ML17124A513

Final After Action Report/Improvement Plan for the Beaver Valley Power Station (BVPS) Medical Services (MS-1) Drill Held on March 29, 2017

ML17124A513
Person / Time
Site:	Beaver Valley
Issue date:	04/26/2017
From:	Welch R US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML17124A513 (65)

Text

I IC '* '-1 ' Nuclear Regulatory Commission Headquarters Office of Nuclear Security and Incident Response Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 To Whom It May Concern: APR .2 6 2017 U.S. Department of Homeland Security Region III One Independence Mall, 6th Floor 615 Chestnut Street Philadelphia, PA 19106-4404 FEMA Enclosed is the final After Action Report/Improvement Plan for the Beaver Valley Power Station (BVPS) Medical Services (MS-1) Drill that was held on March 29, 2017. The Weirton Medical Center and Brooke County Emergency Medical Service participated in the drill. There were no Level 1 Findings, Level 2 Findings, or Planning Issues identified during the drill. Based on the results of the exercise and a review of the off site radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CPR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

If you have any questions, please contact Thomas Scardino at (215) 931-5546.

Sincerely, ,/,f 6.,,it)w { Robert P. Welch Acting Regional Administrator Enclosure www.fema.gov l ,, ' l Beaver Valley Power Station Medical Services Drill After Action Report/Improvement Plan Drill Date -March 29, 201 7 Radiological Emergency Preparedness (REP) Program Published April 21, 2017 This page is intentionally blank. ( I

';1ift' Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Contents Beaver Valley Power Station Medical Services Drill After Action Report/Improvement Plan Published Date: April 22, 2017 EXECUTIVE SlJJ\.1l\llARY

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3 SECTION 1: EXERCISE OVERVIEW ..................................... ....*..............................................

4 1.1 Drill Details .....................................................................................**............................*..........

4 1.2 Planning Team Leadership

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4 1.3 Participating Organizations

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5 SECTION 2: DESIGN SlJJ\.1l\llARY

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6 2.1 Purpose and Design ..................................................................................................................

6. 2.2 Objectives, Capabilities and Activities

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7 2.3 Scenario Summary ...................................................................................................................

8 SECTION 3: ANALYSIS OF CAP ABII.JTIES

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9 3.1 Evaluation and Results .......................................................................*.........................*..........

9 3.2 Summary Results of Evaluation

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9 3.3 Criteria Evaluation Summaries

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121 3.3.1 Private Organizations

...*.... !'*************************************************************************************122 SECTION 4: CONCLUSION

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' .... 13 APPENDIX A: EVALUATORS AND TEAM LEADERS .. ..........................................................

14 APPENDIX B: ACRONYMS AND ABBREVIA TIONS ..................................*.............................

15 APPENDIX C: EXERCISE PLAN .....................................................................................*......... .. 16 1 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report!lmprovement Plan Beaver Valley Power Station This page is intentionally blank. 2 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Reporl/lmprovement Plan Beaver Valley Power Station EXECUTIVE

SUMMARY

On March 29, 2017 a Medical Services (MS-1) Drill was conducted for the 10-mile Plume Exposure Pathway, Emergency Planning Zone (EPZ) around the Beaver Valley Power Station (BVPS) by the Department of Homeland Security (DRS), Federal Emergency Management

• Agency (FEMA) Region III. The most recent prior MS-1 Drill for this site was conducted March 12, 2015. The purpose of the Beaver Valley Power Station MS-1 Drill was to assess the State and local offsite response organizations preparedness in responding to a radiological medical emergency.

The Drill was held in accordance with FEMA's policies and guidance concerning the evaluation of State and local Radiological Emergency Response Plans (RERP) and procedures.

FEMA wishes to acknowledge the efforts of the many individuals in the State of West Virginia, Hancock County Office of Emergency Management, Brooke County Emergency Management Agency, Weirton Medicfil Center and Brooke County Emergency Medical Services who 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) hows a day to the communities in which they live. Cooperation and teamwork of all the participants was observed during this Drill. This report contains the final evaluation of the MS-1 Drill. The State of West Virginia and local organizations demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Level 1 or Level 2 Findings or Plan Issues as a result of this Drill. 3 Unclassified Radiological Emergenqy Preparedness Program (REPP) After Action Report/Improvement Plan SECTION 1: EXERCISE OVERVIEW 1.1 Drill Details Drill Name Weirton Medical Center 2017 Medical Services Drill Type of Drill Medical Services Drill Date March 29, 2017 Program Beaver Valley Power Station Department of Homeland Security/FEMA Radiological Emergency Preparedness Program

• Scenario Type Radioactive Contaminated/Injured Person 1.2 Planning Team Leadership Christopher N emcheck Technological Hazards Program Specialist Federal Emergency Management Agency One Independence Mall 615 Chestnut Street Philadelphia, PA J 9106 (202) 709-0668 christopher.nemcheck@fema.dhs.gov Sam Paletta Offsite Coordinator First Energy Nuclear Operating Company Beaver Valley Power Station Route 168 Shippingport, Pennsylvama, 15077 724-682-5774 palettas@firstenergycorp.com Robert Jelacic Planning Coordinator/REP Manager WV Division of Homeland Security and Emergency Management State Capitol Complex 1900 Kanawha Blvd., East Charleston, West Virginia, 25305 304-558-5380 ro bert.1.j elacic@wv.gov 4 {. I*

Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Jason Lively Radiological Emergency Preparedness County Coordinator WV Division of Homeland Security and Emergency Management 82 Emergency Drive New Cumberland, WV 2604 7 (304) 545-3058 Jason.k.lively@wv.gov 1.3 Participating Organizations Beaver Valley Power Station Agencies and organizations of the following jurisdictions participated in the BVPS 2017 Medical Services Drill: County Jurisdictions Brooke County Emergency Management Agency Hancock County Office of Emergency Management Private Sector Organizations Brooke County Emergency Medical Service Weirton Medical Center 5 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power 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 radfological planning and response.

FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351and352.

These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the TMI accident inMarch 1979. 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 local government participation in joint exercises with licensees.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

A. *Taking the lead in offsite emergency planning and in the review and evaluation of radiological emergency response plans and 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 of the plans and procedures conducted by State and local goveriunents;

• 1 ** C. Responding to requests bythe U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated December 7, 2015 (Federal Register, Vol. 81, No. 57, March 24, 2016) and; D. Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process: -U.S. Department of Commerce -U.S. Nuclear Regulatory Commission

-U.S. Environmental Protection Agency -U.S. Department of Energy -U.S. Department of Health and Human Ser\rices

-U.S. Department of Transportation

-U.S. Department of Agriculture

-U.S. Department of the Interior -U.S. Food and Drug Administration Representatives of these agencies serve on the Region III Regional Assistance Committee (RAC), which is chaired by FEMA. A Radiological Emergency Preparedness MS-I Drill was conducted on March 29, 2017, 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 BVPS. 6 U ni;lassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station The purpose of this After Action Report is to present the Drill results, and fmdings on the performance of the Off-site Response Organizations (OROs) during a simulated radiological emergency involving a contaminated injured individual.

The Drill was designed to demonstrate and evaluate the responder's knowledge of patient and responder personal protective measures, equipment preparation and employment, and decontamination procedures.

All activities were demonstrated in accordance with the participants' plans and procedures as they would be performed in an actual emergency, except as agreed to in the Exercise Plan and Extent-of-Play Agreement.

The findings presented in this report are based on the evaluations of the Federal evaluator teain, with final determinations made by the FEMA Region III Regional Assistance Committee (RAC) Chairperson and approved by FEMA Headquarters.

These reports are provided to the NRC and participating States. State and local governments utilize the findings contained in these repoqs for the purposes of planning, training, and improving emergency response capabilities.

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

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

• Section 3 of this report entitled Analysis of Capabilities contains detailed Evaluation and Results; a Summary Results of Evaluation; and Criteria Evaluation Summary. Information on the demonstration for each jurisdiction or functional entity evaluated is presented in a jurisdiction-based, issue-only format.

• Section 4 of this report entitled Conclusion, is a description ofFEMA's overall assessment of the capabilities of the participating organizations.

The criteria utilized in the FEMA evaluation process are contained in the following:

• NUREG-0654/FEMA-REP-l, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980;

• Radiological Emergency Preparedness Program Manual, January 2016 2.2 Objectives, Capabilities and Activities The Beaver Valley Power Station MS-1 Drill evaluated by FEMA, was designed to demonstrate that the ORO can transport, transfer, monitor, decontaminate and treat a contaminated/injured person while minimizing any cross contamination during a radiological emergency.

