ML16176A156

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After Action Report/Improvement Plan Drill Date - May 11, 2016
ML16176A156
Person / Time
Site: Limerick  
Issue date: 06/06/2016
From: Tierney M
US Dept of Homeland Security, Federal Emergency Management Agency
To:
Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML16176A156 (38)


Text

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:

JUN 0 6 2016 U.S. Department of Homeland Security Region Ill One Independence Mall, 6th Floor 615 Chestnut Street Philadelphia, PA 19106-4404 FEMA Enclosed is the final After Action Report/Improvement Plan for the Limerick Generating Station (LGS) Medical Services (MS-I) Drill that was held on May 11, 2016. The Bally Community Ambulance Company and Reading Hospital participated in the drill.

There were no Level 1 Findings, Level 2 Findings, or Planning Issues identified during the drill.

Based on the results of the exercise and a review of the off site 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.

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

Enclosure Sincerely, tPJd Mary Ann Tierney Regional Administrator www.fema.gov

Limerick Generating Station After Action Report/

Improvement Plan Drill Date-May 11, 2016 Radiological Emergency Preparedness (REP) Program FEMA Published May 23, 2016

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station This page is intentionally hlank.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

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  • t Limerick Generating Station After Action* Report/Improvement Plan**...
  • EXECUTIVE

SUMMARY

.......................................................................................................... 3 SECTION 1: EXERCISE OVERVIEW..............*...*..............................................**.*................ 4 1.1 Exercise Details.................................................................................................................... 4 1.2 Exercise Planning Team Leadership....................................*.......*................................*.*. 4 1.3 Participating Organizations...........................*...........***...*..*.........................*......*......*...... 5 SECTION 2: EXERCISE DESIGN

SUMMARY

...............................*......***....***......*............... 6 2.1 Exercise Purpose and Design............................................................................................. 6 2.2 Exercise Objectives, Capabilities and Activities ***....*..................................................*.**. 8 2.3 Scenario Summary............................................................................................................... 9 SECTION 3: ANALYSIS OF CAPABILITIES.....................*................................................. 10 3.1 Exercise Evaluation and Results...........................................*..*.*..*..........................*....... 10 3.2 Summary Results of Exercise Evaluation..............................................*........................ 10 3.3 Criteria Evaluation Summaries..............................................**...***..***............................ 13

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3. 3.1 Risk Junsd1ct1ons...... ;.... ;.. :.... :......... ;.:.;::*....... *;............................................................. 15 SECTION 4: CONCLUSION...................................................................*.**............................. 23 APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS *.......***.*******............. 24 APPENDIX B: ACRONYMS AND ABBREVIATIONS..........................***........................... 25 APPENDIX C: EXTENT-OF-PLAY........*.....*.....**.....*.....................................*...**..*...*.......... 25 1

Unclassified Radiologi~al Emergency Preparedf!ess Program (REP)

After Action Report/Improvement Plan Limerick.G~nerating Sta~ion This page is *intentionally blank.

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Un~Ia!isified*

Radiological Ediergeilcy Preparedness Program (REP)

After Action ReportYimprc\\vement Plan

  • 'Limerii:k'Generating'Station EXECUTIVE

SUMMARY

On May 11, 2016, a Medical Services (MS-1) Drill was evaluated for the 10-mile Plume Exposure Pathway, Emergency Planning Zone (EPZ) around the Limerick Generating Station (LOS) by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) Region III. The most recent prior MS-1 drill for this site was conducted on June 12, 2013 (Commonwealth of Pennsylvania).

The purpose of the Limerick MS-1 drill was to assess the State and local off site response organization preparedness in responding to a radiological medical emergency. The drill was held in accordance with FEMA's policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERP) and procedures.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania, Berks County Office of Emergency Operations, Reading Hospital and the Bally Community Ambulance 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 in which they live. Cooperation a.nd teamwork among all the participants was observed during this drill.

This report contains the final evaluation of the MS-1 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 or Level 2 Findings or Plan issues.

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U,nf,assiped Radiological,Emerg~ncy *Prepa(ed~ess Program (REP)

After A.ction R~port/Jmp,r?vement Plan

..,. :.. Umerick Generating Stati.on SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details

... :Exercise 'Name Limerick Generating Station (LGS) Medical Services (MS-1)'.Drill *

*.. -.* i Type of Exercise Medical Services (MS-1) Drill Exercise Date May 11, 2016 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Not Applicable 1.2 Exercise Planning Team Leadership Tina Lai Thomas Emergency Management Specialist, Evaluator Federal Emergency Management Agency 615 Chestnut Street Sixth Floor One Independence Mall Philadelphia, PA, 19106 (215) 931-5680 tina.thomas@fema.dhs.gov Jeffery Dean Emergency Preparedness Coordinator Exelon Corporation 298 Longview Toad Royersford, PA, 19468 (610) 718-2022 jeffery.dean@exeloncorp.com Sandra Silva Emergency Management Specialist Pennsylvania Emergency Management Agency 2605 Interstate Drive Harrisburg, PA, 17110 (717) 651-2235 sansilva@pa.gov 4

U nc.Iassified Radicilogical Emergency Preparedness Program (REP)

After Action Repcirt/lmprovement Plan

'Limerick Generating-Station

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1.3 Participating Organizations

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Agencies and organizations of the following jurisdictions participated in the Limerick Generating Station drill:

  • Support Jurisdictions Reading Hospital Bally Community Ambulance

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Unclassified RadioloiPcal Emergency pj~!>aredn~ss Progra~ (REP)

After Aftion Report/Improvement Plan

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Lime,rick Gen~ratjng Station SECTION 2: EXERCI~E.DE~IG:N.

SUMMARY

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2.1 Exercise Purpose and Design I

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  • On December 7, '1979; the Presidentdirectedthe Federal Emergency-Management Agency*

(FEMA) to: assume the lead responsibility for all off.. site radiological planning and response.

  • FEMA's activities were conducted pursuant to"44 Code ofFederai'Regulations (CFR) P~rts 350; 351and352. These regulations are a key elementin the RadiologicaFEmergency 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 goven.1.nient participation in joint exercises with licensees. FEMA's responsibilities in radiological emergency planning fodixed nuclear facilities;inClude-the following:*

A.

Taking the lead in offsite emergency planning and in the.review and evaluation or.

Radiological Emergency Response Plans (RERPs).and procedures developed by State and local governments; B.

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

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I C.

Responding to requests by the U.8; NuclearRegulatory Commission (NRC) pursuant to the Memorandum of'Uh.derstanding*between.the NRC andFEMA 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 proce$s:

(.;._*

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 Hurrian Services,. *

  • ,.U.S. Department of Transportation, *

.. *.. U.S. Department of Agriculture,

  • U.S. Department of the* Interior, and
  • U.S. Food and Drug Administration. ',
f.

Representatives of these agencies serve on the Region III*Radiological Assistance Committee*'

(RAC), which is chaired by FEMA. A Radiological Emergency Preparedness Medical Services (MS-1) Drill was conducted May' U, 2016, to: assess the capabilities of Sfate and local emergency preparedness*organizations in implementing their RERPs *and. pi;ocedures to protect :'*.

the public health and safety.during*a radiologi~al emergency. involving Limerick 'Generating. ** *,:

Station. The. purpose* of this exercise reporfis to present _the drill results arid findings on the 6

Un~lassified

  • Radiological Emergen'cy Preparedness Program (REP)

After Action Report/Improvement Plan

'Limerick Generating Station performance of the off-site response organiZations (OR Os) 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 ma.de by the FEMA Regi9_n IJI Radiological Assistance Committee (RAC).Chairp~rson and approved by, FEM.A Headquarter~.. Thesl;! reports are pr,ovided to the NRC and participating States. State and local governments utiJize the findings contained in these "

reports for the.purposes of planning, training, and improving emergency response capabilities.

