ML043640238

FEMA Final Report - Tri-City Medical Center Medical Drill, San Onofre Nuclear Generating Station, Report Dated September 8, 2004

ML043640238
Person / Time
Site:	San Onofre
Issue date:	10/01/2004
From:	Armes K Federal Emergency Management Agency
To:	Mallett B Region 4 Administrator
Schneck D NSIR/DPR/EPD 415-3079
References
Download: ML043640238 (29)

Text

U.S. Department of Homeland Security I I11 Broadway, Suite 1200 Oakland. CA 946074052

-FEMA OCT - 1 2004 4 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza, Suite 400 Arlington, Texas 76011-8064

Dear Mr. Mallett:

On April 30, 2004, the U.S. Department of. Homeland& Security's Federal Emergency Management Agency (FEMA) Region IX evaluated the Tri-City Medical Center Drill for the San Onofre Nuclear Generating Station (SONGS). The purpose of this drill was to assess the level of State and local preparedness in responding to a radiological emergency.

I have enclosed a copy of the final report for your records. No issues were identified. We have determined that based on the overall results of the drill, there is reasonable assurance that appropriate measures can be taken off-site to protect the health and safety of the public in the event of a radiological emergency at SONGS. The level of preparedness and adequacy in the off-site radiological emergency response plans for the State of California and the jurisdictions site-specific to SONGS, together with the ability to implement these plans, were well demonstrated. Therefore, the Title 44 Code of Federal Regulations, Part 350 interim approval of the off-site radiological emergency response plans and preparedness for the State of California, site-specific to SONGS, will remain in effect.

If you have any questions or need additional information, please contact me at (510) 627-7100, or your staff may contact Mr. Kenneth Chin, Regional Assistance Committee Chair, at (510) 627-7122.

Sincerely, aren . Armes Acting Regional Director FEMA Region IX Enclosure cc: Ms. Vanessa Quinn, FEMA HQ Mr. Eric Weiss, NRC HQ www.fema.gov

j Final Report Tri-City Medical Center Medical Drill SAN ONOFRE NUCLEAR GENERATING STATION Licensee: Southern California Edison Company Drill Date: April 30,2004 Report Date: September 8, 2004 FEDERAL EMERGENCY MANAGEMENT AGENCY REGION IX 1111 Broadway, Suite 1200 Oakland, California 94607-4052

lU_

EXECUTIVE

SUMMARY

On April 30,2004, an Off-site Medical Drill for the Tri-City Medical Center was conducted in the emergency planning zone (EPZ) around the San Onofre Nuclear Generating Station.

The purpose of the exercise was to assess the level of local and State preparedness in responding to a radiological emergency. This drill was held in accordance with FEMA's policies and guidance concerning the exercise of local and State radiological emergency response plans and procedures.

The most recent previous plume pathway exercise at this site was conducted on October 22,.

2003. The qualifying emergency preparedness exercise was conducted on May 13, 1981.

The most recent drill for the Tri-City Medical Center was conducted on July 21, 2000.

FEMA wishes to acknowledge the efforts of the many individuals from the Interjuisdictional Planning Committee Jurisdictions, the State of California, the volunteer organizations, and the private organizations who participated in this medical drill.

Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities.

Cooperation and teamwork of all the participants were evident during this exercise.

This report contains the final evaluation of the medical drill.

The State and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no issues identified as a result of the drill.

i

REPORT CREDITS Document Preparatio tn. Richard Echavarria Research FEMA Region IX and Chief Editor Final Editor . ~Kenneth Chin Chair, Regional Assistance Committee FEMA Region IX

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• ii

TABLE OF CONTENTS Page I. EXECUTIVE

SUMMARY

..................................... i II. REPORT CREDITS/TABLE OF CONTENTS ...................................... ii

.. INTRODUCTION ........... v IV. OVERVIEW ..................................... viii A. Plume Emergency Planning Zone Description .................... ................. viii B. Participants ..................................... ix V. EVALUATION AND RESULTS .................................. .. x A. Summary Results of Evaluation ...................... x B. Status of Jurisdictions Evaluated ...................... xii o Drill Detail 1 o Mercy Air Ambulance I o Tri-City Medical Center 3 List of Tables Table I - Summary Results of Evaluation .xi Table 2 -Drill Issues .xiv iii