The demonstration included the ability to: A. Respond to a radiation medical emergency following Hancock County Office of 7 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Emergency Management, Weirton Medical Center and Brooke County 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. Condud timely and accurate communications between the hospital and offsite response agencies.

D. Exhibit correct priorities and appropriate techniques in Emergency Medical Services (EMS); transportation of patients; and pre-hospital and hospital emergency care of radioactively

• contaminated patients.

E. Demonstrate inter-agency cooperation between the Ambulance Service/EMS and the hospital.

2.3 Scenario Summary The scenario for this Medical Services Drill consisted of simulated notifications of escalating emergency classification levels at the BVPS from Site Area Emergency to General Emergency.

Subsequent to a release of radiological material the plal).t declared a General Emergency.

During the incident, an evacuee with a vehicle being.decoritaminateq trips over a parking stop, twisting their right knee, but catches themselves before fa],lip_g.9n the potentially contaminated vehicle with their forearms.

The victim has an injured right knee immediately known without X-rays) and is complaining of great pain in the area. The victim's right forearm area is also abraded and bruised. Brooke County Emergency Medical* Services was dispatched to the scene to provide medical support and transport to the nearest MS-1 Hospital.

Upon arrival at Weirton Medical Center, the Radiation Emergency Medical Team met the Emergency Medical Services (EMS) team at the exterior entrance to the Radiation Emergency Area (REA) to receive and treat the patient. The hospital's medical team assessed the patient's condition and surveyed the patient for radiological contamination.

There were contamination readings of 1800 cpm on the right and left forearms.

First decontamination attempt decreases readings to 800 cpm. Second decontamination attempt results in a reading of less than 100 cpm. 8 *-

., Unclassified Radiologi.cal Emergency Preparedness Program* (REPP) After Action Report/Improvement Plan

• Beaver Valley Power *station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Evaluation and Results Contained in this section are the results and :findings of the evaluations of all jurisdictions and locations that participated in the March 29, 2017 Beaver Valley Power Station MS-1 Drill. The Drill was conducted to demonstrate the ability of the ORbs to respond to a potentially contaminated injured person associated with BVPS.

• Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the appropriate Demonstration Criteria contained in the REP Program Manual. Detailed information on the Demonstration Criteria and the Extent-of-Play Agreement are found in Appendix C. ' . . The Drill was conducted and evaluated in accordance with the Radiological Emergency Preparedness Program Manual (January 2016) and NUREG-0654/FEMA-REP-1, Rev. 1. The Demonstration Criteria included:

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

3.a.1-The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures.

Emergency workers periodically and attlie end of mission read their dosii:neters and record * the readings on the appropriate'

exposti.re

record or chart. OROs maintain appropriate record-keeping bf the administtatiori of Kl to emergency workers. . ' 6.d.l-The facility/ORO has the appropriate space, adequate resources, and trained'personnel to provide transport, monitoring; decontamination, and medical services to contaminated injured individuals.

3.2 Summary Results of Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the Demonstration Criteria from the REP Program Manual that were scheduled for demonstration during this Drill by all participating jurisdictions and functional entities.

Drill Demonstration Criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters: (LI) 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 ill 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) Leyel 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. 9 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station (P) Plan Issue: An observed or identified inadequacy in the off-site response organizations' emergency plan/implementing procedures, rather than that of the ORO's performance. (N) Not Demonstrated:

The term applied to the status of a REP Evalilation Area Criterion indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area Criterion, as required in the Extent-of-Play Agreement or at the two-year or eight-year interval required in the FEMA REP Program Manual. * (M) Met: The status of a REP Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the Extent-of-Play Agreement with no findings assessed in the current exercise and no unresolved prior findings.

10 Unclassified Radiological Emergency Preparedness Program (REPP) After' Plan Beaver Valley Power Station Table 3.1 -Summary ofDrill.Evaluation Date: March 29, 2017 Site: Beaver Valley Power Station IZl u :;s (M) Met, (1) Level 1 Finding, (2) Level 2 Finding, (P) Planning Issue u O'.l

--.*.. . .** *. I\ . .-. -*. . .. -. I Mobilization lal Facilities lbl Direction and Control lcl Communications ldl Equipment and Supplies to Support Operations lel M M ...

• *--"* ... : ,,.,, "" --*--' *-* < --__ , .*. c., Emergency Worker Exuosure Control 2al Accident Assessment and Pars for the Emergency Event 2bl PAD decision-making process and coordination for the General Public 2b2 P ADs for disabilities

& access/functional needs people 2cl Radiological Assessment

& Decision making for the Ingestion Pathway 2el Radiological Assessment

& Decision making for Relocation/Reentry/Return 2dl

• ** .. , . .. ,.---, .. -*"--: .. .; .: '----<"'--

.. ---Implementation of Emergency Worker Exposure Control 3al M M Implementation of KIP AD for Institutionalized Individuals/Public 3b2 Implementation of P ADs for disabilities

& access/functional needs people 3cl Implementation of PADS for Schools 3c2 Implementation of Traffic and Access Control 3dl Impediments to Evacuation 3d2 Implementation of Relocation/Reentry/Return Decisions 3fl

___ ,_,, __ : --* .. : ,* --*m-. _,.,. __ .

-" *. .. . *-. * .. .. L .. ... _, .. .:: -* *-* RESERVED 4al Field Team Management 4a2 Plume Phase Field Measurement, Handling, & Analyses ' 4a3 Post Plume Phase Field Measurements

& Sampling 4bl ***

• *-*--'-*** .:. *. .1 I'". . **. -

--

.. , **-* ****: ,. ..::: . .,., -

• -,

.""'l .. '* ;:::,,,,, ,4 **; ____ Activation of the Prompt Alert & Notification System (ANS) 5al RESERVED 5a2 Activation of the Back-up ANS 5a3 Activation of the Exception Area ANS 5a4 Emergency Inforniation

& Instructions to the Public/Media 5bl ...

...

.... '" ; ... :-.. <"" . :;_ ---,, .. l'

'> ... ... , ----.. .. Monitoring, Decontamination, & Registration of Evacuees 6al Monitoring/Decontamination of Emergency Workers and Equipment 6bl Temporary Care ofEvacuees 6cl Transportation/Treatment of Contaminated Injured Individuals 6dl M M 11 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station 3.3 Criteria Evaiuation Summaries 3.3.1 Private Organizations In summary, the status ofDHS/FEMA criteria for the Private Sector Organization&are as follows:

Weirton Medical Center a. MET: l.e.l; 3.a.l; 6.d.l b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLAN ISSUES: NONE e. PRIOR ISSUES -RESOLVED:

NONE f. PRIOR ISSUES -UNRESOLVED:

NONE 3.3.1.2 Brooke County, Brooke County Emergency Medical Service a. MET; l.e.1; 3.a.l; 6.d .. 1 b. LEVEL 1 FINDINGS:

NONE .. ' . c. LEVEL 2 FINDINGS':

NONE d. PLAN ISSUES: NONE e. PRIOR ISSUES -RESOLVED:

NONE f. PRIOR ISSUES -UNRESOLVED:

NONE 12 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station SECTION 4: CONCLUSION The State of West Virginia and private sector organizations, except where noted in this report, demonstrated knowledge of their radiological emergency response plans and procedures and they were successfully implemented during the BVPS MS-1 Drill evaluated on March 29, 2017. Three FEMA evaluators provided analyses of six evaluation criteria.

These analyses resulted in a determination of no Findings, no new Plan Issues, and no unresolved Plan Issues. The Brooke County Emergency Medical Service (BCEMS) demonstrated that necessary equipment and supplies were available to support the treatment of an injured/contaminated patient. EMS personnel prioritized life-saving medical practices over contamination concerns, implemented protective measures through the use of Personal Protective Equipment, regular glove changes, and control of cross contamination.

Appropriate patient assessments were demonstrated as well as regular and ongoing communications with Weirton Medical Center. The Weirton Medical Center successfully demonstrated the mobilization of staff, staffing assignments, issue of dosim,etry and monitoring equipment, and effective use 9f Personal Protective Equipment during the exercise.

The hospital staff effectively responded to communications

from the BCEMS, initiated the set-up and management of a Radiation . Emergency Area, and accepted and successfully injured/cqntaminated patient while administering life-saving medical attention over contamination concerns.

In addition, the medical facility provided security control of the facility including the drop off bay for the patient and overall protective measures for contamination control and prevention of cross contamination.

