ML18348A584

FEMA - Limerick, After Action Report Medical Services Drill - Radiological Emergency Preparedness (REP) Program

ML18348A584
Person / Time
Site:	Limerick
Issue date:	10/25/2018
From:	US Dept of Homeland Security, Federal Emergency Management Agency
To:	Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML18348A584 (28)

Text

Limerick Generating Station Medic.al Services Drill After Action Report

• Drill Date - October 25, 2018 Radiological Emerg~ncy Preparedne~s (RE_P) Program FEMA

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Radiological Emergency Preparedness Progra~ (REPP)

• After Action Report Limerick Generating Station .

Limerick Generating Station Medical Services Drill

• After Action Report/hnprovement Plan Published Date: November 16, 2018 Contents EXECUTIVE

SUMMARY

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SECTION 1: EXERCISE OVERVIEW .................................~ .................................... :............... 4

.1.1.Drill' Details

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1.2 Pla~ning T_eam Leadership*.:............... ,.. *;***..... ;_..:; .................... _.********:.************************************ 4 *

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13prti c1pating O.rgaDIZa .. tions .......

SECTION 2: DESIGN

SUMMARY

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. I 2.1 Pqrpose and Design .................. _.:.;****:*: .............. ::*******u;:********: ..*. *........*.. _..; ............ .- ..*. :...*. ;... 6 2.2 Objectives, Capabilities and Activities .. ,.;.: ............ ,......... :...... :...~ ........................ ,.... :......... 7 2.3 Scenario Summary******************:*:*****: ......... :******'.**,.: ..................... '.;'. ...-.. ;,:*.****:*******:*******;*;*****:***** 8 SECTION 3: ANALYSIS OF CAPABILITIES .. ;,... ;: ............. ;..... :......... ;..................................... :. 8 3.1 Evaluation and Results-., ............. :..... :................ :.... *:'*********,***************:; ..... ,.........................*.. 9 3.2' Summary Results of Evaluation .................. *; ... ;.............. :........................ :....................... :.: ... 9 3.3 Criteria Evaluation Summaries ............... ,.............. :; ............ , ...... .'.,._... :....... ;... *...... .'....*... ;...... 12 3.3.1 Private Organ~ations , .................:.._. .. .-... ~ .................. ,... ,..... ::*************************,**..... :.. 12 SECTION 4: CON(:LUSION ... ;...... :....... ,.;*;: .............................. .-......... :... :................................... i3 APPENDIX A: EVALUATORS AND TEAM LEADERS ................ ,....... *......... :....................... : 14.

APPENDIXB:

. ACRONYl\1:SANDABBREVIATIONS

. .. . .... :..... ;......... :.............. :............... ;..........

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APPENDIX C: EXTENT-OF~PLAY AG~EMENT ......... :....:.....*........ ;................. ~ .... :............ 16 I

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Radiological Emerg!lncy Preparedness Program (REPP)

• After Action Report Limerick Generating Station This page is intentionally blank.

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Radiological Emergency Preparedness Program (REPP)

After Action Report Limerick Generating Station EXECUTIVE.

SUMMARY

On October 25, 2018 a Medical Services (MS:-1) Drill was conducted for the IO-mile Plume Exposure Pathway, Emergency Plamiing Zone (EPZ) around the Liip.erick Generating Station (LGS) by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) Region III. The most recent prior MS-1 Drill for this site was conducted on October 27, 2016.

The purpose of the MS-1. Drill was to as&ess the State and local offsite response organization~*

m preparedness responding to a radiological medical emergency. The Drill was held in accordance with FEMA' s poljci.es and guidance concerning the evaluation of State and local Radiological Emergency Response Plans (RERP) and pro<;:edures. *

• FEMAwishes to ackn.pwledge the efforti:; oftbe many individuals Ill the Commonwealth of Pennsylvania, Montgomery County Emergency Management Agency, Holy Redeemer Hospital and the Cheltenham Township Emergency Medical Services, who were evaluated during this Drill.. .

Protecting the public health and safety is the full-time job of some of the Drill participants and an

• additional assigned responsibility for others. Still others have willingly sought this responsibility as volunteers providing vital emergency services twenty-four (24) hours a day to the .

• communities in which* they live. Cooperation and teiµn.work of all the participants was observed during this drill. .

• This report contains the final *evaiuation of the MS-1 Drill. TheCommonweaith of Pennsylvania

. and local organizations demonstrated knowledge of their emergency response plans and procedures and *adequately implemented thein. There were no Level 1 or Level 2 Findings or Plan Issues as a result of this drill .

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Radiological Emergen~y Preparedness Program (REPP)

• After Action Report SECTION 1:.EXERCISE OVERVIEW Limerick Generating Station 1.1 Drill Details Drill Name

.2018 Holy Redeemer Hospital Medical Services Drill Type of Drill

• Medical Services Drill Date October 25, 2018

• Program Department of Homeland Secunty/FEMA Radiological Emergency Preparedness Program Scenario Type Radioactive Cpntaminated/Iiljured Person

• 1.2 Planning Team Leadership

. Tina Lai Thomas Technological° Hazards Program Specialist Federal Emergency Management Agency .

One Independence Mall

• 615 Chestnut Street Philadelphia, PA 19106 Phone: (215) 931-5680 Tina.thomas@fema.dhs.gov Sandra B. Silva Emergency Management Specialist *

Sureau of Technological H¥ards PA Emergency Management Agency

• 1310 Elmerton-Avenue I Harrisburg, PA 17110 Phone: 717.651.2235 Sansilva@pa. g;ov Sara Schmidt Emergency Preparedness Specialist Exelon Corporation 200 Exelon Way .

Kennett Square, PA 19348 Phone: (267) 533-1426 Sara.Schmidt@exeloncorp.com 4

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Radiological Emergency Preparedness Program (REPP)

• After Action Report 1.3 Participating Organizations Limerick Generating Station Agencies arid organizations of the followingjurisdictions participated in the LGS 2018 Medical Services Drill:

• Stat.e Jurisdictions

• Pennsylvania Emergency Management Agency Risk Jurisdictions

• Montgomery CounJy Emergency Managemen,t A~~ncy (MCEMA)

Private Sector OrganizatiOJJ.!!

