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Kriss Kennedy Regional Administrator
OCT 3 1 2015
U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, Texas 76011
Dear Mr. Kennedy:
U.S. Department of Homeland Security Region IX 1111 Broadway, Suite 1200 Oakland, CA 94607-4052
FEMA
I am forwarding a copy of the Final After Action Report for the Medical Services exercise held in the city of Santa Maria, California on August 10, 2016, for the Diab lo Canyon Power Plant (DCPP). The purpose of this exercise was to assess the level of state and local preparedness in responding to a radiological emergency. The final exercise report was prepared by the U.S. Department of Homeland Security's Federal Emergency Management Agency, Region IX Radiological Emergency Preparedness Program staff.
No Level 1 or Level 2 Findings were identified during this exercise.
Based on the evaluation of the August 10, 2016, Medical Services exercise, the offsite r_adiological emergency response plans for the state of California and the affected local jurisdictions site-specific to DCPP 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 in the event of a radiological emergency at DCPP.
Therefore, the Code of Federal Regulations, Title 44 § 350 approval of the offsite radiological emergency response plans and preparedness for the state of California, site-specific to DCPP, will remain in effect.
www.fema.gov
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Mr. Kriss Kennedy Page2
If you have any questions or need additional information, please contact me at (510) 627-7100. Your staff may also contact Alberto Sifuentes, DCPP Site-Specialist, at ( 510) 627-7108, or Johanna Johnson, Acting Regional Assistance Committee Chairperson, at (510) 627-7164.
Enclosure
cc: NRC Headquarters Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555-0001
Vanessa Quinn, Chief Radiological Emergency Preparedness Branch
Sincerely,
Robert J. Fenton Regional Administrator FEMA Region IX
National Preparedness Directorate, FEMA Headquarters
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Diablo Canyon Power Plant
After Action Report/ Improvement Plan
Exercise Date - August 10, 2016
Radiological Emergency Preparedness Program
Published October 28, 2016
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Diablo Canyon Power Plant
After Action Report/Improvement Plan Contents Executive Summary
Section 1: Exercise Overview
1.1 Exercise Details
1.2 Exercise Planning Team Leadership
1.3 Participating Organizations
Section 2: Exercise Design Summary
2.1 Exercise Purpose and Design
2.2 Exercise Activities, Criteria and Capabilities
2.2.1 FEMA REP Exercise Demonstration Criteria
2.2.2 Department of Homeland Security Core Capability
2.3 Scenario Summary
2.3.1 Extent Of Play Agreement Summary
2.3 .2 Scenario Timeline
Section 3: Analysis of Capabilities
3 .1 Exercise Evaluation and Results
3.2 Summary Results of Exercise Evaluation
3 .3 Criteria Evaluation Summaries
3 .3 .1.1 Risk Jurisdictions
3.3.2 Sheriffs Dispatch Center MEDCOM
3.3.3 Private Organizations
3 .3 .3 .1 Cambria Community Healthcare Center
3 .3 .3 .2 Marian Regional Medical Center
Section 4: Conclusion
Appendix A: Improvement Plan
Appendix B: Exercise Evaluators and Team Leaders
Appendix C: Acronyms and Abbreviations
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EXECUTIVE SUMMARY
The U.S. Department of Homeland Security's Federal Emergency Management Agency Region
IX National Preparedness Division, Technological Hazards Branch evaluated a Medical
Services exercise for local emergency Offsite Response Organizations at Marian Regional
Medical Center on August 10, 2016. Marian Regional Medical Center is situated outside of the
Diablo Canyon Power Plant Plume Exposure Pathway Emergency Planning Zone in Santa
Barbara County, California. This report contains the evaluation results of that exercise.
A Medical Services exercise is part of the Federal Emergency Management Agency (FEMA)
Radiological Emergency Preparedness Program. It is conducted to assess the ability oflocal
emergency Offsite Response Organizations to implement plans and procedures for the
protection of the public in the event of a radiological incident at a commercial nuclear power
plant, in this case, the Diablo Canyon Power Plant.