List of Appendices APPENDIX 1 - ACRONYMS AND ABBREVIATIONS 8 APPENDIX 2 - EVALUATORS AND TEAM LEADERS ......................................... :.10 I . . -

APPENDIX 3 - EVALUATION AREA CRITERIA AND EXTENT-OF-PLAY AGREEMENT ............................. 11 APPENDIX 4 - SCENARIO .................. -  ; 14 iv

I III. INTRODUCTION On December 7, 1979, the President directed FEMA to assume the lead responsibility for all off-site nuclear planning and response. FEMA's activities are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

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

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

• Taking the lead in off-site emergency planning and in the review and evaluation of RERPs and procedures developed by State and local governments;

• Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments;

• Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, September 14, 1993);

and

• Coordinating the activities of Federal agencies with responsibilities in the radiological emergency planning process:

- U.S. Department of Commerce,

- U.S. Nuclear Regulatory Commission,

- U.S. Environmental Protection Agency,

- U.S. Department of Energy,

- U.S. Department of Health and Human Services,

- U.S. Department of Transportation,

- U.S. Department of Agriculture,

- U.S. Department of the Interior, and

- U.S. Food and Drug Administration.

Representatives of these agencies serve on the FEMA Region RIX Regional Assistance Committee (RAC) which is chaired by FEMA.

v

Formal submission of the RERPs for the San Onofre Nuclear Generating Station to FEMA Region IX by the State of California and the involved local jurisdictions occurred

-on May 31, 1988.

State and local Radiological Emergency Preparedness plans are required, in NUREG-0654/FEMA REP 1, Rev. 1 (November 1980), to designate primary and back-up medical facilities capable of providing appropriate care to injured/contaminated individuals originating from the off-site effects of an incident at a nuclear power plant. One or more of these facilities are usually exercised as part of the biennial StatelLocal REP exercise.

Others may be exercised during the off-year period. At least one evaluated medical drill must be held each year at eachnuclear.facility, according to NUREG-0654 Planning Standard N.2.c.

FEMA Region IX evaluated an April 30, 2004, Off-site Medical Drill for the Tri-City Medical Center, to assess the capabilities of local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the San Onofre Nuclear Generating Station.

The purpose of this report is to present the results and findings on the performance of the

'off-site response organizations (ORO) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the FEMA Region IX RAC Chairperson, and approved by the Regional Director.

The criteria utilized in the FEMA evaluation process are contained in:

• NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980; FEMA Radiological Emergency Preparedness: Exercise Evaluation Methodology, April, 2002; and

• FEMA Guidance Memoranda MS-1, "Medical Services," November, 1986.

Section IV of this report, entitled "Overview," presents basic information and data relevant to the drill. This section of the report contains a description of the plume pathway EPZ and a listing of all participating jurisdictions and functional entities that were evaluated.

vi

Section V of this report, entitled "Evaluation and Results," presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only fornat. This section also contains:

(1) descriptions of all ARCAs assessed during this exercise, recommended corrective actions, and (2) descriptions of unresolved ARCAs assessed during previous drills.

vii

IV. EXERCISE OVERVIEW Contained in this section are data and basic information relevant to the April 30, 2004, Off-site Medical-Drill for the Tri-City Medical Center to test the off-site emergency response capabilities in the area surrounding the San Onofre Nuclear Generating'Station. This section of the exercise report includes a description of the plume pathway EPZ, a'description of the 50-mile ingestion pathway zone (IPZ), a' listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities.

A. Plume EPZ Description The SONGS EPZ extends nearly fourteen miles from the SONGS site due to jurisdictional boundaries and topography. The EPZ includes the following:

Orange County:

the City of Dana Point; the City of San Clemente; the City of San Juan Capistrano; Rancho Mission Viejo, an unincorporated area of Orange County bordering the cities of San Clemente and San Juan Capistrano and the Cleveland National Forest; and Doheny and San Clemente State Beaches.

