ML112510573
| ML112510573 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/09/2011 |
| From: | Ward N Federal Emergency Management Agency, US Dept of Homeland Security |
| To: | Collins E Region 4 Administrator |
| cecere, Bethany NSIR/DPR 415-6754 | |
| References | |
| Download: ML112510573 (52) | |
Text
San Onofre Nuclear Generating Station After Action Report/Improvement Plan Exercise Date - April 12, 2011 Radiological Emergency Preparedness (REP) Program Published August 4, 2011
Unclassified Radiological Emergency Preparedness Program (REP)
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station San Onofre Nuclear Generating Station After Action Report/Improvement Plan Published August 4, 2011 Contents Section 1. Exercise Overview .................................................................... 6 1.1 Exercise Details ..................................................................................................................... 6 1.2 Exercise Planning Team Leadership .................................................................................... 6 1.3 Participating Organizations................................................................................................... 7 Section 2. Exercise Design Summary........................................................ 9 2.1 Exercise Purpose and Design................................................................................................ 9 2.2 Exercise Objectives, Capabilities and Activities ................................................................. 9 2.3 Scenario Summary .............................................................................................................. 11 Section 3. Analysis of Capabilities .......................................................... 12 3.1 Exercise Evaluation and Results......................................................................................... 12 3.2 Summary Results of Exercise Evaluation .......................................................................... 12 3.3 Criteria Evaluation Summaries ........................................................................................... 16 3.3.1 State Jurisdictions ........................................................................................................ 16 3.3.2 Risk Jurisdictions ......................................................................................................... 16 3.3.3 Private Jurisdictions ..................................................................................................... 21 Section 4. Conclusion .............................................................................. 22 Appendices .............................................................................................. 23 Appendix A : Improvement Plan .................................................................................................. 23 Appendix B : Exercise Timeline .................................................................................................. 24 Appendix C : Exercise Evaluators ................................................................................................ 26 Appendix D : Acronyms and Abbreviations................................................................................ 27 Appendix E : Extent-of-Play........................................................................................................ 28 3
Unclassified Radiological Emergency Preparedness Program (REP)
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station EXECUTIVE
SUMMARY
The U.S. Department of Homeland Security's Federal Emergency Management Agency (FEMA)
National Preparedness Division - Technological Hazards Branch in Region IX evaluated a biennial Radiological Emergency Preparedness (REP) plume phase exercise for the emergency planning zone (EPZ) around the San Onofre Nuclear Generating Station (SONGS) on April 12, 2011. Out-of-sequence demonstrations were conducted on October 21, 2010, April 7, 8, and 13, 2011. The previous biennial plume phase exercise at this site was conducted on September 23, 2009.
The purpose of the exercise was to assess the level of state and local preparedness in response to a simulated radiological emergency at SONGS. This exercise was held in accordance with FEMAs policies and guidance concerning the exercise of state and local Radiological Emergency Response Plans (RERP) and procedures.
FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise.
Protecting the public health and safety is the full-time job of some of the exercise participants and 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 evaluation of the exercise. The exercise participants except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately demonstrated the ability to execute those plans. No Deficiencies and one Area Requiring Corrective Action (ARCA) were identified during the course of the exercise. One evaluation area criteria scheduled to be demonstrated during this exercise could not be evaluated and will be demonstrated before the next biennial exercise. The corrective action plan for the ARCA will be documented in the 2011 SONGS Plume Phase Exercise Improvement Plan in Appendix A.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station SECTION 1. EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name San Onofre Nuclear Generating Station Plume Phase Exercise Type of Exercise Plume Phase Exercise Exercise Dates April 12, 2011 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Sara Kaminske Assistant Emergency Manager Orange County Sheriff Department 2644 Santiago Canyon Road Silverado, CA 92676 Rick Garcia Emergency Services Coordinator Southern California Edison P.O. Box 128 San Clemente, CA 92672 Lynne Olson California Emergency Management Agency Senior Emergency Services Coordinator Nuclear Preparedness Program 3650 Schriever Ave Mather, CA 95655 6
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station Richard Echavarria Senior Site Specialist Radiological Emergency Preparedness Program FEMA Region IX 1111 Broadway Suite 1200 Oakland, CA 94607 1.3 Participating Organizations The following agencies and organizations participated in the San Onofre Nuclear Generating Station exercise:
State California Department of Public Health California Department of Transportation California Emergency Management Agency California Highway Patrol California State Parks and Recreation, Orange Coast District Parks County County of Orange County of San Diego Local Capistrano Unified School District City of Dana Point City of San Clemente City of San Juan Capistrano Other Public Agencies Oceanside Fire Department Orange County Fire Authority Orange County Transportation Authority Non-Governmental Organizations American Red Cross Private Sector Organizations KWVE-FM, Orange County Emergency Alert System 7
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station KOGO-AM, San Diego Emergency Alert System San Diego Gas & Electric San Onofre Nuclear Generating Station Southern California Edison Federal Agencies Federal Emergency Management Agency Marine Corps Base Camp Pendleton Nuclear Regulatory Commission 8
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station SECTION 2. EXERCISE DESIGN
SUMMARY
2.1 Exercise Purpose and Design FEMA Region IX evaluated the exercise 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 SONGS. The purpose of this After Action Report (AAR) is to present the results and findings on the performance of the Offsite Response Organizations (ORO) during a simulated radiological emergency.