Based on the results of the Drill and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-l, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this Drill. An Improvement Plan (IP) will not be developed as part of this report.

. Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX A: EVALUATORS

'The following is the list of Evaluators for the Beaver Valley Power Station 2017 MS-1 Drill evaluated on March 29, 2017. The following constitutes the managing staff for the Evaluation:

• Thomas Scardino, DHS/FEMA, Regional Assistance Committee Chairman

• Christopher Nemcheck, DHS/FEMA, Technological Hazards Program Specialist/Site Specialist DATE: March29, 2017 SITE: Beaver Valley Power Station

..... _,,. ___ '.;. '<< * .**--'-' * ',

• *,,,. __ ,

_.i_;;/ *'"*

__ ,;; "'; f' ..

Weirton Medical Center NickBuls FEMARIII Brooke County Emergency Medical Service Lee Torres FEMARIII Brooke County Emergency Medical Service .Christopher Nemcheck FEMARIII *1 °fl:* =,: 14 U nClassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX B: ACRONYMS AND ABBREVIATIONS Acronym Meanin2 BCEMS Brooke County Emergency Medical Service BVPS . Beaver Valley Power 'Station DHS Department of Homeland Security DRD Direct Reading Dosimeter EMS Emergency Medical Services EMT Medical Technician EPZ Emergency Planning Zone FEMA Federal Emergency Management Agency FENOC First Energy Nuclear Operating Company IP Improvement Plan MS-1 Medical Services NPP Nuclear Power Plant NRC Nuclear Regulatory Commission ORO Offsite Response Organization PEMA Pennsylvania Emergency Management Agency PPE Personal Protective Equipment PRD Permanent Record Dosimeter RAC Regional Assistance Committee REA Radioactive Emergency Area REP Radiological Emergency Preparedness RO Radiological Officer SAE Site Area Emergency WMC Weirton Medical Center 15 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX C: EXERCISE PLAN The Exercise Plan (ExPlan) was created as an overall tool for facilitation and implementation of the Beaver Valley Power Station MS-1 Drill and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program Exercise Methodology.

16 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station 2017 WMC MS-1 Evaluated Exercise Exercise Plan 3/29/2017 The Exercise Plan (ExPlan) gives elected and appointed officials, observers, media personnel, and players from participating organizations information they need to observe or participate in the exercise.

Some exercise material is intended for the* exclusive use of exercise planners, controllers, and evaluators, but players may view other materials that are necessary to their performance.

All exercise participants may view the Exercise Plan. 17 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Exercise Name Exercise Dates Scope Mission Area(s) Core Capabilities Threat or I-Iazard Scenario Sponsor EXERCISE OVERVIEW 2017 WMC MS-1 Evaluated Exercise This exercise is a Functional Exercise, planned for five hours at Weirton Medical Center, Weirton, WV. Exercise play is limited to coordination and management of a potentially radiologically contaminated patient. Response Public Health and Medical Services; Environmental Response/Health and Safety; Operational Coordination Demonstrate or Explain the ability to alert, mobilize and activate personnel.

Demonstrate the adequacy of facilities, equipment, displays and other materials to support emergency operations.

Demonstrate the ability to continuously monitor and control emergency worker exposure.

Demonstrate the adequacy of medical facility's equipment, procedures and personnel for handling contaminated, injured or exposed individuals.

Return the facility to pre-emergency conditions (will not be demonstrated, but explained).

Demonstrate the ability to communicate with appropriate locations, organizations and field personnel. (Telephones, cell phones, and/or radios) Demonstrate the adequacy of vehicles, equipment, procedures and personnel for transporting contaminated and/or exposed individuals.

Technological/radiological release The exercise scenario will involve a contaminated patient with a minor injury requiring to be surveyed and decontaminated prior to being medically evaluated at the emergency room. FENOC First Energy Beaver Valley Power Station 18 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Participating Organizations Point of Contact Participants in this exercise will include one federal agency, one state agency, three county level agencies and two private agencies.

Jason Lively, WV Division of Homeland Security and Emergency Management, 82 Emergency Dr., New Cumberland, WV 26047, 304-545-3058, jason.k.lively@wv.gov 19 Unclassified Radiological Emergency Preparedness Prograll) (REPP). After Action Report/Improvement Plan Beaver Valley Power Statio.n GENERAL INFORMAT.ION Exercise Objectives and Core Capabilities The following exercise objectives*in Table 1 describe the expected outcomes for the exercise.

The objectives are linked to core capabilities, which are distinct critical elements necessary to achieve the specific mission area(s). The 'objectives and aligned core capabilities are guided by elected and appointed officials and selected by the Exercise Planning Team. Exercise Objective I Core Capability Demonstrate or Explain the ability to alert,

• Operational Coordinati.on mobilize and activate personnel. . ' Demonstrate the .adequacy of facilities, equipment, displays and other materials to. Public Health and Medical Services . . support emergency operations.

Demonstrate the ability to continuously monitor Environmental Response/Health cind Safety and control emergency worker exposure.

Demonstrate the adequacy of medical facility's equipment, procedures and personnel for

• Public Health* and Medical Services handling contaminated, injured or exposed individuals.

' Return.the facility to pre-emergency conditions

• Erivironillental Response/Health and Safety (will not be demonstrated, but explained).

'11. . . Demonstrate the ability to communicate with appropriate locations; organizations and field * .. ' Operational Coordination personnel. (Telephones, cell phones, and/or radios) .. Demonstrate the adequacy of vehicles, equipment, procedures and personnel for . Public Health and Medical Services transporting contaminated and/or exposed individuals.

Table 1. Exercise Objectives and Associated Core Capabilities REP Manual Criterion I Demonstration Guidance OROs use effective procedures to alert, notify, and mobilize Criterion 1.a.1 emergency personnel and activate facilities in a timely manner. (NUREG-0654/FEMA-REP-1, A.1.a, e; A.3,4; C.1,4, 6; D.4; E.1, 2; G.3.a; H.3, 4) Equipment, maps, displays, monitoring instruments,, dosimetry, Criterion 1.e.1 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) The OROs issue appropriate dosimetry, Kl, and procedures, and manage radiological expos.ure to Criterion 3.a.1 emergency workers in accordance with the plans/procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record keeping of the 20 Uncllissified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station REP Manual Criterion I Demonstration Guidance Criterion 6.d.1 administration of Kl to. emergency workers. (NUREG-0654/FEMA-REP-1, K.3.a, b; K.4) The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (Nl.IREG-0654/FEMAREP-1, F.2; H.10; K.5.a, b; L.1, 4) Table 2. REP Manual Criterion and Demonstration Guidance Participant Roles and Responsibilities The term participant encompasses many groups of people, not just those playing in the exercise.

Groups of participants involved in the exercise, and their respective roles and responsibilities, are as follows: Players. Players are personnel who have an active role in discussing or performing their *regular roles and responsibilities during the exercise.

Players discuss or initiate actions in response to the simulated emergency.

• Controllers.

Controllers plan and manage exercise play, set up and operate the exercise site, and act in the roles of organizations or individuals that are not playing in the exercise.

Controllers direct the pace of the exercise, provide key data to players, and may prompt or initiate certain player actions to ensure*exercise continuity.

In addition, they issue *,exercise material to as required, monitor the exercise timeline, and supervise the . safety of all exercise participants. . .. '* * * ' Simulators.

Simulators.

are control staff personnel who role play organizations or Individuals.

They most often operate out of the Simulation Cell (SimCell), but they may occasionally have face-to-face contact with players. Simulators function semi-independently under the supervision of SimCell controllers, enacting roles (e.g., media reporters or next of kin) in accordance with instructions provided in the* Master Scenario Events List (MSEL). All simulators are ultimately accountable to the Exercise Director and Senior Controller.

Evaluators.

Evaluators evaluate and provide feedback on a designated functional area of the exercise.

Evaluators observe and document performance against established capability targets and critical tasks, in accordance with the Exercise Evaluation Guides (EEGs). Actors. Actors simuiate specific roles during exercise play, typically victims or other bystanders

.. Observers.

Observers visit or view selected segments of the exercise.

Observers do not play in the exercise, nor do they perform any control or evaluation functions.

Observers view the exercise from a designated observation area and must remain within the observation area during the exercise.

Very Important Persons (VIPs) are also observers, but they frequently are grouped separately.

Media Personnel.

Some media personnel may be present as observers, pending approyal by the sponsor organization and the Exercise Planning Team. Support Staff. The exercise support staff fucludes individuals who perform administrative and logistical support tasks during the exercise (e.g., registration, catering).

