ML16053A060

FEMA, Submittal of After Action Report/Improvement Plan for the Beaver Valley Power Station

ML16053A060
Person / Time
Site:	Beaver Valley
Issue date:	01/29/2016
From:	Tierney M US Dept of Homeland Security
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML16053A060 (56)

Text

U.S. Department of Homeland Security Region III One Independence Mall, 6th Floor 615 Chestnut Street Philadelphia, PA 19106-4404 0)FEMA JAN 3 9 2016 Nuclear Regulatory Commission Headquarters Office of Nuclear Security and Incident Response Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 To Whom It May Concern:

Enclosed is the final After Action Report/Improvement Plan for the Beaver Valley Power Station (BVPS) Medical Services (MS-I1) Drill that was held on November 4, 2015. The Lawrence County, Eliwood City Hospital and Noga Ambulance Service participated in the drill.

There were no Level 1 Findings, one (1) Level 2 Finding, and no Planning Issues identified. The Level 2 Finding was successfully re-demonstrated during the drill.

Based on the results of the exercise and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards of NUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

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

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

Beaver Valley Power Station After Action Report!

Improvement Plan Drill Date - November 4, 2015 Radiological Emergency Preparedness (REP) Program

Unclassified Radiological Emergency Preparedness Program (REP)

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After Action Reportllmprovement Plan Beaver Valley Powser Station Beaver Valley Power Station After Action Report/Improvement Plan Published January 12, 2016 EXECUTIVE

SUMMARY

.............................................................................. 5 SECTION 1: EXERCISE OVERVIEW...............

............................................. 6 1.1 Exercise Details................................................................................... 6 1.2 Exercise Planning Team Leadership.......................................................... 6 1.3 Participating Organizations.................................................................... 7 SECTION 2: EXERCISE DESIGN suMMARY.........

i......................................... 8 2.1 Exercise Purpose and Design................................................................... 8 2.2 Exercise Objectives, Capabilities and Activities............................................ 11 2.3 Scenario Summary............................................................................... 11 SECTION 3: ANALYSIS OF CAPABILITIES................................................... 12 3.1 Exercise Evaluation and Results.............................................................. 12 3.2 Summary Results of Exercise Evaluation.................................................... 12 3.3 Criteria Evaluation Summaries............................................................... 15 3.3.1 Support Jurisdictions........................................................................ 15 SECTION 4: CONCLUSION........................................................................ 17 APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS....................... 18 APPENDIX B: ACRONYMS AN]) ABBREVIATIONS........................................ 19 APPENDIX C: EXERCISE PLAN................................................................. 20 3

Unclassified Radiological Emergency Preparedness Program (REP)

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Imnprovement Plan Beaver Valley Poiier Station EXECUTIVE

SUMMARY

On November 4, 2015, a Medical Services (MS-i) Driliwas evaluated for the 10-mile Plume Exposure Pathway, Emergency Planning Zone (EPZJ around the Beaver Valley Power Station (BVPS) by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) Region m*. The most recent prior MS-i drill for this site was conducted on November 2, 2011.

The purpose of the Beaver Valley Power Station MS-i driliwas to assess the State and local offsite response organizations preparedness in responding to a radiological medical emergency.

The drill was held in accordance with FEMA' s policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERP) and procedures.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania, Lawrence County Department of Public Safety, Ellwood City Hospital and the Noga Ambulance Service who were evaluated during this exercise.

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

This report contains the final evaluation of the MS-i1 drill. The Commonwealth of Pennsylvania and local organizations demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Level 1 Findings, one (1) Level 2 Finding and no Plan issues identified. The Level 2 Finding was successfully re-demonstrated during the 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 Beaver Valley Po~ier Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Beaver Valley Power Station (BVPS) Medical Services (MS-i) Drill Type of Exercise Medical Services (MS-i) Drill Exercise Date November 4, 2015 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Not Applicable 1.2 Exercise Planning Team Leadership Victor Wilson State Training Coordinator Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, PA, 17110 (724) 682-5769 vicwilson@pa.gov Lee Torres Technological Hazards Program Specialist Federal Emergency Management Agency 615 Chestnut Street One Independence Mall, 6th Floor Philadelphia, PA, 19106 (202) 436-1455 lee.torres@fema.dhs.gov 6

Unclassified Radiological Fmergency Preparedness Program (REP)

After Action Report/Improvement Plan B~eaver Valley Po~~er Station Barton Freeman Technological Hazards Program Specialist Federal Emergency Management Agency 615 Chestnut Street One Independence Mall, 6th Floor Philadelphia, PA, 19106 (215) 931-5567 barton.freeman@fema.dhs, gov Dave Linkimer Offsite Coordinator First Energy Nuclear Operating Company Beaver Valley Power Station Route 168 Shippingport, PA, 15077 (412) 720-2940 dlinkimer@firstenergycorp.co m 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Beaver Valley Power Station exercise:

State Jurisdictions Pennsylvania Emergency Management Agency Support Jurisdictions Lawrence County, Ellwood City Hospital Lawrence County, Noga Ambulance Service Lawrence County Department of Public Safety 7

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Pov~r Station SECTION 2: EXERCISE DESIGN

SUMMARY

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

FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

44 CFR 350 establishes the policies and procedures for FEMA's initial and continued approval of State and local governments' radiological emergency planning and preparedness for commercial nuclear power plants. This approval is contingent, in part, on State and local government participation in joint exercises with licensees. FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

A.

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

Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; C.

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

Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process:

U.S. Department of Commerce, U.S. Nuclear Regulatory Commission, U.S. Environmental Protection Agency, U.S. Department of Energy, U.S. Department of Health and Human Services, U.S. Department of Transportation, U.S. Department of Agriculture, U.S. Department of the Interior, and U.S. Food and Drug Administration.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Poiwr Station Representatives of these agencies serve on the Region III Radiological Assistance Committee (RAC), which is chaired by FEMA. A Radiological Emergency Preparedness (REP) Medical Services drill was conducted November 4, 2015, to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Beaver Valley Power Station. The purpose of this exercise report is to present the drill results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency involving a contaminated injured individual.

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

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

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

• Radiological Emergency Preparedness Program Manual, July 2015 Section 1 of this report, entitled "Exercise Overview", presents the "Exercise Planning Team" and the "Participating Organizations".

Section 2 of this report, entitled "Exercise Design Summary", and includes the "Purpose and Design", "Exercise Objectives, Capabilities, and Activities", and the "Scenario Summary".

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

Section 4, of this report, entitled "Conclusion", is a description of the Region's overall assessment of the capabilities of the participating organizations. It also presents information on planning issues if any were identified.

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Unclassified Radiological Emer-gency Preparedness Program (REP)

After Action Report/Improvement Plan Beater Valley Poiier Station EMERGENCY PLANNING ZONE DESCRIPTION:

BVPS is located in western Pennsylvania on the southern bank of the Ohio River in Beaver County, Pennsylvania. The site is located near Shippingport Borough, about 1.5 miles from Midland, Pennsylvania, on 501 acres of fairly level terrace owned by the First Energy Nuclear Operating Company (FENOC). The latitude for the site is 400377189' north; the longitude is 80026902?' west. Two pressurized water reactors are located on the 17 acres of the parcel occupied by the power station. The operating licenses for the facility were granted,in July 1976 (Unit 1) and August 1987 (Unit 2); commercial operations began at the site during October 1976 (Unit 1) and November 1987 (Unit 2). Unit 1 generates an output of 954 megawatts (MW); the Unit 2 output is 978 MW. One-hundred and twenty sirens cover the plume EPZ; eighty-five of the sirens are in Pennsylvania, twelve in West Virginia and twenty-three are in Ohio.

Steep slopes that contributed to the development of river mill towns, where most of the industry and residences are located, characterize the general topography of the region. The region is part of the large industrial complex centered around Pittsburgh, Pennsylvania. The terrain rises from the Ohio River to a maximum elevation of 1,160 feet above mean sea level (MSL). Drainage is predominantly toward the river. The soils in the area are made up of alluvial sands and gravel.

The bedrock geology consists' of sedimentary formations composed of shale and sandstone. No faults are located under or near the facility. The Ohio River is about 664 feet above MSL, and the plant grade is 735 feet above MSL.

The climate is a humid continental type. The average annual temperature for the area is about 50°F. Annual precipitation is approximately 36 inches. The area around the plant is mostly agricultural or undeveloped. The nearest community is Shippingport Borough, Pennsylvania, which is the parent borough for the site and has a population of 237. The nearest major population center of more than 25,000'people is Pittsburgh, which has an estimated population of 305,841 and lies 22 miles to the southeast. The maximum population distribution, including residents and transients, is 112,445 in the 10-mile EPZ.

Four major industries employ a total of 8,000 persons within 10 miles of the plant.. Two small airfields (Beaver County and Herron Airport) are also in the 10 mile EPZ. Runways at both airports are oriented so that the extensions do not pass over the plant. No major thoroughfares exist in the immediate vicinity. The main line of the 'Conrail Railroad runs parallel to the plant along the north bank of the Ohio 'River.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Poiver St~ation 2.2 Exercise Objectives, Capabilities and Activities The Beaver Valley Power Station Medical Services (MS-i) drill evaluated by the Federal Emergency Management Agency was designed to demonstrate the capabilities of State and local emergency management agencies to technically assess the extent of the radiological impact from a contaminated injured individual, including transport and receipt at a hospital. The demonstration included the ability to:

A.

Respond to a radiation medical emergency following the procedures of Lawrence County Department of Public Safety, Ellwood City Hospital and Noga Ambulance Services.

B.

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

C.