2.2 Exercise Objectives, Capabilities and Activities The exercise evaluation area criteria, contained in the FEMA Federal Register Notice, "Radiological Emergency Preparedness Exercise Evaluation Methodology," dated August 25, 2002 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.
The objectives of this exercise are as follows:
Criterion 1.a.1: OROs uses effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654: A.4, D.3, 4; E.1, 2; H.4)
Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible. (NUREG-0654: A.1.d, A.2.a, b)
Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations.
Communications capabilities are managed in support of emergency operations. (NUREG-0654:
F.1, 2)
Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654: H.7, 10; J.10.a, b, e; J.11; K.3.a)
Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654: J.10.e, f; K.4) 9
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654: I.8, 10; Supplement 3)
Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions for the general public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654: J.9; J.10.f, m)
Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups. (NUREG-0654: J.9; J.10.d, e)
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.a, b)
Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record-keeping of the administration of KI for emergency workers and institutionalized individuals is maintained. (NUREG-0654: J.10.e)
Criterion 3.c.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective action. (NUREG-0654: J.10.c, d, g)
Criterion 3.c.2: OROs/School officials implements protective actions for schools. (NUREG-0654: J.10.c, d, g)
Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654: J.10.g, j)
Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654: J.10.k)
Criterion 4.a.1: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.
(NUREG-0654: H.10; I.7, 8, 9).
Criterion 4.a.2: Field monitoring teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654: I.8, 11; J.10.a; H.12).
Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media.
(NUREG-0654: I.9) 10
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP guidance. (10 CFR Part 50, Appendix E.IV.D & NUREG-0654: E.5, 6, 7)
Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654: E.6, Appendix 3.B.2.c)
Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654: E.5, 7; G.3.a; G.4.c) 2.3 Scenario Summary This section contains a summary of the simulated sequence of events used as the basis for invoking emergency response actions by OROs, submitted to FEMA by the state of California and SONGS (See Appendix B for detailed Exercise Timeline Matrix).
The exercise begins with SONGS Unit 2 Train B Diesel Generator suffering a catastrophic failure. Within fifteen minutes of this event, SONGS declares an Alert and notifies the jurisdictions within the EPZ. In an unrelated event, the Control Room receives a Unit 2 vibration and loose parts alarm. Subsequently, Unit 2 Reactor Coolant Pump #2 suffers a sheared shaft, resulting in a 380 gallon per minute release of reactor coolant into containment. A chemistry sample taken approximately thirty minutes later indicates the loose parts damage more than one percent to the fuel in the reactor vessel. As a result of the damage to the reactor fuel, SONGS declares a Site Area Emergency. With the reactor coolant leak increasing significantly, and containment pressure levels rising, SONGS declares a General Emergency. A containment purge valve is moved off its seat as a result of increased pressure in the containment, releasing radioactive material to the environment.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station SECTION 3. ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the April 12, 2011, biennial plume phase exercise and out-of-sequence interviews and demonstrations which were conducted to test the offsite emergency response capabilities of state and local government agencies for the SONGS EPZ.
Each jurisdiction and functional entity was evaluated on its demonstration of criteria contained in the exercise evaluation areas as outlined in the Federal Register, Vol.67, No. 80 FEMA-Radiological Emergency Preparedness: Exercise Evaluation Methodology (April 25, 2002).
Detailed information on the extent-of-play agreement used in this exercise is found in Appendix E of this report.
