25/2022 5/11/2022
IT Systems Consultant 5/25/2022 5/20/2022
Mgr, Key Account 5/25/2022 5/16/2022
Power Plant Technician Senior 5/25/2022 5/18/2022
Distribution Constr Leader 5/25/2022 5/17/2022
Supv, Human Resources 5/25/2022 5/11/2022
Facility Service Specialist 5/25/2022 5/18/2022
Supv, Customer Service (311) 5/25/2022 5/11/2022
VP, Tchnol&Data 5/25/2022 5/11/2022
Div Mgr, Info Systems 5/25/2022 5/17/2022
IT Application Analyst (311) 5/25/2022 5/16/2022
SCADA/EMS Analyst Senior 5/25/2022 5/16/2022
IT Application Analyst Senior (311) 5/25/2022 5/16/2022
Contractor 5/25/2022 5/18/2022
Supv, Power Plant Maintenance 5/25/2022 5/17/2022
Dir, Energy Ops 5/25/2022 5/19/2022
Mgr, AE Customer Service 5/25/2022 5/20/2022
Utility Rglty Policy Analyst 5/25/2022 5/11/2022
IT Application Analyst 5/25/2022 5/13/2022
Power System Principal Engr 5/25/2022 5/12/2022
Distribution Constr Leader 5/25/2022 5/11/2022
Dir, Customer Care Svcs 5/25/2022 5/16/2022
Prgm Mgr, Public Info & Mktng 5/25/2022 5/18/2022
Page 3 of 8
Date of
Distribution
Supv I, Inventory Control 5/25/2022 5/11/2022
Prgm Mgr, Trans Plng 5/25/2022 5/13/2022
Mgr, Elec Sys Field Ops 5/25/2022 5/19/2022
Supv, Electric Metering 5/25/2022 5/17/2022
Contract Mngmt Specialist III 5/25/2022 5/12/2022
Business Process Consultant Sr 5/25/2022 5/11/2022
Dir, Energy Ops 5/25/2022 5/16/2022
Supt, Power Plant Operator 5/25/2022 5/18/2022
IT Manager 5/25/2022 5/17/2022
Mgr, Elec Sys Field Ops 5/25/2022 5/13/2022
Supv, AE Distribution GIS 5/25/2022 5/13/2022
Prgm Mgr, Advanced Technology 5/25/2022 5/11/2022
IT Project Mgr Sr 5/25/2022 5/11/2022
Coord, Security 5/25/2022 5/11/2022
Supv, Distrib Constr 5/25/2022 5/12/2022
Mgr, Energy Efficiency Svcs 5/25/2022 5/20/2022
Dir, AE Envirn Hlth&Sfty Svcs 5/25/2022 5/18/2022
IT Manager 5/25/2022 5/17/2022
Mgr, Occ Envir Health & Safety 5/25/2022 5/10/2022
Prgm Mgr, Risk Control 5/25/2022 5/16/2022
Supv, Electrical Sys Cntrlr 5/25/2022 5/11/2022
Mgr, Grn Bldg and Sust 5/25/2022 5/11/2022
IT Manager 5/25/2022 5/18/2022
Page 4 of 8
Date of
Distribution
Vehicle Scheduler II 5/25/2022 5/16/2022
AE Power Delivery Trainer 5/25/2022 5/16/2022
Project Mgr 5/25/2022 5/11/2022
Dir, AE Corporate Complnc Prgm 5/25/2022 5/1/2022
Enterprise Risk Analyst 5/25/2022 5/13/2022
Mgr, Power Plant (600+ MW) 5/25/2022 5/19/2022
Supv, Training 5/25/2022 5/10/2022
Div Mgr, Info Systems 5/25/2022 5/10/2022
Human Resources Advisor Sr 5/25/2022 5/19/2022
Dir, AE Communications 5/25/2022 5/11/2022
Ofcr, AE Dep GM&Chf Fncl&Admin 5/25/2022 5/13/2022
Public Information Spec Sr (311) 5/25/2022 5/18/2022
Administrative Specialist 5/25/2022 5/13/2022
Compl Analyst Sr 5/25/2022 5/2/2022
Compl Analyst Sr 5/25/2022 5/2/2022
Mgr, Envrnmtl Svc&Ops Complnc 5/25/2022 5/16/2022
Power System Mgng Engineer 5/25/2022 5/13/2022
Mgr, Distribution Process 5/25/2022 5/17/2022
Page 5 of 8
Date of
Distribution
Mgr, AE Principal Accounting 5/25/2022 5/12/2022
Mgr III, Financial 5/25/2022 5/13/2022
Power System Engineer 5/25/2022 5/11/2022
Mgr, AE Bus Ops 5/25/2022 5/19/2022
VP, Power Production 5/25/2022 5/16/2022
Coord, Utility Emergency Mgmt 5/25/2022 5/18/2022
IT Application Analyst Senior (311) 5/25/2022 5/16/2022
Business Process Consultant Sr (311) 5/25/2022 5/12/2022
Supt, Systems Operations 5/25/2022 5/10/2022
Supt, Distribution Constr Main 5/25/2022 5/11/2022
Public Information Spec Sr 5/25/2022 5/16/2022
IT Systems Consultant 5/25/2022 5/17/2022
Prgm Mgr, Fleet 5/25/2022 5/18/2022
Coord, Ocuptnl Health & Safety 5/25/2022 5/13/2022
Mgr, Building Services 5/25/2022 5/11/2022
Dir, AE Engrng&Technl Svcs 5/25/2022 5/18/2022
Inventory Control Spec III 5/25/2022 5/17/2022
Supt, On-Site Energy Resource 5/25/2022 5/12/2022
IT Network Administrator Sr 5/25/2022 5/20/2022
Mgr, AE Customer Service (311) 5/25/2022 5/15/2022
Supt, Substation Constr &Maint 5/25/2022 5/11/2022
Supv I, Inventory Control 5/25/2022 5/11/2022
Mgr, Power Plant (600+ MW) 5/25/2022 5/18/2022
Page 6 of 8
Date of
Distribution
Mgr, AE Customer Service (311) 5/25/2022 5/16/2022
Mgr II, Financial 5/25/2022 5/11/2022
AE O&M Specialist Senior 5/25/2022 5/18/2022
AE Power Delivery Trainer 5/25/2022 5/18/2022
Supt, Power Plant Operator 5/25/2022 5/13/2022
IT Systems Administrator 5/25/2022 5/18/2022
Power Control System Tech II 5/25/2022 5/19/2022
Supv, Facils 5/25/2022 5/17/2022
Mgr, Energy Efficiency Svcs 5/25/2022 5/13/2022
Mgr, Key Account 5/25/2022 5/12/2022
Financial Analyst IV 5/25/2022 5/17/2022
Mgr, Key Account 5/25/2022 5/11/2022
Dir, AE Finance 5/25/2022 5/11/2022
AE Chief of Staff 5/25/2022 5/11/2022
Coord, Advertising & Outreach 5/25/2022 5/20/2022
Ofcr,AE SrVP&Chf Comms&Cmplnc 5/25/2022 5/11/2022
Supv, Human Resources 5/25/2022 5/17/2022
VP, ElectrSysEngrng&Techl Svcs 5/25/2022 5/18/2022
Supt, Power Plant Maintenance 5/25/2022 5/20/2022
Page 7 of 8
Date of
Distribution
Prgm Mgr, Advanced Technology 5/25/2022 5/18/2022
Mgr, AE Occup Health & Safety 5/25/2022 5/17/2022
AE O&M Specialist Senior 5/25/2022 5/18/2022
IT Application Analyst Senior 5/25/2022 5/11/2022
Mgr, Key Account 5/25/2022 5/13/2022
Mgr, Executive Account 5/25/2022 5/16/2022
Page 8 of 8
ALL ANNEXES OF THIS EMERGENCY
OPERATIONS PLAN HAVE BEEN REMOVED
DUE TO CONFIDENTIALITY
EMERGENCY OPERATIONS
PLANS
PUCT 25.53
Nacogdoches
Generating Facility
Cushing, Texas
APRIL
2022
EMERGENCY OPERATIONS
PLANS
PUCT 25.53
Nacogdoches
Generating Facility
Cushing, Texas
APRIL
2022
EMERGENCY OPERATIONS PLAN
Nacogdoches
Generating Facility
Cushing, Texas
Authorized Approval Signature:_&]_._...~-----=-------------
Printed Name & Title: C. lq~ llia~Atc:u. ,..,

Date: S'/2C,/1,.,<rl_1_
The Emergency Operations Plan is effective from the approved date until the date of its authorized
revision, update or replacement.
I, L, S4 ~Le ry c~ , a Notary Public for McLennan County, Texas, do hereby certify

that C fo,; T &,, r "' +-o ,.J personally appeared before me this day and acknowledged the
due execution of the foregoing instrument. Witness my hand and official seal, this the :l f.o day of
D1ay , 20 ~ Q. .
Revision Log
Rev. # Description Date of Rev

1 EOP update in accordance with PUCT 25.53 rule 4/8/2022
TABLE OF CONTENTS
1.0 APPROVAL AND IMPLEMENTATION 4

2.0 COMMINICATION PLAN 4
3.0 PLAN TO MAINTAIN PRE-IDENTIFIED SUPPLIES FOR EMERGECY
RESPONSE 4
4.0 PLAN THAT ADDRESSES STAFFING DURING EMERGENCY RESPONSE 4
5.0 PLAN THAT ADDRESSES HOW AN ENTITY IDENTIFIES WEATHER-
RELATED HAZARDS 5
6.0 ANNEXES
a. WEATHER EMERGENCY 6
b. WATER SHORTAGE 63
c. RESTORATION OF SERVICE 69
d. PANDEMIC AND EPIDEMIC 81
e. HURRICANE 106
f. CYBER SECURITY 119
g. PHYSICAL SECURITY 127
h. COMMUNICATIONS and COMMUNITY RELATIONS 133
7.0 Drills 145
Page |4
1.0 APPROVAL AND IMPLEMENTATION - PUCT 25.53.(d).(1)

Nacogdoches Generating Facility is operated in accordance with plant speci fic
procedures as well as procedures developed by NAES. These procedures include the
Emergency Response Plan, Administrative Manual Plans, and Operating Procedures
which provide guidance to operating staff during plant emergencies.
The plant manager is responsible for maintaining and implementing the EOP. The plant
manager or the compliance manager can update the EOP as needed. The revision log is
attached to this EOP and will be used for tracking purposes.
The EOP was developed in 2016 and was updated 4/8/2022. This EOP updated 4/8//2022
supersedes the previous EOP. This EOP dated 4/8/2022 is approved by Nacogdoches
Generating Facility.
2.0 COMMINICATION PLAN - PUCT 25.53.(d).(2)
Nacogdoches Generating Facility references AMP-102 Communications Plan, AMP-103

Community Relations Plan, SMP-02 Emergency Response Plan for communications. All
these referenced annexes are part of this EOP.
3.0 PLAN TO MAINTAIN PRE-IDENTIFIED SUPPLIES FOR EMERGECY

RESPONSE - PUCT 25.53.(d).(3)
Nacogdoches Generating Facility references the Hurricane Action Plan, Winter

Weatherization Plan, Summer Weatherization Plan for emergency supplies. All these
referenced annexes are part of this EOP.
4.0 PLAN THAT ADDRESSES STAFFING DURING EMERGENCY RESPONSE -

PUCT 25.53.(d).(4)
Nacogdoches Generating Facility references SMP-02 Emergency Response Plan, Hurricane
Action Plan, Winter Weatherization Plan, Summer Weatherization Plan for staffing during
emergency response. All these referenced annexes are part of this EOP.
Page |5
5.0 PLAN THAT ADDRESSES HOW AN ENTITY IDENTIFIES WEATHER-

RELATED HAZARDS - PUCT 25.53.(d).(5)
Nacogdoches Generating Facility references SMP-02 Emergency Response Plan for

identifying weather related hazards. This referenced annex is part of this EOP.
Page |6
6.0a. WEATHER EMERGENCY – PUCT 25.53.(e).(2).(A)

Page |7
SMP-02 – Emergency Response Plan
Rev Issue Date Last Review Date

R1 23 May 17 22 Sep 20
Approved for use by:
Nicole Jackson
TABLE OF CONTENTS
SECTION TITLE PAGE
1. Purpose ................................................................................................................... 9
2. Responsibilities ........................................................................................................ 9
3. Emergency Response Overview .............................................................................. 9
4. Hazardous Waste Operations and Emergency Response (HAZWOPER) .............. 10
A. Spill Response Procedure............................................................................. 10
B. Hazardous Material Spill Training and Follow-up .......................................... 11
5. Fire Response Procedure ...................................................................................... 17
6. Chemical Release/Spill Procedure ......................................................................... 18
7. Medical Emergencies ............................................................................................. 19
8. Earthquakes, Tornados, and Severe Storm Emergencies ...................................... 19
A. Earthquakes.................................................................................................. 19
B. Tornados and Severe Storms ....................................................................... 20
9. Bomb Threats and Acts of Sabotage ...................................................................... 21
A. Recognition ................................................................................................... 21
B. Response ..................................................................................................... 21
C. Communication ............................................................................................. 23
D. Reporting ...................................................................................................... 24
10. Training .................................................................................................................. 25
TABLES
Table 1. Emergency Organizational Telephone Numbers for Threat Control ... 24
APPENDICES
Appendix A: Facility Evacuation Route Diagram .................................................... 26
Appendix B: Bomb Threat Checklist ...................................................................... 27
Page |8
Appendix C: Suspected Bomb/Sabotage Device Safety Precautions..................... 28

Appendix D: Emergency Response Event Log ...................................................... 29
Appendix E: Emergency Response Call Record Form........................................... 30
Appendix F: Emergency Response Contact List.................................................... 31
Appendix G: Actions for Suspected Sabotage Events ............................................ 32
Appendix H: On-Site Hazardous Chemicals .......................................................... 35
REFERENCES
None
SUB-SECTIONS
None
DOCUMENT REVISION HISTORY
Rev Rev Date Description of Changes / Comments

R1 9/22/2020 Updated Plant Contact List
Page |9
1. PURPOSE
The purpose of this Safety Manual Procedure is to establish guidelines for responding to
plant emergencies. The instructions in this SMP apply to all plant personnel, contractors,
and any others who may be on the plant site during a fire, chemical release or spill, medical
emergency, severe weather, or bomb threat.
2. RESPONSIBILITIES
A.
B.
C.
D.
E.
3. EMERGENCY RESPONSE OVERVIEW
This procedure provides immediate action steps to be used in a variety of emergencies.