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

  • . NUREG-0654/FEMA-REP-1, Rev.- 1, "Criteri.a for Preparation and Evaluation of. *
  • Radiological Emergency Response Plans and Prepare_dness.in Support of~uclear' Power *.

Plants," November 1980;.

Radiological Emergency Preparedness*Program Manual, January 2016

  • 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 arid Results" information on the demonstration for each jurisdiction or

' functional entity evaluated in ajurisdiction--based, issue-only format (Criteria Evaluation Summaries).

Section 4*ofthis 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.

Emergency Planning Zone

Description:

Limerick Generating Station (LGS) is located in southeastern Pennsylvania on the' Schuylkill River about 1.7 miles southeast of Pottstown Borough. The-river passes through the site,.

separating the western portion, which is in East Coventry Township in Chester County, from the eastern portion, which is in Limerick and Lower Pottsgrove Townships in* Montgomery County.

The plant is owned and operated by Exelon Nuclear. Two: boiling water reactors each generate an electrical output of 1,050 megawatts (MW). Unit 1 was issued a full-power license in May 1985; commercial operations began in February 1986. Unit 2 was issued a full-power license in May 1989 with commercial' operations beginning in January 1990.

  • The site encompasses 595 acres and is divided into three (3) parts. The principal-portion, where the:majoroperating equipment and buildings are loca.ted, is.on the east bank Of the Schuylkill :-.

River. This portion is separated from the second se~ent~ where the cooling water intake is located, near the main line of.the Reading Railroad. Thethird*portion lies on the west bank of *

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Unclassified Radi~logical Emergency Pr_~P,are.d~ess Program (RE~)

After A.ction ReportllmP.rovement Plan

. Limerick Gene.rating Station the river, adjacent to Conrail railroad tracks. Th~ site coordinate~ are approxi111ately40°13'27"N and 75°35'15":W.

The minimu,m exclusion distance for the LGS.. \\s 2,500,Jeet. from the center of each reactor; The utility owns all the land within the exclusion area. No private residences are. located.~jt,hip the exclusion area; however, some farming may be permitted.

There are 165 sirens installed to cover the 10-mile plume exposure pathway EPZ. These sirens are activated three (3) min.utes ~efor~.the* Em~rgency Alert System (EAS) mes~ages issued by the Commm,1wealth -of Penn,sylv~m~~.are b1:padcast. Soils in this area are of the Reaville-Penn-Klinesville Association and a.re characteristic*9f.rolling.up_lands.. *They are underlain by sedimentary rocks of the Brunswick Formation, consisting mostly of red shale with some.fine-grained sandstone interbedding. The normal pool elevation of the Schuylkill River in this.area is 200 feet above*mean sea l.evel. (msl).. The topography of the area is hilly, with elevation,s ranging from 100-300 feet above msl within five (5) 1niles of the site. The pla,ntis approxil'Il:ately 217 feet above msl..

The climate in this area is dominated by prevailing westerly winds that produce humid, continental-type weather characterized by w;:trm sumµiers and moderately cold w~nters.

Montgomery County is the warmest part of *Pennsylvania, with an ave.rage annuaJ temperature of 57°F. Annual precipitation is ~pproximately 42 inches.. The area in the immediate vicinity o.f the plant is n;iade up rp.ostly of agricuJtural and otlier open land. The Potts~own ;Borough in Montgomery County is the nearest coµm;mnity. The nearest major popl,llatiop center (more t~an 25,000 people) is Philadelphia that lies 25 miles to the southeast of the site.

Two major industries employ a total of 850 persons within two (2) miles of the plant. Two small airfields are also located nearby. A small private airfield is about one (1) mile to the northeast, but its runway is oriented so that the flight path does not pass over the plant. The Pottstown Municipal Airport is 4.3 miles northwest of the site. The LGS does not lie in the approach pattern for this airport. No major thoroughfares are located in the immediate vicinity of the plant. The main line of the Reading Railroad runs along the north bank of the Schuylkill River and traverses the site about 500 feet from the plant.

2.2 Exercise Objectives, Capabilities and Activities The Limerick Generating Station MS-1 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 Berks County Department of Emergency Services, Bally Community Ambulance, and Reading Hospital.

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.)

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U n~Iassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

' 'Limerick Generating-Station C.

Establish correct priorities and appropriate techniques in EMS, transportation of patie-hts and pre-hospital and hospital emergency care of radioactively contaminated p-atiertts-.

D.

Initiate inter-agency'cooperation between-Bally CoinmUriity Ambulance*Corripany;;and Reading Hospital 2.3 Scenario ~ummary The exercise scenario for this MS-1 Drill consisted of simulated notifications of escalating

  • emergency Classification levels (ECL) at the Limerfok Generating Station (LOS) from Site Area Emergency (SAE) to General Emergency (GE); declared following an airborne release of * * -* *.*

radiologi~al materiaL j'

During the incident an emergency worker *tripped* over a :fire hose laridirtg hard on'his hands and knees. The *victim was conscious and coniplainingdfpain in his righf wrist.'.The victim had a-*

small laceration on both knees and hands Bally Community Ambulance Company was dispatched to the scene to provide medical support and transport to the nearest MS-1 Hospital.

Upon arrival at Reading Hospital, the medical treatment team and a radiation safety,*

representative met the Emergency Medical ServiceS'(EMS) team 'at the exterior entrance to the Radiological* Emergency Area (REA).* The hospital's medical team assessed the patient's condition.and surveyed the victim for radiological contamination; Initial contamination* levels *,

were '1100 counts per minute (cpm) on both: the' right arid left palms.*

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Unclassified Radiological Emergency PreP,aredness Program _(REP)

After A_ction Repo,rt!Jmprovement Plan Limerick Gen~ra ti_ng _Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results*

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  • "*-.1 Contained in this section are the results and findings of the evaluations of all jurisdictions and location~ that.participated inthe May 11', 2016, Medical Services_Radiologi9al Emergency
  • Preparedness (REP) Drjll.. The drill was conducted to demonstrate the ability of the Qffsi.te Response Organizaticms to.respond.to-potentially contaminated injur~d patients during incidents.

associated with the Limerick Generating 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 and NUREG 0654. The Evaluation Criteria included:

l.e. l Equipment and supplies to support operations 3.a. l Implementation of emergency worker exposure control 6.d. l Transportation and treatment of contaminated injured individuals The drill successfully demonstrated the response capabilities of all participants.

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:

(D) Demonstrated Strength: an observed action, behavior, procedure, and/or practice that is worthy of special notice and positive recognition, Note: this is already a common practice that many Regions employ when identifying demonstrated strengths.

(Ll) Level 1 Finding: an observed or identified inadequacy or 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).

