ML16326A270

Final After Action Report/Improvement Plan for the Limerick Generating Station (LGS) Medical Services (MS-1) Drill Held on September 15, 2016

ML16326A270
Person / Time
Site:	Limerick
Issue date:	11/01/2016
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: ML16326A270 (28)

Text

U.S. Department of Homeland Security One Independence Mall, Sixth Floor 615 Chestnut Street Philadelphia, PA 19106-4404 FEMA NO_V >>. I 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 Limerick Generating Station (LGS) Medical Services (MS-1) Drill that was held on September 15, 2016. The Abington Memorial Hospital and Plymouth Community Ambulance Association 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 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.

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

MaryAnn Tierney Regional Administrator Enclosure www.fema.gov

Limerick Generating Station After Action Report/Improvement Plan Drill Date - September 15, 2016 Radiological Emergency Preparedness (REP)

Program FEMA Published October 24, 2016

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After Action Report/Improvement Plan Limerick Generating Station After Action Report/Improvement Plan Published Date: October 24, 2016 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 ....................................................................... 11 3.3 Criteria Evaluation Summaries ....................................................................................... 12 3 .3 .1 Risk Jurisdictions ........................................................................................................ 12 SECTION 4: CONCLUSION .................................................................................................... 13 APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS ................................ 14 APPENDIX B: ACRONYMS AND ABBREVIATIONS ........................................................ 15 APPENDIX C: EXTENT-OF-PLAY ........................................................................................ 16 1

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After Action Report/Improvement Plan Limerick Generating Station EXECUTIVE

SUMMARY

On September 15, 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 (LGS) 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 September 11, 2011 (Commonwealth of Pennsylvania).

The purpose of the Limerick MS-1 drill was to assess the State and local offsite 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, Montgomery County Department of Public Safety, Abington Memorial Hospital and the Plymouth Community Ambulance Association 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 and 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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After Action Report/Improvement Plan Limerick Generating Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Limerick Generating Station (LGS) Medical Services (MS-1) Drill Type of Exercise Medical Services (MS-1) Drill Exercise Date September 15, 2016 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radioactive Contaminated/Injured Person 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 Jeffrey Dean Emergency Preparedness Coordinator Exelon Corporation 298 Longview Toad Royersford, PA, 19468 (610) 718-2022 jeffrey.dean@exeloncorp.com Sandra Silva Emergency Management Specialist Pennsylvania Emergency Management Agency 1310 Elmerton A venue Harrisburg, PA, 17110 (717) 651-2235 sansilva@pa.gov 4

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After Action Report/Improvement Plan Limerick Generating Station 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Limerick Generating Statiod drill:

State Jurisdictions:

Pennsylvania Emergency Management Agency Risk Jurisdictions:

Montgomery County Department of Public Safety

. Private Organizations:

Abington Memorial Hospital Plymouth Community Ambulance Association 5

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After Action Report/Improvement Plan Limerick Generating 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 responsibility for all off-site radiological planning and response.

FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CPR) Parts 350, 351and352. 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 CPR 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.

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 September 15, 2016, 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 Limerick Generating Station. The purpose of this exercise report is to present the drill results and findings on the 6

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After Action Report/Improvement Plan Limerick Generating Station 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 contained in the following:

• NUREG-0654/FEMA-REP-l, 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, 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 and Results" information on the demonstration for each jurisdiction or functional entity evaluated in a jurisdiction-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.

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 major operating equipment and buildings are located, is on the east bank of the Schuylkill River. This portion is separated from the second segment, where the cooling water intake is located, near the main line of the Reading Railroad. The third portion lies on the west bank of 7

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Limerick Generating Station the river, adjacent to Conrail railroad tracks. The site coordinates are approximately 40°13'27"N and 75°35'15"W. .

The minimum exclusion distance for the LOS is 2,500 feet from the center of each reactor. The utility owns all the land within the exclusion area. No private residences are located within the exclusion area; however, some farming may be permitted.

