ML15211A244

After Action Report/Improvement Plan

ML15211A244
Person / Time
Site:	Fermi
Issue date:	07/20/2015
From:	Velasquez A US Dept of Homeland Security, Federal Emergency Management Agency, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15211A244 (35)

Text

U.S. Department of Homeland Security FEMA Region V 536 South Clark Street, 6th Floor Chicago, IL 60605 JL20 2015 @: FEM A NRC Headquarters Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-000 1 To Whom It May Concern:

Enclosed is a copy of the Final After Action Report/Improvement Plan for the school evacuation (EV-2) interview and medical services (MS-i) drill conducted on December 16, 2014, for the Fermi 2 Nuclear Power Plant. The State of Michigan, and Monroe and Wayne Counties participated in this exercise.

There were no Deficiencies identified for the State of Michigan or Monroe and Wayne Counties during the drill.

There were no Areas Requiring Corrective Action identified for the State of Michigan during the interview and drill.

There was one Area Requiring Corrective Action identified for Monroe County under Criterion 1.e. 1

- Contrary to the Extent-of-Play for Criterion 1.e. 1 and plans/procedures, Monroe County Ambulance staff was not issued potassium iodide (KI) as Monroe County Emergency Workers.

There was one Area Requiring Corrective Action identified for Wayne County under Criterion 3.a. 1

- The Oakwood Southshore Medical Center (OSMC) Emergency Department Staff did not know how to zero their dosimeters, did not recognize their dosimeter charger, and were generally unfamiliar with dosimetry and its use.

There was one Plan Issue identified for Monroe County under Criterion 3.a.l1 for the Monroe Public School District.

There were no prior issues identified in previous interviews or drills requiring corrective action.

A detailed discussion of these issues can be found in Sections 3 and 4 and Appendix A of the attached report.

Based on the results of the December 16, 2014 interview and drill, the offsite radiological emergency response plans and preparedness for the State of Michigan, and Monroe County, site-specific to the Fermi 2 Nuclear Power Plant can be implemented, and are adequate to provide ww.fema.gov

NRC Headquarters Document Control Desk 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 the site.

Pending successful re-demonstration of the Oakwood Southshore Medical Center (OSMC) medical service drill by Wayne County on August 25, 2015, it is anticipated that the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and preparedness for the State of.

Michigan, and Monroe and Wayne Counties, granted on March 9, 1987, will remain in effect.

If you have any questions, please contact Karl Rabenhorst at (312) 408-5516 or Dwaine Warren at (312) 408-5342.

Sincerely, Andrew Velasquez III Regional Administrator Enclosure

Enrico Fermi 2 Nuclear Power Plant After Action Improvement Plan Report!

Drill Date - December 16, 2014 Radiological Emergency Preparedness (REP) Program

~FEMA ... . ...

Published July U7, 2U15

• Emergency Radiological " Unclaissified' PrepareIn~s~s Progra'n' (REP)l After Action Report/Improvemient Plan Enrico Fermi 2 Nuclear Power Plant

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Unclassified Radiiological Emergency Preparedness Program (REP)

After Action ReportImprovement Plan Enrico Fermi 2 Nuclear Power Plant Enrico Fermi 2 Nuclear Power Plant After Action Report/Improvement Plan Published July 07, 2015 Contents Executive Summary 3 Section 1: Exercise Overview 9 1.1 Exercise Details 9 1.2 Exercise Planning Team Leadership 9 1.3 Participating Organizations 10 Section 2: Exercise Design Summary 12 2.1 Exercise Purpose and Design 12 2.2 Exercise Objectives, Capabilities and Activities 12 2.3 Scenario Summary 12 Section 3: Analysis of Capabilities 13 3.1 Drill Evaluation and Results 13 3.2 Summary Results of Drill Evaluation 14 3.3 Criteria Evaluation Summaries 18 3.3.1 Risk Jurisdictions 18 3.3.1.1 Monroe Community Ambulance 18 3.3.1.2 Wayne County - Oakwood Southishore Medical 19 Center - Medical Service - Facility 3.3.1.3 Monroe County - Monroe Public Schools - EV-2 22 Interview Section 4: Conclusion 25 Appendix A: Improvement Plan 27 Appendix B: Drill Evaluators and Team Leaders 30 I

Unclassified Radiological Emergency Preparedness 'Ptogram (R:EP.)

After Action Report/Improvement plan Enrico Fermi 2 Nuclear Power Plant

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I 2

Uficlassified Radiological Emergent), Preparedness Program.(REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant EXECUTIVE

SUMMARY

On December 16, 2014, the Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA) Region V conducted one school (EV-2) interview and one medical services (MS-i) drill in the 10-mile plume exposure pathway Emergency Planning Zone (EPZ) around the Enrico Fermi 2 Nuclear Power Plant (FNPP). The purpose of the EV-2 interview was to assess the ability of off-site agencies to safely evacuate school children under the continuous supervision of teachers and administrators from a school to a host school serving as a relocation center. The purpose of the medical services drill was to assess the ability of offsite agencies to respond to a medical emergency involving a potentially radioactively contaminated member of the public.

Both the EV-2 interview and MS-i drill were held in accordance with DHS/FEMA policies and guidance concerning the exercise of State and local radiological emergency response plans.

The following criteria, which are part of the DHS/FEMA Radiological Emergency Preparedness Program (REPP) Manual dated June 2013, were evaluated during the EV-2 Interview: Criterion 1.d. 1 - Communications Equipment; Criterion i.e. 1 - Equipment and Supplies to Support Operations; Criterion 3 .a. 1 - Implementation of Emergency Worker Exposure Control; and Criterion 3.c.2 - Implementation of Protective Actions for Persons with Disabilities and Access/Functional Needs. The following criteria were evaluated during the MS-i Drill:

Criterion 1.d. 1 -~Communications Equipment; Criterion i.e. 1 - Equipment and Supplies to Support Operations; Criterion 3.a. 1 - Implementation of Emergency Worker Exposure Control; and 6.d. 1 - Transportation and Treatment of Contaminated Injured Individuals.

The DHS/FEMA wishes to acknowledge the efforts of personnel from the Michigan State Police's Emergency Management and Homeland Security Division, the Monroe County Emergency Management Division, the Wayne County Homeland Security and Emergency Management Department, the Monroe Public School District, Monroe Community Ambulance and Oakwood Southshore Medical Center who participated in the EV-2 interview and MS-i drill. The interview and drill were conducted with representatives of the school district and medical services by DHS/FEMA staff.

Except where noted in this report, the State and local organizations demonstrated knowledge of, and adequately implemented, their emergency response plans and procedures.