3.2 Summary Results of Exercise Evaluation The matrix illustrated in Table 3.1, presents the status of all exercise evaluation area criteria that were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise criteria are listed by number and the demonstration status 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 - ARCAs assessed or unresolved ARCAs from prior exercises N - Not Demonstrated Presented below are definitions of the terms used in this section relative to criteria demonstration status.
- a. 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.
- b. Deficiency - Listing of the demonstrated exercise evaluation area criteria under which one or more Deficiencies were assessed during this exercise. Included is a description of each Deficiency and recommended corrective actions.
- c. Area Requiring Corrective Action - Listing of the demonstrated exercise evaluation area criteria under which one or more ARCAs were assessed during the current exercise. Included is a description of the ARCAs assessed during this exercise and the 12
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station recommended corrective actions to be demonstrated before or during the next biennial plume phase exercise.
- d. Not Demonstrated - Listing of the exercise evaluation area criteria that were scheduled to be demonstrated during this exercise, but were not demonstrated and the reason they were not demonstrated.
The following are classifications of the types of issues that are discussed in this report:
A Deficiency is defined in the FEMA August 2002, Interim REP Program Manual as ...an observed or identified inadequacy of organizational performance in an exercise that could cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that 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 August 2002, Interim 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.
FEMA has developed a standardized system for numbering issues. 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 (-).
- a. Plant Site Identifier - A two-digit number corresponding to the Utility Billable Plant Site Codes.
- b. Exercise Year - The last two digits of the year the exercise was conducted.
- c. Evaluation Area Criterion - A letter and number corresponding to the criteria in the FEMA REP Exercise Evaluation Methodology.
- d. Issue Classification Identifier - D = Deficiency, A = ARCA
- e. Exercise Issue Identification Number - A separate two digit indexing number assigned to each issue identified in the exercise.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station Table 3.1 Summary of Exercise Evaluation Oceanside FMT DATE: 2011-04-12 OC EAS Station SONGS EOF OCFA FMT SITE: San Onofre Nuclear Generating Station, CA OC EOC OC DPW SD EOC ODAC OCSD OC TA A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated Emergency Operations Management Mobilization 1a1 M M M M M M Facilities 1b1 Direction and Control 1c1 M M M M M M Communications Equipment 1d1 M M M M M M M Equip & Supplies to support operations 1e1 M M M M M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2a1 A M M Radiological Assessment and PARs 2b1 M M Decisions for the Plume Phase -PADs 2b2 M M PADs for protection of special populations 2c1 M Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 Rad Assessment and Decision making concerning Relocation, Reentry, and 2e1 Return Protective Action Implementation Implementation of emergency worker exposure control 3a1 M M M M M M M M Implementation of KI decision 3b1 M M M M M M M M Implementation of protective actions for special populations - EOCs 3c1 M M Implementation of protective actions for schools 3c2 M Implementation of traffic and access control 3d1 M M M M Impediments to evacuation are identified and resolved 3d2 M M M Implementation of ingestion pathway decisions - availability/use of info 3e1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3f1 Field Measurement and Analysis Adequate equipment for plume phase field measurements 4a1 M M Field Teams obtain sufficient information 4a2 M M M Field Teams manage sample collection appropriately 4a3 N N Post plume phase field measurements and sampling 4b1 Laboratory operations 4c1 Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1 M M M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception Areas 5a3 M Emergency information and instructions for the public and the media 5b1 M M M Support Operations/Facilities Mon / decontamination of evacuees and emergency workers, and registration 6a1 of evacuees Mon / decontamination of emergency worker equipment 6b1 Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d1 14
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station Table 3.1 Summary of Exercise Evaluation (continued, page 2 of 2)
Dana Point EOC State Parks EOC San Juan SD EAS Station CHP Interview San Clemente OCSD EOC -
