ML23275A108
| ML23275A108 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/29/2023 |
| From: | Tierney M US Dept of Homeland Security, Federal Emergency Management Agency, Region III |
| To: | Padfield D Office of Nuclear Security and Incident Response, State of PA, Emergency Management Agency (PEMA), US Dept of Homeland Security, Federal Emergency Management Agency |
| References | |
| Download: ML23275A108 (1) | |
Text
U.S. Department of Homeland Security Federal Emergency Management Agency Region 3 One Independence Mall 615 Chestnut Street, 6th floor Philadelphia, PA 19106-4404 www.fema.gov September 29, 2023 Mr. David R. Padfield Director Pennsylvania Emergency Management Agency 1310 Elmerton Avenue Harrisburg, PA 17110
Dear Mr. Padfield:
The purpose of this letter is to officially inform you of the Federal Emergency Management Agency's (FEMA) identification of a Level 1 Finding that occurred during the Limerick Generating Station (LGS) Radiological Emergency Preparedness (REP) Exercise conducted on September 26, 2023. A Level 1 Finding is being assessed against the Boyertown/Colebrookdale Emergency Management Agency due to sub-par performance under the following exercise capability targets:
Objective 1-Emergency Operations Management Capability Target 1.2 - Direction and Control During the exercise, the Emergency Management Coordinator (EMC) was in charge of all actions in the Emergency Operations Center (EOC). The EMC did not conduct any briefings throughout the exercise. No brief outs were requested from functional areas, and no actions were conducted, tracked, or completed. Situational awareness was tracked from communication with the Berks County EOC, but no situational awareness was tracked from within the municipality. No coordination occurred between the municipality and other agencies beyond acknowledgement of information from the County EOC. This includes ensuring that special populations, schools, and congregate facilities were contacted and cared for based on the scenario. The facility was adequate to support the emergency response, but no technology was used to maintain awareness of the situation at Limerick Generating Station (LGS) beyond 800mHz radios that were used to communicate with Berks County.
Objective 2-Exposure Control Capability Target 2.2 - Emergency Worker Exposure Control Implementation During the exercise, the Municipalitys Radiological Officer (RO) and the RO backup did not arrive at the EOC to participate in the exercise. The Police Chief attempted to cover for the position and delivered a radiological briefing for emergency workers that would be going
Mr. David R. Padfield September 29, 2023 Page 2 www.fema.gov into the field. He also issued dosimetry and KI (simulated). However, during the demonstration, the EOC did not attempt to get 30-minute readings from the EWs. This was redemonstrated following engagement with the State observer, and then notifying the EMC.
The Police Chief acting in the ROs position did not brief staff in the EOC on dosimetry and KI use, and no dosimetry was issued or checked for potential exposures in the EOC. The jurisdiction is located within the EPZ. Per the extent of play agreement, All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP), will make the dosimetry equipment (and KI) available for inspection by the Federal Evaluator. It was impossible to assess if the dosimetry was in date as the cache of dosimetry provided at the EOC was sealed. There were no calibration or leak test dates on the inventory sheets outside of the sealed containers.
Objective 3 - Alert and Notification Capability Target 3.2 - Alert and Notification of the Public When the sirens were sounded at SAE and GE, the EMC did not direct the EMS coordinator to send teams to notify the hearing impaired of conditions at Limerick Generating Station (LGS) or protective action recommendations. This was in contradiction of approved plans and procedures.
In accordance with 44 CFR 350.9(d) and the DHS/FEMA Radiological Emergency Preparedness (REP) Program Manual, we have thoroughly reviewed and discussed this issue with the pertinent organizations participating in the off-site exercise evaluation. The FEMA REP Program Manual, defines a Level 1 Finding as "...an observed or identified inadequacy of organizational performance in an assessment activity that could cause a finding 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 in the vicinity of a nuclear power plant."
Because of the potential impact of a Level 1 Finding on the protection of the public health and safety, it must be corrected within 120 days from the date of the exercise through appropriate remedial actions including remedial exercises, drills, or other actions. In accordance with the FEMA REP Program Manual, if the remedial exercise can be successfully completed within 75 days of the biennial exercise, FEMA includes the results and findings of the remedial exercise in the final AAR for the biennial exercise.
Please coordinate with this office the date and time of the remedial exercise within 10 days from receipt of this letter.
Mr. David R. Padfield September 29, 2023 Page 3 www.fema.gov Your cooperation in this matter is sincerely appreciated. If you have any questions, please contact Thomas Scardino at (215) 931-5546.
Sincerely, MaryAnn Tierney Regional Administrator FEMA Region III MARYANN E TIERNEY Digitally signed by MARYANN E TIERNEY Date: 2023.09.29 12:11:57 -04'00'