After Action Report/ Improvement Plan - NRC: Home Page · 2017-03-29 · After Action...

Diablo Canyon Power Plant

After Action Report/ Improvement Plan

Exercise Date: March 29, 2017

Radiological Emergency Preparedness Program

Publication Date: June 9, 2017

Unclassified

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



After Action Report/Improvement Plan Contents Executive.Summary 4

Section 1: Overview 5

1.1 Exercise Details 5

1.2 Exercise Planning Team Leadership 5

1.3 Participating Organizations 7

Section 2: Exercise Design Summary 8

2.1 Purpose and Design 8

2.2 Demonstration Criteria and Core Capabilities 8

2.2.1 Demonstration Criteria 8

2.2.2 Mission Area and Core Capabilities 10

2.3 Summary of Scenarios and Extent-of-Play Agreement 12

Section 3: Analysis of Capabilities 1'5

3.1 Exercise Evaluation and Results 15

3.2 Summary Results of Exercise Evaluation 15

3.3 Criteria Evaluation Summaries 18

3.3.1 Risk Jurisdictions 18

3 .3 .1.1 County of San Luis Obispo Sheriffs Dispatch -

MEDCOM 18

3.3.2 Private Organizations 18

3.3.2.1 French Hospital Medical Center 18

3.3.2.2 San Luis Ambulance 19

Section 4: Conclusion 20

Appendix A: Exercise Evaluators 21

Appendix B: Acronyms and Abbreviations 22

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EXECUTIVE SUMMARY

The U.S. Department of Homeland Security's (DHS) Federal Emergency Management Agency

(FEMA) Region IX National Preparedness Division, Technological Hazards Branch, evaluated a

Medical Services Exercise (MS-1) on March 29, 2017, for local emergency Off-site Response

Organizations (ORO). Evaluations were conducted at French Hospital Medical Center (FHMC),

the County of San Luis Obispo (SLO) Sheriff's Dispatch - Medical Communications (MEDCOM),

and San Luis Ambulance (SLA) that are located in the County of SLO.

The purpose of evaluating an MS-1, as part of the Radiological Emergency Preparedness (REP)

Program, is to assess the level of local ORO preparedness in response to a radiological incident

occurring at or within the vicinity of the Diab lo Canyon Power Plant (DCPP). The MS-1 was held

in accordance with FEMA's policies and guidance concerning the implementation of State and local

ORO Radiological Emergency Response Plans (RERP) and procedures.

Prior to the MS-1 an Extent-of-Play (EOP) Agreement and two scenarios were reviewed and

approved by the FEMA Region IX Acting Regional Assistance Committee (RAC) Chair.

The MS-1 evaluation results contained in this report, along with FEMA Region IX Acting RAC

Chair's final determinations, are submitted to the FEMA Acting Regional Administrator (RA) for

final approval.

No Level 1 (Ll) or Level 2 (L2) Findings were identified during the MS-1 conducted at FHMC.

In Summary: The OROs successfully demonstrated that their RERP and procedures can be

adequately implemented in response to a radiological incident occurring at or within the vicinity of

DCPP. This action maintains continued reasonable assurance that emergency safety measures can

be taken to protect the health and safety of the public in the event of a radiological incident

occurring at or within the vicinity of DCPP.

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SECTION 1: EXERCISE OVERVIEW

1.1 Exercise Details

Exercise Name

Diablo Canyon Power Plant - Medical Service Exercise

Type of Exercise

Medical Services Exercise

Exercise Date

March 29, 2017

Program

U.S. Department of Homeland Security's/FEMA REP Program

Scenario Type

Respondii:ig to and transportation of a radiological contaminated/injured individual

1.2 Exercise Planning Team Leadership

Reanna Clayton, RS, BSN

Emergency Services Director

French Hospital Medical Center·

[email protected]

Samantha Caldwell

Emergency Planning Coordinator - Off-site

Pacific Gas and Electric

[email protected]

