ML11353A311

FEMA, Submittal of After Action Report for Peach Bottom Atomic Power Station Medical Services Drill Evaluated on 10/28/11

ML11353A311
Person / Time
Site:	Peach Bottom
Issue date:	12/05/2011
From:	Tierney M US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11353A311 (51)

Text

U.S. Department of Homeland Security One Independence Mall, Sixth Floor 615 Chestnut Street Philadelphia, PA 19106-4404

& FEMA DEC 0 5 2011 NRC Headquarters' Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 To Whom It May Concern:

Enclosed is the After Action Report for the Peach Bottom Atomic Power Stations (PBAPS) Medical Services (MS-I) Drill that was evaluated on October 28, 2011. The Minquas Emergency Medical Services and Brandywine Hospital participated in the drill.

There were no "Deficiencies" or "Areas Requiring Corrective Action (ARCA)" identified during the drill.

Based on the review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate and there is reasonable assurance they can be implemented, as demonstrated during the PBAPS MS-1 Drill.

If you have any questions, please contact Darrell Hammons at (215) 931-5546.

Sincerel, MaryAnn Tierney Regional Administrator Enclosure www.fema.gov

Peach Bottom Atomic Power Station After Action Report/

Improvement Plan Drill Date - October 28, 2011 Radiological Emergency Preparedness (REP) Program SFEMIA Published November 21, 2011 I

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Peach Bottom Atomic Power Station After Action Report/Improvement Plan Published November 21, 2011 Contents Executive Summary 3 Section 1: Exercise Overview 4 1.1 Exercise Details 4 1.2 Exercise Planning Team Leadership 4 1.3 Participating Organizations 5 Section 2: Exercise Design Summary 6 2.1 Exercise Purpose and Design 6 2.2 Exercise Objectives, Capabilities and Activities 11 2.3. Scenario Summary 11 Section 3: Analysis of Capabilities 12 3.1 Drill Evaluation and Results 12 3.2 Summary Results of Drill Evaluation 12 3.3 Criteria Evaluation Summaries 15 3.3.1 Pennsylvania Jurisdictions 15 3.3.1.1 Chester County, The Brandywine Hospital 15 3.3.1.2 Chester County, Minquas Ambulance 15 Section 4: Conclusion 17 Appendix A: Drill Evaluators and Team Leaders 18 Appendix B: Exercise Plan 19 1

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station EXECUTIVE

SUMMARY

On October 28, 2011 an, evaluated Medical Service (MS-i) Drill was conducted for the 10-mile Plume exposure pathway, Emergency Planning Zone (EPZ) around the Peach Bottom Atomic Power Station (PBAPS) by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Region III. The most recent prior MS-I drill for this site was conducted on April 6, 2010 (Maryland).

The purpose of the Peach Bottom MS-1 drill was to assess the State and local offsite response organization preparedness in responding to a radiological medical emergency. The drill was held in accordance with FEMA's 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 in the Commonwealth of Pennsylvania, Chester County, Brandywine Hospital and the Minquas Ambulance Company who were evaluated during this exercise.

Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility as volunteers providing vital emergency services twenty four (24) hours to the communities of which they live. Cooperation and teamwork of all the participantswas observed during this exercise.

This report contains the final evaluation of the MS-I drill. The Commonwealth of Pennsylvania, the local organizations, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies, or Areas Requiring Corrective Action (ARCAs) identified as a result of this exercise.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Peach Bottom Atomic Power Station Type of Exercise Drill Exercise Date October 28, 2011 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Michael Shuler, Sr.

Site Specialist DHS/ Federal Emergency Management Agency Technological Hazards Program Specialist 615 Chestnut Street One Independence Mall Philadelphia, Pennsylvania, 19106 215-931-5526 michael.shuler@dhs.gov Victor Wilson Exercise Planning Team Pennsylvania Emergency Management Agency.

Emergency Managment Specialist 4

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station 2605 Interstate Drive Harrisburg, Pennsylvania, 17110 717-651-2136 vicwilson@pa.gov 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Peach Bottom Atomic Power Station drill:

State Jurisdictions Pennsylvania Emergency Managment Agency Risk Jurisdictions Chester County Office of Emergency Management Private Organizations Brandywine Hospital Minquas Fire Company EMS Federal Jurisdictions Federal Emergency Management Agency 5

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume the lead responsibility for all off-site nuclear planning and response.

FEMA's activities were 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.

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:

A. Taking the lead in offsite emergency planning and in the review and evaluation of Radiological Emergency Response Plans (RERPs) and procedures developed by State and local governments;.

B. 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; C. 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. 1f76, September 14, 1993; and D. Coordinating the activities of the following 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, 6

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station

- 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 Region III Radiological Assistance Committee (RAG), which is chaired by FEMA. A REP Medical Services drill was conducted March 10, 2011, to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Peach Bottom Atomic Power Station. The purpose of this exercise report is to present the drill results -and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency involving a contaminated injured individual.

The findings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the FEMA Region III Radiological Assistance Committee (RAG) Chairperson and approved by FEMA Headquarters. These reports are provided to the NRC and participating States. State and local governments Utilize the findings contained in these reports for the purposes of planning, training, and improving emergency response capabilities.

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

A. 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; B. FEMA Guidance Memoranda MS-1, "Medical Services," Nbvember 1986; C. FEMA-REP-14, "Radiological Emergency Preparedness Exercise Manual," September 1991; D. 66 FR 47546, "FEMA Radiological Emergency Preparedness: Alert and Notification,"

September 12, 2001; and 7

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station E. 67 FR 20580, "FEMA Radiological Emergency Preparedness: Exercise Evaluation Methodology," April 25, 2002.

Section 1 of thisreport,-entitled "Exercise Overview", presents the "Exercise Planning Team" and the "Participating Organizations".

Section 2 is titled "Exercise Design Summary", and includes the "Purpose and Design",

"Exercise Objectives, Capabilities, and Activities", and the "Scenario Summary".

Section 3 of this report, entitled "Analysis of Capabilities", presents detailed "Exercise Evaluation and Results" information on the demonstration for each jurisdiction or functional entity evaluated in a jurisdiction-based, issue-only format (Criteria Evaluation Summaries).

Section 4, "Conclusion", is a description of the Region's overall assessment of the capabilities of the participating organizations. It also presents information on planning issues (both new planning issues identified during this exercise and resolved planning issues identified during previous exercises).

This section also contains:

(1) descriptions of all Deficiencies and Areas Requiring Corrective Action (ARCAs) assessed during this exercise, recommended corrective actions, and the Tribal, State, and local governments' schedule of corrective actions for each identified exercise issue and (2) descriptions of ARCAs assessed during previous exercises and resolved at this exercise, including the corrective action demonstrated, as well as ARCAs assessed during previous exercises and scheduled for demonstration at this exercise which remain unresolved.

The final section of the report is comprised of the appendices, which present the following supplementarylinformation: Improvement Plan, Exercise Timeline, Exercise Evaluators and Team Leaders, Acronyms andAbbreviations, and Exercise Plan as required.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station The following is a basic description of the plume exposure Emergency Planning Zone (EPZ).