(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.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station (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 ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level

  • required in the extent 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/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Drill/Exercise Evaluation Date: 05-11-2016 Site: Limerick Generating Station I*

2 u co u

u (M) Met, (1) Level 1 Finding; (2) Level 2 Finding, (P) Planning Issue co co Emergency Operations Management Mobilization lal Facilities lbl Direction and Control lcl Communications ldl Equipment and Supplies to Support Operations lel M

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

M Implementation of KIP AD for Institutionalized Individuals/Public 3b2 Implementation of P ADs for disabilities & access/functional needs people 3cl Implementation of PADS for Schools 3c2 Implementation of Traffic and Access Control 3dl Impediments to Evacuation 3d2 Implementation of Relocation/Reentry/Return Decisions 3fl Field Measurements and Analysis RESERVED 4al Field Team Management 4a2 Plume Phase Field Measurement, Handling, & Analyses 4a3 Post Plume Phase Field Measurements & Sampling 4bl Emergency Notification and Public Information Activation of the Prompt Alert & Notification System (ANS)

Sal RESERVED 5a2 Activation of the Back-up ANS 5a3 Activation of the Exception Area ANS 5a4 Emergency Information & Instructions to the Public/Media Sbl Support Operations/Facilities Monitoring, Decontamination, & Registration of Evacuees 6al Monitoring/Decontamination of Emergency Workers and Equipment 6bl Temporary Care of Evacuees 6cl Transportation/Treatment of Contaminated Injured Individuals 6dl M

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Un~fassifieil

  • R~diologfoal E~ergeni:y Preparedness Program (REP)

After Actiiin Repoi-t!Improvement Plan

~ *.,- LimerickGeilerating*Station 3.3 Criteria Evaluation Summ'aries' *

,:~.,u 3.3.1. RiskJ urisdiCtions

{ : *.. '... ".... '. ;..

In symmary, the status of PHS/fEM,A i;;riteria,for_the.Stat~juris.diction is as fo~lows,:.

3.3.1.1 Berks County, Reading Hospital.

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"in suriuiiary_, the status ofDHS/FEMAcriterfa:forthis location is*a.s*fol~ows-:

a.* *MET: 1.e.l, 3.a.1~ 6~d.l

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h.. LEVEL 1 FINDINGS: NONE I
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... c;.- 'LEVEL 2 FINDINGS: NONE. -

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d.-_.* PLANJSSl)ES: NONE*

e.

'PRIOR ISSUES - RESOL \\TEn:*N-oNE'

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f. ~ PRIOR ISSUES;_: UNRESOLVED: NONE ;

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I The Reading Hospital (RH) successfully demonsfrated the-capabilify to. proviqe iieces~a~y - ~

equipment and' supplies to support emerg~ncy-qper~t~ons, treatment~ and.decontamination of rapfological contaminated patient. The demo-nstration* was conducted as:pait of_ a MediCal *,- _*; : :

Services (MS-1) Drill condueted on Wednesday, May 11, 2016, from* approximately.0909 fo * -:

1200, at the Reading Hospital located at 629 Parkside Drive North in West Reaqirig, Pennsylvania..

At 0847, the Eirie.rgency Department (ED) Cha~g~ Nur~~: was asked to:de~cribe the ~e~.e~~~ry._*:.:*

equipment to, set-:up the decontamination room ip.;P,reparation for_'.an inj'ureq_co_nta,~inated patient. The Charge Nurse stated that there was a storage area off of the ambularice*bay t]J.;it contained necessary equipment and* supplies for emergency operations...

The storage area: was a locked closet-labeled "Radiological Equipment Room/; The contents-of.

this room included numerous barrier-ropes ~ith radiofogical eontaminatioh ~igilage,' m1iltipie..

cones, set-up. procedures*and signal lights which, could be mounted on top of the 'cones for'night-operations. The.hallway leading to the.lhdiation.Emergenc-y~Area (REA)-had temporary. * :.. :

markings on the-floor to designate the buffer. zcirie for. transfer ofthe patient from the ambula'.rice gurney to the ~ospital bed..There were.multiple roll~ng trash cans with yellow plastic.liners.. ':=.*

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The storage area contained a six foot locking roller cabinet. The contents of this cabinet included 11 Personal Protective Equipment (PPE) Kits, which contained a gown, surgical mask with an eye shield, surgical booties and yellow rubber outer boots. There were two Canberra/RMC kits for body sampling and decontamination which contained several bottles of B

Unclassified Radiological.Emergency, 'Pr_epar~dne.ss Program (REP)

After Ac\\ion ReporµImprovement Plan Limerick G~nerating Sta~ion saline, eight packages of sterile 4x4 gauze, red duct tape, cotton swabs,; multiple boxes and ~izes of latex gloves, beta dyne, hydrogen peroxide, scissors and bioassay sample containment bags.

There were instructions on required bioassay samples and decontamination techniques also contained in the kits.

On the outside of the cabinet there was a poster which detailed the PPE donning sequence and on..

the inside of the cabinet door there was 8x10 laminated sheet outlining the Pennsylvania

  • Emergency Management Agency.(PEMA) Emergency Worker-(EW) Dose Limit of 5 REM, and.

actions to follow when the limits were.. exceeded. Additionally there was a book ofstandai:d operating procedures, administrative.supplies.and recording forms.. There was barrier tape for ~

marking off the decontamination room and step-off pads to use in the buffer zone.

In *ad_dition t~ the radiological emergency -suppli~~' there were two_.radiation su_rvey mete~_s. The meters.were LlJPLUM Model 14C radiatiqn survey!lleters with pancake GM probes. Eacho(.

the meters have a range_of 0 - 50,000 cpm, and.. h~d.,calibration due dates ofDecemb".r 22, 2016.

The cabinet also contained a.Model 51Q, electronic.dqsimeter charger and a portable.air sampler..

The cabinet was checked and resto.cked on a moµthly basis, and after every use.

The RH staff members working in the Radiation Emergency Area (REA) were issued dosimetry by the PEMA. The qosimetry Lssued to each hospital staff member consisted of one.

ARROWTECH Model 730 Direct Read_ing Dosil)J.eter {DRD) with a range.of 0 to 20R (Calibration due date of June 30, 2016),,and a.thermolmpinescent (TLD) permanent record dosimeter (PRD) that w~s changed ou~ on January 1, 2016 (annual bas_is). Each staff membt'.r was also issued a card. with radiation exposure limits for EW s. *... :

Ac~ording to an_ interview with the B~rks Coul].ty Emerge~cy Managem~nt Coordinator, PEMA exchanges all 100 old TLDS. with 100 new J.LP~ arvmally inJ3erks.County. This ensures Berks,

County has up-to-date TLDs for use by County personnel for LGS incidents.

All activities describedin the demonstration criterion were carried out in accordance with the.

plan, procedures and extent_-of-play agreem~i;it..

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Unclassified Radiological Emergency Preparedness Program (REP)

Afte"r Action Report/Improvement Plan Limerick Generating Station 3.a.1 Berks*county,:Reading Hospital The Reading Hospital (RH) successfully demonstrated the capability to issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the. plans and procedures. Emergency workers periodically. and at the ead of.

each mission read their dosimeters and recorded*theTeadings.on the appropriate exposure: record or chart: *The demonstration was conducted as part of a Medical Servjces (MS-1) Drill conducted on Wednesday, May 11, 2016, from approximately 0900 to 1200,.at the Reading*

Hospital located; at 629 Parkside Drive North in West Reading, Pennsylvania.

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The RH staff members working in the Radiation Emergency Area (REA) were issued dosimetry by the Pennsylvania Emergency Management Agency (PEMA). The dosimetry issued to each

  • hospital staff member consisted of orie ARROWTECH Model 130 Direct Readirig Dosimeter* **

(DRD) with a range of 0 to 20 R (Calibratfon due' date* of June 30, 2016); and'a thermoluminescent (TLD) permanent record dosimeter'(PRD) that:was changed out on January 1, 2016 (annual basis). Each stafr'meniber was* also issued a card with radiation exposure limits for Emergency Workers.

