ML17325B007

After Action Report/ Improvement Plan Conducted on September 28, 2017

ML17325B007
Person / Time
Site:	Limerick
Issue date:	10/26/2017
From:	US Dept of Homeland Security, Federal Emergency Management Agency
To:	Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
Shared Package
ML17325A937	List: ML17325B007
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Download: ML17325B007 (15)

Text

After Action Report/ Improvement Plan Radiological Emergency Preparedness (REP) Program Limerick Generating Station Brandywine Hospital Medical Services (MS-1)

Exercise Date - September 28, 2017 FEMA Published, October 26, 2017

After Action Report/Improvement Plan Published, October 26, 2017 EXECUTIVE

SUMMARY

s 6

SECTION 1: EXERCISE OVERVIEW 6

1.1 Exercise Details 1.2 Exercise Planning Team Leadership 6 7

1.3 Participating Organizations SECTION 2: EXERCISE DESIGN

SUMMARY

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2.1 Exercise Purpose and Design 2.2 Emergency Planning Zone Description 9 2.3 Exercise Objectives, Capabilities and Activities 11 2.4 Scenario Summary 11 SECTION 3: ANALYSIS OF CAPABILITIES 13 3.1 Exercise Evaluation and Results 13 3.2 Summary Results of Exercise Evaluation 13 3.3 Criteria Evaluation Summaries 15 15 3 .3 .1 Private Jurisdictions SECTION 4: CONCLUSION 16 APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS 17 APPENDIX B: EXTENT OF PLAY 18 3

EXECUTIVE

SUMMARY

On September 28, 2017 a Medical Services (MS-1) Drill was conducted 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 MS-1 Drill for this site was conducted on October 27, 2016.

The purpose of the LGS MS-1 Drill was to assess the State and local offsite response organizations preparedness in responding to a radiological medical emergency. The Drill was held in accordance with FEMA' s policies and guidance concerning the evaluation 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, Chester County Department of Emergency Services, Brandywine Hospital and the Minquas Fire Co. No. 2 (Station 46) Emergency Medical Services, who were evaluated during this Drill.

Protecting the public health and safety is the full-time job of some of the drill 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 of 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 as a result of this Drill.

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Philadelphia, PA, 19106 (215) 478-2923 tina.thomas@fema.dhs.gov Sandra Silva Radiological Emergency Preparedness Planner Pennsylvania Emergency Management Agency (PEMA) 1310 Emerton A venue Harrisburg, PA 17110 (717) 651-2235 ssilva@state.pa. us 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the exercise:

State Jurisdictions Pennsylvania Emergency Management Agency, (PEMA)

Risk Jurisdictions Chester County Department of Emergency Services, (CCDES)

Support Jurisdictions None Private Organizations Brandywine Hospital Minquas Fire Co. No. 2 (Station 46) Emergency Medical Service Exelon Corporation Federal Organizations Federal Emergency Management Agency (FEMA) 7

procedures to protect the public health and safety during a radiological emergency involving Limerick Generating Station (LGS).

The purpose of this After Action Report is to present the Drill results, and findings on the performance of the Off-site Response Organizations (OROs) during a simulated radiological emergency involving a contaminated injured individual.

The Drill was designed to demonstrate and evaluate the responder's knowledge of patient and responder personal protective measures, equipment preparation and employment, and decontamination procedures. All activities were demonstrated in accordance with the participants' plans and procedures as they would be performed in an actual emergency, except as agreed to in the Exercise Plan and Extent-of-Play Agreement.

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 Regional 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, trainmg, and improving emergency response capabilities.

• Section 1 of this report, entitled Exercise Overview, presents the Exercise Details, Exercise Planning Team and the Participating Organizations.

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

• Section 3 of this report, entitled Analysis of Capabilities contains detailed Evaluation and Results; Results of Exercise Evaluation; and Criteria Evaluation Summary. Information on the demonstration for each jurisdiction or functional entity evaluated is presented in a jurisdiction-based, issue-only format.

• Section 4 of this report, entitled Conclusion, is a description of FEMA's overall assessment of the capabilities of the participating organizations.

2.2 Eme_rgency Planning Zone

Description:

LGS is located in southeastern Pennsylvania on the Schuylkill River about 1. 7 miles southeast of Pottstown Borough. The river passes through the site, separating the western portion, which is in East Coventry Township in Chester County, from the eastern portion, which is in Limerick and Lower Pottsgrove Townships in Montgomery County. The plant is owned and operated by Exelon Nuclear. Two boiling water reactors each generate an electrical output of 1,050 megawatts (MW). Unit 1 was issued a full-power license in August 1985; commercial operations began in February 1986. Unit 2 was issued a full-power license in August 1989 with commercial operations beginning in January 1990.

