ML19190A094

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Pennsylvania Geisinger Bloomsburg Hospital After Action Report/Improvement Plan
ML19190A094
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 06/17/2019
From:
US Dept of Homeland Security, Federal Emergency Management Agency, US Dept of Homeland Security, Region III
To:
Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML19190A094 (23)
v • d • e


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.Susquehanna Steam Electric Station Pennsylvania Geisinger Bloomsburg Hospital After Action. Report/Improvement Plan Drill Date - May 22, 2019 Radiological Emergency Preparedness (REP) Program

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Published June 17, 2019

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Susquehanna Steam Electric Station Susquehanna Steam Electric Station (SSES)

Medical Services Drill After ActJon Report/Improve111;ent Plan

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Published Date: June 17, 2019 Contents EXECUTIVE

SUMMARY

...............................................................................*.......*..................... 5 e~ SECTION 1: EXERCISE OVERVIEW ...................................................................................... 5 1.1 D.rill Details ..*****.*..*****.*....*..*....*....***.*.***..'.*....*..****.*..**...............**.*..*****.*****...........*......*.....*. 5 1.2 Planning Team Leadership ............*.*................................*.................................................. 6 1.3 Participating Organizations................................................................................................. 6 SECTION 2: DESIGN

SUMMARY

............... '! ********************** .-******************************************************** 8 2.1 Purpose and Desig11 *****************~*********~**.*********************** ..********************************************************* 8 2.2 Objectives, Capabilities and Activities ................................................................................ 9 2.3 Scenario Summ.ary ............................................................................................................... 9 SECTION 3: ANALYSIS OF CAPABil.JTIES ..........................................................*................. 11 3.1 Evaluation and Results ....................................................................................................... 11 3.2 Summary Results of Evaluation ........................................................................................ 11 3.3 Criteria Evaluation Summaries......................................................................................... 13 3.3.1 Private Organizations ................................................................. ~ ........................... 13 SECTION 4: CONCLUSION .................................................................;..................................... 14 APPENDIX A: EVALUATORS AND TEAM LEADERS .......................................................... 15

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APPENDIX B: ACRONYMS AND ABBREVIATIONS............................................................. 16 APPENDIX c:*EX'fENT-OF-PLAY AGREEMENT ................................................................... 0 3

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After Action Report/Improvement PJan UndassJfled Radiological Emergency Preparedness Program (REPP)

Susquehanna Steam Electric Station f'9'

  • This page is intentionally blank.

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  • ~ Action Report/lniprovement Plan Undasslfled Radiological Emeigeney Preparedness Program (REPP)

Susquehanna Steam Electric Station

  • EXECUTIVE

SUMMARY

On May 22, 2019, a Medical Services (MS-1) Drill was conducted for the 10-mile Plume Exposure Pathway, Emergency Planning Zone (EPZ) around the Susquehanna Steam Electric Station by the Department of Homeland Security (OHS), Federal Emergency Management Agency (FEMA) Region III. The most recent prior MS-1 Drill for this site was conducted on May 24, 2017.

The purpose of the Susquehanna Steam Electric Station (SSES) MS-1 Drill was to assess the State and local offsite response organizations' preparedness in responding to a radiological medical I*~

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.

1

- FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania, Golumbia County Emergency Management Agency, Geisinger Bloomsburg Hospital, and the Greater Columbia Medical Transport Service were evaluated during this Drill.

Protecting th~ 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 thls 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 I or Level 2 Findings or Plan Issues as a result of this Drill.

Section 1 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 of FEMA 's overall assessment of the capabilities of the participating organizations.