A briefing was conducted by a Reading Hosp*ital Nuclear *Medicine Technician and Buffer Zone,

Nurse while the REA was being set up by non.:.medical staff The briefing included the proper

  • wear of dosimetry (placed a( or near chest level fothe front); the prescribed exposure limit of 5 R; the requirement to read DRDs every 30 minutes arid to report readings to the Buffer Zone
  • Nurse; and tum in of the dosimetry to the Buffer.Zone Nurse upon 'completion of REA activities.

The Nuclear Medicine Technician also emphasized their responsibilities in the REA, including monitoring* patients and REA rriedical staffon *a recutring*basis, tracking DRD reading periodicity, and performing area monitoring and deconfariiination upon cofupletioh of REA activities.

Through intenriew, the Reading Hospital *staff in*the REA were knowledgeable on the use of dosimetry, including frequency of reading and reporting requirements. Additionally, the hospital provided a Nuclear Medicine Technician in the REA serving as a technical advisor to the medical staff on radiological issues. The Nuclear Medicine Technician and Buffer Zone Nurse kept track of the time and every 30 minutes, instructed the REA staff to read their DRDs and report their readings to the Buffer Zone Nurse. Readings were recorded on the Personnel Dosimetry Log.

All dosimetry used by the hospital staff would be returned to PEMA at the conclusion of the incident.

All activities described in the demonstration criterion were carried out in accordance with the plan, procedures, and extent-of-play agreement.

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Unclassified.

Radiological Emergency Preparedness Program (REP)

After Action.Report!ImP,rovement Plan Limerick p~nerating Stat,ion 6.d.l Berks County, Reading Ho_spital

'. ~*'

The Reading Hospital (RH) successfully demonstrated the appropriate space; adequate resources,*.

and trained personnel to provide transport, monitoring, decontamination, and medical services to contamjnated injured individ_uals_.. The demonstration was conducted a!' part of a Medical...

Services (MS-I) Drill conduct.ed on Wednesday; May 'I 1,.. 2016, from approximately 0900 to..

1200,' at the Reading Hospital locatect°'at 629 Parkside Dtive North in West Reading, **.

Pennsylvani~.

At 0900, the Emergericf Departinent (ED) 'Charge Nurse was asked to describe the necessary.**

equipment to set-up the decontamination room in preparation for an injured contaminated patient.:. The Charge Nurse stated t}J.at there was a storage area off of th~ ambµlance b;:iy that.

contai!Jed necessary equiprp.ent_arid supplies for e!llergeticy operations.

The storage area was a iocked closet w~s il\\lb¢l~ci "RadiolOgicaJ Equipme~t Room." The...,

contents of this room.included numerous barrier ropes with radiologital con~amination sigriage, multiple cones, set-up procedures, and signaflights whiCh Could be mounted on top of the caries for a hight operations. The hallway leading to the Radiation Emergency Area (REA) had temporary markings ori the floor to designate the buff er zone for transfer of the patient from the* '

ambulance gurney to. the hospital bed; There'were multiple rolling trash cans with yellow plastic liners.

The* storage *area contain~d a six foot, locldng,' rolier cabinet.' The contents of thi~ cabinet *.

included 11 Personal Protective Equip!tient'Kits (PPE), which corttained a gown, surgical mask' with an eye shield, surgical b,ooties and yellow rubber outer boots. There.were tWo... '*..

Canberra/RMC kits for body sampling and decoiitam!nation*whlch contained severa(bottles of.

saline, eight. packages ofstefile 4x4 gauze, red *<luct tape, cotton swabs, niultipie boxes and sizes of latex gloves, beta dyrte, hydrogen peroxide, sdssors and bioasshy sample containment bags.

There were insttuetions dn requited bioassay samples' and decontamination techniques a:lso contained in the kits.

On the outside of the cabinet there was a poster* whidh detailed the PPE do'nning sequerice and on the inside of the cabinet door th~re was 8x.10 laminated sheet outlining the Pennsylvania EmergencyMariagement.Agency (PEMA) Errierg~ncy_Worker (EW) SR limit and actfons to:*

  • foil ow when the limits~ were read~ 'Additionally there was a book of standard 6peratlrig procedures, administrative supplies and recording forms. There was barrier tape for marking off-'

the decontaminati~n room and step-off pads to use in the buffer zon_e..

1, In addition t~. the radiological emergency.supplies, ther~ were two radiati'oti survey meters. The' meters were LUDLUM Model t4C radiatiori survey_ meters with pancake Geiger-Muller (GM)*

probes. The mete_rs have a range ofO_ -*50;000 Cou,nts Per'Millute {CPM}, and had_ calibration..

due dates of December 22', 2016.. The cabinet also contained a Model 510, electrdnic' dosimeter charger and a portable ait sampler. The. cabinet was checked and restocked on a monthly basis,.

and after every use.

The RH staff members working in the REA were issued dosimetry by PEMA. The dosimetry issued to each hospital staff member consisted of one ARROWTECH Modd. 7~0 Direct Reading Dosimeter (J)RD) with*a range of 0 to *20R (Calibration due date of June 30', 2016);artd. a *.** ' '

.' ',~

  • *.*:I

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I 16

Uriclassitled Radiological Emergency Preparedness Program (REP)

A:fter Action Rep~rt/Impro~ement Plan Limeri~k Generating Station thermoluminescent (TLD) permanent record dosimeter (PRD) that was*changed* olit on January*

1, 2016 (annual basis). Each staff member was also issued a card with radiation exposure limits for Emergency Workers.

At approximately 0945, the Nucle~r Medic.ine Tech~kiai:i des~ribedthe. tadia~i~n survey kit '.

contents which' included; two surv~y' rrieters with panc~ke.probe~; check source coin; dosimetry kit and a Canberra Electronic Personal Dosimeter (EPD) which was worn appropriately by the Nuclear Medicine Technician member and was last calibrated in August 2015. The Nuclear Medicine Techniqian also had a Landauer L~xel Optically*~timulated Luminescence (OSL),

PRD..

f,.1 The two sur\\rey meters were 'LUDLUM Modei 14C;. both c~librated on 'December 22, 2015 arid r with stickers indicating the operational check s~tlrce'r~ading ranges that re:ad 0 mR/hr to 2000-.

mR/hr or 0 CPM to 240,000 CPM and Correction !'.actor (CF) for (pancake) probt?s. '.fhe RH Nuclear Medicine. !echllician also had a Cesium-I~ 1 check source. for pefformjng operability checks on the.survey instruments. The RH Nuc~e~r 1;1ediGin~ Technician performed an operability check on-both instruments prior to placing 1hem in use. The instruments were also.

source-checked using the 1 microcurie Cs-13 7_ check source; both detectors responded within the range ofreadings on the label a~fixed to the side ofthe LUDLUM instruments.

At approximately 0950, the Nuclear Medicine Technician donned the same protective ensemble worn by the REA_ medica~.Stl:J:ff, includit?-g fl surgical mask, and one~: the REA was.activated_ the Nuclear Medicine Technician remained in the REA the entire time the REA was in use. The.

report from the Bally Comm~nity Ambuiance crew was di~s~rriinated.to REA s*taff The r~port detailed the patient's fan* and preli~inary report of~ cut oh the-left elbow with a possible -

fracture: Initial contamination levels reported were-600 CPM on outside clothin'g and both.

hands. Vital signs reported.were :mooq.Pressvr~ 150/84, Heart Rate. 80, Respiratory Rate 16 and Pulse Oxygen at 97%: The patient had fallen in a c9ntaminated area of approximate_ly ~'000.. :

CPM.

The.REA was established at approximately l007 hours..

