ML19206A087

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Pennsylvania Wellspan York Hospital After Action Report/Improvement Plan, Drill Date - May 29, 2019
ML19206A087
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 07/08/2019
From:
US Dept of Homeland Security, Region III
To:
Office of Nuclear Security and Incident Response
Shared Package
ML19206A095 List:
References
Download: ML19206A087 (24)


Text

Peach Bottom Atomic Power Station Pennsylvania Wel1Span York Hospital After Action Report/Improvement Plan

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UnclaMified Radiological Emergency Prepmncss Program (REPP)

After Action ReportJimprovement Plan Peaeb Bottom Nuelesr Power Station Peach Bottom Atomic Power Station (PBAPS)

Medical Services Drill After Action Report/Improvement Plan

, Published Date: July 08, 2019 Contents EXEC'UTIVE

SUMMARY

          • .*....*.******.....****.** ,.,,11e ************ o ************************************************************* S SECTION 1: EXERCISE OVERVIEW ......................... ~ ............................................................. 6 1.1 Drill Details ............................................................................................................................ 6 1.2 Planning Team Leadership ..................~******************************************************************************** 6 1.3 Participating Organim.tions.*........ lJ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 SECTION 2: DESIGN SUMM.AR.Y****..***..**.....................*.........******..*.....**.**. ~ ***.......**......*...**.***.. 8 2.1 Purpose and Design *.....*.. ~*.: .....~~ ..*..~ .. ~ ....*............*......*.~-~ ....**...*.........**...........*.......*............... 8 2.2 Objectives, Capabilities and Activities.....,............................................................................ 9 2.3 Scenario Summaey ........................,............... ~ .......................................................................... 9 SECTION 3: ANALYSIS OF CAPABil,ITIES........................................................................... 10 3.1 Evalllation and ResulU ........................................................................................................ 10 3.2 Summary Results of Evaluation ........................................................................................ 10 3.3 Criteria Evaluation Summaries ......................................................................................... 11 3.3.1 Private 0.-ganiza.tions ................ 0 ***************************************************************************** 11 SECTION 4: CONCL-USION ............................................... 111 * * * (I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 APPENDIX A: EVALUATORS AND TEAM LEADERS .......................................................... 14
  • APPENDIX B: ACRONYMS AND ABBREVIATIONS ........*.........*.* ;**............*..........*.**.......... 15 APPENDIX C: EXTENT-OF-PLAY AGREEMENT ................................................................. 16 3

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. * .. . . Unclassified . . .

Radicfogical Einergem:yl'reparedness Progrmil *(REPP)

After.Action R~pon/lmproveineiit ~ian Peach Bottom Nuclear Power Station*

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After Action Report/Improvement Plan Peach.Bottom Nuclear Power Station EXECUTIVE

SUMMARY

On May 29, 2019, a Medical Services (MS-I) Drill was conducted for the I 0-mile Plume Exposure Pathway, Emergency Planning Zone {EPZ) around the Peach Bottom Atomic Power Station (PBAPS) by the Department of Homeland Security (OHS), Federal Emergency

  • Management Agency (FEMA) Region III. The most recent prior MS-1 Drill for this site was conducted on May 26, 2017.
  • The purpose of the PBAPS MS-I Dr.ill was to assess the State and local offsite response organizations' preparedness in responding to a radiologicai 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, York County Emergency Management Agency, We11Span York Hospital, the Southern York County Emergency Medical Service, and the Delta Cardiff Volunteer Fire Company, 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- I 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.

Section I 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 Purpose 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 ofEvaluation; and Criteria Evaluation Summary. Information on the demonstration for each jurisdiction or functional entity evaluated is presented in a jurisdiction-based, issue-only fonnat.

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

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Unclassified *

. *Rndiologicai

~incrgcncy ~rcpnrcih1cs~*pi~gram

. ,, . . ' . ,. - . *,.. . . . . (REPP)*.

AflcrA~ti!)n Rcpo11/lmprov~ni~nt Pinn .. )'cai:i1 Bqttiim Nudeni: Poi,:er.Station SECTION!: EXERCISE OVERVIEW 1.1. Drill Details Di:ill Name **. . .* . * . . . *. . . . . . .. . . .

Well Sp.an York Hospital 2019 Me9ical Seivices Drill**. *

  • Type of Drill .

. Medicai Services ..

. . DriHDate* .

  • *.. M.ay 2.9, 2019
  • Program . . . . .

bepartmei1{ofHorri~Iand Security/FEM A lladi6Iogi~al' Em.ergefrcy Prepifred11ess Prograrii ..

.*.* SceiiarioType** .*.... :*'. ' .*. *..* *.' .*.' .*. ******.