• ** Holy Redeemer Hospital

• Cheltenham Township .Emerg~ncy Medical Services  !

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.: ZSCJC ..SC~-L

• Radiological Emergency Preparedness Program (REPP)

• .After Action Report Limerick Generating Station *

.SECTION 2: DESIGN.

SUMMARY

2.1 Purpose and Design On December 7, 1979, the President directed the.Federal Emergency Management Agency (FEMA) to assume the lead responsibility for all off-site radiological planning and response.

FEMA's activities were conducted pursuant-to 44 Code of Federal Regulations (CFR) Parts 350, a

. 351 and 352, These regiiiations are key element in the Radiologicai Emergency Preparedness

• (REP) Program that was established following the accident in March 1~79.

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 plants'. This approval is contingent, in part, on State and iocal government participation in joint exercises withlicensees. FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

A. Taking the lead in offsite*emergency plamiing and in the review and evaluation of radiological emergency response plans an,d procedures developed by. State and local governments; B. Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises ofthe plans and procedures conducted by State and local governments; *

• C.

• Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to *

• the Memorandum of Understanding between the NRC an.d FEMA dated December 7, 2015 (Federal Register, Vol. 81, No. 57, M~ch 24, 2016) and; D. Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning pr9cess: . .

• -

• U.S. Department of Commerce

- D.S. Nuclear Regulatory Commission

• - U.S. Environmental Protection Agency

- U.S. Department of Energy

- U.S. J;?epartment of Health and Human Services.

- :U.S. Department of Transportation

• - U.S. Department of Agriculture

- U.S. Department of the Interior

- U.S. Food and Drug Administration Representatives of these agencies serve*on the Region III Regional Assistance Committee (RAC),

which fa chaired by FEMA. A Radiological Emergency Preparedness MS-1 .Drill was conducted on October 25, 2018, 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 involving LGS.

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' un¢n,~~*ueu. .

Radiological Emergency Preparedness Program (REPP)

• After Action Report

• Limerick Generating Station The purpose of this After Action Report (MR) is to present the Drill results, and findings on the performance of the Off-site Response Organ~zations (OROs) dunng a simulated radiological emergency involvinga*contaminated injured individual.

The Drill wa:s designed to demonstrate and evaluate th~ responder's kno:wledge of patient ~d responder personal protective measures, equipment pr¢parat10n and ~ployment, and decontamination procedures.-All activities \vere demonstrated in accordarice with.the part{cipants' plans and prcicedµres as they would be perfonned in an actual e~ergency, except as. agreed to in

. Exercise the .

Plan and Extent-of-Play (BOP) Agreement. .

The findings presented in this report.are qased on the evaluations of the Federal evaluator team, with final determinations made* by the FEMA Region III Regional Assistance Conµnittee (RAC) .

Chairperspn a11-d approved by FEMA Hea~quarters. These reports are provided to the Nuclear

• Regulatory Comniission (NRC) and partfoipating States. State and local governments utilize the findings contained in these reports for the purposes of planning, traini1;1g, arid improving .

emergency response capabilities. .

.

• Section 1 of this report, entitled Overview, presents the Exercise Planni;ng Team ~d the.

Participating Organizations. * ** * **

.* SectioJ:?. 2 of this. report, entitled :Oesign Summary, includes the Purpose and Oe~ign, Objectives, Capabilities and Activities, and the Scenario S:wnmary..

• * \ D' * * ., . * * *

• -*section 3 of this report, entitled Analysis of Capabilities contains detailed Evaluation and Results; a Suinina.ry Results of Evaluation; and Criteria Evaluation Summary: .Information on the demonstration for each jurisdiction or functional entj.fy evaluated i~ presenfod in a jurisdiction-based, issue-only f9nnat * * *

• Sec~on 4 ofthi~ report, entitle4 Coricl~ion, is a desGription ofFEMf.\'s oyerali assessment of the capabilities of the participating organizations:

-Th~ criteria utilized in the FpMA evaluation pro~~ss ~e contained in*the :following;

• NUREG-0654/FEMA-REP-1; Rev. 1, "Criteria for.Preparation and Evaluation of

• Radiologicai Emergency Response Pi.ans' a,nd Preparedness.in Stipp9rt of Nuclear Power Plarits/' November 1980; * *

• Radiological ~mergency Preparedness Program Manual, January 2016

. 2.2

• Objectives, Capabilities and Activities The Limerick Generating Station (LGS) MS-1 Drill ¢valuated by FEMA; wa~ designed to demonstrate that the ORO can transport, transfer, monitor, d~contaminate and treat a contaminated/injured person while minimizing any cross contamination during a radiolo~cal emergency.

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Radiological Emergency Prepar¢ness Program (REPP)

• After Action Report.

The demonstration included.the ability to:

Limerick Generating Station A. Respond fo a radiation medical emergency following Montgomery County Emergency

• Management Agency, Holy Redeemer Hospital and Cheltenham Township Emergency Medical Services procedures.

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

C. Conduct timely and accurat~ communications between: the hospital and offsite response agencies.

D. Exhibit co~ect priorities and appropriate techniqu~s in Emergency Medical Services (EMS); transportation of patients; and pre-hospital and hospital emergency care of patients

• contaminated with radiation. * *

• E. Demonstrate inter-agency cooperation between the Jfoly Redeemer Hospital and*

Cheltenham Township Emergency Medical Services. .

2.3 Scenario Summary The Limerick Generating Station declared a General Emetgen~y and an evacuation was o,rdered. An emergency worker was hosing down an evacuee's *contaminated vehicle when

. she got entangled with the hose and fell to ground.. She fell with both arms stretched out

• but landed on her left wrist.

The patient had a possible left wrist fracture, disfigured, bruised and swollen (not .

immediately known without x..:rays). Patient also had abrasions on her right pal~ and on.

left wrist. * *

• Due to the incident at the Limerick Generating Station, EMS crews assumed that they may be handling a potentially contaminated patient and adjusted treatment protocols in accordance _with their plans* and procedures .