San Diego County:

Camp Pendleton Marine Corps Base; and San Onofre State Beach.

B. Ingestion Pathway Zone Description The SONGS Ingestion Pathway Zone extends for 50 miles around the SONGS site and includes all of Orange County. In addition, it includes portions of the following Counties:

Los Angeles Riverside San Bernardino San Diego viii

C. Exercise Participants The following agencies, organizations, and units of government participated in the April 30, 2004, Off-site Medical Drill for the Tri-City Medical Center.

PRIMARY JURISDICTIONS PRIVATE/VOLUNTEER ORGANIZATIONS Mercy Air Ambulance Tri-City Medical Center Southern California Edison ix

V. EXERCISE EVALUATION AND RESULTS Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities which participated in the Off-site Medical Drill for the Tri-City Medical Center on April 30, 2004, to test the off-site emergency response capabilities of local and State governments in the EPZ surrounding the San Onofre Nuclear Generating Station Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria delineated in exercise evaluation-a're~a criteria contained 'in"the FEMA REP Program Manual. Detailed information on the exercise evaluation area criteria and the extent-of-play agreement used in this exercise are found in Appendix 3 of this report.

A. Summary Results of Exercise Evaluation - Table 1 The matrix presented in Table 1, on the following page(s), presents the status of all exercise evaluation area criteria from the FEMA REP Program Manual that were scheduled for demonstration during this exercise by all participating jurisdictions and functional ,entities.Exercise evaluation area criteria are listed by number and the demonstration status of those evaluation area criteria is indicated by the use of the following letters:

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

D - Deficiency.assessed A ARCA(s) assessed or unresolved ARCA(s) from prior exercise(s)

N Not Demonstrated (Reason explained in Subsection B) x

TABLE 1-

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OF RESULTS OF EXERCISE EVALUATION

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-iA~iMANAGEM2NT:R I >]DECISION.MAKJNG~i N ;i S S j~ 4  ;'.' ' .s;8iANALYSISifC RUBLIC INFO 'OPN/FACILITIES 1aj1i1bl J1c1Ildl 1al 12a1 (2b 1 2b2 2c12d1 2el 3a1 d3e2 33d2 33bd133 33d2 4a1 J4a2 14a3j4b1T4c1 5a1 15a3l5b1 16a1 16bj1I610 6dl MEDICAL DRILL rcy itAmbulance I I I I I IM I i' I 1 1 I1 1 1 II IT I I I I I I I I I -I 11 I I I I I I I1 1 1 11 I I I I I I 9/13/2004

B. Status of Jurisdictions Evaluated This subsection provides information on the evaluation of each participating jurisdiction and functional entity, in a jurisdiction based, issues only format.

Presented below is a definition of the terms used in this subsection relative to objective demonstration status.

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

- under which no ARCAs assessed during, prior exercises remain unresolved.

Deficiency - Listing of the demonstrated exercise evaluation area criteria under which'one or mofe Deficiencies was' assessed during this exercise.

Included is a description of each Deficiency and recommended corrective actions. '

Area Requiring Corrective Actions - Listing of the demonstrated

- - - -exercise evaluation area -criteria under which bne or more ARCAs were assessed during,.the current -exercise or-ARCAs assessed during prior exercises remain unresoWed. Included is a description of the ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before 6r during the next biennial exercise.

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

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

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

xii

The following are definitions of the two types of exercise issues that are discussed in this report.

A Deficiency is defined in the FEMA REP Program Manual as "...an observed or identified inadequacy of organizational performance in an exercise that could cause a finding that off-site emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant."

An ARCA is defined in the FEMA REP Program Manual. as "...an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety."t FEMA has developed a standardized system for numbering exercise issues (Deficiencies and ARCAs). This system is used to achieve consistency in numbering exercise issues among FEMA Regions and site-specific exercise reports within each Region. It is also used to expedite tracking of exercise issues on a nationwide basis.

