ML12101A370

FEMA San Onofre Nuclear Generating Station, Final Exercise Report, Exercise Dates - April 14, 2011, May 18, 2011, and December 14, 2011

ML12101A370
Person / Time
Site:	San Onofre
Issue date:	03/23/2012
From:	Ward N US Dept of Homeland Security, Federal Emergency Management Agency
To:	Collins E Region 4 Administrator
Cecere, Bethany NSIR/DPR 415-6754
References
Download: ML12101A370 (73)

Text

.S. Departmenl of Homelalld Security Region IX 1111 Broadwa . Ul t<:: 1200 Oaklan d, CA 94607-4052 FEMA MAR 232012 Mr. Elmo E. Collins, Jr.

Regional Administrator U.S . Nuclear Regulatory Commission Region rv 1600 East Lamar Boulevard Arlington, Texas 76011

Dear Mr. Collins:

I am forwarding a copy of the Final After Action Report for the Ingestion Phase Exercise held in Orange County on April 14, 2011, May 18,2011, and December 14, 2011 , for the San Onofre Nuclear Generating Station (SONGS). The purpose of this exercise was to assess the level of state and local preparedness in responding to a radiological emergency. The final exercise report was prepared by the U.S. Department of Homeland Security' s Federal Emergency Management Agency, Region IX Radiological Emergency Preparedness Program staff.

No deficiencies were identified during this exercise. There were four Areas Requiring Corrective Action (ARCA) identified as a result of the exercise; three ARCAs were corrected. We will monitor the correction of the remaining ARCA. A detailed discussion of these ARCAs can be found in Section 3.3 of the Final Report.

Based on the evaluation of the April 14, 2011 , May 18, 2011, and December 14, 2011 , Ingestion Phase Exercise, 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.

Therefore, the Code of Federal Regulations, Title 44 Part 350 interim approval of the offsite radiological emergency response plans and preparedness for the state of California, site-specific to SONGS, will remain in effect.

I would also like to take this opportunity to acknowledge the many individuals that participated in this successful exercise. Their dedication to this program was clearly evident.

Mr. Elmo E. Collins, Jr.

Page 2 If you have any questions or need additional information, please contact me at (510) 627-7100.

Your staff may also contact Mr. Richard Echavarria, SONGS Site-Specialist, at (510) 627-7217, or Mr. James Macaulay, Acting Radiological Assistance Committee Chair, at (510) 627-7009.

Sincerely,

(~l:'~

Nancy Ward Regional Administrator FEMA Region IX Enclosure cc: NRC Headquarters Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555-000 I Vanessa Quinn, Chief Radiological Emergency Preparedness Branch FEMA Headquarters

U . Departmenl of Homeland Security Region IX 1111 Broadway, , uite 1200 aklamj C 94(;0 7-4052 FEMA MAR 232012 Mr. Mark Ghilarducci Secretary California Emergency Management Agency 3650 Schriever A venue Mather, CA 95655

Dear Mr. Ghilarducci :

I am forwarding a copy of the Final After Action Report for the Ingestion Phase Exercise held in Orange County on April 14, 20 11, May 18, 2011, and December 14, 2011 , for the San Onofre Nuclear Generating Station (SON GS). The purpose of this exercise was to assess the level of state and local preparedness in responding to a radiological emergency. The tinal exercise report was prepared by the U.S. Department of Homeland Security's Federal Emergency Management Agency, Region IX Radiological Emergency Preparedness Program staff.

No deficiencies were identified during this exercise. There were four Areas Requiring Corrective Action (ARCA) identitied as a result of the exercise; three ARCAs were corrected. We will monitor the correction of the remaining ARCA. A detailed discussion of these ARCAs can be found in Section 3.3 of the Final Rep0I1.

Based on the evaluation of the April 14, 2011 , May 18,2011, and December 14, 2011, Ingestion Phase Exercise, the offsite radiological emergency response plans for the state of California and the atIected 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.

Therefore, the Code of Federal Regulations, Title 44 Part 350 interim approval of the offsite radiological emergency response plans and preparedness for the state of California, site-specific to SONGS, will remain in effect.

I would also like to take this opportunity to acknowledge the many individuals that participated in this successful exercise. Their dedication to this program was clearly evident.

,~" \I.fcma.go"

Mr. Mike Ghilarducci Page 2 I f you have any questions or need additional information, please contact me at (510) 627-7100.

Your staff may also contact Mr. Richard Echavarria, SONGS Site-Specialist, at (510) 627-7217, or Mr. James Macaulay, Acting Radiological Assistance Committee Chair, at (510) 627-7009.