After the.Bally Community Ambulance arrived at RH, initial medicai evaluati9n was.performed by the REA pqysician at approxiµiately 1009.. The patient was transferred fo tbe REA in Trauma Bay Number* 1,." '

  • At approximately 1010, the Nuclear Medicine Technician monitored the injured and contaminate.d patient using a LUDLUM Model 14.C survey instrul.)1ent with pancake GM probe.

The probe w~s covered.in plastic; to pr~vept the po.ten:ti~l. for the spn~ad of coritamiri~tion to the probe surface. The following contamination.lev.eis were obtained: 600 CPM on the outside of.

tht? clothing and shoes. Survey re~ults on. both l~ft-and righthands-Were 6*00 CPM. With concurrence of the Nuclear Me.dicine Technician, the physician decided to remove the outer garments of the patient prior to perfo~ming decontaniinatiori of the wound~ Once the quter _..

garments were removed, the Nuclear Medicine Technician directed the REA medical staff to replac_e ~he out~r surgical glo.ve~.

At ;a~p~oxlmat~l~ 1020~: aft~~ the initial decontami~~tio~,attempt wa~ ~~mp)et~_d, the N~cleai:

t

. r Medicine Technician re-monitored the patient, and the following contamination levels were 17

U nc.Iassificd Radiological Emergency Prepar~dness Program (REP)

After Act!on.Report/Improvement Plan Limer.ick Gem;rating Station found: 40 CPM on the left and right hands, an.~ 1709.~PM on.the cut on the left elbo\\.\\'. The Nuclear Medicine Technician then instructed the REA medical staff to replace their outer surgical gloves. Vital signs reported were Blood Pressure 150/84, Heart Rate 80, Respiratory Rate 16 and Pulse Oxygen at 97%.

At approximately 1022, the Doctor in the REA requested an X-ray of the possible left elbow injury. The REA Doctor and Nuclear Medicine Technician discussed the procedures for transfer of the patient to a gurney across the REA boundary, placing covers over the X-ray platform during procedures, and posting the Nuclear Medicine Technician outside of the REA to escort the patient and ensure the X-ray equipment was not contaminated.

The patient returned from X-ray at approximately -1025'.and a s'econd decontamination on the cut of the left elbow was attempted. After the second decontamination attempt was completed, the Nuclear Medicine Technician re-monitored the patient's wound,' and the following contamination levels were found: 25 CPM on the left elbow. Vital signs reported were Blood Pressure 150/84, Heart Rate 80, Respiratory Rate 16 and Pulse Oxygen at 97%.

At approximately 1028, the Nuclear Medicine Technician instructed the REA medical staff to replace the outer surgical gloves.

At approximately 1030, the Buffer Zone Nurse and Nuclear Medicine Technician instructed the REA medical staff to read their DRDs and report the readings to the Buffer Zone Nurse. None of the DRDs indicated any radiation exposure. Vital signs reported were Blood Pressure 150/84, Heart Rate 80, Respiratory Rate 16 and Pulse Oxygen at 97%.

At approximately 1040, the Nuclear Medicine Technician and REA Staff discussed procedures for the transfer of the patient onto a clean gurney. The Nuclear Medicine Technician monitored the wheels of the clean gurney, and found no contamination. The gurney and patient were released from the REA at 1046.

The Nuclear Medicine Technician then provided instructions to the REA medical staff for doffing their protective clothing and equipment, including reading their DRDs for the second time and reporting the readings to the Buffer Zone Nurse for recording before the dosimetry was turned over to the Buffer Zone Nurse. The Nuclear Medicine Technician stayed in the REA after the medical staff departed to perform area contamination surveys. No contamination was found, and Trauma Room Number 1, which served as the REA, could be released for general use again.

The exercise was terminated at approximately 1050.

All activities described in the demonstration criterion were carried out in accordance with the plan, procedures, and extent-of-play agreement.

18

Uncla~sified Radiological 'Emergency Preparedness Pr~gram (REP)'

After Action 'Report/Improvement Plan Limerick Generating Station

    • 3.3.1.l BerkS Corinfy, Bally Coinlliun~i~ Ambularic~
  • 1 1

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a.

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

p..LEVEL 1 FINDINGS: NONf.:

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c.

LEVEL 2 FINDINGS:. NONE 1

./

d.

PLAN ISS~S: NONE

e.

PRIOR ISSUES - RESPLVED; NONE

  • 'j J.

PRIORISSUES-UNRESOLVED:NONE,

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19

Unclassified,

~adiological Em7rge11cy ~repare\\ln~ss Program (REP)

AfterAdion ReporVJmp~ovement Plan

.Limerick Generating Station 1.e.1 Berks County, Bally Community Aml!ula.l!~e,.

The Bally Community Ambulance successfully cieip.~nstn1ted sufficient equipment and supplies to support emergency operations during the Limerick Generating Static;m Medical Service Drill.

conducted on May 11, 2016.

Prior to the commencement of the ex,ercis~, a re\\;iew andyerification was conducted for the*

equipment inventory carried on the Bally Communjty Ambulan~e.

No dosimetry was required for the Emergency Medical Service. crews, because tpe Bally Community Ambulance and the Reading Hospital were both located outside of the Emergency Planning Zone (EPZ). Personal Protective Equipment (PPE) including Tyvek suits and gloves, along with the required pap~rwork were pn-.hand. Per the negotiated extent-of-play, personnel were allowed to conquct response actions in-no.nn~l dress, with only required PPE being..

sufficient layers of gloves.to demonstrate chan.ges~'..

Upon arrival at the hospital, the hospital staff used a Ludlum Model 14C survey meter for monitoring the patient. The meter's calibration sticker.stated a calibration date of November 15, 2015 and due date of November 15, 2016. follo;w.ingpatient monitoring, the ambulance crew.

used the same survey meter to monitor on.the.:i;~~rgency Medical Service staff and the ambulance.

All activities were based on the. plans and procedures and completed as they wo.uld have b~ep in :

an actual emergency except as noted in the extent-of-play agreement..,

. \\:

20

Un~lassified

  • Radiological Emergency Prepare'dness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.a.1 Berks County, Bally Community Ambufa.'n:ce The Bally Community Ambulance successfully*demonstrated implementation of Emergency*

Worker control duringthe LimerickGenerathig Station Medical Ser"Vice Drill conducted on May 11, 2016.

The drill's' patient pick up location was the 'Severith A venue parking lot across the street from the Reading Hospital. At 0815, the Emergency Medical Services (EMS) from Bally Ambulance ; '

received a call from the Berks County 911 Dispatch Center informing them of the injured person, his condition,*and requesting pick up.

  • According to the Pennsylvania Emergency Management Plans arid Procedures, the ambulance crew is. Consider_ed to be "Category C" emergency workers because their primary duties are *. *
  • performed outside the 'l 0 mile Emergency Planriin:g Zone. \\Category C" Emergency Workers *.

are not issued dosimetry or Potassium Iodide (KI) due to the low' probability of exposure to minimal direct radiological contamination. For this drill survey meters were simulated.

The Emergency Medical Techiiicians (EMS) each wore two sets of gloves in order to demonstrate *changing gloves after physical contact with thd contaminated patient: The EMS team was aware of the patient's previously determined contamination and injury. The EMS asked the patient about her medical condition. The patient's TYVEK outer garment was cut away and left in the Hot Zone. A sheet was spread out next to the patient to provide a clean area for the rescue personnel to work. The patient's wounds were dressed and the patient was '

prepared for transportation to the hospital. The patient *was laid on the' back..:board and "cocooned" in a thermal blanket wrap, secured to the back-board, and placed in the ambulance.

On the way to the hospital the EMS completed the EMS transfer of Care Form that included the patient's medical information.