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Kelly Van Buren

Emergency Services Coordinator

San Luis Obispo County Office of Emergency Services

[email protected]

Anita Konopa



[email protected]

Rachel Monte



[email protected]

Johanna Johnson

Federal Emergency Management Agency - Region IX

Acting Regional Assistance Committee, Chair

[email protected] ·

Alberto Sifuentes

Federal Emergency Management Agency - Region IX

Emergency Management Site-Specialist

Alberto. [email protected]

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1.3 Participating Organizations

Agencies and organizations of the following jurisdictions participated in the Diablo

Canyon Power Plant Medical Services Exercise:

Risk Jurisdictions

County of San Luis Obispo

County of San Luis Obispo Office of Emergency Services

Private Organizations

French Hospital Medical Center

Pacific Gas and Electric - Diablo Canyon Power Plant

San Luis Ambulance

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SECTION 2: EXERCISE DESIGN SUMMARY

2.1 Purpose and Design

The Federal Emergency Management Ag~ncy administers the REP Program pursuant to the

regulations found in Title 44 Code of Federal Regulations (C.F.R.) § 350, 351and352 (October

2011) and the FEMA REP Program Manual, (January 2016). Title 44 C.F.R. § 350, Emergency

Management and Assistance, (October 2011) codifies 16 Planning Standards that form the basis for

radiological emergency response planning for licensees, State, local, and tribal governments

impacted by the Emergency Planning Zone's established for each nuclear power plant (NPP) site in

the United States of America.

The MS-1 scenario's and the EOP Agreement allow the ORO's the opportunity to implement and

demonstrate their RERP and procedures; and for FEMA to evaluate the effectiveness of those

RERP and procedures.

The results of this exercise, together with the review of the RERP and procedures, the verification

of the periodic requirements (found and identified in NUREG-0654/FEMA-REP-1) enable FEMA

to provide a statement with transmission of this final After Action Report to the U.S. Nuclear

Regulatory Commission (NRC) that ORO's plans and preparedness are:

• Adequate to protect the health and safety cifthe public living in the vicinity of DCPP; and

• That appropriate protective measures can be implemented Off-site in the event of a

radiological incident occurring at the NPP.

2.2 Demonstration Criteria and Mission Area Core Capabilities

Demonstration and evaluation of criteria were conducted at three locations. The first location was

at the County of SLO Sheriffs Dispatch - MEDCOM , the second location was with the SLA and

the third location was at FHMC Emergency Department (ED). Locations were pre-identified in the

EOP Agreement.

2.2.1 Demonstration Criteria

Off-site Response Organizations demonstrated the following criteria, contained in FEMA REP

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Program Manual, (January 2016), and referenced to the planning standards published in NUREG-

0654/FEMA-REP-1, and associated core capabilities from the U.S. DHS National Preparedness

Goal, (September 2015):

Evaluation Area 1 "'.'"""Emergency Operations Management

Criterion l.a.1: Mobilization - Off-site Response Organizations use effective procedures to alert,

notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-

0654/FEMA-REP-1, A.La, e; A.3,4:c.1, 4, 6; D.4; e.1, 2; G.3.a: H.3, 4)

Criterion l .d. l: Communication - At least two communication systems are available, at least one

operates properly, and communication links are established and maintained with appropriate

locations. Communications capabilities are managed in support of emergency operations. (NUREG

- 0654/FEMA-REP-l, F.1, 2)

Criterion l .e. l: Equipment and Supplies to Support Operations - Equipment, maps, displays,

dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

(NUREG-0654/FEMA REP-1, H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b)

Evaluation Area 3 - Protective Action Implementation

Criterion 3 .a. l: Implementation of Emergency Worker Exposure Control - The ORO' s 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. Appropriate record keeping of the administration of KI for emergency workers is maintained.