There are 165 sirens installed to cover the 10-mile plume exposure pathway EPZ. These sirens are activated three (3) minutes before the Emergency Alert System (EAS) messages issued by the Commonwealth of Pennsylvania are broadcast. Soils in this area are of the Reaville-Penn-Klinesville Association and are characteristic of rolling uplands. They are underlain by sedimentary rocks of the Brunswick Formation, consisting mostly of red shale with some fine-grained sandstone interbedding. The normal pool elevation of the Schuylkill River in this area is 200 feet above mean sea level (msl). The topography of the area is hilly, with elevations ranging from 100-300 feet above msl within five (5) miles of the site. The plant is approximately 217 feet above msl.

The climate in this area is dominated by prevailing westerly winds that produce humid, continental-type weather characterized by warm summers and moderately cold winters.

Montgomery County is the warmest part of Pennsylvania, with an average annual temperature of 57°F. Annual precipitation is approximately 42 inches. The area in the immediate vicinity of the plant is made up mostly of agricultural and other open land. The Pottstown Borough in Montgomery County is the nearest community. The nearest major population center (more than 25,000 people) is Philadelphia that lies 25 miles to the southeast of the site.

Two major.industries employ a total of 850 persons within two (2) miles of the plant. Two small airfields are also located nearby. A small private airfield is about one (1) mile to the northeast, but its runway is oriented so that the flight path does not pass over the plant. The Pottstown Municipal Airport is 4.3 miles northwest of the site. The LOS 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 Abington 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 Montgomery County, Plymouth Community Ambulance Association and Abington Memorial 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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After Action Report/Improvement Plan Limerick Generating Station 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 Plymouth Community Ambulance Association and Abington Memorial Hospital.

2.3 Scenario Summary The exercise scenario for this Medical Services Drill consisted of simulated notifications of escalating emergency classification levels at Limerick Generating Station from Site Area Emergency to General Emergency.

During the incident, at an evacuee monitoring and decontamination station, an emergency worker tripped over an unattended hose located in the decontamination evacuee-vehicle area.

The victim has a possible right wrist fracture, bruised and swollen (not immediately known without X-rays), and abrasions on both hands. Plymouth Community Ambulance Association was dispatched to the scene to provide medical support and transport to the nearest MS-1 Hospital.

Upon arrival at Abington Memorial 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 patient for radiological contamination. Initial contamination levels included 1200 cpm on both palms. After the first decontamination attempt, the readings fall down to 600 cpm on both palms. After the second attempt, the readings fall to background reading.

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After Action Report/Improvement Plan Limerick Generating 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 September 15, 2016, Medical Services Radiological Emergency Preparedness (REP) Drill. The drill was conducted to demonstrate the ability of the Offsite Response Organizations to respond to potentially contaminated injured 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 Demonstration Criteria contained in the REP Program Manual. Detailed information on the Demonstration Criteria an.d 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 Demonstration 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 Demonstration 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:

(Ll) 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).

(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 in the offsite response organizations' (ORO's) emergency plan/implementing procedures, rather than that of the ORO's performance.

(M) Met: The jurisdiction or functional entity performed all activities under the Demonstration Criterion to the level required in the Extent-of-Play Agreement, with no Level 1 or Level 2 Findings assessed under that criterion in the cmTent exercise and no unresolved prior Level 2 Findings.

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After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Drill/Exercise Evaluation Date: 09-15-2016 Site: Limerick Generating Station

~~ u~

(M) Met, (1) Level 1 Finding, (2) Level 2 Finding, (P) Planning Issue ~

c:;'Emergencybperati611s.M~i,iij~~mMf*., ., * :\:.~;:*~: .*: :rz:" .\; ' :* * {** ,/';

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Mobilization lal Facilities lbl Direction and Control lcl Communications ldl Equipment and Supplies to Support Operations lel M M 0::; *......

f:rC!te9tiy~faA..ct1Q!i *~~¢iS,i01:LI\/J:?K,ing .::*:*.~:: :;1: ID*L :;;*.ni. r2 ' 1:::::T *.t **! . :*~** .*rr*::~:.::~: *. J' , , 10;*~::, . . *:;*v . '*

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

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Implementation of Emergency Worker Exposure Control 3al M M Implementation of KI PAD 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 11Fi'ead!M:~asutemerifs. and')\nalysis .*.; *c: *::*' '{. '"*: }* ,;,.