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

D.

Initiate inter-agency cooperation between Noga Ambulance Services and Eliwood City Hospital.

2.3 Scenario Summary The exercise scenario for this Medical Services Drill consisted of simulated notifications of escalating emergency classification levels at Beaver Valley Power Station from Site Area Emergency tO General Emergency.

During the incident, an emergency worker assigned to vehicle decontamination was running and tripped over a fire hose and lands against a curb. The victim has a broken right ankle (not immediately known without X-rays) and is complaining of great pain in the area. The victim's right elbow/forearm area and the right knee are bruised and abraded. The left hand is also bruised and covered with dirt. Noga Ambulance Service was dispatched to the scene to provide medical support and transport to the nearest MS-i1 Hospital.

Upon arrival at Ellwood City Hospital, the Radiation Emergency Medical Team met the Emergency Medical Services (EMS) team at the exterior entrance to the Radiation Emergency Area (REA) to receive and treat the patient. The hospital's medical team assessed the patient's condition and surveyed the victim for radiological contamination. Initial contamination levels included: 1600 counts per minute (cpm) on right knaee; 1800 cpm on right elbow and 800 cpm on left hand.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlsImprovement Plan Beaver Valley Po~ier Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the November 4, 2015, Medical Services Radiological Emergency Preparedness (REP) Drill. The drill was conducted to demonstrate the ability of the Offsite Response Organizations to respond to a potentially contaminated injured person associated with the Beaver Valley Power Station.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the appropriate 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.

The drill was conducted and evaluated in accordance with the Radiological Emergency Preparedness Program Manual (July 2015) and NUREG 0654. The Evaluation Criteria included:

i.e. 1 Equipment and supplies to support operations 3.a. 1 Implementation of emergency worker exposure control 6.d.1 Transportation and treatment of contaminated injured individuals The drill successfully demonstrated the response capabilities of the participants (except as may be noted in Section 3.2, Summary Results of Drill Evaluation, and Section 3.3, Criteria Evaluation Summaries).

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Program Manual that was scheduled for demonstration during this drill by all participating jurisdictions and functional entities. Drill evaluation area criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters:

(Li) Level 1 Finding: an observed or identified inadequacy of organizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant (NPP).

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaier Valley Power Station (L2) Level 2 Finding: an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.

(P) Plan Issue: an observed or identified inadequacy of organizational in the offsite response organizations' (OROs) emergency plan/implementation procedures, rather than that of the ORO's performance.

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

(M) Met: status of a REP exercise Evaluation Area Criterion indicating that the participating CR0 demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the extent of-of-play agreement with no Findings assessed in the current exercise and no unresolved prior Findings.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improiement Plan Bea~er Valley Po~~er Station Table 3.1 - Summary of Drill/Exercise Evaluation Date: 11-04-2015

-o' Site: Beaver Valley Power Station (M) Met, (1) Level 1 Finding, (2) Level 2 Finding, (P) Planning Issue

.. u O

Emergency Operations Management Mobilization la 1 Facilities 1ib1 Direction and Control 1lcl Communications 1id1 Equipment and Supplies to Support Operations lel M

M

~P rtectivel Action Decision Making Emergency Worker Exposure Control 2a1 Accident Assessment and Pars for the Emergency Event 2bl PAD decision-making process and coordination for the General Public 2b2 PADs. for disabilities & access/functional needs people 2cl Radiological Assessment & Decision making for the Ingestion Pathway 2e1 Radiological Assessment & Decision making for Relocation/Reentry/Return 2dl Protective Action Implementation Implementation of Emergency Worker Exposure Control 3a1 M

M Implementation of KI PAID for Institutionalized Individuals/Public 3b2 Implementation of PADs for disabilities & access/functional needs people 3dcl Implementation of PADS for Schools 3 c2 Implementation of Traffic and Access Control 3dl Impediments to Evacuation 3 d2 Implementation of Relocation/Reentry/Return Decisions 3 fl_____

Field Measurements and Analysis RESERVED 4al Field Team Management 4a2 Plume Phase Field Measurement, Handling, & Analyses 4a3___

Post Plume Phase Field Measurements & Sampling 4bl1__

Emergency Notification and Public information Activation of the Prompt Alert & Notification System (ANS) 5al RESERVED 5a2 Activation of the Back-up ANS 5a3 Activation of the Exception Area ANS 5a4 Emergency Information & Instructions to the Public/Media 5bl Support Operations/Facilities Monitoring, Decontamination, & Registration of Evacuees 6a1 Monitoring/Decontamination of Emergency Workers and Equipment 6b 1 Temporary Care of Evacuees 6cl Transportation/Treatment of Contaminated Injured Individuals 6d1 M

M 14

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportIImproiement Plan Beawr Valley Poiwr Station 3.3 Criteria Evaluation Summaries 3.3.1 Support Jurisdictions 3.3.1.1 Lawrence County, Ellwood City Hospital In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 3.3.1.2 Lawrence County, Noga Ambulance Company 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. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS:

ISSUE NO: 3-15-6d1-L2-01 CRITERION: 6.d. 1 Transportation/Treatment of Contaminated Injured Individuals CONDITION: The Emergency Medical Technicians (EMTs) did not appropriately conduct glove changes while handling a potentially contaminated patient.

POSSIBLE CAUSE: The ambulance company did not receive adequate training prior to the demonstration.

REFERENCE:

NUJREG-0654/FEMA-REP-1, L.4 EFFECT: Improper contamination control could result in cross contamination of personnel and equipment.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportl/Improvement Plan Beaver Valley Poser Station CORRECTIVE ACTION DEMONSTRATED: EMT' s received on the spot training and re-demonstrated proper contamination control.

d. PLAN ISSUES: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 16

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

'Beaver" Valley Powier, Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and local jurisdictions, except where noted in this report demonstrated knowledge of their Radiological Emergency Response Plans (RERP) and procedures were adequately implemented during the Beaver Valley Power Station, Medical Services Drill evaluated on November 4, 2015.

Two (2) Federal Emergency Management Agency (FEMA) evaluators provided analyses of six evaluation criteria. These analyses resulted in a determination of one Level 2 Finding successfully re-demonstrated, no new Plan Issues, and no unresolved Plan Issues.

The Noga Ambulance Service successfully demonstrated that necessary equipment and supplies were available to support the treatment of an injured/contaminated victim. EMS personnel prioritized life-saving medical practices over contamination concerns, implemented protective measures through the use of Personal Protective Equipment (PPE), regular glove changes, and control of cross contamination. Appropriate patient assessments were demonstrated as well as regular and ongoing communications with Ellwood City Hospital.

The Ellwood City Hospital successfully demonstrated the mobilization of staff, staffing assignments, issue of dosimetry and monitoring equipment, and effective use of Personal Protective Equipment (PPE) during the exercise. The hospital staff effectively responded to communications from the Noga Ambulance Service, initiated the set-up and management of a Radiation Emergency Area (REA), and accepted and successfully treated an injured/contaminated victim while administering life-threatening medical attention over contamination concerns. In addition, the medical facility provided security control of the facility including the drop off bay for the patient and overall protective measures for contamination control and prevention of cross contamination.

Based on the results of the exercise and a review of the offsite Radiological Emergency Response Plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

An After Action Implementation Plan (IP) will not be developed as part of this report.

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Unclassified Radiological Emergency Preparedness Program (REP)

After, Action Report/Improvement Plan Beaier Valley Poijer Station APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leader for the Beaver Valley. Power Station 2015 Medical Services (MS-i) Exercise evaluated on November 4, 2015. The following constitutes the managing staff for the Exercise Evaluation:

• Thomas Scardino, DHS/ FEMA, Regional Assistance Committee (RAC) Chairman

• Lee A. Torres, DHTS/FEMA, Program Officer and Site Specialist

• Barton Freeman DHS/ FEMA, Technical Hazards Program Specialist, Evaluator DATE: 11/04/2015, SITE: Beaver Valley Power Station

,LOCATION

,TEAM LEADER

.. AGENCY Lawrence County, Ellwood City Hospital.

Barton Freeman FEMA Region III Lawrence County, Noga Ambulance Company Lee Torres

..FEMA Region III 18

Unclas sified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaver Vailley Pow~er Station APPENDIX B: ACRONYMS AND ABBREVIATIONS A

g I-

.~ s I

BVPS Beaver Valley Power Station BVPS Beaver Valley Power Station DHS Department of Homeland Security DRD Direct Reading Dosimeter EMS Emergency Medical Services EMT Emergency Medical Technician EOP Extent of Play EPZ Emergency Planning Zone ER Emergency Room FEMA Federal Emergency Management Agency FENOC First Energy Nuclear Operating Company GE General Emergency MS-i1 Medical Services NPP Nuclear Power Plant NRC Nuclear Regulatory Commission ORG Offsite Response Organization PPE Personal Protective Equipment PRD Permanent Record Dosimeter REA Radiation Emergency Area REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RO Radiological Officer SAE Site Area Emergency 19

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReporfIlmprovement Plan Beaver Valley Poiser Station APPENDIX C: EXERCISE PLAN The enclosed Exercise Plan was created as an overall tool for facilitation and implementation of the Beaver Valley Power Station Medical Services Drill and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program Exercise Methodology.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportfImprovement Plan Bea~ar Valley Pos~er Station Exercise Plan Beaver Valley Power Station FEMA Evaluated Medical Services.(MS-i1) Drill U.S. DEPARTMENT OF HOMELAND SECURITY 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaver Valley Poiier Station Preface The 2015 Beaver Valley Power Station Evaluated Medical Services Drill (MS-i) is sponsored by Pennsylvania Emergency Management Agency (PEMA) and the Federal Emergency Management Agency (FEMA). This Exercise Plan (ExPlan) was produced with input, advice, and assistance from the Exercise Planning Team (EPT), which followed the guidance set forth in the Federal Emergency Management Agency (FEMA), Homeland Security Exercise and Evaluation Program (HSEEP).

