ML20093C099

Respec of Offsite Emergency Planning Contentions.Certificate of Svc Encl

ML20093C099
Person / Time
Site:	Limerick
Issue date:	10/01/1984
From:	Zitzer P LIMERICK ECOLOGY ACTION, INC.
To:
Shared Package
ML20093C088	List: ML20093C085 ML20093C099
References
OL, NUDOCS 8410100358
Download: ML20093C099 (38)

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Catawba Balancing Test For Late-filed Contentions In its July 26, 1983 Second Special Prehearing Con-forence order,,the Board directed T.merick Ecology Action (LEA) to address the factors set _forth in the Catawba d,ecisions,'

which' factors the Board will then balance in determining whether or ' not so-called " late-filed" contentions are admissible.'

The five factors of 10 CFR 52.7-14 (a) (1) are as follows:

(i) good cause, if any, for failure to fiie o;n time; (ii) the availability of 'other means whereb'y'the.

petitioner's interest will be protected; (iii)

'the extent to which the petitioner's participation

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may reasonably be expected to assist in devel-

.i opment of a sound record; (iv)- the extent to which the petitioner's interest will be represented by existing parties; (v)

.the extent to which the petitioner's participation will broaden the issues or delay the proceeding.

.The 'three-part test overlayed by the Appeal Board in

~ Catawba (and affirmed by the Commission as appropriate in an admissibility determination) is that the contention:

(a)- is wholly dependent upon the content of a particular 1.

Duke Power Co. (Catawba Nuclear Station, Units 1 and 2),

ALAB-687, 16 NRC 460, 469-70 (1982);

Duka Power Co.

(Catawba Nuclear Station, Units 1 and 2), CLI-83-19, slip op. at 5-6 (July 1, 1983).

18 NRC t

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document;'

(b)'

could therefore.not.have'been advanced >with any degree j.

of'specifity (if at all)'in advance of the 'public availability of~the document; and (c) is tendered with the requisite degree of' promptness once-the document comes into existence and is

' accessible for public. examination.

. Limerick? Ecology Action _.has respecified. previously. def erred of f-site emergency (planning contentions ~, pursuant to the Board's-Orders, and

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'hereby addresses the-five 2.714 (a)(1) factors as ovprimid by the

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three part test.

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,. 7 LLEA(first' submitted emergency planning contentions in this proceeding on Nov. 24, 1981, based on all available information at.that time.

The Board's June 1, 1982 Special Prehearing Conference Order stated that'the " Board finds.that emergency planning contentions should be deferred until;.the emergency plans:are available" (p.156). The

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sche'dule:for filing "off-site"' emergency planning contentions was established by'the1 Board's~ Order of May-16,.1983 (Second Prehearing

. Conference Order). Page 5: states, "The triggering eventafor submission of these contentions will.be.the receipt by intervenors and the

. City'of Philadelphia of the emergency plans as they are being sub-

-mitted'toJFEMA following_PEMA's review of them." The Applicant served these documents on Dec.

9, 1983. The Board's Order of Jan. 20, 1984,

' established a: filing deadline 6f Jan. 31, 1984 for the receipt of all "off-site" emergencyLplanning' contentions. On April 20, 1984,

- the. Board ruled on the admissibility of LEA's contentions, chosing

.to admit some.of the contentions, and to again defer others.

Discovery on LEA's admitted "off-site" emergency planning contentions lasted from April 20,-1984 to June 25, 1984. On August IS, 1984, the Board issued-an Order: that-established the schedule for respecification of LEA's admitted contentions, which required

-service on all parties by Sept.

6, 1984 (receive dates).

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~ The Board's August 15,'1984 Order also established a se,hedule for

. the respecification of. LEA's deferred contentions (LEA-1, LEA-2,

- LEA-3,cLEA-4, LEA-5. LEA-6, LEA-23). This ruling ordered FEMA to provide by expedited means the draft FEMA RAC report on the July 25

- Limerick Exercise,-estimated to be issued on or about Sept.

