ML19199A036

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FEMA - Final After Action Report/Improvement Plan for the Calver Cliffs Nuclear Power Plant, Medical Services (MS-1) Drill Held June 18, 2019
ML19199A036
Person / Time
Site: Calvert Cliffs  
Issue date: 07/08/2019
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
ML19199A054 List:
References
Download: ML19199A036 (22)
v • d • e


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After Action Report/Improvement Plan Calvert Cllffl Nuclear Power Plant Calvert Cliffs Nuclear Power Plant Medical Services Drill Contents After Action. Report/Improvement Plan Published Date: July 8, 2019 EXECUTIVE SUl\\fl\\fARY.................................................................. ~............................................. 5 SECTION 1: EXERCISE OVERVIEW.........................................................................,0 **, *********** 6 1.1 Drill Deta.Us.............................................................................................................................. 6 1.2 Planning Team Leadenhip...........................-........................................................................... 6 1.3 Participating Organizations.................................................................................................... 6 SECTION 2: DESIGN SUI\\WARY.................................................................................................. 8 2.1 Purpose and Design....................................................................................., ************ ~***************8 2.2 Objectives, Capabilities and Activities................................................................................... 9 2..3 Scenario Summary................................................................................................................... 9 SECTION 3: ANALYSIS OF CAP ABaITJES.............................................................................. 11 3.1 Evaluation and Results.......................................................................................................... 11 3.2 Summacy Results of Evaluation............................................................... !........................... 11 3.3 Criteria Evaluation Summaries............................................................................................ 13 I

3.3.1 Private Organizations................................................................................................ 13 SECTION 4: CONCLUSION......................................................................................... 0 ***************** 14 APPENDIX A: EV ALU~TORS AND TE.AM LEADERS............................................................. 15

.APPENDIX B: ACRONYMS AND ABBREVIATIONS ********************** ~......................................... 16 APPENDIX.C: EX1'ENT-OF-fLAY AGREEI\\fENT **********************************.********************************* 17 3

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I Unclassified Radiological Emergency Prepmedness Program (REPP)

After Action Report/Improvement Plan Calvert Cliff& Nuclear Power Plaut I

  • EXECUTIVE

SUMMARY

On June 18, 2019, a Medical Services (MS-I) Drill was conducted for the I 0-mile Plume Exposure Pathway, Emergency Planning Zone (EPZ) around the Calvert Cliffs Nuclear Power Plant by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) Region ID. The most recent prior MS-1 Drill for this site was conducted on June 13, 2017.

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The purpose of the Calvert Cliffs Nuclear Power Plant (CCNPP) 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 State of Maryland, Saint Mary's County Emergency Management Division, MedStar Saint Mary's Hospital (MSSM), and the Leonardtown Volunteer Rescue Squad, 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 assign~d responsibility for others. Still, others have willingly sought this responsibility as volunte~rs 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 fmal evaluation of the MS-1 Drill. The State of Maryland and local organizations demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Level l or Level 2 Findings or Plan Issues as* a result of this Drill.

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

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

Section 3 of this report entitled Analysis of Capabilities contains detailed Evaluation and Results; a Summary Results of Evaluation; and Criteria Evaluation Summary. Information on the demonstration for eachjurisdiction or functional entity evaluated is presented in ajurisdiction-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.

5 1

. Unclassified..

  • RridiololP,cai ~iljergency Prepai-i."<lnes.s Program (REPP)

. Cai,*crl Cliffs.Niiclenr Power P.l1111t SECTION 1: ~XER<JISE. OVEJlVIE*w.

. *1~1 D.rm:netails :

. Drill Name.*.....

  • MedStaf Satrit:tviary's Hospita:12019 Medica)s:ervicesDril]

T.y'pe :of Jj l'ill :

  • M~1cal Services *.
  • . l)rill ii~te*: :.*

Jurie 1 s; 2019

. : Pr:ograr.n *.....