Upon arrival at Reading Hospital, the EMS team was instructed to remain in the designated area until surveyed and cleared, and instructed not to eat, smoke, drink, or touch their mouths with their hands. A thorough survey of two members was demonstrated, and a survey of the ambulance was described. All participating personnel were aware of required contamination reports to Berks County if they determined to be contaminated.

The ambulance arrived at Reading Hospital Emergency Department at 0958.

The EMS were monitored by hospital personnel at Reading Hospital after the patient had been transferred for decontamination and treatment. Hospital personnel also monitored the ambulance for contamination.

All activities were based on the plans and procedures and completed as they would have been in an actual emergency except as noted in the extent-of-play agreement.

21

Unclassified Radjological Emergency ?i:_epare,cir:ess Progra~ (REP)

Aft~r A~tion Repor!flmprovement Plan Limerick Generl!ting_ Station 6.d.l Berks County, Bally Community Ambulance The Bally Community Ambulance successfully-demonstrated -the Transportation and Treatment of Contaminated Injured Individuals during the Limerick Generating Station Medical Service Drill con,ducted on May J 1, 20l 6......

Within fiv~ minutes.of receiving a.call from :the B~rk;s.Co.unty 9 U dispatcher that a "radioactiye.

patient" needed assistance, the Bally Community Ambulaµce Emergency Medical Service (EMS) arrived on-scene. For this drill, the incident patient scene was setup at the Seventh A venu,e parking lqt _across the st~eet from thy Rea.ding Hospital. Upon arrival, the EMS called out to the victim to d~t~rmine what happe.ned,.tlw possible extent of injurie's.: Per the patients responses, it was determined she had a possible left elbow fracture indicated by; bruisi11g a swelling of the left arm, but not readily able to be verified without X-rays. The EMS cut away the patient's outer_.clothing and explaii;ied_ that this.wa,s a, method of gross decon~amination that __

would rapidly elimin;ite a._substantial ai,n_ount,of exteri,or contamination. ]2'or this drill surv~y.

meters were. simulated. The EMS assumed.that theY: were handing a contaminated patient..,

According to. the P.ennsylvania Emergency ¥an3;gement Plans and P.rocedur.~s, the ambulance _

crew is considered to }?e '~Category C. Emergency Work;ers because their primary duties are.

performed outside the 10 mpe Emergenqy Planning Zone. "Category C" Emergency W o.rkers.

are not issued dosimetry or Potassium Iodide (KI) due to the low probability of exposure to minimal direct radiological contamination.. -

~

Vital signs were taken,: alopg with other critical per:sonal information - age, medication allergies, etc on,the EMS Transfer of Care Forni. N.o life_ threateni~g concerns were identified an_d the EMS ensured that contamination control was carefully implem_ented.

J Upon departure from the scen_e,the patient's qmdition, w~s clearly communicated to Reading ;

Hospital Emergency Departm~J?.t, along with their expect~d_ estimated time*arrivaL Normally the Bally Community Ambulance took approximately 20 minutes to_arriye at the hospital, Upon arrival, vital signs were verified again, pain level was diagnosed and treated, and the ere~

updated the hospital on any significant cha~ges_ tq the.patient's previously reported. condition. _

~

r All activities were based.on the plans an,d.pro,cedures and completed i;is they would have been i.n an actua_l emergepcy e~cept as.noted in _the extent-of-play agreement. _

22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating 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 Limerick Generating Station, Medical Services Drill evaluated on May 11, 2016.

Two (2) Federal Emergency Management Agency (FEMA) evaluators provided analyses of six evaluation criteria. There were no Level 1 Findings, Level 2 Findings, or Planning Issues identified during the drill.

The Bally Community Ambulance 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 Reading Hospital.

The Reading 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 Bally Community Ambulance, 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 off site Radiological Emergency Response Plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-06547FEMA-REP-l, 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.

23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportllmprovement Plan Limerick Generating Station APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leader for the Limerick Generation Station 2016 Medical Services (MS-1) Exercise evaluated on May 11, 2016. The following constitutes the managing staff for the Exercise Evaluation:

  • Thomas Scardino, DHS/FEMA, Regional Assistance Committee (RAC) Chairman
  • Tina Lai Thomas, DHS/FEMA, Emergency Management Specialist, Team Leader & Evaluator
  • Kenneth Wierman, DHS/FEMA, Emergency Management Specialist, Evaluator DATE 5/11/2016 SITE L'

. kG 1menc s

eneratmg tat1on LOCATION EVALUATOR AGENCY Berks County, Reading Hospital Kenneth Wierman FEMAHQ Berks County, Bally Community Ambulance Tina Lai Thomas FEMA RIII 24

Uiiclassified Radiological E~ergency Preparedness Program (REP),

After A~ilon Report/Improvement Plan

  • 'Limerick 'Gene'rating'Stadon APPENDIX B:- ACRONYMS AND ABBREVIATIONS.

I_*.;

. I, Acronym Meaning

~ *,.. '. ;

CFR Code of Federal Regulations CPM

. Count Per Minute..

DHS -.

Department of Homeland Securitv *

' *='

EAS Emergency Alert System*

! ! ~. f

, '. f

  • _1,/'

EMS Emergency Medical Services Extent-of-play..

,,"' 1 *I' EOP

-Emergency*Plarining Zone

)

EPZ-M'-**

Federal Emergency*Management Agency -

\\

FEMA..

-~-

  • General Emergency *

-'~..,

~

GE

. "' *-*.. *-.. ~

IP Improvement Plan KI Potassium Iodide LGS Limerick Generating Station MSL Mean Sea Level MS-1 Medical Services MW Megawatts NPP Nuclear Power Plant NRC Nuclear Regulatory Commission ORO Offsite Response Organization PEMA Pennsylvania Emergency Management Agency PRD Permeant Record Dosimeter PPE Personal Protection Equipment RAC Regional Assistance Committee SAE Site Area Emergency SAV Site Area Visit REA Radiation Emergencv Area REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plans 25

trnclassified Radiological Emerg_ency Preparedness Program (REP)

After Action )1eportllmP,rpvement Plan

.. *,., ]fimerick Generating Station APP,ENDIX C: *~XJ;ENT-OF-PLA:V

' L.IMERICK GENERATINGc STATION READING HOSPITAL MEDICAL.SERVICES EXERCISE M~y H,. Z016.

Method of,.Operation

1.

The power station and its p,er~onn~l will ~ot play a~ active !Ole. i~ the f8;cilitatic;m of this exercise. The plant's simulatec;l events, l'.adiation releases, and emergency.cla,ssifications will pe injected*by off-site Contrqllers... A,pre-approved scenario.will be used.

2.

The. Pennsylvania Emergency Ma~agem~nt Agency (PEMA), Ar~a Offic~ (Eastern Area)

'Yill not be activa~ed as part of th\\s drill. l;'he Exercise Coordinator will provide pre-exercise coordination and observe exercise activities.

3.

Exelon Corporation will participate as a Controller in this exercise.

4.

Berks County Departm~I).t of Emergency Services will participate in this exerci~e.

I

5.

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

6.

PEMA staff and qualified county emergen~y ~anageme~t personnel w'ill be assigned to key locations for the purpose of obser:ving, noting response actiqns and condi~ions; and recording observations for future use.. Obser¥ers 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 are-demonstration.

7.

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

8.

Exercise activities are scheduled to commence on or about 9:00 a.m., May 11, 2016 and continue until the participants have completed the exercise objectives and demonstrated the Exercise Evaluation Criteria.