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.. uiiciassinea .

Radiological Emergency Preparedness Program (REPP)

• After Action Report Limerick Generating 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 parti.cipated in the October 25, 2018 LGS MS-1 Drill .. The Driil was conducted to demonstrate the ability of the OROs to respond to a potep.tially contaminated injured person associated with LGS.

Each J1:1risdiction and functional entity was evaluated on the basis of its demonstration of the appropriate Demonstration Criteri_a contained in the REP _Progr~ Manual. Detailed information on the Demonstration-Criteria and the Extent-of-Play Agreement are found iri Appendix C.

e The Drill was conducted and evaluated in accordapce with the R_adiological Emergency Preparedness Program Manual (January 2016) and NUREG-0654/FEMA-REP-1, Rev. 1. The Demonstration Criteria included: * * *

1. e.1- Equipment, maps~_displays, monitoring instruments, dosimetry, Potassium Iodide (KI) and other supplies are sufficient to support em¢rgency operations ..

3. a.1- The OROs issue appropriate dosimetry, KI, and procedures, ~d ma'nage radioiogical exposure to-emergency workers.in accordance with the plans/procedures. Emergency workers perio<lically anci at the end of each mission read their dosimeters and record the readings on the appropriate exposure riecord 9r chart. OROs maintain appropriate record-keeptng 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, decqntamination, and medical services to

• contaminated ip.jured individuals. *

• 3.2 Summary Resµlts 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 jurisdictjons. and functional entities .. Drill Demonstration

• Criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters: *

(Ll) Level I Finding: An observed or identified inadequacy of organizational performance in an*

exercise that could cause a determination that offsite emergericy preparedness is not adequate to provide reasonable as"surance tha(appropriate protective measures can be taken in event of a radiological emergency to protect the health* and safety of the public' living in the vicinity of a Nuclear Power Plant (NPP). * .

(L2) Level 2 Finding: An observed or identified inadequacy of organizational performance in an exercise that is not considered,. by itself, to adversely impact public health and safety. *

(P) Plan Issue: An ~bserved oridentifie4 inadequacy in the off-site response organizations' 9

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Radiological Emergency Preparedness Program (REPP)

_.(

• After Action Report emergen.cy plan/implementin g procedures, rather th~*. .

Limerick _Generating Station that o.f the ORO' s p~rfomuµ1ce:

(N) Not Demonstrated: The term applied to the status of a REP Evaluation Area Criterion indicating that the ORO, for ajustifiable reasop., did not demonstrate the Evaluation Area Criterion, as required in the Extent-or-Play Agreement or at the two-year or ~ight~year interval required in the FEMA REP Program Manual. . .

(M) Met: The ~tattis of a* REp' Evaluation Area Criterion. indicating that the participating ORO

• demonstrated all demonstration criteria _for the Evaluation Area Criterion to the l_evel required -in:

the Extent-of-Play Agreement with no findings assessed in the current exercise and no unresolved prior findings. *

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unc1assmea Radiological Emergency Preparedness Program (REPP)

• After Action Report* Limerick Generating Station .

Table 3. l - Summary of Drill Evaluation

!Date: 2018-0cotber-25 Site: Limerick Generating Station (M) Met, (1) Level l Finding, (2) Level 2 Finding, (P) Planning Issue Mobilization lal Facilities - 1bl Direction and Control lei Communications ldl Equipment and Suoolies to Support Operations - lel M M Emen!ency Worker Exposure Control 2al

• Accident Assessment and Pars for the Emergency_Event PAD decision-making process and_ coordination for the Gerieral Public_

• _p ADs for disabilities & access/functional needs people

-2bl 2b2 2cl

• Radiolos:rical Assessment & Decision making for the Ingestion Pathway 2el Radiolos:rical Assessment & Decision making for -_ 2dl

,. -~6' ~

-Implementation ofEmergericy Worker Exposure Control 3al M *M.

Implementation of KIP AD for Institutionalized Individuals/Public 3b2

• Implementation.of PADs .for disabilities & access/functional needs peoole 3cl Implementation of PADS for Schools .

• 3c2 Implementation of Trame and Access Control 3dl Impediments to Evacuation 3d2 Imoletnentation of Reloca:tion/Reentrv/Returh Decisions 3fl

':;*"

o*  :,.

RESERVED 4al 4a2 --

• Field Team Management Plume Phase Field Measurement, Handlinj?;*.& Analyses 4a3 Post Plume Phase Field Measurements & Sampling 4bl Activation of the Prompt Alert & Notification System (ANS} Sal RESERVED 5a2 Activation*ofthe Back-up ANS 5a3 Activation of the Exception Area ANS 5a4 Errier~ency Information & Instructions to the Public/Media 5b 1

• Monitoring, J)~contamination, & Registta,tion of Evacuees*

Monitorinwuecontamination of Emergency Workers and Equipment

• 6al.

6bl

-/ ___ " -- -

Temporary Care of Evacuees

• 6cl Transportation/Treatm~t ofContami_nated Injured Individ_uals - 6dl .M M 11

.... .-.....J.C .. JC. --

Radiological Emergency Preparedness Program (REPP)

• After Action Report Limerick Generating Station

• 3.3* Criteria Evaluation Summaries 3.3.1 Private Organizations 3.3.1.1 Montgomery County, Holy 'Q.edeeiner Hospital

• In summary, the status of DHS/FEMA criteria for the Private Sector Organizations ar~ as

~~= . . .

. a. MET: l.e.l; 3.a.t; 6.d.t *.

b. LEVEL 1 FINDINGS: NONE

/

c. LEVEL 2 FINDINGS: NONE.