21 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Exercise Assumptions and Artificialities In any exercise, assumptions and artificialities may be necessary to complete play in the time allotted and/or account for logistical limitations.

Exercise participants should accept that assumptions and artificialities are inherent in any exercise, and should not allow these considerations to negatively impact their participation.

4 Assumptions Assumptions constitute the implied factual foundation for the exercise and, as such, are assumed to be present before the exercise starts. The following assumptions apply to the exercise:

[The exercise is conducted in a no-fault learning environment wherein capabilities, plans, systems, and processes will be evaluated.]

[The exercise scenario is plausible, and events occur as they are presented.]

[Exercise simulation contains sufficient detail to allow players to react to information and situations as they are presented as ifthe simulated incident were real.] [Participating agencies may need to balance exercise play with real-world emergencies.

Real-world emergencies take priority.]

The Weirton Medical Center Radiological E:n;iergency Response Plan assigns radiological monitoring of the patient to the Hospital.

Monitoring of ambulance personnel and vehicle is the responsibility .of the Hospital, if available, and the monitoring decontamination center (Emergency Worker Decontamination Center) if the hospital is not available.

5 Artificialities During this exercise, the following artificialities apply: [Exercise communication and coordination is limited to participating exercise organizations, venues, and the SimCell.]

Players will be pre-staged for the start of the exercise.

The scenario will be driven by the lead controller at the hospital.

Controllers will also be in the field. [Only communication methods listed in the Communications Directory are available for players to use during the exercise.]

22 '

Un classified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station EXERCISE LOGISTICS Safety Exercise participant safety takes priority over exercise events. The following general requirements apply to the exercise:

A Safety Controller is responsible for participant safety; any safety concerns must be immediately reported to the Safety Controller.

The Safety Controller and Exercise Director will determine if a real-world emergency warrants a pause in exercise play and when exercise play can be resumed. For an emergency that requires assistance, use the phrase ["real-world emergency."]

The following procedures should be used in case of a real emergency during the exercise:

Anyone who observes a participant who is seriously ill or injured will immediately notify emergency services and the closest controller, and, within reason and training, render aid. The controller aware of a real emergency will initiate the ["real-world emergency"]

broadcast and provide the Safety Controller, Senior Controller, and Exercise Director with the location of the emergency and resources needed, if any. The Senior Controller will notify the appropriate participants as soon as possible if a real emergency occurs. 6 Fire Safety Standard fire and safety regulations relevant to the Weirton Medical Center will be followed during the exercise.

• 7 Emergency Medical Services The sponsor organization will coordinate with local emergency medical services in the event of a real-world emergency.

8 Electrical and Generating Device Hazards All applicable electrical and generating device safety requirements should be documented prior to the start of the exercise.

9 Weapons Policy All participants will follow the relevant weapons policy for the exercising organization or exercise venue. Site Access .10 Security If entry control is required for the exercise venue( s ), the venue is responsible for arranging appropriate security measures.

To prevent interruption of tlie exercise, access to exercise sites is 23 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station limited to exercise participants.

Players should advise their venue's controller or evaluator of any unauthorized persons. 11 Media/Observer Coordination Organizations with media personnel and/or observers attending the event should coordinate with the sponsor organization for access to the exercise site. Media/Observers are escorted to designated areas and accompanied by an exercise controller at all times. Sponsor organization representatives and/or the observer controller may be present to explain exercise conduct and answer questions.

Exercise participants should be advised of media and/or observer presence.

POST-EXERCISE AND EVALUATION ACTIVITIES Debriefings Post-exercise debriefings aim to collect sufficient relevant data to support effective evaluation and improvementplanning.

12 HotWash At the conclusion of exercise play, controllers facilitate a Hot Wash to allow players to discuss strengths and areas for improvement, and evaluators to seek clarification regarding player actions. and decision-making processes.

All participants may attend; however, observers are not encouraged to attend the meeting. The Hot Wash should n?t exceed 30 minutes. 13 Controller and Evaluator Debriefing

• Controllers and evaluators attend a facilitated C/E Debriefing immediately following the exercise.

During this debriefing, controllers and evaluators provide an overview of their observed functional areas and discuss strengths and areas fot improvement.

14 Participant Feedback Forms Participant Feedback Forms provide players with the opportunity to comment candidly on exercise activities and exercise design. Participant Feedback Forms should be collected at the conclusion of the Hot Wash. Evaluation 15 Exercise Evaluation Guides EEGs assist evaluators in collecting relevant exercise observations.

EEGs document exercise objectives and aligned core capabilities, capability targets, and critical tasks. Each EEG provides evaluators with information on what they should expect to see demonstrated in their functional area. The EEGs, coupled with Participant Feedback Forms and Hot Wash notes, are used to evaluate the exercise and compile the After-Action Report (AAR). 24

('. Unclassified Radiological Emergency Preparedness Program (REPP) After Action Repqrt/lmprovement Plan Beaver Valley Power Station 16 After-Action Report The AAR summarizes key information related to evaluation.

The AAR primarily focuses on the analysis of core capabilities, including capability performance, strengths, and areas for improvement.

AARs also include basic exercise information, including the exercise name, type of exercise, dates, location, participating organizations, mission area(s), specific threat or hazard, a brief scenario description, and the name of the exercise sponsor and POC. Improvement Planning.

Improvement planning is the process by which the observations recorded in the AAR are resolved thiough development of concrete corrective actions, which are prioritized and tracked as a part of a continuous corrective action program. 17 After-Action Meeting The After-Action Meeting (AAM) is a meeting held among decision-and policy-makers from: the exercising organizations, as well as the Lead Evaluator and members of the Exercise Planning Team, to debriefthe exercise and to review and refine the draft AAR and Improvement Plan (IP). The AAM should be an interactive session, providing attendees the opportunity to discuss and validate the observations and corrective actions in the draft AAR/1P. 18 Improvement Plan The IP identifies specific 'corrective actions; assigns them to parties, and establishes target dates for their completion.

it is created by elected and appointed officials from the organizations participating in the exercise, and discussed and validated d1:1ring the AAM. 25 Unclassified Radiological Emergency Preparedness Program (REPP), After Action Report!Impi:ovement Plan Beaver Valley Power Station PARTICIPANT INFORMATION AND GUIDANCE Exercise Rules The following general rules govern exercise play: Real-world emergency actions take priority over exercise actions . . Exercise players will comply with real-world emergency procedures, unless otherwise directed by the control staff. All communications (including written, radio, telephone, and e-mail) during the exercise will begin and end with the statement

["This is an exercise."]

Exercise players who place telephone calls or initiate radio communication with the SimCell must identify the organization or individual with whom they wish to speak. Players Instructions Players should follow certain guidelines before, during, and after the exercise to ensure a safe and effective exercise.

• 19 Before the Exercise Review appropriate organizational plans, procedures, and exercise support documents.

Be at the appropriate site at least 30 minutes before* the. e'Xercise'starts.

Wear the appropnate uniform and/or identification item(s). ' . * * * *

• Sign in when you arrive. If you gain knowledge of the scenario before the exercise, notify a controller so that appropriate actions can be taken to ensure a valid evaluation.

[Read your Player Information Handout, which includes information on exercise safety.] 20 During the Exercise Respond to exercise events and information as if the emergency were real, unless otherwise directed by an exercise controller.

Controllers will give you only information they are specifically directed to disseminate.

You are expected to obtain other necessary information through existing emergency information channels.

Do not engage in personal conversations with controllers, evaluators, observers, or media personnel.

If you are asked an exercise-related question, give a short, concise answer. If you are busy and cannot immediately respond, indicate that, but report back with an answer as soon as possible.

If you do not understand the scope of the exercise, or if you are uncertain about an organization's participation in an exercise, ask a controller.

26 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Parts of the scenario may seem implausible.

Recognize that the exercise has objectives to satisfy and may require incorporation of unrealistic aspects. Every effort has been made by the exercise's trusted agents to balance realism with safety and to create an effective learning and evaluation environment.

All exercise communications will begin and end with the statement

["This is an exercise."]

This precaution is taken so that anyone who overhears the conversation will not mistake exercise play for a real-world emergency.

When you communicate with the Sim Cell, identify the organization or .individual with whom you wish to speak. Speak when you take an action. This procedure will ensure that evaluators are aware of critical actions as they occur. Maintain a log of your activities.

Many times, this log may include documentation of activities that were missed by a controller or evaluator.