1, 1984.

- Limerick EcoJogy Action was ordered'to file its respecification of deferred contentions by Sept. 25, 1984.

On August-23,-1984, the NRC Staff filed a Motion for Reconsideration of the Board's Aug. 15th. Order to provide the draft. FEM'A RAC

_ report to the parties in this proceeding. On Sept..-5,,.1984' FEMA stated its objections to-the Board's Order which required the. distribution of the draft' FEMA RAC' report. On September'6, 1984, :(h[; Board invited other parties to file an Answer to the NRC Staff's Motio'n for Reconsideration based on FEMA's concerns about release of the draft RAC report. On September 11, 1984, Limerick Ecology Action filed its Answer and request,for access to the draft RAC report,,'

A conference call on. Sept. 14th, between the parties resulted in an agreement that FEMA's Ceneral Counsel would request FEMA to agree to

- make-the factual' portions of the RAC. report available to LEA and other interested parties as soon as possible. On Sept. 19, LEA

- received a message from the NRC Staff Counsel Nathene Wright that

. FEMA had agreed to make portions of the report.available at the FEMA Phila.~ office on the morning of Sept.-21, 1984. Due to the relevance of this material to LEA's deferred contentions, th9. parties jointly. requested an extention of time for the filing of LEA's respecification to allow for an opportunity to obtain, review and discuss the information contained in FEMA's report on the July 25 Exercise. (See-discussion in LEA's Sept. 24, 1984 Request for an extention:of time'for respecification until October 1, 1984; hereby

-incorporated by reference).

Although FEMA did not release the draft RAC repor,t, the Final FEMA Report was made available to the' parties on Sept, 26, 1984, A meeting between Limerick Ecology Action, FEMA, the NRC Staff, and the Applicant and its Counsel took place in Phila, on Sept. 27th. This provided LEA with an opportunity to discuss its proposed respecifications with those present. It was however, unfortunate that PEMA was unable to L m'..

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Participate in s

the meeting, because so many of LEA's concerns focus uon current unmet needs that have been passed on to PEMA from the CountiesLand the-schools, and the.related issue of the* state's ability to satisfactorially resolve these problems. LEA President, Phyllis Zitzer_ contacted Zori Ferkin, Counsel for PEMA to discuss LEA's propose'd respecification. Ms. Ferkin advised LEA that PEMA would address LEA's concerns in a_ response filing to the'respecified.

contentions.

Limerick Ecology ~ Action grateful 1y acknowledges its appreciation to'the.other parties and the Licensing Board for allawin'g the. parties to have the opportunity to review and discuss the FEMA R(port.on the July 25.Exerc'ise before the filing of these respecif$ed'conten-tions. The. meeting provided-annopportunity for the Applicant and

~ LEA to discuss'and resolve several of LEA's concerns, Limerick Ecology Action-has good cause for filing these respecified

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contsntions according to the schedule discussed here. These contentions could not have been advanced with any more specificity

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on an earlier schedule due to the fact that auch of the Applicant's consultant's work 6n the development of off-site emergency response plans is.yet to be completed. In this case in particular, it is only recently that.unnet needs have actually been identified and passed along to the1 County and then the state for resolution. In many cases,

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it is still not known how PEMA will respond to identified unmet,needs,

.or whether the1necessary resources'and personnel are available.

Furthermore LEA received'the FEMA Final Report on the Limerick Exercise on-Sept. 26,?and did-not'have access to this information previously, had been anticipated by the Board.

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LEA's-respecification of deferred contentions has been " tendered with -

s the requisite:: degree of' promptness" since we are following the 5

schedule established by the Board Orders in this proceeding. LEA has no other means to protect its interests relating to "off-site" I

emergency planning contentions in thdt no other regulatory or judicial body has jurisdiction to hear LEA's concerns in a timely fashion. It is the NRC's duty, under its licensing authority to review all matters t

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relevant to the licensing and operation of the Limerick facility, and that authority cannot be userped by any other b o d y.,; Fu r th~e rmo r e,

considering the potential political and other interests that influence their decision-making, participating governmental entities cannot be expected to adequately represent LEA's interests.