The scenario and the Extent-of-Play agreement were reviewed by FEMA Region IX Regional
Assistance Committee Chair and approved for use in this exercise. The evaluation resulted in
no Level 1 or Level 2 Findings (previously called deficiencies and areas requiring corrective
action, respectively). There were no findings from previous Medical Services exercises which
required correction.
In Summary: The Offsite Response Organizations adequately demonstrated their capability to
implement their plans and procedures. This provides confirmation of reasonable assurance that
measures can be taken to protect the health and safety of the public in the event of a radiological
incident at Diablo Canyon Power Plant.
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SECTION 1: EXERCISE OVERVIEW
1.1 Exercise Details
Exercise Name
Diablo Canyon Power Plant (DCPP)
Type of Exercise
Medical Services- 1 (MS)
Exercise Date
August 10, 2016
Program
FEMA Radiological Emergency Preparedness (REP) Program
Scenario Type
Radiological Emergency
1.2 Exercise Planning Team Leadership
Lisa Abeloe Director of Emergency Services Marian Regional Medical Center Lisa.Abeloe@dignityhealth.org
Samantha Caldwell Emergency Planning Coordinator - Offsite Pacific Gas and Electric S5CL@pge.com
Richard Grundstrom Federal Emergency Management Agency - Region IX Regional Assistance Committee, Chair Richard.Grundstrom@fema.dhs.gov
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Johanna Johnson Federal Emergency Management Agency - Region IX Acting for Chair, Regional Assistance Committee Johanna.johnson@fema.dhs.gov
Laurel Ryan Federal Emergency Management Agency - Region IX Emergency Management Specialist Laurel.Ryan@fema.dhs.gov
1.3 Participating Organizations
Diablo Canyon Power Plant
Agencies and organizations of the following jurisdictions participated in the Diablo Canyon Power Plant exercise:
Risk Jurisdictions
San Luis Obispo (SLO) County
Private Organizations
Diablo Canyon Power Plant
Marian Regional Medical Center (MRMC)
Cambria Community Healthcare District (CCHD)
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SECTION 2: EXERCISE DESIGN SUMMARY
2.1 Exercise Purpose and Design
The Federal Emergency Management Agency, Region IX, evaluated the MRMC MS exercise to
assess the capabilities of the local Off site Response Organizations (ORO) to implement their REP
Program and procedures to protect the public health and safety during a simulated emergency at
DCPP on August 10, 2016. The scenario and the Extent of Play (EOP) agreement for the MS
exercise included emergency medical response to a DCPP worker who became injured and
contaminated in the course of carrying out of their duties.
Medical Services exercises are conducted to provide the opportunity to evaluate and assess
emergency plans, and associated implementing procedures; and facilities and equipment which
would be used in an emergency. The purpose of the August 10, 2016, MS exercise was to provide an
opportunity for the ORO to demonstrate implementation of their plans and procedures, and to
provide an opportunity for FEMA to evaluate the effectiveness of their plans and procedures in
accordance with Emergency Management and Assistance, 44 Code of Federal Regulations (C.F.R.) §
350 (October 2011) and FEMA REP Program Manual, (January 2016).
2.2 Exercise Activities, Criteria, and Capabilities
The MS exercise demonstrated the ORO ability to assess and respond to an emergency incident, and
to coordinate efforts for the protection of the health and safety of the public.
Activities for this exercise were conducted in two locations. The first location was Onsite at DCPP,
and the second location was Offsite at MRMC Emergency Department (ED). Both locations had
been identified as per EOP agreement.