SECTION 1: EXERCISE OVERVIEW 1.1 Drill Details Drill Name Geisinger Bloomsburg Medical Center 2019 Medical Services Drill 5

After Action Reporl/Jmprovcmcnt Plan Unclassified Radiological Emergency Preparedness Program (REPP)

Susquclmnna Steam Electric Station, Type of Drill Medical Services Drill Date May 22, 2019 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radioactive Contaminated/Injured Person 1.2 Planning Team Leadership Kathy Duran Technological Hazards Program Specialist Federal Emergency Management Agency One Independence Mall 615 Chestnut Street Philadelphia, PA 19106 (215) 931-45702 I<.athryn.duran@fema.dhs. l!ov Robert Mull Commonwealth of Pennsylvania Planner/Lead Controller Bureau of Technological Hazards PA Emergency Management Agency 1310 Elmerton Avenue Harrisburg, PA i 711 O (717) 651-2735 robemull@pa.gov Megean Brown Senor E1rtergency Preparedness Coordinator - Offsite Lead Talen Energy LLC 769 Salem Boulevard Berwick, PA 18603 .

(570) 542-3601 Megean.Brown@TalenEnergy.com t"°".

1.3 Participating Organizations Agencies and organizations of the followingjurisdictions participated in the SSES 2019 Medical Services Drill:

State Jurisdictions

  • Columbia County Emergency Management Agency Private Sector Organizations
  • Geisinger Bloomsburg Hospital 6
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After Action Report/Improvement Plan Undasdfled Radiological Emergency Preparedness Program (REPP)

Susquehanna Steam Electric Station

  • Greater Columbia Medical Transport Service
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After Action Report/Improvement Plan Unclassified Radiological ~ergency Preparedness Program (REPP)

Susquehanna Steam Electrle Station SECTION 2: DESIGN

SUMMARY

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

FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island 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. Taldng 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. Detennining 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 governments; 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 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 Services U.S. Department of Transportation U.S. Department of Agriculture

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- 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 May 22, 2019, to assess the capabilities of State and local emergency preparedness organizations in implementing their radiological emergency response plans and procedures to protect the public health and safety during a radiological emergency involving SSES.

The purpose of this After-Action Report (AAR) is to present the Drill results, and findings on the performance of the Off-site Response Organizations (OROs) during a simulated radiological 8

  • After Acdon Report/hnprovement Plan

Susquehanna Steam Electric Stadon 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 (BOP) Agreement.

The findings presented in this report are based on the evaluations of the Federal evaluator team, 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 Nuclear Regulatory Commission (NRC) and participating States. State and local governments utilize the findings contained in these reports for the purposes of planning, training, and improving emergency response capabilities.

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 SSES 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 the Columbia County Emergency Management Agency, Geisinger Bloomsburg Hospital, and the Greater Columbia Medical Services Medical Transport Service Emergency Medical Services procedures.

B. Monitor for radiation contamination and uptake, and to validate pers0'1S providing these

.~ services are adequately prepared to handle contaminated individuals.

C. Conduct 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; an<l pre-hospital and hospital emergency care of patients contaminated with radiation.

E. Demonstrate inter-agency cooperation between the Greater Columbia Medical Transport Service, and the Geisinger Bloomsburg Hospital.

2.3 Scenario Summary The scenario began with a Site Area Emergency Classification Level (ECL) at the Susquehanna Steam Electric Station (SSES) at 0900. At 0910, a follow-on call was received at Geisinger Bloomsburg Hospital from the Columbia County 911 Center of an escalation to General 9

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After Action Report/Improvement Plan UndllSlilfled Radiological Emergency Preparedness Program (REPP)

Susquehanna Steam Electric Station Emergency ECL at SSES, and to inform them that the Greater Columbia Medical Transport Service was preparing to transport a potentially contaminated injured patient to their site.

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Susquehanoa Steam Electric Station SECTION 3: ANALYSIS OF CAPABILITIES 3.lEvaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the May 22, 2019 SSES MS-I Drill. The Drill was conducted to demonstrate the ability of the OROs to respond to a potentially contaminated injured person.

