ML13234A033
| ML13234A033 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/07/2013 |
| From: | Tierney M Federal Emergency Management Agency |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML13234A033 (52) | |
Text
U.S. Department of Homeland Security Region IlI One Independence Mall, 6th Floor 615 Chestnut Street Philadelphia, PA 19106-4404 0
FEMA AUb 67 At3 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 Limerick Generating Station (LGS) Reading Hospital MS-I Drill that was evaluated on June 12, 2013.
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 Limerick Generating Station (LGS) Reading Hospital 2013 MS-1 Drill.
If you have any questions, please contact Daniel Lerch at (215) 931-5603.
Sincerely, MaryAnn Tierney Regional Administrator Enclosure www.fema.gov (t4
Limerick Generating Station After Action Report/
Improvement Plan Drill Date - June 12, 2013 Radiological Emergency Preparedness (REP) Program SFEIA Published July 25, 2013
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After Action Report/Improvement Plan Limerick Generating Station Limerick Generating Station After Action Report/Improvement Plan Published July 25, 2013 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 6
Section 2: Exercise Design Summary 8
2.1 Exercise Purpose and Design 8
2.2 Exercise Objectives, Capabilities and Activities 10 2.3 Scenario Summary 10 Section 3: Analysis of Capabilities 11 3.1 Drill Evaluation and Results 11 3.2 Summary Results of Drill Evaluation 11 3.3 Criteria Evaluation Summaries 14 3.3.1 Support Jurisdictions 14 3.3.1.1 Berks County, Reading Hospital & Medical Center 14 3.3.1.2 Berks County, Western Berks Emergency Medcial 14 Services Section 4: Conclusion 15 Appendix A: Drill Evaluators and Team Leaders 16 Appendix B: Acronyms and Abbreviations 17 Appendix C: Exercise Plan 18 1
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After Action Report/Improvement Plan Limerick Generating Station EXECUTIVE
SUMMARY
On June 12, 2013, the Federal Emergency Management Agency (FEMA), Region III, conducted a Medical Services (MS-1) Drill in relation to the Limerick Generating Station (LGS). The purpose of the drill was to assess the level of State and local preparedness in responding to a radiological medical emergency. This drill was held in accordance with FEMA's policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERP).
The most recent evaluated Medical Services Drill at this site was conducted on September 21, 2011.
FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania, the risk jurisdictions of Montgomery, Berks and Chester Counties and the support jurisdictions of Bucks and Lehigh, as well as the Reading Hospital, Western Berks EMS and the Berks County Department of Emergency Services who participated in this drill.
Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities.
Cooperation and teamwork of all the participants were evident during this drill.
The State and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies, Areas Requiring Corrective Action (ARCAs), or Planning Issues identified as a result of this drill. Furthermore, there were no Prior Issues to be resolved as a result of previous drills.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Limerick Generating Station Type of Exercise Drill Exercise Date June 12, 2013 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Robert Meinert Exercise Planning Team Lead Pennsylvania Emergency Managment Agency Emergency Management Specialist 2605 Interstate Drive Harrisburg, Pennsylvania, 17110 717-651-2215 rmeinert@pa.gov Daniel Lerch Hospital Evaluator FEMA Region III Technological Hazards Program Specialist One Independence Mall, 6th Floor 4
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station 615 Chestnut Street Philadelphia, Pennsylvania, 19106 215-931-5603 daniel.lerch@dhs.gov Joseph Suders Ambulance Evaluator FEMA Region III Technological Program Specialist One Independence Mall, 6th Floor 615 Chestnut Street Philadelphia, Pennsylvania, 19106 215-931-5564 joseph.suders@dhs.gov Jeffrey Dean Hospital Controller Exelon Exelon Offsite Coordinator Evergreen Road Sanatoga, Pennsylvania, 19464 610-715-2210 Jeffrey.Dean@Exelon.com Lauren Flemming Hospital Controller Pennsylvania Emergency Management Agency Emergency Planning Specialist 2605 Interstate Drive Harrisburg, Pennsylvania, 17110 717-651-2215 lflemming@pa.gov 5
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Phillip Spence Hospital Controller Berks County DES Emergency Management Specialist 2561 Bernville Rd.