21 After the Exercise Participate in the Hot Wash at your venue with controllers and evaluators.

Complete the Participant Feedback Form. This form allows you to comment candidly on emergency response activities and exercise effectiveness.

Provide the completed form to a controller or evaluator.

Provide* any notes or gene.rated from the exercise to your controller or evaluator for

• review and lnclusi'on in the* AAR. * *

• Simulation Guidelines Because the exercise is of limited duration and scope, certain details will be simulated.

The physical description of what would fully occur at the incident sites and surrounding areas will be relayed to players by controllers.

27 Un classified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station 8:00AM 8:00AM 8:10AM 8:25 AM 8:40AM 9:00AM 8:00AM 8:00AM 8:10AM 8:25 AM 8:40AM 9:00AM lO:OOAM 10:00 AM APPENDIX A: EXERCISE SCHEDULE BROOKE COUNTY EMS Exercise begins. Ambulance Company is notified that Beaver Valley Power Station has declared a Site Area Emergency.

Ambulance Company is notified that Beaver Valley Power Station has escalated to a General Emergency.

An ambulance is requested to report to the accident staging area to pick up an injured and potentially contaminated individual.

Ambulance leaves for Weirton Medical Center. AMBULANCE WILL RESPOND WITHOUT SIRENS AND LIGHTS. Ambulance arrives at the hospital and the patient is removed from the ambulance.

The ambulance is sent (simulated) to the Emergency Worker Decontamination Center. WEIRTON MEDICAL CENTER Exercise begins. The hospital is notified that Beaver Valley Power Station has deplared a Site Area, Emergency.

The hospital is notified that the emergency at the Beaver Valley Power Station has escalated to a General Emergency.

The hospital is notified that a person has been injured who is potentially contaminated.

The hospital is notified that the ambulance is enroute with an ETA of20 minutes. The patient arrives at the hospital.

Exercise Ends. Critique.

Times may vary. Starting time is subject to change. 28 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX 8: EXERCISE PARTICIPANTS Federal Emergency Management Agency ,_ .. West Virginia Division of Homeland Security & Emergency Management

• .. 1'> Hancock County Office of Emergency Management FirstEnergy Nuclear Operating Company *:,* ..

,":",,_,;

...

• • : 'J.H * .. : Brooke County Emergency Management Agency Weirton Medical Center *smoke County EMS 29 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX C: CONTAMINATED PATIENT INFO Situation:

Injuries:

A member of the General Public with a vehicle being decontaminated trips over a parking stop, twisting their right knee, but catches themselves before falling on the potentially contaminated vehicle with their forearms.

The victim has an injured right knee (not immediately known without rays) and is complaining of great pain in the area. The victim's right foreatm area is also abraded and bruised. Blood Pressure:

Pulse: Breathing:

Temperature:

Skin: No Nausea Vision: 118/72 100 22 Normal Pale Clear, eyes equal and reactive

• Patient may give own answer on all other queries. Contamination:

A. Contamination readings of 1600 cpm on right upper arm. Removal of shirt sleeve eliminates reading. B. Injured right knee. C. Right forearm bruised and abraded. Contamination of 1800 cpm. First decon attempt decreases readings to 800 cpm. Second attempt results in less than 100 cpm. D. Left forearm contaminated no injury. Contamination 1600 cpm. First decon attempt decreases readings to 800 cpm. Second attempt results in less than 100 cpm. 30

.. ** U ncla ss ified Radiological E m e r gency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station INDICATES AREAS OF CONTAMINATION/INJURY 1600 CPMs on upper right arm sleeve Left forearm is not injured. 1800 CPMs Removal of outer garments eliminates contamination on right upper arm. Right forearm is bruised and abraded. 1800 CPMs Right knee is injured. NO contamination Right and left forearm is reading 1800 cpms on initial reading. First decon attempt decreases reading to 800 cpm. Second decon attempt results in reading of less than 100 cpm. Right knee is injured. No contamination identified. 31

., U ncl assified Radiological Emerge n cy Preparedness Program (REPP) After Ac tion R e p ort/I mp rove m ent P l an Beaver Va ll ey Power S t at i o n APPENDIX D: EXERCISE SITE MAPS Figure D.1: Weirton Medical Center 32

. "' Unclassified Radiological Eme rg ency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX *E: ACRONYMS I Acronym 1 Term U.S __ De.P.artment of Ho r:og@ri_Q E xe rcise Plan --

HSEEP !:!omeland Security_£xercise and Evaluation Prog@m Ma tter W MC Weirton Medical C en t e r 1Y1egif£ll f)ervices Qri e: 33 APR 2 6 2 017 Nuclear Regulatory Commission Headquarters Office of Nuclear Security and Incident Response Document Control Desk U.S. Nuclear Regulatory Commission Washington , D.C. 20555-0001 To Whom It May Concern: U.S. Department of Homeland Security Region III One Independence Mall , 6th Floor 615 Chestnut Street Philadelphia, PA 19106-4404 FEMA Enclosed is the final After Action Report/Improvement Plan for the Beaver Valley Power Station (BVPS) Medical Services (MS-1) Drill that was held on March 30 , 2017. The Washington Hospital and Washington Ambulance and Chair participated in the drill. There were no Level 1 Findings , Level 2 Findings , or Planning Issues identified during the drill. Based on the results of the exercise and a review of the off site radiological emergency response plans and procedures submitted , FEMA Region III has determined the y are adequate (meet t h e planning and preparedness standards ofNUREG-0654/FEMA-REP-l , Revision 1 , November 1980 , as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented , as demonstrated during this exercise.

If you have any questions, please contact Thomas Scardino at (215) 931-5546.

Sincerely , Robert P. Welch Acting Regional Administrator Enclosure www.fema.gov r---:. j. I ' i. f ' Beaver Valley Power Station Medical Services Drill After Action Report/Improvement Plan Drill Date -March 30, 2017 Radiological Emergency Preparedness (REP) Program Published April 21 , 2017

• 1 " ; This page is intentionally blank.

... ( Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Contents *Beaver Valley Power Station Medical Services Drill After Action Report/Improvement Plan Published Date: March 30, 2017 EXECUTIVE Sl]1.\-f]\1ARY

.................................................................................................................

3 SECTION 1: EXERCISE OVERVIEW ....................................................*.....................................

4 1.1 Drill Details ...............................................................................................................................

4 1.2 Planning Team Leadership

...................

• ...................................*..............................................

4 1.3 Participating Organizations

.................

• ........ ...........................................*..............................

4 SECTION 2: DESIGN SUJ.\.IMAR.Y

.......*...**.***.....*....*...*......**.*........****.*.......***.**.*... ...***...............**

6 /2."l Purpose and Design. ...................................................................................................... ..........

6 2.2 Objectives, Capabilities and Activities

..............................*...................................................*

7 2.3 Scenario Summary ..................................................................................................................

8 SECTION 3: ANA!, YSIS OF CAP ABil,JTIES

................................................................................

9 3.1 Evaluation and Results ...........................................................*............*...................................

9 3.2 Summary of Evaluation

...............*.......................................................................... .. 9 3.3 Criteria Evaluation Summaries

...............................................................*............................

12 3.3.1 Private Organizations

..............................................................................

.................

12 SECTION 4: CONCLUSION

.........................................................*....*..................... .....................

13 APPENDIX A: EV AI,UATORS AND TEAM LEADERS .............................................................

14 APPENDIX B: ACRONYMS AND ABBREVIATIONS

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15 APPENDIX C: EXTENT-OF-PLAY AGREEMENT

..............................................*.....................

16 1 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station This page is intentionally blank. 2

.. Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station EXECUTIVE

SUMMARY

On March 30, 2017 a Medical Services (MS-1) Drill was conducted for the 10-mile Plume Exposure Pathway, Emergency Planning Zone (EPZ) around the Beaver Valley Power Station 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 March 13, 2015. The purpose of the Beaver Valley Power Station (BVPS) MS-1 Drill was to assess the State and local offsite response organizations preparedness in responding to a radiological medical emergency.

The Drill was held in accordance with FEMA's policies and guidance concerning the evaluation of State and local Radiological Emergency Response Plans (RERP) and procedures.