Each jurisdiction and functional entity were evaluated on the basis of their demonstration of the appropriate Demonstration Criteria contained in the REP Program Manual. Detailed infonnation 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, Kl, 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. OROs maintain appropriate record-keeping of the administration of KI to emergency workers. '

6.d.1- The facility/ORO has the appropriate space, adequate resources, and trained personnel_

to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

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

  • the following letters: .
  • (Ll) Level 1 Finding: An observed oridentified inadequacy of organizational

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performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures cap be taken in event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant.

  • (L2) Level 2 Finding: An observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.
  • (P) Plan Issue: An observed or identified inadequacy in the off-site response organizations' emergency plan/implementing procedures, rather than that of the ORO's performance. .
  • (N) Not Demonstrated: The tenn 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 11

After Actiim Report/Improvement Plan_

Unc)Jlssified Radiological *Emergency Preparedness Program (REPP)

Susquehanna Steam El!!ctric Station required in the Extent-of-:Play Agreeme.rtt With no :findings assesse.d in the current exercise and no unresolved prior-findings. .

Table 3 .1 - Sumn:iary of Drill Evaluation Date: 2019 May 22 Site: SSES tI:

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(M) Met, (1) Level 1 Finding, (2) Leyei 2 Finding, (P) Planning Issue c:,

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Mobilization'*

rai Facilities J)iI:ection and Control Communications ,

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Equipment and Suoolies to Suooort Operations .. lel M M EmergencvWorker :Exposure Control. 2a1 Accident Assessment and Pars for the Emergencv*Event 2bl PAD decision-making process and coordina'tion for the General Public 2b2 p Abs for. disabilities &access/ftinctiorial needs oeoole: 2d Radiologfoal Assessment & Decision-making for the Ingestion Pathway 2el Radiological Assessment & Decision making for Relocatioi.1/Reerttry/Return 2dl

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Iri:iolementation of Emeniertcv Worker Exposure *control 3al M M lmolementation ofKI PAD for Institutionalized Individuals/Public 3b2.

lmolementation of PADs for disabilities & access/functional needs peoole 3cl lmolementation of PADS for Schools . 3c2 lmolementation of Traffic and Access.Control ,, 3dl Impediments to Evacuation 3d2.

Implementation ofRelocation/Reentry/RetumDecisions 3fl

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.RESERVED. 4al Field Team Management 4a2 Plume Phase Field Measurenient;Hartdlirig, & Analyses. 4a3:

Post Plume Phase Field Measurements & Sainolirig 4bl

tmeigencyNotiticatien.and'.ll.iiblic.fnforniation. -- ... _* ~ .. -** ...

Activation of the Prompt Alert & Notification System JANS)

RESERVED 5al sa1 * ('°".

Activation of the Back-uo ANS 5a3 Activation of the.Exceotion Area ANS *5a4 Emerii:encv lrifonnation & Instructions to the Public/Media . "5bl

S_und0rtOoerations!Eaci1it1es . . . .. . . . . . .. _

Momtormg. Decontamination. &Registration ofEvacuees .. 6al Monitorin!!/Decontamination .ofEmergency Workers and -Equipment 6bl Temocirarv Care ofEvacuees 6cl Transportatiol)l'Treatment c:ifCcihtaminated Irijured in4iviciuals 6dl M M 12

Susquehanna Steam Electric Station 3.3 Criteria Evaluation Summaries 3.3.1 Private Organizations In summary, the status of DHS/FEMA criteria for the Private Sector Organizations are as follows:

3.3.1.1 Geisinger Bloomsburg Hospital

a. Met: 1.e.l; 3.a.1; 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
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3.3.1.2 Greater Columbia Medical Transport Service

a. Met: 1.e.1; 3.a.1; 6.d.1
b. Level I Findings: NONE
c. Level 2 Findings: NONE
d. Plan Issues: NONE
e. Prior Issues - Resolved: NONE
f. Prior Issues - Unresolved: NONE

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After Action Report/Improvement Plan*

Unclassified Radiological Emergency Preparedness Program (REPP)

Susquehanna Steam Electric Station

  • sECTION 4: CONCLUSION The Commonwealth of Pennsylvania 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 SSES MS-1 Drill evaluated on May 22, 2019.

