ML19317D088

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After Action Report/Improvement Plan Based on August 7, 2019 Exercise
ML19317D088
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 10/15/2019
From:
US Dept of Homeland Security, Region IX, Federal Emergency Management Agency
To:
Office of Nuclear Reactor Regulation, NRC Region 4
Shared Package
ML19317D405 List:
References
Download: ML19317D088 (29)


Text

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.*Di~blo Canyon Power*P~ant After.. Action Report/Improvement_ Pla~

Exercise Date: August 07, 2019

  • Radi0I9gical Em:ergen*cy Preparedness Program

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Public*ation Date: October 15, 20'!9

Unclas.,ifled Radtological Emergency Preparedness Program After Action Report/Improvement Plan D1ablo Canyon Power Plant

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Unclassified Rad1ological Emerg~cy Preparedness Program After Action Report/Improvement Plan Dtablo Canyon Power Plant Diablo Canyon Power Plant After Action Report/Improvement Plan, Contents EXECUTNE SillvfMAf\Y 5 SECTION 1: EXERCISE OVERVIEW 7 1.1 Exercise Details 7 1.2 Exercise Planning Team Leadership 7 1.3 Participating Organizations, 9 SECTION 2: EXERCISE DESIGN

SUMMARY

11 2.1 Exercise Purpose and Design 11 2.2 Core Capabilities, Demonstration Criteria Objectives and Mission Areas 11 2.2.1 Demonstration C:iteria Objectives 14 2.2.2 Mission Areas 15 2.3 Scenario Summary and Extent of Play Summary 16 SECTION 3: ANALYSIS OF CAPABILITIES 21 3.1 Exercise Evaluation and Results 21 3.2 Summary Results of Exercise Evaluation 21 3 .3 Criteria Evaluation Summaries 23 3.3.1 Risk Jurisdiction 23 3 .3 .1.1 County of San Luis Obispo Sheriff Dispatch -

MEDCOM 23 3 .3 .2 Private Organiz.ations 23 3.3 .2.1 San Luis Ambulance 24 3 .3 .2.2 French Hospital Medical Center 24 SECTION 4: CONCLUSION 25 APPENDIX A: EXERCISE EVALUATORS 26 APPENDIX B: ACRONYMS AND ABBREVIATIONS 27 3

Unclusificd Radiological Emergency Preparedness Program After Acbon Re~provement Plan Dtablo Canyon Power Plant

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Unclassl.fled Rad10logical Emergency Preparedness Program After ActJ.on Report/Improvement Plan Drnblo Canyon Power Plant EXECUTIVE*

SUMMARY

The United States (U.S.) Department of Homeland Security's (DHS) Federal Emergency Management Agency (FEMA) Region IX National Preparedness Division (NPD), Technological Hazards Branch (THB), evaluated a Medical Services (MS-1) exercise at French Hospital. Medical Ce1i1ter (FHMC) outside the Emergency Planning Zone (EPZ) surrounding the Diablo Canyon Power Plant (DCPP) on August 07, 2019.

The purpose of the FHMC MS-1 exercise is to assess local emergency Offsite Response Organizations' (ORO) level of preparedness in response to a radiological incident occurring at DCPP. State, local, and tribal governments primarily are responsible for determining and implementing measures to protect life, property, and the environment in those areas surrounding the commercial nuclear power plants (NPP). Evaluated exercises play a vital role in national prepa'.redness by enabling whole co~unity stakeholders to test and validate plans and identify capability gaps. Additionally, a well-designed exercise provides a low-risk environment to test capabilities, familiarize personnel with roles and responsibilities, and foster meaningful communication across organizations.

The FHMC MS-1 exercise assessment is part of the Radiological Emergency Preparedness Program (REPP) to ensure that adequate capabilities exist to prevent, protect against, mitigate the effects of, responq. to and recover from radiological incidents involving commercial NPPs. The assessment of the FHMC MS-1 exercise resulted in no Plan Issues, Level 1 (Ll) or Level 2 (L2) Findings.

The FHMC MS-1 exercise was held in accordance with FEMA's policies and guidance concerning the implementation of the County of San Luis Obispo (SLO) and local ORO Radiological Emergency Response Plans (RERP) and' procedures.

The Extent' of Play (EOP) agreement was submitted to FEMA Region IX Regional Assistance Committee (RAC) Chair on May 03, 2019. The EOP agreement was reviewed and approved by the RAC Chair on June 11, 2019.