DATE: 2011-04-12 SITE: San Onofre Nuclear Generating Station, CA CalTrans A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated EOC Capistrano EOC IPC-JIC CUSD Interview Mobilization Emergency Operations Management Mobilization 1a1 M M M M M M Facilities 1b1 Direction and Control 1c1 M M M M M Communications Equipment 1d1 M M M M M M Equip & Supplies to support operations 1e1 M M M M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2a1 Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 M M M PADs for protection of special populations 2c1 M Rad Assessment and Decision making for the Ingestion Exposure 2d1 Pathway Rad Assessment and Decision making concerning Relocation, 2e1 Reentry, and Return Protective Action Implementation Implementation of emergency worker exposure control 3a1 M M M M M M M Implementation of KI decision 3b1 M M M M M M M Implementation of protective actions for special populations - EOCs 3c1 Implementation of protective actions for schools 3c2 M Implementation of traffic and access control 3d1 M M M M M M Impediments to evacuation are identified and resolved 3d2 M M M M M Implementation of ingestion pathway decisions - availability/use of 3e1 info Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3f1 Field Measurement and Analysis Adequate equipment for plume phase field measurements 4a1 Field Teams obtain sufficient information 4a2 Field Teams manage sample collection appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laboratory operations 4c1 Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1 M M M M M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception 5a3 M M M M M Areas Emergency information and instructions for the public and the media 5b1 M M M M M M Support Operations/Facilities Mon / decontamination of evacuees and emergency workers, and 6a1 registration of evacuees Mon / decontamination of emergency worker equipment 6b1 Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d1 15
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 State Jurisdictions 3.3.1.1 California Highway Patrol Interview
- a. MET: 1.e.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.3
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.1.2 California Department of Transportation Field Operations Interview
- a. MET: 1.e.1, 3.a.1, 3.b.1, 3.d.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2 Risk Jurisdictions 3.3.2.1 SONGS Emergency Operations Facility
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1
- b. Areas requiring corrective action: None
- c. DEFICIENCY: None
- d. Not demonstrated: None 3.3.2.2 Offsite Dose Assessment Center
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.1, 3.a.1, 3.b.1, 4.a.2
- b. AREA REQUIRING CORRECTIVE ACTION: 2.a.1 ISSUE NO.: 51-11-2a1-A-01 CRITERION: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.
(NUREG-0654: J.10.e, f; K.4)
CONDITION: The ODAC functions as the technical offsite center to coordinate and make independent offsite environmental assessments and measurements, radiological evaluations and protective action recommendations.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station The Radiation Monitoring Team Supervisor directed two field monitoring teams to enter the plume before they ingested KI. At 1021, while SONGS was under a Site Area Emergency ECL, the SONGS Corporate Emergency Director announced to the EOF and the ODAC that there were indications that a release to the atmosphere was in progress and the release was confirmed by a SONGS field monitoring team. At 1031 and 1043, the Radiation Monitoring Team Supervisor directed FMT-8 and FMT-2 to traverse the plume and collect air samples at the plume centerline, prior to obtaining the authorization to ingest KI.
The Radiation Monitoring Supervisor should have recognized the need to consider the ingestion of KI and/or additional protective measures when field survey data confirmed a release, regardless of the ECL.
POSSIBLE CAUSE: Since a General Emergency ECL had not yet been declared, ODAC staff had not yet requested an authorization from the County Health Officers to ingest KI.
REFERENCE:
NUREG-0654, J. 10.e, f; K.4 EFFECT: Directing a FMT into a plume prior to considering the ingestion of KI, or additional protective measures could result in unnecessary increased dose.
This is not consistent with the health physics concept of as low as reasonably achievable.
RECOMMENDATION: Provide training for ODAC and Radiation Monitoring Team staff to consider protective measures at any time when field survey data confirms a radioactive release, and to ensure that ODAC and Radiation Monitoring Team staff understand the concept of as low as reasonably achievable.
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.3 Orange County Fire Authority Field Monitoring Team
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: 4.a.3 CRITERION: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected.
Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media.
CONDITION: The exercise plan called for the air sample cartridge to be transferred from the FMT to the EOF Count-room. Lab personnel were released from the exercise prior to the FMTs returning to the ODAC. According to the 17
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station lab procedures, the lab would print a sample receipt and provide it to the FMTs.
This would be the only verification to the FMT that chain-of-custody and integrity of its sample was maintained. This was not demonstrated and chain-of-custody was not observed.
POSSIBLE CAUSE: SONGS lab personnel were released from the exercise prior to the FMTs returning to the ODAC.
REFERENCE:
NUREG-0654, I.9 EFFECT: The demonstration of chain-of-custody and contamination controls could not be observed and evaluated.
RECOMMENDATION: FMTs would need to demonstrate all activities involving contamination control and sample transfer to the EOF Count-room technician in accordance with the current plan and procedures.
3.3.2.4 Oceanside Field Monitoring Team
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: 4.a.3 CRITERION: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected.
Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media.
CONDITION: The exercise plan called for the air sample cartridge to be transferred from the FMT to the EOF Count-room. Lab personnel were released from the exercise prior to the FMTs returning to the ODAC. According to the lab procedures, the lab would print a sample receipt and provide it to the FMTs.
This would be the only verification to the FMT that chain-of-custody and integrity of its sample was maintained. This was not demonstrated and chain-of-custody was not observed.
POSSIBLE CAUSE: SONGS lab personnel were released from the exercise prior to the FMTs returning to the ODAC.
REFERENCE:
NUREG-0654, I.9 EFFECT: The demonstration of chain-of-custody and contamination controls could not be observed and evaluated.
RECOMMENDATION: FMTs would need to demonstrate all activities involving contamination control and sample transfer to the EOF Count-room technician in accordance with the current plan and procedures.
18
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station 3.3.2.5 Orange County Emergency Operations Center
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.6 Orange County Sheriffs Department Emergency Operations Center -
Mobilization
- a. MET: 1.a.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.7 Orange County Sheriffs Department Interview
- a. MET: 1.e.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.8 Orange County Department of Public Works Interview
- a. MET: 1.e.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.9 Orange County Transportation Authority Interview
- a. MET: 1.e.1, 3.a.1, 3.b.1, 3.c.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.10 San Diego County Emergency Operations Center
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 3.d.1, 5.a.1, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None 19
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.11 Dana Point Emergency Operations Center
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.2, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.12 San Clemente Emergency Operations Center
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.2, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.13 San Juan Capistrano Emergency Operations Center
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.2, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.14 State Parks Emergency Operations Center
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.1, 5.a.1, 5.a.3, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.15 Interjurisdictional Planning Committee - Joint Information Center
- a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.2.16 Capistrano Unified School District Interview
- a. MET: 1.e.1, 2.c.1, 3.a.1, 3.b.1, 3.c.2 20
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- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.3 Private Jurisdictions 3.3.3.1 Orange County Emergency Alert System Radio Station
- a. MET: 1.d.1, 5.a.1, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 3.3.3.2 San Diego County Emergency Alert System Radio Station
- a. MET: 1.d.1, 5.a.1, 5.b.1
- b. AREA REQUIRING CORRECTIVE ACTION: None
- c. DEFICIENCY: None
- d. NOT DEMONSTRATED: None 21
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station SECTION 4. CONCLUSION FEMA Region IX evaluated the biennial plume phase exercise on April 12, 2011, for the plume exposure pathway EPZ around SONGS. The purpose of the exercise was to assess the level of state and local emergency preparedness in response to a simulated radiological emergency. This exercise was held in accordance with FEMA policies and guidance concerning the exercise of state and local RERP and procedures.
The findings presented in this AAR are based on the evaluations of the federal evaluation team, with final determinations made by the FEMA Region IX Regional Assistance Committee Chairperson and approved by the Regional Administrator.
No deficiencies and one ARCA were identified during the course of this exercise. One evaluation area criteria scheduled to be demonstrated during this exercise could not be evaluated and will be scheduled for demonstration before the next biennial exercise. The corrective action plan for the ARCA will be documented in the 2011 SONGS Plume Phase Exercise Improvement Plan in Appendix A.
Based on the evaluation of the April 12, 2011, biennial plume phase exercise and out-of-sequence demonstrations, the offsite radiological emergency response plans for the State of California and the affected local jurisdictions site-specific to SONGS can be implemented, and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at SONGS.
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After Action Report/Improvement Plan San Onofre Nuclear Generating Station APPENDIX A : IMPROVEMENT PLAN Issue Number : 51-11-2a1-A-01 Criterion: 2.a.1 ISSUE: The ODAC functions as the technical offsite center to coordinate and make independent offsite environmental assessments and measurements, radiological evaluations and protective action recommendations.
The Radiation Monitoring Team Supervisor directed two field monitoring teams to enter the plume before they ingested KI. At 1021, while SONGS was under a Site Area Emergency ECL, the SONGS Corporate Emergency Director announced to the EOF and the ODAC that there were indications that a release to the atmosphere was in progress and the release was confirmed by a SONGS field monitoring team. At 1031 and 1043, the Radiation Monitoring Team Supervisor directed FMT-8 and FMT-2 to traverse the plume and collect air samples at the plume centerline, prior to obtaining the authorization to ingest KI.