Two 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 Greater Columbia Medical Transport Service Paramedics successfully demo~ted that necessary equipment and supplies were available to support the treatment of an injured/contaminated patient, and prioritized life-saving medical practices over contamination concerns, implemented protective measures through the use of Personal Protective Equipment ~*

(PPE), regular glove changes, and control of cross contamination. Appropriate patient assessments were demonstrated as well as regular and ongoing communications with Geisinger Bloomsburg Hospital.

Geisinger Bloomsburg Hospital successfully demonstrated the mobilization of stat'( 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 Greater Columbia Medical Transport Service, initiated the set-up and management of a Radiation Emergency Area, and accepted and successfully treated an injured/co.,.taminated 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 ID has detennined they are adequate (meet the planning and prep~edness 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. ,....

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°"'I Unclassified Radioloj!ical Emergency Preparedness Program (REPP)

After Action Reportlimproyement Plan Susqueh_ann!I Stea_m Electric S_tation

  • APPENDIX A:

. - - . . ... . . -EVALUATORS

- -*.*. .. '. . . . AND TEAM LEAOERS The following is the list of Evaluators and Tea111 Lead_erl? for th~ SSES 20l9 MS.;1 Drill evaluated on May 22, 2019. The following: constitutes tl;ie imuiaging staff for the Evaluation: * *

  • Thomas Scardino, DHS/FEMA, Regional Assistance Committee Chairman
  • Kathy Duran, DHS/FEMA, Senior Emergency Management Specialist, L~ad Evaluator * * * * ** * * * -

DATE: May 22, 2019

  • ""' SITE: Susquenna Steam Electric Station

. -EVA:t:0ATCR

- AGENCY***

Oei~inger J3lo.omsburg_ Medical _Center Kathy Duran FEMA*Rlll

---+-------'--------1-------,-----1 Gre~ter Colu,.ubia Medical Sei:yice rrapspo~ Jennifer Greene FEMA RHI

---,,-'--_..,_,----,.---------,-,,~----e---~

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After Action Report/Improvement Plan Unclassified Radiological Emergency Preparedness Program (REPP)

Susquehanna Steam Electric Station APPENJ)IX B: ACRONYMS AND ~BREVIATIONS Acronym Mtjaning AAR After Action Report ALARA. AsLow Aslleasonaply Achievable ALC Artnual Letter of Certification ANS Alert and Notification Syst~m BRP Bureau of Radiation Protection  ;

DHS _Department of Homeland Security DRD Direct Reading Dosimeter EMS Emergency Medical Services EOP EPZ Extent of Plav Em~rgency Planning Zone

("",

FEMA Federal Emergency Management Agency

'.FMT" Field

- Mi:initoringTeam GE General Emergency

_IP Improvement Pl~

KFCA Kingston Fireman's Community Ambulance KI Potassium Iodide MS-1 Medical Servic~s NRC Nuclear Re!!i.Ilatory Commission ORO Offsite Response Organization PEMA Pennsylvania Emergency Managemei1t Agency PPE Personal Protective Equipment PRD Permanent Record Dosimeter RAC Regional Assistance Committee REA Radiation Emergency Area REP Radiological Emergency Preparedness RERP Radiological Emergency Preparedness Program SAE Site Area Emergency t".

  • SOP _Standard Operating Procedure SAV Staff Assistance Visit SSES Susqueh~a Steam Electric Station 16 to-

After Action Report/Improvement Plan Susquehanna Steam Eleetrlc Station APPENDIX C: EXTENT-OF-PLAY AGREEMENT The Extent-of-Play Agreement was extracted from the Exercise Plan, which was drafted by Pennsylvania Emergency Management Agency, and is included in this report as an Appendix. The Extent-of-Play was negotiated and agreed upon by FEMA Region III, and Pennsylvania Emergency Management Agenc~.