-t>epaittnerit of Hori1eland Security/FEMA

  • Radfologfo~l Einei*gency P:reparedness Prqgram *

. *:* *.. scenario Type :_ * *

  • . Rad to logically Conta1111riated/ltijured Person*

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  • t2.. Planriinfl'eani: Lea_d~:rsbip. :
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  • Ni_cholas:Buk
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Pl~ladelphia,: ~ A*.19106. :

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  • Rick Woods*.

. : State Ra~iological Plarinel'..

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... 1.3 J>ai*tkipating Organizatio'1S. *..

. Agencies :and *o~*ganizatio,1s _of the followinijjurisdictions. participated in: the ¢CNPP 20) 9.

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Unclasslfled Radiological Emergency PJq,aredness Program (REPP).

After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Pl1111t Medical Services Drill: *,

State Jurisdictions Maryland Emergency Management Agency County Jurisdictions Saint Mary's County Emergency Management Division Saint Mary's County Health Department Local Jurisdictions Leonardtown Volunteer Rescue Squad Private Sector Organizations Med,Star Saint Mary's Hospital.

Exelon Corporation 7

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Uadudfled Radiological Emergency~ Pmgmm (REPP)

Calvert Cllll'a Nuclear Power Plant SECTION 2: DESIGN

SUMMARY

2.1 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 respo~.

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

44 CPR 350 establishes the policies and.procedures for FEMA's initial and continued approwµ of State and local govemmenJs' radiological emergency pbmning and preparedness for cpmmercial 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 tile follow~g~...

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A,. Taking the lead in o:ffsite emergency p~ and in the ~ew and* ev~uation of radiological emergency response plans and procedures developed by Sta~ ~

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_teqQ.ests by the U.S: Nuclear Regulatory Commission (NRC) pursuantto

  • the Memorandum of Understanding between the NRC and FEMA dated December 7, 2015 (FederaYRegister, Vol. 81, No. 57, March 24, 2016) 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. Dep,artment 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

- U.S. Food and Drug Administration Representatives of these agencies serve on the Region III Regional Assistance Committee (RAC), which is chaired by FEMA. A Radiological Emergency _Preparedness MS-I Drill was

  • conducted on June 18, 2019, to assess the capabilities of State and local emergency preparedness organizations in implementing their radiological emergency response plans and procedures to protect the p}lblic health and safety during a radiological emergency involving CCNPP.

The purpose of this After Action Report is to present the Drill results, and findings on the perfonnance of the Off-site Response Organizations (OROs) during a simulated radiological 8

Undanlfled Rlldlological Emerueney Preparcdacss Program (REPP)

After Aetion Reportllmprowment Plan Calvert Clllli Nu~ear Power Plant emergency involving a contaminated injured individual.

The Drill was designed to demonstrate and evaluate the responder's knowledge of patient ancl responder personal protective measures, equipment preparation and employment, _and decontamination procedures. All activities were*demonstrated in accordance with the participants' plans and procedures as diey 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 detenninations made by the FEMA Region m Regional Assistance Committee (RAC)

Chait.person 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 pwposes of planning, training, and improving emergency response capabilities.

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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 2.2 Objectives, Capabilities and Activities The CCNPP MS-1 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 contanµnation during a radiological emergency. The demonstration included the ability to:
  • A. Respond to a radiation medical emergency following Saint Mary's County Emergency Management I)ivision,. MedStar Saint Mary~s H~spital and Leonardtown Vol~teer _

Rescue Squad organization procedures.

B.

  • Monitor for radiation contamination and uptake,. and.to validate pmo~ providing these services are adequately prepared to handle con~ted individuals..,,
  • C. Conduct timely and accurate communica~o~ between the hospital and o~te response
  • agencies.

D.. Exlu'bit correct priorities and appropriate techniques in. Emergency** M;edi~al. Services (EMS); transportation of patients; and * ~hospital. and hospital. emergency care of radioactively contaminated patients.

E. Demonstrate int~-agency cooperation betw~ the Ambulance Service/BMS and the

. hospital.