(NUREG- 0654/FEMA-REP-l, J.10.e; K.3.a, b; K.4)

Evaluation Area 6 - Support Operations/Facilities

Criterion 6.d.1: Transportation and Treatment of Contaminated Injured Individuals - The

facility/ORO has the appropriate space, adequate resources, and trained personnel to provide

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

(NUREG-0654/FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4)

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2.2.2 Mission Area and Core Capabilities

Mission Areas serve as an aid in integration and coordination across Core Capabilities to achieve

the goal of a secure and resilient nation.

One Mission Area identified during the MS-1 was that of Response.

The Response Mission Area consists of fifteen Core Capabilities. Of these, five were cross

referenced with the demonstration criteria. These are:

• Environmental Response/Health and Safety

• Mass Care Services

• Operational Communications

• Public and Private Services and Resources

• Public Health and Medical Services

Three of the 32 Core Capabilities are common to all Mission Areas. These are Planning, Public

Information and Warning, and Operational Coordination. Of these, one was cross-referenced with

the demonstration criteria. This was:

• Operational Coordination

The following are classifications of those Core Capabilities, within associated Mission Areas, and

related REP Program demonstration criteria evaluated during the MS-1:

Response Mission Area Core Capabilities minimize human exposure to environmental public

health hazards, and ensures adequately trained and equipped personnel, and resources are available

at the time of an incident to protect the safety and health of on-scene first responders,

hospital/medical facility personnel, and skilled support personnel through the creation and

maintenance of an effective safety and health program.

Associated diverse activities include:

• Mobilize all critical resources and establish command, control, and coordination

structures within the affected community and other coordinating bodies in surrounding

communities and across the Nation.

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• Establish physical access through appropriate transportation corridors and deliver

required resources to save lives and to meet the needs of disaster survivors.

• Provide life-sustaining and human services to the affected population, to include

hydration, feeding, sheltering, temporary housing, evacuee support, reunification, and

distribution of emergency supplies.

• Ensure the capacity for timely communications in support of security, situational

awareness, and operations by any and all means available, among and between affected

communities in the impact area and all response forces.

• Provide lifesaving medical treatment via Emergency Medical Services and related

operations and avoid additional disease. and injury by providing targeted public health,

medical, and behavioral health support, and products to all affected populations.

Response Mission Area Core Capabilities is met by the demonstration of REP Program criteria:

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

Core Capabilities common to all Mission Areas emphasize saving and sustaining lives,

stabilizing the incident, rapidly meeting basic human needs, establishing a safe and secure

environment, and supporting the transition to recovery through Operational Coordination.

Associated diverse activities include:

• Establish and maintain a, unified and coordinated operational structure and process that

appropriately integrates all critical stakeholders and supports the execution of core

capabilities.

• Mobilize all critical resources and establish command, control, and coordination

structures within the affected community and other coordinating bodies in surrounding

communities and across the Nation.

Core Capabilities common to all Mission Areas is met by the demonstration of REP Program

criteria: 3.a.1, and 6.d.l.

Capabilities-based planning allows for exercise planning teams to develop exercise objectives and

observe/evaluate exercise outcomes through a framework of specific action items derived from the

Core Capabilities List. The following Core Capabilities form the basis for FEMA Region IX REP

Program objectives observed and evaluated during the MS-1:

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Environmental Response/Health and Safety

Description: Conduct appropriate measures. to ensure the protection of the health and safety of the

public and workers, as well as.the environment, from all-hazards in support ofresponder operations

and the affected communities.

Operational Coordination

Description: Establish and maintain a unified and coordinated operational structure and process

that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

Operational Communications

Description: Ensure the capacity for timely communications in support of security, situational

awareness, and operations by any means available, among and between affected communities in the

impacted area and all response forces.

Mass Care Services

Description: Provide life-sustaining and human series to the affected population, to include

hydration, feeding, sheltering, temporary housing, evacuee support, reunification, and distribution

of emergency supplies.

Public Health, Healthcare, and Emergency Medical Services

Description: Provide lifesaving medical treatment via Emergency Medical Services and related

operations and avoid additional disease and injury by providing targeted public health, medical, and

behavioral health support, and products to all affected populations.