The Exercise Plan was created as an overall tool for facilitation and implementation of the SSES MS-1 Drill and to integrate the concepts and policies of the Homeland Security Exercise Evaluation Program with the Radiological Emergency Preparedness Program Exercise M.ethodology. * *

  • IQ\.

GEISINGER BLOOMSBURG MEDICAL SERVICES EXERCISE Extent of Play Agreement Eval~ation Area I-Emergency Operations Management Sub-element 1.e - Equipment and Supplies to Supp~rt Operations

'INTENT This sub-el~ent derives from NUREG-0654 / FEMA-REP-1, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.

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

Assessment/ Extent-of-Play Assessment of this 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 role in the ORO's emergency operations plans. Use of maps and other displays is e~ 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 (~.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows:

KI: Responsible OROs 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/ procedures, members of the general public (including transients) within the plume pathway EPz: In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special o*

Unclassified Radiological Emergency Preparedness Program (REPP)

  • After Action Report/Improvement Plan Susquehanna Steam Electric Station Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/ procedures. The plans/ 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.

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 bottl~ or blister packs. As an alternative, the ORO may produce a letter from a certified private or state

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laboratory indicating that the KI supply remains potent, in accordance with U.S. Phannacopoeia standards.

Dosimetry: Sufficient quantities of appropriate direct!"readit!g and permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to perform art 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 / 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 /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 (CDV-138s) (0-200 mR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly an<l replaced when necessary. This leakage testing will be verified during the exercise, through documentation submitted in the (Annual Letter of Certification (ALC} and/or through a Staff Assistance Visit (SAV).

Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer's instructions and be verified during the exercise, through documentation submitted in the ALC and/or through an SAV. ,...

Monitoring Instruments: All instruments 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 recomniendation 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. hi 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 Field Monitoring Teams (FMTs), the instruments must be capable of measuring gamma 1

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After Action Report/Improvement Plan Susquehanna Steam l(ectrfc: Station exposure rates and detecting beta radiation. These instruments must be capable of measuring a range of activity and exposure, including radiological protection/ 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/ procedures. An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than 1R/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

  • Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March
  • /2\ 1995) or. in accordance with the manufacturer's recommendations.

Mutual Aid Resources: If the incoming resources arrive with their own equipment (i.e., monitors and/ or dosimetry) they will be evaluated by REP Program standards. FEMA will not inventory equipment that is not part of the REP Program. If an agency has a defined role in the REP Plan, they are subject to the planning process and standards, as well as the guidance of this Manual.

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

State Negotiated Extent ofPlav:

. In accordance with PEMA standard operating procedures ambulance crews operating outside the JO-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 gloves, and surgical masks.

Ambulance "Category C" emergency workers are not issued dosimetry or Kl unless they are tasked to enter the I 0-mile EPZ. At that time, the county will issue what is needed.

. Hospital personnel are also considered "Category C" emergency workers and will conform to

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PEMA Standard Operating Procedure (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.

Evaluation Area 3-Protective Action Implementation Sub-element 3.a - Implementation ofEmergency Worker Exposure Control INTENT .

This Sub-element is derived from NUREG-0654 / FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency

  • workers to incur radiation exposures in excess of the PAGs; and the capability to provide Kl for 2

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Unclassified Radiological Emergency Preparedness Program {REPP)*

  • After Action ReporUimprovement Plan Susquehanna Steam Elecbic Station emergency workers, aiways applying the as low as is reasonably,achievable (ALARA) principle as appropriate.

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

Emergency workers periodically and at the end ofeach mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain t;zppropriate record-

. keeping ofthe administration ofKl to emergency workers.(NUREG-0654 I FEMA~REP-1, K3.a,

~K-0 .