It is impossible to provide the exact steps to be followed in all emergencies and
emergencies can involve several types of problems at once (a fire with corresponding
injuries and a release of hazardous materials for example). Also, the sequence of actions
in this procedure may not be the best sequence given the specific situation of an
emergency. Steps in this procedure should be performed in an order that fits each
situation, relying on sound judgment from plant operators.
A. General Referencing
Use the Emergency Response Call Record Form (Appendix E) to document all
notifications made during an emergency, including all instructions given by parties
contacted. The Emergency Response Contact List (Appendix F) should be posted
in the Control Room. Reporting guidelines for accidents and injuries, and for “near-
P a g e | 10
miss” safety/environmental accidents, are covered later in this Safety Manual

(SMP-14, Accident and Injury Reporting).
4. HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (HAZWOPER)
A. SPILL RESPONSE PROCEDURE
The following steps will be done immediately upon observation of a hazardous

material spill. This procedure is intended to be a concise list of the basic
emergency response steps and must be used in conjunction with Hazardous
Material Spill Training and Follow-up section below.
1. ENSURE that all personnel are evacuated from the spill area. Attend to
any injured personnel.
2. EVACUATE the entire plant if it becomes necessary. Primary evacuation

routes are shown in Appendix A. The Plant Manager or his designee may
designate different evacuation routes at the time of the accident based on
the information known at the time. Personnel may also be directed to go
to a particular area of the plant to evacuate the area of the emergency if
evacuation of the site is undesirable.
3. Additionally, if the emergency involves a toxic airborne release, the Plant

Manager or his designee will EVALUATE the release and wind conditions
and DETERMINE whether or not to evacuate plant personnel or “shelter-
in-place”. The shelter-in-place concept is preferable in the situation where
a high concentration cloud of toxic gas passes a building containing people.
If the gas cloud is moving in the direction of the control room, SHUT DOWN
all air conditioning and ventilation systems. All personnel in the building
should enter the control room area and all doors leading to this area should
be closed.
4. TAKE the necessary steps to MITIGATE the spill or release (e.g., SHUT
OFF pumps, CLOSE valves, DISCONTINUE loading/unloading operations,
etc.) if it safe to do so. If at all possible, STOP the spill at its source.
5. Immediately NOTIFY (Control Room Operator (or equivalent)) all

personnel on-site of the spill/release.
NOTE
6.
P a g e | 11
emergency responders and remediation contractors to help control/clean

up the spill.
7. If the spill or release is of a nature that may place the public at risk,
INITIATE public warnings through the local emergency agencies listed on
the Emergency Response Contact List in Appendix F.
8. The Plant Manager or his designee will MAINTAIN plant security and
communications. In no case shall members of the press be admitted
without the approval of Owner Representative. The Owner Representative
or his designee will handle all public relations, press releases, and outside
inquiries.
9. Make every reasonable effort to keep the spill on the plant property. In the
event that the material has been released from the containment system, all
necessary steps shall be taken to prevent it from entering storm sewers,
public waters, or from escaping the facility property as long as it is safe to
do so.
10. REFER to Safety Data Sheets (SDS) for proper use of personnel protective
equipment.
11. BUILD berms, PLACE absorbent materials, PLUG storm drain inlets,
culverts, and ditches to stop the flow of the spill. If necessary, PLUG
culverts of streams and drainage ditches leaving the plant to stop the flow
of the spill.
NOTE
12. DOCUMENT all events in detail as soon as possible.
13. FOLLOW UP with all emergency response organizations, NAES

headquarters, and the Owner Representative to ensure all reporting
requirements have been met. REPORT all injuries in accordance with
SMP-14, Injury Response & Reporting.
B. HAZARDOUS MATERIAL SPILL TRAINING AND FOLLOW-UP
This section provides details and information to be used in preparation for and
response to emergencies involving hazardous materials incidents in compliance
with OSHA Hazardous Waste Operations and Emergency Response Standard.
This section is also to be used in conjunction with the facility Spill Prevention,
Control, and Countermeasure Plan (SPCC) if the spill involves a fuel oil spill at the
plant. The SPCC is required by EPA oil spill regulations 40 CFR 110 (which
defines the discharge of oil) and 40 CFR 112.3 (which requires an SPCC). The
SPCC is a spill prevention plan (that is, actions to be taken before the spill occurs),
P a g e | 12
while this procedure is a spill response plan (that is, an action to be taken after the
spill occurs).
Guidance pertaining to employee safety and training related to major hazardous

materials releases and subsequent cleanup operations is contained in 29 CFR
1910.120, Hazardous Waste Operations and Emergency Response, referred to as
HAZWOPER.
Overview of Hazardous Materials
The chemicals listed in Appendix J possess characteristics which could, if released

in an uncontrolled manner and in sufficient quantity (above a specified threshold
quantity), necessitate an emergency response under regulations specified by 29
CFR 1910.120.
Hazardous Materials Release Guidelines
Incidental releases can be controlled, contained, and cleaned up by employees in

the immediate area. No outside or special assistance is required. Nuisance spills
and minor releases which do not require immediate attention (due to lack of danger
to employees) would be considered within the normal activities and training of the
employee.
Incidental releases, for the purposes of operator training and response activities
pertaining to the unintended release of hazardous materials on-site, may be
approached, controlled, stopped, absorbed, neutralized, and cleaned up as long
as plant personnel do not endanger themselves, others, or the environment in the
process.
Personnel will carry out system operations at a safe distance to minimize the
severity of the release. Remote control of valves and pumps will be employed as
available to minimize the necessity of approaching the point of origin of an
incidental release. Personnel will employ PPE, as needed and for which they are
trained, to minimize potential for contact with the released materials. Clean up and
hazardous material disposal techniques will be followed to ensure safe and
efficient return to normal operations.
Recording and reporting of the release should be made promptly as described in

the Notification section below. The Plant Manager, or a designee, shall review the
situation and notification requirements to determine what outside organizations are
required to be notified. As a minimum, the Owner Representative and NAES
Headquarters Managers shall be notified. Refer to the table for
Reportable/Threshold Quantities for any Extremely Hazardous Substances that
are stored on-site. Proper decontamination of equipment and PPE shall be
implemented after the cleanup is completed.
A hazardous materials emergency response is any response effort by employees

from outside the immediate release area or by other designated responders (i.e.,
mutual aid groups, local fire departments, etc.) to an occurrence which results, or
is likely to result, in an uncontrolled release, which may cause high levels of
exposure to toxic substances, or which poses danger to employees requiring
P a g e | 13
immediate attention. No employee shall attempt to perform actions for which they
have not been prepared, through training and experience, or for which they are not
properly equipped. On-site and off-site training will be conducted both initially and
on a continuing basis, as necessary, to ensure that personnel have the knowledge
and experience to make a reasonable determination of the dangers when faced
with a release situation.
If an uncontrolled release occurs resulting in an emergency, the designated off-

site emergency response organizations shall be contacted. Refer to the
Emergency Response Contact (Phone) List in Appendix F.
Resource Allocation
Emergency Response Training
Training shall be based on the duties and functions to be performed by each

employee. Documentation of such training, including program agendas (with a
copy of any outlines, overheads or handouts) and training rosters shall be
maintained.
Facility response personnel are given instruction in emergency procedures related

to a release of a hazardous substance or any hazardous chemical. Topics of
instruction include emergency equipment (proper use, inspection and
maintenance procedures), emergency systems (such as alarms/communications,
key cut off systems for automatic feed systems), response procedures for fires,
explosions, and spills (including spills to groundwater), and the organizational
responsibilities of response personnel under the National Incident Management
System.
First Responder Awareness Level
First responders at the awareness level are individuals who are likely to witness or
discover a hazardous substance release and who have been trained to initiate an
emergency response sequence by notifying the proper authorities of the release.
They will take no further action beyond notifying the authorities of the release. First
responders at the awareness level shall have sufficient training or have had
sufficient experience to objectively demonstrate competency in the following
areas:
1. An understanding of what a hazardous substances are, and the risks

associated with them in an incident
P a g e | 14
2. An understanding of the potential outcomes associated with an emergency

created when hazardous substances are present
3. The ability to recognize the presence of hazardous substances in an

emergency
4. An understanding of the role of the first responder awareness individual in

the employer emergency response plan, including site security and control,
and the DOT Emergency Response Guidebook
5. The ability to realize the need for additional resources, and to make the
appropriate notifications to the communications center
First Responder Operations Level
First responders at the operations level are individuals who respond to releases or
potential releases of hazardous substances as part of the initial response to the
site for the purpose of protecting nearby persons, property, or the environment
from the effects of the release. They are trained to respond in a defensive fashion
without actually trying to stop the release. Their function is to contain the spill from
a safe distance, keep it from spreading, and prevent exposures. First responders
at the operational level shall have received at least eight hours of training or have
had sufficient experience to objectively demonstrate competency in the following
areas in addition to those listed for the awareness level:
1. Knowledge of the basic hazard and risk assessment techniques
2. Knowledge of how to select and use proper PPE provided to the first
responder operational level
3. An understanding of basic hazardous materials terms
4. Knowledge of how to perform basic control, containment and/or

confinement within the capabilities of the resources and PPE available
within their unit
5. Knowledge of how to implement basic decontamination procedures
6. An understanding of the relevant standard operating and termination

procedures
Spill Response
Upon observation of a release of a hazardous material, chemical, or oil, employees

shall immediately notify the Plant Manager with information concerning the spill,
such as:
1. Employee name
2. Location of spill
3. Type and quantity of material spilled

P a g e | 15
4. Actions and result of actions taken to mitigate the spill
5. Circumstances that caused the spill
1. The facility name, exact location, and phone number
2. The source and cause of the spill
3. The type (chemical name), volume of material released, and whether the
material is classified as extremely hazardous
4. The volume estimated that reached navigable waters
5. The time, date, and duration of the spill
6. The medium of release (air, soil, water) and anticipated release movement
7. The action taken and anticipated
8. State whether evacuation is needed
9. The weather conditions, if applicable
10. Known health risks and required medical attention
11. Names of other parties contacted
12. Names of other parties to be contacted
Keep notifications factual and do not speculate. Keep a record of all notifications
made including all instructions given by parties contacted using the Emergency
Response Call Record Form shown on Appendix E.
All inquiries from the media and the public should be referred to the Plant Manager,
or his designee. Under no circumstances shall any plant personnel provide
information to media or the general public concerning the spill. The Plant Manager
will refer all inquiries to the Owner Representative.
P a g e | 16
For plants with fuel oil: Per 40 CFR 112.4, in the event that a discharge of 1,000
gallons of oil escapes the containment systems and enters into the navigable
waters of the United States in a single spill event or a discharge of harmful
quantities in two spill events within any twelve month period occurs, the Plant
Manager will submit notification in writing to the EPA Regional Administrator:
NOTE
The following information is required in the above notification. An asterisk