Public and Private Services and Resources

Description: Deliver essential commodities, equipment, and services in support of impacted

communities and survivors, to include emergency power and fuel support, as well as the

coordination of access to community staples. Synchronize logistics capabilities and enable the

restoration of impacted supply chains.

Additionally, each capability was linked to several corresponding activities and criteria to provide

additional detail.

2.3 Scenarios and Extent-of-Play Agreement Summary

The March 29, 2017, MS-I was based on two scenarios occurring consecutively. The first scenario

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· After Action Report/Improvement Plan Radiological Emergency Preparedness (REP) Program


(S-1) occurred On-site at DCPP with an injured and contaminated utility worker requiring

assessment and transportation to a designated hospital for treatment. The second scenario (S-2)

involved a member of the general public who is involved in a vehicular accident during a

radiological release from DCPP. The individual was injured, and may potentially be contaminated.

Both scenarios will invoke a sequence of emergency response actions to be initiated and carried out

by the OROs.

The FEMA Lead Evaluator and the Lead ORO Exercise Controller will terminate the MS-1 when

all parties agree that all the required demonstration criteria have been adequately demonstrated and

evaluated.

A summary of the MS-I S-1 is as follows (times listed are for planning purposes only):

Initial conditions at DCPP have Unit I at I 00% power and operating at normal operating

temperature and pressure. Unit 2 (U2) is shut down for refueling.

At 0755, a Chemistry and Radiation Protection (C&RP) technician completes sampling the U2

Coolant System.

The C&RP technician is descending the U2 stairwell when they slip and fall, breaking their left

ankle and landing on a container holding sample coolant vials. Several of the sample vials are

broken and puncture the C&RP technician's lower body.

A co-worker, who witnessed the accident, calls the DCPP emergency line. On-site emergency

personnel follow emergency protocol, and initiate contact with MEDCOM.

The injured C&RP technician is stabilized and ready for transportation to FHMC via SLA.

A turnover of the injured C&RP technician will occur outside of the DCPP security gate (as per

EOP Agreement).

Upoµ successful turnover, DCPP will terminate the exercise On-site. The Off-site the exercise will

proceed with SLA initiating contamination controls and transporting the injured C&RP technician

toFHMC.

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Once SLA arrives at FHMC, the injured C&RP technician will be transported into the Radiological

Emergency Area (REA). Upon successful decontamination, the C&RP technician will be released

from the REA and S 1 will be terminated.

A summary of the MS-1 S-2 is as follows (times listed are for planning purposes only):

The S-2 occurs during a simulated Plume Phase occurring at DCPP.

An Emergency Classification Level (ECL) of Site Area Emergency was declared at 1200, a General

Emergency declared at 1500, and a radiological release occurs at 1600.

As of 1600, Protective Action Zones (PAZ) 1, 2, and 3 have been evacuated. French HospitaI

Medical Center has been identified to receive and treat injured radiologically contaminated

individuals. San Luis Ambulance has been notified of the ECLs and the radiological release

occurring at DCPP.

At approximately 1800, a Port San Luis (PSL) angler comes ashore and prepares to exit from PAZ

3. The PSL angler is involved in car accident with a DCPP employee _leaving the plant. The PSL

angler complains of neck and back pain. The uninjured DCPP employee calls 9-1-1 to report the

accident, and request emergency assistance.

During this period, the County of SLO Emergency Operations Center (BOC) has utilized available

dose projections to conclude that within the next three hours, areas within the vicinity of PSL would

be affected by the release of radiation from DCPP.

The County of SLO Sheriffs MED COM will receive the 9-1-1 call and upon gathering specifics on

the car accident will identify it having occurred within the release area.

San Luis Ambulance will be dispatched, by MEDCOM, to respond to the car accident and to follow

their radiological procedures; as it is within the affected area.