.**. Radioactive C:onta1hinated/h1jured.PerS0n *.

  • 1~2** i>ianningTeain Leadership . . .*
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  • Jei1111ferGree11e .. ** **.. ** * * * .. * * *. :.* ** * . *.* *

' *.* Technological Haz~rds Prograni Specialist ....

..*Federal Emergency Managen1erit Agericy .. * .

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6.15 Chestnut Street ...

Philadeiphia; PA 19*106 (102ysn.-s148 . . . . . .

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. *Lmfrin Flemi'ng . * . * . . . . *. * . . . . * . *

. .** *Con11T16n,veahh of Peimsylvania Plai1hei*/Lead Controller

    • . * .. Bureau of TechnolC>gicat Haz:ards *** . . . . . .
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  • PA E.mergency Jvianageinent Ag~ncy. *.
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  • Eme~g~1icy Pi*epai;e.di1es'sSpecialist.
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200 E~c:Jo,~ Way : * . .

Kerim~tt Square, PA, I 9348. *.

(570)244--7954 *.* . . * .....

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Und!l!slfieif Radiological Emergency Preparedness Prograni (REPP)

After Aedon Reportllmprovemen* Plan Peach Bottom N.idear Power Station

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1.3 Participating Organizations Agencies and organizations of the followingjurisdictions participated in the PQ~J>S 20119. 1 i

Medical Services Drill: * = * '

State Jurisdictions . _ . ,* ,;

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Risk Jurisdictions '

, f Private Sector Organizations
  • Wel1Span York Hospital
  • Southern York Emergency Medical Service
  • . Delta Cardiff Volunteer Fire Company.*. i. '. ~ ~ i '

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After Action Report/Improvement Plan Undasslfled Rediological Emergency~- Program (REPP)

Peach Bottom Nuclear Power Station SECTION 2: DESIGN

SUMMARY

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  • 2.1 Purpose and Design .. ..

On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to asBUme the:lead,respoQsibility for alJ,off-site radio.logictll planning and ~sponse.

FEMA',s aqtiviti~s we~ conducted pu_rsu~t to 44 Code of Federal Regulations (CFR).Parts 350, 3S I and 352*. These regub,tions are. a lcey elemt ln ~e Radiological .Emergency Preparedness (REP) Program that w~ established fol.loyving the Three Mile:Island accident in March 1979.

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44 CFR 350 establishes the policies and procedures for FEMA's initial and continued approval of .

State and local governments' radiological emergency planning and preparedness for commercial

. nuclear power plant,s. This ,spprovaf: i~ c_qntingent, jn, pa~ on State and local government participation .in Jo~nt exercises wi~ Jic~n~*. FEMA' s responsibiliti~s in radiological emergency planning for fi_xed 11ucl~facilities, i11clu_de, ~~ following: , . . :;:. , * . . *

  • A. Taking the lead in offsite emergency planning and in the review and .evaluation of radiological emergency respo~~,p~ans ~d_procedures.developed. by State governments; * * * * * * ** ** * * ..

and local B. Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of me plans and procedures conducted by State and local govenunents; . . * * * **

  • C. *R~qdirig to requests by theJJ .$. Nuclear Regulat()ry Commission (NRC) pursuant to the Memorandum ofUnderstandihg between 'the NRC arid FEMA dated December 7, 2015 (Federat'ilegister,.Vol. 81~ No;57~ Marth24~ 2016) and;  :, . * .

D. Coordinating the actiyities of the foJlowing Federal agencies with responsi~ilities in the ra~iologfoal CIJl~rgency 'p)anni1:1g' process:.

-.u;s. Department of Commerce* *** ,

, - U.S. Nuclear RegUlatory c;:ommission ,

. - U.S: Environp1.ent1il Protection.Agency .

- U.S. Pepartrnent of Energy** ' * * * **

  • - U.S. Departrnent of Health and Human Services

-. U.S. Department of Transportation

-. U:S'. Department of Agriculture. .

- U~S. Department of the Interior ..

  • _- . U.S.

F9od and Drug Admi~istration Representatives of these agencies serve on the Region III Regional Assistance Committee (RAC),

which is chaired by FEMA. A I,udiological Emergency Preparedness MS-1 Drill was conducted on May 29, 2019, to assess the capabilities of State and local emergency preparedness organizations in implementing their radiological emergency response plans *and procedures to protect 'the public health and 'safety* during a* radiological emergency involv~ng PBAPS.