Exelon Nuclear owns and operates the Peach Bottom Atomic Power Station (PBAPS). The station consists of one 40-megawatt (MW), high-temperature, gas-cooled reactor (Unit 1),

decommissioned in October 1974, and two operating boiling water reactors (Units 2 and 3) rated at 1,065 MW per unit. The operating licenses for the facility were granted in October 1973 (Unit

2) and July 1974 (Unit 3); commercial operation began at the site in July 1974 (Unit 2) and December 1974 (Unit 3).

The coordinates of the plant site are 39045'32" north (latitude) by 76'16'9" west (longitude).

The site consists of 620 acres located on the west shore of Conowingo Pond, a reservoir formed by the backwater of the Conowingo Dam on the Susquehanna River. The site is primarily in Peach Bottom Township; York County/ Pennsylvania; a small portion of the property lies in Lancaster County in southeastern Pennsylvania near the mouth of Rock Run Creek. The minimum exclusion distance (distance from the center point of the reactorvessel to the site area boundary) specified for the PBAPS is 2,700 feet. Exelon Nuclear owns all the land within the exclusion area; there are no private residences on site.

The plant is located about 38 miles north-northeast of Baltimore, Maryland; 45 miles southeast of Harrisburg, Pennsylvania; and 20 miles south-southeast of Lancaster, Pennsylvania. The nearest communities are Delta, Pennsylvania, and Cardiff, Maryland, which are located approximately four and five miles west-southwest of the site, respectively.. There are 97 sirens providing coverage for the 10-mile EPZ; 65 are in Pennsylvania. Soils of the Manor-Glenelg Association predominate in the site area. These soils, which are generally underlain by schist or phyllite, are shallow to moderately deep and are found on moderate to very steep slopes. The general topography of the site is hilly, with elevations ranging from '11Ofeet to over 460 feet above mean sea level (MSL); the plant is 116 feet above MSL.

The site is characterized by broad ridge tops and steep hillsides along the river. The climate in this area of York County is mild but humid. Prevailing winds are from the west. The average rainfall is approximately 40.5 inches, and the average annual temperature is 52.8' Fahrenheit.

The area in the immediate vicinity of the plant is mostly agricultural. There are no commercial airports within a 10-mile radius. The closest major airport is in Harrisburg, about 50 miles northwest of the site.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station A smaller airport servicing commuter and private aircraft is located in Lancaster, about 25 miles north of the site. No public highways pass through the plant, and no major arterial highways pass near it. Access to the plant is by two roads: one, from the nearby town of Delta, leads to the decommissioned Unit 1 area and Information Center; the other passes north of Delta and enters the plant area near Units 2 and 3.

The 10-mile EPZ for PBAPS, with a total risk population of approximately 57,645, covers the following jurisdictions:

Commonwealth of Pennsylvania Chester County West Nottingham Township Lancaster County Drumore Township.

East Drumore Township Fulton Township Little Britain Township Martic Township Providence Township Quarryville Borough York County Delta Borough, Peach Bottom Township,:

Fawn Township Fawn Grove Borough Lower Chanceford Township State of Maryland Cecil County Harford County 10 0

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station 2.2 Exercise Objectives, Capabilities and Activities The Peach Bottom Atomic Power Station 2011 Medical Services drill was a Functional Exercise (FE) evaluated by the Federal Emergency Management Agency designed to demonstrate the capabilities of State and local emergency management agencies to technically assess the extent of the radiological impact from a contaminated injured individual including transport and receipt at a hospital. The demonstration includes the ability to:

A. Demonstrate the ability to respond to a radiation medical emergency following the procedures of Chester County Division of Emergency Medical Services Paramedics, Minquas Fire Company/EMS and the Brandywine Hospital.

B. Demonstrate timely and accurate communications between the hospital and offsite response agencies. (Telephones will be used in lieu of radios whenever possible to limit the potential misinterpretation of the drill as an actual event.)

C. Demonstrate correct priorities and appropriate techniques in EMS, transportation of patients and pre-hospital and hospital emergency care of radioactively contaminated patients.

D. Demonstrate inter-agency cooperation between Minquas Ambulance Company/ EMS and the Hospital.

2.3 Scenario Summary The exercise scenario for this Drill consisted of simulated notifications of escalating emergency classification levels at Peach Bottom Atomic Power Station (PBAPS) from Site Area Emergency to General Emergency. Subsequent to being notified of the General Emergency,: the 911 Center informed the Brandywine Hospital that an incident had occurred at a decontamination center resulting in injury and possible radiological contamination of an emergency worker. The Brandywine Hospital implemented its plan to prepare a Radiation Emergency Area (REA) to receive and treat the patient and activated its radiation emergency medical team. The patient had lost control of his vehicle and hit autility pole. The victim is conscious and complaining of lower back pain. The Minquas Ambulance Company was dispatched to provide medical support and transport to the nearest MS-I Hospital.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Drill Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the October 28, 2011, Medical Services Radiological Emergency Preparedness (REP) Exercise. The exercise was conducted to, demonstrate the ability of the Offsite Response Organization to response to a potentially radiological contaminated injured person associated with the Peach Bottom Atomic Power Station.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the Exercise Evaluation Area Criteria contained in the REP Exercise Evaluation Methodology.

Detailed information on the exercise evaluation area criteria and the Extent-of-Play agreement are found in Appendix B.

3.2 Summary Results of Drill Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Exercise Evaluation Methodology that was 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 the criteria is indicated by the use of the following letters:

(D) Deficiency: 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.

(A) Area Requiring Corrective Action (ARCA): an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.

(P) Plan Issue: an observed or identified inadequacy in the ORO's emergency plan or implementing procedures, rather than in the ORO's performance. Plan Issues are not exercise issues and are required to be corrected through the revision of the appropriate plans or 12 0

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station procedures during the next annual plan review and update, submitted for FEMA review, and reported in the State Annual Letter of Certification.

(N) Not Demonstrated: term applied to the status of a REP exercise Evaluation Area Criterion indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area Criterion, as required in the extent-of-play agreement or at the two -year or six-year interval required in the FEMA REP Program Manual.

(M) Met: status of a REP exercise Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the extent of-of-play agreement with no Deficiencies or ARCAs assessed in the current exercise and no unresolved prior ARCAs.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Table 3.1 - Summary of Drill Evaluation DATE: 2011-10-28 SITE: Peach Bottom Atomic Power Station, PA Q U M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated U U Emergency Operations Management Mobilization 1al Facilities Ibl Direction and Control Ict Communications Equipment Id1 Equip & Supplies to support operations lel M Protective Action Decision Making Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2b 1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and Return 2el Protective Action Implementation Implementation of emergency worker exposure control 3al M M Implementation of KI decision 3bl Implementation of protective actions for special populations - EOCs 3c1 Implementation of protective actions for Schools 3c2 Implementation of traffic and access control 3dl Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3fl Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laboratory operations 4c0 Emergency Notification and Public Info Activation of the prompt alert and notification system 5al Activation of the prompt alert and notification system - Fast Breaker 5a2 0 Activation of prompt alert and notification system-Excptn Areas/Bkup RA 5a3 Emergency information "arid instructions for the public and the media 5bl Support Operations/Facilities Mon/decon of evacuees and emergency workers, and registration of evacuees 6a 1 Mon/decon of emergency worker equipment' 6b I Temporary care of evacuees 6c 1 Transportation and treatment of contaminated injured individuals 6dl M M 14 0

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station 3.3 Criteria Evaluation Summaries 3.3.1 Pennsylvania Jurisdictions 3.3.1.1 Chester County, The Brandywine Hospital In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.e.1, 3.a.1, 6.d.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 Chester County, Minquas Ambulance In summary, the status of DHS/FEMA Criteria for this location is as follows:

a. MET: 3.a.1, 6.d.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 6.d. 1.