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Unclassified Radiological Emergency..Preparedness Program (REP)

I After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Pl'ant

.  : . ... . , . . , ,

• I. ". i " ': ,* "

• There were no Deficiencies identified for the, State of Michigan during the interview and drill.I There were no Deficiencies identified for Monroe County during the interview and drill.

There were no Deficiencies identified for Wayne County during the drill.

There were no Areas Requiring Corrective Action identified for the State of Michigan during the interview and drill. , . * ,:*. . . .... .. , -. ';Z ..'

. ... . * .  : . . " ' " J.,

s" Y "2 There. ,were.no Areas Requiring. Corrective-,Action...identified.: .. for Monroe County during the.

interview. .. . ,

There was one Area Requiring Corre~ctive Action identified for Monroe,.County dUring the drill.I Monroe County received an Area Requiring Corrective. Action-under Criterion i .e. 1:-Contrary 'I to the. Extent-of-Play for Criterion 1.e.1 and plans/procedures; Monroe County Ambulance staff was not. issued, pOtassium iodide. (.KI) as . Monroe .. County .Emergency Workers. "

There was one Area Requiring Corrective Action identified for*Wayne 5County during the; drill.

Wayne County received an Area Requiring. Corrective. Action under Criterion 3.a.1 - The...:

Oakwood Southshore Medical Center (OSMC). Emergency Department Staff did not know how to zero their dosimeters, did not recognize their dosimeter charger, and Were generally unfamiliar with dosimetry and its-use. Per the Extent-of-Play,. 'The use of-dosimetry and KI will be .

demonstrated by hospital .staff.' Potassium iodide (KI) was neither observed, nor mentioned by either the hospital staff or controllers. The Step-Off Pad indicated~in the OSMC Radiological Emergency Area-Diagram (0SMC RME Plan, Attachment 2) was neither used, mentioned norI observed in the equipment closet. Without the constant guidance provided by the Michigan Department of Environmental Equality (MDEQ) Health Physics Technicians who actively participated throughout the drill, it appeared, improbable that the OSMC Emergency Department staff would have contained radiological contamination to the Decontamination Room.

Dedicated ands hands-on practical, training is required for all potential REA staff nmembers regarding the Radiological Medical Emergency plan, with emphasis on donning/doffing PPE;1 4 I I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan E*nrico Fermi 2 Nuclear Power Plant theory and operation of personal dosimetry and personal exposure control; and radiological contamination mitigation,, control 'and decontamination. This issue is scheduled to be resolved through a complete re-demonstration of the medical service drill on August 25, 2015.

There was one Plan Issue identified for Monroe County during the interview.

Monroe County received a Plan Issue under Criterion 3.a. 1 - Per the Monroe Public School District (MPSD) Radiological Emergency* Respo0nse Plan (RERP); evacuation of all three Tiers of risk schools requires betwveen five hours (best case) and seven hours (worst case). Once"...

students have been evacuated, bus drivers are instructed to report to the staging area for distribution ofdosimetryr and KI and reassignment as emergencyworkers. If a release begins before the second or third tier risk schools have been evacuated, the bus drivers could exit the.

EPZ without dosimetry and KI, but would require dosimetry and KI to reenter the EPZ. The plan does not clearly define a procesS to ensure that ddsimetry and KI will be issued to school~

bus drivers who need to re-enter the EPZ in order to evacuate students and staff which could potentially delay the evaicuation of Tier 2 and 3 risk Schdols'. ". .

There were no prior issues identified in preVious intervieWs or drills requiring corrective~action.

INTRODUCTION - EXERCISE BASIS :' ." ,.

On December 7, 1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. DHS/FEMA's *activities are conducted pursuant to Title 44 of the Code of Federal Regulations'(CFR) Parts 350 "Review and Approval of State and Local Radiological Emergency Plans and 'Prep~aredness", 351 "Radioogical Emergency Planning and Preparedness" and 352 "Commercial Nuclear Power Plants: Emergency Preparedness Planning" (Commonly referred to as 44CFR350 through 352). These regulations are a key element' in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.  :

The FEMA Regulation 44 CFR 350 establishes the policies and procedures for DHS/FEMA'S initial and continued approval of State and local governments' radiologicail emiergency planning and preparedness for commercial nuclear power plants. This approval is contingent, in part, on State and local governments' participatiori in joint exercises with nuclear power plant licensees in their vicinity: .,::-

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After Action Report/Improvement Plan Radiolgical RailgclEmergency Unclassified Preparedness Program (REp)

Enrico Fermi 2 Nuclear Power Plantn The DHS/FEMA~s. responsibilities in*radiological *emergency pl~anning* for fixed nuclear facilities I include .thefollowing: .. . .:,.., . :- . .. :,

• Taking the lead in offsite emergency planning and in the review and evaluation of radiological emergency response plans (RERP.. s).a.n~d p rocedures 4ev.eloped by.State and.local governments;

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• Determining whether such plans and procedures canbeimrplemented. on the~basis of observation and evaluation of exercises of the plans and procedures conducted by State and localI governm ents; .: .- : . .. *,, *.,, . o .

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• Responding to requests by the.U.S, ,.Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17,. 1 993. (,Federal I Register, Vol. 58, No. 176, September 14, 1993); and

• Coordinating the activities of Federal .agenci~es with responsibilities in. the radiological .

emergency planning process: , ..... .. . ..

- U.S. Department of Agriculture; ... ,... .H... *.

- U.S. Department of Commerce;*.-*',' " ,,, ,,I

- U.S. Department of Energy; . .... *...-...

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

- U.S. Department-of the interior; , ' " .-..-. "i

- U.S. Departirient of Transportation; . ._ * .

-U.S. Environmental Protection Agency;

- U.S. Food and Drug. Administration; and*.. ,n

- U.S. Nuclear Regulatory. Commission.. .

Representatives of these agencies serve on the DHSiFEMA Region V Regional Assistance Committee (RAC), which is chaired b~y DHS/FEMA.. .. n Formal submission of the RERPs for the Enrico Fermi 2 Nuclear Power Plant to FEMA Region V by the State of Illinois and involved local jurisdictions occurred on March 22, 1982. Formal approval of these RERPs was granted by FEMA on March 9, 1987, in accordance with 44 CFRi 350. , - . . , .... -,,[

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Unclassified Radiological' Emergency Preparedness Program"(REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear'Power Plant The purpose of this After'Action Report.(AA:R)/Improvement Plan (IP) is to present the interview results and findings based on the performance of the Offsite Response Organizations (OROs) during a radiological emergency at the Enrico Fermi 2 Nuclear Power Plant.