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

Plant Site Identifier - A two-digit number corresponding to the Utility Billable Plant Site Codes.

Exercise Year - The last two digits of the year the exercise was conducted.

Evaluation Area Criterion - A letter and number corresponding to the criteria in the FEMA REP Program Manual.

Issue Classification Identifier - (D = Deficiency, A = ARCA). Only Deficiencies and ARCAs are included in exercise reports.

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

xiii

TABLE 2 DRILL ISSUES LOCATION -CURRENT ISSUE(S) ISSUE(S)

__ISSUE(S) RESOLVED UNRESOLVED Mercy Air Ambulance NONE ' NONE NONE Tri-City Medical Center NONE NONE NONE I I

, , : , 1. , . , , " I ..

xiv

U DRILL DETAIL There were three criteria selected for observation, demonstration, and evaluation, for Medical Drill at Tri-City Medical Center (TCMC). All criteria were met. There was one ARCA identified and corrected. There are no uncorrected ARCAs from previous drills.

MvIercv Air Ambulance Mercy Air Ambulance (MAA) adequately demonstrated that they had sufficient equipment and supplies to. support emergency operations. The equipment available consisted of the necessary medical supplies and medical monitors for the care of the injured/contaminated victim, while en route to the TCMC.

Dosimetry was available for the air crew at Station 5, located at McClellan Palomar Airport in Carlsbad. This equipment consisted of a Thermoluminescent Dosimeter (TLD) for each crew member, a Mydose PDM-203 electronic direct-reading dosimeter (EDRD) with a full-scale range of 0-9999mR; and a Form R- 1,Emergency Worker Radiation Exposure Form. If Station 5 was not the responding air ambulance, the crews from the other stations would receive their dosimetry at the San Onofre Nuclear Generating Station (SONGS) from the Health Physicist (HP) at the scene.' All dosimetry used and/or issued was returned to SONGS for processing, in addition to the completed R-1 Forms. The established administrative exposure consisted of mission limit of 10OOmR.

The MAA crew demonstrated that demonstrated the capability to continuously monitor and control radiation exposure. The MAA crew was familiar with their dosimetry and the Form R-1, Emergency Worker Radiation Exposure Form.

The air ambulance crew was mobilized by a call from SONGS to transport an injured/contaminated worker at the station. Dosimetry was available at Station 5 located at McClellan Palomar Airport in Carlsbad. This equipment consisted of a Thermoluminescent Dosimeter (TLD) for each crew member, a Mydose PDM-203 electronic direct reading dosimeter (EDRD) with a full-scale range of 0-9999mR. The Mydose PMP-203 is self zeroing through the action powering the unit on. If Station 5 was not the responding air ambulance, the crews from the other stations would receive their dosimetry at the SONGS from the HP at the scene.

The initial MAA crew from Station 5 was diverted from participation in the exercise and replaced by an air crew from Station 6 from Gillespie Field located in El Cajon, CA. Normally the air crew from Station 6 would fly directly SONGS and pick up the victim and be issued their dosimetry from an HP at the scene. However, for this drill the aircraft landed at McClellan Palomar Airport at 0850 to retrieve the emergency response packet and associated dosimetry and departed for SONGS shortly thereafter.

The crew indicated that the EDRD was to be read every 15 minutes and the reading recorded on the I

R-1 forms. All dosimetry used and/or issued was returned to SONGS for processing, in addition to the completed R-1 Forms. The established administrative exposure consisted of mission limit of 1O0OmR.

MAA had adequate resources, and trained personnel to provide transport and medical 'services for contaminated injured individuals. At 0838, the controller at the SONGS helipad received a call with information that the on-site portion medical drill had begun. The estimated time of arrival (ETA) for the victim to the SONGS helipad was 10 minutes, and the ETA for the MAA to the helipad was 0900. The ambulance with the victim arrived at 0855, and the MAA helicopter arrived at 0908.