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

The 2015 Beaver Valley Power Station MS-i Drill is an unclassified exercise. The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, Controllers, and Evaluators, but Players may view other materials deemed necessary to their performance. The ExPlan may be viewed by all exercise participants, but the Controller and Evaluator (C/E) 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 DHS and the EPT.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

.Bea~er Valley Po~~er Station Handling Instructions

1. The title of this document is 2015 Beaver Valley Power Station MS-i 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 points of contact (POCs):

Federal POC(s):

Lee A. Torres, Project Officer & Site Specialist Department of Homeland Security (DHS)

Federal Emergency Management Agency (FEMA) 615 Chestnut Street One Independence Mall Philadelphia, Pennsylvania 215.931.5563

• lee.a.torres@dhs. gov" State POC(s):

Victor Wilson, Radiological Planner Pennsylvani'a Emergency Management Agency P.O. Box 4 Simulator 2 Shippingport, Pennsylvania 15077 717.433.1227 vicwilson~state.pa.us 24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllnmprovement Plan Beaver Valley Povier Station TABLE OF CONTENTS Exercise Plan..............................................................................................

20 BEAVER VALLEY POWER STATION FEMA EVALUATED REP EXERCISE..........................

20 U.S. DEPARTMENT OF HOMELANID SECURITY..............................................

20 Preface..................................................:....................................................

23 Handling Instructions....................................................................................

24 Chapter 1: General Information......................................................................

27 Introduction........................................................................................... 27 Confidentiality......................................................................................... 27 Purpose..................................................................................................

27 Target Capabilities..................................................................................... 28 Exercise Objectives................................................................................... 28 Chapter 2: Exercise Logistics......................................................

i.......................30 Exercise Summary........................

30 General.....................................

30 Assumptions.......................

.................................................................... 30 Constructs and Constraints.....................................................

................... 30 Exercise Participants............................................

....... 31 Controller and Evaluator Handbook................................................................. 32 Master Scenario Events............................................................................ 32 Exercise Implementation.............................................................................

32 Exercise Play....................................................................................... 32 Exercise Rules...................................................................................... 33 General.............................................................................................. 33 Exercise Setup.................................

...................................................... 34 Accident Reporting and Real Emergencies.........

34 Site Access............................................................................................ 34 Security.............................................................................................. 34 Observer Coordination............................................................................ 35 Parking and Directions............................................................................. 35 Restroom Facilities................................................................................. 35 Exercise Identification................................................................................ 35 Communications Plan................................................................................. 35 Exercise Start, Suspension, and Termination Instructions...................................... 35 Player Communication............................................................................. 35 Player Briefing...................................................................................... 36 Public Affairs....................................................................................... 36 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improxement Plan Beawer Valley Poiier Station Chapter 3: Player Guidelines................

........................................................ 37 Exercise Staff.......................................................................................... 37 Lead Controller...................................................................................... 37 Controllers.......................................................................................... 37 Evaluators.......................................................................................... 38 Player Instructions.................................................................................... 38 Before the Exercise.................................................................................. 38 Following the Exercise............................................................................ 39 Simulation Guidelines.....................................

• .......................................... 40 Chapter 4: Evaluation and Post-Exercise Activities.............................................. 41 Exercise Documentation..............................................................,.......,......... 41 Mfter Action Report.................................................................................... 41 After Action Conference and Improvement Plan...................................................41 After Action Conference.............

............................................................. 41 Improvement Plan......... i.....................

............. *..................................... 42 Appendix A: Exercise Schedule...................................................................... 43 Appendix B: Extent of Play Information........................................................... 44 26

Unclas sified Radiological' Emergency Preparedness Program (REP)

After Action Reportllmnproiement Plan Beaier Valley Powier Station Chapter 1: General Information Introduction The 2015 Beaver Valley Power Station Medical Services Drill is a Functional Exercise (FE) designed to establish a learning environment for players to exercise emergency response plans, policies, and procedures as they pertain to Nuclear Power Plant accidents. A Functional Exercise is a complex event that requires detailed planning. To conduct an effective exercise, subject matter experts (SMEs) and local representatives from numerous agencies have taken part in the planning process and will take part in exercise conduct and evaluation.

This Exercise Plan (ExPlan) was produced at the direction of the Federal Emergency Management Agency with the input, advice, and assistance of the Commonwealth of Pennsylvania. The 2015 Beaver Valley Power Station Medical Services Drill is evidence of the growing partnership between State and local jurisdictions for response to the threats our Nation and communities face, Confidentiality The 2015 Beaver Valley Power Station Medical Services Drill is an unclassified exercise. The control of informationi 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 (C/E) 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 Federal Emergency Management Agency (FEMA) and the Exercise Planning Team.

Purpose The purpose of this exercise is to evaluate player actions against current response plans and capabilities for a nuclear power plant-related incident, and to comply with the requirements of 44 CFR 350 and the guidelines of NUREG 0654/FEMA-REP-1. Exercise planners utilized the elements described in the 67 FR 20580 (April 25, 2002) and Radiological Emergency Preparedness (REP) Program Manual (July 2015) to develop this exercise.

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Unclassified Radiological Emergency Preparedness Program' (REP)

After Action Report/Improiement Plan B~eaier Valley Poiwer Station The objective of The Federal Emergency Management Agency and, The Pennsylvania Emergency Management Agency, and local jurisdictions is to demonstrate reasonable assurance that the public can be protected during a nuclear power plant emergency.

Target Capabilities The establishment of the National Preparedness Priorities have steered the focus of homeland security toward a capabilities-basedplanning approach. Capabilities-basedplanning 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 Program Manual (July 2015), 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 and Decontamination

• Emergency Triage and Pre-Hospital Treatment

• Medical Supplies Management and Distribution Exercise Objectives The Emergency Preparedness Evaluation Areas - the elements and sub elements - for this drill are those that are required to be demonstrated in every MS-i Drill, per 67 FR 20580 (April 25, 2002) and the Radiological Exercise Preparedness (REP) Program Manual (July 2015). Appendix B, Extent of Play, shows the emergency preparedness elements that are required to be demonstrated in the 2015 Beaver Valley Power Station Medical Services Drill, along with the level of demonstration that will be displayed in the exercise (i.e., fully demonstrated limited demonstration, simulated, Out-of-Sequence interviews, not demonstrated).

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley PowerStation 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.

Outstanding Issues There are no deficiencies, Areas Requiring Corrective Action (ARCAs), or planning issues as a result of the FEMA-evaluated plume-phase exercise at Ellwood City Hospital MS-i1 Drill conducted November 2, 2011.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lInprovement Plan Beaver Valley Poiier Station Chapter 2: Exercise Logistics Exercise Summary General The 2015 Beaver Valley Power Station Medical Services Drill is designed to establish a learning environment for players to exercise their plans and procedures for responding to a nuclear power plant incident. The 2015 Beaver Valley Power Station Medical Services Drill will be conducted on November 4, 2015. Exercise play is scheduled for four (4) hours or until the Lead Controller, after consulting with the FEMA Site Specialist, 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 2015 Beaver Valley Power Station. Medical* Services Drill:

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

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

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

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

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

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

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

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After Action Report/Imnprovement Plan Beaver Valley Poiier Station

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

• 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 exerciseand 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 evaluation functions. Local Observers will view the exercise from a designated observation area and will be asked to remain within the observation area during the exercise. PEMA observers may be present at selected locations as assigned by the Lead Controller. VJIPs or other visitors will be handled by each agency or location (Municipal BOC, County BOC, etc.) according to those agencies' policies and procedures.

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After Action Report/Improvement Plan Beaver Valley Poiier Station

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

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

Exercise Tools Controller and Evaluator Handbook The 2015 Beaver Valley Power Station Medical Services Drill C/E Handbook is designed to help exercise Controllers and Evaluators conduct and evaluate an effective exercise. This Handbook also enables Controllers and Evaluators to understand their roles and responsibilities in exercise execution and evaluation.

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

For the 2015 Beaver Valley power Station Medical Services Drill the MSEL will not be used.

Exercise Implementation Exercise Play Exercise play will begin at approximately 0800 with a situation update going to each participating venue. Play will proceed according to the events outlined in the scenario, in accordance with established plans and procedures. The exercise will conclude upon the completion of operations and attainment of the exercise objectives, as determined by the Lead Controller after consultation with Lead FEMA Evaluator.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reporf/Improiement Plan Beaiar Valley Poiwr' Station 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 a drill. "

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

Safety Requirements General Exercise participant safety takes priority over exercise events. Although the organizations involved in the 2015 Beaver Valley Power Station Medical Services Drill Come from various response agencies, they share the basic responsibility for ensuring a safe environment for all personnel involved in the exercise. In addition, aspects'of an emergency response are dangerous.