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

~niergenty involving*a contaminated injured individual. ;

The Drill was designed to demonstrate and evaluate the responder's knowledge of patient and 8

  • Undasslfled Radiological Emergency PrcpllR!lness Prog,am (REPP)

After Action Report/Improvement Plan Peaeb Bottom Nndear Power Station responder personal protectiv.e measures, equipment pr.eparation and employment, and decontamination procedures. All activities were demonstrated in accordance with the participants' plans and procedures as they would be perfonned in an actual emergency, except as agreed to in

. the Exercise Plan and Extent-of-Play (EOP) Agreement. * '** * :

  • The findings presented in this report are based .on the evahiations of the *Federal evaluator team, with final determinations made by the FEMA Region Ill Regional Assistance Committee (RAC)
  • Chairperson and approved by FEMA Headquarters. These reports*are provided.to the Nuclear .

Regul~tory Commission (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. : .i ' .*: .. ,.

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The criteria utilized in the FEMA evaluation process ate contained in the foilowing: :

  • NUREG-0654/FEMA-REP-l, Rev: I, Criteriaftjr]~repar~tion ~d Evaltiation of Radiological Emergency Response Plans and'Preparedness in Support ()f Nuclear Power Plants," November 1980; * ** ,::, .. *
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2.2 Objectives, Capabilities and Activities . .

The PBAPS MS-I D~ll evaluated by FEMA was. designed to ~emonstrate that the ORO can .

transport, transfer, moni~or, decontaminate and treat a.contaminated/injured person*while minimizing 'any cross contamination during a radiological emergency. The demonstra~on included the ability to: . . . . . .* . . . a *

  • A. Respond to a radiation medical emergency following York County Emergency. ' _

Management Agency, We11Span York Hospital and die Southern, Y.prk Airtbulance Emergency Medi~l Services procedures. . * .. ' ** * . : ., * . .

B. Monitor for radiation contamination and uptake, and to vali<l:ate persons providing these services are adequately prepared to handle *contaminated* individu~ls. . ' *

  • C. Conduct timely and acc~rate communications between the hospital and offsite response

~~ . . .

D. Exhibit correct priorities and appropriate techniques in Emergency Medical Services (EMS); transportation of patients; and pre-hospital and ho!iJ>ital .emergency care patients of contaminated with radiation. ** * * * **

E. Demonstrate inter-agency cooperation between the Southern York Emergency Medical

. Service, and WellSpan York Hospital. *

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2.3 Scenario Summary . . . .. . .. ,. ... , . . , .:. . . .

The scenario began with a Site Area Emergen.cy Clas~ific~~fun.Level (E<::Lj at the P~ach Bottom Atomic Power Station (PBAPS) at 0835. . . . . *. . . . *. . .. , . .. . .. .

At 0845, a follow-on call was rec~ived at WeUSpan Y~rk Ho~pital from York'co~nty 91'1. C~i:iter of an escalation to General Emergency ECL at PBAPS~ and to inform then;i th3:t the. SoutQenj York Emergency Medical Service was preparing to transport a potentially contaminated injure~ patient to their site.

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Unclassified ,-.

After Action Report/Improvement Plan Peach Bottom Nuclear Power Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the May 29, 2019 PBAPS MS-1 DriU. The Drill was conducted to demonstrate the ability of the OROs to respond to a potentially contaminated injured person.

Each jurisdiction and :functional entity were evaluated on the basis of their 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 Demonstraiion Criteria included:

1.e.1- Equipment, m.aps, 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 e.ach 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: .

  • (L 1) Level 1 Finding: An observ~ or identified inadequacy of orgariizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures cari 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.
  • (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 off-site response organizations' emergency plan/implementing procedures, rather than that of the ORO's performance.*
  • (N) Not Demonstrated: The term applied to the status of a REP Evaluation Area Criterioi:i indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area Criterion, as required in the Extent-of-Play Agreement or at the two-year or eight-year interval required in the FEMA REP Program Manual.
  • (M) Met: The status of a REP Evaluation Area Criterion indicating that the participating 10

Unclassified Radiological Emergency Pi~paredness Program{REPP)

After Action Report/Improvement Plan Peach Bottom Nuclear PowerSt11tion ORO demonstrated all demonstration crit~ria for the Evaluation Area Criterion to the level required in the Extent-of-Play Agreem~nt with no findings assc;:ssed in the current exercise and no unresolved prior ~findings. * * *  :

Table 3.1 ~ Summary of Drill Eval_uation

  • Date: 2019-Ml;\y.:.29 Site:'. PBAPS (M) Met, (I.) Level l Finding, (2) Level 2 Finding,'(P) Plannit1g Issue.