2.3 Scenario Summary The scenario for this Medical Services Drill consisted of simulated not;ificauons of escalating emergency classification levels at CCNPP from Site Area Emergency to General Emergenpy, 9

Undaulfted Radiological Emagcncy Pn:parcdncss Program (REPP) -

After Action Report/Improvement Plan Calvert Cllffs Nuclear Power Plant Following an offsite release of radiological material,CCNPP declared a,General Emergency.

During the release and evacuation of Protective A-ction Zones six and seven, an Emergency Worker assigned to a Field Monitoring Team suffers a fall. The Emergency Worker has abrasions to the neck and right pal, and a possible break of the right forearm'. Due to the worker's lo.cation and duties in the plume, the injuries are:8'18Pected and assumed to be contaminated by radiological materials deposited by the plume; _

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Uadanifiecl Radiological Emagcncy Preparedness P.rognmi (REPP)

After Aedon Reportllmpmvement Plan Calvert Cllfl'I Nuclear Power Pbnt SECTION 3: ANALYSIS OF CAPABll.,ITIES 3.1 Evaluatio1i and Results Contained in this section are the results arid findings of the evaluations of all jurisdictions and locations that participated in the June 18, 2019 CCNPP.MS-l !)rill.. The Drill was conaucted;to demonstrate the ability of the OROs to respond to a potentially contaminated injured person associated with CCNPP.

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 infonnation on the Demonstration Criteria and the Extent-of-Play Agreement are found in AppendixC.

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 Criteri~ included:

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

3.a.1-The OROs issue appropriate do$imetry, 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 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 Qr identified inadequacy of organizational

  • performance in an exercise that oouid cause a determination that o:ffsite 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.

perfonnance 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 off-site response organizations* emergency plan/implementing procedures, rather than that of the ORO's perfonnance.

(N) Not Demonstrated: The tenn applied to the status of a REP 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-11

Unclassified Radiological 'Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant year or eight-year interval required iQ the FEMA RE~ Program Manual.

(M) Met: The status of a REP Evaluation Area Criterion indicating that the participating ORO demonsttated all demonstration criteria for the Ev&luation Area Criterion to the level required in the Extent-of-,Play Agreement with no findings assessed in the current exercise and no unresolved pi;ior fmdings, a e. -

T bl 31 S ummaryo r1 va ua fD *u E 1 ti on Date: 2019-June-l 9 Site: Calvert Cliffs

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(M) Met, (1) Level l Finding,(~) Level 2 Finding, (P)PlanningJssue

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  • Eint:lrgenpy 0perations Management
  • Mobilization *.

lal Facilities lbl Direction and Control

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lei Communications

~i Eauibment and Sunrilies to Sunnorl Ooerations M

M Protective Action. Decision Makin11 Worker Exposure Control 2ai ssessment and Pars for the Emernencv Event 2bl sion-making brocess and coordination for the General Public 2b2 disabilities & access/functional needs neonle 2cl Radiofoeical Assessment &Decision rriak:ine:'forihe In11:estion Pathwav

.2el Radiological Assessment &Decision makirili for Relcicatioh/Reentrv/Retum.

2dl

,P.rotecfive-Actioti Imolementation.

Implementation ofErriergencv.Worker Exn6sili'e Control 3al.,M M

Imolementation of KIP AD for Institutionalized Individuals/Public 3b2 Imolemeritation of P ADs for disabilities &access/furictional needs rieoole 3cl linnlementat"ion of PADS for Schools

. 3c2 Imnleinentation ofTraffic and Access Control 3d1.

Impediments to Evacuation 3d2 lmi>lementationofRelocatieh/Reentrv/Retum Decisions 3fl 1Field-Measiirements and:Anal:vsis RESERVED 4a1 Field Team Mana2ement 4a:2 Plume Phase Field Measurement Handline:; & Analvses 4a3 PostPlume Fhase Fieid Measurements & Saiiioling 4bl

'*Emernencv Noti.fication and*Publiclnformation I

i.