The transfer of the victim went quickly and smoothly. Upon arrival, the MAA Flight Nurse received a briefing about the victim's injuries and vital signs. The victim had been wrapped and cocooned by the SONGS personnel to prevent the spread of contamination. All SONGS personnel were equipped with the proper dosimetry and wore a double set of gloves. The MAA Flight Nurse also wore a double set of gloves, and was equipped with a TLD and EDRD, which she read before they moved the victim to the helicopter. They transferred the victim to the helicopter, which departed at 0922:

SONGS personnel surveyed their hands and feet, and the ambulance for'contamination prior.to departing from the helipad.

The TCMC had a helicopter pad on the roof of the hospital above the emergency room that provided sufficient space, adequate resources, and trained personnel to provide the transfer 6f ihe patient to the Contaminated Injury Room (CIR), including medical services, monitoring, and decontamination of the contaminated injured individual.

MAA provided the transport of the contaminated injured patient from the SONGS to the TCMC.

MAA radioed an estimated time of arrival (ETA) of 8 minutes at 0926.Upon landing at 0934, the MAA Bell-222 helicopter was met by a Tri-City medical team and security personnel. The victim had been cocooned at SONGS and monitored for contamination. The MAA medical technician informed the Tri-City medical team of the injuries of the victim including vital signs and where significant levels of contamination were located. The patient was immediately transferred from the helicopter to a decontamination gurney and escorted by security and the TCMC medical team to the CIR for medical attention. -

While the patient was taken'to CIR, the-MAA crew remained behind with a'SONGS HP who initiated a monitoring of the crew and helicopter utilizing an Eberline RM-14 meter (calibrated 7/15/2004, calibration due 7/15/2004) equipped with HP-260 thin-window Geiger-MUller (GM) pancake probe. The ciew 'was found to 'be'clean. ' The helicopter was also monitored for contamination. The entire interior of the aircraft was monitored in addition to the exterior of the doors and handles; The helicopter was found to the clean. Following the contamination checks, the helicopter was released, and departed the helipad at 0955.

The HP indicated that the helipad would be swept with a mop affixed with Masslin cloth. At the completion of the sweep, the bottom of mop'would be -monitored with the Eberline RM-14 meter 2

equipped with HP-260 thin-window GM pancake probe, for any contamination picked up by the cloth.

Evaluation Area Criteria 'Met L.e.I, 3.c.1, 6.d.1 Deficiencies None Areas Requiring Corrective Action None -

Prior Areas Requiring Corrective Action - Corrected None Prior Areas Requiring Corrective Action - Uncorrected None Tri-City Medical Center The TCMC had adequate equipment, dosimetry and supplies to support emergency operations. There were sufficient medical equipment and supplies to treat an ill or injured/contaminated patient. Two SONGS Disaster carts, stored in the TCMC, contained the supplies and equipment for setting up the CIR and were transferred, when needed, to the patient care area in the Emergency Department. Two CIR Room R or Room 1 layout maps were available on the carts to insure the proper setup of the CIR. Two charts, Radiation Accident the Emergency Care of the Contaminated Patient and Responding to Radiation Accidents-Dressing and Undressing, were prominently displayed in the CIR. There was also an adequate supply of protective clothing.

Two monitoring instruments, a Ludlum Model 3 with a thin-window Model 44-9 GM pancake probe (calibrated 1/27/04, due for calibration 1/27/05) and an Eberline model E 140 with a thin-window model HP260 GM pancake probe (calibrated4/15/04 and due forcalibration 4/15105) were available from the TCMC Nuclear Medicine Department.

A sufficient number of TLDs were on the disaster cart, and available for issue to the hospital staff. A Mydose PDM-203 EDRD (range 0 to 9999mR) was positioned approximately 5 feet above the contaminated patient.

3

Additional monitoring and dose rate measuring instruments were available from the utility.

The staff at the TCMC demonstrated the capability to continuously monitor and controlfradiation exposure to the medical team. Each member of the TCMC Staff, working in the CIR orbufferzones that could come in contact with the contaminated patient or'samples taken from the patient was issued a TLD. Personal information and the serial number of the TLD were entered on a TCMC Dosimetry Issue Log for later assignment of total dose to the user. The TLDs were issued by the Radiation Safety Officer (RSO).