Exercise terminates when utility, ORO and FEMA's lead evaluator have concurred that the scenario
has been played out and all decontamination objectives have been successfully demonstrated
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2.2.1 FEMA REP Exercise Demonstration Criteria
Offsite Response Organizations demonstrated the following criteria contained in FEMA REP
Program Manual, (January 2016):
Evaluation Area 1 - Emergency Operations Management
Criterion l .a. l: The ORO use effective procedures to alert, notify, and mobilize emergency
personnel and activate facilities in a timely manner. (Nuclear Regulatory (NUREG)-
0654/FEMA-REP-1, A.La, e; A.3, 4; C.l, 4, 6; D.4; E.1, 2; H.3, 4)
Criterion l .d. l: 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-1, F.1, 2)
Criterion l .e. l: 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.1: The ORO 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-1,
J.10.e; K.3.a, b; K.4)
Evaluation Area 6 - Support Operations/Facilities
Criterion 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. (NUREG-0654/FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4).
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2.2.2 Department of Homeland Security Core Capability
Offsite Response Organizations demonstrated the associated core capabilities from the U.S.
Department of Homeland Security's National Preparedness Goal, (September 2015): Planning,
Public Information and Warning, and Operational Coordination. These core capabilities span
five mission areas. Mission areas serve as an aid in integration and coordination across core
capabilities to achieve the goal of a secure and resilient nation. Core capabilities directly
involve more than one mission area and are listed in each mission area as appropriate.
The following are classifications of those Core Capabilities, associated Mission Areas and
related REP Program demonstration criteria evaluated during the MS exercise:
Protection Mission Area Core Capabilities are the product of diverse activities, and include the
capabilities to safe guard the homeland against acts of terrorism and man-made or natural
disasters. Associated diverse activities include:
• Develop protection plans that identify critical objectives based on planning
requirements, provide a complete and integrated picture of the sequence and scope of the
tasks to achieve the planning objectives, and implement planning requirements within
the time frame contemplated within the plan using available resources for protection-
related plans.
• Implement, exercise, and maintain plans to ensure continuity of operations.
Protection Mission Area Core Capabilities is met by the demonstration of REP Program
criterion l.a.l, l.e.1, 3.a.l, and 6.d.l.
Mitigation Mission Area Core Capabilities focus on the premise that individuals, the private and
nonprofit sectors, communities, and the Nation as a whole are made more resilient when the
consequences and impacts, the duration and human cost to respond to and recover all adverse
incidents are reduced. Associated diverse activities include:
• Build and sustain resilient systems, communities, and critical infrastructure and key
resources lifelines so as to reduce their vulnerability to natural, technological, and
human-caused threats and hazards by lessening the likelihood, severity, and duration of
the adverse consequences.
• Assess risk and disaster resilience so that decision makers and responders can take
informed action to reduce their entity's risk and increase their resilience.
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Mitigation Mission Area Core Capabilities is met by the demonstration of REP Program
criterion 3 .a.1, and 6.d.1.
Response Mission Area Core Capabilities emphasizes saving and sustaining lives, stabilizing the
incident, rapidly meeting basic human needs, establishing a safe and secure environment, and
supporting the transition to recovery. 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.
• Enhance and maintain command, control and coordination structures, consistent with the
National Incident Management System.
• Establish physical access through appropriate transportation corridors and deliver
required resources to save lives and to meet the needs of disaster survivors.
• Identify, assess, and mitigate worker health and safety hazards and disseminate health
and safety guidance and resources to response and recovery workers.
• Deliver medical countermeasures to exposed populations.
Response Mission Area Core Capabilities is met by the demonstration of REP Program criteria
1.a.1, 1.d.l, 1.e.l, 3.a.l, and 6.d.1.
2.3 Scenario Summary
This section contains a summary of the simulated sequence of events used as the basis for
invoking emergency response actions by the ORO during the MRMC MS exercise conducted on
August 10, 2016.
Results of a technical review of the scenario, completed on June 06, 2016, indicated that the
scenario was adequate to support demonstration ofDHS/FEMA requirements, as well as
selected Offsite evaluation criteria per the EOP agreement and as provided in the REP Program
Manual, (January 2016).