Professional health and Safety ethics should guide all participants to operate in their assigned roles in the safest manner possible. The following general requirements apply to the exercise:

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.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

.Beaver Valley Power Station 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 9-1-1,and state "This is not aDrill" prior to explaining the inj ury 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 A Drill" on the controller radio netiwork or telephone, providing the following information to the Lead Controller and Exercise Director:

o Venue/Ifunction o

Location within the venue / function o

Condition o

Requirements

• 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 The Lead Controller or Exercise Director will control entry to the exercise venues. To prevent confusion and interruption of the exercise, access to the exercise sites will be limited to exercise participants oniy. 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.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inmprovement Plan Beaver Valley Po~r Station Observer Coordination Each organization with observers will coordinate with the Lead Controller or Exercise Director for access to the exercise site. Observers will be escorted to an observation area for orientation and conduct of the exercise. All observers Will be asked to remain within the designated observation area during the exercise. Exercise Director and/or the Observer Controller will be present to explain the exercise program and answer questions for the observers during the exercise..

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

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 isin play.

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 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Beaver Valley Pow~er Station 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 handourts or other materials to give to players in order to better orient them to the exercise environment.

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

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Uniclassified Radiological Emergency Preparedness Program (REP)

After Action Reportflmnpraoement Plan Beaiar Valley Poiier Station Chapter 3: Player Guidelines Exercise Staff Exercise Director The Exercise Director has the overall responsibility for planning, coordinating, and overseeing all exercise fuhctions. The Exercise Director for the 2015 Beaver Valley Power Station Medical Services Drill is the Lead Controller who will manage the exercise activities and maintain a close dialogue with the Controllers regarding the status of play and the achievement of the exercise design objectives.

Trusted Agents Trusted agents are exercise planners and participants 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 2015 Beaver Valley Power Station MS-i Drill include the Exercise Director, Lead Controller, First Energy Nuclear, Beaver County Office of Emergency Management, and the FEMA Site Specialist.

Lead Controller The Lead Controller is responsible for the overall organization of the 2015 Beaver Valley Power Station MS-i Drill. The Lead Controller monitors exercise progress and coordinates decisions regarding deviations or significant changes to the scenario cansed by unexpected developments during play. The Lead Controller monitors actions by individual Controllers and ensures they implement all designated and modified actions at the appropriate time. The Lead Controller debriefs the Controllers after the exercise and oversees the setup and takedown of the exercise.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Po~ier Station Lead Evaluator The Lead Evaluator is responsible for the overall evaluation of the 2015 Beaver Valley Power Station MS-i Drill. The Lead Evaluator monitors exercise progress and stays in contact with the Lead Controller regarding changes to the exercise during play. The Lead Evaluator monitors actions of individual Evaluators and ensures they are tracking progress of the players in accordance with the Overview of Play. The Lead Evaluator debriefs the evaluators after the exercise and oversees the entire evaluation and After Action process. The Lead Evaluator will be the FEMA Region HI Site Specialist for Beaver Valley Power Station.

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

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

Player Instructions Before the Exercise

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

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

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

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

• Please sign in.

During the Exercise

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

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

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Powier Station

• 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, conlcise 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.

• 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.

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

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

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Unclassified.

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Povier Station Simulation Guidelines Because the 2015 Beaver Valley Power Station MS-i Drill is of limited duration and scope, the physical description of what would frilly occur at the incident sites and surrounding areas will be relayed to the Players by Simulators or Controllers.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Beaver' Valley Power Station Chapter 4: Evaluation and Post-Exercise Activities Exercise Documentation The goal of the 2015 Beaver Valley Power Station MS-i Drill is to comprehensively exercise and evaluate the OROs' plans and capabilities as they pertain to a potential nuclear power plant incident. After the exercise, data collected by Controllers, Evaluators, and Players will be used to identify strengths and areas for improvement in the context of the exercise design objectives.

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

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

After Action Conference and Improvement Plan The improvement process represents the comprehensive, continuing preparedness effort of which the 2015 Beaver Valley Power Station MS-i Drill is a part. The lessons learned and recommendations fr~om the AAR will be incorporated into the Improvement Plan (IP).

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 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 2015 Beaver Valley Power Station MS-i Drill participating agency officials during the AAC scheduled within 60 days of the drill.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improiement Plan Beaver Valley Poiver Station Appendix A: Exercise Schedule Table A.1 2015 Beaver Valley Power Station MS-i1 Drill Schedule S

November 4, 2015 0800 Lawrence County Department of Exercise Begins Public Safety, Noga Ambulance Services and Eliwood City Hospital 1200 Ellwood City Hospital Exercise Ends 1215 All Drill Participants Critique and Debrief 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllxmprovement Plan Beaver Valley Poiser Station Appendix B: Extent of Play Information BEAVER VALLEY POWER STATION ELLWOOD CITY HOSPITAL MEDICAL SERVICES DRILL November 4, 2015 Method of Operation

1.

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

2.

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

3.

First Energy Nuclear will participate as a Controller in this drill.

4.

Lawrence County Departm~ent of Public Safety will participate in this drill.

5.

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

6.

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

7.

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

8.

Drill activities are scheduled to commence on or about 0800, November 4, 2015 and continue until the participants have completed the drill objectives and demonstrated the Exercise Evaluation Criteria.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Poiier 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 drill any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants during the exercise, provided it does not negatively interfere with the exercise. Refresher training may be provided by the players, observers, and/or controllers. Evaluators are not per~mitted to provide refresher training.

Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. PEMA may advise the RAC Chair prior to initiating any re-demonstrations.

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

Objectives A.

Demonstrate the ability to respond to a radiation medical emergency following the procedur'es of Lawrence County Department of Public Safety, Noga Ambulance Service /

EMS and Ellwood City Hospital.

B.

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

C.

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

D.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Powecr Station Extent of Play Evaluation Area 1--Emergency Operations Management Sub-Element i.e--Equipment and Supplies to Support Operations Intent This sub-element is derived from NUREG-0654 / FEMA-REP-1, which requires 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 (KU), and other supplies are sufficient to support emergency operations.

(NUREG-0654 / EEMA-REP-1, 11.7,10; 1.7, 8, 9; J.10.a, b, e, J.11, 12; K.3.a; K.5.b).

Extent of Play Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation and subsequent periodic inspections.

A particular facility's equipment and supplies must besufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use ofrmaps 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 equiipment (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 caipability 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 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Po~ver Station identifying emergency workers that have declined K(1 in advance. Consider carefully the placement of emergency workers that have declined KI1 in advance.

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 SAy.

Available supplies of KI must be within the expiration date indicated on K(1 bottles or blister packs. As an alternative, the ORO may produce a letter fr'om a certified private or State laboratory indicating that the KI supply remains potent, in accordance with U.S. Pharmacopoeia standards.

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, HAZM'AT, 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 piansj/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-138s) (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 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Vallcy Poiver Station 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 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 1R/hr) 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:

Ambulance crews are not trained or equipped to operate or carry radiological monitoring equipment. In accordance with PEA/A 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. "Category C" emergency worker dosimetry issue consists of one permanent reading dosimeter per worker.

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.

48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Beaver Valley Poiser Station Outstanding Issues:

None 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beawer Valley Power Station Evaluation Area 3--Protective Action Implementation Sub-Element 3. a--Implementation of Emergency Worker Exposure Control Intent This Sub-element is derived from NUJREG0654 / FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for. each emergency worker; establishing a decision chain or authorization procedure. for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KIt for emergency workers, always applying the "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, K.3.a, b; K.4)

Extent of Play Assessment of this Demonstration,criterion may be accomplished during a biennial or tabletop exercise. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI1, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dos imetry 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.

50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Beaver Valley Poi~er Station 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 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 co -workers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. 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., EO~s 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 re-enter an evacuated area during the plume (emergency) phase, must be limited to the lowest radi1ologicail 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., lifesaving, protection of valuable property, all activities). OROs must ensure that the process uised to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving 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 thle 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 RI 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.

51

Unclassified Radiological Emergency Prepa~redness Program (REP)

After Action Report/Improvement Plan Beaver Valley Poijer Station State Negotiated Extent of Play:

Demonstrate appropriate procedures and equipment to manage radiologi cal 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.

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 pl ayers or supervisors to clarify radiological information. In Pennsylvania, emergency workers outside the EPZ do not have turn-back values. Standard issue of dosimetry and potassium iodide for each category of emergency worker isas follows:

Category A: 1 PRD, 1 DRD, and 1 unit of KJ Category B." I PRD and 1 unit of KI Cate gory C.. 1 PRDJT All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP) will make the dosimetry equipment (and K!, as appropriate) available for inspection by the Federal Evaluator. Simulation PRDs with mock serial numbers may be used.

Outstanding Issues:

None 52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaver Valley Poiier Station Evaluation Area 6--Support Operation / Facilities Sub-Element 6. d--Transportation and Treatment of Contaminated In] ured Individuals Intent This Sub-element is derived from NUJREG0654 / FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Criterion 6.d.l: The facility / ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

(NUIREG0654 /FEEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4)

Extent of Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, or drills. FEMA has determined that these capabilities have been enhanced and consistently demonstrated as adequate; therefore, offsite medical services drills need only be evaluated biennially. FEMA will, at the request of the involved ORO, continue to evaluate the drills on an annual basis. If more than two medical facilities and transportation providers are designated as primary or backup, they are also evaluated biennially.

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. It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "victim(s)" to the medical facility. This option is used in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests of the community.

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 53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovemnent Plan Beaver Valley Poiier Station 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. Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s). However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored. Before using monitoring instruments, the monitor(s) must demonstrate the process 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. Medical facilities are expected to have at least one trained physician and one trained nurse to perform and supervise treatment of contaminated injured individuals. 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 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, uniess 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 contaminated/injured individuals.

Demonstrate the ability to transport contaminated /injured individuals while using ALARA principles.

Noga Ambulance Service will pick-up a pre-staged simulated contaminated / in]juredvictim.