The site encompasses 595 acres and is divided into three (3) parts. The principal portion, where the major operating equipment and buildings are located, is on the east bank of the Schuylkill 9

2.3 Exercise Objectives, Capabilities and Activities The LGS Medical Services Drill evaluated by FEMA, was designed to demonstrate that the ORO can transport, transfer, monitor, decontaminate and treat a contaminated/injured person while minimizing any cross contamination during a radiological emergency.

The demonstration included the ability to:

A. Respond to a radiation medical emergency following Chester County Department of Emergency Services, Brandywine Hospital and Minquas Fire Co. No. 2 (Station 46)

Emergency Medical Services organization procedures.

B. Monitor for radiation contamination and uptake, and to validate persons providing these services are adequately prepared to handle contaminated individuals.

C. Conduct timely and accurate communications between the hospital and offsite response agencies.

D. Exhibit correct priorities and appropriate techniques in Emergency Medical Services (EMS); transportation of patients; and pre-hospital and hospital emergency care of radioactively contaminated patients.

E. Demonstrate inter-agency cooperation between the Ambulance Service/EMS and the hospital.

2.4 Scenario Summary The Limerick Generating Station declared a General Emergency and an evacuation was ordered.

An evacuee was walking towards the monitoring and decontamination center and talking on the phone, not paying attention to her surroundings. As an emergency worker was directing traffic, she bumped into him causing her phone to fly out of her hand. In attempt to catch it, she tripped over her untied shoe, and fell. She broke her fall by landing on her hands but her right wrist twisted in the process.

Injuries: The victim has a possible right wrist fracture, bruised and swollen (not immediately known without X-rays), and abrasions on her left palm.

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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 Limerick Generating Station MS-1 Drill demonstration of September 28, 2017. This Drill was conducted to demonstrate the ability of the OROs to respond to a potentially contaminated injured person associated with 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 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 (January 2016) and NUREG-0654/FEMA-REP-1, Rev. 1. The Demonstration Criteria included:

l .e.1- Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (Kl) and other supplies are sufficient to support emergency operations.

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.

6.d.1- The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

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 were scheduled for demonstration during this drill by all participating jurisdictions and functional entities. Drill Demonstration 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).

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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 5bl Sunnort Operations/Facilities Monitoring, Decontamination, & Registration ofEvacuees 6al Monitoring/Decontamination of Emergency Workers and Equipment 6bl Temporary Care of Evacuees 6cl Transportation/Treatment of Contaminated Injured Individuals 6dl M M 3.3 Criteria Evaluation Summaries 3.3.1 Private Jurisdictions 3.3.1.11 Chester County, Minquas Ambulance In summary, the status ofDHS/FEMA criteria for the Private Sector Organizations are as follows:

a. MET: l.e.l ; 3.a.l ; 6.d.1

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES - RESOLVED: NONE

f. PRIOR ISSUES - UNRESOLVED: NONE 3.3.1.1 2 Chester County, Brandywine Hospital In summary, the status ofDHS/FEMA criteria for the Private Sector Organizations are 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 15

APPENDIX A: EXERCISE EVALUATORS AND TEAM LEADERS DATE: September 28, 2017 SITE: Limerick Generating Station AGENCY -

LOCATION TEAM LEADER Chester County, Minquas Ambulance Michael Shuler FEMARIIl Chester County, Brandywine Hospital Michael Shuler FEMARIIl LOCATION

~

- EVALUATOR AGENCY Chester County, Minquas Ambulance Barton Freeman FEMARIIl Chester County, Brandywine Hospital Patricia Gardner FEMARIIl 17

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

8. Exercise activities are scheduled to commence on or about 8:00 a.m. , September 28, 2017 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 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 Chester County Department of Emergency Services, Minquas Fire Co.

No. 2 (Station 46) and Brandywine 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.)

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Evaluation Area I-Emergency Operations Management Sub-Element 1.e--Equipment and Supplies to Support Operations Intent This sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that Offsite Response Organizations (ORO) have emergency equipment and supplies adequate to support the emergency response.

Criterion 1.e.1: Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations.

(NURE~654/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 21

Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

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 ofthis 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 the PEMA SOP Annex E, Appendix 5 "Radiological Exposure Control" (March 2002), 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.

Ambulance crews are provided additional dosimetry if they are tasked with entering the 10-mile EPZ.

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 23

take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge of whom to contact in case authorization is needed, and at what exposure levels.

Workers may use any available resources (e.g., written procedures and/or co-workers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. In such cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimete:r: 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.

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Evaluation Area 6-Support Operation/Facilities Sub-Element 6.d-Transportation and Treatment of Contaminated Injured Individuals Intent 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.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG0654/FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4)

Assessment/Extent of Play I

Assessment ofthis 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.

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