In Summary: The County of SLO and local OROs demonstrated that their plans and procedures could be adequately implemented. The FEMA has continued reasonable assurance that measures can be taken to protect the health and safety of the public in the event of a radiological incident occurring at DCPP.

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UncIIWiflcd Radiological Emergency Preparedness Program.

After Action Report/Improvement Plan D1ablo Canyon Power Plant SECTION 1: EXERCISE OVERVIEW 1.l Exercise Details Exercise Name FHMC-MS-1 Type of Exercise Medical Services Functional Exercise Exercise Date August 07, 2019 .

Program

. U.S. DHS/FEMA REPP Scenario Type a

Responding to and transport of radiological. contaminated injured patient 1.2 Exercise Planning Team Leadership Paula Smith, B.S.N.

~t~rim Director - Emergency Services French Hospital Medical Center Paula:Smith@DignityHealth.org Anita Konopa Emergency Services Coordinator Counfy of San Luis Obispo Office of Emergency Services akonopa@co.slo.caus

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UncllWifled Radiological Emergency Preparedness Program After Action Report/Improvement Plan Diablo Canyon Power Plant Kelly Van Buren 'I Emergency Services Coordinator County of San Luis Obispo Office of Emergency Services kv.anburen@co.slo.ca.us Rachel Dion Emergency Services Coordinator

' I County of San Luis Obispo Office of Emergency Services rdion@co.slo.ca us Samantha Caldwell Emergency Planning Coordinator - Offsity Pacific Gas and Electric Company ..

S5CL@pge.com I

Johanna Johnson.

Federal Emergency Management Agency - Region IX Regional Assistance Committee, Chair

,, J ohanna.Johnson@f~db.s.gov Alberto Sifuentes Federal Emergency Managemen,t Agency - Region IX Emergency Manage~ent Specialist Alberto.Sifuentes@femadhs.gov 8

Unclassified Rad1ological Emergency Preparedness Program After Action Report/Improvement Plan D1ablo Canyon Power Plant 1.3 Participating Organizations Jurisdiction and organizations that participated in the FHMC MS-1 exercise are as follows:

Risk Jurisdiction:

  • County of San Luis Obispo (SLO)

Private Organizations:

French Hospital Medical Center (FHMC)

Pacific Gas and Electric (PG&E) - Diablo Canyon Power Plant (DCPP)

San Luis Ambulance (SLA) Company

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Unclassifled Ra<hological Emergency Preparedness Program After Action Report/Improvement Plan Dmblo Canyon Power Plant SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design The FEMA a~sters the REPP pursuant to the regulations formd in Title 44 Code of Federal Regulations (C.F.R.) § 350,351 and 352 (October 2011) and the FEMA REPP Manual (Janu,ary 2016). /

Title 44 C.F.R. § 350 (October 2011) codifies 16 Planning Standards that form the basis for radioiogical emergency response planning for licensees, State, local, and tribal governments impacted by the EPZ's established for each NPP site in the U.S. One of the REPP cornerstones established by these regulations is an eight-year exercise design cycle of offsite response capabilities.'

The EOP agreement and approved scenario for the FHMC MS-1 exercise allowed the OROs the opportunity to implement and demonstrate their plans and procedures to protect the health and safety of the public in the event of a radiological incident occurring at an NPP.

Exercise planners utilized the elements described in the REPP Manual (January 2016) and Homeland Security Exercise and Evaluation Program (April 2013) to develop this exercise.

The demonstration criteria objectives evaluated during the FHMC MS-1 exercise, along with the review of the RERPs and procedures, and the verification of the periodic requirements

identified in U.S. Nuclear Regulatory Commission Regulation (NUREG)-0654/FEMA-Radiological Emergency Preparedness (REP)-1 enable FEMA to provide a statement along with a transfnission ofthis final After Action Report to the U.S. Nuclear Regulatory Commission that State and local plans and pro~ures are:
  • adeq~te to protect the health and safety of the public living near a NPP; and
  • that continued appropriate protective measures can be implemented offsite in the event of a radiological incident occurring at a NPP.

2.2 Core Capabilities, Demonstration Criteria Objectives and Mission Areas The establishment of the National Preparedness Priorities have steered the focus of the U.S.