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RESERVED 4al Field Team Management 4a2 Plume Phase Field Measurement, Handling, & Analyses 4a3 Post Plume Phase Field Measurements & Sampling 4bl EinergenC;)i:, :N"ptiii~atiP,n and J>tJ:~liC Intofmati.<?n.:.\ :1, ;.~.~:; .' ,,* :1. :'~**~: '.{r~:.rii'* :::J. ' 11;ilil~\ *, ;:~:!!l ; ;* *::,i;i; 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 5bl SPP'i50.tfl!t>J)erations/Facilities * .* :;.v: :**h11'1 ,;*~ 1~

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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 M 11

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After Action Report/Improvement Plan Limerick Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 Risk Jurisdictions 3.3.1.1 Montgomery County, Abington Memorial Hospital In summary, the status of DHS/FEMA criteria for this location is as follows:

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

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 Montgomery County, Plymouth Community Ambulance Association In summary, the status ofDHS/FEMA criteria for this location is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 12

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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 September 15, 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 Plymouth Community Ambulance Association 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 Abington Memorial Hospital.

The Abington Memorial 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 Plymouth Emergency Medical Service Station, 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-l, Revision 1, November 1980, as referenced in 44 CPR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

An Improvement Plan will not be developed as part of this report.

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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 September 15, 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

• Lee Torres, DHS/FEMA, Emergency Management Specialist, Evaluator DATE: 9/15/2016, SITE: Limerick Generating Station

. EVALtTAtOR: AGENCY Montgomery, Abington Memorial Hospital Tina Lai Thomas FEMARIII Montgomery, Plymouth Community Ambulance Association Lee Torres FEMARIII 14

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After Action Report/Improvement Plan Limerick Generating Station APPENDIX B: ACRONYMS AND ABBREVIATIONS Acronym Description CFR Code of Federal Regulations CPM Count Per Minute DHS Deoartment of Homeland Security EAS Emergency Alert System EMS Emergency Medical Services EOP Extent-of-Play EPZ Emergency Planning Zone FEMA Federal Emergency Management Agency GE General Emergency IP Imorovement Plan KI Potassium Iodide LGS Limerick Generatin!! Station MSL Mean Sea Level MS-I Medical Services MW Megawatts NPP Nuclear Power Plant NRC Nuclear Regulatorv Commission ORO Offsite Resoonse Organization PEMA Pennsylvania Ememency Management Agency PRD Permeant Record Dosimeter PPE Personal Protection Equipment RAC Regional Assistance Committee SAE Site Area Emergency SAY Site Area Visit REA Radiation Emergency Area REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plans 15

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After Action Report/Improvement Plan Limerick Generating Station Appendix C: Extent-of-Play Information LIMERICK GENERATING STATION ABINGTON MEMORIAL HOSPITAL MEDICAL SERVICES EXERCISE SEPTEMBER 15, 2016 Method of Operation

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

2. The Pennsylvania Emergency Management Agency (PEMA), Area Office (Eastern Area) will not be activated as part of this drill. The Exercise Coordinator will provide pre-exercise coordination and observe exercise activities.

3. Exelon Corporation will participate as a Controller in this exercise.

4. Montgomery County Department of Public Safety will participate in this exercise.

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. Exercise activities are scheduled to commence on or about 8:00 a.m., September 15, 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 16

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After Action Report/Improvement Plan Limerick Generating Station scenario. The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a plan that they cannot take actions that are more protective of the public.