The findings presented 'in this 'AARIIP are based on the evaluations of the Federal evaluation team, with final determinations made by the DUS/FEMA Region V RAG Chairperson, and approved by the DHS1,FEMA HeadqUarters.: .. q. - "",'

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

, NUREG-0654/FEMA-REP-I, Rev. 1, "Criteria for' Preparation and Evaluation of Radiological Emergency Respo8nse Plans and Preparedness in Support of Nuclear Power Plants," November 1980; and  : .

• FEMA "Radiological Emergency'Preparedness: ExerCise Evaluation Methodology; as published in the FEMA Radiological Emergency Preparedness Manual, dated June 2013.

Section 1 of this report, entitled "Exercise Overview", presents information pertaining to 'the team that planned and coordinated the interviews. This section also provides listing of all participating jurisdictions and functional entities that were evaluated..

Section 2 of this report, entitled "Exercise Design Summary", contains'the purpose and design of the exercise and presents basic information and data relevanti to the exercise scenario.

Section 3 of this report, entitled "Analysis of Capabilities", presents detailed iniformation on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format.

Section 4 of this report, entitled "Conclusion", presents the DHS/FEMA summary of overall exercise conduct and results as evaluated against the requirements of 44 CFR 350.

EMERGENCY PLANNING ZONE (EPZ) DESCRIPTION' The Enrico Fermi 2 Nuclear Power Plant is comprised of approximately 1,120 acres of land 7

Unclassified Radiological Emergency Preparedness ,Program.(REP.)

I After Action Report/Improvement plan Enrico Fermi 2 Nuclear Power PlantI owned by DTE.Energy. The. plant, operator, is. Detroit,. Edison,.:...,,. Cornpany.:.:

,,, The site is bounded onI the north by Swan Creek; ona the east by Lake Erie,"onthe-south by Pointe Aux Peaux Road, and on the west by Toll Road. Entrance to the site is from Enrico Fermi Drive (a private road owned by Edison) to the west, and from Pointe Aux Peaux Road to another private road owned byI Edison to the south. '

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• The plant is approximately six miles northeast of Monroe, Michigan; 30 miles southwest of downtown Detroit, Michigan; and 25 miles northeast of downtown Toledo,"bhio. iThe latitude of the site is 410° 57' 48" north and the longitude is 830 15' 31" west. Site elevations range from the I level of Lake Erie, on the eastern edge of the site, to approximately 25 feet above the lake level, on the western edge of the site. '*...."I The 10-mile EPZ includes parts of Monroe and Wayne Counties in Michigan; parts.  :- of Lake.*..

Erie;I and the southern tip of Essex County,.(Bay Point) Canada. Most of the 10-mile EPZ lies .withinI Monroe County. Coordinated efforts occur between the'two counties, which are divided into five Protective Action Areas. The following jurisdictions are located within the 10-mile EPZ:

Ash Township, Carleton Village, Berlin Township, Estral Beach Village, Exeter Township, South Rockwood Village, Frenchtown Township, Monroe City, Monroe Township, RaisinvilleI Township, Brownstown Township, Gibraltar City, Flat Rock City, and Rockwood City. The population in the 10-mile EPZ, based on the June 13, 2012 Michigan State Police EmergencyI "i,....

Management and Homeland Security Protective Action Area Populations Map, is 97,825.

Land use within the EPZ is diverse. About 55 percent of the land is farmland; the majority of agricultural land is located in Monroe County. The portion of Wayne County nearest to Detroit is a growing residential suburb. Twelve state parks and recreational areas, and several lightI industries are located within the 10-mile EPZ.

There are three major roads within 10 miles of the plant, Interstates 75 and 275, and U.S. Route I

24. Their closest approach to the plant is 4.1 miles, 4.2 miles and 5.8 miles, respectively. Five railroad lines operate within 10 miles of the plant. These include the Canadian National Railroad, I the Norfolk Southern Railroad, the Chesapeake and Ohio Railroad, the Detroit Toledo and Ironton Railroad, and the Detroit and Toledo Shore Line Railroad. There are no major airports .I within 15 miles of the site.-

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Unclassified Radiological Emergency Pr'eparedness Program* (REP)

After Action Report/Improvement Plan Enrico Femif 2 Nuclear Power Plant

'SECTION,' 1:'EXERCISE OVERVIE 1.1 Exercise Details ...

Exercise Name..: - .,  :

Enrico Fermi 2 Nuclear Power Plant

,Type of Ex~ercise ... .. ., .4.: . . .* . ., , .

Exercise Date December 16, 2014 Department of Homeland Security/FEMA Radiological' Emergency Prep aredness ":

Program Scenairio Type Rdiologica 1Emergeny '

1.2 Exercise Planning Team LeaderShip :

Sean O'Leary Regional Assistance Commit~tee Chaair' DHS/FEMA Region V ""

Technological Hazards Branch Chief ":"  :

536 South Clark Street, 6th Floor Chicago, Illinois, 60605 312-408-5389 .

Sean.Oleary@fema.dhs.gov... -

Dwaine Warren" Exercise Director *:..

DHSIFEMA Region V REP Supervisory Team Leader 536 South Clark Street, 6th Floor 9

Radiolgical UnclassifiedI RailgclEmergency Prepare~dness Program (REp)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant I Chicago, Illinois, 60605 -.

II Clinton Crackel Regional Site Specialist 1 DHS/FEMA Region V Technological Hazards Program Specialist 536 South Clark Street, 6th Floor Chicago, Illinois, 60605 I 312-408-5545 Clint.Crackel@fema.dhs.gov n Tonya Nobach State Lead ControllerI MSP/EMHSD REP Unit Manager 1I 4000 Collins Road Lansing, Michigan, 489101 517-333-5028 NobachT@michigan.govm 1.3 Participating Organizations1 Agencies and Organizations of the following jurisdictions participated in the Enrico Fermi 2 Nuclear Power Plant drill:l State Jurisdictions Michigan State Police/Emergency Management and Homeland Security Division I Michigan Department of Environmental Quality Risk Jurisdictions Monroe County Emergency Management Division I

• Monroe Public School District Wayne County Homeland Security and Emergency Management Department.n 10 I I

Unclassified Rkadlological Emergency Preparedness Program~ (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant Private Organizations Oakwood Southshore Medical Center "

Monroe Community Ambulance ..

DTE Energy 11

Radiolgical Unclassified RailgclEmergency Preparedness Program (REP)

After Action Report/Improvemcnt Plan Enrico Fermi 2 Nuclear Power Plant SECTION 2: EXERCISE DESIGN:

SUMMARY

I 2.1 Exercise Purpose and Design , ,,:.*.* ,..