Sincerely,

~i'o1. Nancy Ward U Regional Administrator FEMA Region IX Enclosure

San Onofre Nuclear Generating Station After Action Report/Improvement Plan Exercise Dates - April 14, 2011, May 18, 2011, and December 14, 2011 Radiological Emergency Preparedness (REP) Program Published March 12, 2012

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After Action Report/Improvement Plan San Onofre Nuclear Generating Station San Onofre Nuclear Generating Station After Action Report/Improvement Plan Published March 12, 2012 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 ................................................ 7 2.1 Exercise Purpose and Design ............................................................................................................ 7 2.2 Exercise Objectives, Capabilities and Activities .............................................................................. 7 2.3 Scenario Summary ............................................................................................................................ 9 SECTION 3. Analysis of Capabilities ................................................... 10 3.1 Exercise Evaluation and Results ..................................................................................................... 10 3.2 Summary Results of Exercise Evaluation ....................................................................................... 10 3.3 Criteria Evaluation Summaries ....................................................................................................... 14 3.3.1 California Jurisdictions ........................................................................................................... 14 3.3.2 Risk Jurisdictions .................................................................................................................... 17 SECTION 4. Conclusion ....................................................................... 21 Appendix A  : Improvement Plan ............................................................................................................ 22 Appendix B  : Exercise Evaluators.......................................................................................................... 23 Appendix C  : Acronyms and Abbreviations........................................................................................... 24 Appendix D  : Extent-of-Play .................................................................................................................. 25 1

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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) Region IX National Preparedness Division - Technological Hazards Branch evaluated an Ingestion Pathway Exercise conducted within the 50-mile Ingestion Pathway Zone (IPZ) around the San Onofre Nuclear Generating Station (SONGS) on April 14, 2011, May 18, 2011, and December 14, 2011.

The most recent biennial plume phase exercise at this site was conducted on April 12, 2011. The qualifying emergency preparedness exercise was conducted on May 13, 1981.

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 final 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. There were no Deficiencies and four Areas Requiring Corrective Action (ARCA) identified during the course of the exercise; three ARCAs were corrected.

The 2011 SONGS Ingestion Pathway Exercise Improvement Plan contains the recommended corrective action plan for the remaining ARCA.

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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 Ingestion Pathway Exercise Exercise Dates April 14, 2011, May 18, 2011, and December 14, 2011 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Sara Kaminske Exercise Coordinator Orange County Sheriffs Department Assistant Emergency Manager 2644 Santiago Canyon Road Silverado, CA 92676 Richard Garcia Technical Specialist Southern California Edison Emergency Services Coordinator P.O.Box 128 San Clemente, CA 92672 Bill Potter Senior Emergency Services Coordinator 3650 Schriever Avenue Mather, CA 95655 Richard Echavarria Senior Site Specialist Radiological Emergency Preparedness Program FEMA Region IX Oakland, CA 94607 4

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station 1.3 Participating Organizations The following agencies and organizations participated in the San Onofre Nuclear Generating Station exercise:

State Jurisdictions California Emergency Management Agency California Department of Fish and Game California Department of Food and Agriculture California Department of Public Health California Department of Parks and Recreation, Orange Coast District California Department of Transportation California Highway Patrol Risk Jurisdictions Capistrano Unified School District City of Dana Point City of San Clemente City of San Juan Capistrano Los Angeles County Agricultural Commissioner Los Angeles County Department of Health Services Orange County Agricultural Commissioner Orange County Health Care Agency Orange County Fire Authority Oceanside Fire Department Orange County Sheriff - Coroner Department Orange County Transportation Authority Riverside County Agricultural Commissioners Office Riverside County Department of Public Health Riverside County Environmental Health Riverside County Fire Department - Office of Emergency Services Riverside County Sheriffs Department San Bernardino County Department of Agriculture, Weights and Measure San Bernardino Department of Public Health San Diego County Agriculture, Weights and Measure San Diego County Department of Animal Services 5

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station San Diego County Communications Office San Diego County Department of Environmental Health San Diego County Health and Human Services San Diego County Office of Emergency Services San Diego County Planning and Land Use San Diego County Public Safety Group San Diego County Sheriffs Department San Diego State University Private Sector/Volunteer Organizations American Red Cross San Diego Gas & Electric San Onofre Nuclear Generating Station Southern California Edison Federal Jurisdictions Center for Disease Control and Prevention Federal Emergency Management Agency Food and Drug Administration Nuclear Regulatory Commission U.S. Department of Agriculture Marine Corps Base Camp Pendleton 6

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 April 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 use 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)

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 off-site environmental conditions. (NUREG-0654: I.8, 10; Supplement 3) Criterion 2.b.2:

Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups.