ISSUE NO.: 46-05-6dl-A-01 ISSUE: The Minquas ambulance Emergency Medical Tecchcians, (EMT's)failed to prevent the potential spread of radioactive contamination from the injured evacuee to the restricted area around the patient by not instituting proper contamination control measures. All Emergency Medical Technicians initially made contact with the patient before determining from the facility supervisor where and if any contamination was present. The crew laid their equipment bag on the ground next to the patient and brought in the stretcher from the ambulance into a potentially contaminated area. The patient was not properly cocooned prior to being loaded into the ambulance for transport to the hospital. The Minquas fire department does not 15

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After Action Report/improvcmcnt Plan Peach Bottom Atomic Power Station maintain any radiological detection equipment or dosimetry. Equipment is provided by the County to the Brandywine Hospital.

CORRECTIVE ACTION DEMONSTRATED: The Minquas Fire Company/Emergency Medical Services (EMS) successfully demonstrated their ability to reduce potential spread and cross contamination from an injured evacuee.

The Emergency Medical Team (EMT)demonstrated creating a laydown area used to provide a controlled space to place equipment and cocoon the patient. The EMT's also successfully demonstrated exterior glove changes and described they would expand the restricted area if they suspected the area was potentially contaminated.

g. PRIOR ISSUES - UNRESOLVED: None 16 0

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania, and local jurisdictions except where noted in this report, demonstrated knowledge of their Radiological Emergency Response Plans (RERP) and procedures during the Peach Bottom Atomic Power Station, Medical Services drill and adequately implemented them.

Three (3) Federal Emergency Management Agency (FEMA) evaluators provided analyses of 5 evaluation criteria. These analyses resulted in a determination of no Areas Requiring Corrective Action (ARCA and no new Planning Issues were assessed. There were no unresolved issues or re-demonstration. A prior ARCA from the Demonstration in 2005 was corrected and closed as part of this evaluation.

Based on the review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate and there is a reasonable assurance they can be implemented, as demonstrated during the Peach Bottom Atomic Power Medical Services drill.

An After Action Improvement Plan (IP) will not developed as part of this report 17

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station APPENDIX A: DRILL EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leaders for the Peach Bottom Atomic Power Station 2011 Medical Services Exercise evaluated on October 28, 2011. The following constitutes the managing staff for the Exercise Evaluation:

" Darrell Hammons, DHS/ FEMA, Radiological Assistance Committee Chairman

" Michael E. Shuler, Sr., DHS/ FEMA, Exercise Evaluation Program Manager and Site Specialist

" Robert Neff, DHS/ FEMA, Evaluator

" Martin Vyenielo, DHS/ FEMA, Evaluator DATE: 2011-10-28, SITE: Peach Bottom Atomic Power Station, PA LOCATION EVALUATOR AGENCY Chester County, The Brandywine Hospital *Michael Shuler Department of Joseph Suders Homeland Security FEMA RII Chester County, Minquas Ambulance Robert Neff FEMA RIII

• Team Leader 18 0

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station APPENDIX B: EXERCISE PLAN The enclosed Exercise Plan was created as an overall tool for facilitation and implementation of the Peach Bottom Atomic Power Station 2011 Medical Services drill and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program Exercise Methodology.

The Exercise Plan was originally drafted and published by the Federal Emergency Agency (FEMA) as an independent document and is annexed here. The Peach Bottom Atomic Power Station Extent of Play was negotiated and agreed upon by FEMA Region III, Pennsylvania Emergency Management Agency (PEMA). The Extent of Play (EOP) is included as an Appendix of the Exercise Plan.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill PREFACE The 2011 Peach Bottom Atomic Power Station Evaluated Medical Services Drill (MS-i) is sponsored by Pennsylvania Emergency Management Agency (PEMA) and the Federal Emergency Management Agency (FEMA). This Exercise Plan (ExPlan) was produced with input, advice, and assistance from the Exercise Planning Team (EPT), which followed the guidance set forth in the Federal Emergency Management Agency (FEMA), Homeland Security Exercise and Evaluation Program (HSEEP).

The ExPlan gives officials, observers, media personnel, and players from participating organizations the information necessary to observe or participate in a nuclear power plant accident response exercise focusing on participants' emergency response plans, policies, and procedures as they pertain to this type of event. The information in this document is current as of the date of publication and is subject to change as dictated by the EPT.

The 2011 Peach Bottom Atomic Power Station MS-I Drill is an unclassifiedexercise. The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, Controllers, and Evaluators, but Players may view other materials deemed necessary to their performance. The ExPlan may be viewed by all exercise participants, but the Controllerand Evaluator(C/E) Handbook is a restricteddocument intendedfor Controllers and Evaluators only.

All exercise participants should use appropriate guidelines to ensure the proper control of information within their areas of expertise and to protect this material in accordance with current jurisdictional directives. Public release of exercise materials to third parties is at the discretion of Department of Homeland Security (DHS) and the EPT.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Servicos Drill HANDLING INS TRUCTIONS

1. The title of this document is 2011 Peach Bottom Atomic Power Station MS-I Exercise Plan (ExPlan).

2. At a minimum, the attached materials will be disseminated only on a need-to-know basis and when unattended, will be stored in an area offering sufficient protection against theft, compromise, inadvertent access, and unauthorized disclosure.

3. For more information, please consult the following points of contact (POCs):

Federal POC(s):

Michael E. Shuler, Sr, Project Officer & Site Specialist Department of Homeland Security (DHS)

Federal Emergency Management Agency (FEMA) 615 Chestnut Street One Independence Mall Philadelphia, Pennsylvania 215.931.5526 michael.shuler~dhs.,gov State POC(s):

Victor Wilson, Exercise Planner Pennsylvania Emergency Management Agency (PEMA) 2605 Interstate Drive Harrisburg, Pennsylvania 17110 717.651.2136 vicwilson(Zpa.gov 23

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan. Medical Services Drill TABLE OF CONTENTS Exercise Plan Peach Bottom Atomic Power Station FEMA Evaluated REP Exercise US. DEPARTMENT OF HOMELAND SECURITY Preface ......................................... ................................................................................................... 22 Handling Instructions ......................  !.......................... 23 Chapter 1: General Information ............................................................................................ 26 In tro du ctio n ................................................................................................................................. 26 Con fi dentiality ........................................................................................................................ 26 P urp ose ......................................................................................................................................... 26 Target Capabilities........................................... ... ..................................... 27 E xercise Objectives .................... ........ * . . .......................................... .......... 27 O utstanding Issues ............................................................................................................... ......... 28 Chapter 2: Exercise Logistics ........................................... 29 E xercise Sum m ary ..:.................. .. ........................................... ....... ...... ........... ....... ........ . ..... 29 G en era l .................................................................................................................................. 29 Assumptions ....... ....................... .... ..................... 29 Constructs and Constraints .............. ................................ 29 Exercise Participants .............................................. 30 E xercise T ools ............................ :................. ................................................................... . . . 31 Controller and Evaluator Handbook ........................................................... 31 Master Scenario Events List ......................................... 31 Exercise Implementation ............................................... .................................................. 31 E x ercise Play .*.:...................  :.: ........................................................................................... 31 Exercise Rules,....; ................................................................. .......... ........ 31 Safey Requirements ........................................................................................................... 32 G eneral ................................................................................................................................. 32 E x ercise S etup ...................................................................................................................... 32 Accident Reporting and Real Emergencies ....................................... 33 S ite Access ................................................................................................................................. 33 S ecurity .................................................................... ................................................... . . 33 Observer Coordination ................................................................................................... 33 Parking and Directions ...................................................................................................... 34 Exercise Identification .......................................................................................................... 34 24