• FEMA wishes to acknowledge.the efforts of the many individuals in the Commonwealth of Pennsylvania, Washington County Department of Public Safety Office, Washington Hospital (WH), Washington Ambulance and Chair and Washington County Hazmat, who participated during this Drill. Protecting the public health and safety is the full-time job of some of the Drill participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility as volunteers providing vital emergency services twenty-four (24) hours a day to the communities in which they live. Cooperation and teamwork of all the participants was observed during this Drill. This report contains the final evaluation of the MS-1 Drill. The Commonwealth of Pennsylvania and local organizations demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Level 1 or Level 2 Findings or Plan Issues as a result of this Drill. 3 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan SECTION 1: EXERCISE OVERVIEW 1.1 Drill Details Drill Name Washington Hospital 2017 Medical Services Drill Type of Drill Medical Services Drill Date March 30, 2017 Program Beaver Valley Power Station Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radioactive Contaminated/Injured Person 1.2 Planning Team Leadership Chris N emcheck Technological Hazards Program Specialist Federal Emergency Management Agency One Independence Mall 615 Chestnut Street Philadelphia, PA 19106 (202) 709-0668 christopher.nemcheck@fema.dhs.gov Victor Wilson Bureau of Technological Hazards PA Emergency Management Agency C/O BRP Southwest Regional Office 400 Waterfront Drive Pittsburgh, PA 15222 (412) 442-4223 vicwilson@PA.gov Dave Linkimer Sr. Nuclear Specialist Emergency Preparedness

-Offsite Liaison FirstEnergy-Beaver Valley Power Station (412) 720-2940 dlinkimer@firstenergycorp.com 4 ...

. ' Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station 1.3 Participating Organizations Agencies and organizations of the folf owing jurisdictions participated in the BVPS 2017 Medical Services Drill:

• County Jurisdictions Washington County Department of Public Safety Office Washington County HAZMAT Private Sector Organizations Washington Hospital Washington Ambulance and Chair 5 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power 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 responsibilitjr for all off-site radiological planning and response.

FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351and352.

These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was .established following the TMI accident in March 1979. 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 local government participation in joint exercises with licensees.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following: , A. Taking the lead in offsite emergency planning and in the review and evaluation of radiological emergency response plans and procedures developed by State and local governments; B. Determining whether such plans and procedures can be implemented mi the basis of observation and evaluatiqn of exercises of the plans and procedures conducted by State and . local governments; , * * ' * *i* I ,. C. Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated December 7, 2015 (Federal Register, Vol. 81, No. 57, March 24, 2016) and; D. Coordinating the activities of the following Federal agencies with responsibilities in the radiological planning process: -U.S. Department of Commerce -U.S. Nuclear Regulatory Commission

-U.S. Environmental Protection Agency -U.S. Department of Energy -U.S. Department of Health and Human Services -U.S. Department of Transportation

-U.S. Department of Agriculture

-U.S. Department of the Interior -U.S. Food and Drug Administration Representatives of these agencies serve on the Region III Regional Assistance Committee (RAC), which is chaired by FEMA. A Radiological Emergency Preparedness MS-1 Drill was conducted on March 30, 2017, 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 BVPS. 6 ** .

Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station The purpose of this After Action Report is to present the Drill results, and findings on the performance of the Off-site Response Organizations (OROs) during a simulated radiological emergency involving a contaminated injured individual.

The Drill was designed to demonstrate and evaluate the responder's knowledge of patient and responder personal protective measures, equipment preparation and employment, and decontamination procedures.

All activities were demonstrated in accordance with the participants' plans and procedures as they would be performed in an actual emergency, except as agreed to in the Exercise Plan and Extent-of-Play Agreement. .

• The findings presented in this report are based on the evaluations of the Federal evaluator team., with final determinations rriade by the FEMARegion III Regional Assistance Coillm.ittee (RAC) Chairperson and approved by FEMA Headquarters.

These reports are provided to the NRC and participating States. State and local governments utilize the findings contained in these reports for the purposes of planning, training, and improving emergency response capabilities.

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

'

• Section 2 ofthis report, entitled Design Sum.m.ary, and includes the Purpose and Design, Objectives, Capabilities, and Activities, and the Scenario Sum.m.ary.

• Section 3 of this report entitled Allalysis of Capabilities contains detailed Evaluation and Results; a Sum.m.ary Results of Evaluation; and Criteria Evaluation Sum.m.ary.*

Information on the demonstration for each jurisdiction or functional entity evaluated is presented in a jurisdiction-based, issue-only format.

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

The criteria utilized in the FEMA evaluation process are contained in the following:

• NUREG-0654/FEMA-REP-1, Rev. l; "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980;

• Radiological Emergency Preparedness Program. Manual, January 2016 2.2 _Objectives, Capabilities and Activities The BVPS MS-1 Drill evaluated by FEMA, was designed to demonstrate that the ORO can transport, transfer, monitor, decontaminate and treat a contaminated/injured person while m.inim.izing any cross contarriination during a radiological emergency.

The demonstration included the ability to: A. Respond to a radiation medical emergency following Washington County Department of 7 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley ,Power Station Public Safety Office, Washington Hospital and Washington Ambulance and Chair organization 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 accurate communications between the and offsite response agencies.

D. Exhibit correct priorities and appropriate techniques in Emergency Medical Services (EMS); transportation of patients; and pre-hospital and hospital emergency care of radioactively contaminated patients.

E. Demonstrate inter-agency cooperation between the Ambulance Service/EMS and the hospital.

2.3 Scenario Summary The scenario for this Medical Services Drill consisted of simulated notifications

'of escalating emergency classification levels at the BVPS from Site Area Emergency to General Emergency.

Subsequent to a release of radiological materiaHhe plant declared a General Emergency.

During an evacuation of the BVPS Emergency Planning Zone, EMS personnel arrived at an emergency worker monitoring and decontamination station, . A vyorker, assigned to v:eill,cle decontamination is hit by an openingdoor and knocked down .. The victim has a possible fractured nose, bruised and swollen (not immediately known without X-rays) and is complaining of pain in the right wrist area. 8 ..

.. Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station SECTION 3: ANALYSIS OF CAP ABILITIES 3.1 Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the March 3 0, 2017 BVPS MS'." 1 Drill. The Drill was conducted to demonstrate the ability of the OROs to respond to a potentially contaminated injured person associated with BVPS. Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the appropriate Demonstration Criteria contained in the REP Program Manual. Detailed information on the Demonstration Criteria and the Extent-of-Play Agreement are found in Appendix C. The Drill was conducted and evaluated in accordance with the Radiological Emergency Preparedness Program Manual (January 2016) and NUREG-0654/FEMA-REP-1, Rev. 1. The Demonstration Criteria included:

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

3.a.1-The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the. readings on the appropriate exposure record or chart. OR Os maintain appropriate record-keeping of the' adiniriistratiori of KI to emergency workers. 6.d.1-The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated individuals.

3.2 Summary Results of Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the Demonstration Criteria from the REP Program Manual that were scheduled for demonstration during this Drill by all participating jurisdictions and functional entities.

Drill Demonstration Criteria are listed by number and the demonstration status of the criteria is indicated by the use of the follow.ing letters: (Ll) 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 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. 9 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station (P) Plan Issue: An observed or identified inadequacy in the off-site response organizations' emergency plan/implementing procedures, rather than that of the ORO's performance. (N) Not Demonstrated:

The term applied to the status of a REP Evaluation Area Criterion indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area Criterion, as required in the Extent-of-Play Agreement or at the two-year or eight-year interval required in the FEMA REP Program Manual. (M) Met: The status of a REP Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the Extent-of-Play Agreement with no findings assessed in the current exercise and no unresolved prior findings.

' .,., ' . '*. 10 ..