. Mobilization ' ** fal

Facilities

  • lbl' Direction and Control 'Jcl Communications ldl Equipment and Supplies to SunnorfQperations .Jel. .. M M Emergencv Worker Exoosure Control ,,

Accident Assessment and Pars f6f *the Erilei"genov EVent ** 2bl PAD decision-makimi nrocess arid coordination for the General Puolic' 2b2 PADs for disabilities & access/functional needs oeoole' *

  • 2c1 olol!;~cal Assessment &Dec!s!on mak!nl!: for the ln~~stion ~athwaV * . * . , 2el
  • olomcal Assessment & Dec1s1ofi makmg for.Relocation/Reentrv/Retum. 2dl. - ., .. -,~,.

lmolementation ofEmer1?ericv Worker Exoosure Control 3al ,, M .M Imolementation ofKI PAD for Institutionalized Individuals!Public 3b2 Imolementation of PADs for disabilities & access/functional needs oeoole 3cl Implementation of PADS for Schools .. " 'Jc2 Imolementation of Traffic and Access Control *-  ; ,* 3d]

Impediments to Evacuation 3d2, Imp lementation of Relocation/Reentry/Return Decisions .,

3 . , .. ,,

'FieldMeasurements arid Amilvsis RESERVED 4a1 Field Team Management 4a2 Plume Phase Field Measurement, Handling, & Analyses 4a3 Post Plume Phase Field Measurements & Samo line: .  : 4b)

Activation of the Prompt Alert & Notification Svstem (ANS) Sal A

RESERVED 5a2 Activation of the Back-uo ANS 5a3 Activation of the Exceotion Area ANS 5a4 Emen?encv Information & Instructions to the Public/Media

  • Sbl
S11nn0rtOtierationslFacrHties : ... .. .. . .. - . i ** .. '

Monitorina. Decontamination, & Ree:istiation ofEvacuees ,, 6al Monitoring/Decontamination of Emergency Workers and Eouioment 6bl Temporarv Care of Evacuees 6cl Transportation/freatment ofColjtaminated Injured Inpividuals 6d] *.M M 3.3. Criteria Evaluation Summaries 3.3.1 Private Organizations 11

Uaelasslficd ,- 41 Radiological

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Emergencx:

l'reparedness. Program (REPP)

After Ac~ Repar,llmprovem,ent Plan Peach Bottom Nuclear Power Station

. In summary, the status <>f DHS/FEMA criteria follows:

for *the Private $ector Organizations are as 3.3.1.1 We11Span York Hospital

a. i Met: 1.e.1; 3.a.l; 6.d.l;.
  • b~ *'.Level J. Findings: NONE C.' Level 2 Findings: NONff
  • i * * *, , .
d. Plan Issues: NONE
e. Prior Issues - Resolved: NONE
f. **.Prior Issues ... Unresolved:*NONE *, *

.,; . ( ,*

3.3.1.2 Southern York Emergency Medical Service '

a; 'Met:l.e.1; 3.a.1;6.d~l'. ;,. '.

b. LeveJ:1 Findings: NONE *,.,
  • c.: Level 2 Findings: NONE .:,* ..  ;,: **,1 d.r Plan Issues:,NONE *. * * >*, *, .*
e. ,Prior Issues - Resolved:.NONE :
  • ' f.
  • Prior'lssues-Uriresolved: NONE

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,G;', UaclassUJed . . . ..

Radiologieal Emergency Preparedness Program (REPP)

After Action Report/Improvement PJ1n Peach Bottom Nuclear Power Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and private sector organizatioµs, except where noted in this report, demonstrated knowledge of their radiological emergency'.response plans~anc;I ptocedures and they were successfully implemented during the PBAPS MS-4 Drill. evaluated-on May 29, 2019.

Two FEMA evaluators provided analyses of six evaluation *criteria. These analyses resulted in a determination of no Findin~, no new Plan Issues, and no unresolved Plan Issues.

' } ,. : ' ' ',i The Southern York Emergency Medical Service Paramedics successfully demonstrated that necessary equipment and supplies were available to support the :treatmentof an , . . ,

injured/contaminated patient, and 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 Wel1Sp~*Yo*.1Hospital Wel1Span York 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 the Southern York Emergency Medical Service, initiated the set-up and management of a Radiation Emergency Area, and accepted and successfully treated an injured/contaminated patient while administering life-saving 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 DriJI and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region Ill has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-l, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this Drill.

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

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Unclassified Radiological Emergency Preparedness Program (REPP)

After Action Report/Improvement Plan . Pench Bottom Nuclcnr Power Station APPENDIX A:* EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leaders for the PBAPS 2019 MS-I Drill evaluated 9n May 29, 2019. The following constitutes rhe managing staff for the Evaluation:

  • Thomas Scardino, DHS/FEMA, Regional Assistance Committee Chairman
  • Jennifer Greene, DHS/FEMA, Emergency Management Specialist, Lead Evaluator DATE: May 29, 2019 SITE: PBAPS

... .. ** w - --* ... .. ... .. -  ;* ,. ~-.- - -- .. ,. -~ - *-* . ..