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill Com munications Plan .......................................................................................................... 34 Exercise Start, Suspension, and Termination Instructions......................... 34 Player C om munication ...................................................................................... ............... 34 P layer B riefi ng ...................................... ........ ................................................................ . . 34 E xternal Affairs..... ......................................... " .......... ..................... ... .................... 34 Chapter 3: Player Guidelines ... ,......................................... o..... 35 Exercise Staff ............................................................... 35 E xercise Director ................................................................................................................... 35 Trusted A gents .................................................................... . ............. i.......... ........ 35 L ead C ontroller ...... ............................................................. ......... ............. .....-....... ...... 35 C ontro llers ............................................................................................................................ 35 Lead Evaluator .................................................... . ....I........... .................. 35 E v alu ators ................................. ............................................................................................ 36 Player Instructions ...................... ..... ......................... 36 B efore the Exercise ............................................................................................ 36 During the Exercise ...................................... ......... 36 Follow ing the Exercise .................................................................................................... 37 Sim ulation Guidelines, ......... ........... ......... ...... .... .. ......................... 37 Chapter 4: Evaluation and Post-Exercise Activities ........................................................... 38 Exercise Docum entation ...................................................................................................... 38 D eb riefi n g ...................................... I........................................................................................... 38 Participants and Public/Media Briefing .................................... 38 A fter A ction R eport .............................................................. . ...... . ................... ... ............. 38 After Action Conference and Improvement Plan .............................. 38 After Action Conference ........................................... 38 Improvement Plan ..................................... ........... 38 Appendix A: Exercise Schedule ........................................................................................... 39 Appendix B: Extent of Play Information ......... ....................................................... ............ 40 25

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill CHAPTER 1: GENERAL INFORMATION Introduction The 2011 Peach Bottom Atomic Power Station Medical Services Drill is a Functional Exercise (FE) designed to establish a learning environment for players to exercise emergency response plans, policies, and procedures as they pertain to Nuclear Power Plant accidents. A Functional Exercise is a complex event that requires detailed planning. To conduct an effective exercise, subject matter experts (SMEs) and local representatives from numerous agencies have taken part in the planning process and will take part in exercise conduct and evaluation.

This Exercise Plan (ExPlan) was produced at the direction of the Federal Emergency Management Agency with the input, advice, and assistance of the Commonwealth of Pennsylvania. The 2011 Peach Bottom Atomic Power Station Medical Services Drill is evidence of the growing partnership between State and local jurisdictions for response to the threats our Nation and communities face.

Confidentiality The 2011 Peach Bottom Atomic Power Station Medical Services Drill is an unclassified exercise. The control of information is based more on public sensitivity regarding the nature of the exercise than'on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, controllers, and evaluators, but players may view other materials deemed necessary to their performance. This Exercise Plan may be viewed by all exercise participants, but the Controllerand Evaluator (CIE) Handbook is a restricteddocument intendedfor controllersand evaluatorsonly.

All exercise participants should use appropriate guidelines to ensure the proper control of information within their areas of expertise and protect this material in accordance with current Federal, State and Local directives.

Public release of exercise materials to third parties is at the discretion of the Federal Emergency Management Agency (FEMA) and the Exercise Planning Team.

Purpose The purpose of this exercise is to evaluate player actions against current response plans and capabilities for a nuclear power plant-related incident, and to comply with the requirements of 44 CFR 350 and the guidelines of NUREG 0654/FEMA-REP-1. Exercise planners utilized the elements described in the 67 FR 20580 (April 25, 2002) and Interim Radiological Emergency Preparedness (REP) Program Manual (August 2002) to develop this exercise.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill The objective of The Federal Emergency Management Agency and, The Pennsylvania Emergency Management Agency, and local jurisdictions is to demonstrate reasonable assurance that the public can be protected during a nuclear power plant emergency.

Target Capabilities The establishment of the National Preparedness Priorities have steered the focus of homeland security toward a capabilities-based planning approach. Capabilities-based planning focuses on planning under uncertainty, since the next danger or disaster can never be forecast with complete accuracy. Therefore, capabilities-based planning takes an all-hazards approach to planning and preparation which builds capabilities that can be applied to a wide variety of incidents. States and urban areas use capabilities-based planning to identify a baseline assessment of their homeland security efforts by comparing their current capabilities against the Target Capabilities List (TCL) and the critical tasks of the Universal Task List (UTL). This approach identifies gaps in current capabilities and focuses efforts on identifying and developing priority capabilities and tasks for the jurisdiction. These priority capabilities are articulated in the jurisdiction's homeland security strategy and Multi-Year Training and Exercise Plan (TEP), of which this exercise is a component of.

from the priority The capabilities listed below have been selected by the Exercise Planning Team capabilities identified in Commonwealth of Pennsylvania Multi-Year TEP and the FEMA Interim Radiological Emergency Preparedness Program Manual (August 2002), Exercise Evaluation Criteria. These capabilities provide the foundation for development of the exercise objectives and scenario, as the purpose of this exercise is to measure and validate performance of these capabilities and their associated critical tasks.

• Planning

• Communications

• Community Preparedness and Participation

• WMD/HazMat Response ad Decontamination

• Emergency Triage and Pre-Hospital Treatment

• Medical Supplies Management and Distribution Exercise Objectives The Emergency Preparedness Evaluation Areas - the elements and sub elements - for this drill are those that are required to be demonstrated in every MS-I Drill, per 67 FR 20580 (April 25, 2002) and the Interim Radiological Exercise Preparedness (REP) Program manual (August 2001). Appendix B, Extent of Play, Shows the emergency preparedness elements that are required to be demonstrated in the 2011 Peach Bottom Atomic Power Station Medical Services Drill, along with the level of demonstration that will be displayed in the exercise (i.e., fully demonstrated limited demonstration, simulated, Out Of Sequence interviews, not demonstrated).

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill The objective of this exercise islto demonstrate reasonable assurance that the health and safety of the public can be protected, through successful demonstration of tasks identified in Appendix B.

Outstanding Issues There are no prior deficiencies, no planning issues, but one Area Requiring Corrective Action (ARCAs), as a result of the FEMA-evaluated plume-phase exercise at Brandywine Hospital MS-1 Drill conducted August 17, 2005:

Issue No.: 46-05-6.d.1-A-01 CONDITION: The Minquas ambulance crew failed to prevent the potential spread of contamination from the injured evacuee and the area by not instituting proper contamination control measures. All crew members initially had contact with the patient before determining from the facility supervisor where and if any contamination was present. The crew laid their equipment bag on the ground next to the patient and brought in the stretcher into a potentially contaminated area. The patient was not properly cocooned prior to being loaded into the ambulance for transport to the hospital.