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Unclasslfied Radiological Emergency Preparedness Program After Acl:!on Report/Improvement Plan Dtablo Canyon Power'Plant DHS toward a yapabilities-based planning approach. Capabilities-based planning focuses on planning under uncertainty, since the next*disaster can never be forecasted with complete_

accuracy. Therefore, capabilities-based planning takes an all-hazards approach to planning and preparation which builds capabilities that can be applied to a wide variety of incidents, while working within an economic framework. Thus capabilities-based planning allows prioritization and choice while addressing potential challenges and circumstances.

These capabilities, now known as "Core Capabilities" (previously referred to as "Target Capabilities"), allows the exercise planning team to develop radiological emergency plans and provides the foundation for development of the exercise objectives and scenario. Core Capabilities, along with their associated capability targets and performance measures, are distinct critical elements necessary to the meet the U.S. DHS National Preparedness Goal (September 2015) and are essential for the execution of Mission Areas.

Mission Areas serve as an aid in integration and coordination across Core Capabilities to achieve the goal of a secure and resilient nation. The U.S. DHS National Preparedness Goal (September 2015) organizes Core Capabilities into five Mission Areas: Prevention, Protection, Mitigation, Response, and Recovery.

Of the five Mission Areas listed only three were utilized during the FHMC MS-1:

Prevention, Protection and Response.

Those three Mission Areas, along with associated Core Capabilities definitions, form the basis for FHM:C MS-1 exercise objectiv.es, critical task observed and evaluated.

Prevention: Planning Objective: Conduct a systematic process engaging the whole community as appropriate in the development of executable strategic, operational, and/or tactical-level approaches to meet defined objectives.

Critical Task: Identify critical objectives during the planning process, provide a complete and integrated picture of the sequence and-scope of the tasks to achieve the objectives, and ensure the objectives are implementable within the time frame contemplated within the plan I '

using available resources for prevention-related plans.

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Unclassiffed Rachological Emergency Preparedness Program After Act.Ion Reportllmp_rovement Plan Diablo Canyon Power Plant Protection: Operational Coordination Objective: Establish ap.d maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

Critical Task: Establish and maintain partnership structures among Protection elements to support networking, planning, and coordination. Establish tiered, integrated leadership, and inclusive coordinating organizations that operate with a unity of effort and are supported by sufficient assessment and analysis to provide defined structure and decision-making processes for recovery activities.

Response: Environmental Response and Health and Safety Objective: Conduct appropriate measures to ensure the protection of the health and. safety of the public and workers, as well as the environment, from all-hazards in support ofresponder

) . operations and the affected communities.

Critical Task: Identify, assess, and mitigate worker health and safety hazards and disseminate health and safety guidance and resources to response and recovery workers.

Identify, evaluate, and implement measures to prevent an~ minimize impacts to the environment, natural and cultural resources, and historic properties from all-hazard emergencies and response operations.

Response: Operational Communications Objective: Ensure the capacity for timely communications in support of security, situational awareness, and operations by any means available, among and between affected communities in the impacted area and all response forces.

Critical Task: Ensure the capacity to communicate with both the emergency response community and the affected populations and establish interoperable voice arid data communications between Federal, tribal, state and local first responders.

Additionally, each Core Capability listed was linked to several corresponding activities and tasks (Demonstration Criteria Objectives) to provide additional detail.

2.2.1 Demonstration Criteria Objectives Demonstration Criteria Objectives sets the standard for an ORO's ability to perform a 13 j

Unclassifled Rad1ological Emergency Preparedness Program After Action Report/Improvement Plan Diablo Canyon Powe~ Plant specific emergency function under the sub-element (e.g., communicating among response organizations; alerting and notifying the public). Additionally, demonstration criteria objectives provide evaluation parameters much like the use of Core Capabilities described in the Homeland Security Exercise and Evaluation Program guidance.

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Offsite Response Organizations executed the following demonstration criteria objectives, with references to the 16 Planning Standards, contained in the FEMA REPP Manual (January 2016), and associated Core Capabilities from the U.S. DHS National Preparedness Goal (September 2015) and Title 44 C.F.R. § 350 (October 2011).

The assessment areas listed below contain specific criterion and sub-elements demonstrated during the FHMC MS-1 ex.ercise:

Assessment Area 1 - Emergency Operations Management Criterion l .a. l : Offsite Response Organizations use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a tim{?ly manner. (NUREG-0654/FEMA-REP-1, A.La, e; A.3, 4: c.l, 4, 6; D.4; E.1, 2; G.3.a: H.3, 4)

Criterion l .d. l : At 1~ two communication systems are available, ~t least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.