A Mydose PDM-203 EDRD with a range of 0-9999 mR was positioned directly over the patient on the decontamination table. The EDRD was read at 15 minute intervals and the reading together with the time was entered on an Emergency Department Continuing Nursing Progress Record. The CIR staff was aware that a reading of 100mR on the EDRD was the decision point at which time the CIR team or individual members may be rotated.

The RSO retrieved the TLDs, TCMC Dosimetry Issue Log, and Emergency Department Contin'uirig Nursing Progress Record; upon which the 15 minute EDRD readings were recorded;'at the conclusion of the simulated response.

The TCMC demonstrated the adequacy of equijpment, procedures, supplies, and personnel for the treatment and decontamination of a contaminated patient. TCMC received the initial call from the SONGS at 0835 and verified the call by a call back to SONGS via land line. The initial call indicated that a female employee had a severe head injury and contamination ranging from 6,000 to 15,000 counts per minute (cpm) and that MAA had been called. The TCMC Initial Notification Log was completed. The TCMC telephone operator was called and announced a "Code Yellow in the EmergencyDepartment" and initiated a group page to appropriate staff members. An individual page was made to Security. All paged personnel had responded by 0855. Communications'with the MAA Was via the 800 MHz Med Net.

The two disaster carts containing supplies and equipment for setting up the CIR were immediately brought to the Emergency Department patient treatment area7 The CIR was setup in a timely, efficient and effective manner. Plastic coverings were placed over non-essential equipmnent that could not be removed from the CIR. Appropriate waste containers, a special decontamination gurney, entrance floor coverings, and step 'off pads were placed in the patient treatment area. A hose with a shower head, to be utilized for decontamination, was hooked to a water faucet.

TLDs were issued by the RSO to the CIR and buffer zone staff that could come in contact with the contaminated patient or samples taken from the patient. Personal data and the serial number of the TLD were entered on TCMC Dosimetry Issue Log for later assignment of dose to the user: The CIR staff then dressed out in shoe covers, double gowns, and a first pair of gloves which were pulled over the'gown cuffs and taped, a second pair of gloves, cap, mask, and face shield. A Mydose PDM-203 EDRD was positioned approximately five feet above the patient's decontamination gurney and was 4

Areas Requiring Corrective Action None Prior Areas Requiring Corrective Action - Corrected None Prior Areas Requiring Corrective Action - Uncorrected None 7

APPENDIX 1 ACRONYMS AND ABBREVIATIONS The following is a list of the acronyms and abbreviations that were used in this report.

ARCA Area Requiring Corrective Action CAT computed axial tomography CFR Code of Federal Regulations CIR Contaminated Injury Room Ci Curie jiCi microCurie (106 Curies).

cpm counts per minute EDRD Electronic Direct-Reading Dosimeter EOC Emergency Operations Center EPZ Emergency Planning Zone ETA estimated time of arrival FEMA Federal Emergency Management Agency FR Federal Register GM Geiger-MUller HP Health Physicist MAA Mercy Air Ambulance miR milliroentgen (10 3 Roentgen) mR/h milliroentgen per hour pR microroentgen (10.6 Roentgens)

NRC U.S. Nuclear Regulatory Commission .

NUTREG-0654 NUREG-0654JFEMA-REP-1, Rev. 1, "CriteriaforPreparationand Evaluation of Radiological Emergency Response Plans and Preparedness in Support of NuclearPowerPlants, " Nov'ember 1980 8

R Roentgen R/h Roentgen(s) per hour mR milliroentgen (10-3 Roentgen) mR/h milliroentgen per hour R microroentgen (10-6 Roentgens)

RAC Regional Assistance Committee rem Roentgen Equivalent Man REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RSO Radiation Safety Officer SCE Southern California Edison SONGS San Onofre Nuclear Generating Station TCMC Tri-City Medical Center TLD Thermoluminescent Dosimeter 9

APPENDIX 2 EVALUATORS AND TEAM LEADERS The following is a list of the personnel who evaluated the San Onofre Nuclear Generating Station Off-site Medical Drill for the Tri-City Medical Center on April 30,2004. The letters "(TL)" indicate evaluator Team Leaders after their names. The organization that each evaluator represents is indicated by the following abbreviations:

FEMA - Federal Emergency Management Agency ICF -ICF Consulting EVALR. .