Therefore, if, by not following the plan, the responders protect the public equally, as well as provided in the plan, it should be noted for possible modification of the plan; but not classified as a negative incident. Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so that the plan can be modified and the appropriate negative assessment corrected.

11. During the exercise any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants during the exercise, provided it does not negatively interfere with the exercise. Refresher training may be provided by the players, observers, and/or Controllers. Evaluators are not permitted to provide refresher training.

Re-demonstrations will be negotiated between the Players, Observers, Controllers, and Evaluators. PEMA may advise the Regional Assistance Committee 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 procedures of Montgomery County Department of Public Safety, Plymouth Community Ambulance Association and Abington Memorial Hospital.

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

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

D. Demonstrate inter-agency cooperation between the ambulance company/EMS and the hospital.

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After Action Report/Improvement Plan Limerick Generating Station Extent of Play Evaluation Area 1-Emergency Operations Management Sub-Element Le-Equipment and Supplies to Support Operations 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 (Kl), and other supplies are sufficient to support emergency operations.

(NUREG-0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, e, J.11, 12; K.3.a; K.5.b).

Assessment/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 be sufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is encouraged. For non-facility based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows:

KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transients) within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures). The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined KI in advance.

ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV.

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

• 18

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Limerick Generating Station Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to perform an ORO mission. In addition, OROs must demonstrate provisions to make dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures.

Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures.

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary. Civil Defense Victoreen Model 138s (CD V-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 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 IR/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 use~ul 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.

19

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Limerick Generating Station Mutual Aid Resources: If the incoming resources arrive with their own equipment (i.e.,

monitors and/or dosimetry), they will be evaluated by REP Program standards. FEMA 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 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 PEMA standard operating procedures ambulance crews operating outside the 10 mile Emergency Planning Zone are considered "Category C" emergency workers; therefore, they are only required to implement protective measures consistent with protection against blood-borne pathogens; i.e., long sleeved garments, trousers, impermeable gloves, and surgical masks. "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.

Outstanding Issues:

None 20

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Limerick Generating Station Evaluation Area 3-Protective Action Implementation Sub-Element 3.a-Implementation of Emergency Worker Exposure Control This Sub-element is derived from NUREG0654/FEMA-REP-l, 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 KI 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)

Assessment/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, 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.

21

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Limerick Generating Station 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., EOCs.and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry. Individuals authorized by the ORO to 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. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. Emergency workers must demonstrate basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.

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

State Negotiated Extent of Play:

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

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

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

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 turn-back values. Standard issue of dosimetry and potassium iodide for each category of emergency worker is as follows:

22

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Limerick Generating Station Category A: 1 PRD, 1 DRD, and 1 unit of Kl Category B: 1 PRD and 1 unit of Kl Category C: 1 P RD All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP) will make the dosimetry equipment (and Kl, as appropriate) available for inspection by the Federal Evaluator. Simulation PRDs with mock serial numbers may be used.

Outstanding Issues:

None 23

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Limerick Generating Station Evaluation Area 6-Support Operation/Facilities Sub-Element 6.d-Transportation and Treatment of Contaminated Injured Individuals This Sub-element is derived from NUREG0654/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.

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

Assessment/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 ORO, continue to evaluate the drills on an annual basis. All hospitals listed in the plan as medical services hospitals must be evaluated, with a transportation provider, every 2 years. Additional transportation providers will be rotated through the drills in the 8-year exercise cycle. For the ambulance providers who do 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 efforts must not delay urgent medical care for the victim.

OROs must demonstrate the capability to monitor/decontaminate and 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 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 24

Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Limerick Generating Station 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, unless noted above or otherwise specified in the Extent-of- Play Agreement.

State Negotiated Extent ofPlay:

• 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.

Plymouth Community Ambulance Association will pick-up a pre-staged simulated contaminated/injured victim.

Outstanding Issues:

None 25