(NUREG-0654/FEMA-REP-1, F.1,,.2)

Criterion l.e.l: Equipment, maps, displays, dosimetry, potassium iodide (Kl) and other supplies are sufficient to support emergency operations. (NUREG-0654/FEMA REP-1,- H. 7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b)

- Assessment Area 3 - Protective Action Implementation Criterion 3.a. l: The OROs issue appropriate dosimetry, Kl, and procedures, and manage radiological exposure to emergency workers (EW) 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. Appropriate record keeping of the administration of KI for EWs is maintained. (NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b;'K.4) 14

Unclassified Rad1olog1cal Emergency Preparedness Program After Actton Report/Improvement Plan D1ablo Canyon Power Plant Assessment Area 6 - Support Operation / Facilities Criterion 6.d. l: The facility/ORO has the appropriate space, adequate resources, and trained I

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

to contaminated injured individuals. (NUREG-0654/FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4) 2.2.2 Mission Areas Mission Areas serve as an aid in integration and coordination across Core Capabilities to achieve the goal of a secure and resilient nation.

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Of the five REPP Assessment Areas -and Demonstration Criteria listed in 2.2.1, there are two Core Capabilities which are Common to the Mission Areas used in the FHMC MS-1 exercise.

The two Core Capabilities are:

  • Planning; and
  • Operational Coordination.

Common Mission Area Core Capabilities serve to unify the mission areas and, in many

. ways, are necessary for the success of the-remaining core capabilities.

Associated diverse activities include:

  • Develop a s~t of planning factors, intended to mimic a series of cascading incide:t;1!8 and identify the necessary core capabilities;
  • Draw upon three hazards identified by the Strategic National Risk Assessment (i.e.,

large-scale earthquake, major hurricane, weapons of mass destruction); and

  • The whole community must maintain the ability to conduct mission essential functions during an actual hazard or incident to ensure delivery of core capabilities for all mission areas.

Common Mission Area Core Capabilities is ~et by the demonstration of REPP criteria:

1.a.l, 1.d.1, 1.e.l, 3.a.l and 6.d.1.

There are two Core Capabilities identified in one Mission Area used in the FHMC MS-1 exercise: Response.

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U nclassifled Rad1ological Emergency Preparedness I'fogram After Action Report/Improvement Plan Dlablo Canyon Power Plant

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The two Core Capabilities are:

  • Environmental Response/Health and. Safety; and
  • Operational Communications.

Response Mission Area Core Capabilities include those capabilities necessary to save lives, protect property and the environment after an incident has occmed. It is focused on ensuring_that the Nation can effectively respond to any threat or hazard, including those with cascading effects, with an emphasi~ on saving and s ~ g live, stabilizing the incident, meeting basic human needs, establishing a safe and secure environment and supporting the trap.sition to recovery.

Associated diverse activities include:

  • Provide transportation (including infrastructure access and accessible transportation services) for response priority objectives, including the evacuation of people and animals, an~ the delivery of vital response personnel, equipment and services into the affected areas.
  • Conduct appropriate measures to ensure the protection of the health and safety of the public <;111d workers, as well as the environment, from all-hazards in support of responder operations and the affected communities.
  • Ensure.the capacity for tim~ly communications in support of security, situational awareness, and operations by any and all means available, among and between affected communities in the impacted area
  • Provide lifesaving medical treatment via Emergency Medical Services and related operations and avoid additional disease and injury by providing targeted public health, medical, and behavioral health support , and products to all affected populations.

Response Mission Area Core Capabilities*is met by the demonstration of REPP C?teria:

Lal,, l.d.1, le.I, 3.al, anq 6.d.l.

2.3 Scenario and Extent of Play Summary The August 07, 2019, FHMC MS-1 exe~cise was based on two radiological scenarios: One occurring at DCPP, and the other offsite in a public area,. Both scenarios invoked local OROs to conduct emergency response actions.

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UnclJWiflcd Radiological Emergency Preparedness Program After Action Report/Improvement Plan D1ablo Canyon Power Plant The FHMC MS-1 EOP agreement identifies exercise planning deviations from the local OROs Standard Operating Procedures (SOP). The FHMC MS-1 EOP agreement scenarios were approved on June 11, 2019, by the FEMA Region IX RAC Chair who made the final determination that it was adequate to support demonstration ofDHS/FEMA criteria requirements as outlined in the REPP Manual (January 2016).