The Radiation Monitoring Supervisor should have recognized the need to consider the ingestion of KI and/or additional protective measures when field survey data confirmed a release, regardless of the ECL.
RECOMMENDATION: Provide training for ODAC and Radiation Monitoring Team staff to consider protective measures at any time when field survey data confirms a radioactive release.
Provide training to ensure that ODAC and Radiation Monitoring Team staff understands the concept of as low as reasonably achievable.
CORRECTIVE ACTION DESCRIPTION:
PRIMARY RESPONSIBLE AGENCY: START DATE:
AGENCY POC: COMPLETION DATE:
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After Action Report/Improvement Plan San Onofre Nuclear Generating Station APPENDIX B : EXERCISE TIMELINE DATE: 2011-04-12, SITE: San Onofre Nuclear Generating Station, CA San Clemente OCFA FMT Time Utility Oceanside Dana Point San Juan State Parks OCEOC SD EOC SONGS ODAC Emergency Classification Level or Event Capistrano JIC EOF FMT Declared EOC EOC EOC EOC Unusual Event N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 0800 0800 0800 0815 0815 0808 0807 0807 0806 0807 0809 0810 Site Area Emergency 1008 1008 1008 1012 1012 1017 1018 1017 1017 1017 1017 1014 General Emergency 1044 1044 1044 1048 1048 1056 1058 1056 1056 1017 1057 1054 Simulated Rad. Release 1021 1021 1021 1035 1035 1033 1024 1032 1032 1032 1032 1054 Started Simulated Rad. Release Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Terminated Facility Declared Operational 0833 0836 N/A N/A 0820 0852 0825 0846 0845 0817 0830 Declaration of Emergency: Orange N/A N/A N/A N/A 1003 N/A N/A N/A N/A N/A 1018 County Declaration of Emergency: San N/A N/A N/A N/A N/A 1026 N/A 1023 N/A N/A 1045 Diego County Declaration of Emergency: Dana N/A N/A N/A N/A N/A N/A 1018 N/A N/A N/A 1054 Point Declaration of Emergency: San Juan N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 1028 Capistrano Declaration of Emergency: San N/A N/A N/A N/A N/A N/A N/A N/A 1140 N/A 1151 Clemente Declaration of Emergency: State N/A N/A N/A N/A N/A N/A N/A N/A N/A 1003 N/A Parks and Recreation Plume Phase Terminated N/A N/A N/A N/A 1355 1354 N/A N/A N/A 1353 1347 Early Precautionary Actions: Close N/A N/A N/A N/A N/A N/A N/A 1023 N/A N/A N/A San Clemente City Beach Early Precautionary Actions: Close San Onofre State Beaches - San Mateo Campground, San Onofre 1020 1020 N/A N/A N/A N/A N/A N/A N/A 0900 0908 Bluffs Campground, San Onofre Bluffs Beach, San Onofre Bluffs Surf Beach, Trestles Beach Early Precautionary Actions: Close Doheny State Park, San Clemente N/A N/A N/A N/A N/A N/A N/A N/A N/A 1030 1048 Beach and Calafia Beach Early Precautionary Actions: Dana Point TCP personnel alerted and N/A N/A N/A N/A N/A N/A 1000 N/A N/A N/A N/A equipment staged Early Precautionary Actions: Restrict N/A N/A N/A N/A N/A 1037 N/A N/A N/A N/A N/A Air- 2500 feet, FAA notified Early Precautionary Actions: Restrict waterways 10-miles, Coast Guard N/A N/A N/A N/A N/A 1022 N/A N/A N/A N/A N/A Notified Early Precautionary Actions: Close N/A N/A N/A N/A 1105 1059 N/A N/A N/A N/A N/A 24
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After Action Report/Improvement Plan San Onofre Nuclear Generating Station DATE: 2011-04-12, SITE: San Onofre Nuclear Generating Station, CA San Clemente OCFA FMT Time Utility Oceanside Dana Point San Juan State Parks OCEOC SD EOC SONGS ODAC Emergency Classification Level or Event Capistrano JIC EOF FMT Declared EOC EOC EOC EOC Rail Traffic Early Precautionary Actions: Close 0843 0843 N/A N/A N/A N/A N/A N/A N/A N/A 0908 Parks in PAZ 1 Early Precautionary Actions: School N/A N/A N/A N/A 1036 N/A N/A N/A N/A N/A 1030 Transfers Early Precautionary Actions: Ag N/A N/A N/A N/A 1123 N/A N/A N/A N/A N/A 1125 Advisory 1st Protective Action Decision:
Evacuate State Beach and PAZ 1 & 4, 1111 1129 N/A N/A 1111 1111 1111 1111 1112 1111 1114 Ingest KI in PAZ 1 & 4 for General Public and EW 1st Siren Activation 1121 1129 N/A N/A 1121 N/A 1121 1111 1112 1111 1114 1st EAS or EBS Message 1126 1129 N/A N/A 1126 1126 1126 1121 1126 1126 1114 KI Administration Decision for EW 1111 1112 1115 1115 1111 1111 1111 1111 1140 1113 1114 KI Administration Decision for 1111 1112 N/A N/A 1111 1111 1111 1111 N/A N/A 1114 Public KI Administration Decision for EW N/A N/A N/A N/A 1140 N/A 1216 N/A N/A N/A 1022 in PAZ 5 25
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After Action Report/Improvement Plan San Onofre Nuclear Generating Station APPENDIX C : EXERCISE EVALUATORS Location Evaluator Agency SONGS Emergency Operations Facility Elsa Lopez FEMA RVI Offsite Dose Assessment Center **Daryl Thome ICF Bill Maier NRC RIV Orange County Fire Authority Field Monitoring Team Mike Howe FEMA HQ Oceanside Field Monitoring Team Jeff Clark FEMA RVII Orange County Emergency Operations Center Rebecca Fontenot FEMA HQ Melissa Savilonis FEMA RI John Woytak FEMA RIX Nan Calhoun FEMA RVI
- Joe Keller ICF Renae Connell OJT FEMA HQ Orange County Sheriffs Department Interview Rebecca Fontenot FEMA HQ Orange County Department of Public Works Rebecca Fontenot FEMA HQ Interview Orange County Transportation Authority Interview Melissa Savilonis FEMA RI San Diego County Emergency Operations Center Robert Swartz FEMA RI
- Team Leader OJT: Trainee Out-of-Sequence Interviews and Demonstrations Location Evaluator Agency California Highway Patrol / California Department of Roy Smith ICF Transportation San Diego Emergency Alert System Radio Station Roy Smith ICF Orange County Emergency Alert System Radio Roy Smith ICF Station Capistrano Unified School District Interview Roy Smith ICF Alberto Sifuentes FEMA RIX Orange County Sheriffs Department EOC Paul Anderson FEMA RIX Mobilization FEMA Region IX Senior Site Specialist, Richard Echavarria FEMA Region IX Radiological Assistance Committee Chair, Craig Fiore 26
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After Action Report/Improvement Plan San Onofre Nuclear Generating Station APPENDIX D : ACRONYMS AND ABBREVIATIONS Acronym / Abbreviation Meaning ARCA Area Requiring Corrective Action CA-DHS California Department of Health Services CalTrans California Department of Transportation CUSD Capistrano Unified School District DPW Department of Public Works EDRD Electronic Direct Reading Dosimeter EOC Emergency Operations Center EOF Emergency Operations Facility EW Emergency Worker FEMA Federal Emergency Management Agency FMT Field Monitoring Team IPC Interjurisdictional Planning Committee JIC Joint Information Center KI Potassium Iodide OC Orange County OCFA Orange County Fire Authority OCTA Orange County Transportation Agency ODAC Offsite Dose Assessment Center OROs Offsite Response Organization PAZ Protective Action Zone REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan SD San Diego SONGS San Onofre Nuclear Generating Station 27
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan San Onofre Nuclear Generating Station APPENDIX E : EXTENT-OF-PLAY Presented in this appendix is a compilation of exercise scenario materials submitted by the state of California and the SONGS. This appendix contains the extent-of-play agreement prepared by the state of California and approved by FEMA Region IX to provide evaluators with guidance on expected actual demonstration of the evaluation area criteria.
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After Action Report/Improvement Plan San Onofre Nuclear Generating Station This section contains applicable portions of the Extent-of-Play for the October 21, 2010, SONGS Mobilization Drill.
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After Action Report/Improvement Plan San Onofre Nuclear Generating Station This section contains applicable portions of the Extent-of-Play Agreement for the April 12, 2011, SONGS Plume Phase Exercise and out-of-sequence demonstrations.
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