Reading, Pennsylvania, 19605 610-374-4800 berksdes@countyofberks.com Donnie Swope Ambulance & Notifications Controller Berks County DES Planning Officer Direct Link Technology Center 2561 Bernville Road Reading, Pennsylvania, 19605 610-374-4800 dswope@countyofberks.com Patrick Flynn Ambulance & Notifications Controller Pennsylvania Emergency Management Agency Emergency Management Specialist 2605 Interstate Drive Harrisburg, Pennsylvania, 17110 717-651-2215 pflynn@pa.gov 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Limerick Generating Station drill:
State Jurisdictions 6
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Reading Hospital Western Berks EMS Berks County Department of Emergency Services Pennsylvania Emergency Management Agency 7
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After Action Reportllmprovement Plan Limerick Generating Station SECTION 2: EXERCISE DESIGN
SUMMARY
2.1 Exercise Purpose and Design On June 12, 2013, a Medical Services Drill was facilitated in relation to the Limerick Generating Station (LGS) by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Region III, Radiological Emergency Preparedness Program (REPP). The purpose of the drill was to assess the level of State and local preparedness in responding to a radiological medical emergency. This drill was held in accordance with DHS's policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERP) and procedures. The most recent FEMA evaluated Medical Services Drill for this site in Pennsylvania was conducted on September 21, 2011.
FEMA, Region II, wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania, Berks County, as well as the Western Berks Emergency Medical Services Ambulance and the Reading Hospital, who participated in this drill.
Protecting the public health.and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities.
Cooperation and teamwork of all the participants were evident during this drill.
EMERGENCY PLANNING ZONE DESCRIPTION:
LGS is located in southeastern Pennsylvania on the Schuylkill River about 1.7 miles southeast of Pottstown Borough. The river passes through the site, separating the western portion, which is in East Coventry Township in Chester County, from the eastern portion, which is in Limerick and Lower Pottsgrove Townships in Montgomery County. The plant is owned and operated by Exelon Nuclear. Two boiling water reactors each generate an electrical output of 1,050 megawatts (MW). Unit 1 was issued a full-power license in August 1985; commercial operations began in February 1986. Unit 2 was issued a full-power license in August 1989 with commercial operations beginning in January 1990.
The site encompasses 595 acres and is divided into three (3) parts. The principal portion, where the major operating equipment and buildings are located, is on the east bank of the Schuylkill 8
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station River. This portion is separated from the second segment, where the cooling water intake is located, near the main line of the Reading Railroad. The third portion lies on the west bank of the river, adjacent to Conrail railroad tracks. The site coordinates are approximately 40013'27"N and 75035' 15"W.
The minimum exclusion distance for the LGS is 2,500 feet from the center of each reactor. The utility owns all the land within the exclusion area. No private residences are located within the exclusion area; however, some farming may be permitted.
There are 165 sirens installed to cover the 1 0-mile plume exposure pathway EPZ. These sirens are activated three (3) minutes before the Emergency Alert System (EAS) messages issued by the Commonwealth of Pennsylvania are broadcast.
Soils in this area are of the Reaville-Penn-Klinesville Association and are characteristic of rolling uplands. They are underlain by sedimentary rocks of the Brunswick Formation, consisting mostly of red shale with some fine-grained sandstone interbedding. The normal pool elevation of the Schuylkill River in this area is 200 feet above mean sea level (msl). The topography of the area is hilly, with elevations ranging from 100-300 feet above msl within five (5) miles of the site. The plant is approximately 217 feet above msl. The climate in this area is dominated by prevailing westerly winds that produce humid, continental-type weather characterized by warm summers and moderately cold winters. Montgomery County is the warmest part of Pennsylvania, with an average annual temperature of 57°F. Annual precipitation is approximately 42 inches.