(*) denotes information included in the SPCC plan.
1. A complete copy of the SPCC plan
2. Name, phone number, and address of the facility (*)
3. Owner and operator name and address (*)
4. Date and year of initial facility operation (*)
5. Maximum storage capacity and average daily use (*)
6. Description of the facility (*)
7. Quantity and type of material spilled
8. Cause(s) of the spill(s)
9. Corrective actions
10. Additional preventative measures
11. Other pertinent information
The plant staff shall investigate each incident that resulted in, or could reasonably
have resulted in, a release of hazardous materials. An incident investigation shall
be initiated as promptly as possible, but not later than 24 hours following the
incident.
Managerial Responsibilities
P a g e | 17
Spill Clean-up and Disposal Procedure
Cleanup will be conducted to coordinate collection for isolation and disposal of

contaminated products and materials, as appropriate. The categories listed below
will be isolated and secured independently. These steps are necessary to reduce
costs associated with clean up and disposal of contaminated materials.
1. Recovered pure product for possible refining and reuse
2. Contaminated PPE for separate disposal
3. Oiled debris for separate disposal, i.e., wood products, beauty bark, etc.
4. Contaminated soils for possible incineration or separate disposal
5. Absorbent materials for incineration
All residuals (recovered chemicals, contaminated clean up materials, and

contaminated soil) resulting from spill remediation will be placed in containers that
have been inspected for use as such.
Disposal of spilled material will meet all Federal and State regulations guiding the
disposal of waste. Hazardous waste manifests will accompany containers of spill
residues if the residue is determined by definitions of hazardous regulations to be
hazardous. All required labeling and recordkeeping requirements will be followed.
Consult the applicable Material Safety Data Sheet for the substance to determine
the appropriate cleanup procedures. Ensure all plant and contractor personnel
assisting with the clean-up are aware of clean-up instructions and hazards listed
on the SDS.
Refer to the facility Environmental instructions for further guidelines on the disposal
of hazardous materials. Additionally, contact NAES headquarters and or the
NAES Environmental Support Services (ESS) Division for assistance, if needed.
5. FIRE RESPONSE PROCEDURE
A.
P a g e | 18
B. Incipient stage fire means a fire which is in the initial or beginning stage and which
can be controlled or extinguished by one person with one portable fire extinguisher.
If the fire is in the incipient stage and you have been properly trained, respond
using the appropriate fire response equipment.
NOTE
If the fire progresses into a life-threatening event, immediately evacuate

the area and notify the Control Room.
C. In the event that the fire is beyond the incipient stage and requires outside
emergency response the CRO will contact 911 and sound the plant evacuation
alarm.
D. To facilitate a quick response, the plant will designate a liaison to meet the Fire
Response Service at the main entrance gate.
E. The areas on-site that have been designated as “muster areas” are listed and
locations identified in Appendix A.
F. Upon hearing the fire evacuation alarm, all personnel shall evacuate to their
primary evacuation area.
G. If necessary, a secondary evacuation area will be determined based upon site

conditions and wind direction (as determined by the wind sock).
H. The Visitor Log Book from the Administration Building should be utilized to aid in
accounting for all personnel.
I. Fire Evacuation Drills shall be conducted annually. At a minimum, the plant

evacuation alarm shall be tested monthly. A written record of all drills shall be
maintained. Any deficiencies observed shall be corrected.
6. CHEMICAL RELEASE/SPILL PROCEDURE
A. In the event of a chemical spill or release, immediately report it to the CRO via
plant radio, cell phone, or other means. The report to the CRO shall include the
following:
1. Your name
2. Nature of event – “chemical spill/release”

P a g e | 19
3. Location of the spill/release
4. Chemical identity and severity of the spill/release (estimate quantity)
5. Your planned action (ex. – evacuate or close remote valve)
B. Depending on the chemical and quantity involved, refer to section 4.B for steps
necessary to respond to the spill.
7. MEDICAL EMERGENCIES
A. All injuries must be reported to your supervisor, no matter how small. First
Aid/CPR trained personnel will be called to respond to minor first aid injuries.
B. If someone is seriously hurt, notify the CRO of the location of the injured person,
nature of the injury, and any other important information related to the incident
scene (ex. down power line next to injured person, chemical drum spill, etc.).
C. The CRO will contact 911 to alert emergency crews. An individual will be
designated to meet emergency crews at the main entrance gate.
D. The CRO will make an announcement for all available First Aid/CPR trained
personnel to report to the incident site. The First Aid/CPR trained personnel will
administer first aid and any other measures within their training until the emergency
crews arrive at the scene.
E. If the situation warrants the rescue of an unconscious or immobile person from a

confined space or an elevated surface, or in a personal fall arrest system the CRO
will be instructed to dial 911 and shall explain to emergency personnel the type,
location, and hazards of the area.
8. EARTHQUAKES, TORNADOS, AND SEVERE STORM EMERGENCIES
A. EARTHQUAKES
1. TAKE cover under a desk or strong table or in a doorway, or sit or stand

against an inside wall.
2. STAY away from windows, glass, bookcases, and outside doors.
3. DO NOT ATTEMPT to leave the building during a severe earthquake

because of the hazards of downed power lines, falling debris from the
building, etc.
4. MOVE away from buildings and utility wires.
5. WATCH for falling glass, electrical wires, poles or other debris.
6. CHECK for injuries and provide first aid as necessary.
7. CHECK for broken fuel lines and electrical faults. Isolate ruptures and
faults as necessary.
P a g e | 20
8. CHECK for ruptures in systems containing hazardous chemicals. Isolate

and contain spills.
9. PLACE the plant in a safe condition by shutting down equipment as

necessary.
10. AVOID using the telephone except for emergency notification.
B. TORNADOS AND SEVERE STORMS
In the event of impending severe weather, plant personnel will monitor the local
emergency weather broadcast. The Plant Manager shall be notified and will try to
be on-site to determine appropriate action. If the Plant Manager cannot be
contacted, the CRO shall determine the appropriate action.
During severe thunderstorms, caution should be used during outside activities. If

thunderstorms are in the immediate area of the plant, outside activities should be
curtailed. The safety of plant personnel shall be the prime concern and reasonable
judgment shall be used.
The best protection in a tornado is usually an underground area. The best above
ground areas in a building are:
1. Small interior rooms on the lowest floor without windows
2. Hallways on lowest floor away from outside doors and windows
3. Rooms constructed of reinforced concrete, brick or block with no windows

and a heavy concrete floor or roof system.
4. Employees should be instructed to seek shelter areas as near as possible

to inside walls, away from window areas. The CRO will make an
announcement, and ensure that all personnel have been warned of the
outside conditions and to seek shelter inside in a safe location.
5. Get as close to the floor as possible and against sturdy machinery that will
prevent portions of the roof, etc. from striking directly should they fall.
6. Do not evacuate the building until dangerous wind levels have subsided.
An automobile is not a safe place to be in these circumstances.
7. If outside, seek safety in a low-lying depression such as a ditch or ravine.
8. An announcement shall be made indicating when the tornado or severe

storm has passed.
9. An investigative team shall be designated to inspect all outside plant areas

looking for damages, down power lines, and other potentially dangerous
conditions.
P a g e | 21
9. BOMB THREATS AND ACTS OF SABOTAGE
A. RECOGNITION
Understanding when an act of Sabotage is taking place or is about to take place

is the first step towards preventing the subsequent injury and damage that the
event can ultimately result in. A variety of tools are available to each NAES-
managed facility meant to be used in conjunction with the Emergency Response
Plan for any actual or potential Acts of Sabotage. These tools are available as
Appendices to this procedure and are described below:
1.
2.
3.
B. RESPONSE
Although many threats turn out to be hoaxes, it is very important to not dismiss the
possibility of injury and damage and treat every situation seriously. When a bomb
threat or discovery of a suspected Sabotage event is discovered, remember to not
panic, remain calm, and follow the steps below:
1. For any abnormal events that could potentially be acts of Sabotage, refer
to Appendix I – Actions for Suspected Sabotage Events.
2. When a call is received regarding a bomb threat or other act of Sabotage,

refer to Appendix B – Bomb Threat Checklist while keeping the following
items in mind:
a.
b.
c.
P a g e | 22
d.
e.
f.
g.
3. Maintain security and communications. The Plant Manager (or designee)

shall maintain plant security by restricting access so that only essential
plant personnel and emergency personnel are admitted.
The Owner Representative or his designee will handle all

public relations, press releases, and outside inquiries.
4. Quickly search the plant area for suspicious, unusual, or foreign items
(suspected bombs/Sabotage devices), and report any findings, but do not
touch, move, jar, disturb, or cover any suspicious items found. Observe
the precautions listed in Appendix C. When police arrive, assist as
necessary with a more detailed search of the plant.
5. If a suspicious item or bomb is located during the search, do the following:
a.
b.
c.
d.
NOTE
At any time during these actions, the Plant Manager or on shift CRO can
order the shutdown of equipment and evacuation if, in his judgment, there
are strong indications of an immediate serious threat to the plant and/or its
personnel.
6.
7. Upon completion of the threat, the management team shall assemble to

critique the handling of the situation. Any recommendations for
P a g e | 23
improvement must be incorporated into the policy and re-training

conducted with the necessary personnel.
C. COMMUNICATION
1.
2.
3.
NOTE
Have all written records or notes of the threat available.
4.
5.
P a g e | 24
6.
Emergency Organizational Telephone Numbers for Threat Control
Mobile
Name Title Office Number
Number
D. REPORTING
It is essential that any incident involving a real or suspected threat of Sabotage be

reported as soon as reasonably possible.
Distribution of this information should be initiated by the immediate submission of

an Electrical Emergency Incident and Disturbance Report (Form OE-417) to the
US Department of Energy according to the OE-417 Form instructions
(http://www.oe.netl.doe.gov/oe417.aspx). The Form OE-417 consists of an Alert
Notice (Schedule 1) and a Narrative Description (Schedule 2) which must be
submitted within the time frames described below (and as specified in the top
portion of the Alert Notice).
P a g e | 25
10. TRAINING
A. All plant employees shall receive training on emergency response procedures on

an annual basis.
B. All newly hired employees shall receive this training during orientation.
C. Contract employees must receive this training as integrated into the contractor
orientation and training.
NOTE
In addition to the training, the appropriate number of radios shall be

determined and issued to the Contractor Supervisor/Foreman.
D. All plant employees training must include at a minimum the following:
1. Familiarization with this plan
2. Any Hazmat Training that may be applicable
3. The use of any firefighting equipment available
4. Any special items or needs that may rise
E. All contract employees training must include the following:
1. A general overview of this plan
2. Any special items or needs that may arise during the course of their stay
on-site
F. A written record must be maintained of all plant employees and contract

employees who have received the training.
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Facility Evacuation Route Diagram

P a g e | 27
Bomb Threat Checklist
Instructions: Have someone else call police (911) and keep caller on the line. Listen; do
not interrupt the caller except to ask:
1. When will it go off?
2. Where is it planted?
3. What floor is it on?
4. What kind of bomb is it?
5. What does it look like?
6. Why are you doing this?
7. Who are you?
8. Where are you?
Call received by: Time of Call
Date Time of Hang-up
Description of Caller: Male Female Adult Juvenile ______ App. Age
Voice Characteristics Speech Language
Loud Soft Fast Slow Excellent Good
High Pitch Deep Distinct Distorted Fair Poor
Pleasant Raspy Stutter Nasal Four Other
Intoxicated Slurred Precise Use of Certain Words or Phases:
Other Other
Accent Manner Background Noises

Local Not Local Calm Angry Office Street
Foreign Regional Rational Irrational Machines Traffic
Race Other Coherent Incoherent Factory Airplanes
Deliberate Emotional Machines Trains
Explain: Righteous Laughing Bedlam Voices
Animals Music
Is voice familiar? Sounds like Quiet Party
________________________ Mixed Atmosphere
Action to take immediately after call:

1. Notify plant management.
2. Notify Owner's Representative.
3. Notify NAES Headquarters' Management.
4 Refer to RCP-NERC-EOP-004-ATT-A for NERC related reporting
5. Forward a copy of this to parties above ASAP.
6. Write exact statement or caller below:
P a g e | 28
Suspected Bomb/Sabotage Device Safety Precautions
The safety precautions below are designed to acquaint you with dangers inherent in the
search, discovery, and handling of “suspected bombs” or “suspected Sabotage devices”.
P a g e | 29
Emergency Response Event Log
Emergency Description:
Date and Time of Emergency:
Note: Log all events associated with the emergency chronologically. Keep logs factual and concise.
P a g e | 30
Emergency Response Call Record Form
Emergency Description:
Date and Time of Emergency:
Time Company/Agency Notified Company/Agency Contact NAES HQ Contact
Description of Correspondence:
P a g e | 31
Emergency Response Contact List
Contacts should be made in the following order whenever possible. However, if contact
cannot be made after two attempts, move on to the next level.
Event Contact Title Phone 1 Phone 2 Comment

Sabotage/Bomb Local Emergency 911
Threat/Event Services
Plant Manager
P a g e | 32
Actions for Suspected Sabotage Events
All personnel should pay close attention to the events described in the table below. For all situations, perform the following
actions along with the supplementary actions and then refer back to Section 9:
1. Immediately contact the Plant Manager (or designee in his/her absence)

2. Ensure that all on duty personnel are alerted to the possibility of a sabotage event.
3. Document as many details about the situation as possible. Note times, events, and descriptions as applicable to the
situation.
4. If appropriate, notify law enforcement and parties of the interconnection in accordance with Section 9C.
Event Event Definition Supplementary Actions

Abnormal Behavior of Personnel
Unfamiliar/Unescorted Visitors
Unexplained Packages or
Shipments
Abandoned Vehicles
Abnormal Observations
P a g e | 33

Equipment Misuse/Abuse
Attempted Intrusion (Physical)
Attempted Intrusion (Cyber)
Cyber and/or Communication

Disruptions
Information Theft and/or Loss of

Sensitive Plant Information
P a g e | 34

Unauthorized Modification of
Software or Data
Multiple breaker operations in your

switchyard and adjacent
Transmission Owners switchyard
Cyber systems for parties in the

interconnection start showing
equipment operation that has not
physically occurred.
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On-Site Hazardous Chemicals
Chemical Name, Threshold Qty, Threshold Qty Stored Qty

Description Pure Product Solution in Use On-site
Aqueous Ammonia
(10-30% solution)
Diesel Fuel Oil
(No. 2 grade)
Sulfuric Acid
(93% solution)
Sodium Hydroxide
(50% solution)
P a g e | 36
Approved By: Nicole Jackson Date: 12/8/2021
Nacogdoches Generating Plant
Winter Weatherization Plan