Activation of the Ptomot Alert &Notification Svstein. (ANS)

Sif RESERVED" 5a2 Acitivation'oftheBack~uo ANS

.5a3 Activation of the Exceotion Area ANS 5a4 Emeniencv Information & Instructions to tlie Public/Media 5bl S.uunorUJiileiations/Faciliti~

~

Monitorim?:, Decontamination, & ReRistration ofEvacriees 6al Monitoring/Decontamination ofEmentencv Workers and Eouioment

.6bl Temoorarv Care ofEvacuees 6cl Transport~tionn'reatment qfContaillihated Injured Individuals 6d1 M

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  • Unelasslfled
  • Radiological Emergency Pmpamlncss Program (REPP)

After Acdon Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 3.3 Criteria Evaluation Summaries 3.3.1 Evaluated Organizations In summary, the status of DHS/FEMA criteria for the Evaluated Organizations are as follows:

3.3.1.1 Saint Mary's County, MedStar Saint Mary's Hospital

a. Met: Le.I; 3.a.1; 6.dl
b. Level I 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 Saint Mary's County, Leonardtown Volunteer Rescue Squad
a. Met: Le.I; 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 13

After Aelon Report/Improvement Plan Cal.vert Cliffs Nuclear Power Plant SECTION 4: CONCLUSION*

. The State of Maryland, County, Local, and Private Sector organizations, except where noted in

. this report, demonstrated knowledge of th~ir radiological emergency response plans and procedures and they were successfully implemented during the CCNPP MS-1 Drill evaluated on June 18, 2019.

Three FEMA evaluators provided analyses of six evaluation criteria. These analyses resulted in a detennination of no Findings, no new Plan Issues, and no unresolved Plan Issues.

The Leonardtown Volunteer Rescue Squad (L VRS) successfully demonstrated that necessary equipment and supplies were available to support the treatment of an injured/contaminated patient. EMS perso~el prioritized life-saving medical practices over contamination concerns, implemented protective measures through the use of~ersonal Protective Equipment, regular glove changes, and control of cross contamination. Appropriate patient assessments were demonstrated as well as regular and ongoing communications with MedStar Saint Mary's Hospital.

Tiie MedStar Saint Mary's Hospital successfully demonstrated the mobilization of staff, staffing

. assignments, issue of dosimetry and monitoring equipment, and effective use of Personal

  • Protective Equipment during the exercise. The hospital staff effectively responded to
  • communications from Saint Mary's County Emergency Management Division and L VRS, initiated the set-up and management of a Radiation Emergency Area (REA), and accepted and successfully treated an injured/contaminated patient while administering life-saying medical attention over contamination concerns. In addition, the medical facility provided security control of the facility including the drop off'bay for the patient, separate exterior entrance to the REA, and overall protective measures for contamination control and prevention of cross contamination.

Based on the results of the Drill and a review of the off'site radiological emergency response plans and procedures submitted, FEMA Region ill has determined they are adequate (meet the planning and preparedness standards ofNURE0-0654/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 Drill.

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

14 f"",

Unclnssilied Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Pinn Colvert Cliffs Nuclenr Power Pinnt APPENDIX A: EVALUATORS AND TEAM LEADERS The following is the li~t ofEvalµat9rs andTe~m Leader for the Calvert Cliffs Nuclear Power Plant 2019 MS-1 Drill evaluated on June 18, 2019. The following constitutes the managfog staff for the Evaluation:

  • Thomas Scardino, DHS/FEMA, Regional Assistance Committee Chairman* *.
  • Nicholas Buis, DHS/FEMA, Technological Ha~ards Program Specialist, Lead Ev~lµator DATE: June 18, 2019 SITE: Calvert Cliffs Nuclear Power Plant LOCATION EVALUATOR AGENCY MedStar Saint Mary's Hospital Nicholas Buts

-. FEMARIII Leonardtown Volunteer Rescu.t:;, Squad Jennifer Greene FEMARIII 15

Unclasiiilied Radiological Emergency Preplirediiess Program (REPP}

After Action Report/Improvement Pla'1 Calveri Cliffs Nuclear Power Plant APPENDIX B: ACRONYMS AND ABBREVIATIONS.