The DHS/FEMA Region V Office conducted one-EV-2 interview and one MS-i drill on-December, 16, 2014 to assess the capabilities of local emergency preparedness organizations in implementing their. Radiological Emergency Response..Plans (RERP) and procedures to protectI the health and safety of students and school staff and transportation arid care for potentially contaminated patients during a radiological emergency involving the Enrico Fermi 2 Nuclear Power Plant. The purpose'of this report is-to present'the results and findings of,the EV'-2 interview conducted in the Monroe Public School District iinMonroe County and. the: MS-1 drill conducted at the Oakwood Southshore.Medical Center in Wayne County. .- :.

2.2 Exercise Objectives, Capabilities and Activities *.-I Identified REP Criteria selected to be demonstrated are listed in Table 3.1 - Summary of Drill Evaluation. .. .*.:....*'  : ... . ..

2.3 Scenario Summary '":..* , .. "

The date for the EV-2 interview and MS-i drill was submitted by the State of Michigan on ,. ,I November 26, 2014 and accepted by DHS/FEMA Region V on November 26, 2014.

• *"... .., . * :"t. * *i . ...*"I A scenariowas not utilized for the EV-2 interview..However; a. FEMA-approved EV-2 School Questionnaire was referenced to assist with .the interview,. ,

The final extent-of-play agreement for the MS-i drill was submitted by the State of Michigan on December 12, 2014.I I

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Drill 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 December 16, 2014 EV-2 interview and MS-i, drill to*

evaluate the offsite emergency response~capabilities of State and :local governments in the .10-,

mile EPZ surrounding the Enrico. Fermi 2:Nu~clear Power 'Plant..... *' '*

Each jurisdiction: and functional entity was evaluated based~on its discussion/demonstration of criteria delineated-iin the FEMA REP Program Manual, dated June 2013. Detailed information ,

on the exercise criteria used: in these interviews are found in Appendix E of this report.

Presented below are definitions of the. terms used in this report relative to the criteria demonstration status:

• M - Met: The status of a REP exercise Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the extent-of-play agreement with no Deficiencies,. Areas Requiring Corrective Action (ARCA) or Plan Issues assessed in the current exercise and no unresolved prior ARCAs.. , '.,

• D - Deficiency: An observed or identified inadequacy of organizational performance in an exercise that could cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in..the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant.

• A - ARCA - An observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety. Listing of the demonstrated exercise criteria under which one or more ARCAs was/were assessed during the current exercise or ARCAs assessed during prior exercises remain unresolved. Included is a description of any ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise.

• P - Plan Issue - An observed or identified inadequacy in the ORO's emergency plan or 13

Radiolgical UnclassifiedI RailgclEmergency Preparedness Program ( ,EP)

After Action ReportlImprovement Plan .Enrico Fermi 2 Nuclear Power Plant implementing procedures, rather than in the .ORO 's performA.ance,...

• I

• N - Not Demonstrated - Exercise criteria that were not demonstrated as scheduled during this exercise and the reason(s) they were not demonstrated.": -- ... I

• PriorlARCAs

...- Resolved:- Descriptions...,. of ARCAs assessed during, previou~s: exercises that were resolved and the corrective actions demonstrated, in this exercise. -..  !, I

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

3.2 Summary Results of Drill Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of all exercise criteria from the FEMA REP Program Manual, dated June 2013, which were scheduled for I discussion!/demonstration during the EV-2 interviews by all participating jurisdictions and fuinction~il entities. The criterion status box is blank if it was not scheduled for!

discussion/demonstration.

This subsection provides information on the evaluation of each participating jurisdiction and I functional entity in a jurisdiction-based, issues-only format.!

The DHS/FEMA has developed a standardized system for numbering exercise issues. This system is used to achieve consistency in numbering exercise issues among DHS/FEMA Regions and site-specific exercise reports within each Region. It also is used to expedite tracking of exercise issues on a nationwide basis.

The identifying number of Deficiencies, Areas Requiring Corrective Action (ARCA), and Plan Issues includes the following elements, with each element separated by a hyphen (-).

• Plant Site Identifier - A two-digit number, corresponding to the Utility Billable Plant Site Code (23 for Fermi 2 Nuclear Power Plant).

• Exercise Year - The last two digits of the year the interviews were conducted. Criterion I 14 I I

Unc~lassified Radliological Emerge'ncy Preparedness Program (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant Number - An alpha and two-digitnumnber: corresponding to the criteria numbers in the six Exercise Evaluation Areas described in the FEMA REP Program Manual, dated lume 2013.

• Issue Classification Identifier - (D =Deficienicy, A =- ARCA, P = Plan Issue)- '

• Exercise Identification.Number - A separate .twO or -three-digitindexing number assigned to*.

each issue identified in the -exercise.  : , .... *" * -... ,""- ."":'

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Unclassified Radiological Emergency.Preparedness Program (REP)

I After Action Report/Improvement Plan Table 3.1 Summary of Drill .Evaluatiorn Enrico Fermi 2 Nuclear Power Plant I

I DATE: 2014-12-16 SITE: Enrico Fermi 2 Nuclear Power Plant, MI * -

I M: Met, A: AIRCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated<

I Emergency Operations Management Mobilization 1lal I

Facilities lb I Direction and Control Communications Equipment Equipment and Supplies to Support Operations lci ldl lel M

A M

M M

M I

Protective Action Decision Making EW Exposure Control Decisions PARs 2al 2b 1 I

PADs 2b2 PADs for Disabled/Functional Needs Ingestion PADs 2c I 2d1 I

RRR Decisions 2e 1 Protective Action Implementation EW Exposure Control Implementation KI Public/Institutionalized 3a1 3b I M A P I PAD Implementation Disabled/Functional Needs PAD Implementation Schools TACP Establishment 3cl 3c2 3dl M I Impediments Implement Ingestion PADs Ingestion Pathway Decisions 3d2 3e 1 3e2 I

Implementation of RRR Decisions3l I

FeldMeasren RESERVED meofcaintand Publyic Info 4al I

BildTacku Alert Fxepiond Aream aoiiations Samlering Subseruetor Informations 4a3 a4b 4cntucin b1 I

SupprtgOera Ntiftons/acilit bies nf RException Cetre Operations 5a4 I

EW Monitoring & Decontamination Congregate Care 6b 1 i

'6cl 16 I I

Unclassified P~adlological Emiergency Preparedness: Pr:ogr~nm (REP)

After Action Report/Improvement Plan Enrico Fermni 2 Nuclear Power Plant

[Contaminated Injured Transport & Care'. -.. .,," '6dl [ M [M [ [

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Unclassified Radiological Emergency Preparedness P~rogram (R*EP)

I After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant 3.3 Criteria Evaluation Summaries -

3.3.1 Risk Jurisdictions 3.3.1.1 Monroe Community Ambulance In summary, the status of DHS/FEMA criteria for this location is as follow*:.

a. M ET: 1.d.l,3.a.l,6,d.l. ;" : -.. . ' '.* . .-. ' ..:

b. AREAS REQUIRING CORRECTIVE ACTION: 1.e.1. I ISSUE NO.: 23-14-1el-A-02..° CRITERION: Equipment, maps, displays, dosimetry, potassium iodide, and other Ssupplies are sufficient to' support emergency operations. .,."I.:

CONDITION: Contrary to the2Extent-of-Play for. Criterion 1.e.l. and

• I plans/procedures,.Monroe County AmbUlance staff was not-issued potassium iodide (KI) as Monroe County Emergency Workers.*

POSSIBLE CAUSE: Per both plans/procedures and noted in the Extent-of-Play for Criterion 1.e., 1,(1 was~missing-as-part of the listed required, resources/equipment.