Assessment/ Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial or tabletop exercise. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

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OROs must demonstrate the capability to provide emergency workers {including supplemental resources) with the appropriate direct-reading and pennanent 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 / procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as *specified in the ORO's plans / procedures. if supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological

  • exposure control.

During a plume phase exercise, emergency workers must demonstrate the procedures to be 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 /

procedures. OROs must demonstrate the actions described in the plans / procedures by detennining whether to replace the worker, authorize the worker to incur additional exposures, or ,-.

  • 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 detennine their knowledge of whom to contact in case authorization is needed, and at what exposure levels. Wo.rkers may use any available resources {e.g., written procedures and/or coworkers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. In such cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimeter {ORD) worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed 3

(A,

After Action Report/Improvement Plan Susquehanna Steam Electric Station in the work area). Each team member must still have his or her own permanent record dosimetry.

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

OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers performing various services (e.g., life-saving, protection of valuable property, ~1 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 life-saving and/or protection.of valuable property may require an urgent response.

  • ~ OROs must demonstrate the capability to accomplish distribution of KI to 'emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they .

did so. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be perfonned. OROs must demonstrate the capability to fonnulate and disseminate instructions on using KI for those advised to take it.

Emergency workers must demonstrate basic kn~wledge of procedures for using Kl 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 / 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 ofPlav:

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, emergency workers outside the EPZ do not have turn-back values. Standard issue ofdosimetry

Category A: I PRD, I DRD, and I unit ofKl e~ Category B: I PRD and I unit ofKl Category C: I PRD All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP) will make the dosimetry equipment (and Kl, as appropriate) available/or inspection by the Federal Evaluator. In order to demonstrate an understanding ofthe use ofthe dosimetry equipment, KI and associated forms,* the location need only remove and distribute I issue a maximum ofsix (6) units ofdosimetry from their inventory. Simulation Permanent Record Dosimeters (PRDs) with mock serial numbers may be used.

  • EMS units outside the EPZfall under guidance from the Interim Annex E letter dated April 6, 2009. Under section V-Concept ofOperations, subsection D-Survey equipment requirements, Paragraph 8 EMS crews outside the EPZ are exempted from needing PRD, DRD, or Kl (Page 1-4

Unclassified Radiological Emesgency Preparedness Program (REPP)

Susqueluuma Steam Electric Station After Action ReporUlmprovement Plan 7).

Evaluation Area 6-Support Operation/ Facilities Sub-element 6.d - Transportation. and Treatment of Contaminated Injured Individuals INTENT This Sub-element is derived from NUREG-0654 / 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.1: The facility I ORO has the appropriate space, adequate resources, and trained ,...

personnel to provide t,.ansport, monitoring, decontamination, and medical services to .

contaminated injured individuals. (NUREG-0654 I FEMA-REP-1, F.2; H.10,* K.5.a, b; L.J, 4)

Assessment/ Extent-of-Play Assessment of this Demonstration Criterion maybe accomplished during a biennial exercise, an actual event, or drills. FEMA has detennined that these capabilities have been enhanced and

  • . consistently demonstrated as adequate; therefore, offsite medical services drills need only be .

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

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

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

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility. It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "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 communicati.ons between the ambulance/dispatcher and the receiving medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available; In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

Monitoring of the victim may be performed before transport or enroute or may be deferred to the 5

  • Unclassified Radiological Emergency Prepamlness Program (REPP)

After Action ReporUlmprovement Plan Susquehanna Steam Electric Station medical facility.

Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s). However, ifan 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 / procedures.

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

State Negotiated Extent ofPlav:

Demonstrate that the facility has the appropriate space, adequate resources and trained personnel to provlde monltoring, decontamlnation and medical services to contaminated/injured individuals.

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

The Ambulance Service will pick-up a pre-staged simulated contaminated/injured victim.

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