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 26

Unc.Iassified-'

Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Gene'rilting Station as provided in the plan, it should.be ri0ted*for*possible modification of the plan, but not classified as a negative incident.- 'Furthermore, if, by foliowing the plan there is a failure to protect the public health :a:nd 'safety; it shou'Id be noted so that the plan can be modified and the appropriate negative assessment :Corrected.

11.

During the exercise any activity that is nof 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..£valuators are ntit permitted to provide refresher training. Re-demonstrations will be negotiated between the Pia:yers,. Observers, Controllers, and Evaluators. PEMA may advise the Regional Assistance Committee Chair prior to

. initiating any re-demonstrations. It 'is* permissible* to' extend the demoristration. window, within reason, to* accommodate the re-demonstration. Activities corrected from ate-demonstration will be so noted.

1 Objectives I.

A.

Demonstrate the ability to respond to a r~diatioil medical emergency following the procedures of Berks County Department of Emergency Services, Bally Community Ambulance and Reading Hospital. ~..

~

B. * ' Demonstrate timely and* accurate communications between the hospital and.off site response agencies. (Telephone8 will be used hi lieu of radios whenever possible to limit the potential misinterpretation of the exercise as an actual event.)

C.

Demonstrate eorrect priorities and approp'tiate*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.

27

Unclassified Radiological Emerg\\:ncy P~epared~ess Program (REP) _

~,

After A~tiQn Report/Imp,rQvement Plan

. Lime~ick venerating Stati"n Extent-of-play Evalu~tio~-A~~a 1-Emerge~cy o*p~rati~~s M~:~~ge~en~

S;ub-Elemeµtl.e--Equipnieqt-and Supplies to Support Operations -

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This sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that Offsite Respol!se Organizat~ons. (ORO), hav~,emergt?ncy eq~iprperit and supplies adequat~ to-, support.

the emergency respon~e.

Criterioq 1.e.1: Equipment,. m_ap_s, dis.plays, mm1itoring instruments, d_osimetry,

  • potassium.iodide, (KI),,._and other.suppiies ~u;e s.ufficient to support emeI_"gency opera~ions.. -

(NUREG-0654/FEMA,-REP.,.1, H.7, 10;_Ir7;.. 8_, -9;:J.10-.a, b, e, J.11,,12; K.3.a; K.5.b).. -- _ *. _

Assessment/Extent.,of-play -

.. i,.

~. '. :. '

' l Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation an~ subsequeQt periodic. inspections, 1

., ', ) *I I

~

A particular facility's equipment and supplies must be suffi<?i~nt and cousistent with that _

facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is ~ncouraged. J:or.non-facility _b~s~d operations, the equipment,~nd supplies _m~st be sufficient and consistent with, th.e_ assigned operatjcmal role. At loca~ions ~here traffic :and a,cc~ss control personnel are deployed, appropriate ~quiprr:i,~nt (e.g., veh,icle~, barriers, traffic <.>_ones,- and signs) _must ~e available,_o_r the.ir availability described. _

~.'. :-

~ -

~ -

Specific equipr.nent and: supplies that;must be demonstrated un~er this criterion include KL:

inventories, c:l,o_simetry, and-~onitori_ng ~quipm~nt~ ~~ follows:

KI: R~spon~ible. _OROs niu~t demonstrate th~ cap~biUty to n;a~ntain inventories of KJ suffj._~i~~t..

for use by: (1) emergency workers; (2) institutionali;zed ingiviquals,,as, ind~cated tP: capacity_ lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transie1,1ts) within.the pluml'._pathway Erz. In aqditiop.,,ORO~. mu,_s_t d~mo_nstrate..

provisions to make KI availablt? to spe9ialized rt;sponse teams (e.g., civi.l supportteam,,Special.

Weapons aµd Tactics Teams, urban search f!:nd _rescµe, bomb.squads, HAZMA'"f, or otl:ler-ancillary groups) a_s ide11tified-in plans/procedures)_. Jhe plans/procedures.must ipclude the foi:rri~

to be used for documenting emergency worker ingestion-pf KI, as well as a mechanism for identifying emergency workers t~at have depli~ed ~I ii:i advance. Consider carefully the placement of;emerg~ncy.workers that have decl~ne,d K~ in advance..

\\*

"t ORO quantities of dosimetry and ~I ~vailable aJ,ld s~orage -l<?cations(~) 'Yill be. confirmed by.*

physical inspection at the storage location(s) or through documentation of current inventory submitted duripg the exercise, provid~d in the. ALG submissisin, and/or verified during an SA V,.,_,

Available supplies _pfKLmust be.within _the,expiration~date indj9ated op Klbottl~s or blister packs. As analtemative,_th~.Q.~O may pr9du_ce.a l~tter ~rom ~certified private or ~tatc.. " : '..,. 1,,

laboratory indicating that ~he KI,supply.rerpaips pote~t, in accordance with_U,.S~ PR.amiacopoe\\a

  • standards.

28

Unclassified Radioiogical Emergency Preparedness Program (REP)

  • After Action Report/Improv*ement Plan Limerick Generating Station

'}',,

.;, ~ :.. *. -~,. :.. ' '

Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available fods'suance tb all emergency workers who will° be*

dispatched to perform an ORO mission., In addition; OR.Os must demonstrate provisions to make dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as' identified in plans/procedures.

Appropriate direct-reading dosimetry* rr11ist'*a11ow an* individual(s} to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures:

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance.* The dosimeters must be inspeCted for electrical leakage at least annually and replaced when' necessary.. Civil Defense Victoreen-Model 138s (CD V-BSs)*(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 AL.C 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 SAY * * :

  • Monitorin*g Insfruments: All instruments must be inspected; inventoried, and operationally checked before each use: Instruments must be*calibtated ih'.accordance with the manufacturer's recommeridati6ns. Unmodified CDV-700.series*instniinerits and other ihstrurrients without a manufacturer's recommendation must be calibrated anmiaJly.* Modified CDV-700 instruments,

must be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration *must be on each instrument or calibrated frequency can.be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings* that the meter should indicate w~en it is response::.checked usin*g a standard test source.".

For FMTs; the instruments must be capable ofm~asuring*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 arid 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 IR/hr) and for high-range instruments whe~ available. If*a source is not available for a high-range instrume.nt, a procedure must exist to operationally test the instrument before en~ering an area where only a high-range instrument can° make useful r~adings.

In areas where portal monitors are used,.the O~Os musf set up and operationally check the monitor(s)." The moriitoi(s) must conform to the standards set forth in*the Contamination Monitoring*'Standard'for a Portal Monitor Used for-Emergency ReSpons.e, *FEMA-REP-2 i (March* 1995) or in accordance with the manufactur~r' s. recommendatiOns*.

29

Unclassified Radiological Emergency Preparedness Program (REP)

/

' I

~

I p

l ' ' '

_After A~ti~n Report/lmP,rovement Plan Mutual Aid Resources: If the incoming resou~c~s.. ar:dve with their own equipmen.t.(i.e.,,

~ '

.,. ~ r" {

r t

monitors and/or d9,sime~ry),,they will be evah.iat~dJ?Y ~p Program standard,s. F~MA will not,

inventory equipment that is not part of the REP Program. If an agency has a defined role in the REP Plan, they are subject to the planning process and standards, as well as the guidance of this.

Manual.