Outstanding Issues:

None 54

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvenment Plan Reaver Valley Posier Station 55

U.S. Department of Homeland Security Region III One Independence Mall, 6th Floor 615 Chestnut Street Philadelphia, PA 19106-4404 0)FEMA JAN 3 9 2016 Nuclear Regulatory Commission Headquarters Office of Nuclear Security and Incident Response Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 To Whom It May Concern:

Enclosed is the final After Action Report/Improvement Plan for the Beaver Valley Power Station (BVPS) Medical Services (MS-I1) Drill that was held on November 4, 2015. The Lawrence County, Eliwood City Hospital and Noga Ambulance Service participated in the drill.

There were no Level 1 Findings, one (1) Level 2 Finding, and no Planning Issues identified. The Level 2 Finding was successfully re-demonstrated during the drill.

Based on the results of the exercise and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards of NUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

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

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

Beaver Valley Power Station After Action Report!

Improvement Plan Drill Date - November 4, 2015 Radiological Emergency Preparedness (REP) Program

Unclassified Radiological Emergency Preparedness Program (REP)

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaver Valley Powser Station Beaver Valley Power Station After Action Report/Improvement Plan Published January 12, 2016 EXECUTIVE

SUMMARY

.............................................................................. 5 SECTION 1: EXERCISE OVERVIEW...............

............................................. 6 1.1 Exercise Details................................................................................... 6 1.2 Exercise Planning Team Leadership.......................................................... 6 1.3 Participating Organizations.................................................................... 7 SECTION 2: EXERCISE DESIGN suMMARY.........

i......................................... 8 2.1 Exercise Purpose and Design................................................................... 8 2.2 Exercise Objectives, Capabilities and Activities............................................ 11 2.3 Scenario Summary............................................................................... 11 SECTION 3: ANALYSIS OF CAPABILITIES................................................... 12 3.1 Exercise Evaluation and Results.............................................................. 12 3.2 Summary Results of Exercise Evaluation.................................................... 12 3.3 Criteria Evaluation Summaries............................................................... 15 3.3.1 Support Jurisdictions........................................................................ 15 SECTION 4: CONCLUSION........................................................................ 17 APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS....................... 18 APPENDIX B: ACRONYMS AN]) ABBREVIATIONS........................................ 19 APPENDIX C: EXERCISE PLAN................................................................. 20 3

Unclassified Radiological Emergency Preparedness Program (REP)

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Imnprovement Plan Beaver Valley Poiier Station EXECUTIVE

SUMMARY

On November 4, 2015, a Medical Services (MS-i) Driliwas evaluated for the 10-mile Plume Exposure Pathway, Emergency Planning Zone (EPZJ around the Beaver Valley Power Station (BVPS) by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) Region m*. The most recent prior MS-i drill for this site was conducted on November 2, 2011.

The purpose of the Beaver Valley Power Station MS-i driliwas to assess the State and local offsite response organizations preparedness in responding to a radiological medical emergency.

The drill was held in accordance with FEMA' s policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERP) and procedures.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania, Lawrence County Department of Public Safety, Ellwood City Hospital and the Noga Ambulance Service who were evaluated during this exercise.

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

This report contains the final evaluation of the MS-i1 drill. The Commonwealth of Pennsylvania and local organizations demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Level 1 Findings, one (1) Level 2 Finding and no Plan issues identified. The Level 2 Finding was successfully re-demonstrated during the drill. Furthermore, there were no Prior Issues to be resolved as a result of previous drills.

5

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Po~ier Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Beaver Valley Power Station (BVPS) Medical Services (MS-i) Drill Type of Exercise Medical Services (MS-i) Drill Exercise Date November 4, 2015 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Not Applicable 1.2 Exercise Planning Team Leadership Victor Wilson State Training Coordinator Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, PA, 17110 (724) 682-5769 vicwilson@pa.gov Lee Torres Technological Hazards Program Specialist Federal Emergency Management Agency 615 Chestnut Street One Independence Mall, 6th Floor Philadelphia, PA, 19106 (202) 436-1455 lee.torres@fema.dhs.gov 6

Unclassified Radiological Fmergency Preparedness Program (REP)

After Action Report/Improvement Plan B~eaver Valley Po~~er Station Barton Freeman Technological Hazards Program Specialist Federal Emergency Management Agency 615 Chestnut Street One Independence Mall, 6th Floor Philadelphia, PA, 19106 (215) 931-5567 barton.freeman@fema.dhs, gov Dave Linkimer Offsite Coordinator First Energy Nuclear Operating Company Beaver Valley Power Station Route 168 Shippingport, PA, 15077 (412) 720-2940 dlinkimer@firstenergycorp.co m 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Beaver Valley Power Station exercise:

State Jurisdictions Pennsylvania Emergency Management Agency Support Jurisdictions Lawrence County, Ellwood City Hospital Lawrence County, Noga Ambulance Service Lawrence County Department of Public Safety 7

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Pov~r Station SECTION 2: EXERCISE DESIGN

SUMMARY

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

FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

44 CFR 350 establishes the policies and procedures for FEMA's initial and continued approval of State and local governments' radiological emergency planning and preparedness for commercial nuclear power plants. This approval is contingent, in part, on State and local government participation in joint exercises with licensees. FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

A.

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

Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; C.

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

Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process:

U.S. Department of Commerce, U.S. Nuclear Regulatory Commission, U.S. Environmental Protection Agency, U.S. Department of Energy, U.S. Department of Health and Human Services, U.S. Department of Transportation, U.S. Department of Agriculture, U.S. Department of the Interior, and U.S. Food and Drug Administration.

8

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Poiwr Station Representatives of these agencies serve on the Region III Radiological Assistance Committee (RAC), which is chaired by FEMA. A Radiological Emergency Preparedness (REP) Medical Services drill was conducted November 4, 2015, to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Beaver Valley Power Station. The purpose of this exercise report is to present the drill results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency involving a contaminated injured individual.

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

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

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

• Radiological Emergency Preparedness Program Manual, July 2015 Section 1 of this report, entitled "Exercise Overview", presents the "Exercise Planning Team" and the "Participating Organizations".

Section 2 of this report, entitled "Exercise Design Summary", and includes the "Purpose and Design", "Exercise Objectives, Capabilities, and Activities", and the "Scenario Summary".

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

Section 4, of this report, entitled "Conclusion", is a description of the Region's overall assessment of the capabilities of the participating organizations. It also presents information on planning issues if any were identified.

9

Unclassified Radiological Emer-gency Preparedness Program (REP)

After Action Report/Improvement Plan Beater Valley Poiier Station EMERGENCY PLANNING ZONE DESCRIPTION:

BVPS is located in western Pennsylvania on the southern bank of the Ohio River in Beaver County, Pennsylvania. The site is located near Shippingport Borough, about 1.5 miles from Midland, Pennsylvania, on 501 acres of fairly level terrace owned by the First Energy Nuclear Operating Company (FENOC). The latitude for the site is 400377189' north; the longitude is 80026902?' west. Two pressurized water reactors are located on the 17 acres of the parcel occupied by the power station. The operating licenses for the facility were granted,in July 1976 (Unit 1) and August 1987 (Unit 2); commercial operations began at the site during October 1976 (Unit 1) and November 1987 (Unit 2). Unit 1 generates an output of 954 megawatts (MW); the Unit 2 output is 978 MW. One-hundred and twenty sirens cover the plume EPZ; eighty-five of the sirens are in Pennsylvania, twelve in West Virginia and twenty-three are in Ohio.

Steep slopes that contributed to the development of river mill towns, where most of the industry and residences are located, characterize the general topography of the region. The region is part of the large industrial complex centered around Pittsburgh, Pennsylvania. The terrain rises from the Ohio River to a maximum elevation of 1,160 feet above mean sea level (MSL). Drainage is predominantly toward the river. The soils in the area are made up of alluvial sands and gravel.

The bedrock geology consists' of sedimentary formations composed of shale and sandstone. No faults are located under or near the facility. The Ohio River is about 664 feet above MSL, and the plant grade is 735 feet above MSL.

The climate is a humid continental type. The average annual temperature for the area is about 50°F. Annual precipitation is approximately 36 inches. The area around the plant is mostly agricultural or undeveloped. The nearest community is Shippingport Borough, Pennsylvania, which is the parent borough for the site and has a population of 237. The nearest major population center of more than 25,000'people is Pittsburgh, which has an estimated population of 305,841 and lies 22 miles to the southeast. The maximum population distribution, including residents and transients, is 112,445 in the 10-mile EPZ.

Four major industries employ a total of 8,000 persons within 10 miles of the plant.. Two small airfields (Beaver County and Herron Airport) are also in the 10 mile EPZ. Runways at both airports are oriented so that the extensions do not pass over the plant. No major thoroughfares exist in the immediate vicinity. The main line of the 'Conrail Railroad runs parallel to the plant along the north bank of the Ohio 'River.

10

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Poiver St~ation 2.2 Exercise Objectives, Capabilities and Activities The Beaver Valley Power Station Medical Services (MS-i) drill evaluated by the Federal Emergency Management Agency was designed to demonstrate the capabilities of State and local emergency management agencies to technically assess the extent of the radiological impact from a contaminated injured individual, including transport and receipt at a hospital. The demonstration included the ability to:

A.

Respond to a radiation medical emergency following the procedures of Lawrence County Department of Public Safety, Ellwood City Hospital and Noga Ambulance Services.

B.

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

C.

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

D.

Initiate inter-agency cooperation between Noga Ambulance Services and Eliwood City Hospital.

2.3 Scenario Summary The exercise scenario for this Medical Services Drill consisted of simulated notifications of escalating emergency classification levels at Beaver Valley Power Station from Site Area Emergency tO General Emergency.