REFERENCE:

NIJREG-0654/FEMA-R*EP-l1, J.i10.e and Extent-of-Play agreement. I EFFECT: The emergency workers were not provided any thyroid uptake protection (KI) from radio iodine despite being assigned to a mission that required entry into the

, FNPP 10-mile EPZ. I

• RECOMMENDATION::Ensure that KI1 is issued to Monroe County Emergency

'*. Workers per plans/procedures and as identified in Extent-of-Play agreements. I

c. DEFICIENCY: None I

d. PLAN ISSUES: None

e. NOT DEMONSTRATED:. *None 18p 1s

Unclassified R~adiological'Emergency PreparednessProgram (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power'Plant

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 Wayne County - Oakwood Southshore Medical Center - Medical Service - Facility In summary, the status of DHS/FEMA criteria for this location is as follows:

a. M ET: 1.d.l,1!.e.1.,.6.d.1. , ,.,.. ,* ,' .. . ,, ,-

b. AREAS REQUIRING CORRECTIVE ACTION: 3.a.l. ,, ',,

ISSUE NO.: 23-14-3al-A-01 CRITERION: The Offsite Response Organizations issue appropriate dosimetry, potassi.umn iodide. (KI), and procedures, and manage ,radiological exposure to emergency workers in accordancewith 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. Appropriate record-keeping of

,- the administration of KI-for emergency workers is maintained.

CONDITION: The Oakwood Southshore Medical Center (OSMC) Emergency

• -.Department Staff did not know how to zero their *dosimeters, did not recognize their

-dosimeter charger,, and were generally unfamiliar~with dosimetry and its use. The hospital's entire supply of dosimeters was stored in two Ziploc sandwich bags on the top shelf of the equipment closet between a spool and a loose coil of rope used to mark the Radiological Exclusion Area (REA) in the ambulance bay. The shock sensitive instruments had no protective packaging and a 5+,foot drop to .the tiled floor could have rendered them inoperable. Per the Extent-of-Play, 'The use of dosimetry and KI will be demonstrated by hospital staff.' Potassium iodide (RI) was neither observed, nor mentioned by either the hospital staff or controllers. Initially, the medical staff donned smocks rather than coveralls as Personal Protective Equipment for entry into the Decontamination Room. When advised to change into coveralls, the medical Staff taped the ends of the arms and legs so thoroughly that they were difficult to remove at the end of the drill. To make it easier for the HP Tech to monitor her for contamination, one of the nurses moved while being monitored and touched the survey meter probe with .her coveralls, requiring.

additional monitoring and potential decontamination of the monitoring equipment.

The Step-Off Pad indicated in the OSMC Radiological Emergency Area Diagram 19

Radiolgical Unclassified RailgcIEmergency Preparedness Program' (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plantn (OSMC RME Plan, Attachment 2) was neither used, mentioned nor observed in the equipment closet. Without a 'buddy system'.-ir 'chaii to. facilitate PPE removal, the

', medica~l staff attempted .tO remove the tapei sealing, their coveralls at'their ankles

while standing on their Other foot; .One person inadvertently leaned against the wall and required: additional, monitoring, .requiring: additional monitoring and .possibly decontamination. Shock sensitive direct reading dosimeters were dropped into a trash bag while being collected at the end of the drill and the medical staff did not

..kno.w that placing .the .bag of dosimeters in the Radiological waste bag; would result*

in additional exposure being inidicatedo6n the. dosimeters and most likely result in I

• contamination which would delay .their reuse., .'.. ._;..

II POSSIBLE CAUSE: The Oak~wood Southshore Medical Center (0SMG) Emergency Department's participation appeared to be. a realistic demonstration of ai actual, no- [

notice, response. The attending physician reported that she had stopped in on her day [

• off and was asked to assist with the drill. Real-world patients, arriving in ambulances from everY jurisdiction supported by the hospital, in~addition to walk-in patients, were admitted throughout the course of the Drill. The nursing staff demonstrated a veypositive, 'can do' attitude.and indicated that~managing multiple, concurrent crises is what:Emergency Departments .do. Both Treatment/Decon Nurses were competent and demonstrated enough-basic knowledge to suggest *that they* had i received some. radiological training.*. The hospital's radiology staff did not appear to [

• participate, so the Charge Nurse actedas. the Dosimetry Control Officer and personally performed all support functions outside of the Treatment/DecontaminationI Room. Radiological emergency response, contamination control and dosimetry training appeared minimal. The Charge Nurse referred to the Radiologicaln Emergency Area Diagram, referred to and periodically briefed portions of then Radiological Medical Emergency (RME) Plan procedures to the medical staff and [

maintained Personnel Dosimetry Log form, but no one else referred to any plans, [

procedures or checklists, etc. The dosimeters were not zeroed (realistic), which

.:,caused confusion and without pre-packaged dosimetry kits and individual briefing I cards, checklists, etc., the participants struggled to figure out what they needed.

.Surv.ey meters, dosimetry, barrier rope and tape, personal protective equipment,n

....* reference binders, Rad Waste bags, etc., .were stored in~the Radiological Emergencyn Equipment Storage Cabijnet/Closet, but-were not organized in a way that facilitated*

.*the response. . A copy. of the current OSMC RMVE Plan was not~provided to FEMA. [

20 n I

Unclassified Radiological Emergency Preparedness Program (R.EP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant

REFERENCE:

NUREG-0654/FEMA-REP-1, Criteria J. 10.e; K.3.a, b, K.4; FEMA REP ProgramManual of'Jiine*2013,.Part II; NUREG Criterion K.3.a, paragraph b.