A summary of the MS exercise scenario follows: Initial conditions at DCPP have both units at
100% power and operating at normal operating temperature and pressure. Off site medical .
personnel are not Onsite.
A DCPP Chemistry Technician (CT) was performing the monthly correlation of the unit 1 's
reactor coolant system (RCS) dissolved oxygen (D02) orbisphere, at the unit 1 nuclear stream
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supply system sink. During the correlation a D02 CHEMet glass ampule, full of RCS,
shattered. The CT inadvertently punctured their right glove with the broken end of the ampule
and cut their hand. The CT upon seeing blood seeping from the wound fainted and fell back
striking their head on the concrete floor. They are unconscious, and a co-worker who witnessed
the accident notifies the DCPP control room.
Upon receiving the call of an injured and potentially contaminated CT a DCPP shift manager
will request an ambulance, via the San Luis Obispo (SLO) County Sheriffs Dispatch Center
(SDC) Medical Communications (MEDCOM), by landline. The injured and potentially
contaminated individual will be stabilized by DCPP Fire personnel and a Radiological
Protection Technician (RPT), and appropriate radiological and exposure control measures will
be taken before transferring the individual to a Cambria Community Healthcare District
ambulance outside the security gate.
2.3.1 Extent-of-Play Agreement Summary
The DCPP 2016 MS exercise is designed to demonstrate emergency response plans, policies,
and procedures as they pertain to MRMC capability for evaluation of radiation exposure and
uptake, including assurance that individuals providing these services are adequately prepared to
handle contaminated individuals in a nuclear power plant related incident. The MS exercise
commences at DCPP and will transit to MRMC located at 1400 East Church Street, Santa
Maria, California.
A DCPP shift manger will dial 911, by landline, and request that an ambulance be dispatched to
DCPP to transport an injured and potentially contaminated individual.
The SLO County SDC MEDCOM upon receiving the 911 call will contact CCHD to request
transportation of an injured and radiologically contaminated DCPP individual to MRMC ED.
Cambria Community Healthcare District paramedics will demonstrate communications and
contamination controls while transporting the injured and radiologically contaminated patient.
Marian Regional Medical Center, upon notification, will activate designated staff. Per Letter of
Agreement (July 2014) with Pacific Gas & Electric, MRMC is designated as one of two
hospitals which would treat a radiologically contaminated individual(s). Designated MRMC
staff are notified, by pager, to report to the ED and initiate radiological controls, and implement
radiological exposure control in accordance with their Radiological Emergency Response Plans
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(RERP) and Response to Radiologically Contaminated Patient (April 2016) Standard Operating
Procedure (SOP) in preparation for the arrival of the injured and potentially contaminated
patient. The ED will also commence preparation of a designated transfer area and
contamination injury room prior to the arrival of CCHD.
Upon arrival to MRMC, CCHD paramedics will transfer the injured and potentially
contaminated patient to the care of the designated ED staff. The patient will be transferred to
the Radiation Emergency Area (REA) for decontamination and further assessment. Emergency
Department staff will assess the patient's vitals, and monitor radiological levels to make a
dete1mination if treatment of the injury takes precedence over decontamination. Treatment and
decontamination of the patient, handling and disposal of contaminated materials will be held in
accordance with MRMC RERP and SOP.
Upon successful decontamination, the patient is transferred out of the REA to a receiving floor
for injury treatment, and designated MRMC staff will successfully egresses from the REA and
resume their normal duties.
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2.3.2 Scenario Timeline
Time Event Name Expected Actions
0759 Initial Conditions Initial conditions of ongoing work activity
Industrial Injury With DCPP CT is injured during the correlation of RCS D02 ~ 0800 Radioactive CHEMet glass ampule. Ampule shatters, injures and
Contamination contaminates the CT who faints and falls onto the floor.
~ 0801 Onsite Response DCPP First Responders (Fire, RPT, and Operations Responder) arrive at the scene and initiate first aid.