The area in the immediate vicinity of the plant is made up mostly of agricultural and other open land. The Pottstown Borough in Montgomery County is the nearest community and has a population of 22,377 based on the 2010 Census. The nearest major population center (more than 25,000 people) is Philadelphia that lies 25 miles to the southeast of the site. Two major industries employ a total of 850 persons within two (2) miles of the plant. Two small airfields are also located nearby. A small private airfield is about one (1) mile to the northeast, but its runway is oriented so that the flight path does not pass over the plant. The Pottstown Municipal Airport is 4.3 miles northwest of the site. The LGS does not lie in the approach pattern for this airport. No major thoroughfares are located in the immediate vicinity of the plant. The main line of the Reading Railroad runs along the north bank of the Schuylkill River and traverses the site about 500 feet from the plant.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station 2.2 Exercise Objectives, Capabilities and Activities The objective of the Limerick Generating Station/Reading Hospital Medical Services (MS-
- 1) Drill was to demonstrate that the response organizations have the personnel, equipment, training, and knowledge to effectively assess the condition of a potentially radioactively contaminated patient, protect against cross contamination, transport, and transfer the patient to a hospital where the patient can then be decontaminated and treated. The hospital personnel are responsible for preparing a receiving and treatment area, operating radiological detection equipment, and implementing proper emergency worker protective procedures.
All activities were evaluated in accordance with current FEMA directives and guidance and were performed in accordance with current hospital plans and procedures.
2.3 Scenario Summary The exercise scenario for this Medical Services Drill consisted of simulated notifications of escalating emergency classification levels at the Limerick Generating Station from Site Area Emergency to General Emergency. Subsequent to being notified of the General Emergency, the 911 Center informed the Hospital that an incident had occurred at the nuclear plant, resulting in the injury and possible radiological contamination of a general public evacuee picked up at the Monitoring/Decontamination Center. The Hospital implemented its plan to prepare a Radiation Emergency Area to receive and treat the patient and activated its radiation emergency medical team.
The patient was injured in a fall that resulted in possible neck, hand and knee injuries.
The victim has an abrasion and swelling on the forehead, a small laceration upon the left knee found on survey, and is complaining of neck pain and pain in the left knee area. Detectable radioactive contamination was found on the right and left palms and left knee.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating 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 June 12, 2013 Medical Services Radiological Emergency Preparedness (REP) Exercise. The exercise was conducted to demonstrate the ability of the Offsite Response Organizations to respond to a potentially radiologically contaminated injured person associated with the Limerick Nuclear Generating Station.
Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the Exercise Evaluation Area Criteria contained in the REP Program Manual. Detailed information on the exercise evaluation area criteria and the Extent-of-Play agreement are found in Appendix C.
3.2 Summary Results of Drill Evaluation The Limerick Generating Station 2013 Medical Services Drill evaluation included two (2) participating locations. Two evaluators provided analyses of six (6) Exercise Criteria. These analyses resulted in a determination that all criteria were successfully demonstrated and there were no Deficiencies, Areas Requiring Corrective Action, or Planning Issues.
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After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Drill Evaluation DATE: 2013-06-12 SITE: Limerick Generating Station, PA U 2 M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated 0
0 Emergency Operations Management Mobilization lal Facilities lbl Direction and Control Icl Communications Equipment Idl Equipment and Supplies to Support Operations lel M
M Protective Action Decision Making Emergency Worker Exposure Control 2a 1 Dose Assessment & PARs & PADs for the Emergency Event 2bl Dose Assessment & PARs & PADs for the Emergency Event 2b2 PADs for disabilities & access/functional needs people 2c 1 Radiological Assessment & Decision-making for Ingestion Pathway 2d I Radiological Assessment & Decision-making for Relocation/Reentry/Return 2el Protective Action Implementation Implementation of Emergency Worker Exposure Control 3al M
M Implementation of KI PAD for Institutionalized Individuals/Public 3b]
Implementation of PADs for disabilities & access/functional needs people 3c1 Implementation of PADs for Schools 3c2 Implementation of Traffic & Access Control 3d I Impediments to Evacuation 3d2 Availability & use of Commodity & Resource Information 3el Preprinted Materials for Implementing PADs for Commodities & Resources 3e2 Implementation of Relocation/Reentry/Return Decisions 3f1 Field Mýas-ir~iiient and Analysis RESERVED 4a 1 Field Team Management 4a2 Plume Phase Field Measurement. Handling, & Analyses 4a3 Post Plume Phase Field Measurements & Sampling 4bl Laboratory Operations 4c 1 Emergency Notification and Public Info Activation of the Prompt Alert & Notification System 5al RESERVED 5a2 Activation of the Back-up ANS 5a3 Activation of the Exception Area ANS 5a4 Emergency Information & Instructions for the Public/Media 5bI Support O0erations/Facilities Monitoring, Decontamination. & Registration of Evacuees 6al Monitoring/,/Decontamination of Emergency Workers/Equipment/Vehicles 6bI Temporary Care of Evacuees 6c I Transportation/Treatment of Contaminated Injured Individuals 6dl M
M 12
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After Action Report/Improvement Plan Limerick Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 Support Jurisdictions 3.3.1.1 Berks County, Reading Hospital & Medical Center 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 Berks County, Western Berks Emergency Medcial Services In summary, the status of DHS/FEMA criteria for this location is as follows:
- a.