During the incident, an emergency worker assigned to vehicle decontamination was running and tripped over a fire hose and lands against a curb. The victim has a broken right ankle (not immediately known without X-rays) and is complaining of great pain in the area. The victim's right elbow/forearm area and the right knee are bruised and abraded. The left hand is also bruised and covered with dirt. Noga Ambulance Service was dispatched to the scene to provide medical support and transport to the nearest MS-i1 Hospital.

Upon arrival at Ellwood City Hospital, the Radiation Emergency Medical Team met the Emergency Medical Services (EMS) team at the exterior entrance to the Radiation Emergency Area (REA) to receive and treat the patient. The hospital's medical team assessed the patient's condition and surveyed the victim for radiological contamination. Initial contamination levels included: 1600 counts per minute (cpm) on right knaee; 1800 cpm on right elbow and 800 cpm on left hand.

11

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlsImprovement Plan Beaver Valley Po~ier Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the November 4, 2015, Medical Services Radiological Emergency Preparedness (REP) Drill. The drill was conducted to demonstrate the ability of the Offsite Response Organizations to respond to a potentially contaminated injured person associated with the Beaver Valley Power Station.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the appropriate 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.

The drill was conducted and evaluated in accordance with the Radiological Emergency Preparedness Program Manual (July 2015) and NUREG 0654. The Evaluation Criteria included:

i.e. 1 Equipment and supplies to support operations 3.a. 1 Implementation of emergency worker exposure control 6.d.1 Transportation and treatment of contaminated injured individuals The drill successfully demonstrated the response capabilities of the participants (except as may be noted in Section 3.2, Summary Results of Drill Evaluation, and Section 3.3, Criteria Evaluation Summaries).

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Program Manual that was scheduled for demonstration during this drill by all participating jurisdictions and functional entities. Drill evaluation area criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters:

(Li) Level 1 Finding: an observed or identified inadequacy of organizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant (NPP).

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaier Valley Power Station (L2) Level 2 Finding: an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.

(P) Plan Issue: an observed or identified inadequacy of organizational in the offsite response organizations' (OROs) emergency plan/implementation procedures, rather than that of the ORO's performance.

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

(M) Met: status of a REP exercise Evaluation Area Criterion indicating that the participating CR0 demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the extent of-of-play agreement with no Findings assessed in the current exercise and no unresolved prior Findings.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improiement Plan Bea~er Valley Po~~er Station Table 3.1 - Summary of Drill/Exercise Evaluation Date: 11-04-2015

-o' Site: Beaver Valley Power Station (M) Met, (1) Level 1 Finding, (2) Level 2 Finding, (P) Planning Issue

.. u O

Emergency Operations Management Mobilization la 1 Facilities 1ib1 Direction and Control 1lcl Communications 1id1 Equipment and Supplies to Support Operations lel M

M

~P rtectivel Action Decision Making Emergency Worker Exposure Control 2a1 Accident Assessment and Pars for the Emergency Event 2bl PAD decision-making process and coordination for the General Public 2b2 PADs. for disabilities & access/functional needs people 2cl Radiological Assessment & Decision making for the Ingestion Pathway 2e1 Radiological Assessment & Decision making for Relocation/Reentry/Return 2dl Protective Action Implementation Implementation of Emergency Worker Exposure Control 3a1 M

M Implementation of KI PAID for Institutionalized Individuals/Public 3b2 Implementation of PADs for disabilities & access/functional needs people 3dcl Implementation of PADS for Schools 3 c2 Implementation of Traffic and Access Control 3dl Impediments to Evacuation 3 d2 Implementation of Relocation/Reentry/Return Decisions 3 fl_____

Field Measurements and Analysis RESERVED 4al Field Team Management 4a2 Plume Phase Field Measurement, Handling, & Analyses 4a3___

Post Plume Phase Field Measurements & Sampling 4bl1__

Emergency Notification and Public information Activation of the Prompt Alert & Notification System (ANS) 5al RESERVED 5a2 Activation of the Back-up ANS 5a3 Activation of the Exception Area ANS 5a4 Emergency Information & Instructions to the Public/Media 5bl Support Operations/Facilities Monitoring, Decontamination, & Registration of Evacuees 6a1 Monitoring/Decontamination of Emergency Workers and Equipment 6b 1 Temporary Care of Evacuees 6cl Transportation/Treatment of Contaminated Injured Individuals 6d1 M

M 14

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportIImproiement Plan Beawr Valley Poiwr Station 3.3 Criteria Evaluation Summaries 3.3.1 Support Jurisdictions 3.3.1.1 Lawrence County, Ellwood City Hospital In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 3.3.1.2 Lawrence County, Noga Ambulance Company 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. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS:

ISSUE NO: 3-15-6d1-L2-01 CRITERION: 6.d. 1 Transportation/Treatment of Contaminated Injured Individuals CONDITION: The Emergency Medical Technicians (EMTs) did not appropriately conduct glove changes while handling a potentially contaminated patient.

POSSIBLE CAUSE: The ambulance company did not receive adequate training prior to the demonstration.

REFERENCE:

NUJREG-0654/FEMA-REP-1, L.4 EFFECT: Improper contamination control could result in cross contamination of personnel and equipment.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportl/Improvement Plan Beaver Valley Poser Station CORRECTIVE ACTION DEMONSTRATED: EMT' s received on the spot training and re-demonstrated proper contamination control.

d. PLAN ISSUES: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 16

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

'Beaver" Valley Powier, Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and local jurisdictions, except where noted in this report demonstrated knowledge of their Radiological Emergency Response Plans (RERP) and procedures were adequately implemented during the Beaver Valley Power Station, Medical Services Drill evaluated on November 4, 2015.

Two (2) Federal Emergency Management Agency (FEMA) evaluators provided analyses of six evaluation criteria. These analyses resulted in a determination of one Level 2 Finding successfully re-demonstrated, no new Plan Issues, and no unresolved Plan Issues.

The Noga Ambulance Service successfully demonstrated that necessary equipment and supplies were available to support the treatment of an injured/contaminated victim. EMS personnel prioritized life-saving medical practices over contamination concerns, implemented protective measures through the use of Personal Protective Equipment (PPE), regular glove changes, and control of cross contamination. Appropriate patient assessments were demonstrated as well as regular and ongoing communications with Ellwood City Hospital.

The Ellwood City Hospital successfully demonstrated the mobilization of staff, staffing assignments, issue of dosimetry and monitoring equipment, and effective use of Personal Protective Equipment (PPE) during the exercise. The hospital staff effectively responded to communications from the Noga Ambulance Service, initiated the set-up and management of a Radiation Emergency Area (REA), and accepted and successfully treated an injured/contaminated victim while administering life-threatening medical attention over contamination concerns. In addition, the medical facility provided security control of the facility including the drop off bay for the patient and overall protective measures for contamination control and prevention of cross contamination.

Based on the results of the exercise and a review of the offsite Radiological Emergency Response Plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

An After Action Implementation Plan (IP) will not be developed as part of this report.

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Unclassified Radiological Emergency Preparedness Program (REP)

After, Action Report/Improvement Plan Beaier Valley Poijer Station APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leader for the Beaver Valley. Power Station 2015 Medical Services (MS-i) Exercise evaluated on November 4, 2015. The following constitutes the managing staff for the Exercise Evaluation:

• Thomas Scardino, DHS/ FEMA, Regional Assistance Committee (RAC) Chairman

• Lee A. Torres, DHTS/FEMA, Program Officer and Site Specialist

• Barton Freeman DHS/ FEMA, Technical Hazards Program Specialist, Evaluator DATE: 11/04/2015, SITE: Beaver Valley Power Station

,LOCATION

,TEAM LEADER

.. AGENCY Lawrence County, Ellwood City Hospital.

Barton Freeman FEMA Region III Lawrence County, Noga Ambulance Company Lee Torres

..FEMA Region III 18

Unclas sified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaver Vailley Pow~er Station APPENDIX B: ACRONYMS AND ABBREVIATIONS A

g I-

.~ s I

BVPS Beaver Valley Power Station BVPS Beaver Valley Power Station DHS Department of Homeland Security DRD Direct Reading Dosimeter EMS Emergency Medical Services EMT Emergency Medical Technician EOP Extent of Play EPZ Emergency Planning Zone ER Emergency Room FEMA Federal Emergency Management Agency FENOC First Energy Nuclear Operating Company GE General Emergency MS-i1 Medical Services NPP Nuclear Power Plant NRC Nuclear Regulatory Commission ORG Offsite Response Organization PPE Personal Protective Equipment PRD Permanent Record Dosimeter REA Radiation Emergency Area REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RO Radiological Officer SAE Site Area Emergency 19

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReporfIlmprovement Plan Beaver Valley Poiser Station APPENDIX C: EXERCISE PLAN The enclosed Exercise Plan was created as an overall tool for facilitation and implementation of the Beaver Valley Power Station Medical Services Drill and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program Exercise Methodology.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportfImproxement Plan Beaver Valley Po~wr Station This page is intentionally blank.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportfImprovement Plan Bea~ar Valley Pos~er Station Exercise Plan Beaver Valley Power Station FEMA Evaluated Medical Services.(MS-i1) Drill U.S. DEPARTMENT OF HOMELAND SECURITY 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaver Valley Poiier Station Preface The 2015 Beaver Valley Power Station Evaluated Medical Services Drill (MS-i) is sponsored by Pennsylvania Emergency Management Agency (PEMA) and the Federal Emergency Management Agency (FEMA). This Exercise Plan (ExPlan) was produced with input, advice, and assistance from the Exercise Planning Team (EPT), which followed the guidance set forth in the Federal Emergency Management Agency (FEMA), Homeland Security Exercise and Evaluation Program (HSEEP).