.. Unclassified Radiological Emergency Preparedness Program (REPP) Mter Action Report/Improvement Plan Beaver Valley Power Station Table 3.1 -Summary of Drill Evaluation Date: 2017-March-30 Site: Beaver Valley Power Station (M) Met, (1) Level 1 Finding, (2) Level 2 Finding, (P) Plaiining Issue Mobilization lal Facilities lbl Direction and Control lcl Communications ldl Equipment and Supplies to Support Operations lel M M Emergency Worker Exposure Control 2al Accident Assessment and Pars for the Emergency Event 2bl PAD decision-making process and coordination for the General Public 2b2 P ADs for disabilities

& access/functional needs people 2cl Radiological Assessment

& Decision making for the Ingestion Pathway 2el Radiological Assessment

& Decision making for Relocation/Reentry/Return 2dl Implementation ofEmergency Worker Exposure Control 3al M M Implementation of KIP AD for Institutionalized Individuals/Public 3b2 Implementation of P ADs for disabilities

& access/functional needs people 3cl Implementation of PADS for Schools 3c2 Implementation of Traffic and Access Control 3dl Impediments to Evacuation 3d2 Implementation ofRelocation/Reentry

/Return Decisions 3fl RESERVED 4al Field TeamManagement 4a2 Plume Phase Field Measurement, Handling, & Analyses 4a3 Post Plume Phase Field Measurements

& Sampling 4b 1 _ _ :'.::_:: ___ ;:-

-'-*;

___ :

_ Activation of the Prompt Alert & Notification System (ANS) 5al RESERVED 5a2 Activation of the Back-up ANS 5a3 Activation of the Exception Area ANS 5a4 Emergency Information

& Instructions to the Public/Media 5bl .I ---* -, .. *-Monitoring, Decontamination, & Registration of Evacuees 6al Monitoring/Decontamination of Emergency Workers and Equipment 6bl Temporary Care ofEvacuees 6cl Transportation/Treatment of Contaminated Injured Individuals 6dl M M 11 I ___ _J Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station 3.3 Criteria Evaluation Summaries 3.3.l Private Organizations

• In summary, the status ofDHS/FEMA criteria for the Private Sector Organizations are. as follows: 3.3.1.1 Washington County, Washington Hospital a. MET: l.e.l; 3.a.1; 6.d.l b. LEVEL 1 FINDINGS:

NONE c. LEVEL 2 FINDINGS:

NONE d. PLANISSUES:NONE.

e. PRIOR ISSUES -RESOLVED:

NONE f. PRIOR ISSUES -UNRESOLVED:

NONE 3.3.1.2 Washington County, Washington Ambulance a.nd Chair a. MET: 1.e.1; 3.a.l; 6.d.l b. LEVEL 1 FINDINGS:

NONE ' ; I c. LEVEL 2 FINDINGS:

NONE , ' d. PLAN,ISSUES:

NONE e. PRIOR ISSUES -RESOLVED:

NONE f. PRIOR ISSUES -UNRESOLVED:

NONE 12 ..

. , Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and private sector organizations, except where noted in this report, demonstrated knowledge oftheirradiological emergency response plans and procedures and they were successfully implemented during the BVPS MS-1 ])rill evaluated on March 30, 2017. Three FEMA evaluators provided analyses of six evaluation criteria.

These analyses resulted in a determination of no Findings, no new Plan Issues, and no unresolved Plan Issues. The Washington Ambulance and Chair (WAC) successfully demonstrated that necessary equipment and supplies were available to support the treatment of an injured/contaminated patient. EMS personnel prioritized life-saving medical practices over contamination concerns, implemented protective measures through the use of Personal Protective Equipment, regular glove changes, and control of cross contamination.

Appropriate patient assessments were demonstrated as well as regular and ongoing communications with Washington Hospital.

The Washington Hospital successfully dempnstrated the mobilization of staff, staffing assignments, issue of dosimetry and monitoring equipment, and effective use of Personal Protective Equipment during the exercise.

The hospital staff effectively responded to communications from the WAC, initiated the set-up and management of a Radiation Emergency Area, and accepted and successfully treated an injured/contaminated patient while administering life-saving medical attention over contamination concerns.

In addition, the medical facility provided security control of the facility including the drop off bay for.the patient and overall protective-measures for contamination control and prevention of cross contamination.

Based on the results of the Drill and a review of the offsite radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this Drill. An Improvement Plan (IP) will not be developed as part of this report. 13

Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report!I_m_,p'--r_ov_em_e_nt_P_Ia_n

__________________

B_ea_ve_r_V_al-'ley'--P_o_w_er_S_ta_tio_n

____ _ APPENDIX A: EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leader for the Beaver Valley Power Station 2017 MS-1 Drill evaluated on March 30, 2017. The following constitutes the managing staff for th,e Evaluation:

• Thomas Scardino, DHS/FEMA, Regional Assistance Committee Chairman

• Christopher Nemcheck, DHS/FEMA, Technological Hazards Program Specialist/Site Specialist DATE: March 30, 2017 SITE: Beaver Valley Power Station _'.> --

• --------:--.. :-

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_:.-*----.'-.:.,,.,. Washington Hospital NickBuls FEMARlII Washington Hospital Chris N emcheck FEMARIII Washington Ambulance and Chair Lee Torres FEMARlII 1:.:, ! . .** . .,i: . '*: 14

. .. . . .* After Action Report/Improvement Plan Unclassified RadiologicarEmergency Preparedness Program (REPP) . . Beaver Valley Power Station APPENDIX B: ACRONYMS AND ABBREVIATIONS BVPS Beaver Valley Power Station DRS De artment of Homeland Securi . EMS Emergency Medical Services EMT Emergency Medical Technician EPZ Emergency Planning Zone FEMA Federal Emergency Management Agency ER Emergency Room

• IP Im rovement Plan MS-1 Medical Services NPP Nuclear Power Plant NRC Nuclear Regulatory Commission ORO Offsite Res onse Organization PEMA Pennsylvania Emergency Management Agency RAC Regional Assistance Committee REP Radiological Emergency Pre aredness WAC Washin on Ambulance and Chair WCDPS WH Washin 15 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station APPENDIXC:

EXTENT-OF-PLAY AGREEMENT The Extent-of-Play Agreement was extracted from the Exercise Plan, which was drafted by the 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 the Pennsylvania Emergency Management Agency. The Exercise Plan was created as an overall tool for and implementation of the BVPS .MS-1 Drill and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program ExerCise . Methodology.

16 * >

Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station APPENDIX 8: EXTENT OF PLAY INFORMATION BEA VER VALLEY POWER STATION WASHINGTON HOSPITAL MEDICAL SERVICES DRILL March 30, 2017 Method of Operation I. The power station and its personnel will not play as active role in the facilitatio;n of this drill. The plant's simulated events, radiation releases, and emergency classifications will be injected by off-site controllers.

A pre-approved scenario will be used. 2. The Pennsylvania Emergency Management Agency (PEMA), Area Offices (Harrisburg Central Area and Indiana Western Area) will not be activated as part of this drill. The Exercise Coordinator will provide pre-drill coordination and observe drill activities.

3. First Energy Nuclear will participate as a Controller in this drill. 4. Washington County Department of Public Safety Office will participate in this drill. 5. Controllers will be supplied by PEMA. Controllers are not players and will provide injects and information to initiate and stimulate drill play by providing radiological readings during the monitoring of personnel.

Live radioactive sources will only be used to perfopn operational checks of radiological monitoring instruments.

6. PEMA staff and qualifie_d county emergency management personnel will be assigned to key ' locations for the purpose of observing, noting response actions and conditions, and recording observations for future use. Observers will not take an active part in the proceedings, but will interact with staff members to the extent necessary to fulfill their observer responsibilities.

Coaching of players is not permitted, except as appropriate to provide training to participants awaiting a re-demonstration.

7. Department of Homeland Security (DRS), Federal Emergency Management Agency (FEMA), Radiological Emergency Preparedness Program (REPP) Evaluators:

FEMA Evaluators will be present at designated demonstration locations.

8. Drill activities are scheduled to commence on or about 0800, March 30, 2017 and continue until the participants have completed the drill objectives and demonstrated the Exercise Evaluation Criteria.

9. Participants and agencies will Stand Down when the Controllers 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. 17 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station. 10. An emergency plan is drafted to address the generally expected conditions of an emergency.

Not everything in the emergency plan may be applicable for a given scenario.

The main purpose of an emergency plan is to assemble 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 talce 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 modification 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, it should be noted so that the plan can be modified and the appropriate negative assessment corrected.

• 11. During the drill any activity that is not satisfactorily demonstrated may be demonstrated by the participants during the exercise, provided it does not negatively interfere with the exercise.

Refresher training may be provided by the players, observers, and/or controllers.

Evaluators are not permitted to provide refresher training.

Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators.

PEMA may advise the RAC Chair prior to initiating any re-demonstrations.

It is permissible to extend the demonstration window, within reason, to accommodate the demonstration.

Activities corrected from a re-demonstration will be so noted. Objectives . . . A. Demonstrate the ability, to .tp, fl following the procedures of Washington County Department of Public Safety, Washington Ambulance

& Chair I EMS and Washington Hospital.

• B. Demonstrate timely and accurate communications between the hospital and offsite response agencies. (Telephones will be used in lieu of radios whenever possible to limit the potential misinterpretation of the drill as an actual event.) C. Demonstrate correct priorities and appropriate techniques in EMS, transportation of patients and pre-hospital and hospital emergency care of radioactively contaminated patients.

D. Demonstrate inter-agency cooperation between the Ambulance Company I EMS and the Hospital.

18 . ' .

. . Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Extent of Play Evaluation Area 1-Emergency Operations Management Sub-Element Le-Equipment and Supplies to Support Operations Intent Beaver Valley Power Station This sub-element is derived from NUREG-0654 I FEMA-REP-1, which requires that Offsite Response Organizations (ORO) have emergency equipment a,nd supplies adequate to support the emergency response.

Criterion 1.e.l: Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG--0654 I FEMA-REP-1, H.7,10; 1.7, 8, 9; J.10.a, b, e, J.11, 12; K.3.a; K.5.b). Extent of Play Assessment ofthis Demonstration Criterion is accomplished primarily through a baseline evaluation and subsequent periodic inspections.

A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned tole in the'ORO's emergency operations plans. Use of maps and other displays is encouraged.

For non-facility based operations, the equipment and, supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability de'scribed.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows: KI: Responsible OR Os must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans I procedures, members of the general public (including transients) within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make Kl available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans I procedures).

The plans I procedures must include the forms to be used for documenting emergency worker ingestion of KI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined KI in advance. ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. Available supplies of KI must be within the expiration date indicated on KI bottles or blister packs. 19 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station As an alternative, the ORO may produce a letter from a certified private or State laboratory indicating that the Kl supply remains potent, in accordance with U.S. Pharmacopoeia standards.

Dosimetry:

Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to perform an ORO mission. In addition, OROs must demonstrate provisions to make dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans I procedures).

Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans I procedures.

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance.

The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary.

Civil Defense Victoreen Model 138s (CD V-138s) (0-200 rnR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary.

This leakage testing will be verified during the exercise, through documentation submitted in the ALC and/or through an SAV. Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer's instructions and be verified during the exercise, through documentation submitted in the ALC and/or through an SA V. '*" Monitoring Instruments:

All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation must be calibrated annually.

Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer.

A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings.

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

• For FMTs, the instruments must 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 I exposure control of team members and detection of activity on air sample collection media, consistent with the intended use of the instrument and the ORO's plans I procedures.

An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than lR/hr) and for high-range instruments when available.

If a source is not available for a high-range instrument, a procedure must exist to operationally test the instrument before entering an area where only a high-range instrument can make useful readings.

In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s).

The monitor(s) must conform to the standards set forth in the Contamination 20 . .

I f Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Monitoring Standard for a Portal Monitor Used for Emergency Respor,zse, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

All activities must be based on the ORO's plans I procedures and completed as they would be in an actual emergency, linless noted above or otherwise specified in the Extent-of-Play Agreement.

State Negotiated Extent of Play: Ambulance crews are not trained or equipped to Operate or carry radiological monitoring equipment.

In accordance with the PEMA SOP Annex E, Appendix 5 "Radiological Exposure Control" (March 2002), ambulance crews operating outside the 10 mile Emergency Planning Zone are considered "Category C" emergency workers; therefore, they are only required to implement protective measures consistent with protection against blood-borne pathogens; i.e., long sleeved garments, trousers, impermeable gl<?ves, and surgicalmasks. "Category C" emergency worker dosimetry issue consists of one permanent reading dosimeter per worker. Ambulance crews are* provided additional dosimetry if they are tasked with entering the 'i 0-mile EPZ.

• Hospital personnel are also considered "Category C" emergency workers and will conform to PEMA SOP protective measures at minimum .. Direct Reading Dosimeters may be issued individually; however, an Area Kit will be established in the Radiation Emergency Area (REA). Individual PRDs will be issued by the hospital.

Radiological Survey Instruments are calibrated per manufactures recommendations.

Outstanding Issues: None 21 J Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Evaluation Area 3-Protective Action Implementation Suh-Element 3.a-Implementation of Emergency Worker Exposure Control Intent This Sub-element is derived from NUREG0654 I FEMA-REP-1, which requires that OROs have the capability to provide for the following:

distribution, use, collection, and processing of reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate

frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or procedure for emergency workers . ' to incur radiation exposures in excess of the PA Gs, 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 manage radiological exposure to emergency workers in accordance with the plans I procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to emergency workers. (NUREG-0654 I FEMA-REP-1, K.3.a, b; K.4) Extent of Play . ) ..... *,._,' -* ... * ... ,'_!. ; ,* Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise.

Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

OR Os 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 of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation ofTEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans I procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans I procedures.

If supplemental resources are used, they must be provided 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 followed 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 I procedures.

OROs must demonstrate the actions described in the plans I procedures by determining whether to replace the worker, authorize the worker to incur additional exposures, or 22 J 4 .. Unclassified Radiological Emergency Preparedness Program (REPP) After Action Repo_rtllmprovement Plan Beaver Valley Power Station take other actions. If exercise play does not require emergency workers 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 (e.g., written procedures and/or co-workers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. In such cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimeter worn by the team leader. Emergency workers assigned to exposure rate fixed facilities (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry.

Individuals authorized by the ORO to re-enter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with completing their missions.

OR Os may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers performing various services (e.g., lifesaving, protection of valuable property, all activities).

OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent OR Os must demonstrate the capability to accomplish distribution of Kl to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of

• emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. Ingestion of KI recommended by the designated ORO health official is voluntary.

For evaluation purposes, the actual ingestion of KI shall not be performed.

OROs must demonstrate the capability to formulate and disseminate instructions on using Kl 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. This can be accomplished by an interview with the evaluator.

All activities must be based on the ORO's plans I procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

State Negotiated Extent of Play:

• Demonstrate appropriate procedures and equipment to manage radiological exposure to staff .

• 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 provided to address exposure limits and procedures to replace personnel approaching limits and how permission to exceed limits is obtained At any time, players may ask other players or supervisors to clarify radiological information.

In Pennsylvania, 23 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver VaJley Power Station emergency workers outside the EPZ do not have turn-back values. Standard_

issue of dosimetry and potassium iodide for each category of emergency worker is as follows: Category A: 1 P RD, 1 DRD, and 1 unit of Kl Category B: 1 P RD and 1 unit of Kl Category C: 1 P RD All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP) will make the dosimetry equipment (and Kl, as appropriate) available for inspection by the Federal Evaluator.

Simulation P RDs with mock serial numbers may be used. Outstanding Issues: None 24

, . . . Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station Evaluation Area 6-Support Operation I Facilities Sub-Element 6.d-Transportation and Treatment of Contaminated Injured Individuals Intent This Sub-element is derived from NUREG0654

/ FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Criterion 6.d.l: The facility I ORO has the appropriate space, adequate resources, and trained personnel to provid". transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG0654

/ FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4) Extent of Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, or drills. FEMA has determined that these capabilities have been enhanced and consistently demonstrated as adequate; therefore, o:ffsite medical services drills need only be evaluated biennially.

FEMA will, at the request of the involved ORO, continue to evaluate the drills on an annual basis. If more than two medical facilities and transportation providers are designated as prim'!Ty or backup, they are also evaluated biennially.

Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the victim. OROs must demonstrate the capability to transport contaminated injured individuals to medical facilities.

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OR Os may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility.

It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "victim(s)" to the medical facility.

This option is used in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests of the community.

Normal communications between the ambulance I dispatcher and the receiving medical facility must be demonstrated.

If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available.

In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, ifrequired, or whom to contact for such information.

Monitoring of the victim may be performed before transport or en route, or may be deferred to the medical facility.

Contaminated injured individuals transported to medical facilities are monitored 25 Unclassified Radiological Emergency Preparedness Program (REPP) After Action Report/Improvement Plan Beaver Valley Power Station as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s).

However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored.

Before using monitoring instruments, the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

All monitoring activities must be completed as they would be in an actual emergency.

Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility.

The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment.

Medical facilities are expected to have at least one trained physician and one trained nurse to perform and supervise treatment of contaminated injured individuals.

Equipment and supplies must be available for treatment of contaminated injured individuals.

The medical facility must demonstrate the capability to make decisions on the need for decontamination of the individual, follow appropriate decontamination procedures, and maintain records of all survey measurements and samples taken. All procedures for collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator.

Waste water from decontamination operations must be handled according to facility plans I procedures.

All activities must be based on the ORO's plans I procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

State Negotiated Extent of Play: Demonstrate that the facility has the appropriate space, adequate resources and trained personnel to provide monitoring, decontamination and medical services to contaminated/injured individuals.

Demonstrate the ability to transport contaminated I injured individuals while using ALARA principles.

The Washington Ambulance

& Chair will pick-up a pre-staged simulated contaminated I injured victim. Outstanding Issues: None 26 <:' *I. ..