(NUREG-0654: J.9; J.10.d, e) 7

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station 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 implement 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)

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654, C.3; J.11)

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 off-site 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 off-site 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) 8

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station 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.

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 IPZ. 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 of 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 14, 2011, May 18, 2011, and December 14, 2011, Ingestion Pathway Exercise to test the offsite emergency response capabilities of state and local government agencies for the SONGS IPZ.

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 D 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 ARCA assessed and no unresolved ARCA from prior exercises)

D - Deficiency assessed A - ARCA assessed or unresolved ARCA 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 recommended corrective actions to be demonstrated before or during the next Ingestion 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.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station 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 a 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 DATE: 2011-04-14, 2011-05-18, 2011-12-14 State of California San Juan Capistrano Riverside County San Diego County Los Angeles County San Bernardino Orange County SITE: San Onofre Nuclear Generating Station, CA Dana Point San Clemente County A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated Emergency Operations Management Mobilization 1a1 Facilities 1b1 Direction and Control 1c1 M M M M M M M M M Communications Equipment 1d1 Equip & Supplies to support operations 1e1 Protective Action Decision Making Emergency Worker Exposure Control 2a1 M M M M M M Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c1 M Rad Assessment and Decision making for the Ingestion Exposure 2d1 M M M M M M Pathway Rad Assessment and Decision making concerning Relocation, 2e1 M M M M M M Reentry, and Return Protective Action Implementation Implementation of emergency worker exposure control 3a1 M M M Implementation of KI decision 3b1 Implementation of protective actions for special populations - EOCs 3c1 M Implementation of protective actions for schools 3c2 M Implementation of traffic and access control 3d1 M M M M M Impediments to evacuation are identified and resolved 3d2 Implementation of Ingestion Pathway decisions - availability/use of 3e1 M M M M M M info Materials for Ingestion Pathway PADs are available 3e2 M M M M M M Implementation of relocation, re-entry, and return decisions 3f1 M M M M M M 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 Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception 5a3 Areas Emergency information and instructions for the public and the 5b1 M M M M M M M M M media 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 12

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station DATE: 2011-04-14, 2011-5-18, 2011-12-14 California Capistrano Unified State Dose SITE: San Onofre Nuclear Generating Station, CA California Department of FST A FST B Department of School District Assessment Center A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated Public Health Public Health SRPU Laboratory Emergency Operations Management Mobilization 1a1 Facilities 1b1 Direction and Control 1c1 M M M M Communications Equipment 1d1 M M Equip & Supplies to support operations 1e1 M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2a1 M Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c1 M Rad Assessment and Decision making for the Ingestion Exposure 2d1 M Pathway Rad Assessment and Decision making concerning Relocation, 2e1 M Reentry, and Return Protective Action Implementation Implementation of emergency worker exposure control 3a1 M M A M Implementation of KI decision 3b1 Implementation of protective actions for special populations - EOCs 3c1 Implementation of protective actions for schools 3c2 M Implementation of traffic and access control 3d1 Impediments to evacuation are identified and resolved 3d2 Implementation of Ingestion Phase decisions - availability/use of 3e1 info Materials for Ingestion Phase PADs are available 3e2 M Implementation of relocation, re-entry, and return decisions 3f1 M 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 M M M Laboratory operations 4c1 M Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1 Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception 5a3 Areas Emergency information and instructions for the public and the 5b1 media Support Operations/Facilities Mon / decontamination of evacuees and emergency workers, and 6a1 M registration of evacuees Mon / decontamination of emergency worker equipment 6b1 M Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d1 13

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 California Jurisdictions 3.3.1.1 State of California In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 2.a.1, 2.d.1, 2.e.1, 3.a.1, 3.d.1, 3.e.1, 3.e.2, 3.f.1, 5.b.1.

b. AREA 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 California Department of Public Health (CDPH) Drinking Water and Radiation Laboratory Branch In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 3.a.1, 4.c.1.

b. AREA REQUIRING CORRECTIVE ACTION: 4.c.1.

ISSUE NO: 51-11-4c1-A-2 CRITERION: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654, C.3; J.11)

CONDITION: The chemist preparing samples prior to analysis did not change his gloves after completion of preparing the first soil sample and starting the preparation of the second sample.

POSSIBLE CAUSE: Failure to follow normal contamination control considerations.

REFERENCE:

NUREG C.3; J.11 EFFECT: The potential to cross-contaminate the second soil sample.

CORRECTIVE ACTION DEMONSTRATED: When preparing samples, the preparers gloves should be changed between samples and at other times that would minimize the opportunity to cross-contaminate samples or contaminate equipment.