. (

. d...PLAN ISSUES: NONE

e. PRIOR ISSUES - ~SOLVED: NONE

f. PRIOR ISSUES- UNRESOLVED: NONE 3.3.1.2 Montgomery County, Cheltenham Township, Emergency Medical Services In summary, the status o:fDHS/FEMA, criteria for th.e Private Sector Organizations are as foli9ws: * * ..

a. tMET: l.e.l; 3.a.1;*6.d.l

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES -*RESOLVED:'NONE * *

f. PRIOR .ISSUES - UNRESOL~D: NONE 12

vl"'-*A.:,.:1Wi.u Radio~ogical ~mergency Prepar~dness Program (REPP)

• After Action Report Limerick Generating Statiol!,

SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and private sector organizations, except wher~ noted in.this rq,ort, demonstrated knowledge of their radiological emergency tesponsy plan~ and pr<>cedures arid th~y were successfully hnplemented during the Limerick Oenerating Station (LGS) Medical Se.rvice (MS-1).I>rili evahiated on October 25, 201s: . * . .

• * . ' , * ' I T

• Two FEMA evaluators provided analyses of ~ix evaluation criteria. Thes~ analyses resulted in a

• det~nati_on ofrto Findings, no new Plan Issues, and noµnresolved Plan Issues.

The Cheltenh~ Township Emergency Medic.al* Services* successfully demonstrated that necessary equipment and supplies were available to support the treatment *of an injured/contaminated . . .

over

• patient.* EMS per~onnel prioritjzed iife-saving medical practi9es implemented prote_ctive measures through the use of Personal Protective glove chang~s, and CQntroi of cro~s ~ntaminaticm. Approptj.ate patient assessments were:

CQntµninatioi1 conc;ems,

~quipment (PPE), regular*

demonstrated as weli as regular .and ongoing cominuriicatfons _with ~oly R~d~emer Hospital.

The Holy Redeemer. Hospital su¢~essfully d~onstrated th~ ]Jlobiiizatio~ of staff, staffing assignments, issue of dosimetry and.monitorip.g equipment, and effective use Perso~ar . of

. . Protective Equipment during tlie exercise. The _hospital staff_effectiveiy resp<;nided tq ..

commun1cations from the Cheltenh~ Township Emergency Medicai Services, initiateq the set-up i

inid management of Radiation Emergency Area, arid accepted and, suc~essfully treated ari .

injureci/contaminated patient whlle.administerip.g life-s~ving medi9a1 attention over coi1taminati.on*

of concerns.* fu aµdition.; the medical facility provided security C<>ntroi: the facility jncluding the

.* drop off bay for the patieiit and overall p1\>tecHve w.easures for contaminatic,n control and

• prevention of cross contamination: . . '. '

. Based on the results of the .drill and a review ~f the offsite radiological emergency responslplatis .

and procedure~ submitted, FEMA. Region I~I has detennine.d .they ar_e adequat.e (meet the pl~ng and preparedness standards of NUREG"'.0654/FEMA-REP-l; *Revision 1; November 1980~ as referenced in. 44.CFR 350_..5) and there is reasonable assurance they can be .jmplerilented, as demonstrated quring this drilL * * ** . *

\

• i An lnlprovement Pl~ (IP) will not .be requ1red as part ofthis rqJort:

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£-0..2-2::C Radiological Emergency.Preparedness Program (REPP)

• After:Action Report * .

• Limerick Generating Station APPENDIX A: EVALUATORS AND-TEAM.LEADERS

- / . . . .

The following is the list of Evaluators and Team Leaders for the LGS 2018 MS-1 Drill evaluated on October 2;;, 2018. The following constitutes the managing staff for the*

Evaluation: *

• Thomas Scardino, DHS/FEMA,' Regional Assistance Committee Chainn~

• Tina Thomas, DHS/FEMA, Technological Hazards Program Specialist

• PATE: Octoper 25, 2018

• SITE: Limerick Generating Station Holy Redeemer Ho~pital Patricia Gardner FEMARilI Cheltenham Townshi'.p Emergency Medical

• Services . .

• Kathryn Duran . FEMARIII 14

u ucla~:,uku

. Radiological Emergency Pre~aredness Program (REPP)

• Mter Action Report *

• Limeric1'.. Generating Station .

APPENDIXB: ACRONYMS AND ABBID,l:VIATIONS Acronym Meaning AAR After-Action Reoort ALARA .As Lc:>w As Reasonably Achievable.

ALC Annual.Le<<et of Certifi~ation __

ANS_. Alert and Notifi~atfon System BRP .Bureau of Radiation Protection -

OHS -. -Department of Hmnelan.d Security .

_ORD Direct Readiri.gj)osimetet EMS._ Einer~ency Medical s*ervices

• EOP EPZ _

Extent.of Piay FASP .First _Aid and Safety PaJrol FEMA -_Federal Emergeri~y Management Agen¢y FMT

• .GE. General Enier~eJ:J.cy _

IP

• Improvement Plan_ ..

KI Potassium Iodide .

LGS Limerick Generating station MCEMA-' .Mont,iomerv County' Em~rgency Management Ai~ncy':.

MS.; 1 . Medical Services

.NPP . Nuclear Pow~r-Plant '

NRC . . : Ntrclear R~srulatt>rv_ Co~ission : :

ORO O[fsite Response Org~.ation

.i>EMA :Pennsylvania Em~rgency Management Agency . -* . _-'

PPB _PetS:onal Protective, Equipnwnt.

PRO . PeiTnanentRecoid.Dosimeter RAC Regional "'Assistance Committee

• - REA REP RERP Radiation Emergency Area .

Radiologicai Ertiergericy_Preoarednes~ .

-: Radiological Emei,-gencv -Preparedness Prol!fam' ..

1 SAE -Site Area Emergency SOP Standard Operating ~rocedure *.-

• sAv Staff Assistan~e Visit 15

.Unclass~ed Radiological Emergency Preparedness Program (REPP) .. _J

• After Action Report/Improvement Plan Limerick Generating Station APPENDIX C: EXTENT-OF-PLAY AGREEMENT

• t .. .,. * * ;, ' . ', . rt' * *** '..:.i. . . . . ' ' . . ' .. ' *. ~ . . .

The Extent~of-'Pla.y Agreement was extracted !tofu the Exercfse Plan, which was drafted by .