Acronym Meaning CNPP

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. 1 s. uc ear,.ower lrtClfflNl P

Pl t an DHS Department ofHomeland Se9urity EMS Em_ergency Medical Services*

EMT

. EmergencyM_edicEil 'r¢chnician EPZ Emergency Planning Zone FE1'1A f'.edera(Em:ergency Management Agency IP Improvemeitt Plan LVRS Leonardtown Volunteer Rescue Squad MEMA rtviaprland Etn~!ge11cy M~nagement Agency Mij:.l MedicaJ S¢rvi~~s MSSM MedStar Saint Mary's Hospifal

  • NPf Nuclear Po:wei:: Plant NRC.

Nucleijr Re~latory Commissioq ORO Offsite Response Organization, RAC

~egional Assistance Committee REP Radi9kigical am¢rgen~y Pr!-W~e!'.ln~ss SMCEMI>

Saint Mary's County Emergeri9yManagement Division 16

APPENDIXC: E~E,NT":QF-PLAY AGREEMENT The Extent-of-Play Agreement was.extracted from the Exercise Plan, which was drafted by Maryland Emergency Management Agency and is included in this Report as an Appendix. The Extent-of-Play was negotiated and agreed upon by FEMA Region m, and Maryland Emergency Management Agency.

The Exercises Plan was created as an overall tool for facilitation ~d implementation of the*

CCNPP

  • MS-1 Drill and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program Exercise Methodology.

Criterion 1.e.1: Equipment, maps, displays, dosi~etry~ potassium iodide (Kl), and other supplies are sufficient to support emergency operations. (NUREG0654/FEMA-REP-l, R 7, JO; L7, 8, 9,* J.10.a.b.e; J.11, 12,* K.3.a; K.5.b)

INTENT This sub-element is derived from NUREG-0654 REP-I, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.

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 descn'bed.

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

KI: Responsible OROs must be 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 decline,d KI in advance.

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

17

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

Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry arid 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 teains (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 electri~al leakage at least annually and replaced when necessary. Civil Defense Victoteen 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 SA V.

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 SA V.

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. A label indicating such calibration niust be on each instrument or calibrated frequency can be verifi~ by other nieans. 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. ofr~4ings.that the meter should indicate_ when it is response-checked using a standard test source.

For Fi~ld Monitoring Teams (FMTs),Jhe jnstruments. musibe capable of measuring gamma.

exposure rates and detecting beta radiation. These instrum.1.mts must be capable of measuring a. *

  • range of activity and,exposure, including radiological prot~tion/ 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 c~eck source must be used to verify proper operational response for each low-range radiation measurement instrument (less than lR/hr.) and for a high-range instruments when available. If a source is not :

available fQr a high-riuige instrument, *a: procedure must exist to operationally test the instruinent before entering an area where only a high-range instrument can make useful readings.

In areas where portal monitors are used, th~ OROs must set up and _operationally check the monitor(s), The m,onitor(s) m,ust confirm 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.

Mutual Aid Resources: If the incoming resources arriving 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 18

REP Plan, they are subject to the planning process and standards, as well as the guiJlce 9f this Manual.

All activities must be based on the ORO' s plans/procedures and completed at they w9uld be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement STATE OF MARYLAND EXTENT OF PLAY All activities will be based on the*ORO's plans and procedures and completed as they*would be*

in an actual emergency, unless noted above or otherwise indicated in this extent of play.

  • agreement. St Macy's County emergency workers may substitute electronic personnel dosimetry for the self-reading dosimeters. KI will *not be issued to emergency workers for a contaminated injured response. Calibration and electrical leakage testing of dosimetry will be evaluated with.
  • the State of Maryland Annual Letter.of Certification.

LOCATIONS EVALUATED ',,

Med.Star St Mary's Hospital

  • Leonardtown Volunteer Rescue Squad St Mary's County Health Department OUTSTANDING ISSUES None Criterion 3.a.1: The OROs issue appropriate dosimetry, Kl, and procedures, and manage radiological exposure to. emergency workers. in accordance*with the plans/procedures. Emergency workers *.

periodically and at.th_e 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 Kl to emergency workers. (NUREG-0654/FEMA.-REP-l. K.3.,;i. b; K.4)

INTENT.