The FHMC MS-1 exercise was developed with two scenarios. Scenario 1 (S 1) involved an injured and potentially radiologically contaminated utility worker who was prepared for transportation from DCPP to FHMC. Scenario 2 (S2) involved DCPP at an Emergency Classification Level (ECL) of General Emergency ( GE) with a release of radiation in progress. An evacuation order for the general public was issued for the affected EPZ areas, and an individual from the general public was injured and possibly contaminated and required transportation to FHMC. Note: Only S2s drill time compression was increased to allow adequate time for demonstration of assigned criteria A summary of the FHMC MS-1 exercise - S 1 is presented below:

Unit 1 (U 1) is at 100% power, operating at Normal Operating Temperature and Pressure.

Unit 2 is at 100% power, operating at Normal Operating Temperature and Pressure.

Diablo Canyon Power Plant maintenance workers perform work to change out the Ul Spent Fuel Pool Filter due to high differential pressure.

Filter transfer cask 0-3 was being used based on a pre-job filter survey that showed the contact dose rate on.the filter to be 3 roentgens per hour (R/br).

While positioning the filter transfer cask containing the spent filter from above the filter housing to over the base plate, the grappling device failed and the spent filter fell from within the cask. The spent fuel filter bounced off the filter housing and landed on the posted contamination area surface. The spent fuel filter rolled outside of the posted contami~ated area spilling contaminated water onto the adjoining surface area and on one of the decon-specialists taking part in the spent fuel filter change out.

Startled, the contaminated decon-specialist stumbled back and tripped over the lower comer of the filte! housing, rotating to their right side as they fell. Their left shoulder and then left 17

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan D1ablo Canyon Power Plant elbow struck the upper comer of the filter housing resulting in a laceration and contusion to both areas.

Attempting to break their fall, the decon-sp~ialist extended their right arm. This resulted in their right palm striking the Herculite fabric, that had been laid out for contamination control, and resulted in abrasions and friction burns. There was no loss of consciousness or change in mental status to the decon-specialist An exercise Controller (simulating one of the maintenance workers) initiated the medical/fire alarm and provided the location and description of the accident to the Control Room (CR).

  • The CR implemented their procedures in regard to a DCPP worker injured and potentially contaminated. A Shift Manager (SM) sounded the .Medical/Fire Alarm and made a public

- address announcement requesting DCPP Fire personnel to respond to the location of the medical emergency.

A bridge line was established so that the SM, DCPP Fire Captain, DCPP Medlcal Facility, Operations (Ops) Respond~r and Radiation Protection (RP) to confirm whether response was required.

Fo~owing the bridge line brief, the DCPP Fire Captain, Ops Responder and RP were dispatched to the location of the medical emergency. The County of SLO Sheriff's Medical Communications Center (MEDCOM) was contacted for an ambulance to transport the injured, potentially contaminated worker to a designated medical facility. .

Radiation Protection and DCPP medical personnel prepared the injured potentially contaminated worker for transportation prior to the arrival of SLA. Appropriate radiological and exposure control measures were taken during the preparation of the patient. During this process the Senior RP technician was informed that the patient was to be transported to FHMC. Upon SLA arrival RP personnel were to assist with patient transfer and accompany SLA crew to FHMC.

Summary of the FHMC MS-1 exercise S2 is presented below:

(Note: Any times listed are for planning purposes only.)

A radiological event had occurred at DCPP, and following protocol the offsite warning 18

Unchwified Radiological Emergency Preparedness Program*

After Act10n Report/Improvement Plan Dwblo Canyon Power Plant center was notified.

Initial conditions are as follows:

  • 1100 ECL of ALERT declared,
  • 1200 ECL of Site Area Emergency (SAE) declared,
  • 1500-+- Protective Action Zones (PAZ) 1, 2 and 5 evacuated, and
  • Hospital and Emergency Medical Services staff notified of the ECLs as they occurred.

As per standard procedure and EOP agreement, SLA personnel had been issued Emergency Worker Exposure Control (EWEC) dosimeters and Personal Protective Equipment (PPE) from J:?edical facilities at the ECL of ALERT.

Shortly after the ECL declaration of GE, an exercise Controller inject was given to FHMC and MEDCOM that a radiation release was in progress. For the purposes of the FHMC MS-1 exercise the simulated start time commenced at 1800.