P a g e | 37
Revision Log

1 Protocols – 1.) Main steam flow transmitter. 8.) The plant will hold 10-28-14
freeze protection training prior to the winter season.
2 Protocols – 1.) Removed DA level transmitters, Drum level 10-11-16
transmitters, Main Steam flow transmitters, Hotwell level
transmitters, Cooling tower level transmitters, HP and LP heater
level transmitters from procedure.
3 Updated Plan to include attachments with new PM’s in place. 2-22-17
Updated Lessons Learned from previous events section.
4 3-14-18
Updated Southern Power Company Duty Phone Number on
5 11/6/18
Attachment A
Removed all Southern Power Company Information and updated
6 10/14/19
with NAES
Updated PM list to include PM NAC4260 Freeze Protection Annual 10/14/19
Refresher Training
Updated PM list to include PM NAC1401 Freeze Protection 10/14/19
Inspection and Readiness
Updated Wind Break Installation List 10/14/19
Added a spot for the temperature reading to the freeze protection
7 3/18/2020
round sheets
Added to protocol #2 operations will review the freeze protection 3/18/2020
round sheet during annual training. Added to review the loss of
drum control procedure during annual training. (NAC-1-3561.000)
Added PM NAC4211 Air Compressor Maintenance Quarterly 3/18/2020
Checks to protocol #1
Updated PM NAC4206 attachment to include a column to note 3/18/2020
critical circuits
Updated with new Approver Signature, new Plant Manager
8 10/27/2020
Updated Attachment A Emergency Contacts
Added additional lessons learned (13-17) from February 2021

9 09/21/2021
freeze event
Added new PM NAC1410 Testing Freeze Protection Components

10 12/08/2021
P a g e | 38
Purpose
Safety is the highest priority at Nacogdoches Generating Facility and overrides any
other requirements. The purpose of this procedure is to establish a winter
weatherization plan which provides an overview of the actions being undertaken in
order to maintain the reliability of the generating facility during the winter season.
This plan is intended to meet and exceed the requirements of NPRR 473, which
requires assessment of the reliability of the system by ERCOT during extreme weather.
WWP Scope
The Winter Weatherization Plan (WWP) consists of the following protocols implemented
through a preventative maintenance process tool and combined with daily operations
rounds to document any deficiencies.
Protocols
1. Freeze Protection/winter weather preparedness preventative work orders will be
generated annually prior to the onset of winter season for:
a. PM NAC4258 -Insulation Inspection
b. PM NAC1401 -Inspection and Readiness
c. PM NAC4206 -Heat Trace Inspection Semi-Annual and Annual
d. PM NAC4260 -Freeze Protection Annual Refresher Training
e. PM NAC4214 -Remove Freeze Protection Assets installed for Winter
Weatherization Plan
f. PM NAC4211 -Air Compressor Maintenance Quarterly Checks
g. PM NAC1410 – Testing Freeze Protection Components
2. Freeze Protection Training will be held annually before the winter season.
During this training Operations will review the freeze protection round sheets.
During this training operations will review the loss of drum level control
procedure NAC-1-3561.000.
3. Prior to the onset of winter season, Plant Nacogdoches will conduct an inventory
of critical supplies needed to keep the plant operational.
4. Wind breaks will be erected, and additional heat sources supplied to the
following areas:
-
-
-
-
-
-
-
P a g e | 39
5. When temperatures fall below 30 degrees’ plant personnel will perform freeze
protection rounds on critical components in addition to our normal rounds. If the
unit is online plant personnel will record readings every 2 hours on critical
components until the temperature reaches 30 degrees’. If the unit is offline we
will record freeze protection rounds on critical components once per shift in
addition to our normal rounds.
6. Plant Nacogdoches is staffed 24X7 year-round. We will call in additional
resources as needed to support the reliability of the unit.
7. Plant Nacogdoches has back up communication in place via satellite phone.
Lessons Learned from previous events
1.
2.
3.
4.
5.
6.
7.
8.
9.
10
11
12
13
14
15
16
17
P a g e | 40
Attachments
A. Emergency Contacts
B. PM NAC4260 -Annual Freeze Protection Training
C. PM NAC4258 -Insulation Inspection
D. PM NAC1401 -Inspection and Readiness
E. PM NAC4206 -Heat Trace Inspection Semi-Annual and Annual
F. PM NAC4214 -Remove Freeze Protection Assets
G. Freeze Protection online and offline rounds
H. Heat trace circuit drawings
I. List of Critical Equipment
J. PM NAC4211 -Air Compressor Maintenance Quarterly Checks
K. PM NAC1410 -Testing Freeze Protection Components
P a g e | 41
Attachment A
Emergency Contacts
Plant Contact
▪ Nicole Jackson
Dispatch
▪ Austin Energy (Control Center)
Reliability Entities (Reliability Coordinator)
▪ ERCOT (Control Center)
Reliability Entities (Transmission Operator)
▪ Oncor (Control Center)
Federal Bureau of Investigation (FBI) Offices
▪ Texas (FBI Duty Agent – Austin)
If Plant Management cannot make positive contact with any of their first-tier contacts
identified in the contact tree, they will call subsequent tiers until appropriate entities are
notified.
P a g e | 42
Attachment B
Annual Freeze Protection Training

P a g e | 43
Attachment C
Insulation Inspection
P a g e | 44
Attachment D
Inspection and Readiness
Freeze Protection Job Box

P a g e | 45
Attachment D (Cont.)
Supplemental Equipment Inventory List

5
4
1
4
6
2
2
2
2
P a g e | 46
Attachment E
Heat Trace Inspection

P a g e | 47
Attachment F
Remove Freeze Protection Assets

P a g e | 48
Attachment G
Freeze Protection online and offline rounds

P a g e | 49
Attachment H
Heat trace circuit drawings

P a g e | 50
Attachment I
List of Critical Equipment

P a g e | 51
Attachment J
Air Compressor Maintenance Quarterly Checks

P a g e | 52
Attachment K
Testing Freeze Protection Components

P a g e | 53
P a g e | 54
Approved By: Nicole Jackson Date: 3/9/2021
Nacogdoches Generating Facility
Summer Weatherization Plan

P a g e | 55
Revision Log

1 Updated Emergency Contacts 5/1/2020
1 Updated Purpose Language 5/1/2020
2 Updated Template 3/9/2021
2 Updated Plant Contacts List 3/9/2021
2 Included Previous Events 3/9/2021
P a g e | 56
Table of Contents
PURPOSE AND SCOPE ......................................................................... 57

Purpose ................................................................................................ 57
Scope ................................................................................................... 57
SAFETY PRECAUTIONS / LIMITATIONS............................................... 57
Protocol.................................................................................................... 58
HOT WEATHER PREPAREDNESS ........................................................ 59
PERSONNEL ACTIONS DURING HOT WEATHER EVENT .................. 59
CRITICAL COOLING EQUIPMENT CHECKLIST .................................... 60
Emergency Contacts……………………………………………………8
Previous Weather Events…………………………………………………….9
P a g e | 57
PURPOSE AND SCOPE
Purpose
Safety is the highest priority at Nacogdoches Generating Facility and overrides any
other requirements. The purpose of this procedure is to establish a summer
weatherization plan which provides an overview of the actions being undertaken in
order to maintain the reliability of the generating facility during the summer season.
This plan is intended to meet and exceed the requirements of ERCOT Nodal Protocols
Section 22, which is the declaration of summer weather preparations.
Scope
The Summer Weatherization Plan (SWP) consist of the following protocols
implemented through a preventative maintenance process tool and combined with daily
operations rounds to document any deficiencies.
SAFETY PRECAUTIONS / LIMITATIONS
i. All Safety and Health procedures shall always be followed.
ii. A thorough Job Safety Briefing (JSB) shall be completed before beginning work.
iii. Employees should always use the proper Personal Protection Equipment (PPE) for
the task they are performing.
iv. Personnel must observe standard safety precautions when working around or with
high-temperature piping systems.
v. Personnel must be aware that components of this system are maintained in an

automatic mode of operation. The equipment may start at any time without
warning.
vi. Personnel should remain clear of all rotating machinery, whether operating or in
standby, at all times during unit operation.
vii. Rotating machinery must never be placed in service without the appropriate
equipment guards in place.
viii. No attempt should be made to bypass or eliminate equipment safety interlocks.

Doing so could result in equipment damage and possible injury to plant
personnel.
P a g e | 58
Protocol
1. The plant generates preventative maintenance work orders to address the

proper operation or non-operation (summer conditions) of the complete heat
trace system.
2. The work order program also generates work orders to inspect and maintain
all equipment across each system at the designated interval: weekly, monthly,
semi-annual, annual, etc. as recommended by the original equipment
manufacturer (OEM).
3. The plant utilizes shift rounds to visually inspect and verify the correct
conditions associated with chemical and propane storage. This includes
monitoring equipment conditions, both operating and non-operating, and
varying storage levels affected by different ambient conditions.
4. The plant continuously monitors the age of the biomass fuel inventory in
addition to other measures (ambient temperature, rainfall) turning the pile as
needed to prevent the possibility of fire or safety-related issue.
5. In addition, fuel sampling is performed, sent offsite, and evaluated to ensure
accurate analysis of fuel quality.
P a g e | 59
HOT WEATHER PREPAREDNESS
A planning meeting should be scheduled and conducted, well in advance of the

summer operating season, to estimate and determine the requirements of the
summer months approaching.
1. REVIEW Previous Summer Weather Events.
2. IDENTIFY Inventory needing replenishment.
a. Drinking water and sports drinks.
b. Engine coolants for rolling stock and emergency fire pump and generators.
c. Air horns and port-a-cools.
3. CHECK the following equipment for Proper Operation and Readiness:
a. Rolling Stock
b. Emergency Diesel Fire Pump
c. Emergency Diesel Generator
4. VERIFY emergency phone list is correct.
5. VERIFY 24 hour HVAC support is available.
6. INFORM personnel of special operating limitations and countermeasures.
7. CHECK that Air Conditioning Contractors have serviced all air conditioning units.
8. VERIFY proper first aid supplies are on hand.
9. PERFORM an operational function check of all transformer vent fans.
10. PERFORM an operational function check of all oil cooler fans.
11. ENSURE all plant heat exchangers are clean and in good working order.
12.COMMUNICATE Summer Weatherization Plan responsibilities to appropriate personnel.
PERSONNEL ACTIONS DURING HOT WEATHER EVENT
In the event that extreme hot weather is forecasted the following plan should be
initiated.
1. Stage portable cooling equipment and air horns in accessible areas or place in
known areas of need.
2. Stage water and sports drinks in coolers throughout work areas. (Elevator, etc.)
3. Personnel will discuss the weather forecast and safety implications at the
beginning of each shift.
4. Communicate and implement summer weather advisories.
a. Note in shift logs that summer weather advisory has been implemented.
b. Note in shift logs when the summer weather advisory is released.
5. Implement operating controls during extreme summer weather advisories.
a. Complete critical cooling equipment checklists immediately following the
implementation of a summer weather advisory.
b. Assure adequate staff for readiness implementation.
c. Impose restriction on maintenance activities during advisories.
P a g e | 60
CRITICAL COOLING EQUIPMENT CHECKLIST
DATE: NAME: AMBIENT TEMP:

LOCATION IS UNIT LOCATION IS UNIT
OPERATING OPERATING
CORRECTLY? CORRECTLY?
Y/N Y/N
P a g e | 61
Emergency Contacts
Plant Contact
Dispatch
Reliability Entities (Reliability Coordinator)
▪ ERCOT (Control Center)
Reliability Entities (Transmission Operator)
▪ Oncor (Control Center)
Federal Bureau of Investigation (FBI) Offices
▪ Texas (FBI Duty Agent – Austin)
If Plant Management cannot make positive contact with any of their first-tier contacts
identified in the contact tree, they will call subsequent tiers until appropriate entities are
notified.
P a g e | 62
Previous Weather Events

P a g e | 63
6.0b. Water Shortage – PUCT 25.53.(e).(2).(B)
This plan is designed to provide an action plan that addresses supply shortages of water used
in the generation of electricity. The focus of the plan is to ensure generation capability
to support grid reliability. In accordance with PUCT 25.53.(e).(2).(B), The loss of
cooling tower make up is included in this section.
P a g e | 64
Approved By: Date:
OPERATOR EVENT RESPONSE ACTION
LOSS OF COOLING TOWER MAKE UP