EVALUATION SITE  : EVAL-ATO ORGANIZATION Mercy Air Ambulance Hollis Berry ICF (TL)I Tri-City Medical Center Frank Bold ICF Site-Specialist Richard Echavarria FEMA RIX 10

APPENDIX 3 EXERCISE EVALUATION AREA CRITERIA AND EXTENT-OF-PLAY AGREEMMENT This appendix lists the exercise evaluation area criteria that were scheduled for demonstration in the San Onofre Nuclear Generating Station Off-site Medical Drill for the Tri-City Medical Center on April 30, 2004 and the extent-of-play agreement approved by FEMA Region IX.

The Evaluation Area Criteria, contained in the "Radiological Emergency Preparedness Exercise New Methodology" represent a functional translation of the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

November 1980.

Because the evaluation area criteria are intended for use at all nuclear power plant sites, and because of variations among off-site plans and procedures, an extent-of-play agreement is prepared by the State and approved by FEMA to provide evaluators with guidance on expected actual demonstration of the Evaluation Area Criteria.

A. Exercise Evaluation Area Criteria Listed below is the specific radiological emergency preparedness evaluation area criteria scheduled for demonstration during this exercise.

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element Le - Equipment and Supplies to Support Operations Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654, H.,

J. 10.a.b.e.fj.k., 11, K.3.a.)

EVALUATION AREA 3: PROTECTIVE ACTION INIPLENIENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3.)

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EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654, F.2, H.10., K.5.a.b., L.1., 4.)

B. Extent-of-Play Agreement The extent-of-play agreement on the following pages was submitted by the County of San Diego and was approved by FEMA'Region'RIX, in preparation'San Onofre Nu'lear Generating Station Off-site Medical Drill for the Tri-City Medical Center on April 30, 2004. The extent-of-play agreement includes any significant modification or change in' the level of demonstration of each exercise evaluationiarea criterion listed in'Subsection A of this appendix.

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MEDICAL EMERGENCY PLAN EXERCISE Apri130,2004 April 30, 2004 MEDICAL EMERGENCY PLAN EXERCISE Exercise Objectives San Onofre Nuclear Generating Station Exercise Objectives

1. Demonstrate the ability of San Onofre Firefighters to respond to a radiation medical emergency.

2. Demonstrate the ability of San Onofre Security Officers to respond to a radiation medical emergency.

3. Demonstrate the ability of San Onofre Health Physics personnel to respond to a radiation medical emergency.

Tn-City Medical Center and Mercy Air Exercise Objectives Criterion 1.e.1 - Equipment and Supplies to Support Operations Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654, H., J.10.a.b.e.f.j.k., 11, K.3.a.)

Criterion 3.a.1 - Implementation of Emergency Worker Exposure Control Tri-City Medical Center and Mercy Air issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3.)

Criterion 6.d.1 - Transportation and Treatment of Contaminated Injured Individuals Tri-City Medical Center and Mercy Air has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

(NUREG-0654, F.2, H.10., K.5.a.b., Li., 4.)

Exercise Extent of Play All activities associated with exercise will be based on existing the plans, procedures, equipment and supplies needed to support an actual medical emergency, unless noted below.

Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the simulated victim.

Mercy Air can only land at approved locations during non-emergencies. Therefore, the exercise will begin at an approved helicopter pad in San Diego County. Mercy Air policy will not allow Controllers, Evaluators and/or Heath Physics Technicians to accompany the victim to the hospital.

Mercy Air will demonstrate the capability to transport a contaminated injured individual via air ambulance to the Tri-City Medical Center. Mercy Air does not perform radiological monitoring or decontamination of patients. Normal communications between San Onofre Nuclear Generating Station, Mercy Air, and Tri-City Medical Center will be demonstrated. This will include reporting radiation monitoring results, if available. Additionally, the ambulance, staff and equipment will be monitored after transport.