MET: 1.e.1,3.a.1,6.d.l.
- 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 14
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After Action Report/Improvement Plan Limerick Generating Station SECTION 4: CONCLUSION 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 Limerick Generating Station/Reading Hospital 2013 MS-1 Drill.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station APPENDIX A: DRILL EVALUATORS AND TEAM LEADERS DATE: 2013-06-12, SITE: Limerick Generating Station, PA LOCATION Berks County, Reading Hospital & Medical Center Berks County, Western Berks Emergency Medcial Services
- Team Leader EVALUATOR
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station APPENDIX B: ACRONYMS AND ABBREVIATIONS DHS Department of Homeland Security DRD Direct Reading Dosimeter EMS Emergency Medical Services EMT Emergency Medical Technician FEMA Federal Emergency Management Agency GE General Emergency LGS Limerick Generating Station MS Medical Services PEMA Pennsylvania Emergency Management Agency PPE Personal Protective Equipment PRD Permanent Record Dosimeter REA Radiation Emergency Area REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plans RO Radiological Officer SAE Site Area Emergency 17
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station APPENDIX C: EXERCISE PLAN The enclosed Exercise Plan was created as an overall tool for facilitation and implementation of the Limerick Generating Station 2013 Medical Services Drill and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program (HSEEP) with the Radiological Emergency Preparedness Program Manual (April 2012). The Exercise Plan was originally drafted and published by the Pennsylvania Emergency Management Agency (PEMA) as an independent document and is annexed here.
The "Limerick Generating Station's Medical Services Drill Extent-of-Play 2013" was negotiated and agreed upon by FEMA Region I1, PEMA, and the offices of emergency management of the Risk and Support Jurisdictions. It is included as an Appendix of the Exercise Plan.
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After Action Report/Improvement Plan Limerick Generating Station 2013 Limerick Generating Station Medical Services Exercise EVALUATED MEDICAL SERVICES EXERCISE (MS-i)
READING HEALTH SYSTEM AT READING HOSPITAL Exercise Date: June 12, 2013 Date Published: March 11, 2013 19
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After Action Report/Improvement Plan Limerick Generating Station PREFACE The 2013 Limerick Generating Station Medical Services Exercise (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 2013 Limerick Generating Station Medical Services Exercise 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. The ExPlan may be viewed by all exercise participants, but the Controller and Evaluator (CIE) Handbook is a restricted document intended for 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 PEMA.
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After Action Report/Improvement Plan Limerick Generating Station HANDLING INSTRUCTIONS
- 1. The title of this document is 2013 Limerick Generating Station Medical Services Exercise Plan (ExPlan).
- 2. The information gathered in this ExPlan is For Official Use Only (FOUO) and should be handled as sensitive information not to be disclosed. This document should be safeguarded, handled, transmitted, and stored in accordance with appropriate security directives.
- 3. At a minimum, the attached materials will be disseminated only on a need-to-know basis and when unattended, will be stored in a locked container or area offering sufficient protection against theft, compromise, inadvertent access, and unauthorized disclosure.