Pennsylvania Emergency Management Agency, and is included in this report as an Appendix. The Extent-of-Play was negotiated and agreed upon by FEMA Region III, and Pennsylvania E111ergen~y Manag~ent Ag¢ncy. . .

. The Exercise Plan was. created as an overall tool for facilitation ap.d implementation ~f the. LGS MS-1 Driil and to integrate the concepts andpoli,cies of the Homeland ~ec1U1ty Exercise Evalµation Program with the Radiological Emergency :Preparedness Program Exercise Methodology. * * * * *

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. Unclassified Radiological Emer~ency Preparedness Program (REPP)

• After Action Report/Improvement Plan . Limerick Generating Station Limerick Generating Stati9n aoly. Redeemer Jlospital October 25, 2018 Method of pper~tion* .

'l,

• The*power station.and its personnel will not piay as active role in the facilitation ofthi~ . *

. exercise. The plant's. simulated events, radiation releases, and emergen.~y classificatioris w~ll be injected by off-site controilers. A pre~approved scenario wm ht:? us.ed. .

• 2. The Pe~sylvania Emergency Mana.g(?ment Agency (PEMA), PEMA Central Area Office as

.and the Bure~u of Radiation Protection (BRP) will not be activated part oftlns *exercise..-

The Exercise Coordinaforwill provide pre-exercise coprdfua,tion arid observe ex,ercise activities. * *

3. .Exelon will participate as a Confro~ler in this exerci.se..

4; Montgomery County Emerg~ncy Management Agency will *provide pre-exercise as coordin~tion;: parti9ipate iti'this' exercise the county 'communicatfons coordinator and.

'observe exer~ise activities' . * . .

.5 ... _Co1;1troliers will b~ supplied by PEMA/Exelo:n,. Controllers-are not players and will provide fojects and information to ,initiate and stimulate exercise play by providing .

radiological readings during the monitoring 'of personnel: ' Live radioactive sourc~s will*

only be used to *p~cmn oper~tional checks of radfological monitoring instruments.

6. 'PEMA staff and qualified county emergency management personnel will be assigned to.

key locations for the purp9se of observm,g,,noting response actions and conditions, and recording observatjons for future.use. Observei:s wilt' not take an active part in'the .

'proceedings, but will interact' with staff members to the extent necessary t<;> fulfill their observer responsibilities. Coaching of players is not permitted, except as appropriate to

• ?;

provide*training to participants awaiting. a re-demonstration Department. oflfom.eland Security (DH;S) Federal Emergency Management Agency (FEMA), Radiological Emergency Preparedness Program (REJ>P) Evaluators: FEMA Evaluators will be present at designated denio:nstration locations;

8. Exercise activities are scheduled to commerice on or about 0800, October 25, 2018 anci coh~inue until the_participEmts hav~ completed tp.e exercis.e obj~ctives and demonstrated the Exercise Evaluation Criteria.

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Unclassified . _

Radiological Emergency Preparedness_ Program (REPP)_

• .After Action Report/Improvement Plan

• Limerick Generating Station .

'9. Participants and agenqies*will Starid Down when the Controliers-have confirmed with the evaluators that all evaluation criteria have been demonstrated and when the State and

• County Observers are satisfied that the Objectives have been met.

10. An emergency plan is drafted to address the generally expected conditions of an emergency. Not everything fu the emergency plan may be applicable for a given scenario.

The main purpose of an emergency plan .is to as~emble sufficient expertise and officials so

.*as to properly react to the events as they occur.. The responders should not be so tied"to a

. plan that they cannot take actions that are more protective of the public. Therefore, if;- by

• _ not following the plan, the responders protect the-public equally as well as provided in the plan, it should be noted for possible modifi~ation of the plan, but not classified as -a

• negative incident. Furthermore, if, by following the plan there is a failure to 'protect the public health and_ safety, jt should be noted so that the plan can be modified and. the

• appropriate negative assessment corrected.

During the exercise any activity that is not satisfactorily qemonstrated may be re:...

demonstrated: by the participant~ during the ex;ercise, 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 pennissible to extend the demonstration window, within reason, to accommodate the re-demonstration.. Activities corrected from a re-demonstration will be* so noted.

• I Obiectives .

• A. Demonstrate the ability to respond to a radiation medical emerge11cy following the procedures of Montgomery-County Emergency Management Agency, C::heltenham To_wnship Emergency Medical S~ices EMS and Holy Redeemer Hospital.

B. Demonstrate tiinely and accurate communications between .the hospitai and offsite, response agencies. {Telephones will -be used in lieu of radios whenever possible to limit the potential_ mfain,terpretation of the exercise as an* actual event. Y C. Demonstrate correct priorities and appropriate techniques in EMS, transportation of

• • patients and pre-hospital and hospit&l emergency care of radioactively contaminated _-

.

• patients.

D. _ Demon~trate inter-agency -cooperation betw:een the* Ambulance Company/EMS and the Hospital.

-18

Unclllssified .

Radiological Emer~ency Preparedness Program (REPP) *

• After Action Report/lmprov.ement Plan Limerick Generating Station.

Limerick Generating Station Holy Redeemer Hospital Medical Service Exercise Extent-of-Play Evaluation Area 1-**Emergency Operations Management 1*

• Sub-Element Le-*Eqilipmeni and Supplies to Support iJp~~ations Intent-This st1b-el~ent is derived from NUREG---0654/FEMA:-REP-*1,'which requires that Offsite ..

Response bigani.zations (ORQ) have erii.ergency equipment a:ncl supplies adequate to support

• the emergency response. . .

Criterion Ie.1: Equipmeiit, maps, displays, mQnitor.ing instruments, dosimetry, potassium iodide (Kl)_, ~nd* other suj,plie~ are sufficient io _suppf!rl em.ergency operations. . .

. (NUREG-0654~FEA1A-RQP-J, IL 7, iO; L 7, 8, 9; .J.lO~a, b,' e,. J.li, 12; K.3.a; K.5.b)~

'. . ... . - /

Assessment/Exteht-of.:pfay Assessment of this Demo~stration Criterion is ac¢omplished primarily through a baseline

. evaluation and subsequent petj.odic hispectioi:is.. . . . . . .