LOCATION ..

EVALUATOR AGE.NCY WeIISpan York Hospital

  • Christopher Nemcheck FEMA RIII Southern York EMS Jennifer Greene FpMA RIil 14

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Unclassified Radiological Ell'!erg.:ncy ?£eparedne~ Program (REPP)

Affer ActiQD Repo!"f/improvemeut Plan reach B.ott~m Nu~lear Power s*tation APPENDIX:B: ACIRONYl\JS,AND ABBREVIATI()NS Acronvm Meaning AAR After Action Report ,.  :

ALAR.A As Lbw As* Reasott~hlvAchieva.hle . "*;

ALC Annual Letter- of Certification ANS Alert and Notification System -*

BRP Bureau,of Radiatt()ri Ptotection "

DHS Department ofHomeland-Security DRD Direct Re~dinh;* J)osimeier

  • EMS Emergency Medical Servfoes EOP . Extent of Plav EPZ Emer~ency Rla11I11nil;,,ZQn~,. "

FEMA Federal EmergencyJNfanagementAgency.

-FMT Field Monitoring Team .

GE. Generai Emergency * '

IP ImprovementPlan, Kl Pot_assiurh Iodide MS--t' Metlica] Services -

NRC NuclearReirulatorv Commission ORO Offsite Response 'Organization . ,.

PBAPS

-,Peach Bottom Atomic* Power:Station '

PEMA Pennsylvania Emergency Management A_gen:cy PPE Personal Pr9tective Eaµioment PRD Permanent Record *Di;>simeter RAC -Regional Assistance Committee REA,. Radiati.on Emergency Area REP* Radiological Emergency Preparedn.ess RERP Radiological Emergency Preparedness Program SAE Site Area E1nergency SOP stindard :boetatina PrQcedure ,,

SAV Staff Assistance Visit WGSH Wellspan,YorkBospital 1!>

Unelllssirml Radiological Emagency Prepa:n:dncss Program (REPP)

After,Accton RePortllmprovemeat Plan Peacb BoHom Naeleer Power Station

,APPENDIX C: EXTENT-OF-PLAY AGREEMENT The Extent-of-Play Agreement was extracted from the Exercise Plan, which was drafted by Pennsylvania E,mergency Management Agency, and is included in this report as an Appendix. The Extent-of-Play was negotiated and agreed upon by FBMA Regionr-III; and Pennsylvania Emergency:ManagementAgency: '

The Exercise Plan was created as an overall tool for facilitation and implementation of the PBAPS MS~ 1 JJrill and to integrate:tne concepts and policies of.the Homeland Security* Exercise Evaluatio*n'Prograin.with the:Radiologicld Emergency Preparedness Program Exercise

  • Methodology. *' ** * :,*; . *
  • PEACH BOTTOM*ATOMIC POWER STATION: ,. *
  • * . We11Spail York Hospital :' -~ *..

'**,' \

'May729; 2019 **.

  • *, * * * *, * * * * * *  ;,:' Methothif.Operatioa*., * , * * *. *
1. The power*statJohand its personnel will nbt'play an active role in the facilitation of this
      • exercise~ *:1n_e plant's simulated events, radiation releases,*and emergency classifications will' be injected by off-sit¢controllers*. A pre-approved scenario will~ used; , ..

~d* the* Bureau Radiation Protection (BRP) wiU not be activated as part of this exercise. 'The Exercise Coordinator will provide pre-exercise coordination and observe exercise activities. : .

3. Exelon Energy will participate* as a Controller irt*this exercise~
4. York County Office of Emergency Management will provide pre-exercise coordination, participate in this exercise as _the county communications coordinator and observe exercise activities
s. Controllers will be'supplied by PEMA/Exelon. Controllers are not pJayers.and will
  • provide injects and information to initiate and stimulate exercise play'by providing radiological readings during the monitoring of personnel. Live radioactive sources will only be used to perfonn operational checks of radiological monitoring instruments.

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6. PEMA'staffarld 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 witli staff membe,;s 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.

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Unelsssllied

  • Radiologi'181 Emergency Prepam!ness Program (REPP)

After Ac:Clon Report/Improvement Plan l'eacb Bottom Nuelear Power Stallon

7. . Department of Homeland Security (DHS) Federal.Emergency Mana~ent;Agency (FEMA), Radiological Emergency Preparedness Program (REPP) Evaluators: FEMA Evaluators will be present at desi~ demonstratio.n locations.
8. Exercise activitie~*are schedu1¢ to co~menc~ on or about 0800, lvJ1J.y.29, 201~**and . ,,: .

continue until the participants have completed the exercise. objectives.and:demonstrated the Exercise Evaluation Criteria.