A hiker was at the Montana de Oro State Park, located in PAZ 2, and did not leave the park when it was closed following the evacuation order. Upon exiting the park, the hiker learned of the evacuation order of PAZs 1, 2 and 5. The hiker decided to return to their residence, in Los Osos, to pack some personal necessities prior to evacuating the area While at their residence, the hiker accidently fell down a flight of stairs sustaining injuries and possibly breaking their right leg. By exercise inject the injured hiker was able to call 9-1-1 and report the accident.

During this time the C~unty of SLOs Emergency Operations Center predicted that within the next three hours PAZ 5 's dose projections would be affected by the release of radiation.

The SLO County Health Officer (CHO) instructed (simulated by Controller inject) that the Operations Section notify field personnel to wear gloves, booties and review their procedures. This included SOPs that reference the handling and transportation of potentially contaminated patients. In accordance with the CHO's directive SLA personnel were contacted via MEDCOM.

The injured hiker's 9-1-1 call was received by County of SLO Sheriffs dispatch who transferred the caller to MEDCOM. The hiker's location was identified by MEDCOM as being in the PAZ potentially ~ected by the radiological release. MEDCOM dispatched an 19

J Unclamfled Radiological Emergency Preparedness Program After Action Report/Improvement Plan Diablo Canyon Power Plant SLA to the location and notified the SLA personnel that the location was in the potentially affected area MEDCOM reminded SLA personnel to follow procedures in treating and transporting a potentially contaminated patient According to standard procedures treatment of injuries have precedence over treatment of contamination.

Arriving at the injured hiker's residence SLA personnel asked the hiker their locatiop. prior to the fall. San Luis Ambulance personnel relayed the patient's vitals to FHMC and that the patient was potentially contaminated.

Upon arrival at FHMC SLA was guided toward the radiological exclusion area (REA) and SLA personnel turned over the patient to FHMC staff. French Hospital Medical Center monitoring technicians (MT) conducted a survey of the injured patient to make the final determination if any radiological contamination is present The MT determined the injured

  • patient was free of radiological contamination and transferred to a clean gumey. The injured patient was then taken to the Emergency Room for further examination and treatment.

Extent of Play Agreement Summary:

The purpose of the EOP agreement is to identify participants, negotiate evaluation areas, demonstration criteria/objectives and limitations, identify previous Plan Issues (PI), and any planned deviations from the implementation of the applicable plans that were evaluated during the FHMC MS-1 exercise.

  • The County of SLO provided to FEMA the following SOPs for review and use by responding OROs during the FHMC MS-1 exercise. The submitted SOPs included: FHMC (07/2019), CHA (06/2018), County Sheriff's D~partment (06/2018), EWEC (07/2016) and
  • Radiation Survey Equipment (02/2019).

Successful demonstration of criteria objectives validates. that continued reasonable assurance exists to protect that the health and safety of the general public during a NPP incident.

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Unchwifled Rad1ological Emergency Preparedness Program After Action Report/Improvement Plan Diablo Canyon Power Plant SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results This section presents the results and findings of the FEMA evaluation of the risk jurisdiction and private organizations that participated in the August 07, 2019, FHMC MS-1 exercise.

The risk jurisdiction and private organizations were evaluated on their demonstration of offsite emergency response Core Capabilities and selected demonstrated criteria as indicated in the EOP agreement and as outlined in the FEMA REPP Manual (January 2016).

3.2 Summary Results of Exercise Evaluation The FEMA REPP uses an alphanumeric key to indicate status classification of demonstrated criteria. Alphanumeric key definitions as defined in the FEMA REPP Manual, (January 2016), are listed below.

Level 1 Finding: "An observed or identified inadequacy of organizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living

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in the vicinity of a NPP."

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."

Met: "The jurisdiction or functional entity performed all activities under the Demonstration Criterion to the level required in the EOP agreement, with no Ll or L2 Findings assessed under that criterion in the current exercise and no unresolved prior Level 2 Findings."

Not Demonstrated: "For a justifiable reason, the jurisdiction or functional entity did not perform activities under the Demonstration Criterion as specified in the EOP agreement or at the frequency required in Exhibit III-2 (REPP Manual, 2016)."

Plan Issue: "An observed or identified inadequacy in the ORO's emergency plan/procedures, rather than that in the ORO's performance."