A particular facility's equipnient and supplies 11).ust be suffici.ent*and consiste~t iith that facility'*s assigned role in the OR,O'.s enJ.ergel)cy operations plani,. Ds~ of maps and other displays is .

encouraged. Fpr _non-facility based operations; the equipment and supplies must be sufficient and consh,tentwith .the a~sigried* operational rok{ At locatiOJ)S where traffic. and acc~ss conef,ol personnel ~edeployed, appropriate equipment (e.g.,'vehicles, barriers, traffic cones,*and signs) must be.available, or their avaiJability describeq.. . . - - .... - .

• ~ * ~ , * ' !c * .* . * ,

Specific equipment and supplies that must be demonstrated under this criterion in~lude KI equipment, as follows: . . .

inventories, dosimetry~ and. monitoring' KI: Responsible OR{)s must demonstrate the ~apability to m~mtairi inventqries of KI sufficient-for use by: (1) ~~ergency'workers; (2) irtstitµtionalized individuals; .as' ind_icatecl in capadty lists for facilitjes; and (3) where stipulated by the plans/procedures, members of the general.public .

(iI!,clud1ng transients) wi~n the plume pathway ~PZ. In addition, OROs mu~t *dernonstr~te -

provisions to make KI available t9 specialized response teanis ( e.g., civ.il support team, Special Weapoijs-and Tactics T~anis,.rirban search and rescue, bomb squads,-HAZMAT, or other ancillary*

. groups) as identified in plans/procedures). The plans/procedures must include the f~mris to be used for documenting emergency worker ingestion of KI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the pi~~em~nt of emergency workers that haye declined kI in advance. * *

• 19

Unclassified J,{adiological Emergency Preparedness Program (REPP.)

• After Action Report/Improvement Plan Limerick-Generating Station ORO quantities of dosimetry .and KI avaiiable and sto:rage loc~tions(s) will be coiifimied by physical inspection at the storage location(s) or through documentation of current inventory

. submitted during the exercise, provided in the Annual Letter. of Certification {ALC) subinission, and/or verified during a Site Assistance Visit (SAV). Available supplies of KI must be within the expiration date indicated on KI bottles or blister packs.

• As an alternative, the ORO may produce a letter from* a certified private or State laboratory indicating that the KI supply remains potent, in accordance with U.S. Phannacopoeia standards. .*. .

Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and q.osimeter charger~'must be available for issuance to all emergency workers who will be.

dispatched to perform:' an ORO mission. In addition, OROs must demonstrate provisions to make dosim~try available to specialized response teams (e.g., civil support team, *special Weapons and.

• Tactics Teanis,'urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as

• . identified in plans/procedures. * *

• Appropriate direct-reading dosimetry must aliow an mdividual(s) to read the administrative.

report~ng limits. and maximum exposure'limits: contained in the ORO's plans/procedures. *

.* Direct-reading dosimeters must be zeroed or ope:rationally checked prior to issuance. *The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary.

Civil Defense Victorian Model 138s (CD V-138s}(0-200 mar), due'to their docuinented,history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced .

when necessary. This leakage testing will be verified during the exercise, through documentation

• submitted in the ALC and/or through an SAV. * * *

. Operational checks arid testing of electronic _dosimeters. must be in accordance with the .

manufacturer's instru9tions and be verified during ~he exercise, through doqum¢ntation submitted in-the AL<; and/or. through an SAY_.

• Monitoring Instruments: All instruments must be inspected, inventori~, and operationally .

checked before each use. Instruments must be calibrated in -accordance with the manufacturer's recommendations.' Unmodifi~d CDV-700 series instruments ~d other instruments without a manufacturer's recommendation must be calibrated annually. Modified CDV-700. instruments must be calibrated in accordance with the recommendation of the modification manufacturer. A

• label indi~ating such calibration must be on eaqh instrument or calibrated freq~ency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to theirsides*indicating the effective range of the readings. The range of readings

• documentation specifies the acceptable range of readings that the meter should indicate whep. it is response-checked using a standard test source.

• For FMTs, the instruments mui;t be capable of measuring gamma exposure rates and detecting*

,beta radiation .. These instruments must be capable of measuring a range of activity and exposure, including radiological protection/exposure control ofteam members and detection of activity on air sampie collection media; 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 each low-range radiation measurement instrument (i~ss than IRihr.) and 20

• Unclassified Radiological Emergency Preparedness Program (REPP)

• After Action Report/Improvement Plan . . Limerick Generating Station

• a for high.:.range instruments when available. If source IS not available for a high-range* .

instrument, a procedure must exist to operationally test the instrument before* enterjng ~ area where m1ly a µigh-range instrument cari m~e useful readings. In, are~s where portal monitors are .

• used, the OROs must set up .and operationally check the monitor(s). The rnonitor(s) must conform

. to the standards set forth in the Contamination Monitoring Standard fw a Portal M.onitor .Usedfor Emergency Response, FEMA-REf-21 (March 1995) or in accordance with the manufi1cturer's recommep.dations. *

• ' Mutual Aid Resources: Ifthe.inpomiiigre.sourc¢s arrive \Yi.th their own equipme11t (i.e:, monitors and/qr dosimetry), they will be evaluated by REP 'Program standards. FEMA will not inv~tory equipment that is not part of the REP Program. Ir'an agency has a defined role in the R]$P P_lan, they ;;ire subject to the planning process and standards, as well ~s the ~1dance of this Manual. '

• All ~ctivities must be b~sed on the ORO's plans/procedures anci completed a~ they :wo~ld bein*~

actual emergerj.cy, unless-rioted ~hove or otherivis~ specified in the Extent~of-'Play Agreement..

State Negotiated Extelit;;.of.-Pl~v:

or Ambuiancfi! crews are not traip,ed eq1,1,ippe:d to qperate or carry radiologi.cai ,;,,onitoring *.

equipment. In acc;ordance with the PEMA SOP Annex E, Appe~dix 5 ."Radi~logi.~al Expb;ure Control" (March, 2002), ambula.ncecrews operating ol,ltside th~ JO-mile Emergency'Planning .