The controller halted the demonstration and explained that the chemist preparing the samples needed to change gloves between samples. The chemist agreed, he changed his gloves, and the demonstration continued. For the remainder of the 14

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station drill, the chemist was very cognizant of changing his gloves and changed his gloves between samples and at all other appropriate times.

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None.

3.3.1.3 State Dose Assessment Center (SDAC)

In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 1.e.1, 2.e.1, 3.e.2, 3.f.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.1.4 State Field Sampling Team A In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 4.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.1.5 State Field Sampling Team B In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 1.e.1, 4.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: 3.a.1, 4.b.1.

ISSUE NO: 51-11-3a1-A-3 CRITERION: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plan 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) 15

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station CONDITION: A field team member was issued a thermoluminescent dosimeter (TLD) by the Department of Energy Radiological Assistance Program (RAP) team member and no documentation was completed.

POSSIBLE CAUSE: Each of the team members are issued TLDs for their normal day-to-day job functions. These TLDs were used for dose record as part of the exercise. One team member did not have her TLD with her and was given one by the Federal RAP on site. The team member may have assumed the TLD used was simulating her normally worn TLD, though that was never made clear.

REFERENCE:

NUREG-0654, K.3.a, b; CDPH Nuclear Emergency Response Procedure: SDAC Worker Radiation & Monitoring DRAFT FINAL 6/10/10 8.8.2, 10.2 (pages 11 & 15).

EFFECT: If not simulating her day-to-day TLD, the worker would have no paper record of which TLD she was issued by the RAP and no way to track the dose received during the sampling event.

RECOMMENDATION: The team member should complete the proper forms when issued a TLD.

ISSUE NO: 51-11-4b1-A-4 CRITERION: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision making. (NUREG-0654, I.8; J.11)

CONDITION: A field team member did not don a second pair of protective gloves prior to handing samples over to sample receipt staff as is prescribed in the procedures and check list detailed below.

POSSIBLE CAUSE: Field Team 2 was assigned task of delivering samples to sample receipt area. The team did not double glove since they were not collecting samples. The team advised the evaluator two pairs of protective gloves would be worn for sampling to prevent cross-contamination and the outer pair removed prior to re-entering the vehicle.

When the team arrived at the sample drop-off area the sample deliverer simply forgot to put on an outer pair of gloves.

REFERENCE:

NUREG-0654, J.11; FEMA REP 13, 4.2.1 pages 42-43; CDPH Nuclear Emergency Response Procedure No. E-81: SDAC Field Team Standard Operating Procedures Attachment B, C.

EFFECT: If inner gloves were contaminated, the team member ran the risk of cross-contaminating the sample and sample receipt area.

CORRECTIVE ACTION DEMONSTRATED: Play was halted and the need for the second pair of gloves was discussed. The team member explained that samples were packaged in mutli-layered containers limiting cross-contamination to the samples. The Field Team 2 member also checked hands frequently by frisking with a Ludlum Model 3 meter equipped with a pancake probe. The controller indicated outer gloves were prescribed in the procedure checklist. The situation was re-demonstrated successfully.

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None 16

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e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.1.6 California Department of Public Health Sampling Receipt and Processing Unit In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 1.d.1, 1.e.1, 2.a.1, 3.a.1, 4.b.1, 6.a.1, 6.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: 4.b.1.

ISSUE NO: 51-11-4b1-A-5 CRITERION: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision making. (NUREG-0654, I.8; J.11)

CONDITION: When the water sample was being received, the exterior of the outer bag was surveyed and found to be free of loose contamination. However the exterior of the sample bag, inside the outer bag, was contaminated by inject from the Controller. The Sample Receipt and Processing Unit Health Physicist should have then recognized that the inside of the outer bag, that had been previously removed, was potentially contaminated. The decision was made to place the sample back into a second bag. The original potentially contaminated outer bag was used and the top of the bag inverted as is common practice when placing a contaminated item into a bag. However in this case the inverted interior surface was a bag that was potentially contaminated. Before the Health Physicist had an opportunity to recognize this situation and self correct, the Controller called a Time Out and explained the potential loss of contamination control. The Health Physicist then used a new clean second bag to contain the water sample.

POSSIBLE CAUSE: The health physicist failed to recognize the possibility that the inside of the outer bag was potentially contaminated.

REFERENCE:

NUREG I.8; J.11 EFFECT: The loss of contamination control while re-bagging the water sample.

CORRECTIVE ACTION DEMONSTRATED: The Health Physicist replaced the contaminated bag with a new clean second bag to contain the water sample.