P a g e | 65
Revision Log

P a g e | 66
Table of Contents
3588.000 PURPOSE/FUNCTION.................................................................... 67
3588.100 PRECAUTIONS/LIMITATIONS ....................................................... 67
3588.200 GENERAL ....................................................................................... 67
3588.300 INITIAL CONDITIONS ..................................................................... 67
3588.400 POTENTIAL CAUSES ..................................................................... 67
3588.500 AUTOMATIC PLANT RESPONSE .................................................. 67
3588.600 OPERATOR ACTIONS.................................................................... 68
3588.700 PLANT RECOVERY ........................................................................ 68
3588.800 FOLLOW UP ................................................................................... 68
P a g e | 67
2. PURPOSE/FUNCTION
i. This procedure is intended to guide the Operations team through a cooling

tower make up water loss event.
ii. This procedure details actions that must be accomplished by either the
Control Room Operator or the Outside Operator to maintain the plant in a
safe condition and protect equipment.
3. PRECAUTIONS/LIMITATIONS
i. Under no circumstances should operators compromise safety standards.
ii. Any alarms/trips that occur must be responded to immediately and
appropriate corrective action taken quickly. Document all abnormal
occurrences.
4. GENERAL
i.
5. INITIAL CONDITIONS
i. The plant can be in any operating configuration.
6. POTENTIAL CAUSES
i.
ii.
iii.
iv.
v.
vi.
vii.
7. AUTOMATIC PLANT RESPONSE
i.
ii.
P a g e | 68
8. OPERATOR ACTIONS
i.
ii.
iii.
iv.
v.
Note
vi.
vii.
viii.
ix.
x.
xi.
9. PLANT RECOVERY
i.
ii.
iii.
10. FOLLOW UP
i. Provide necessary documentation for future reference.
ii. Notify Plant Management that event has been resolved.
P a g e | 69
6.0c. Restoration of Service– PUCT 25.53.(e).(2).(C)

P a g e | 70
PRIORITIES FOR RECOVERY OF

GENERATION CAPACITY
P a g e | 71
TABLE OF CONTENTS
SECTION TITLE PAGE
1.
2. Introduction
Purpose 2
3. Objective 2
4. Reference Policies 2
5. Priorities for Recovery 3
6. Plant Preparatory Actions and Timeline 3
7. Resources 3
8. Recovery Actions 4
PEP-OO9 Restoration Rev 1

P a g e | 72
1. INTRODUCTION
Recognizing that proper preparation and planning are essential to ensure reliability during
recovery of electric generation capability following a system-wide outage Nacogdoches
Generating Facility has established this Priorities for Recovery of Generation Capacity Plan.
This Emergency Plan shall be followed by Nacogdoches Generating Facility personnel to

respond to a plant outage, in conjunction with a system-wide outage
2. PURPOSE
The Pr ior ities for Recovery of Generation Capacity Plan is a plan to guide activities required
to prepare for emergency conditions for generation recovery and satisfies the requirements
of several outside agencies. The focus is on maintaining facility reliability and preventing
prolonged outages.
3. OBJECTIVE
It is the responsibility of Nacogdoches Generating Facility personnel to develop and

implement a robust Recovery of Generation Plan to maintain the readiness and reliability
of this facility. This plan should be reviewed periodically to incorporate industry best
practices and lessons learned for continuous improvement.
4. REFERENCE POLICIES
Substantive Rules Applicable to Electric Service Providers
Nacogdoches Generating Facility Startup Procedure

Nacogdoches Generating Facility Shutdown Procedure
PEP-009 Restoration Rev 1

P a g e | 73
5. PRIORITIES FOR RECOVERY
The Nacogdoches Generating Facility will follow the recovery plan of the local
Independent System Operator {ISO) or Regional Entity (RE). The primary focus will be
to return the plant to service to support recovery of the grid, according to the needs of
the ISO or RE. The information in this procedure will be used to guide the facility recovery
actions.
6. PLANT PREPARATORY ACTIONS AND TIMELINE
In the event of an emergency requiring power plant shutdown, the facility will report
immediately to Austin Energy's Qualified Scheduling Entity ("QSE") 24-hour desk, who
will in turn notify all appropriate internal and external parties. After declaring an all-clear
condition at the location, the facility will follow a comprehensive startup procedure
that is unique to the capabilities of each specific power plant.
7. RESOURCES
• Nacogdoches Generating Facility maintains additional procedures in other

sections of this EOP to address operating emergencies. Additional operating
procedures for System Operators are maintained in the control room.

P a g e | 74
8. RECOVERY ACTIONS
A. RESUME normal plant operations as permitted by system restoration. Ensure proper

safety requirements are met when restoring operability to systems and their
components.

P a g e | 75
LOSS OF STATION SERVICE
PROCEDURE
P a g e | 76
Revision Log

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Table of Contents
3589.000 PURPOSE AND SCOPE ......................................................................... 78

3589.100 PRECAUTIONS/LIMITATIONS ............................................................... 78
3589.200 GENERAL................................................................................................ 78
3589.300 INITIAL CONDITIONS ............................................................................. 78
3589.400 AUTOMATIC PLANT RESPONSE .......................................................... 78
3589.500 OPERATOR ACTIONS ............................................................................ 79
3589.600 PLANT RECOVERY ................................................................................ 80
3589.700 FOLLOW-UP ........................................................................................... 80
3589.800 ATTACHMENTS ...................................................................................... 80
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11. PURPOSE AND SCOPE
i. This procedure is intended to guide the Operation Team in the event Station
Service is lost.
ii. This procedure details actions that must be accomplished by either the Control
Room Operator and/or the Outside Operator to ensure safe recovery to normal
condition or ensure Emergency Generator is supplying necessary power for
Critical Equipment to place Steam Turbine on Turning Gear.
12. PRECAUTIONS/LIMITATIONS
i. Under no circumstances should operators compromise safety standards.

ii. Any alarms/trips that occur must be responded to immediately and appropriate
corrective action taken quickly. Document all abnormal occurrences.
13. GENERAL
i.
ii.
14. INITIAL CONDITIONS
i.
ii.
15. AUTOMATIC PLANT RESPONSE
i.
16. OPERATOR ACTIONS
1.____
2.____
3.____
4.____
5.____
6.____
7.____
8.____
9.____
10.____
Note
If grid is available proceed to switch power from emergency diesel generator
to construction transformer.
11.____
12.____
13.____
14.____
15.____
16.____
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17.____
18.____
19.____
20.____
21.____
17. PLANT RECOVERY
i. Isolation of Fault
1.
2.
3.
4.
5.
ii. Returning to Normal Operation
1.
2.
3.
18. FOLLOW-UP
i. Verify all plant auxiliaries are running.
19. ATTACHMENTS
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6.0d. Pandemic and Epidemic– PUCT 25.53.(e).(2).(D)
The plan identifies risk assessments for major business functions and recovery strategies
for loss of key personnel. Procedures are in place which identify alternate personnel for
key business functions and critical employee skills required to sustain operation. In
accordance with PUCT 25.53.(e).(2).(D) the Influenza Pandemic Plan is included in this
section.
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SMP-20 Influenza Pandemic Response Plan
Rev Issue Date Last Review Date

R3 11 Oct 19 24 May 2021
TABLE OF CONTENTS
SECTION TITLE PAGE

1. Introduction ........................................................................................................... 84
A. Pandemic Characteristics ............................................................................. 84
B. Pandemic Phases ........................................................................................ 85
2. Planning Responsibilities ....................................................................................... 86
A. Corporate Responsibilities ........................................................................... 86
B. Employee Responsibilities ........................................................................... 87
3. Pandemic Response Plan Development ............................................................... 87
A. Business Processes Assessment ................................................................. 88
B. Pandemic Risks Assessment ....................................................................... 88
C. Loss of Key Personnel ................................................................................. 89
D. Employee Critical Skills Inventory ................................................................ 90
E. Information Systems (IS) Inventory .............................................................. 91
4. Threat Mitigation - General Guidelines .................................................................. 92
5. Mitigation Strategies .............................................................................................. 93
TABLES
Table 1. Major Business Functions .................................................................................. 88
Table 2. Largest Risks ..................................................................................................... 88
Table 3. Recovery Strategies .......................................................................................... 89
Table 4. Key Personnel and Critical Functions ................................................................ 89
Table 5. Critical Skill Inventory ........................................................................................ 90
Table 6. Work Recovery Time ......................................................................................... 91
Table 7. Information Systems (IS) Recovery Strategies................................................... 91
Table 8. Detailed IS Recovery Strategies ........................................................................ 92
APPENDICES
Appendix A: Matrix of Major Risks and Mitigations ......................................................... 97
Appendix B: Critical Equipment and Materials ................................................................ 99
Appendix C: Vital Records Access and Storage ........................................................... 100
Appendix D: Plant-Specific Manuals and Procedural Instructions ................................. 101
Appendix E: Employee Contact List .............................................................................. 102
Appendix F: Emergency Contacts List .......................................................................... 104
Appendix G: Emergency Information Resources ........................................................... 105
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REFERENCES
1. The information in this Pandemic Response Plan was primarily obtained from:
Center for Infectious Disease Research and Policy, University of Minnesota
http://www.codrap.umn.edu/
North American Electric Reliability Council
http://www.nerc.com
United States Center for Disease Control
http://www.cdc.gov/flu/avian/index.htm
2 Other websites with useful pandemic information:

http://www.pandemicflu.gov/ - U.S. Government Public Information Site
http://www.who.int/topics/influenza/en/ - World Health Organization Site
http://www.pandemicflu.gove/plan/businesschecklist.html - DHS site (U.S.)
http://www.phac-aspc.gc.ca/influenza - Public Health Agency of Canada
SUB-SECTIONS
None

R0 11 Oct 19 Issued R0
R1 12 Mar 20 Updated skill set and contact list with new employees
R2 9 Sep 20 Removed Mark Williamson from skill set list
R3 24 May Updated I&C and Op Tech contacts, Updated Operation Supervisor &
21 Plt Manager Contact Info
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• INTRODUCTION
The objective of this Safety Manual Procedure is to describe potential pandemic

threats, to identify and prioritize the critical operations and business functions of this
facility, and to provide appropriate response guidelines. The information in this Plan
is based on generally accepted assumptions about the development, outbreak, and
expected progress of an influenza pandemic. Site-specific information required for
implementing this Plan (contact lists, recovery details, etc) is provided in Appendices
A through G at the end of this Procedure. Control and survival of a pandemic will
depend on the ability of thoughtful individuals to conduct a well-planned and well
organized response. The ultimate objective of this Plan is to prepare those individuals
for success.
O PANDEMIC CHARACTERISTICS
• Timing and severity of the outbreak of a pandemic are uncertain and

may not be immediately recognized. The most feared pandemic strains
(such as avian influenza or “bird flu”, H5N1) exhibit the following
characteristics:
o Able to cause severe disease in humans
o Global human population has no pre-existing immunity
o Able to spread rapidly through human-to-human contact
• Once human to human transmission begins, the disease will spread

very rapidly around the world within three to eight weeks. It is likely that
20 to 30 percent of global population will contract influenza during the
first wave and will become very ill for several weeks. Additional waves
will follow over one to two weeks.
• Absentee rates for employees may be in the range of 25 to 60 percent

for the duration of the pandemic, due to employee illness and to other
factors such as caring for family members. Absentee rates will normally
vary across an organization based on location and isolation.
• With the expected high percentage of ill people, the existing healthcare
system will be overwhelmed. Most government and health
organizations will not have sufficient stockpiles of anti-viral agents or
vaccines to treat those who are exposed or who will become ill if a
pandemic occurs in the next one to two years.
• Persons who contract the virus are not expected to contract it a second
time due to a buildup of personal immunity. However, if the virus
mutates, recurrences for the same individuals could be possible.
• Personnel management will need to be modified to continue essential

plant operations and business processes, while minimizing the spread
of the virus.
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• The organizational response will need to include the distribution of

accurate and timely information to employees, families, and customers.
• Because of the percentage of affected people around the world, global

trade and the global economy will be significantly impacted by the
pandemic, limiting the supplies of food and manufactured goods.
• Other cross dependencies with other segments of the utility sector

(generators, transmission operators, distribution providers) and other
critical infrastructure (communications, nuclear, natural gas, petroleum,
transportation, emergency services, etc) as well as contractors and
suppliers will be severely tested during influenza pandemic.
O PANDEMIC PHASES
Information developed by the World Health Organization (WHO) defines five

phases of a possible pandemic as listed below. These five phases provide a
useful framework for pandemic response planning.
• Phase 1 -- Pandemic Alert
Governments, owners, and operators are notified that a pandemic is

possible and preparedness plans should be reviewed and updated.
• Phase 2 -- Pre-Pandemic
Localized outbreaks are occurring with human-to-human transmission.

Governments and electricity sector entities begin to assign resources,
prepare staffing, and implement contingency plans. Begin an
information distribution program to promote appropriate responses by
employees.
• Phase 3 -- Pandemic Outbreak
General outbreaks across borders and continents. Organizations

implement response plans.
• Phase 4 -- Maximum Disruption
High absentee rates occur, and fatalities begin to impact the workforce.
This phase could last for several months.
• Phase 5 -- Prolonged Recovery
Recovery will be slow, and the underlying economy will weaken.