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

The 2015 Beaver Valley Power Station MS-i Drill is an unclassified exercise. The control of information is based more on public sensitivity regarding the nature of the exercise than on the actual exercise content. Some exercise material is intended for the exclusive use of exercise planners, Controllers, and Evaluators, but Players may view other materials deemed necessary to their performance. The ExPlan may be viewed by all exercise participants, but the Controller and Evaluator (C/E) 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 DHS and the EPT.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

.Bea~er Valley Po~~er Station Handling Instructions

1. The title of this document is 2015 Beaver Valley Power Station MS-i 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 points of contact (POCs):

Federal POC(s):

Lee A. Torres, Project Officer & Site Specialist Department of Homeland Security (DHS)

Federal Emergency Management Agency (FEMA) 615 Chestnut Street One Independence Mall Philadelphia, Pennsylvania 215.931.5563

• lee.a.torres@dhs. gov" State POC(s):

Victor Wilson, Radiological Planner Pennsylvani'a Emergency Management Agency P.O. Box 4 Simulator 2 Shippingport, Pennsylvania 15077 717.433.1227 vicwilson~state.pa.us 24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllnmprovement Plan Beaver Valley Povier Station TABLE OF CONTENTS Exercise Plan..............................................................................................

20 BEAVER VALLEY POWER STATION FEMA EVALUATED REP EXERCISE..........................

20 U.S. DEPARTMENT OF HOMELANID SECURITY..............................................

20 Preface..................................................:....................................................

23 Handling Instructions....................................................................................

24 Chapter 1: General Information......................................................................

27 Introduction........................................................................................... 27 Confidentiality......................................................................................... 27 Purpose..................................................................................................

27 Target Capabilities..................................................................................... 28 Exercise Objectives................................................................................... 28 Chapter 2: Exercise Logistics......................................................

i.......................30 Exercise Summary........................

30 General.....................................

30 Assumptions.......................

.................................................................... 30 Constructs and Constraints.....................................................

................... 30 Exercise Participants............................................

....... 31 Controller and Evaluator Handbook................................................................. 32 Master Scenario Events............................................................................ 32 Exercise Implementation.............................................................................

32 Exercise Play....................................................................................... 32 Exercise Rules...................................................................................... 33 General.............................................................................................. 33 Exercise Setup.................................

...................................................... 34 Accident Reporting and Real Emergencies.........

34 Site Access............................................................................................ 34 Security.............................................................................................. 34 Observer Coordination............................................................................ 35 Parking and Directions............................................................................. 35 Restroom Facilities................................................................................. 35 Exercise Identification................................................................................ 35 Communications Plan................................................................................. 35 Exercise Start, Suspension, and Termination Instructions...................................... 35 Player Communication............................................................................. 35 Player Briefing...................................................................................... 36 Public Affairs....................................................................................... 36 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improxement Plan Beawer Valley Poiier Station Chapter 3: Player Guidelines................

........................................................ 37 Exercise Staff.......................................................................................... 37 Lead Controller...................................................................................... 37 Controllers.......................................................................................... 37 Evaluators.......................................................................................... 38 Player Instructions.................................................................................... 38 Before the Exercise.................................................................................. 38 Following the Exercise............................................................................ 39 Simulation Guidelines.....................................

• .......................................... 40 Chapter 4: Evaluation and Post-Exercise Activities.............................................. 41 Exercise Documentation..............................................................,.......,......... 41 Mfter Action Report.................................................................................... 41 After Action Conference and Improvement Plan...................................................41 After Action Conference.............

............................................................. 41 Improvement Plan......... i.....................

............. *..................................... 42 Appendix A: Exercise Schedule...................................................................... 43 Appendix B: Extent of Play Information........................................................... 44 26

Unclas sified Radiological' Emergency Preparedness Program (REP)

After Action Reportllmnproiement Plan Beaier Valley Powier Station Chapter 1: General Information Introduction The 2015 Beaver Valley Power Station Medical Services Drill is a Functional Exercise (FE) designed to establish a learning environment for players to exercise emergency response plans, policies, and procedures as they pertain to Nuclear Power Plant accidents. A Functional Exercise is a complex event that requires detailed planning. To conduct an effective exercise, subject matter experts (SMEs) and local representatives from numerous agencies have taken part in the planning process and will take part in exercise conduct and evaluation.

This Exercise Plan (ExPlan) was produced at the direction of the Federal Emergency Management Agency with the input, advice, and assistance of the Commonwealth of Pennsylvania. The 2015 Beaver Valley Power Station Medical Services Drill is evidence of the growing partnership between State and local jurisdictions for response to the threats our Nation and communities face, Confidentiality The 2015 Beaver Valley Power Station Medical Services Drill is an unclassified exercise. The control of informationi 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 (C/E) 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 Federal Emergency Management Agency (FEMA) and the Exercise Planning Team.

Purpose The purpose of this exercise is to evaluate player actions against current response plans and capabilities for a nuclear power plant-related incident, and to comply with the requirements of 44 CFR 350 and the guidelines of NUREG 0654/FEMA-REP-1. Exercise planners utilized the elements described in the 67 FR 20580 (April 25, 2002) and Radiological Emergency Preparedness (REP) Program Manual (July 2015) to develop this exercise.

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Unclassified Radiological Emergency Preparedness Program' (REP)

After Action Report/Improiement Plan B~eaier Valley Poiwer Station The objective of The Federal Emergency Management Agency and, The Pennsylvania Emergency Management Agency, and local jurisdictions is to demonstrate reasonable assurance that the public can be protected during a nuclear power plant emergency.

Target Capabilities The establishment of the National Preparedness Priorities have steered the focus of homeland security toward a capabilities-basedplanning approach. Capabilities-basedplanning 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 Program Manual (July 2015), 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 and Decontamination

• Emergency Triage and Pre-Hospital Treatment

• Medical Supplies Management and Distribution Exercise Objectives The Emergency Preparedness Evaluation Areas - the elements and sub elements - for this drill are those that are required to be demonstrated in every MS-i Drill, per 67 FR 20580 (April 25, 2002) and the Radiological Exercise Preparedness (REP) Program Manual (July 2015). Appendix B, Extent of Play, shows the emergency preparedness elements that are required to be demonstrated in the 2015 Beaver Valley Power Station Medical Services Drill, along with the level of demonstration that will be displayed in the exercise (i.e., fully demonstrated limited demonstration, simulated, Out-of-Sequence interviews, not demonstrated).

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley PowerStation 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.

Outstanding Issues There are no deficiencies, Areas Requiring Corrective Action (ARCAs), or planning issues as a result of the FEMA-evaluated plume-phase exercise at Ellwood City Hospital MS-i1 Drill conducted November 2, 2011.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lInprovement Plan Beaver Valley Poiier Station Chapter 2: Exercise Logistics Exercise Summary General The 2015 Beaver Valley Power Station Medical Services Drill is designed to establish a learning environment for players to exercise their plans and procedures for responding to a nuclear power plant incident. The 2015 Beaver Valley Power Station Medical Services Drill will be conducted on November 4, 2015. Exercise play is scheduled for four (4) hours or until the Lead Controller, after consulting with the FEMA Site Specialist, 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 2015 Beaver Valley Power Station. Medical* Services Drill:

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

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

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

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

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

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

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Imnprovement Plan Beaver Valley Poiier Station

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

• 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 exerciseand 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 evaluation functions. Local Observers will view the exercise from a designated observation area and will be asked to remain within the observation area during the exercise. PEMA observers may be present at selected locations as assigned by the Lead Controller. VJIPs or other visitors will be handled by each agency or location (Municipal BOC, County BOC, etc.) according to those agencies' policies and procedures.

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After Action Report/Improvement Plan Beaver Valley Poiier Station

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

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

Exercise Tools Controller and Evaluator Handbook The 2015 Beaver Valley Power Station Medical Services Drill C/E Handbook is designed to help exercise Controllers and Evaluators conduct and evaluate an effective exercise. This Handbook also enables Controllers and Evaluators to understand their roles and responsibilities in exercise execution and evaluation.

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

For the 2015 Beaver Valley power Station Medical Services Drill the MSEL will not be used.

Exercise Implementation Exercise Play Exercise play will begin at approximately 0800 with a situation update going to each participating venue. Play will proceed according to the events outlined in the scenario, in accordance with established plans and procedures. The exercise will conclude upon the completion of operations and attainment of the exercise objectives, as determined by the Lead Controller after consultation with Lead FEMA Evaluator.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reporf/Improiement Plan Beaiar Valley Poiwr' Station 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 a drill. "

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

Safety Requirements General Exercise participant safety takes priority over exercise events. Although the organizations involved in the 2015 Beaver Valley Power Station Medical Services Drill Come from various response agencies, they share the basic responsibility for ensuring a safe environment for all personnel involved in the exercise. In addition, aspects'of an emergency response are dangerous.

Professional health and Safety ethics should guide all participants to operate in their assigned roles in the safest manner possible. The following general requirements apply to the exercise:

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.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

.Beaver Valley Power Station 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 9-1-1,and state "This is not aDrill" prior to explaining the inj ury 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 A Drill" on the controller radio netiwork or telephone, providing the following information to the Lead Controller and Exercise Director:

o Venue/Ifunction o

Location within the venue / function o

Condition o

Requirements

• 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 The Lead Controller or Exercise Director will control entry to the exercise venues. To prevent confusion and interruption of the exercise, access to the exercise sites will be limited to exercise participants oniy. 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.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inmprovement Plan Beaver Valley Po~r Station Observer Coordination Each organization with observers will coordinate with the Lead Controller or Exercise Director for access to the exercise site. Observers will be escorted to an observation area for orientation and conduct of the exercise. All observers Will be asked to remain within the designated observation area during the exercise. Exercise Director and/or the Observer Controller will be present to explain the exercise program and answer questions for the observers during the exercise..