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.2 Risk Jurisdictions 3.3.2.1 City of Dana Point - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

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a. MET: 1.c.1, 2.e.1, 3.d.1, 3.f.1, 5.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.2.2 City of San Clemente - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 2.e.1, 3.d.1, 3.f.1, 5.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.2.3 City of San Juan Capistrano - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 2.e.1, 3.d.1, 3.f.1, 5.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.2.4 Orange County - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 2.a.1, 2.c.1, 2.d.1, 2.e.1, 3.a.1, 3.c.1, 3.c.2, 3.d.1, 3.e.1, 3.e.2, 3.f.1, 5.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 18

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After Action Report/Improvement Plan San Onofre Nuclear Generating Station 3.3.2.5 Riverside County - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 2.a.1, 2.d.1, 3.e.1, 3.e.2, 5.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.2.6 San Diego County - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 2.a.1, 2.d.1, 2.e.1, 3.a.1, 3.e.1, 3.e.2, 3.f.1, 5.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.2.7 San Bernardino County - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 2.a.1, 2.d.1, 3.e.1, 3.e.2, 5.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.2.8 Los Angeles County - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 2.a.1, 2.d.1, 3.e.1, 3.e.2, 5.b.1.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None 19

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e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 3.3.2.9 Capistrano Unified School District - Recovery In summary, the status of the DHS/FEMA criteria for this location is as follows:

a. MET: 2.c.1, 3.c.2.

b. AREA REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES RESOLVED: None

f. PRIOR ISSUES UNRESOLVED: None 20

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After Action Report/Improvement Plan San Onofre Nuclear Generating Station SECTION 4. CONCLUSION FEMA Region IX evaluated the Ingestion Pathway Exercise on April 14, 2011, May 18, 2011, and December 14, 2011, in the IPZ 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 four ARCAs were identified during the course of this exercise. Three ARCAs were corrected during the exercise. The 2011 SONGS Ingestion Pathway Exercise Improvement Plan, Appendix A, contains the recommended corrective action plan for the remaining ARCA.

Based on the evaluation of the April 14, 2011, May 18, 2011, and December 14, 2011, Ingestion Pathway Exercise, 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: 51-11-3a1-A-3 Criterion: 3a1 ISSUE: A field team member was issued a TLD by the RAP team and no documentation was completed.

RECOMMENDATION: The team member should complete the proper forms when issued a TLD.

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 EVALUATORS Location Evaluator Agency State of California Henry Christiansen ICF Katherine Nishihara FEMA Region IX Daryl Thome ICF State of California CDPH Drinking Water and Katherine Nishihara FEMA Region IX Radiation Laboratory Daryl Thome ICF State Dose Assessment Center Johanna Berkey FEMA Region X Richard Echavarria FEMA Region IX Joseph Keller ICF Alberto Sifuentes FEMA Region IX Paul Ward FEMA HQ Daryl Thome ICF David Stuenkel ICF State Field Sampling Team A Michael Howe FEMA HQ State Field Sampling Team B Bart Ray ICF CDPH Sampling Receipt and Processing Unit Dennis Wilford ICF Katherine Nishihara FEMA Region IX City of Dana Point Henry Christiansen ICF Willis Larrabee ICF City of San Clemente Gary Bolender ICF Henry Christiansen ICF City of San Juan Capistrano Robert Gantt ICF Henry Christiansen ICF Orange County Joseph Keller ICF Melissa Savilonis FEMA RI Henry Christiansen ICF Riverside County Brad McRee ICF Pat Tenorio FEMA HQ San Diego County Richard Grundstrom ICF Pat Tenorio FEMA HQ San Bernardino County Elsa Lopez FEMA Region VI Pat Tenorio FEMA HQ Los Angeles County Roy Smith ICF Pat Tenorio FEMA HQ Capistrano Unified School District Gary Bolender ICF FEMA Region IX Senior Site-Specialist, Richard Echavarria 23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station APPENDIX C : ACRONYMS AND ABBREVIATIONS Acronym / Abbreviation Meaning AAR After Action Report ARCA Area Requiring Corrective Action CDPH California Department of Public Health DHS Department of Homeland Security FEMA Federal Emergency Management Agency IPZ Emergency Planning Zone KI Potassium Iodide ORO Offsite Response Organization RAP Radiological Assistance Program REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan SDAC State Dose Assessment Center SONGS San Onofre Nuclear Generating Station TLD Thermoluminescent Dosimeter 24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan San Onofre Nuclear Generating Station APPENDIX D : EXTENT-OF-PLAY Presented in this appendix is a compilation of exercise scenario materials submitted by the state of California and 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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