Zone are considered "Category C"*emergency workers; therefore, they are only required t9

. implemeilt protective measures cortsistenfwith pr'C?tection.against blood..,borne pathogens; i.e.,

long sleevid garments, trousers, impermeable gloves, and surgical masks.. "Category CJ" emergency worker dosimetry issue consists .ofone pen,Z:anent reading dosimeier per worker.

Ambulance *crews are prov},ded additional dosimetry if ihey are tasked :with. entering the f O-miie EPZ.. .. . . ,. . . ..

Jfo;pitdl personnel are aiso (:Qnsidered, 1~Category C" emergency workers and will conform to at PEMA SOP protective rµea;su,::e; a minimu~~ Direct Reiidfng Dosiriiete~s *may be issue,/: .

individually; how?ver, an Area Kitwill be established in the.Radit;ztion Emergency Area (REA) ..

• 1ndividuai PRDs will be issued by the hospztal. Radiological Survey Instruments are ~a/ibrated per manufactures recommendations: . . .

• Outs.tandillg Issi,es:

Non~*

l . * . '

21

Unclassified Radiological Emergency Preparedness Program (REPP)

• After Action Report/Improvement Plan Limerick Generating Station

. Evaluation Area 3-:---,;.Protective Action lmplementati011 Sub-Element 3.a~Imple~entation ofE&iergency Worker Exposure Control Intent This Sub-element is derived from NUREG0654/FEMA-REP-1, which require~ that OROs have the capability to provide for the following: dtstr:ibutiori, use;collectiori, and processing of direct-reading dosimetry and pettnanent re~ord dosimetry} reading of direct-reading dosimetry by emergency workers*at appropriate frequencies; maintaining a radiation do.se record for each emergency worker; establtshirig a decision chain 0:r authorization procedure for emergency

• workers to incur radiation exposures in excess of the. P AGs, and the capability to provide KI for

.. emergency workers, always applying the' "as low as is reasonably achievable'; principle as

• . appropriate.

Criterion 3~a.1: The OROs issue appropriate dosimetry, .KI, and procedures, and manµge radiological expoiure to emergency workers iii accordance with tlie plans/procedures. .

Emergency workers periodically and at the end of each mission r~ad their dosimeters and*

record the readings on the appropriate exposure record or chart OROs maintain appropriate

• record-keeping of the- administration ofKI to elitet'gency workers. * -

(NUREG-0654/FEMA-REP-1; K.3.q, b; K.4) . -

Assessment/Extent of Play Asse'ssinent of this_ Demonstration Criterion may be acco~plished'during a biennial or. tabletop exercise. Other means m,ay include drills; seminars or training activities that would 'fully deJ.'!lonstrate technical proficiency..

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct;.reading and permanent record dosimetry, dosimeter,,

chargers,' KI; and instructions on the use ofthese items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the

.administrative reporting iimits that are pre-est~blished at a level low enough to consider . '

• . subsequent calculation of TEDE and maximum exposure limits, for those emergency workers

• involved,in lifesaving activities, contained in the OR.O's plans/procedures.

Each emergency worker must have basic knowJedge of radiatio~ exposure limits as specified~in the ORO's plans/procedures: If supplemental resources are used, they must be provided with jlist-in-time* training to ensure basic knowledge of radiation exposure controL Emergency workers , .

must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.

During a plume phase exercise, emergency workers must demonstrate* the procedures to be followe<;l when administrative exposure limits and tum-back values are reached. The emergency

• worker must report accumulated exposures during the exercise as indicated in the

• plans/procedures. OROs must demonstrate the actions described in the plans/procedures by

• 22

Unclassified Radiological Emergency Preparedness Program (REPP)

• After Action Report/Improvement Plan Limerick Generating Station determining whether to replace the worker, authorize. the worker to incur additional exposures, or take other actiqns. lf exercise play does not require emergency \\'.Orkers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge of whom to contact in case authorization is needed, and at what exposure levels.* Workers may use any available resources ( e.g., written procedures and/<;>r co-workers) in providing responses.

Although it is desirable for all emergency workers to each have a djrect-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 worn by ~e team leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOcs*and communi,cations cent~r within.the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosini.eters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically piaced in the work

• area). Each team member mu~t still have his or her own permanent record dosimetry. *Individuals authorized by the ORO to re-enter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiologicaJ exposure commensurate with completing their missions.

OROs may have administrative limits lower than EPA- 400-R-92-001 dose limits for emergency workers perfon;ning vari<;>us services (e.g., lifesavjng~ protection of valuable property, all

. activities). OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact-the capability to respond to an iJJ_cident where lifesaving arid/or prote.ction of valuable property may require an urgent response.

OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested-KI, including documentation of the date(s) and time(s) they did so. Ingestion of KI recommended by the designat¢d ORO lie~lth official is *voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed: OROs must demonstrate-the capability to formulate anq disseminate instructions on using KI for those advised to take it.

Emergency workers must demonstrate basic'knowledge of procedures for using KI whether. or not the scenario drives the implementation of KI use._ *nis can be accomplished by an interview with the evaluator.

All activities must be based on the ORO's plans/procedures and completed as they would be in an

• actual emergency, unless noted ab~ve or otherwise specified in the Extent.:.of-Play Agreement.

State Negotiated Extent-ofPlay:

.* Demonstrate appropri'ate procedures and equipment to manag~ radiological exposure to sta.ff. .