- 4. For more information, please consult the following point of contact (POC):
Federal POC(s):
Daniel Lerch Emergency Management Program Specialist Federal Emergency Management Agency 615 Chestnut Street Philadelphia, PA 19106-4404 215-931-5603 daniel.lerchta, dhs..qov State POC(s):
Robert L. Meinert, MS-1 Coordinator Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, Pennsylvania 17110 717-651-2215 rmeinert(dpa.pov Al Brinser Chief, Technological Hazards Division Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, PA 17110 717-651-2217 abrinser(-pa..ov 21
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station TABLE OF CONTENTS Exercise Plan Limerick Generating Station FEMA Evaluated MS-1 Exercise U.S. DEPARTMENT OF HOMELAND SECURITY Preface...........................................................................................................................................
20 Handling Instructions..................................................................................................................
21 Chapter 1: G eneral Inform ation............................................................................................
25 Introduction...............................................................................................................................
25 Confidentiality...........................................................................................................................
25 P u rp o se......................................................................................................................................
2 5 Target Capabilities....................................................................................................................
26 Exercise Objectives..................................................................................................................
26 Outstanding Issues.....................................................................................................................
27 Chapter 2: Exercise Logistics................................................................................................
28 Exercise Sum m ary.....................................................................................................................
28 G en era l.....................................................................................................................................
2 8 Assumptions.............................................................................................................................
28 Constructs and Constraints...................................................................................................
28 Exercise Participants...............................................................................................................
29 Exercise Tools...........................................................................................................................
30 Controller and Evaluator Handbook....................................................................................
30 M aster Scenario Events List.................................................................................................
30 Exercise Im plem entation...........................................................................................................
30 Exercise Play............................................................................................................................
30 Exercise Rules..........................................................................................................................
30 Safety Requirem ents.................................................................................................................
31 G en era l.....................................................................................................................................
3 1 Exercise Setup..........................................................................................................................
31 Accident Reporting and Real Em ergencies.........................................................................
31 Site Access................................................................................................................................
32 Security.....................................................................................................................................
32 Observer Coordination.............................................................................................................
32 Parking and Directions.............................................................................................................
32 Restroom Facilities...................................................................................................................
32 Exercise Identification...............................................................................................................
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After Action Report/Improvement Plan Limerick Generating Station Communications Plan...........................................................................................................
33 Exercise Start, Suspension, and Term ination Instructions...................................................
33 Player Comm unication..........................................................................................................
33 Player Briefing.........................................................................................................................
33 Public Affairs...........................................................................................................................
33 Chapter 3: Player Guidelines.................................................................................................
34 Exercise Staff............................................................................................................................
34 Lead Controller.........................................................................................................................
34 Controllers................................................................................................................................
34 Evaluators.................................................................................................................................
35 Player Instructions.....................................................................................................................
35 Before the Exercise..................................................................................................................
35 During the Exercise..................................................................................................................
35 Following the Exercise..........................................................................................................
36 Simulation Guidelines..........................................................................................................
36 Chapter 4: Evaluation and Post-Exercise Activities...........................................................
37 Exercise Docum entation......................................................................................................
37 After Action Report...................................................................................................................
37 Improvem ent Plan....................................................................................................................
37 Appendix A : Exercise Schedule............................................................................................
38 Appendix B: Extent of Play Inform ation..............................................................................
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After Action Report/Improvement Plan Limerick Generating Station CHAPTER 1: GENERAL INFORMATION Introduction The 2013 Limerick Generating Station Medical Services Exercise (MS-1) 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 2013 Limerick Generating Station Medical Services Exercise (MS-i) is evidence of the growing partnership between State and local jurisdictions for response to the threats our Nation and communities face.
Confidentiality The 2013 Limerick Generating Station Medical Services Exercise 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 Controller and Evaluator (CIE) Handbook is a restricted document intended for controllers and evaluators only.
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 Pennsylvania Emergency Management Agency (PEMA) 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 the Radiological Emergency Preparedness (REP) Program Manual (April 2012) to develop this exercise.
The objective of 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.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station 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.