POSSIBLE CAUSE: The Minquas crew participating did not have training prior to the exercise.

REFERENCE:

NUREG-0654, L. 1 EFFECT: Equipment and personnel could have been contaminated and out of service while decontamination takes place. Personnel could have received dose from being contaminated due to improper contamination control procedures.

RECOMMENDATION: Ambulance crew should attend classes on proper handling of potentially contaminated patients and control of potentially contaminated areas.

CORRECTIVE ACTION TO BE DEMONSTRATED: The ambulance crew will be trained on proper handling of potentially contaminated patients and control of potentially contaminated areas.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill CHAPTER 2: EXERCISE LOGISTICS Exercise Summary General The 2011 Peach Bottom Atomic Power Station Medical Services Drill is designed to establish a learning environment for players to exercise their plans and procedures for responding to a terrorist incident. The 2011 Peach Bottom Atomic Power Station Medical Services Drill will be conducted on October 28, 2011. The demonstration is scheduled between 12:30pm and 3:30pm or, until the Lead Controller after consulting with the FEMA Site Specialist, determine that the exercise objectives have been met at each venue.

Assumptions Assumptions constitute the implied factual foundation-for the exercise and, hence, are assumed to be present before the start of the exercise. The following general assumptions apply to the 2011 Peach Bottom Atomic Power Station MedicalServices Drill:

• The exercise will be graded against the REP criteria. Elements outside the scope of the REP criteria will not be graded.

• This exercise will be conducted in a no-fault learning environment wherein systems and processes, not individuals, will be evaluated.

" Exercise simulation will be realistic and plausible, containing sufficient detail from which to respond.

• Exercise players will react to the information and situations as they are presented, in the same manner as if this had been a real event.

Constructs and Constraints Constructs are exercise devices designed to enhance or improve exercise realism. Alternatively, constraints are exercise limitations that may detract from exercise realism., Constraints maybe the inadvertent result of a faulty construct or may pertain to financial and staffing issues.

Although there are a number of constructs and constraints (also known as exercise artificialities) for any exercise, the EPT recognizes and accepts the following as necessary:

• Exercise communication and coordination will be limited to the participating exercise venues.

• Communication methods may include telephone, mobile telephone, radio, and other method made available for players to use during the exercise.

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• Out-of-Sequence play is allowed.

• Certain simulations are allowed.

The participating agencies may need to balance exercise play with real-world emergencies. It is understood that real-world emergencies will take priority.

Exercise Participants The following are the categories of participants involved in this exercise; note that the term "participant" refers to all categories listed below, not just those playing in the exercise:

" Players. Players are agency personnel who have an active role in responding to the simulated emergency and perform their regular, roles and responsibilities during the exercise. Players initiate actions that will respond to and mitigate the simulated emergency.

• Controllers. Controllers set up and operate the exercise site; plan and manage exercise play; act in the roles of response individuals and agencies not playing in the exercise.

Controllers direct the pace of exercise play and routinely include members from the exercise planning team. They providekey data to players and may prompt or initiate certain player actions to ensure 'exercise continuity.

" Evaluators. Evaluators are chosen to evaluate and provide feedback on a designated functional area of the exercise. They are chosen based on their expertise in the functional area(s) they have been assigned to review during the exercise and their familiarity with local emergency response procedures. Evaluators assess and document participants' performance against established emergency plans and exercise evaluation criteria, in accordance with HSEEP standards and within the bounds of REP Program guidance and regulations. They are typically chosen from amongst planning committeermembers or the agencies/organizations that are participating in the exercise. FEMA Evaluators will not serve as Controllers.

" Actors. Actors are exercise participants who act or simulate specific roles during exercise play. They are, typically volunteers who have been recruited to play the role of victims or other bystanders.

• Observers. Observers visit or view selected segments of the exercise. Local Observers do not play in the exercise, and do not perform any control or evaluation functions. Local Observers will view the exercise from a designated observation area and will be asked to remain within the observation area during the exercise. PEMA observers may be present at selected locations as assigned by the Lead Controller. VIPs or other visitors will be handled by each agency or location (Municipal EOC, County EOC, etc.) according to those agencies' policies and procedures.

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• Media Personnel. Some media personnel may be present as observers pending approval by the Pennsylvania Emergency Management Agency (PEMA).

• Support Staff. Exercise support staff includes individuals who are assigned administrative and logistical support tasks during the exercise (i.e. registration, catering, etc.

Exercise Tools Controller and Evaluator Handbook The 2011 Peach Bottom Atomic Power Station Medical Services Drill C/E Handbook is designed to help exercise Controllers and evaluators conduct and evaluate an effective exercise.

This Handbook also enables Controllers and Evaluators to understand their roles and responsibilities in exercise execution and evaluation.

Master Scenario Events List The MSEL outlines benchmarks, as well as injects that drive exercise play. It also details realistic input to the exercise players as well as information expected to emanate from simulated organizations (i.e., those nonparticipating organizations, agencies, and individuals who would usually respond to the situation). An inject will include several items of information, such as inject time, intended recipient, responsible controller, inject type, a short description of the event, and the expected player action.

For the 2011 Peach Bottom Atomic Power Station Medical Services Drill the MSEL will not be used.

Exercise Implementation Exercise Play Exercise play will begin at approximately 1230 with a situation update going to each participating venue. Play will proceed according to the events outlined in the scenario, in accordance with established plans and procedures. The exercise will conclude upon the completion of operations and attainment of the exercise objectives, as determined by the Lead Controller after consultation with Lead FEMA Evaluator.,

Exercise Rules The following are the general rules that govern exercise play:

• Real-world emergency actions take priority over exercise actions.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill

• Exercise participants will comply with real-world response procedures, unless otherwise directed by control staff.

• All communications (written, radio, telephone, etc.) made during the exercise will begin and end with the phrase, "This is a drill."

Exercise participants placing telephone calls or initiating radio communication must identify the organization, agency, office, and/or individual with whom they wish to speak.

Safety Requirements General Exercise participant safety takes priority over exercise events. Although the organizations involved in the 2.01 ! Peach Bottom Atomic Power Station Medical Services Drill come from various response agencies, they share the basic responsibility for ensuring a safe environment for all personnel involved in the exercise. In addition, aspects of an emergency response are dangerous. Professional health and safety ethics should guide all participants to operate in their assigned roles in the safest manner possible. The following general requirements apply to the exercise:

• All exercise controllers, evaluators, and staff will serve as safety observers while the exercise activities are underway. Any safety concerns must be immediately reported to the Lead Controller.'

• Participants will be responsible for their own and each other's safety during the exercise.

It is the responsibility of all persons associated with the exercise to stop play if, in their opinion, a real safety problem exists. Once the problem is corrected, exercise play can be restarted.

• All organizations will comply with their respective environmental, health, and safety plans and proceduires, as well as the appropriate Federal, State, and local environmental health and safety regulations.

Exercise Setup

Exercise setup involves the pre-staging and dispersal of exercise materials; including registration materials, documentation, signage, and other equipment as appropriate.