Upon arrival, SLA EMS will initiate appropriate radiological and exposure control measures prior

to transporting the injured and potentially contaminated patient to FHMC.

Once SLA arrives at FHMC, the injured and potentially contaminated patient will be turned over to

FHMC ED staff and transported to the REA. Upon successful decontamination; the injured patient

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Diab lo Canyon Power Plant

is released from the REA and transferred to a floor unit, and S2 will be terminated.

Extent-of-Play Agreement Summary:

The purpose of the EOP Agreement is to identify, and negotiate, demonstration criteria and any

planned deviations from the implementation of the applicable plans that will be evaluated during the

MS-1. Additionally, the EOP Agreement represents the level of participation and any limitations

on the demonstration of Emergency Preparedness Evaluation Area Elements by the participating

agencies and organizations.

The expected outcome of the MS-1 is the successful demonstration of reasonable assurance that the

health and safety of the public can be protected during a radiological incident occurring at or within

the vicinity of a NPP.

SECTION 3: ANALYSIS OF CAPABILITIES

3.1 Exercise Evaluation and Results

Contained in this section are the results and findings of the evaluation of all jurisdictions and

functional entities that participated in the March 29, 2017, demonstrating portions of the Off-site

emergency response capabilities.

Each jurisdiction and functional entity was evaluated on its demonstration of selected criteria as

indicated in the EOP Agreement and as outlined in the FEMA REP Program Manual, (January

2016).

3.2 · Summary Results of Exercise Evaluation

The matrix in Table 3 .1 presents the status of all exercise Assessment Areas and sub-element

criterion that were demonstrated, for evaluation during the MS-1, by all participating jurisdictions

and functional entities. The REP Program uses the following alphanumeric key to indicate

demonstration status of those criteria evaluated during the MS-1:

LI - Level 1 Finding identified (previously listed as an Deficiency)

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L2 - Level 2 Finding identified (previously listed as an Area Requiring Corrective Action

(ARCA))

M - Met (No Ll or L2 Findings assessed and no unresolved ARCAs from prior MS-1)

N - Not Demonstrated

P - Plan Issue identified

Below are the alphanumeric key definitions as defined in the FEMA REP Program Manual,

(January 2016):

Level 1 Finding: "An observed or identified inadequacy of organizational performance in an

exercise that could cause a determination that Off-site emergency preparedness is not adequate to

provide reasonable assurance that appropriate protective measures ~an be taken in the event of a

radiological emergency to protect the health and safety of the public living in the vicinity of a

NPP."

Level 2 Finding: "An observed or identified inadequacy of organizational performance in an

exercise that is not considered, by itself, to adversely impact public health and safety."

Met: "The jurisdiction or functional entity performed all activities under the Demonstration

Criterion to the level required in the EOP Agreement, with no Level 1 or Level 2 Findings assessed

under that criterion in the current exercise and no unresolved prior Level 2 Findings."

Not Demonstrated: "A justifiable reason, the jurisdiction or functional entity did not perform

activities under the Demonstration Criterion as specified in the EOP Agreement or at the frequency

required in Exhibit III-2."

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

than in the ORO's performance."

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Table 3.1 - Summary of Exercise Evaluation

~ 0 u A

~ DATE: March 29, 2017 ' ..c::

SITE: Diablo Canyon Power Plant ~ 0.

"' ===================== cs ct (gj

Ll: Level 1 Finding a:: ·c .... "' w ..c:: "' I- CZl E

L2: Level 2 Finding a:: 0 "' 0. u u "' <ii

P: Plan Issue z :E <.J

0 0 ;a "' "' M: Met ~ ·5 ~

>-l ~

Not Demonstrated ex: ~

N: I- "' 0. V'l CZl 00

z c.... ~ 0 0 .P ..c:: ~ ~ <.J

;::l ~ w 0 "' c .... u ~

:··. .. > I• ..