The capabilities listed below have been selected by the Exercise Planning Team from the priority capabilities identified in Commonwealth of Pennsylvania Multi-Year TEP and the FEMA Radiological Emergency Preparedness (REP) Program Manual (April 2012), 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 exercise are those that are required to be demonstrated in every MS-1 Exercise, per 67 FR 20580 (April 25, 2002) and the Radiological Exercise Preparedness (REP) Program Manual (April 2012). Appendix B, Extent of Play, Shows the emergency preparedness elements that are required to be demonstrated in the 2013 Limerick Generating Station Medical Services Exercise, 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).
The objective of this exercise is to demonstrate reasonable assurance that the health and safety of the public can be protected, through successful demonstration of tasks identified in Appendix B.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Outstanding Issues There were no Areas Requiring Corrective Action (ARCAs) as a result of the previous FEMA-evaluated MS-1 Exercise.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station CHAPTER 2: EXERCISE LOGISTICS Exercise Summary General The 2013 Limerick Generating Station Medical Services Exercise is designed to establish a learning environment for players to exercise their plans and procedures for responding to a radiological incident. The 2013 Limerick Generating Station Medical Services Exercise will be conducted on June 12, 2013. Exercise play is scheduled for 0800 for four (4) hours or until the Lead Controller in consultation with FEMA and the Utility representative determines 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 2013 Limerick Generating Station Medical Services Exercise:
" 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 may be the inadvertent result of a faulty construct or may pertain to financial and staffing issues.
Althoughthere 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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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station 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 provide key 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 committee members 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 evaluationfunctions.
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.
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.)
29
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Exercise Tools Controller and Evaluator Handbook The 2013 Limerick Generating Station Medical Services Exercise 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. It is comprised of the Exercise Scenario, Timeline/Event Sequence List and controller prompts.
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 respondto 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 2013 Limerick Generating Station Medical Services Exercise the MSEL will not be used since the scenario in the C/E Handbook incorporates MSEL elements such as the time, expected action and controller prompts/injects.
Exercise Implementation Exercise Play Exercise play will begin at approximately 0800 June 12, 2013 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.
Exercise Rules The following are the general rules that govern exercise play:
Real-world emergency actions take priority over exercise actions.
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 an exercise."
Exercise participants placing telephone calls or initiating radio communication must identify the organization, agency, office, and/or individual with whom they wish to speak.
30
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Safety Requirements General Exercise participant safety takes priority over exercise events. Although the organizations involved in the 2013 Limerick Generating Station Medical Services Exercise come from various response agencies, they share the basic responsibility for ensuring a safe environment for ail 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:
- An exercise Safety Controller will be identified and be responsible for participant safety.
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 Safety 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 procedures, 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 911,and state "This is not an exercise" prior to explaining the injury or illness then if possible, renders aid, provided the aid does not exceed his or her training.
- The controller who is made aware of a real emergency will initiate the broadcast "This Is Not An Exercise" 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
" Requirements 31
Unclassified Radiological Emergency Preparedness Program (REP)
After Action ReportlImprovement Plan Limerick Generating Station If the nature of the emergency requires a suspension of the exercise at the 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 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. PEMA will assign Observers and Liaison Officers to each site as deemed necessary.
Observers are not players and should refer players to a controller or Liaison. Liaisons are players for specific responsibilities.
Parking and Directions Parking information and directions to each venue area are available from the Lead Controller.
Restroom Facilities Restroom facilities will be available at each venue.
Exercise Identification Players, Controllers and Evaluators will display the agency issued Identification badges while the exercise is in play.
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Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Communications Plan Exercise Start, Suspension, and Termination Instructions The exercise is scheduled to run for four (4) hours 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 PEMA Press Office, the Reading Hospital Public Information Office and the Limerick Public Information Office.
33
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station 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 2013 Limerick Generating Station Medical Services Exercise 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 who are 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 2013 Limerick Generating Station MS-1 Exercise include the Exercise Director, Lead Controller, Exelon Nuclear, and the Berks County Department of Emergency Services.
Lead Controller The Lead Controller is responsible for the overall organization of the 2013 Limerick Generating Station MS-1 Exercise. 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 exercise. 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 2013 Limerick Generating Station MS-1 Exercise. The Lead Evaluator monitors exercise progress and stays in contact with the Lead Controller regarding changes to the exercise during play. The Lead Evaluator 34
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station 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 PEMA MS-1 Program Coordinator.