Altered business conditions will be prevalent for large and small firms.
This phase will last for at least three months and possibly up to six
months.
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• PLANNING RESPONSIBILITIES
The diagram below is the organization chart for the NAES Pandemic Management
Program Team (PMPT) for this facility. The PMPT task force is responsible for the
preparation, the continuing readiness, and (if needed) the implementation of this Plan.
O CORPORATE RESPONSIBILITIES
• Plan Development
o Recognize threat and authorize a planning and response effort
o Identify critical departments needing response plans
o Require preparation of approved Pandemic Response Plans
o Provide schedule for preparation of Plans
o Request draft policy changes needed for pandemic

management
o Adjust strategy and response level as needed
• PMPT Inputs
o Pandemic threat and impact information
o Program coordination
o Initiation criteria
o Threat monitoring updates

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o Department pandemic management plan templates and

coaching
o Coordination with support departments (Human Resources,

Information Services, etc)
• NAES Headquarters Inputs
o General pandemic information (issues, impacts, mitigation

strategies, pandemic management, suggested plan outline)
o Guidance and coaching
o Plan templates
o Family care outline and websites
• Plant Staff Responsibilities
o Brainstorm critical business functions and priorities
o Determine locally appropriate mitigations
o Prepare and test draft Pandemic Response Plans
o Assist employees with family care plans
o Manage work continuation if a pandemic strikes
o If NAES corporate management is not available, plant

managers shall take control
O EMPLOYEE RESPONSIBILITIES
• Perform critical department work if a pandemic strikes
• If management is not available, senior personnel will provide leadership
• Remain individually healthy by following guidelines
• Review family care outlines and websites; prepare a family response

plan and discuss with family members
• Stockpile essential supplies
• PANDEMIC RESPONSE PLAN DEVELOPMENT
This section will provide guidelines for corporate departmental planning to meet the
challenges of an influenza pandemic. Various charts and tables are provided
throughout this section for planners to use during these assessment processes.
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O BUSINESS PROCESSES ASSESSMENT
In planning for a potential Pandemic, it is important to identify the major

business processes in the organization. It is also important to determine the
critical inputs that are needed to accomplish those processes. Other
departments in the company may depend on some of your organization’s
output to do their work. The most important outputs should also be defined.
As you identify critical inputs and outputs, consult with upstream and
downstream organizations. They may have priorities that are different from
your own and negotiation with them may be necessary. Critical information
should include Contact Lists, Vendor Lists, etc. To set the Priority Ranking, #1
is for most important, and #5 is for least. For example, the critical business
functions needed for the business to survive should be in the #1 category.
The following “Major Business Functions” assessment chart is recommended

as a starting point for the NAES Pandemic Management process. Several
follow-up assessment charts are shown on the ensuing pages.
Major Business Functions
Major Business Priority Critical Inputs

Processes Ranking and Outputs
O PANDEMIC RISKS ASSESSMENT
Once the major business processes have been identified, it will be important
to determine what the largest risks to those functions are. What problems
would be caused by loss of key staff inside or outside of the company (loss of
key department personnel, loss of vendors, bankruptcy of a large customer,
stock market crash, late or no payments, inability to communicate with other
businesses, failure of service providers, etc. Once these largest risks are
determined, appropriate mitigation strategies can be established.
Largest Risks
Major Business Largest Risk Priority of

Processes (Internal & External) Risk
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Major Business Largest Risk Priority of

Processes (Internal & External) Risk
O LOSS OF KEY PERSONNEL
• For Influenza Pandemic Only
This case differs from the normal Business Continuity case because all
the supporting departments and vendors that the department might call
upon in an emergency will also be having a personnel shortage. This
means many more vendors will be needed, more work must be
cancelled or postponed, and more drastic measures to protect the
remaining employees must be taken.
Recovery Strategies
• Major Business • Recovery Strategies

Processes
• For Influenza Pandemic with Emergency Succession
In the following table, identify key persons doing critical work for each
major business function. These key people are those persons without
whom, the Major Business Function could not be done. This might be
a senior department employee, group leader or supervisor.
After naming the current key personnel, enter the name(s) of the
person(s) that could take over the work in an emergency where the
current key person is not available. In other words, this table is an
emergency succession plan for the work that is most important to the
company.
Key Personnel and Critical Functions
Major Business Key Person(s) & Emergency Alternate(s)

Processes for Organizational Assignments
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Major Business Key Person(s) & Emergency Alternate(s)

Processes for Organizational Assignments
O EMPLOYEE CRITICAL SKILLS INVENTORY
Use the table below to list your personnel who have skills in high demand
critical areas that could fill in for others in an emergency. The table lists some
typical skill sets for plant operations but should be modified as needed for the
skill set categories that suit your department’s needs.
Critical Skills Inventory
List of Critical Skill Sets

Employee Mechanical Electrical Plant Other
Names CRO APO Warehouse
Skills Skills DCS PLC
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Critical Skill Inventory
O INFORMATION SYSTEMS (IS) INVENTORY
• Critical Systems
Use the table below to list the critical Information Systems and IS
Applications which are essential to the most important work done in the
department. The following acronyms used in this table are defined as:
o RTO (Recovery Time Objective) - The period of time within

which systems, applications, or functions must be recovered
after an outage.
o WRT (Work Recovery Time) - The period of time needed to

complete the disrupted work on a recovered/repaired resource
in order to return it to normal operational status.
Work Recovery Time
Critical Critical Critical IT Systems RTO WRT

Business Business and Applications
Functions Processes
• Loss of Software, Hardware or Data Assets
Use the table below to help list hardware loss strategy. In the event
that your critical IT Systems and Applications are not available, what is
your strategy to continue work? Would you use a simple Excel
spreadsheet to record and manipulate data until the main application
was restored? Would you use another application that could do some
of the important functions? Is there an old or newer program that would
work? Would you cease work? Are there any other relevant questions?
Information Systems (IS) Recovery Strategies

Major Business Loss of
Emergency Software Recovery Strategies
Functions Systems
• Recovery of Lost Software, Hardware, or Data Assets

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Assume that the loss of Software, Hardware or Data Assets scenario

has occurred and the recovery team has been activated. The general
strategy from the previous sections applies but more detail is needed
to describe the steps that would be taken.
In the following table, replace the example by listing the detailed tasks
that must be initiated and indicating which member(s) of the recovery
team (e.g., team leader, team member, or names of individuals) will
perform it.
Detailed current backups of the following software and systems are

maintained on file in a fireproof cabinet in an area separate from the
main control area:
Detailed IS Recovery Strategies
Major Equipment Contact

N/A
• Pandemic Plan Validation
Identify the known gaps, issues and problems with this Pandemic Plan
that would make it difficult to succeed, contribute to its failure or make
the recovery from a significant event slower and less efficient. Identify
the expected time frame to eliminate these problem areas. If an
economic, time related, organizational or technical issue is causing the
gap, include the description of this cause. Describe the gaps in order
of importance, with the most important one listed first.
• Qualified CROs
o Long term action is to get APOs sufficiently trained and qualified

to fill in as CROs.
o Cross training of plant personnel is required for better flexibility.
• Limited Vendor Resources
o Resources critically tied to interstate transportation. These

include lime, soda ash, hydrogen, caustic, acid, and ammonia.
o Some staff may not be from the local area. This makes
alternate transportation more difficult and timely relief for ill
personnel may not be readily available.
• THREAT MITIGATION - GENERAL GUIDELINES
The purpose of a Pandemic Management Program is to assist NAES plant

management in preparing for a potential pandemic by developing plans to manage the
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threat. The actions listed below could be taken by all departments to help them
minimize the impact if the pandemic threat becomes real.
• Review existing emergency plans. Update these and inform essential

personnel.
• Update the contact list of all employees in your department. Include after-hours
contact number(s); some of these phone numbers may be out of this region,
such as parents, or other family members or friends.
• Identify employees and key customers with special needs and incorporate the
requirements of such persons into your preparedness plan.
• Consider the impact of community containment measures and quarantines,

school and/or business closures, and public and financial institution closures.
• Expand the use of teleconferencing and videoconferencing to limit the

frequency of meetings and other types of face-to-face contact.
• Implement guidelines to modify the frequency and type of face-to-face contact

(e.g. handshaking, seating in meetings, shared workstations) among
employees and between employees and customers.
• Train and prepare ancillary workforce (e.g. contractors, employees in other

jobs or other departments, retirees, etc).
• Develop cross training programs to assure adequate staffing of essential

functions; consider strategies such as developing “job sheets” that outline key
activities by position.
• Consider a transportation plan in case of fuel shortages and loss of public

transportation.
• Develop a plan to send home non-critical staff and shift workers to home offices
or other sites or change work hours that would minimize exposure risks,
address potential fuel shortages, and curtail dependence on public
transportation.
• If services are contracted to outside organizations, contact vendors and find

what type of contingency plans they may have in place.
• Consider the impact of a disruption of social systems and services on your

organization (assume the possibility of no response or slow response from
emergency first responders, other basic services not available, etc.)
• MITIGATION STRATEGIES
There are several possible risks and mitigations to be considered when planning your
strategies. Appendix A contains a listing of the most common risks and the associated
mitigations. Each specific facility or department may have more or different risks than
those listed in Appendix A.
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• Protect Work Force
o Protect the workers that you have.
o Provide the personal protective equipment that may be needed.
o Minimize meetings and face to face contact.
o Wherever possible, get priority medical treatment arranged.
o Provide essential medical training for on-site emergencies.
o Gather essential health and protective equipment.
o Gather the contact phone numbers for your employees and their “out
of area” contact numbers.
o Be prepared to have an alternative way to transport essential

employees to work or locations where they can work.
o Consider the impact of civil unrest and a breakdown in social order if

police, fire and other personnel are not available. How will your protect
your work site and employees?
o Should you be prepared for some employees to live on the work site for
several days or weeks?
• Help Employees Protect Their Families
o Provide information so employees can protect their families and can

feel free to work.
o Provided the personal protective equipment that may be needed.
o Counsel employees that need help coping with illness or losses.
• Augment the Work Force
o Broaden the vendor base in type and geographic area.
o Gather the contact phone numbers for your vendors and their after-
hours contact numbers.
o Ask that your most critical vendors also have and carry out Pandemic
Planning and Mitigation.
o Ask to see their plans and be briefed on them.
o Identify groups of additional workers from other departments, retirees,

employment agencies, etc. The lists should be long and geographically
diverse.
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• Protect Work Processes
o Be prepared to alter your work process and use alternative methods.

Your normal software may become disabled due to routine failure and
there may not be personnel to get it repaired. Your software or
application recovery may not be on a high priority list.
o Cross train your personnel to be more generalists rather than

specialists so they can support and stand in for each other.
o Is it possible for vendors to help with more routine work or to outsource

the some of the work?
o Buy, write or update procedure or instruction manuals so that a broader

segment of the department could do the work. Train the work force on
these procedures.
o Maintain essential data on backup CD-ROMs or other sources. Make

sure several people know how to access this data.
o Move some processes away from “just in time” methods. The “just in
time” processes might collapse when critical materials or data are not
available. Some stockpiling or source diversification may be
necessary.
o How will you work if the city or state is broken up into quarantined
areas?
o Have a current and workable succession plan.
• Stockpile Resources
o Stockpile critical materials (parts, supplies, protective equipment,

routine but necessary supplies, fuel, etc.)
o Consider alternative transportation methods to get workers to and from

work.
o Consider storing bottled water, canned goods, and emergency meals.

Include flashlights, batteries, radios, masks, disposable gloves, soaps
and disinfectants.
• Reduce Non-essential Work
o Each department should identify its most critical business functions and
the overall mitigation strategies for them. Determine what lower priority
work to cut.
o Each department should determine its essential inputs needed for its
work and the critical outputs that others need for their work.
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o Reduce work to the most important tasks.
o Reduce personal contact and make essential contact safer.
o Have people work from home where possible.
o Reduce or “sanitize” customer contact.
o Teach proper hand washing, use of sanitizing wipes, use of disinfectant

soaps, proper use of effective masks and gloves and other personal
protective measures.
o Teach people how to handle potentially contaminated material from

other people.
• Develop Communication Plans
o What are the essential information data and messages that need to
reach employees, vendors, their families, customers and the public.
o What is the structure of these messages, what is the likely content that
is needed?
o Develop specific, honest, timely and helpful messages that give the
whole, unvarnished truth. Have these messages available and ready
to fill in the blanks.
o Have enough people to do the information gathering and to do the

communication.
o Test the messages on people outside of the communications

department. Are the messages clear and do they give the intended
information?
o What alternative ways will the company use to communicate if normal

services are not available? Can Webcasts, internet sites, phone
recordings, or other sources be of help?
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Matrix of Major Risks and Mitigations
Description of Major Recommended Mitigation Options

Risks/Problems
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Description of Major Recommended Mitigation Options

Risks/Problems
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Critical Equipment and Materials
Needed
Equipment Intended Equipment Recovery Rebuild
Upgrades or
& Materials Users Supplier Quantity Quantity
Special Features
COMMENTS:
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Vital Records Access and Storage
• Media Types: E – Electronic, P – Paper, M – Microfilm/fiche
Associated Vital
Key Business Media Type Vital Record Storage
Records Required for
Process (E/P/M) Locations and Access
Process
COMMENTS:
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Plant-Specific Manuals and Procedural Instructions
• Media Types: E – Electronic, P – Paper, M – Microfilm/fiche
Title of Manual or Storage Media Type Quantity

Description
Procedure Location (E/P/M) Available
COMMENTS:
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Employee Contact List
Name Radio Position Ext Email Cell
Management
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Name Radio Position Ext Email Cell

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Emergency Contacts List
Emergency Business Street Address

Organization Comments
Telephone Telephone or Website
• PUBLIC SAFETY SERVICES
Local/City Fire Available

911
Department 24 x 7
Local/City Police Available

911
Department 24 x 7
Available
County Sheriff’s Office 911
24 x 7
Available
State Police Office 911
24 x 7
Local Emergency Available

Operations Center 24 x 7
Available
American Red Cross (800) 733-2761 http://www.redcross.org/
24 x 7
National Poison Control Available

(800) 222-1222
Center 24 x 7
Local Hospital
Emergency Room
Local Hospital
Emergency Room
• EMERGENCY BUSINESS SERVICES

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Emergency Information Resources
Emergency Business Street Address