"Dosimeters"' and paragraph e! '"Dose Control and Limits."; EPA: 4002R-92-00 1, Protective Action Guide Manual, *Table 2.2; and EPA Interim PAG Manual of March 2013 . *'*. ' -. .  :. ".- : -. . *- ,; "

EFFECT: Without 'the constant guidance~provided by the Michigan Department of Environmentail Equality (MDEQ) Health Physics .Technicians who actively participated throughout the drill, it appeared improbable' that the 0OSMC Emergency Department staff would have contained radiological contamination to the

.Decontamination Room. 'Despite .the MDEQ assistance,: numerous errors were

• observed, some of,which,. were not detected, and. would mtost likely have r'esulted in

.contamination being Spread outside of the Decontamination Room.

• RECOMMENDATION: .Review the* Radiological'. Medical Emergency Plan and

• consider replacing the Michigan Department of Environmental Equality (MDEQ)

Health. Physics Technicians with hospital radiology department staff who can be Sregularly trained'and integrated into the. REA team: and will be readily aVailable on

'short notice..Use radiology department staff to 'issue dosimetry and maintain exposure records, ,i'hich is their area of expertise 'and would permit'the Charge Nurse to focus supervising and, coordinating the REA' operations. Consider repurposing "MDEQ resources to provide training and oversight support rather than providing the primary contamination control. Consider reorganizing the REA staff to better distribute the workload and span-of-control: Consider reorganizing the Radiological Emergency Equipment Storage Cabinet so that, much like an operating room, essential items are stored in a w~ay that facilitates a timely and orderly response, e.g.

store coveralls, booties, face masks and head Covers sequentially' on the same shelf and/or post inventory sheets, checklists and visual aids on the inside of the Radiological Emergency Equipment Storage Cabinet doors* Develop pre-packaged individual dosimetry kits containing a DRD, OSLD, instruction card(s) and

• potassium iodide (if actually issued). Store dosimetry kits and the dosimeter charger(s).in a covered, plastic storage box/bin which is protected from drop, impact and crush hazards. Implement a 'buddy system' for donning/doffing personal protective equipment (PPE)'and/or provide'something 'for people to sit on while 2.1

• Unclassitled Radiological Emergency PreParedness program (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant

... re moving their PPE...Conduct dedicated andflhands-0n practical training for all [

potential REA staff members on the Radiologiqal Medical. Emergency Plan, with

• emphasis .on donning/doffing.PPE; theory and, operation.ofp~erso~nal dosimetry and

-per7sonal expo~sure conltrol;_and radiological pontamnination mitigation, control and

• *.decontamination. :R.edemonstrate this criterion within :120 days~of the publication of 3

l the final Afer Actin Reportl orv~ementj*lan. ..... ,.*:- ...

c. DEFICIENCY: None.... ...  : , , .).:;  :[

d. PLAN IS SUES: None I

e. NOT DEMONSTRAT.ED: None: .',- "*,.

.f. PRIOR ISSUES - RESOLED: None. "- "....'; ii

g. PRIOR ISSUES -UNRESOLVED: None. ..  ::..

3.3.1.3 Monroe County - Monroe Public Schools - EV-2 Interview .... Irl In summary, the status of DHSiFEMA, * .. this, location*is, as follows:,:

criteria for* II

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

b.. AREAS REQUIRING CORRECTIVE ACTION: None .,I

c. DEFICIENCY:*None .

d. PLAN ISSUES: 3.a.1. ...

ISSUE NO.: 23-14-3al-P-03 lI CRITERION: The Offsite Response Organizations issue appropriate dosimetry,

• potassium iodide .(KI), and procedures,, and manage radiological exposure to emergency workers in accordance with the Plans/procedures. Emergency workersi

• periodically and at the end of each mission read their dosimeters and record the [

readings on the appropriate exposure record or chart. Appropriate record-keeping of II

,the administration of KI for emergency workers is maintained.

I CONDITION: Per the Monroe Public School District (MPSD) Radiological Emergency Response: Plan,*(RERP), evacuation of all three. Tiers of risk schools requires between five, hours (best case) and seven hours (worst case). .Appendix 3- H Transportation Coordinator,Section III, Site Area Emergency (School in Session), [

states on page 44, 'Once s~tudents, have been evacuated, instruct bus drivers to report I to staging area at Monroe Community College for distribution of dosimetry and KI 22 m I

Unclassified

.Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant and reassignment;' If a relei~e'sbegins before the second or third tier risk schools have been evacuatedl, the :bus drivers could exit the EPZ without dosimetry and KI, but would require dosimetry andKLL to reenter the EPZ.* The plan *does not clearly define a process to ensure that dosimetry and KI will be issued to school bus drivers who need, to~re-en~ter the EPZ in order to evacuate student* and staff and eliminate potential confusion and unnecessary :delay in-the evacuation of Tier 2 .or 3 risk schools, caused by school bus drivers arriving at a Traffic and Access Control Point during a GE without proper dosimetry, KI and emergency worker training.*

POSSIBLE CAUSE: The Plan's underlying assumption is that all risk schools will be evacuated prior to any radiological release~and declaration of a General Emergency.

The possibility of a GE occurring in less than five to seven hours does not appear to have been considered.

REFERENCE:

NUREG-0654iFEMA-REP-1 Criteria J. 10.e, K.3.a, b, K.4, and FEMA REP Program Majiual of Julne 2013, Part II, NUREG Criterion K.3.a & b.

EFFECT: It is possible that school bus drivers Who' arrive at the staging area during a GE might inadvertently attempt to re-enter the EPZ in order to evacuate Tier 2 or 3 risk schools without proper dosimetry, KI1 and emergency worker training and would be turned back by Traffic and Access Control Point personnel because they lacked required emergency worker personal protective equipment required to enter the EPZ during a GE.

RECOMMENDATION: Add an action item to the 'General Emergency (School in session), If Evacuation is recommended or ordered' on page 44 directing that dosimetry, KI and Emergency Wor'ker Training be provided to School bus drivers who arrive at the MCC transfer point/staging area *during a GE (i.e. before they re-enter the EPZ). This would eliminate potential confusion and unnecessary delay in the evacuation of Tier 2 or 3 risk schools, caused by school bus drivers arriving at a Traffic and Access *Control Point during a GE Without appropriate emergency worker personal protective equipment and training. Overall, the MPS RERP is a well-conceived plan; However, several minor clerical errors in page and paragraph numbering (apparently introduced through successive updates) were observed in the Table of Contents and various attachments. Additionally, Appendix 3, Attachment 23

UnclassifiedI

.Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant C, Emergency Worker Control Criteria refers to~Roentgen equivalent man (rem) and Roentgen (R) interchangeabl;* the Michigain"Department of Environmental Quality (MDEQ) is revising their exposure limit language and the plan should adopt the new MDEQ language. The plan review St~aff Assistance Visits (SAVs) Scheduled for the spring of 2015 would provide an opportunity to identify & correct these minor inconsistencies.