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 least30 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.
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.
35
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station 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 Hotwash with the controllers and evaluators.
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 2013 Limerick Generating Station MS-1 Exercise 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 orControllers.
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 each venue. If a real emergency occurs, say "Real-World Emergency" and notify the nearest Controller and Evaluator.
36
Unclassified Radiological Emergency Preparedness Program (REP)
After Action ReportL/Improvement Plan Limerick Generating Station CHAPTER 4: EVALUATION AND POST-EXERCISE ACTIVITIES Exercise Documentation The goal of the 2013 Limerick Generating Station MS-1 Exercise 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.
Exercise Hotwash A post exercise debriefing or "hotwash" will occur within a half hour after the completion of the exercise. All hospital and EMS players as well as the Observers, Actors, Controllers and Evaluators will meet in a hospital meeting/conference room to review the exercise play, player performance and any issues identified during the progress of the exercise. All attending will be given the opportunity to identify things that went well (strengths),and areas for impr'Ovement.
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. The FEMA Site Specialist, as the head evaluator and Team Chief, along with his evaluators, will be responsible for developing the draft After Action Report within 30 days of the date of the exercise, This will be followed by a 30 day review period. Following thiis, the FEMA team will evaluate the input and develop the final After Action Report by 90 days post exercise.
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 2013 Limerick Generating Station MS-1 Exercise participating agency officials.
37
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station APPENDIX A: EXERCISE SCHEDULE Table A.1 MS-1 Exercise Schedule Tim (Tnaie Persnne Actvt June 12, 2013 0730 Exercise Staff Assembly Exercise Briefing 0800 Exercise Participants Begin Exercise 0815 Hospital Maintenance Staff Setup REA 1130 Exercise Staff Assembly Exercise Debriefing/Hotwash 38
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station APPENDIX B: EXTENT OF PLAY INFORMATION LIMERICK GENERATING STATION READING HOSPITAL MEDICAL SERVICES EXERCISE June 12, 2013 Method of Operation
- 1.
The power station and its personnel will not play as active role in the facilitation of this exercise. 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), and Eastern Area Office will not be activated as part of this exercise. The Exercise Coordinator will provide pre-exercise coordination and observe exercise activities.
- 3.
Exelon Nuclear will participate as a Controller in this exercise.
- 4.
Berks County Department of Emergency Services will participate in this exercise providing pre-exercise coordination and observe exercise activities.
- 5.
Controllers will be supplied by PEMA. Controllers are not players and will provide injects and information to initiate and stimulate exercise 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.
Exercise activities are scheduled to commence on or about 0800, June 12, 2013 and continue until the participants have completed the exercise objectives and demonstrated the Exercise Evaluation Criteria.
39
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station
- 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 exercise 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. Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. 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.
Objectives A.
Demonstrate the ability to respond to a radiation medical emergency following the procedures of Berks County Department of Emergency Services, Western Berks EMS and Reading 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 exercise 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 the Ambulance Company/ EMS and the Hospital.
40
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Extent of Play Evaluation Area 1-Emergency Operations Management Sub-Element I.e-Equipment and 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.1: Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations.
(NUREG-0654, H.7,10; 1.7, J.10.a, b, e, J.11, 12; K.3.a; K.5.b).
Extent of Play A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is encouraged. For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.
Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows:
KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transients) within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures). The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined KI in advance.
41
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV.
Available supplies of KI must 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.94F Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to perform an ORO mission. In addition, OROs must demonstrate provisions to make dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures).
Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary. Civil Defense Victoreen Model 138s (CD V-1 38s) (0-200 mR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary. This leakage testing Will be verified during the exercise, through documentation submitted in the ALC and/or through an SAV.
Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer's instructions and be verified during the exercise, through documentation submitted in the ALC and/or through an SAV.
Monitoring Instruments: All instruments must be -inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation must be calibrated annually. Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must. have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source.
For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta radiation. These instruments must be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on air sample collection media, consistent with the intended use of the instrument and the 42
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station ORO's plans/procedures. An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than 1 RJhr) and for high-range instruments when available. If a source is not available for a high-range instrument, a procedure must exist to operationally test the instrument before entering an area where only a high-range instrument can make useful readings.