All aCtivities must be bas.ed on* the, ORQ' s pl~ns/procedures and completed as they ~ou}d ~e in'..

an actual eQiergency, unless noted above. or ptherw.ise specified in the Extent-of,,, Play Agreement.'. * *

. ~

~

State.Negotiated Extent-of-play:

Ambulance crews are not trained or equipped to' 0°perate or carry radiofogi~~i ~~nitorin°g:

equipment. In accordance with PEMA standard operating procedures ambulance crews.

operating outside t~e 10 i;nile Emerg_ency Planp~ng:Zo.ne are considered "Cf1tegory C" emergency workers;"therefore1 they are only requ1req to,,impleinent protec:tive i;n~asures copsistent with.

protectio17-again.st blo.oq.. bome pafhogells; i.e,,, loP,g sleeved garments, t~cmsers: impermeable..

gloves, and surg~~al masks. "C.ategory C". epi~rg~Q.cy worker dosimetry issue consists of one permanenf~eading ~osimeter per w.orke~,*

~..,. '.. *, * *~....

Hospital personnel are also considered "Category C" emerge~cy workers and will conform to PEMA SOP protective measures at minimum. Direct Reading Dosimeters. may be issµed individually; however, an Area Kit will be established in the Radiation Einergency Area (REA).**

  • Individual PRDs will be i.ssued by.the hospital. Radiological Survey Instruments are calibrated per manufactures re.~qnimendatiop.s.. '
  • Outstanding Issues:

None

.. \\

~:.,....

30

uilc1assified Radiological Emergency *Preparedness Program (REP)

After,.Acti~'n Report/lmp~~vement Plan

  • Limerick Gene~a'ting Station Evaluation Area 3-Protective Actidn
  • Implem*enfation Sub-Elemen~ 3.a-lnipl~mentation bf Emergen'cy Worker Exposure Cont~ol i ; I.

~

This Sub-element is derived from NUREG0654/FEMA-REP-1, which requires that OROs 4.ave the cap~biliiy to provide for the following: distribution,' use; collection; *and processing of direct-reading dosimetry and' permanent reeord dosimetry; readiiig 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 PA Gs, and the capability to *provide KLfor *..

emergency workers, always applying the "as low as is reasonably achievable" principle as appropriate.

j

~. '.* :.

Criterfon 3.a.1: Th'e*OROs issu~ appropriate.dosimetry, KI, and proced,iires, and manage radiological' exposure to emergency workers in"accQrdance with the plans/procedures.

  • Emergency workers periodically and at* the end of each. mission read their dosimeters and record *the readings on the appropriate exposu're 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)

I

.' *~. :.

Asses~~ent/Extent-of-pia*

  • Assessm~nt of this Demonstration Criterfon may be accomplished during *a b.iennial 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, KI, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.

During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and tum-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.

31

Unclassified Radiological Emergency Preparedn(!SS Proi.;ram (REP)

Af~er Action Report/Improvement Plan Limeri~k Gener~ting Station Workers may use any available resources (e.g., written.proc~dures 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 memqers. will be in close proximity to each other duripg the entire mission."* In such cases, adequate control of expo_sur~ can be achie.ved for all team members.

using one direct-reading.dosimeter worn by the tearri leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOCs and *communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters. or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategi~ally 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 radiological exposure commensurate with completing their missions.

OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers performing various services (e.g., lifesaving, protection of valuable property, all activities). OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where 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 the date(s) and time(s) they did so. Ingestion of KI recommended by the designated ORO health official is voluntary.

For evaluation purposes, the actual ingestion of KI shall not be performed. OR Os must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. Emergency workers must demonstrate basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

State Negotiated Extent-of-play:

Demonstrate appropriate procedures and equipment to manage radiological exposure to staff.

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

Demonstrate the ability to utilize dosimetry, equipment and procedures to manage radiological exposure to emergency workers as required by plans.

Radiological briefings will be provided to address exposure limits and procedures to replace personnel approaching limits and how permission to exceed limits is obtained. At any time, players may ask other players or supervisors to clarify radiological information. In Pennsylvania, emergency workers outside the EPZ do not have tum-back values. Standard issue of dosimetry and potassium iodide for each category of emergency worker is as follows:

32

Uni:Iassifie.d Radiological Emergency Preparedriess Program (REP)

After A~min Reportlimpr~vement Plan CategoryA:*l PRD,*1 DRD, and 1:uni{of'Ki"':*

Category B: 1 PRD and 1 unit of KI Category C: 1 PRD Limerick G~nerating s*tation All locatfons that have dosimetry ~quipmerit indicated' within their RadiOlogical Ernerge~cy :...

Response Phm (RERP) will make the dosirrtetry equl'prii.ent (and KI, as appropriate) availaple fqr

inspection by the Federal'Evaluator. Siniiilatio*n PRDs W,ith mock serial numbers µi~y be µsed...

I f

Outstanding Issues:

' ~I None

,',I

~ *i

' :. '.: ~

l.. *,.

,I' i<

. \\

33

Unclassified Radiological Emergency Preparedness Program (REP)

. A.fter Action Rep~rt/lmprovement Plan

" *, Lim~rick Ge.ner'ating*Statidn Evalu~tion Area 6-Support OperationfFaciliti~~. '. *. *,.

  • Sub-Element 6.d-Transportation and Treatr_nent ofContamillated Injured Individuals*

1 Intent.,

This-Suh-element is derived from NUREG0654/FEMA-REP-l, which requires that OROs have the capability to transport contaminated _injure~ individtia:ls to medical facilities with the capability to provide medical services.

Criterion 6.d.1: The facility/ORO 1-~sJhe* ~p_propriate space, adequate resources, and trained personnel to provid~ transport, moµ.fro~ing~ ciecontamination, and m~dical services to *contaminated injured individuals.*.

(NUREG0654/FEMA-REP-1, F.2; H.10; K.5.a, b;'L.1, 4)

Assessment/Extent-of-play

'. t Assessment of this Demonstration Cdte~~~n i;n~y*be accomplished during a biennial exercise, an actual event, or drills. FEMA has determined th.at these capabilities have been enhanced and con~istently demonstrated as adeq~ate; therefore; "9ffsite. medical se~ic'es drills need only be*,

evaluated biennially. FEMA will, at the request of the ORO, continue* to evaluate the* drills on an annual basis. All hospitals listed in the plan as medical services hospitals must'beevaluated, with a transportation provider, every 2 years.. Ad~itional transportation providers will be rotated through the drills 'in the 8-year exercise cycle,. For.the ambulance providers who d6 not

  • participate in an evaluated drill during the two year cycle, training will be provided.** This training will be documented in the ALC.

Monitoring, decontamination, and contamination control effort's must not delay urgent medical care for the victim.

OROs must demonstrate the capability to monito~/dec,on~aminate and transport contaminated injured individuals to medical facilitie~.

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OR Os may use any vehicle (e.g., car, truck, or van) to transport the ~ictim to the niediCal facility. It is all~wabie 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 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 34

Unclassified Rad_iological Emergency Preparedness Program (REP)

After,J\\cti~n Report/Improvement Plan Limerick Generating Station monitored as soon as possible to assure that eyeryone (ambulance and medical facility)-is aware.

of the medical and radiological status of the irtdividu~l(s). However, if an ~mbulance 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 proces.s of checking the -instrument(s) for proper operation. AlLmonitoring activities must be completed as they would be in an actual emergency.* App~opriate 'con.tamination*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 ~xpected 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 mailltain record~ of.all survey measurements and samples taken: Ali procedures for colleqtion and analysis of ~amples *and decontamination of the individual must be demonstrated or described to the evaluator. W~ste water from.decontamination.dperations must be handled according to facility plal).s/pr.ocedures....

All activities must be based on tlie ORO's plahs/proc*edures and completed as 'they would be in an actual emergency, unless noted above or otheffirise 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, Bally Community Ambulance will pick~up a pre-staged simulated contaminated/injured victim.

Outstanding Issues:

None

., ' r*

35