Accident Reporting and Real Emergencies

• Anyone observing a participant who is seriously ill or injured will first advise the nearest controller to call 91 l,and state "This is not a Drill" prior to explaining the injury or illness then if possible, renders aid, provided the aid does not exceed his or her training.

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" The controller who is made aware of a real emergency will initiate the broadcast "This Is Not A Drill" on the controller radio network or telephone, providing the following information to the Lead Controller and Exercise Director:

o Venue/function o Location within the venue/function o Condition o Requirements

• If the nature of the emergency requires a suspension of the exercise atthe venue/function, all exercise activities at that facility will immediately cease. Exercise play may resume at that venue/function once the "Real-World Emergency" situation has been addressed.

• Exercise play at other venue/functions should not cease if one venue/function has declared a "Real-World Emergency" unless they are reliant on the affected venue.

" If a real emergency occurs that affects the entire exercise, the exercise may be suspended or terminated at the discretion of the Exercise Director and Lead Controller.

Site Access Security The Lead Controller or Exercise Director will control entry to the exercise venues. To prevent confusion and interruption of the exercise, access to the exercise sites will be limited to exercise participants only. Players should advise their venue's controller or evaluator if an unauthorized person is present. Each organization should follow its internal security procedures, augmented as necessary to comply with exercise requirements.

Observer Coordination Each organization with observers will coordinate with the Lead 'Controller or Exercise Director for access to the exercise site. Observers will be escorted to an observation area for orientation and conduct of the exercise. All observers will be asked to remain within the designated observation area during the exercise. Exercise Director and/or the Observer Controller will be present to explain the exercise program and answer questions for the observers during the exercise.

Parking and Directions Parking information and directions to each venue area are available from the Lead Controller.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill Exercise Identification Players, Controllers and Evaluators will display the agency issued Identification badges while the exercise is in play.

Communications Plan Exercise Start, Suspension, and Termination Instructions The exercise is scheduled to run for about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or until the Lead Controller after consultation with the Lead Evaluator determines that the exercise objectives have been met. The Lead Controller will announce the exercise suspension or termination.

Player Communication Players will use routine, in-place agency communication systems. Additional communication assets may be made available as the exercise progresses. The need to maintain capability for a real-world response may preclude the use of certain communication channels or systems that would usually be available for an actual emergency incident. In no instance will exercise communication interfere with real-world emergency communications. Each venue will coordinate its own internal communication networks and channels.

The primary means of communication among, Controllers, and the venues will be telephone.

Player Briefing Controllers/Evaluators may be required to read specific scenario details to the participants to begin exercise play. They may also have technical handouts or other materials to give to players in order to better orient them to the exercise environment.

External Affairs Any participation by actual media shall be coordinated through the FEMA Office of External Affairs.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill Chapter 3: Player Guidelines Exercise Staff Exercise Director The Exercise Director has the overall responsibility for planning, coordinating, and overseeing all exercise functions. The Exercise Director for the 2011 Peach Bottom Atomic Power Station Medical Services Drill is the Lead Controller who will manage the exercise activities and maintain a close dialogue with the Controllers regarding the status of play and the achievement of the exercise design objectives.

Trusted Agents Trusted agents are exercise planners and participants who0,ae responsible for developing the Scenario and the Master Scenario Events List (MSEL). These documents are restricted and are not available to other members of the Exercise Planning Team, Players, or other Participants.

The trusted agents for the 2011 Peach Bottom Atomic Power Station MS-I Drill include the Exercise Director, Lead Controller, Exelon Nuclear, Chester County Office of Emergency Management, and the FEMA Site Specialist.

Lead Controller The Lead Controller is responsible for the overall organization of the 2011 Peach Bottom Atomic Power Station MS-1 Drill. The Lead Controller monitors exercise progress and coordinates decisions regarding deviations or significant changes to the scenario caused by unexpected developments during play. The Lead Controller monitors actions by individual Controllers and ensures they implement all designated and modified actions at the appropriate time. The Lead Controller debriefs the Controllers after the exercise and oversees the setup and takedown of the exercise.

Controllers At least one controller will be onsite with every facility participating in the drill. The Lead Facility Controller at each location will coordinate any changes that impact the scenario or affect other areas of play through the Lead Controller. The individual controllers issue exercise materials to players as required and monitor the exercise timeline. Controllers also provide injects to the players as described in the scenario.

Lead Evaluator The Lead Evaluator is responsible for the overall evaluation of the 2011 Peach Bottom Atomic Power Station MS- 1 Drill. The Lead Evaluator monitors exercise progress and stays in contact 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvcment Plan Peach Bottom Atomic Power Station Exercise Plan * - Medical Services Drill with the Lead Controller regarding changes to the exercise during play. The Lead Evaluator monitors actions of individual Evaluators and ensures they are tracking progress of the players in accordance with the Overview of Play. The Lead Evaluator debriefs the evaluators after the exercise and oversees the entire evaluation and After Action process. The Lead Evaluator will be the FEMA Region III Site Specialist for Peach Bottom Atomic Power Station.

Evaluators Evaluators work under the direction of the Lead Evaluator, and as a team with Controllers.

Evaluators are SMEs who record events that take place during the exercise and assess/submit documentation for review and inclusion in the After Action Report (AAR). Evaluators should refrain from any direct interaction With the players during exercise play except with the facilitation of a Controller for clarification of issues or during scheduled interviews.

Player Instructions Before the Exercise

• Review the appropriate emergency plans, procedures, and exercise support documents.

• Be at the appropriate site at least 30 minutes before the start of the exercise. Wear appropriate uniform/identification badge.

• If you gain knowledge of the scenario before the exercise, notify a controller so that appropriate actions can be taken to ensure a valid evaluation.

" Read your Player Information Handout, which includes information on exercise safety.

• Please sign in.

During the Exercise

• Respond to the exercise events and information as if the emergency were real, unless otherwise directed by an exercise controller.

Controllers will only give you information they are specifically directed to disseminate.

You are expected to obtain other necessary information through existing emergency information channels.

" Do not, engage in personal conversations with controllers, evaluators, observers, or media personnel while the exercise is in progress. If you are asked an exercise-related question, give a short, concise answer. If you are busy and cannot immediately respond, indicate so, but report back with an answer at the earliest time possible.

• If you do not understand the scope of the exercise or if you are uncertain about an organization's or agency's participation in an exercise, ask a controller.

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• Parts of the scenario may seem implausible. Recognize that the exercise has objectives to satisfy and may require the incorporation of unrealistic aspects. Note that every effort has been made by the trusted agents to balance realism with safety and the creation of an effective learning and evaluation environment.

" All exercise communication will begin and end with the phrase "This is an exercise.'.

This is a precaution taken so anyone overhearing the conversation will not mistake the exercise play for a real-world emergency.

" When communicating with any venue, identify the organization, agency, office, and/or individual with which you want to speak.

" Verbalize out loud when taking an action. This will ensure that evaluators are made aware of critical actions as they occur.

• Maintain a log of your activities. Many times, this log may include documentation of activities missed by a controller or evaluator.

Following the Exercise

• At the end of the exercise at your facility, participate in the debrief with the controllers and evaluators.

• Complete the Participant Feedback Form as required. This form allows you to comment candidly onemergency response activities and effectiveness of the exercise. Please provide the completed form to a controller or evaluator.