Mobilization lal M M

Direction and Control lcl

Communications Eauioment ldl M M M

Eauioment and Suoolies to Suooort Ooerations lel M M M

. ,. . Prqtec~ye Action'DecisiortMaking ·. .'.,

Emern:encv Worker Exposure Control Decision Making 2al

Protective Action Decision's (P ADs) for Disabled/Functional Needs 2cl

Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl

Rad Assessment and Decision making concerning Relocation, Reentry, and Return 2el

.. , .. ·. ; '1:1,· ,· :), ''• Imolementation ofEmern:encv Worker Exoosure Control 3al M M

Implementation of protective actions for special populations 3cl

Imolementation of Traffic and Access Control 3dl

Imolementation oflngestion Pathwav decisions - availabilitv use of info 3el

Materials for Ingestion Pathway P ADs are available 3e2

Implementation of relocation, reentry, and return decisions 3fl

. · .. i~ '. ' ' •...

Post nlume ohase field measurements and samnJing 4bl

Laboratorv ooerations 4cl

Emern:encv Information and Instructions for the Public and the Media 5bl

•: '., . Contaminated Injured Transport and Care 6dl

M M

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3.3 Criteria Evaluation Summaries

3.3.1 Risk Jurisdictions

3.3.1.1 County of San Luis Obispo Sheriff's Dispatch -

MEDCOM

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a.1, 1.d. l, 1.e.1.

b. LEVEL 1 FINDING: None

c. LEVEL 2 FINDING: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None

3.3.2 Private Organizations

3.3.2.1 French Hospital Medical Center

In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: 1.a.l, 1.d.l, 1.e.l, 3.a.l, 6.d.1.




e. NOT DEMONSTRATED: None



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3.3.2.2 San Luis Ambulance

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: l.d.l, l.e.l, 3.a.1, 6.d.l.




e. NOTDEMONSTRATED:None



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After Action Report/hnprovement Plan Radiological Emergency Preparedness (REP) Program


SECTION 4: CONCLUSION

The Federal Emergency Management Agency, Region IX, evaluated an MS-1 on March 29,

2017, in SLO County. The purpose of the MS-1 was to assess the level of local emergency

preparedness in response to a simulated radiological incident occurring at or within the

vicinity of DCPP.

The MS-1 was evaluated in accordance with FEMA policies and guidance in regards to

implementing local RERP and procedures.

The MS-1 evaluation results contained in this report, along with FEMA Region IX Acting

RAC Chair's final determinations, are submitted to the FEMA Region IX Acting RA for

final approval.

Based on the evaluation of the criteria demonstrated on March 29, 2017, the Off-site

radiological emergency response plans for the affected local jurisdictions can be

implemented, and are adequate to provide continued reasonable assurance that appropriate

measures can be taken Off".'site to protect the health and safety of the public.

Therefore, Title 44 C.F.R. § 350, Emergency Management and Assistance, (October 2011),

approval of the Off-site RERP and preparedness for the state of California, site-specific to

DCPP, will remain in effect.

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APPENDIX A: EXERCISE EVALUATORS

Roy Smith French Hospital Medical Center

Daryl Thome

San Luis Ambulance Dennis Wilford

County of San Luis Obispo Sheriff's Dispatch - MED COM John Woytak

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ICFI

ICFI

FEMA Region IX

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APPENDIX B: ACRONYMS AND

ABBREVIATIONS

BUPSC C&RP

C.F.R.

DCPP DHS ECL ED

EOC EOP EW

FEMA enc FHMC

KI Potassium Iodide Ll Level I Findin L2 Level 2 Findin

MEDCOM Medical Communications MS-1 Medical Service exercise

NPP Nuclear Power Plant

NRC ORO PAD Protective Action Decision PAZ Protective Action Zone

P Plan Issue PSL Port San Luis RAC Re ional Assistance Committee REA Radio lo REP

RERP S 1 First Scenario S2 Second Scenario

SLA San Luis Ambulance SLO San Luis Obis o U2 Unit 2

U.S. United States

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