• Demonstrate the ability to transport contaminated/injured ,individuals while using ALARA principles. * * *

~ Demonstrate the ability to utilize dosimetry, equipment and procedures to manage radiological exposure to emergency workers as required* by plans;

• Radiological briefings *will be provzded to address exposure limits and procedures to replace 23' I

Unclassified Radiological Emergency Preparellness Prqgram (REPP)

• After Action Report/Improvement Plan

• Limerick Generating Station personnel 'approaching limits and how permission to exceed limits is obtained. At any time,*

. *players may ask otherplayers or supervisors t9 clarify radiological information. In Pennsylvania, emergency workers outside the EPZ do not have turn-back values. Standard issue ofdosimetry and potassium iodide for each category of emergency Worker is as.follows:

Category A.: IPRD, J' DRD,. and 1 unit ofKI Category B: 1 PRD and 1 unit ofKI Category C: IPRD NOTE: As per Annex E,.Appendix 5, page E-~-:35, "Emerge~cy r~sponders located outside

. the EPZ who, due to assigned tasking 's during a nuclear emergency, have limited

• potential for radiation exposure (e.g,, monitoring/decontamination teams; MS-1 hospital staffs).. Transporters of contamination or p~tentially contaminated

• indivtduals outside of the EPi are not provided dosime~.

• All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP) will make the dosimetry equipment (and KI, as appropriate) available for inspection by the Federal Evaluator. Simulation PRDs with tnock serial numbers may pe used.

~utstanding Issues:

None 24

Unclassified Radiological Emergency Preparedness Program (REPJ>) *

• After Action Report/lmprovelilent*Plan ... Limerick Generating Station.

Evaluation Area 6-a--Support Operation/Facilities Sub-Element. 6.d-* .

Tr~nsportation and Treatment of Contaminated

. ' . Injured Individuals Intent This Sub-element is derived from NUREG0654/FEMA-REP-1, w4ich r~quitesthat OR.Os have the capability to trahsp~>Ii cqhtaminated injured individuals to medical facilities W!fh the capability to provide medical ~ervic:es. .

-Criterion 6.d.l: Thefacility/OftO has th_e .appropriate space; adequate resources, (l~d traine(l

. personnei to provitle transpo_rt, monitoring, dec.ontaminqtion, and medical services to .

confa~inated injured individuals. (NUREG0654/FEMA-ReP-:-t F.2; H.10; l(.5~a, b; Ll, 4j

• Assessment/Extent of-Play Assessment of this Demopstration Ctjterion rhay be accomplisl)_ed during abiennial exercise, an actual event, or drills. FEMA has determined that these *capabilitie*s :have been enhanced and.*

consist~ritly :demo'nstrated as adequate! therefore, qffsite med1cal setvjces drills neeci only be evaluated biemually. FEMA will, at the request of the ORO, ccmtitme to evaluate ihe'drills-oi1 an annual basis. All hospitals listed in the pian .as medical. setvtces hospitals inustbe evaluated, with a ttan.sportatiori* provider, every 2 *years,. Additfoµal transportati9n providers will be rotated through the drills in the 8.,.year ~xercise cycie; For th~ ainbtilance providers who do not participate

. in'an evaluated dqll during the two-year cycie, trai,niilg will be provided. This traiajng will be

• documented in the ALC . * * * * *

• Monitori~g, decontamination, and contamination* coritrol efforts must not del~y urgent medical care for the victim. . .

OROs rimst demonstrate the capability to in_onitor/decont~huite and transport cbnt~inated

• _injured individuais-to

' / . . .

medical. facilities. .' .

An ambillance must be used for response to the vfotit}1. However, tq avoid taltjng an ambulance

• out of service for ~ extended t1me, OROs may use any vehicle (e.g., cat, truck, or van}to

• . transport the victim to the medical faci]ity. It is 'allowable for an, atnb1,1lance tc:, d~oristrate. up to .

the point of departure for the medical facility and'then have~ non-specialized vehicle transport the

vi'ctim(st to the medical facility; This option is use4 in areas where removing ambulance

• an from service to drive a great distance (over an hour) for a drill wouid not be in the best' interests qf the conuni.inity. .. . '  : . . . .

. ' .. . . / . .

Nomial communications between tlie ambulance/dispatcher and the receiving medic~l facility must be demonstrated. If a substitute vehicie is used for .transport to. the medical fi1.cility, this

~mm'unicatio:p. must occur before relea,sitig the ambµlance froin the drill. This communication

_wo1.1ld include reporting radiation monitoring results, if ~vailable. 1h addi_tiort, the ambulance crew must demon~trate, by interview, knowledge of where the ambul$ice ap.d crew would be monitored .

and decontaminated, if required, or whom to contact for such information.

.' 25. ' . '

. Unclassified .

Radiological Emergency Preparl,ldness Program (REPP)

• After Action Repo~provement Plan Limerick Generating Station*

Monitoring of the victim may be performed before transport or end route, 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 aware of the medical and radiologicafstatus of the irtdividual(s). However, if an ambulance.defers m<;mitoring to the medical facility, then.the ambulance crew presumes that the patient(s) is

. contaminated and demonstrate appropriate contamination controls until th~ patient(s) is* monitored:

Before using monitoring instrw,nents, the m~riitor(s) must demonstrate the process of checking the instrument(s) for proper operation. All nioniioring activities *must be completed as they would be in an actual emergency.

• Appropriate contamination control measures must be demonstrated

-before at1d during transport and at the receiving medical facility.

The medical facility must demonstrate the capabiiity 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 ofcontaminated inju,red

.individuals. * * * * *

-The medicai facility *must demonstrate *the capabiitty to 111ake decision~, on the need for decontamination of tp.e individual, follow appropna:fe decontamination procedures, and mam,i&fu records of all survey measurements and samples tak~. All procedures for collection and analysis of samples arid decontm,nination of the individµal musfbe demonstrated.or d¢scribed to the*

• evaluator. *Waste water from decontamination operations* must be handled *according to facility p,ans/procedures: ** * * ** *

• All activities must be. based on the ORO' s plans/procedures and completed as they ~ould \)e in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreetl).ent.

State Negotiated* Exteni-of-Plav:

Demonstrat~ thq.t thefacil~ty hq.s th~ appropriate spaqe, ad_~quate.resources and, t,:ainedpers.onnez*

io provide monitoring, d~contamination and *11'f_edical services to coniaminatedlinj_ured individuals.

Demon;i~aie the ability to transport c~n(amin~t~dlinjured individuals while usi-,ig'ALARA principles. * * * * *

• **Cheltenham !ownship EMS will pick-up a pre-staged simulat~d contaminated/injured patient.

• Outstanding Issues:

None*

26