• Provide all rosters, sign in sheets, logs, messages, notes or materials generated from the exercise to your controller or evaluator for review and inclusion in the After Action Report (AAR).

Simulation Guidelines Because the 2011 Peach Bottom Atomic Power Station MS- 1 Drill is of limited duration and scope, the physical description of what would fully occur at the incident sites and surrounding areas will be relayed to the Players by Simulators or Controllers.

If a real emergency occurs during the exercise, the exercise at your respective venue may be suspended or terminated at the discretion of the controller(s) at eachvenue. If a real emergency occurs, say "Real-World Emergency" and notify the nearest Controller and Evaluator.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill CHAPTER 4: EVALUATION AND POST-EXERCISE ACTIVITIES Exercise Documentation The goal of the 2011iPeach Bottom Atomic Power Station MS-I Drill is to comprehensively exercise and evaluate the OROs' plans and capabilities as they pertain to a potential nuclear power plant incident. After the exercise, data collected by Controllers, Evaluators, and Players will be used to identify strengths and areas for improvement in the context of the exercise design objectives.

Debriefing Immediately following the completion of exercise play, Controllers will facilitate a debrief with Players from their assigned location. The debrief is an opportunity for Players to voice their opinions on the exercise and their own performance. At this time, Evaluators can also seek clarification on certain actions and what prompted Players to take them. The debrief should not last more than 30 minutes. Evaluators should take notes during the debrief and include these observationsin their analysis.

After Action Report The AAR is the culmination of the exercise. It is a written report outlining the strengths and areas for improvement identified during the exercise. The AAR will include the timeline, executive summary, scenario description, mission outcomes, and capability analysis. The AAR will be drafted by a core group of individuals from the exercise planning team.

After Action Conference and Improvement Plan The improvement process represents the comprehensive, continuing preparedness effort of which the 2011 Peach Bottom Atomic Power Station MS-I Drill is a part. The lessons learned and recommendations from the AAR will be incorporated into the Improvement Plan (IP).

After Action Conference The After Action Conference (AAC), scheduled within 60 days of the drill to allow jurisdiction officials to hear the results of the evaluation analysis, validate the findings and recommendations in the draft AAR, and begin development of the IP.

Improvement Plan The IP identifies how recommendations will be addressed, including what actions will be taken, who is responsible, and the timeline for completion. It is created by key stakeholders from the 38 0

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan . " Medical Services Drill 2011 Peach Bottom Atomic Power Station MS-1 Drill participating agency officials during the AAC scheduled within 60 days of the drill.

APPENDIXA: EXERCISE SCHEDULE Table A.1 2011 Peach Bottom Atomic Power Station MS-1 Drill Schedule October 28, 2011,. ,,,,_

1230 Minquas Fire Company Exercise Begins Brandywine Hospital 1400 Minquas Fire Company Exercise Ends 1515 Brandywine Hospital Exercise Ends 1530 Drill Participants Critique and Debrief 39

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill APPENDIX B: EXTENT OF PLAY INFORMATION PEACH BOTTOM ATOMIC POWER STATION BRANDYWINE HOSPITAL MEDICAL SERVICES DRILL October 28, 2011 Method of Operation

1. The power station and its personnel will not play an active role in the facilitation of this drill. The-plant's simulated events, radiation releases, and emergency classifications will be injected by off-site controllers. A pre-approved scenario will be used.

2. The Pennsylvania Emergency Management Agency (PEMA), Area Offices (Harrisburg Central Area and Hamburg Eastern Area) will not be activated as part of this drill. The Exercise Coordinator will provide pre-drill coordination and observe drill activities.

3. Exelon Nuclear will participate as a Controller in this drill.

4. Chester County Office of Emergency Management will participate in this drill

5. Controllers will be supplied by PEMA. Controllers are not players and will provide injects and information to initiate and stimulate drill play by providing radiological readings during the monitoring of personnel. Live radioactive sources will only be used to perform operational checks of radiological monitoring instruments.

6. PEMA staff and qualified, county emergency management personnel will be assigned to key locations for the purpose of observing, noting response actions and conditions, and recording observations for future use. Observers will not take an active part in the proceedings, but will interact with staff members to the extent necessary to fulfill their observer responsibilities. Coaching of players is not permitted, except as appropriate to provide training to participants awaiting a re-demonstration.

7. Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Radiological Emergency Preparedness Program (REPP) Evaluators: FEMA Evaluators will be present at designated demonstration locations.

8. Drill activities are scheduled to commence on or about 1230, October 28, 2011 and continue until the participants have completed the drill objectives and demonstrated the Exercise Evaluation Criteria.

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9. Participants and agencies will Stand Down when the Controllers have confirmed with the evaluators that all evaluation criteria have been demonstrated and when the State and County Observers are satisfied that the Objectives have been met.

10. An emergency plan is drafted to address the generally expected conditions of an emergency. Not everything in the emergency plan may be applicable for a given scenario. The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a plan that they cannot take actions that are more protective of the public.

Therefore, if, by not following the plan, the responders protect the public equally as well as provided in the plan, it should'be noted for possible modification of the plan, but not classified as a negative incident. Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so that the plan can be modified and the appropriate negative assessment corrected.

11. During the drill any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants during the exercise, provided it does not negatively interfere with the exercise. Refresher training may be provided by the players, observers, and/or controllers. Evaluators are not permitted to provide refresher training. Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. PEMA may advise the RAC Chair prior to initiating any re-demonstrations.

It is permissible to extend the demonstration window, within reason, to accommodate the re-demonstration. Activities corrected from a re-demonstration will be so noted.

Obiectives A. Demonstrate the ability to respond to a radiation medical emergency following the procedures of Chester County Division of Emergency Services, Minquas Fire Company

/EMS and Brandywine Hospital.

B. Demonstrate timely and accurate communications between the hospital and offsite response agencies. (Telephones will be used in lieu of radios- WhenedVer possible to limit the potential misinterpretation of the drill as an actual evenvte.)

C. Demonstrate correct priorities and appropriate techniques in EMS, transportation of patients and pre-hospital and hospital emergency care of radioactively contaminated patients.

D. Demonstrate inter-agency cooperation between the Ambulance Company/ EMS and the Hospital.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill Extent of Play Evaluation Area 1-Emergency Operations Management Sub-Element 1.e-Equipmentand Supplies To Support Operations Intent This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have emergency equipment and supplies adequate to support the emergency response.

Criterion 1.e.I: 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).

Extent of Play Equipment within the facility (facilities) should be sufficient and consistent with the role assigned to that facility in the ORO's plans and/or procedures in support of emergency operations. Use of maps and displays is encouraged. All instruments should be inspected, inventoried, and operationally checked before each use. Instruments should be calibrated in accordance with the manufacturer's recommendations. Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation should be calibrated annually. Modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration should be on each instrument, or calibrated frequency can be verified by other' means. Additionally, instruments being used to measure activity should have a range of readings sticker affixed to the side of the instrument. The above considerations should be included in 4.a. 1 for field team equipment; 4.c. 1 -for radiological laboratory equipment (does not apply to analytical equipment); reception center and emergency worker facilities' equipment under 6-a. 1 and-ambulance and medical facilities' equipment under 6.d. 1.

Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers should be available for issuance to all categories of emergency workers that could be deployed from that facility. Appropriate direct-reading dosimetry should allow individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans and procedures.