Organization Comment
Telephone Telephone or Website
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6.0e. Hurricane– PUCT 25.53.(e).(2).(E)

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Hurricane Action Plan
Revision Description Revised by Reviewed by Approved by Date

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CONTENTS
1.0 Purpose and Scope

2.0 Definitions and References
3.0 Responsibility
3.1 Plant Manager
3.2 Management Team
4.0 Hurricane Plan
4.1 Hurricane Plan
4.2 Hurricane Warning
4.3 Hurricane
4.4 Hurricane Recovery
5.0 Key Contact
6.0 Quality Records
7.0 Attachments
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1.0 PURPOSE AND SCOPE
1.1 Purpose
The hurricane action plan is to be used as a guideline to prepare Power facilities for
hurricane or near-hurricane conditions. These guidelines are not intended to cover all
possible specific problems that may arise. Although some basic procedures must be
followed, it is up to the operator to familiarize him or her with the characteristics of this
guideline. Because conditions may develop that will require diverging from these
guidelines, plant management must use sound judgment in all phases of operation during
hurricane or near-hurricane conditions.
1.2 Scope
This guideline applies at all Power facilities, employees, and supplemental staff.
2.0 DEFINITIONS AND REFERENCES
2.1 Definitions
hurricane warning – an announcement that sustained winds of 74 mph or higher are

expected in a specified coastal area within 24 hours.
hurricane watch – an announcement that hurricane conditions pose a possible threat to a

specified coastal area within 36 hours.
2.2 References
None.
3.0 RESPONSIBILITY
3.1 Plant Manager
The plant manager has primary responsibility for implementation and direction of the
hurricane response and will coordinate communication between Power and other
appropriate parties.
3.2 Management Team
When instructed by the plant manager, the management team will implement the hurricane
action plan.
4.0 HURRICANE PLAN
The hurricane action plan is to be used as an operating guideline to help prepare for
hurricane and near-hurricane conditions. Plant management should continuously monitor a
storm’s location, strength, and possible landfall location.
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4.1 Hurricane Watch
Emergency authorities may issue a hurricane watch 36 to 48 hours in advance of

anticipated landfall. If a hurricane watch may be declared during normal off-duty working
hours such as holidays or weekends, the plant manager will review the hurricane action
plan and initiate procedures that will facilitate an orderly transition to the hurricane watch
status when it is declared.
4.1.1 Initial Preparations
The following table presents detailed activities that should be completed during the
hurricane watch phase. The party typically responsible for the action is also presented;
however, the plant manager or designee may assign the responsibility to another party as
needed.
Action Responsible Completed

party (initials)
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party (initials)
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party (initials)
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party (initials)
4.1.2 Sustained Winds of 35 mph or Greater
During a hurricane watch, when sustained winds reach 35 mi/h or greater for a significant
period of time, take the following actions:

party (initials)
4.2 Hurricane Warning
Although emergency authorities try to give more warning, they may issue a hurricane
warning less than 24 hours prior to the hurricane’s landfall.
4.2.1 Final Preparations
When authorities issue a hurricane warning, ensure the actions detailed below are
completed 24 hours before the expected arrival of hurricane force winds. For storms rated
category 3 or higher, see 4.3.2, Category 3 or Higher.

(initials)
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party (initials)
4.2.1.1 Safe Parking
The keys shall be left in all parked company vehicles to ensure accessibility when needed.
The safe parking is designated as the following:
Vehicle Location Responsibility

Pickup trucks Parked at the Operations team leader
warehouse or in shop
area
Small trailers Parked in the Operations team leader

warehouse
Employee vehicles Employees may park

their vehicles in other
areas of the facility
as directed by plant
management.
4.3 Hurricane
See attachment B, Hurricane Categories, for wind speed and typical damage.
4.3.1 Category 1 and 2 Storms

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1. During category 1 and 2 hurricanes, plant loads will be adjusted as directed by

the load dispatcher. If the system sustains damage, the units may be shut down if deemed
appropriate by the plant manager to ensure personnel safety and to protect the facility.
2. Operations will proceed as required to protect plant equipment from damage.
3. In the event of loss of all communications, plants will operate as previously

agreed with the load dispatchers.
4. All doors should remain unlocked to allow access in an emergency.
5. The administration building is not rated for winds greater than 110 mi/h. Plant
employees should be evacuated to a safe refuge area prior to 110 mi/h winds.
4.3.2 Category 3 or Higher Storms
In the event of a hurricane rated category 3 or higher, the units may be shut down if
deemed appropriate by the plant manager to ensure personnel safety and to protect the
facility.
4.4 Hurricane Recovery
1. After storm passage, assess damage to plant and equipment as quickly as

possible, and report to Power and joint owner management. Estimates of repair
requirements and assistance beyond the capabilities of plant personnel shall be a part of
this report.
2. Advise the load dispatchers concerning the availability of units and estimated
availability of damaged units.
3. Units will be loaded as directed as system recovery proceeds.
5.0 KEY CONTACT
EMERGENCY NOTIFICATIONS
P a g e | 116
Emergency Phone Numbers

911 From any Plant Phone
6.0 QUALITY RECORDS
None.
7.0 ATTACHMENTS
Attachment A, Hurricane Supplies.

Attachment B, Hurricane Categories.
Attachment C, Hurricane Team.
Attachment A - Hurricane Supplies
The following table presents a list of suggested supplies to be kept on site for distribution in
the hurricane warning stage.
Material Quantity
P a g e | 117
The supplies should remain boxed, separated, and labeled as to contents and the area the
supplies are to be issued. All materials unused should be returned after the hurricane
danger has passed.
Attachment B - Hurricane Categories
Category Wind Speed Damage

Category 1 74 to 95 mi/h No real damage to building structures.
Damage primarily to unanchored mobile
homes, shrubbery, and trees. Also, some
coastal flooding and minor pier damage.
Category 2 96 to 110 mi/h Some roofing material, door, and window

damage. Considerable damage to
vegetation, mobile homes, etc. Flooding
damages piers, and small craft in
unprotected moorings may break their
moorings.
Category 3 110 to 130 mi/h Some structural damage to small

residences and utility buildings, with a
minor amount of curtainwall failures.
Mobile homes are destroyed. Flooding
near the coast destroys smaller structures
P a g e | 118
with larger structures damaged by floating

debris. Terrain may be flooded well inland.
Category 4 131 to 155 mi/h More extensive curtain wall failures with
some complete roof structure failure on
small residences. Major erosion of beach
areas. Terrain may be flooded well inland.
Category 5 155+ mi/h Complete roof failure on many residences

and industrial buildings. Some complete
building failures with small utility buildings
blown over or away. Flooding causes
major damage to lower floors of all
structures near the shoreline. Massive
evacuation of residential areas may be
required.
Attachment C - Hurricane Team
The following table is a list of suggested plant staffing during a hurricane.
Hurricane Team
Department Suggested personnel
P a g e | 119
6.0f. Cyber Security– PUCT 25.53.(e).(2).(F)
In accordance with PUCT 25.53.(e).(2).(F) the Cyber Security Policy is included in this
section.
P a g e | 120
RCP-NERC-CIP-003-ATT-A
NACOGDOCHES GENERATING FACILITY - CUSHING,
TX
Referencing Documents: Revision: Rev 2
NERC-RCP-CIP-003 R1.2 Revision Date: September 11, 2021
CYBER SECURITY POLICY
1. INTRODUCTION .............................................................................................................................................. 121

A. PURPOSE .................................................................................................................................................... 121
B. SCOPE ......................................................................................................................................................... 121
C. DEFINITIONS AND DEFINED TERMS ........................................................................................................ 121
2. POLICY STATEMENTS ................................................................................................................................... 121
A. GENERAL ..................................................................................................................................................... 121
B. VIOLATION of POLICY ................................................................................................................................ 121
C. CYBER SECURITY AWARENESS (ATT 1, section 1) ................................................................................ 122
D. PHYSICAL SECURITY CONTROLS (ATT 1, section 2) .............................................................................. 122
E. ELECTRONIC ACCESS CONTROLS (att 1, Section 3) .............................................................................. 122
F. CYBER SECURITY INCIDENT RESPONSE (ATT 1, section 4) ................................................................. 123
G. TRANSIENT CYBER ASSET AND REMOVABLE MEDIA (section 5) ......................................................... 124
H. DECLARING AND RESPONDING TO CIP EXCEPTIONAL CIRCUMSTANCES ....................................... 124
3. REVIEW ............................................................................................................................................................ 125
4. Policy Responsibility ......................................................................................................................................... 125
P a g e | 121
1. INTRODUCTION
A. PURPOSE
The purpose of this document is to specify consistent and sustainable security

policies that establish responsibility and accountability to protect
B. SCOPE
CIP-003 R1.2 applies to Nacogdoches Generating Facility as an entity with

Low Impact BES Cyber Systems which may have External Routable
Connectivity and Electronic Access Point Cyber Assets.
C. DEFINITIONS AND DEFINED TERMS
Capitalized terms included in this policy statement are defined in the NERC
Glossary of Terms Used in NERC Reliability Standards, which is periodically
updated, or are listed below in this section as Nacogdoches Generating
Facility specific terms. The most current version of the Glossary can be
accessed by clicking the following link:
http://www.nerc.com/pa/Stand/Glossary of Terms/Glossary_of_Terms.pdf
2. POLICY STATEMENTS
A. GENERAL
Low Impact BES Cyber Security configurations, plans, programs, processes

and procedures shall comply with all existing policies and standards as well
as the NERC Reliability Standards CIP-002 & CIP-003 (i.e. “the Standards”).
Where there is a conflict, the NERC Reliability Standards shall prevail.
shall have a documented “CIP Senior Manager” responsible for ensuring the
organization is meeting the requirements of the Standards and of this Policy.
The CIP Senior Manager shall be appointed in accordance with CIP-003 R3.
Where reviews and approvals are required, the CIP Senior Manager or
delegate(s) shall determine the appropriate level of management if not
specified in the Standards.
B. VIOLATION OF POLICY
P a g e | 122
C. CYBER SECURITY AWARENESS (ATT 1, SECTION 1)
Cyber Security practices shall be reinforced at least once every 15 calendar

months (which may include associated physical security practices).
Reinforcement may occur through direct or indirect communications such as
emails, system wide publications, intranet postings and at various meetings
and training modules. The evidence could be documentation through one or
more of the following methods:
1. Direct communications (for example, e-mails, memos, or

computer-based training);
2. Indirect communications (for example, posters, intranet, or

brochures); or
3. Management support and reinforcement (for example,

presentations or meetings).
Nacogdoches Generating Facility shall ensure that any employee, contractor,

or vendor, who has a need for physical and/or electronic access to a Low
Impact BES Cyber System be subject to the Cyber Security Awareness
Program.
D. PHYSICAL SECURITY CONTROLS (ATT 1, SECTION 2)
E. ELECTRONIC ACCESS CONTROLS (ATT 1, SECTION 3)
1.
2.
P a g e | 123
3. not used for time-sensitive protection or control functions

between intelligent electronic devices (e.g., communications
using protocol IEC TR-61850-90-5 R-GOOSE).
F. CYBER SECURITY INCIDENT RESPONSE (ATT 1, SECTION 4)
shall have one or more Cyber Security Incident response plan(s), either by
asset or group of assets, which shall include:
1. Identification, classification, and response to Cyber Security

Incidents;
2. Determination of whether an identified Cyber Security Incident

is a Reportable Cyber Security Incident and subsequent
notification to the Electricity Information Sharing and Analysis
Center (E-ISAC), unless prohibited by law;
3. Identification of the roles and responsibilities for Cyber Security

Incident response by groups or individuals;
4. Incident handling for Cyber Security Incidents;
5. Testing the Cyber Security Incident response plan(s) at least

once every 36 calendar months by:
a. responding to an actual Reportable Cyber Security

Incident;
b. using a drill or tabletop exercise of a Reportable Cyber

Security Incident; or
c. using an operational exercise of a Reportable Cyber

Security Incident; and
6. Updating the Cyber Security Incident response plan(s), if

needed, within 180 calendar days after completion of a Cyber
Security Incident response plan(s) test or actual Reportable
Cyber Security Incident. shall invoke its Cyber Security
Incident Response Plan to rapidly detect incidents to minimize
loss and destruction, mitigate exploited weaknesses, restore
P a g e | 124
computing services, and identify and report Cyber Security

Incidents to the Electricity Information Sharing and Analysis
Center (E-ISAC), unless prohibited by law.
G. TRANSIENT CYBER ASSET AND REMOVABLE MEDIA (SECTION

5)
shall maintain processes for appropriate use of Transient Cyber Assets

(TCAs) and Removable Media to prevent unauthorized access or malware
propagation to BCSs; and prevent unauthorized access to BCS Information.
All TCAs managed by shall require use and documentation of one or more of
the following safeguards in an ongoing or on-demand manner per TCA
capability:
1. Antivirus software, including manual or managed updates of

signatures or patterns.
2. Application whitelisting; or
3. Other method(s) to mitigate the introduction of malicious code.
All TCAs not managed by shall use of one or more of the following safeguards
which must be documented and reviewed by the System Administrator prior
to allowing connection of the TCA to a BCS:
1. Antivirus update level.
2. Antivirus update process used.
3. Application whitelisting.
4. Use of live operating system and software executable only

from read-only media.
5. System hardening used.
6. Other method(s) to mitigate the introduction of malicious code.
3.
shall require documentation and use of method(s) to detect malicious code
on Removable Media using a Cyber Asset other than a BCS; and
documentation and mitigation of the threat of detected malicious code on the
Removable Media prior to connecting Removable Media to a BES Cyber
System.
A. DECLARING AND RESPONDING TO CIP EXCEPTIONAL