.e. NOT DEMONSTRATED: None ';" *

f. PRIOR ISSUES - RESOLVED: None I Sg. PRIOR ISSUES - UNRESOLVE*D: None::

lI

.,, *, ,,I

• " " " " " "I I

lI I

Unclassified R'adiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Enirico Fermi 2 Nuclear Power Plant sECTioN 4: CONCLUSION:

There were no Deficiencies identified for the State of Michigan during the interview and drill.

There were no Deficiencies identified for Monroe County* during thae interview and drill.

There were no Deficiencies identified for Wayne County during the drill.

There were no Areas Requiring Corrective Action identified. for the State of Michigan *during the interview and drill.

There were no Areas Requiring Corrective Action identified for Monroe County during the interview.

There was one Area Requiring Corrective Action identified for Monroe County during the drill.

Monroe County received an Area Requiring Corrective Action under Criterion i .e. 1 - Contrary to the Extent-of-Play for Criterion 1.e. 1 and plans/procedures; Monroe County Ambulance staff was not issued potassium iodide (KI) as Monroe County Emergency Workers.

There was one Area Requiring Corrective Action identified for Wayne County during the drill.

Wayne County received an Area Requiring Corrective Action under Criterion 3.a. 1 - The Oakwood Southshore Medical Center (OSMC) Emergency Department Staff did not know how to zero their dosimeters, did not recognize their dosimeter charger, and were generally unfamiliar with dosimetry and its use. Per the Extent-of-Play, 'The use of dosimetry and KI will be demonstrated by hospital staff.' Potassium iodide (LU) was neither observed, nor mentioned by either the hospital staff or controllers. The Step-Off Pad indicated in the OSMC Radiological Emergency Area Diagram (OSMC RME Plan, Attachment 2) was neither used, mentioned nor observed in the equipment closet. Without the constant guidance provided by the Michigan Department of Environmental Equality (MDEQ) Health Physics Technicians who actively participated throughout the drill, it appeared improbable that the OSMC Emergency Department staff would have contained radiological contamination to the Decontamination Room.

Dedicated and.hands-on practical training is required for all potential REA staff members 25

Unclassified Radiological Emergency Preparedness Program'(REP)

I After Action Report-t/mprovement Plan Enrico Fermi 2 Nuclear Power Plant regarding the Radiological Medical Emergency Plan, with emphasis on donning/doffing PPE;

" "" """? *J' '"' " '*""

theory and operation of personal dosimetry and personalr exl~osuie control; and radiological contamination mnitigatio~n, control and decontamin~ation~, Thi* issue is sc~eduled to be resolved th~rough a complete :re-demuonstration of the medical 'servic~e drill on Aug-tast 25, 2015.

There was one Plan Issue identified for Monroe County during the interview.

Monroe County received a Plan Issue under Criterion 3.a. 1 - Per the Monroe Public School District (MPSD) Radiological-Emergency Response Plan :(RERP), evacuation~of all three Tiers

'of risk schools requires between five hours (best case,) and seven hours (worst'case). Once students have been evacuated, bus drivers-are instructed to. report to the staging area for distribution of dosimetr'y and KI and reassignment as emergency workers. If a relkase begins before the second or third tier risk schools have been evacuated, the bus drivers could exit thei EPZ without dosimetry and KI, but would require dosimetry- and KI to reenter the EPZ. The plan does not clearly define a pr'ocess to ensure that dosimetry and KI will be issued'to School bus drivers who need to re-enter the EPZ in order to evacuate students and staff which could potentially delay the evacuation of Tier 2 and 3 risk Schools.

There were no prior issues identified in previous interviews or drills requiring corrective action.U I

26I

Unclassified R~adiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power: Plant APPENDIX A: IMPROVEMENT PLAN ISSUE: Contrary was not issued to the Extent-of-Play potassium for Criterion iodide (KI) as Monroe County1.e.Emergency 1 and plans/procedures, Workers. Monroe County Ambulance staff RECOMMENDATION: Ensure that K! iSissued to Monroe County Emergency Workers per plafls/prdcedures and as identified in Extent-of-Play agreements.

CORRECTIVE ATIN DESCRIPTION: .Mo--nroe County .will re-demonstrate issuing potassium~iodide.

(KI) to the Monroe County Ambulance staff along With the Emergency Worker Kit that would be received. Per their email of July,2; 2015, the Michigan State Police, has proposed that the re-demonstration~be Conducted at 0900 on August 25, .20 15 at the South Shore Hospital. ______________________

Responder Safety and Health ""'Monroe County Emergency Management CAPABILITY ELEMENT: *, 'START DATE::

Systems and .Equipment .2015-03-05 ...

AGENCY POC:" ESTIMATFED COMPLETION DATE:

Mark Hammoiid 734-240-3135 -

• 2015-'08-25 . . .

27

Unclassified Radiological Emergency PreparedneassProgram (REP)

I After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant p,

ISSUE: Per the Monroe: Public School District (MPSD) Radiological :Emergency Response Plan (RERP), .

evacuation of all three Tiers of risk schools requires between five hours, (best. case) and seven hours (worst case).

Appendix 3 -.Transportation Coordinator,Section III, Site Area Emergency. (*School in Session), states on page 44,

'Once students have been evacuated, instruct bus drivers to report to .staging~area at Monroe Community College.

for distribution of dosimetry and KI and reassignment.' If a .release begins before the second or third tier risk m schools have~been evacuated, the bus drivers could exit th PZwthout dosimetry and KI, but would requireI dosimetry and KIt 9 r'eenter th~e EPZ. The plan does not clearly..define a process to ensure that dosimetry and KI will be issued to school bus drivers who need to re-enter the EPZ in order to evacuate, students and staff and eliminate potential confusion and unnecessary delay, in the eva~cuation of Tier,2 or 3 .risk: schools, caused by school bus drivers arriving at a Traffic and Access.Contro~l Point during a GE without properdosimetry, KI and I]

[

RECOMMENDATION: Add an action itenm to ihe :'General Emergency (School in session), If Evacuation is*

recommended or ordered' on page 44 directing tlhat dosimetryi, KI and Emergency Worker Training be *provided to school bus drivers who arrive at the MCC transfer point/staging area during a GE (i.e. before: they re-enter the EPZ). This would eliminate potential confusion~ and unnecessary delay in the evaicuation of Tier 2 or 3 risk schools, caused byschool buas drivers arriving 'at a Traffic and Access Control Point durirng a GE Withiout appropriate emergency worker personal protective equipment and tf-ainitig. Overall, the MPS RERP,kis awell-conceived plan. However, several minor clerical errors in page and paragraph numbering (apparently introducedI through successive updates) were observed in-the Table of Contents and variou~s attachments. Additiofially, Appendix .3, Attachment C, Emergency Worker Control Criteria refers toRoentgen equivalent man (rein) and Roentgen.(R) interchangeably; the Michigan Department of Environmental Quality (MDEQ) is: revisi~ng their [

exposure limit language and the p~lan should adopt the new MDEQ language...The plan review Staff.Assistance inconsistencies...