SLO County SDC MEDCOM receive call from DCPP Shift ~0804 Offsite Response Manager requesting an ambulance to transport an injured and
potentially contaminated worker.
DCPP Security and Radiation Protection staff met CCHD at security gate and assist with dosimetry issue, radiological
~0820 Onsite Response survey and contamination control measures, and will escort the ambulance crew to the location (simulated as per EOP Agreement) where the injured and potentially contaminated worker awaits transportation to MRMC.
~0832 Offsite Response CCHD transports the injured and potentially contaminated patient to MRMC for final treatment and decontamination.
~0900 Onsite Exercise Termination of the Onsite portion of the MS exercise occurs Termination when CCHD leaves DCPP.
Offsite Exercise Termination of the Offsite portion of the MS exercise when
~ 1100 Termination
patient is decontaminated and released from REA, and all evaluation criteria has been successfully demonstrated.
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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 August 10, 2016, DCPP MS exercise demonstrating
portions of the Off site emergency response capabilities outside the Emergency Planning Zone
(EPZ) surrounding DCPP.
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
Table 3.1 presents the status of all exercise evaluation area criteria which were scheduled for
demonstration during this exercise by all participating jurisdictions and functional entities.
Exercise evaluation area criteria are listed by number and the demonstration status of those
evaluation area criteria is indicated by the use of the following letters:
M-Met (No Ll or L2's assessed and no umesolved findings from prior exercises)
Ll -A Level 1 finding was identified (previously Deficiency)
L2 - A Level 2 finding was identified (previously Area Requiring Corrective Action)
P - A Plan issue was identified
N - Not Demonstrated
The following are classifications of the types of issues that are discussed in this report:
Level 1 Finding:
Defined in the FEMA REP Program Manual, (January 2016), as "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 the event of a radiological emergency to protect
the health and safety of the public living in the vicinity of a nuclear power plant."
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Level 2 Finding:
Defined in the FEMA REP Program Manual, (January 2016), as "An observed or identified
inadequacy of organizational performance in an exercise that is not considered, by itself, to
adversely impact public health and safety."
Plan Issue:
Defined in the FEMA REP Program Manual, (2016, January), as "An observed or identified
inadequacy in the ORO's emergency plan/procedures, rather than in the ORO's performance."
Table 3.1 - Summary of Exercise Evaluation
DATE: 2015-02-25
SITE: Diablo Canyon Power Plant, CA ~ 0 u Q
M:Met, LI: Level 1, L2: Level 2, P: Plan Issue, N: Not Demonstrated Q ::r: ~ u ~ u
Emergency OperationsManageme~t .. y ; ,.
Mobilization lal M
Facilities lbl
Direction and Control lcl
Communications Equipment ldl M M
Equipment and Supplies to Support Operations lel M
Protective Action. ImpJementation '. .. ' ' , . Implementation of Emergency Worker Exposure Control 3al M
Implementation of KI Decision for Institutionalized Individuals and the Public 3bl
Implementation of Protective Actions for persons with disabilities and 3cl access/functional needs Implementation of Protective Actions for Schools 3c2
Implementation of Traffic and Access Control 3dl
Impediments to Evacuation 3d2
Implementation of Ingestion Pathway Decisions 3el
Ingestion Strategies and Information 3e2
Implementation of Relocation, Reentry, and Return Decisions 3fl
Support Opera.tions/Facilities .. .. Temporary Care of Evacuees 6cl
Contaminated Injured Transport & Care 6dl M
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3.3 Criteria Evaluation Summaries
3.3.1 Risk Jurisdictions
3.3.2 San Luis Obispo County Sheriffs Dispatch Center
County Medical Communications Center
Diab lo Canyon Power Plant
In summary, the status ofDHS/FEMA criteria for this location is as follows:
a. MET: I.a. I, l.d. l.