CIRCUMSTANCES
CIP Senior Manager or delegate shall have the authority to declare CIP
Exceptional Circumstances when it cannot conform to this Policy.
P a g e | 125
shall document an explanation as to why the exception is necessary and any

compensating measures authorized by the CIP Senior Manager or delegate.
4. REVIEW
This policy shall be updated as needed or when the Standards addressed by this
policy are modified.
5. POLICY RESPONSIBILITY
P a g e | 126
Latest Revision Approval:

Written By: NAES Corp Date: 2/15/2019
Approved By: William White Date: September 11, 2021
REVISION HISTORY LOG

RCP-NERC-CIP-003-ATT-A
By Approval
Rev. Date Description
Initials Initials
June 17, Revised to make policy statements supportive
0 MJS JNB
2019 of CIP-003-7 implementation.
1 3/1/2020 Updated for 15-Month Review and Approval NAES JNB
2 9/11/2021 Updated for 15-Month Review and Approval NAES WEW
3
P a g e | 127
6.0g. Physical Security Incident– PUCT 25.53.(e).(2).(G)
In accordance with PUCT 25.53.(e).(2).(G) the Physical Security Controls is included in

this section.
P a g e | 128
RCP-NERC-CIP-003-ATT-C
NACOGDOCHES GENERATING FACILITY - CUSHING, TX
Referencing Documents: Revision: Rev 0
RCP-NERC-CIP-003 R2 Revision Date: June 17, 2019
PHYSICAL SECURITY CONTROLS

1. INTRODUCTION .................................................................................................. 129
A. PURPOSE................................................................................................... 129
B. SCOPE ....................................................................................................... 129
C. DEFINED TERMS ....................................................................................... 129
2. COntrolling PHYSICAL ACCESS.......................................................................... 129
A. PHYSICAL ACCESS CONTROLS & MONITORING ................................... 129
B. PROCEDURES FOR GRANTING AND REVOKING PHYSICAL ACCESS . 130
3. INTERNAL CONTROLS/Evidence........................................................................ 131
4. REVIEWS and UPDATES .................................................................................... 131
5. PROGRAM RESPONSIBILITY ............................................................................. 131
P a g e | 129
11. INTRODUCTION
A. PURPOSE
This document defines Nacogdoches Generating Facility’s Physical Security

Controls program.
B. SCOPE
C. DEFINED TERMS
Capitalized terms included in this policy statement are defined in the NERC
Glossary of Terms Used in NERC Reliability Standards, which is periodically
updated, or are listed below in this section as Nacogdoches Generating
Facility specific terms. The most current version of the Glossary can be
accessed by clicking the following link:
http://www.nerc.com/pa/Stand/Glossary of Terms/Glossary_of_Terms.pdf
12. CONTROLLING PHYSICAL ACCESS
A. PHYSICAL ACCESS CONTROLS & MONITORING
1.
2.
3.
4.
P a g e | 130
1.
2.
3.
4.
B. PROCEDURES FOR GRANTING AND REVOKING PHYSICAL ACCESS
Granting Access
Identified Roles Requiring Access:
1.
2.
3.
4.
5.
6.
7.
Temporary Access
Other positions as dictated by plant needs may include:

1.
2.
P a g e | 131
Revoking Access
All access shall be revoked as soon as practical when it is determined that

access is no longer required. Possible methods to remove access include:
1.
2.
3.
4.
13. INTERNAL CONTROLS/EVIDENCE
has implemented the following, additional physical security controls:
Quarterly reviews and documentation to validate business need, and employee

status of:
•
•
Other routine reviews or controls:

•
•
•
14. REVIEWS AND UPDATES
This program shall be reviewed and updated as needed and upon the approval of any
new versions of the CIP Standards.
15. PROGRAM RESPONSIBILITY

P a g e | 132
Latest Revision Approval: (Revision History)

Written By: NAES Corp Date: 2/15/2019
Approved By: Joseph Bennett Date: June 17, 2019
REVISION HISTORY LOG

RCP-NERC-CIP-003-ATT-C
By Approval
Rev. Date Description
Initials Initials
0 June 17, Updated for CIP-003-7 and added Internal MJS JNB
2019 Controls Section
3
P a g e | 133
6.0h. Communication– PUCT 25.53.(e).(2).(H)
In accordance with PUCT 25.53.(e).(2).(H) the Communications Policy and the

Community Relations Policy is included in this section.
P a g e | 134
ADMINISTRATIVE MANUAL
Number: Subject:
AMP-102 Communications
Approved for use by: Current Issue: Date:
R0 17 Oct 19
Page 1 of 146 Prepared by NAES Corporation
TABLE OF CONTENTS
SECTION TITLE PAGE

1. Purpose ............................................................................................................. 136
2. Communications with Outside Organizations .................................................... 136
3. Communications with Headquarters .................................................................. 136
4. Company Records/Communication Guidelines ................................................. 136
5. Release of Corporate Information ...................................................................... 137
6. Communications among Plant Employees ........................................................ 137
7. Incoming Mail .................................................................................................... 137
8. Telephone Usage .............................................................................................. 137
9. Electronic Media ................................................................................................ 137
10. U.S. Mail and Messenger Service ..................................................................... 138
11. Office Equipment Use ....................................................................................... 139
TABLES
None
EXHIBITS
None
P a g e | 135

D1 13 Jun 19 Issued for plant review.
P a g e | 136
16. PURPOSE
The purpose of this procedure is to provide guidance on the proper means of

communications within the plant and between the plant and outside organizations
and to ensure that any release of corporate information is properly authorized and
accurate.
17. COMMUNICATIONS WITH OUTSIDE ORGANIZATIONS
All written communications between the plant and outside organizations shall be
routed through the Plant Manager. This is important to ensure that the Plant Manager
is kept aware of all business concerning the plant and to prevent plant personnel from
initiating actions independent of plant management involvement.
The Plant Manager can authorize other personnel to act as the point of contact for
particular organizations.
The point of contact for official communication to the Plant Owner’s Representative
is the Plant Manager or designee.
Any form of publicity or statement to the media made by NAES personnel shall be
approved by both the Plant Owner’s Representative and the Plant Manager.
18. COMMUNICATIONS WITH HEADQUARTERS
19. COMPANY RECORDS/COMMUNICATION GUIDELINES
Accurate and reliable records are of critical importance in meeting legal, financial,
and management obligations of the Company. Continual care is required by all
employees to insure the correctness, appropriateness, and honesty of all internal and
external records, reports and correspondence.
A.
B.
C.
D.
E.
P a g e | 137
20. RELEASE OF CORPORATE INFORMATION
A.
B.
C.
D.
21. COMMUNICATIONS AMONG PLANT EMPLOYEES
22. INCOMING MAIL
All mail addressed to the site will be opened and forwarded to the appropriate
personnel. This policy is in accordance with Federal Regulations. All employees are
responsible for ensuring that they do not solicit mail of a personal nature. Mail
received that is obviously personal in nature will not be opened.
23. TELEPHONE USAGE
The use of the phone for personal matters should be minimized. All personal calls
should be made as brief as possible. Outgoing long distance personal calls may be
billed to the employee placing the call. All employees must keep in mind that the
priorities for use of the plant phones are as follows: 1) Emergencies, 2) Plant
Business and 3) Personal Use.
24. ELECTRONIC MEDIA
This sets forth the Company's policy on access to and disclosure of electronic mail
messages sent or received by Company employees who use the electronic mail
systems and on the proper use of electronic media systems in general. This policy
may be changed at any time.
P a g e | 138
The electronic mail and other electronic media or information systems of the
Company, both internal and external (including, but not limited to, the Internet,
Intranets and e-mail), are not to be used in a way that may be disruptive, offensive to
others, derogatory in nature, defamatory toward any person or harmful to morale.
Display or transmission of sexually explicit images, messages, or cartoons, or any

transmission or use of e-mail communications that contain ethnic slurs, racial
epithets, or anything that may be construed as harassment or disparagement of
others based on their race, national origin, sex, sexual orientation, age, disability, or
religious or political beliefs is prohibited.
It is the employee's responsibility to avoid infringing on the use of copyrighted or

otherwise proprietary information. Misuse of Company resources to "hack" or cause
damage to other networks, including the Company's system, is strictly prohibited.
25. U.S. MAIL AND MESSENGER SERVICE
Not for personal use.

P a g e | 139
26. OFFICE EQUIPMENT USE
Business Only.
P a g e | 140
ADMINISTRATIVE MANUAL
Number: Subject:
AMP-103 Community Relations
Approved for use by: Current Issue: Date:
R0 17 Oct 19
Page 1 of 146 Prepared by NAES Corporation
TABLE OF CONTENTS
SECTION TITLE PAGE

1. Purpose ............................................................................................................. 141
2. Personnel Actions ............................................................................................. 141
3. Press Releases ................................................................................................. 141
4. Media Events .................................................................................................... 142
TABLES
None
EXHIBITS
None

D1 13 Jun 19 Issued for plant review.
P a g e | 141
27. PURPOSE
The purpose of this procedure is to provide guidance to plant personnel regarding

good community relations and appropriate media coverage.
Good community relations will benefit plant operation by virtue of minimizing time
spent in a defensive or adversarial relationship with community members. It can
enhance employee morale through increased company pride and community
interaction. It will benefit the community because various resources associated with
the plant can help the local community reduce costs, enhance local image, and
provide for good labor relations.
28. PERSONNEL ACTIONS
A. The Plant Manager
1.
2.
3.
B. Plant Staff
1.
2.
29. PRESS RELEASES

P a g e | 142
30. MEDIA EVENTS
The purpose of this section is to present guidelines to allow for the plant to more
easily address the media. This section was designed primarily to support an
emergency or crisis situation however portions can be used during other events. As
with Press Releases, the Owner’s Representative needs to concur with all actions for
media contact.
A. Prior to the media event
1.
2.
3.
4.
5.
B. Guidelines for the Spokesperson
The following rules of thumb are designed to assist the spokesperson more
easily address the media.
1.
2.
3.
4.
5.
6.
7.
P a g e | 143
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
C. Following the Media Event
1.
P a g e | 144
2.
3.
4.
P a g e | 145
7.0. Drills– PUCT 25.53.(f)

P a g e | 146

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What is the purpose of the Emergency Operations Plan?

What is the purpose of the Emergency Operations Plan?

What framework does Austin Energy use for emergency response?

What framework does Austin Energy use for emergency response?

Austin Energy Emergency Operations Plan

May 26, 2022

EMERGENCY OPERATIONS PLAN

Austin Energy Annexes

Executive Summary of the Emergency Operations

Austin Energy Page 1 of 4

Rule Reference Index

(c)(1)(A)(i) Executive Summary EOP-01: Executive Summary All pages

(c)(1)(A)(i)(I) Contents and Policies EOP-01: Executive Summary Pages 1-2

(c)(1)(A)(i)(II) Rule References EOP-01: Executive Summary Pages 2-4

(c)(1)(A)(ii) Complete EOP Entire document

EOP-05: Emergency Contact

(d)(1)(C) Revision Control Summary EOP-03: Record of Revisions All pages

(d)(1)(D) Current EOP Statement EOP-04: Record of Revisions All pages

(d)(1)(E) Date of Approval EOP-00: AE EOP Cover All pages

Austin Energy Page 2 of 4

(d)(2)(D) ERCOT Communications Plan Not Applicable (ERCOT only)

(d)(6) Relevant Annexes All Subsequent Sections

TD-01: AE T&D Weather

T&D Pandemic and Epidemic AE-04: AE Pandemic and

(e)(1)(H) T&D Black Start Annex Not Applicable (TDUs only)

TD-04: AE Black Start and

Austin Energy Page 3 of 4

AE-05: AE Hurricane Response

(e)(2)(H) Generation Additional Annexes No Additional Generation Annexes

(e)(3) REP Annexes Not Applicable (REPs only)

(e)(4) ERCOT Annexes Not Applicable (ERCOT only)

The record of distribution can be found in section EOP-04.

The affidavit can be found subsequently in this section, EOP-01.

Austin Energy Page 4 of 4

Introduction and Applicability

Fayette Power Project

South Texas Project

Nacogdoches Generating Facility

Austin Energy Values

Emergency Operations Plan Contents

There are four annex categories:

EOP Maintenance and Implementation

Austin Energy Page 2 of 16

Activating AE’s EOP and Incident Command System

Response to Weather-Related Hazards

Austin Energy Page 4 of 16

• Flooding – A flooding emergency may be brought on by a sudden storm, persistent rain, or

Maintaining Supplies for Emergency Response

Training and Accessibility of the EOP

Drills and Notifications

Austin Energy Page 6 of 16

Austin Energy Page 7 of 16

Austin Energy Page 9 of 16

Austin Energy Page 10 of 16

Austin Energy Page 11 of 16

Austin Energy Page 12 of 16

Austin Energy Page 13 of 16

Austin Energy Page 15 of 16

Tropical Disturbance- A moving area of thunderstorms in the tropics.

Austin Energy Page 16 of 16