9. Participants and agencies,will Stand-Down wher:t the C::ontrollers have coµfirmed with the.

evaluators that allevaluation criteria-have been dem<mstrated and when the State and ,

  • County Observers are satisfied that the Objectives have been met. * * *'
  • 1o. An emergency *plan is drafted to address the*generally* expected conditions of an *
  • emergency. Not everything in the emergen(?y,pian may be applicabief.or a given scenario.

The main purpose of an emergency plan js to asse~ble sufficient expertise and officials so as to properly react to the events as they ooo,ur..Thes.esponders 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 modifi~on of th~, plan, bqt not class!fied as a.

negative incident..Furthennqre, if, by following the plan there is a failure to protectthe public health and safety, it should be noted so that. the plan* can be modified,. and~~

appropriate negative assessment corrected. *

11. During the exercise any activity.that is not satisfactorily,demonsi,ated 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. Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. It is. permissible,to ex~end the demonstratiop windo:w, within reason, to accommodate the re-demonstration. Activities corrected from a re:.

demonstration will be so noted.

Obiectives.

A. Demonstrate the ability to respond to a radiation medicaJ emergency following:the procedures of York County Office of Emergency Management, Southeni York County EMS, and Wel1Span York Hospital.

8. Demonstrate timely and accurate c~mmunicatio~s be~een the* h~pital arid offsite response agencies. (Telephones will* be used .in,lieu of ra~ios whenevei: possible to limit the*

potential misintetpretation oftheexercise as .an a~tµal e-vent.) ,.' . ; . ".

C. Demonstrate*correct priorities and appropriate techniques in EMS, tr!ln~portation of

patients and pre-hospital and hospital emergency care ofradioactiveJy.CC>ntaminated patients.

17

Undasslfled Radiological E;mergency Preparedmlss Program (REPP)

After Adion Rcpon/lmprovement Plan Peai:h Botmm Nuclear Power Stadoa D. Demonstrate inter-agency, cooperation between #}e Ambulance Company/ EMS and the

  • Hospital.

WELLSPAN YORK HOSPITAL MEDICAL SERVICES Ep;RCISE

~ .... ~* .. ', Extent of Play Agreement Evaluation A"'8 l~mergeney Operatjons ~page'8~nt. . ..

Sub-element l.e-Bquipment and Supplies to Support Operations* .

INTENT , . . . .;, 1 .*.

This sub-element derives from NU~G~6,4{Fl;~~RE,P-l, which requi~s*that OROs have emergency equipment and supplies adequate to support the emergency resp.onse.

Cr,iterlon 1-.e.1:. Equipment, ,ma;,;, di;;itzys, m,onitoring instruments:*~~~',;,e~, potassium iodide (KIJ_and other supplies are sufficient tq §upport e,i,ergeT#cy operations. .* . * *

(NUREG-:06541 FEMA-REP-1, H.7,}0;.L7, 8,,'); JdO.a, b, c;J.11.}2; K.3.a,* K.5.b)

,'  ;: ' \ ' :~ ' .

AssessmentlE~tent-of-Play .. *; ** . i *.* ,: . . .

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

A particular*facility's,equipment m1d.sµpplies must be suffic~ent and ~nsistent 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 w.ith the ~signed operatioµal role*. At loc1:1.tions where traffic and access.control personnel are,deployed, appropriate. equiprµent (e.g., vehicles, barriers, lra,ffic cone~ and signs) must be. available, or their availability de.scribed~, *
  • Specific equipn)ent and supplies_thai must be demons~ted under this criterion include KI inventories, dosimetry. and moni~ring.equipment, ~follows:. .

.,r**

KI: Responsible OROs ~ust demonstrate the capabi1ity to maintain inventories' of KI sufficient for use by: (1) emergency workers; (2~ instituti9nalized individuals, as indiqated 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 mttSt demonstrate provisio~s to *e. KI available to specialized response teams (e.g., civil support team, Special WeapQns and Tactics '.fe1mu1, LU'ban searc;h ~d rescue, bomb squads, HAZMAT, or other ancillary groups).11s identifi~.ig. plans./ proced1:1re~. The plans/ procedures must include the fonns to be used* for documenting eme,rgency worker inge.stion of K.I, as wc,11 as, a mechanism for identifying emergency.work~rs that.l,l~ye declin~ KI in,advan~. *

, i **, ** ..

  • r.: .. ,' .