b. LEVEL 2 FINDING: None
c. LEVEL I FINDING: None
d. PLAN ISSUES: None
e. NOT DEMONSTRATED: None
f. PRIOR ISSUES - RESOLVED: None
g. PRIOR ISSUES - UNRESOLVED: None
3.3.3 Private Organizations
3.3.3.1 Cambria Community Healthcare District
In summary, the status ofDHS/FEMA criteria for this location is as follows:
a. MET: l.d.1, Le.I, 3.a.I, 6.d.l.
b. LEVEL 2 FINDING: None
c. LEVEL I FINDING: None
d. PLAN ISSUES: None
e. NOT DEMONSTRATED: None
f. PRIOR ISSUES - RESOLVED: None
g. PRIOR ISSUES - UNRESOLVED: None
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3.3.3.2 Marian Regional Medical Center
In summary, the status ofDHS/FEMA criteria for this location is as follows:
a. MET: l.d.1, l.e.1, 3.a.l, 6.d.l.
b. LEVEL 2 FINDING: None
c. LEVEL 1 FINDING: None
d. PLAN ISSUES: None
e. NOT DEMONSTRATED: None
f. PRIOR ISSUES - RESOLVED: None
g. PRIOR ISSUES - UNRESOLVED: None
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SECTION 4: CONCLUSION
The Federal Emergency Management Agency team completed the evaluation of the
Medical Services exercise conducted on August 10, 2016, in Santa Barbara County,
California.
This report is based on the evaluations of the federal evaluation team, with final
determinations made by the FEMA Region IX RAC Chair, and approved by the Regional
Administrator.
There were no Level 1 or Level 2 findings identified during this evaluated MS exercise.
These results have shown that the Offsite RERP for the affected local jurisdictions site-
specific to DCPP can be implemented and is adequate to provided continued reasonable
assurance that appropriate measures can be taken Offsite to protect the health and safety
of the public in the event of a radiological incident at DCPP.
Therefore, Emergency Management and Assistance, 44 C.F.R. § 350 (2011, October),
approval of the Off site RERP and preparedness for California site-specific to Diablo
Canyon Power Plant will remain in effect.
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APPENDIX A: IMPROVEMENT PLAN
None Required
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APPENDIXB:
EXERCISE EVALUATORS AND TEAM LEADERS
DATE: 2016-08-10 SITE: Diablo Canyon Power Plant, CA
TomEssi
Marian Regional Medical Center Roy Smith Daryl Thome
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FEMA
ICFI
ICFI ICFI
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APPENDIXC:
ACRONYMS AND ABBREVIATIONS
Acronym Meaning ARCA Areas Requiring Corrective Action
CCHD Cambria Community Healthcare District
C.F.R. Code of Federal Regulations
CHEM et CHEMetrics, Inc.
CPM Counts Per Minute
CT Chemistry Technician
DCPP Diablo Canyon Power Plant
DHS Department of Homeland Security
D02 Dissolved Oxygen
ED Emergency Department
EOP Extent-of-Play Agreement
EPZ Emergency Planning Zone
FEMA Federal Emergency Management Agency
KI Potassium Iodide
Ll Level 1 finding
L2 Level 2 finding
MEDCOM Medical Communications
MRMC Marian Regional Medical Center
MS Medical Services-1
N Not Demonstrated
NMT Nuclear Medicine Technician
NUREG Nuclear Regulatory
ossc Offsite Storage Container ORO Offsite Response Organizations
PED Personal Electronic Dosimeter
PPE Personal Protective Equipment
RAC Regional Assistance Committee
RCS Reactor Coolant System
REA Radiation Emergency Area
REP Radiological Emergency Preparedness
RERP Radfological Emergency Response Plans
RP Radiation Protection
RSO Radiation Safety Officer
SDC Sheriffs Dispatch Center
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SLO San Luis Obispo SOP Standard Operating Procedure THB Technological Hazards Branch TLD Thermoluminescent Dosimeter
TDR Treatment/Decontamination Room
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