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uncla.ulfled Rad10Iogical Emergency Preparedness Program After Act:Ion Report/Improvement Plllll D1ablo Canyon Power Plllllt The idei:i.tifying number for Ll Finding and L2 Finding includes the following elements, with each element separated by a hyph~n (-).

  • Plant Site Identifier - A two-digit number corresponding to the Utility Billable Plant Site Codes (19 is the Utility Billable Plant Site Code for DCPP).
  • Exercise Year - The. last two digits of the year in which the exercise was conducted.
  • Demonstration Criterion - An alpha letter and two-digit number corresponding to the
  • criteria in found in the FEMA REP Exercise Preparation Guide (June 2013) version 3. *
  • Issue Classification Identifier- (Ll, L2, or PI)
  • Exercise Issue Identification Number - A separate two (or three) digit indexing number assigned to each issue identified in thp exercise.

The matrix below)resents the status of Assessment Areas and s_ub-element criterion evaluated during the FHMC MS-1 exercise by FEMA evaluators.

E 0

u DATE: 08-07-2019 i~ l3

('.:)

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8 I

SITE_: Diablo Canyon Power Plant, CA u ~ ~

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5~ ]

g a::"'
  • c:: i 8

~

~

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Ll: Level 1 Finding, L2: Level 2 Finding .cl CIJ !a "3

~ 0

..-l

.n Cf.l ~ CIJ

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M: Met, P: Plan Issue, N: Not Demonstrated 5~ 0

r:

.cl

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<+--<

0 0

-~

..-l

§

~ @ 0 !a t=:I u CIJ

~~t

~ -;

Emergency. Ot?erations Managenu;mt .. " '.,' '.

' Mobiliz.ation Lal M M Communications l.d.l M M .M Equipment and Supplies to Support Operations l.e.l M M Protective Action Implementation Implementation of Emergency Worker Exposure Control 3.al M M Sunnort Operations and Facilities Transportation and Treatment of Contaminated Injured lndividual(s) 6.d.l M M-22

Unclusified Radtological Emergency Preparedness Program After Action Report/Improvement Plan Drnblo Canyon Power Plant 3.3 Criteria Evaluation Summaries 3.3.1 Risk Jurisdiction State, local, tribal, or territorial governments where natural or man-made hazards could affect their jurisdiction, identify areas that are vulnerable to those hazards and what assets will be affected.

3.3.1.1 County of San Luis Obispo Sheriff's Dispatch -

MEDCOM An offsite participant that received MS-1 exercise communications via a 9-1-1 call to SLO Sheriff's Office Dispatch Center. The 9-1-1 call to MEDCOM mobilized pre-staged SLA personnel to the DCPP medical facility for patient transfer.

The status ofDHS/FEMA criteria for this location is summarized below:

a MET: I .a. I ,and l .d. l

b. LEVEL 1 FINDING: None
c. LEVEL 2 FINDING: None
d. PLAN ISSUES: None
e. NOT DEMONSTRATED: None
f. PRIOR ISSUES - None
g. PRIOR ISSUES*- UNRESOLVED: None 3.3.2 Private Organization A non-federal body such as faith-based organizations, schools, or independent healthcare that provide emergency protective measures on behalf of state, local, tribal, or territorial governments.

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Unclamfled Radiological Emergency Preparedness Program

  • After Action Report/Improvement Plan D1ablo Canyon Power Plant 3.3.2.1 San Luis Ambulance Offsite participant that received MS-1 exercise communications via MEDCOM and mobilized pre-staged SLA personnel to the DCPP medical facility for patient transfer to FHMC.

The status ofDHS/FEMA criteria for this location is summarized below:

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

b. LEVEL 1 FINDING: None
c. LEVEL 2 FINDING: None
d. PLAN ISSUES: None
e. NOT DEMONS1RATED: None
f. PRIOR ISSUES - None
g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 French Hospital Medical Center Offsite participants received, treated and decontaminated a radiologically contaminated patients.

The status ofDHS/FEMA criteria for this location is summarized below:

a I

MET: Lal, l.d.l, l.e.l, 3.al and 6.d.l

b. LEVEL 1 FINDING: None

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C. LEVEL.2 FINDING: None

d. PLAN ISSUES: None
e. NOT DEMONS1RATED: None I
f. PRIOR ISSUES - None
g. PRIOR ISSUES - UNRESOLVED: None 24

Unclamfled Rachological Emergency Preparedness Program After Action Report/Improvement Plan D1ablo Canyon Power Plant SECTION 4: CONCLUSION The FEMA, Region IX, THB evaluated an MS-1 exercise at FHMC in the County of SLO, California on August 07, 2019. The purpose ofthe.FHMC MS-1 exercise was to assess certain aspects of the level of local emergency preparedness in response to a simulated radiological incident occurring at or within the vicinity of DCPP. The FHMC MS-1 exercise and related demonstration criteria were conducted in accordance with FEMA policies and guidance concerning local RERPs and procedures.