CORRECTIVE ACTION DESCRIPTION: Monroe County will 'patth orePbi Sho itit I Plan to reflect the changes requested by FEMA by August 2015............."

CAPABILITY:

Citizen Evacuation and Shelter-in-Place .Monroe

- PRIMARY RESPONSIBLE AGENCY:*

County Emergency Managemenit Agency* I CAPABILITY ELEMENT:

Planning AGENCY POC: .

START DATE,:.

.2015-03-05*

ESTIMATED COMPLETION DATE:

I Mark Hammond 734-240-3135 2015-08-31 I

28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Powver Plant

3. .

IS SUE: 'The Oakwood Southshore Medida~l 'Center (OSMC) Emergency' Department Staff did not kniow how to zero their dosimeters, did not:recognize their dosimeter charger, and were generally'unfamiiliar with dosimietry aind' its use. The hospital's entire supply of dosimeters was stored in two Ziploc'sandwich bags~on the top shelf of the.

equipment closet between a spool and a to6se"coil'of rope used to mark the RadiologicelExclusion Area"(REA) in.

the ambulance bay.. The shock sensitive instruments .hadno protectiv4e packaging and a 5#: fdot drop fo the tiled" floor could have rendered them inoperable. 'Per the Extent-of-Play,'The use of'dosimtetry and*KI" will be demonstrated by hospital staff.' Potassium iodide (KI). was neither observed, nor' mentioned by either.the hiospital staff or controllers. Initially;i the medical staff donned smbcks rather than' cov'eralls' as Personal Protective .

Equipment for. entry into: the Decontamination Roomi. When advised to ;change into co'Ceralls, the medidal 'staff taped the ends of the arnms and legs so thoroughly thiat th'ey w'Ere difficult to removOe at the 'end of the drill. 'To make it easier for the HP .Tech~toinonitor her for contamination, one of the nurses moved while being monitored and touched the survey meter probe with her coveralls, re~quiring, additional monitoring and potential decontamination of the monitoring equipm~ent. The' Step-Off Pad indic~+/-ed in' the OSMC Radiological Emergency Area Diagram (0SMC RME.Plan, A~ttdchment 2) was neither tis~ed, m'entioned nor oebserved in thae equipment closet. Without a

'buddy system' or, chair-to facilitate PPE remo.val, the medical staff attempted to remove the tape sealing their*

coveralls at their, ankles while standing On their other foot." 'Oie person inadvertently leaned against the wall .and' required additional muoni~toring, requiring additional monitor ~ng and possibly decontamination. Shock sensitive..

direct readixig dosime~te'rs 'Were dropped into a trash bag While beixig collected at the 'end of the drill and the .medical staff did not know that placing the bag of 'dosimeters in the' Radiological Waste bag would result in additional

'exposure being indicated On the dosim'eters and most likely r'esult in.contamina*tion.owhich would delay, their reuse...

RECOMMENDATION:' Review'the Radiological Medical Etijergerncy plan and consider feplacing the

Michigan Department of Environmental.Equali'ty (MDEQ) Health Physics T'echnicians with hospital radiology' department staff who can be regularly trained and'integi'ated into the PEA team and will bereadily available on short notice.. Use radiology department staff to issue dosimetry and maintain exposure records, which is'their area' of expertise and would permit the Charge Nurse to focus supervising and coordinating the REA operations.

• Consider irepurposing MDEQ resources to provide trainijng and oversight support rather than providing the primary contamination control. Consider reorganizing the REA staff'to better distribute the workload and span-of-control.

Consider reorganizing the Radiological Emergency Equipment Storage Cabinet so that, much like an operating room, essential items are stored in a way that facilitates a timely and orderly response, e.g. store coveralls, booties, face masks and head covers sequentially on the ,same .shelf and/or post inventory sheets, checklists and visual aids on the inside of the. Radiological Emergeriiy Equipment Storage Cabinet doors. Develop pre-packaged individual

'dosimetry kits containing a DRD,'OSLD, instruction card(s) and potassium iodide'(if actually issued)..Store" dosimetry kits and the dosimeter charger(s) in a covered, plastic storage box/bin which is protected from drop, impact and crush hazards. Implement a 'buddy system' .for donn~ing/doffing personal protective equipment (PPE)..

and/0r provide something for people to sit on while removing their PPE. Conduct dedicated and hands-on practical training for all potential REA staff members on the Radiological Medical Emergency Plan, with emphasis on donning/doffing PPE; theory and operation of personal dosimetry and personal exposure control; and radiological contamination mitigation, control and decontamination. Redemonstrate this criterion within 120 days of the nublication of the final After Action Report/Improvement Plan.

CORRECTIVE ACTION DESCRIPTION: The Wayne County Department of Homeland Security &

Emergency Management's action plan is to train a three (3) deep team, conduct two (2) drills and then re-demonstrate. Per their email of July 2, 2015, the Michigan State Police has proposed that the re-demonstration be conducted at 0900 on August 25, 2015 at the South Shore Hospital.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Emergency Triage and Pre-Hospital Treatment Wayne County Department of Homeland Security &

Emergency Management CAPABILITY ELEMENT: START DATE:

Training 20 15-03-04 AGENCY POC: ESTIMATED COMPLETION DATE:

Timothy McGillivary 734-728-3711 2015-08-25 29

Unclass~ified I

I Radiological Emergency Preparedness Program (R~EP)

After.Action. Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant APPENDIX B: DRILL EVALUATORS AND TEAM I LEADERS I

LOCATION DATE: 2014-1 2-1 6, SITE: Enrico Fermi 2 Nuclear Power Plant, MI EVALUATOR AGENCY i

Monroe Communi.ty Ambulance Wayne County - Oakwood Southshore Medical Center - Medical Service - Facili.ty

• Clinton Crackel Karl Rabenhorst FEMA RV FEMA RV I

Monroe County - Monroe Public Schools - EV-2 Interview

" ~~*Team Leader...

• Clinton Crackel Karl Rabenhorst FEMA RV FEMA RV I

I I

I I

I I

I I

I 30 I i

Unelassified SRad~iological'Ensergency Preparedness Program (REp)

After Action Report/Improvement Plan Enrico Fermi 2 Nuclear Power Plant

.';, . i , .*

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