ORO quantities of posim~try and KI,~vailable and s~rage locations(s) will be confinned by physicaHnspection.at the storage location(s) or through documentation of current inventory submitted during;the ex.ercise,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 18

. . Undasslfied

. Radiological Emergency l'repalmllll$S Program (REPP)

After Action Repon/lmprovement Plan . *Peach Bottom Nuclear Power Station packs. As an alternative~* the ORO nuiy produce. a letter from a certified private or state laboratory indicating that the KI supply remains poteni, in accordance with U.S. Pharmacopoeia*standards.

Dosimetry: Sufficient quantities of appropriate 'direct;.reading and permanent-recortl':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*rililst demonstrate provisions to* make dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue,'bombsquads,;HAZMAT~ otother ahcillary,groups) as identified in plans/ procedures. * ; ** * ~. *,o.: <' * * :,*.

  • i * *, ,
  • Appropriate direct-reading dosimt:try must allow an individual(s) to read the administrative *..

reporting limits and* maximum exposure limits contairied'in th~ ORO's plans/ procedures *. ;. ,.-

.... , r,/ *
  • _._! ( ; >.:*., :* *~
  • Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The oosimeters must be *inspected for electrical leakage at least'.annuallyand replaced'when necessary.

Civil Defense Victoreen Model 138s (CDV-138s) (0;.200 mR);dtie to-their documented history of, electrical Ieakage-probl~s, must be inspecte<Mor electricai leakage at least-quarterly and replaced-when necessary. This leakage testing will be verified during the exercise, through documentation submitted in the (Annual Letter of Certification (ALC) and/or tl)rough a Staff*Assistance Visit , :

(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 ttiustbe inspected~ inventonedrand operationally' '.

checked before each use. Instruments must be calibrated in accordance .with the tnanufacturer~s * * *;

recommendations. Unmodified CDV-700 series instruments and other instruments *without --1 * * , ** a.

manufacturer's recommendation must be calibrated annually. Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modificatlon*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 rarig~*of the readings. The range of readings documentation specifies the acceptable range of readirigs"that the meter should indicate whefi,it is
  • response-checked usin~ a standard tesfsource. * :- **'
  • For Field Monitoring Teams (FMTs), the instruments must be capable 6f'-measuring gamma * ,

exposure rates and det~ting beta radiaiion.: These instruments must-bcfcapable of measuring a range of activity and exposure,* inQluding radiological protection / exposure control* ofteam.

members and detection of-activity on air sample collection meclia, 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 e_ach low-range radiation m~urement instrument (less than IR/hr) and for high-range*instn.unents when available. Ira*sourcEds not available for a high-range instrument, a procedure'must exist to operationally test the instrument*'*:

before entering an area where only a high~range instrument can make useful readings. * , .:, .

  • 19

Unclassified Radiological Emergency Preparedness Program (REPP)

After Aclioli Report/Jmpnn'.enient Pllin Peach Bottom Nuclear Power Station 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 Standardfor 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. .Ifan 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 l procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Exter;it-of-Play Agreement.

State Negotiated Extent ofPlay:,*~ **. , .... , .

In accordance with PEMA standard operating procedures ambulance crews operating outside the JO-mile Emergency Planning Zone are.,considered*'Category C" emer.gencyworkers; therefore, they are only required to implementprotective.measures consistent with protection against blood-bornepathogens; i.e., long sleeved garments, trousers, impermeable gloves, and surgical masks.

Ambulance "Category C" emergency workers are,not issued dosimetry or Kl unless they are tasked to enter the JO-mile EPZ. At that time, the county will issue what is needed:

Hospital personnel are also considered '!Category. C" emergency workers and will conform to PEMA Standard Operating Procedure (SOP) protective measures at minimum. Direct Reading Dosimeters'may be*issuedindividually;.however, an Area Kit will be established in the Radiation Emergency Area (REA). Individu(ll PRDs will be issued by the hospital. Radiological Survey Instruments are calibrated per *manufactures recommendations.

Evaluation Area 3 ;.;. Protective Action Implementation Sub-element 3~a -Implementation ofEmergency Worker Exposure Control INTENT This Sub-element is *derived from NUREG-0654 / FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading*dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dost: record for each emergency.worker;_establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess ofthe PAGs; and the capability to provide KI for emergency workers, *always applying .the as low as is reasonably achievable (ALARA) principle as appropriate.* ,

  • Criterion 3.a.1: The OROs issue appropriate dosimetry, Kl, and procedures, and manage radiological exposure to emergency workers in accordance with the plans I procedures:

Emerge.ncy workers periodically and at the end ofeach mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping ofthe administration ofKl to emergencyworkers. (NUREG-0654 I FEMA-REP-1, 20