In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.
All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
State Negotiated Extent of Play:
In accordance with PEMA standard operating procedures ambulance crews operating outside the 10 mile Emergency Planning Zone are considered 'Category C" emergency workers; therefore, they are only required to implement protective measures consistent with protection against blood-borne pathogens; i.e., long sleeved garments, trousers, impermeable gloves, and surgical masks.
Ambulance "Category C" emergency workers are not issued dosimetry or KI unless they are tasked to enter the 10 mile EPZ. At that-time the county will issue what is needed.
Hospital personnel 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 established in the Radiation Emergency Area (REA).
Individual PRDs will be issued by the hospital. Radiological Survey Instruments are calibrated per manufactures recommendations.
Outstanding Issues:
None 43
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station 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.1: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/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. OROs maintain appropriate record-keeping of the administration of KI to emergency workers. (NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4)
Extent of Play OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.
Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.
During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker must report accumulated exposures during the exercise as indicated in the plans/procedures. OROs must demonstrate the actions described in the plans/procedures by determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge 44
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station of whom to contact in case authorization is needed, and at what exposure levels. Workers may use any available resources (e.g., written procedures and/or coworkers) 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. In such cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimeter worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry.
Individuals authorized by the ORO to reenter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with completing their missions.
OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers performing various services (e.g., life saving, protection of valuable property, all activities). OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where life saving and/or protection of valuable property may require an urgent response.
OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it.
Emergency workers must demonstrate basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.
All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
State Negotiated Extent of Play:
Demonstrate appropriate procedures and equipment to manage radiological exposure to staff.
Demonstrate the ability to transport contaminated/injured individuals while using ALARA principles.
Demonstrate the ability to utilize dosimetry, equipment and procedures to manage radiological exposure to emergency workers as required by plans 45
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Radiological briefings will be provided to address exposure limits and procedures to replace personnel approaching limits and how permission to exceed limits is obtained. At any time, players may ask other players or supervisors to clarify radiological information. In Pennsylvania, emergency workers outside the EPZ do not have tum-back values. Standard issue of dosimetry and potassium iodide for each category of emergency worker is as follows:
Category A: 1 PRD, 1 DRD, and 1 unit of KI Category B: 1 PRD and 1 unit of KI Category C: 1 PRD All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP) will make the dosimetry equipment (and KI, as appropriate) available for inspection by the Federal Evaluator. Simulation PRDs with mock serial numbers may be used.
Outstanding Issues:
None 46
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station Evaluation Area 6-Support Operation/ Facilities Sub-Element 6. d-Transportation and Treatment of Contaminated Injured 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.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654, F.2; H.10; K.5.a, b; LI, 4).
Extent of Play Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the victim.
OROs must demonstrate the capability to transport contaminated injured individuals to medical facilities.
An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility. Normal communications between the ambulance/dispatcher and the receiving medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available. In addition, the ambulance crew must 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 or en route, or may be deferred to the medical facility. Before using monitoring instruments, the monitor(s) must demonstrate the pocess of checking the instrument(s) for proper operation. All monitoring activities must be completed as they would be in an actual emergency. Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility.
The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment. Equipment and supplies must be available for treatment of contaminated injured individuals.
The medical facility must demonstrate the capability to make decisions on the need for decontamination of the individual, follow appropriate decontamination procedures, and maintain records of all survey measurements and samples taken. All procedures for collection and 47
Unclassified Radiological Emergency Preparedness Program (REP)
After Action Report/Improvement Plan Limerick Generating Station analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator. Waste water from decontamination operations must be handled according to facility plans/procedures.
All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
State Negotiated Extent of Play:
Demonstrate that the facility has the appropriate space, adequate resources and trained personnel to provide monitoring, decontamination and medical services to contaminatedlinjured individuals.
Demonstrate the ability to transport contaminated/injured individuals while using ALARA principles.
The Ambulance Service will pick-up a pre-staged simulated contaminated/injured victim.
Outstanding Issues:
None 48
Unclassified Radiological Emergency Preparedness Program (REP)
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