A copy of the approved EOP agreement is maintained by FEMA Region IX NPD / THB, the state of California OES, the County of SLO OES, and is herein incorporated by reference.

Based on the evaluation of the FHMC MS-1 exercise the offsite RERPs for the affected support jurisdiction, site-specific to DCPP, can be implemented and ar,e adequate to provide continued reasonable assurance that appropriate measures can be taken to protect the health and safety of the public in the event of a radiological inc.ident occurring at or within the vicinity DCPP.

Therefore, Title 44 C.F.R. § 350 (October 2011), approval of the offsite RERPs and preparedness for the County of San Luis Obispo site-specific to DCPP will remain in effect.

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Unclassllled Radtological Emergency Preparedness Program After Action Report/Improvement Plan Dtablo Canyon P?wer Plant APPENDIX A: EXERCISE EVALUATORS

.. LOCATION .. , " ~'

Evaluator AQBNCY -*

Sheriff's, Dispatch Center - MEDCOM John Woytak FEMA Region IX Criteria l.al and l.d.l French Regional Medical Center Vince Kalson FEMA'Region IX Criteria l .a 1 and l .d. l French Regional Medical Center '

Michael DeBonis FEMA Region II Criteria l.e.l, 3.al and 6.d.l San Luis Ambulance Tom Essig ICF, Inc.

Criteria l.d.l, l.e.l, 3.al and 6.d.l 26

Unclamflcd Radiological Emergency Preparedness Program After Action Report/Improvement Plan D1ablo Canyon Power Plant APPENDIX B: ACRONYMS AND ABBREVIATIONS

.-\l'l"llll\'111 Phrnst*

C.F.R. Code of Federal Regulations CMHBD County Medical/Health Branch Director CHO County Health Officer CPM Counts Per Minute CR Control Room DCPP Diablo Canvon Power Plant DECON Treatment Decontamination DHS Department of Homeland Security ECL Emergency Classification Level ED Emergencv Director EMT Emergency Medical Technician EOC Emergency Operations Center EOP Extent of Play EPZ Emergency Planning Zone ETA Estimated Time of Arrival EW Emergency Worker EWEC Emergency Worker Exposure Control FEMA Federal Emergency Management Agency FHMC French Hosoital Medical Center GE General Emergency GM Geiger-Mueller ICF Inter City Fund KI Potassium Iodide Ll Level 1 Finding L2 Level 2 Finding LOA Letters of A2Ieement MEDCOM Medical Communications Center MGP Mirion Technologies MT Monitoring Technician mrem milliroentgen equivalent man MS-1 Medical Services NMT Nuclear Medicine Technician NPD National Preparedness Division NPP Nuclear Power Plant NUREG Nuclear Regulatory Commission Regulation OES Office of Emergency Services 27

Uncluslflcd Radiological Emergency Preparedness Program Afta ActJ.on Report/Improvement Plan D1ablo Canyon Power Plant OPS Ooerations '

ORO Offsite Resoonse Organization PAZ Protective Action Zone

'PED Personal Electronic Dosimeters PG&E Pacific Gas and Electric PI Plan Issue PPE Personnel Protective Eauipment R Roent,l.!;en r/hr Roentgen per hour ,

RAC Regional Assistance Committee REA . Radiolol!ical Emergency Area REP Radiolocical Emergency Preparedness REPP Radiolocical Emergency Preparedness Program RERP Radiological Emergency Response Plans RP Radiation Protection Sl Scenario 1 S2 Scenario 2 SAE Site Area Emergency SDC Sheriff's Dispatch Center SLA ,I San Luis Ambulance SLO San Luis Obisoo SM Shift Ma.nrurer SOP Standard Operating *Procedure TEDE Total Effective Dose Equivalent TIIB Technological Hazards Branch TLD Thermoluminescent Dosimeter U.S. United States

  • UHF Ultra-High Frequency ,

Ul Unit 1 VHF Very High Frequency 28

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