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill Dosimetry should be inspected for electrical leakage at least annually and replaced, if necessary.

CDV-138s, due to their documented history of electrical leakage problems, should be inspected for electrical leakage at least quarterly and replaced if necessary. This leakage testing will be verified during the exercise, through documentation submitted in the Annual Letter of Certification, and/or through a staff assistance visit.

Responsible OROs should demonstrate the capability to maintain inventories of KI sufficient for use by emergency workers, as indicated on rosters; institutionalized individuals, as indicated in capacity lists for facilities; and, where stipulated by the plan and/ or procedures, members of the general public (including transients) within the plume pathway EPZ.

Quantities of dosimetry andKI available and storage locations(s) will be confirmed by physical inspection at storage location(s) or through documentation of current inventory submitted during the exercise, provided in the Annual Letter of Certification submission, and/or verified during a Staff Assistance Visit. Available supplies of KI should be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may produce a letter from a certified private or State laboratory indicating that the KI supply remains potent, in accordance with U.S.

Pharmacopoeia standards.

At locations where traffic and access control personnel are deployed, appropriate equipment (for example, vehicles, barriers, traffic cones and signs, etc.) should beavailable or their availability described.

All activities must be based on the ORO's plans and procedures and. completed as they would be.

in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

State NegotiatedExtent of Play:

Ambulance crews are not trainedor equipped to operate or carry radiologicalmonitoring equipment. In accordancewith PEMA standardoperatingproceduresambulance crews operatingoutside the 10 mile Emergency PlanningZone are considered 'Category C" emergency workers; therefore, they, are only requiredto implement protective measures, consistent with protection againstblood-bornepathogens; i.e., long sleeved garments, trousers, impermeable gloves, and surgicalmasks. "Category C" emergency worker dosimetry issue consists of one permanent reading dosimeterper worker.

Hospitalpersonnel are also considered "Category C" emergency workers and will conform to PEMA SOP protective measures at minimum. Direct Reading Dosimeters may be issued-individually; however, an Area Kit will be establishedin the Radiation Emergency Area (REA).

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan;.. Medical Services Drill IndividualPRDs will be issued by the hospital. RadiologicalSurvey Instruments are calibrated per manufacturesrecommendations.

Outstandin2Issues:

None Evaluation Area 3-Protective Action Implementation Sub-Element 3.a-Implementation of Emergency Worker Exposure Control Intent This sub-element derives from NUREG-0654, which provides that OROs should have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; the reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; and establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides, always applying the ALARA (As Low As is Reasonably Achievable) principle as appropriate.

Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordan ce 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).

Extent of Play OROs should demonstrate the capability to provide appropriate direct-reading and permanent record dosimetry, dosimeter chargers, and instructions on the use of dosimetry to emergency workers. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows individual(s) to read theadministrative reporting limits (that are pre-established at a level low enough to consider subsequent calculation of Total Effective Dose Equivalent) and maximum exposure limits (for those emergency workers involved in life saving activities) contained in the ORO's plans and procedures.

Each emergency worker should have the basic knowledge of radiation exposure limits as specified in the ORO's plan and/or procedures. Procedures to monitor and record dosimeter readings and to manage radiological exposure control should be demonstrated.

44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill During a plume phase exercise, emergency workers should demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker should report accumulated exposures during the exercise as indicated in the plans and procedures. OROs should demonstrate the actions described in the plan and/or procedures by determining whether to replace the worker, to authorize the worker to incur additional exposures or to take other actions. If scenario events do not require emergency workers to seek authorizations for additional exposure, evaluators should interview at least two emergency workers, to determine their knowledge of whom to contact in the event authorization is needed and at what exposure levels. Emergency workers may use any available resources (for example, written procedures and/or co-workers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission and adequate control of exposure can be effected for all members of the team by one dosimeter worn by the team leader. Emergency workers who are assigned to. low exposure rate areas, for example, at reception centers, counting laboratories, emergency operations centers, and communications centers, may have individual direct-reading dosimeters or they may be monitored by dosimeters strategically placed in the work area. It should be, noted that, even in these situations, each team member must still have their own permanent record dosimetry.

Individuals without specific radiological response missions, such as farmers for animal care, essential utility service personnel, or other members of the public who must re-enter an evacuated area following or during the plume passage, should be limited to the lowest radiological exposure commensurate with completing their missions.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

State NegotiatedExtent of Play:

" Demonstrate appropriateproceduresand equipment to manage radiqlogicqlexposure to staff.

• Demonstrate the ability to transportcontaminated/injuredindividuals while using ALARA principles.

• Demonstratethe ability to utilize dosimetry, equipment andproceduresto manage radiologicalexposure to emergency workers as requiredby plans.

Radiological briefings will be provided to addressexposure limits andprocedures to replace personnelapproachinglimits and how permission to exceed limits is obtained. At any time, players may ask otherplayers or supervisorsto clarify radiologicalinformation. In 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill Pennsylvania,emergency workers outside the EPZ do not have turn-back values, Standardissue of dosimetry andpotassium iodidefor each category of emergency worker is asfollows:

CategoryA: 1 PRD, 1 DRD, and I unit of K1 Category B. 1 PRD and I unit of KI Category C. 1 PRD All locations that have dosimetry equipment indicatedwithin their RadiologicalEmergency Response Plan (RERP) will make the dosimetry equipment (andK1, as appropriate)availablefor inspection by the FederalEvaluator. Simulation PRDs with mock serial numbers may be used.

OutstandingIssues:

None Evaluation Area 6-Support Operation/ Facilities Sub-Element 6.d-Transportationand Treatment of ContaminatedInjured Individuals Intent This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO). should have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Criterion 6.d.l: 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).

Extent of Play U Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the victim.

Offsite Response Organizations (ORO) should demonstrate the capability to transport contaminated injured individuals to medical facilities. An ambulance should be used for the response to the victim. However, to avoid taking an ambulance out of service for an extended time, any vehicle (for example, car, truck, or van) may be used to transport the victim to the medical facility. Normal communications between the ambulance/dispatcher and the receiving medical facility should be demonstrated. If a substitute vehicle is used for transport to the 46 41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Exercise Plan Medical Services Drill medical facility, this communication must occur before releasing the ambulance from the drill.

This communication would include reporting radiation monitoring results, if available.

Additionally, the ambulance crew should demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

Monitoring of the victim may be performed before transport, done en route, or deferred to the medical facility. Before using a monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities should be completed as they would be in an actual emergency. Appropriate contamination control measures should be demonstrated before and during transport and at the receiving medical facility.

The medical facility should demonstrate the capability to activate and set up a radiological emergency area for treatment. Equipment and supplies should be available for the treatment of contaminated injured individuals.

The medical facility should 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 evaluator.:

All activities associated with this criterion must be'based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

State NegotiatedExtent of Play:

Demonstrate that the facility has the appropriatespace, adequate resourcesand trained personnel to provide monitoring, decontaminationand medical services to contaminated/injured individuals.

Demonstrate the ability to transportcontaminated/injuredindividualswhile'using ALARA principles.

The Minquas Ambulance will simulatepicking up a pre-stagedcontaminated/injuredvictim.

OutstandingIssues:

46-05-6.d.1-A-01 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 0

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