Unclasslfied Radiological Emcrgcnc:y Prcpndness Progmm (REPP)

After Action Report/Improvement Plan .Peaeh Bottom Nuclear Power Station 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 pr~vide:emerge~cy workers.(includingsupplemental ..

resources) with the appropriate direct-reading and pennanent l'.ecord dosimetry;, dosimeter .

chargers, Kl, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry :that allows anJndividual(s) to._read the administrative reporting limits that are pre-established at aJevel low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in th~ OR0 S plans / procedure~. * .:

  • 4 Each emergency worker *must have basic knowledge of-radiation exposure* limi~ as,.~pecified .in.

the ORO's plans / procedures.. If supplemental resources are.used, they must be .pro:vided -with* *.

just-in-time training to ensure basic knowledge of radiation:exposure control. Emergency workers must demonstrate procedures to monitor and record*.dosimeter readjngs and man~ge radiological: ,

exposure control. , /1' * '

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 asJndicated in the plans /. *

. procedures. OROsmust demonstrate the actions descrlbed*in the plans/ procedures.by * **.

  • determining whether to replace the worker, authorize. the wor~er to incur additional exposures, or
  • take other actions. If exercise play does not require emergency worke~ to seek authorizations for

. additional exposure, evaluators must interview at leasttwo 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 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 (DRD) 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 do,imeters.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., life-saving, protection of valuable property, all;* .

activities). OROs must ensure that the process used to seek authorizati~n for exceeding dose 21

Unclassified Radiological Emergency Preparedness Program (REPP)

  • After*Action Report/Improvement Plan Peach Bottom Nuclear Power Station limits does not negatively impact the capability to respond to an incident where life-saving and/or .

protection of valuable property may require an urgent response.

OROs must demonstrate the capability to accomplish distribution of Kl 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 pert'onned; OROs.must demonstrate the capability to formulate and disseminate instructions on using KI for those advised. to Wee it.

Emergency workers must demonstrate ~asic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. Thii, can be accomplished by an int~rview with the evaluator. * ,, * . ,, . , ...

All activities 111ust 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 Ext~nt-of-Play Agreement.

State Negotiated Extent ofPlav:

Radiological briefings will beprovided to pdi/ress 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 worke~s outside (he EPZ do not have turn-back values.* Standard issue ofdosimetry and pot~ssium iodide for each. category ofemergencywor~ is asfqllows:

  • Catega,ryA: 1 PRD, 1.()RD,,and 1 unit ofKl Category B: l PRD and./. unit ofKl.

Category C: 1 PRI> .

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 inspectiqn, by tlle l!ederal Evalua(or. In order to demonstrate an understanding ofthe use ofthe dosimetry equipment, Kl and associatedform~; the location need only remove and distribute I issue a maximum ofsix (6) units ofdosinJe,try from their inventory.. Simulatior, Permanent Record Dosimeter.s.(PRDs). with mock serial numbers may be used..

EMS units outside the EPZfall under guidance.from the lnte~im Annex E letter dated April-6, 2009. Under section V-Confept ofOperations, subsection.D-Survey equipment requirements, Paragraph 8 EMS crews outside the EPZ are exempted.from needing PRD, DRD, or Kl (Page 1-7)

Evaluation.A.r~ ~upport Operation/ FaciUties Sub-element 6~d~-. Transportation and Treatment of Cont~n,inated Injured Individuals INTENT .

This Sub-elementjs derived from NUREG-0654 / FEMA-REP-1, which requires that OROs have*

22

Unclassified Radiological Emergency Preparedncss*Program (REPP)

After Action ReporUlmprovement Plan Peach Bottom Nuclear Power Station the capability to transport contaminated injured individuals to medical faci.lities with the capability to provide medical services.

Criterion 6.d.1: The facility I ORO has the appropriate space, adequate resources, and trained .

personnel to provide transport, monitoring, decontamination; and medical services to

  • contaminated injured individuals. (NUREG-0654 I 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 involved ORO, continue to evaluate the drills on an annual basis. If more than two medical facilities and transportation providers are designated as primary or backup, they are-also evaluated biennially.

.. ~

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

OROs must demonstrate the capability to transport contaminated injured individuals to medical .

  • facilities. *0 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 "victiin{s)" to the medical facility. This option is used in ar~as 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 enroute or may be* deferred to the medical facility.

Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is awarcfofthe 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:coritaminated 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*

23

/

Unclasdled Radiological Emergency P.ieplll'edness Pn>gJIIIII (REPP)

After Action Report/lmprovemmt Plan Peach Bottom Nuclear Pewer Station 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 indi.vidual 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 A.LARA principles. The Ambulance Service will pick-up a pre-staged simulated contaminated/injured victim.

24