This Sub-element is derived from NUREG-0654/FBMA-REP-l; which requires that OROs have the '*

  • capability to provide for the following: distn"butim1t use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading do~etry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing.a*,.
  • decision chain or authorization procedure for emergency wor~ers to incur radiation expQsures in excess of the Protective Action Guides (P AGs), and the capability to provide KI for emergency woncers, always

'3Plying the "as low as is reasonably achievable" principle as appropriate....

, EXTENTOFPLAY Assessment of this Demonstration Criterion may be.accomplished during a full-spale~ functional 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 c;m:aergency 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.. readingdosimetry 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 ofTEDE and maximum exposure.

limits, for those emergency workers involved in lifesaving activities, contained in the ORO's *

  • plans/procedures.

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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 withjust-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers. must demonstrate procedures to monitor and record dosimeter [el\\dings 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 reache4 The emergency worker must report accumulated exposures during the exercise as indicated in the plans/procedures. OROs must demons~te the actions descn"bed in the plans/procedures by detennining 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 authoriz.ations 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 coworkers) in providing responses.

Although it is desirable for all emergency work~ to ~<:h have ~ direct-reading dosimeter, there may be situations where team members will be ll1 close proximity to ea~h pther during the entire mission. In such cases, adequate control of exposure can be achieved for all team iiiembers 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 ha'\\'e individual direct-reading dosimeters odhey 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 reenter 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 lmtjts does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response.

'1 OROs must demo.nstrate.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. T:his, can be accomplish~ by an interview with the evaluator.

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

State of Maryland Extent of Play, All activities will be bas.ed on the ORO's plans and procedures and completed as they would be in an actual emergency,.unless noted above or otherwise indicated in the extent of piay agreement. Certain portions of the FEMA extent of play will not be evaluated in the medical drill scenario.

LOCATIONS EVALUATED

  • St Mary's County Environinenial Health MedStar St Mary's Hospital Leonardtown Volunteer Rescue Squad OUTSTANDING ISSUES 20

\\;

~. I

.t>>-*

None 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

  • contami'}ated injured individuals. (NUREG-0654/FEM.A.~REP;_l, F.2; H.10,* K.S.a, b; L.l, 4)

INTENT This Sub~element is derived from,NURE0-065/FEMA-REP-l, whiph'requires that ORC>s have..

the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

  • EXTENT OF PLAY Assessment ofthi!!l*Demonstration Criterion may be*accomplished during*a biennial exercise, an actual event, or drills.,FEMA has determined thaf these *capabilities have been enhanced and consisten~y demonstrated as' adequate; therefore; offsite medical services drills need only be evaluated biennially. FEMA will, at the ~uest.of the ORO, continue to evaluate the drills on mi annual basis. All hospitals. listed in the pli.µi as.medical services hospitals must be' evaluated, with a transportation provider, every 2. years. Addition;s.1 transportation providers will be rotated through the drills in the 8-year exercise cycle. For 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.

r, An ambulan~e must be used for response~ the victinJ. However, to avoid taldng 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 demoJJStrate, up to.

the point of th.e 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 of interests of the community.

Nonnal 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 drills.* Thi_s 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 decontamiriat~ if required, or whom to contact for such inform~tion.

Monitoring of the victim may be performed before transport or enroute or may be deferred to the medical facility. Contaminated injured individuals transported to medical fa,cilities are monitored as soon as possible to assure that evecyone (ambulance and medical facility) is ~ware ~f 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 21

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 descnbed 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 actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

STATE OF MARYLAND'EXTENT OF PLAY All activities associated with this criterion will be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement. Radiological monitoring of the victim will not be the responsibility of the responding rescue squad.

LOCATIONS EVALUATED Leonardtown Volunteer Rescue Squad MedStar St Mary's Hosp~tal OUTSTANDING ISSUES None

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