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

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 isin play.

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 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Beaver Valley Pow~er Station 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 handourts or other materials to give to players in order to better orient them to the exercise environment.

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

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Uniclassified Radiological Emergency Preparedness Program (REP)

After Action Reportflmnpraoement Plan Beaiar Valley Poiier Station Chapter 3: Player Guidelines Exercise Staff Exercise Director The Exercise Director has the overall responsibility for planning, coordinating, and overseeing all exercise fuhctions. The Exercise Director for the 2015 Beaver Valley Power Station Medical Services Drill is the Lead Controller who will manage the exercise activities and maintain a close dialogue with the Controllers regarding the status of play and the achievement of the exercise design objectives.

Trusted Agents Trusted agents are exercise planners and participants 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 2015 Beaver Valley Power Station MS-i Drill include the Exercise Director, Lead Controller, First Energy Nuclear, Beaver County Office of Emergency Management, and the FEMA Site Specialist.

Lead Controller The Lead Controller is responsible for the overall organization of the 2015 Beaver Valley Power Station MS-i Drill. The Lead Controller monitors exercise progress and coordinates decisions regarding deviations or significant changes to the scenario cansed by unexpected developments during play. The Lead Controller monitors actions by individual Controllers and ensures they implement all designated and modified actions at the appropriate time. The Lead Controller debriefs the Controllers after the exercise and oversees the setup and takedown of the exercise.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Po~ier Station Lead Evaluator The Lead Evaluator is responsible for the overall evaluation of the 2015 Beaver Valley Power Station MS-i Drill. The Lead Evaluator monitors exercise progress and stays in contact with the Lead Controller regarding changes to the exercise during play. The Lead Evaluator monitors actions of individual Evaluators and ensures they are tracking progress of the players in accordance with the Overview of Play. The Lead Evaluator debriefs the evaluators after the exercise and oversees the entire evaluation and After Action process. The Lead Evaluator will be the FEMA Region HI Site Specialist for Beaver Valley Power Station.

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

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

Player Instructions Before the Exercise

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

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

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

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

• Please sign in.

During the Exercise

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

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

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Powier Station

• 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, conlcise 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.

• 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.

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

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

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Unclassified.

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Povier Station Simulation Guidelines Because the 2015 Beaver Valley Power Station MS-i Drill is of limited duration and scope, the physical description of what would frilly occur at the incident sites and surrounding areas will be relayed to the Players by Simulators or Controllers.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Beaver' Valley Power Station Chapter 4: Evaluation and Post-Exercise Activities Exercise Documentation The goal of the 2015 Beaver Valley Power Station MS-i Drill is to comprehensively exercise and evaluate the OROs' plans and capabilities as they pertain to a potential nuclear power plant incident. After the exercise, data collected by Controllers, Evaluators, and Players will be used to identify strengths and areas for improvement in the context of the exercise design objectives.

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

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

After Action Conference and Improvement Plan The improvement process represents the comprehensive, continuing preparedness effort of which the 2015 Beaver Valley Power Station MS-i Drill is a part. The lessons learned and recommendations fr~om the AAR will be incorporated into the Improvement Plan (IP).

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

41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Power Station 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 2015 Beaver Valley Power Station MS-i Drill participating agency officials during the AAC scheduled within 60 days of the drill.

42

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improiement Plan Beaver Valley Poiver Station Appendix A: Exercise Schedule Table A.1 2015 Beaver Valley Power Station MS-i1 Drill Schedule S

November 4, 2015 0800 Lawrence County Department of Exercise Begins Public Safety, Noga Ambulance Services and Eliwood City Hospital 1200 Ellwood City Hospital Exercise Ends 1215 All Drill Participants Critique and Debrief 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllxmprovement Plan Beaver Valley Poiser Station Appendix B: Extent of Play Information BEAVER VALLEY POWER STATION ELLWOOD CITY HOSPITAL MEDICAL SERVICES DRILL November 4, 2015 Method of Operation

1.

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

2.

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

3.

First Energy Nuclear will participate as a Controller in this drill.

4.

Lawrence County Departm~ent of Public Safety will participate in this drill.

5.

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

6.

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

7.

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

8.

Drill activities are scheduled to commence on or about 0800, November 4, 2015 and continue until the participants have completed the drill objectives and demonstrated the Exercise Evaluation Criteria.

44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Poiier 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 drill any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants during the exercise, provided it does not negatively interfere with the exercise. Refresher training may be provided by the players, observers, and/or controllers. Evaluators are not per~mitted to provide refresher training.

Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. PEMA may advise the RAC Chair prior to initiating any re-demonstrations.

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

Objectives A.

Demonstrate the ability to respond to a radiation medical emergency following the procedur'es of Lawrence County Department of Public Safety, Noga Ambulance Service /

EMS and Ellwood City Hospital.

B.

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

C.

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

D.

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

45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Powecr Station Extent of Play Evaluation Area 1--Emergency Operations Management Sub-Element i.e--Equipment and Supplies to Support Operations Intent This sub-element is derived from NUREG-0654 / FEMA-REP-1, which requires 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 (KU), and other supplies are sufficient to support emergency operations.

(NUREG-0654 / EEMA-REP-1, 11.7,10; 1.7, 8, 9; J.10.a, b, e, J.11, 12; K.3.a; K.5.b).

Extent of Play Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation and subsequent periodic inspections.

A particular facility's equipment and supplies must besufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use ofrmaps 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 equiipment (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 caipability 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 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Valley Po~ver Station identifying emergency workers that have declined K(1 in advance. Consider carefully the placement of emergency workers that have declined KI1 in advance.

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 SAy.

Available supplies of KI must be within the expiration date indicated on K(1 bottles or blister packs. As an alternative, the ORO may produce a letter fr'om a certified private or State laboratory indicating that the KI supply remains potent, in accordance with U.S. Pharmacopoeia standards.

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, HAZM'AT, 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 piansj/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-138s) (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 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beaver Vallcy Poiver Station 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 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 1R/hr) 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:

Ambulance crews are not trained or equipped to operate or carry radiological monitoring equipment. In accordance with PEA/A 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. "Category C" emergency worker dosimetry issue consists of one permanent reading dosimeter per worker.

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.

48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Beaver Valley Poiser Station Outstanding Issues:

None 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Beawer Valley Power Station Evaluation Area 3--Protective Action Implementation Sub-Element 3. a--Implementation of Emergency Worker Exposure Control Intent This Sub-element is derived from NUJREG0654 / FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for. each emergency worker; establishing a decision chain or authorization procedure. for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KIt for emergency workers, always applying the "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, K.3.a, b; K.4)

Extent of Play Assessment of this Demonstration,criterion may be accomplished during a biennial or tabletop exercise. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI1, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dos imetry 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.

50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportlImprovement Plan Beaver Valley Poi~er Station 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 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 co -workers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. 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., EO~s 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 re-enter an evacuated area during the plume (emergency) phase, must be limited to the lowest radi1ologicail 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., lifesaving, protection of valuable property, all activities). OROs must ensure that the process uised to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving 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 thle 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 RI 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.

51

Unclassified Radiological Emergency Prepa~redness Program (REP)

After Action Report/Improvement Plan Beaver Valley Poijer Station State Negotiated Extent of Play:

Demonstrate appropriate procedures and equipment to manage radiologi cal 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.

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 pl ayers or supervisors to clarify radiological information. In Pennsylvania, emergency workers outside the EPZ do not have turn-back values. Standard issue of dosimetry and potassium iodide for each category of emergency worker isas follows:

Category A: 1 PRD, 1 DRD, and 1 unit of KJ Category B." I PRD and 1 unit of KI Cate gory C.. 1 PRDJT All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP) will make the dosimetry equipment (and K!, as appropriate) available for inspection by the Federal Evaluator. Simulation PRDs with mock serial numbers may be used.

Outstanding Issues:

None 52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Beaver Valley Poiier Station Evaluation Area 6--Support Operation / Facilities Sub-Element 6. d--Transportation and Treatment of Contaminated In] ured Individuals Intent This Sub-element is derived from NUJREG0654 / FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Criterion 6.d.l: The facility / ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

(NUIREG0654 /FEEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4)

Extent of Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, or drills. FEMA has determined that these capabilities have been enhanced and consistently demonstrated as adequate; therefore, offsite medical services drills need only be evaluated biennially. FEMA will, at the request of the involved ORO, continue to evaluate the drills on an annual basis. If more than two medical facilities and transportation providers are designated as primary or backup, they are also evaluated biennially.

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. It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "victim(s)" to the medical facility. This option is used in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests of the community.

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 53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovemnent Plan Beaver Valley Poiier Station 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. Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s). However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored. Before using monitoring instruments, the monitor(s) must demonstrate the process 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. Medical facilities are expected to have at least one trained physician and one trained nurse to perform and supervise treatment of contaminated injured individuals. 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 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, uniess 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 contaminated/injured individuals.

Demonstrate the ability to transport contaminated /injured individuals while using ALARA principles.

Noga Ambulance Service will pick-up a pre-staged simulated contaminated / in]juredvictim.

Outstanding Issues:

None 54

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvenment Plan Reaver Valley Posier Station 55