Monitoring of the simulated victim will be performed prior to transport, and at Tri-City Medical Center. Prior to using monitoring instruments, the monitors will demonstrate the process of checking the instruments for proper operation. All monitoring activities will be completed as they would be in an actual emergency. Appropriate contamination control measures will be demonstrated prior to and during transport and at Tri-City Medical Center.

Tri-City Medical Center will demonstrate the capability to activate and set up a radiological emergency area for treatment. Equipment and supplies will be available for the treatment of contaminated injured individuals.

Tri-City Medical Center will demonstrate the capability to make decisions on the need for decontamination of the individual, to follow appropriate decontamination procedures, and to maintain records of all survey measurements and samples taken. All procedures for the collection and analysis of samples and the decontamination of the individual should be demonstrated or described to the FEMA evaluator.

Play by Mercy Air and Tri-City Medical Center may be interrupted by an actual emergency. Attempts will be made to resume play at the end the actual emergency. If play is unable to resume, the remaining portions of the exercise may be demonstrated via interview with a designated representative of Mercy Air and Tri-City Medical Center.

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APPENDIX 4.

SCENARIO This appendix contains a summary of the simulated sequence of events -- Scenario -- that was used as the basis for invoking emergency response actions by OROs during the San Onofre Nuclear Generating Station Off-site Medical Drill for the Tri-City Medical Ce'nter on April 30, 2004.

This scenario, on the following page, was submitted and approved by FEMA RIX.

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_______________ 'El MEDICAL EMERGENCY PLAN EXERCISE April 30, 2004 Summary NOTE: The primary purpose of this exercise scenario is to provide a realistic training and evaluation opportunity for both Mercy Air and Tri-City Medical Center staff. However In a real situation, Mercy Air would not transport to Tri-City Medical Center, since Tri-City is not a trauma facility.

PRE-EXERCISE BRIEFINGS Pre-exercise briefing for Participants will occur at 0845.

INITIAL CONDITIONS At 0800, a Health Physics Technician walking through the South Yard Machine Shop notices an individual face down at the base of a ladder in a contaminated area. The individual is unconscious and does not respond to sounds. The individual has facial bleeding and swelling to the right elbow. Initial survey results indicate 900 to 9000 cpm on the individuals.

EXPECTED RESPONSES SONGS Firefighters are expected to; Be dispatched to the accident scene Set up their Incident Command System Notify Mercy Air for air ambulance transport Notify Tri-City Medical Center regarding the transport of a radiologically contaminated individual to their facility.

Medically assessed and properly packaged the patient for transport SONGS Health Physics personnel are expected to; Provide proper radiological controls Brief Mercy Air on personnel on radiological conditions Provide a technician to assist Mercy Air as per the Emergency Plan Medical Agreement Provide a technician to assist Tri-City Medical Center as per the Emergency Plan Medical Agreement SONGS Security is expected to; Provide crowd control at the accident scene Facilitate the on-site arrival of Mercy Air personnel at the Heliport Mercy Air personnel are expected to; Respond to SONGS in a timely manner Receive a medical and radiological briefing Utilize proper techniques to minimize the spread of contamination Transport patient to the hospital Ensure they and their helicopter are radiologically monitored prior to being released Tri-City Medical Center Staff are expected to:

Setup Emergency Room for a radiologically contaminated patient according to procedure Institute appropriate radiological and contamination controls at the hospital Treat and decontaminate patient according to procedure EXERCISE TERMINATION The exercise will be closed out at SONGS when patient is transported off-site. This should occur at about 9:00i: The exercise will be closed out at the hospital when the patient has been decontaminated and transported out of the emergency room and the affected staff successfully egresses from the contaminated area. This should occur at 11:00 at the hospital. Upon termination, debriefings will be conducted at SONGS and the hospital by exercise controllers. All activities associated with the exercise should be completed by 12:00 p.m.

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