No other intervet.or has standing on "off-site" emergency planning issues'that can represent LEA's interests. The only individual' intervenor that had any contentions admitted on "off-site" emergency I

planning issues has been consolidated under LEA.

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LEA's participation in this matter can be expected to $ss[st.,in the development of a sound record in this proceeding. LEA hopes to obtain expert assistance in pursuing many of.its contentions, which

'hile not required for licensing proceedings, is an aid to the Board w

as well as to LE'.

A r-The litigation of LEA's contentions is not likely to broaden the issues to be heard in this proceeding by the Board because they were deferred by the Board earlier in the case to allow an opportunity ~.,

e for focusing and narrowing o,f LEA's concerns. These5 matters have been raised in a timely manner according to the schedule established by the Board in this proceeding, and were first raised in 1981'when all other contentions were filed.

Overall, for the reasons set forth 'above, LEA' believes that,it is

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appropriate for the Board to accept LEA's narrowing and focusing of these deferred contentions and to admit them for litigation in this proceeding.

I Respectfully sebmitted, f

ni Phy is Zit er, President October 1, 1984 Lim rick Ecology Action 4

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LEA-1

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The Fusk Counties 7 Municipalities, School Districts, and Institutions haven't promulgated or adopted final radiological emergency response plans, nor have they approved and adopted plans drawn up for them by Energy Consultants, Inc., a Harrisburg firm hired by Philadelphia Electric. Company. There is no reasonable assurance that the present state of planning is predictive of final approval, or that the plans are capable of being implemented.

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Specifically, the Commonwealth system of government in pennsylvania establishes the township or boro, and not the County, as the basic unit of government, as reficcted in State Enabling Legislation and First and Second Class Township Codes.

(a) There is no assurance that pEMA can provide 134 buses for unmet needs in Chester County and 12 coach buses for unmet needs in Montgomery County.

(b) There is no assurance that pE?fA can provide 82 ambulances for unmet needs in Montgomery County and 17 ambulances for unmet needs in Chester County.

The workability of Municipal, County, School District and Institutional RERp's depends on the availability of the above resources. The willingness af elected public officials to accept the responsibility assigned to them by P.L.1332 and the Draf t RERp's cannot be assumed in the absense Cf assured provision of necessary resources to implement the plans.

2. Municipalities respresenthig apnroximately 44,500 people living within the Plume EPZ did not participate in the July 25 test drill, and as documented by FEMA in the Final Drill Report did not display their capability to protect their citizens in the event of an accident at Limerick. FEMA considers this a " Class A" deficiency. In addition, the Dorough Council Cf phoenixville actually voted not to participate in the drill because they did not find the plan acceptable to protect their 14,000 citizens.

(See attachednLEA-1 Supplemental Basis, Attachments #2 and #3)

Also, it was the position of other Counties and Municipalities that participation in the drill did not predict or necessitate final approval of the draft RERp's. (See LEA-1 Supplemental Basis, Attachments # 1,

1. 7'and #8.)

3. As of October 1, 1984, no municipal ~ plans have been signed and most public officialv have stated publicly that they want to reserve the right to still decide whether these plans are workabic or not. With the exception of Perkiomen Valley and Downingtown School Districts, no

'RiskInstitional, School District, or County RERp have been approved.

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. Alternative: planning approaches are being considered 5Y^:mbnyEjurisdictionssimultaneously.withconsiderationofthe

.ECliproposed approach (Owen J Roberts District, Phoenixville tSchool' District, L. Providence,Schuykill,Warwick otc) Reliance on

. alternative plans which.would meet the broad requirements of PL.

11332; State Law'would.not automatically. provide reasonable assuranco as per.NuRog 0654 without a thorough reworking of coordination and-procedures atimany levels. Participation in planning different'-than the. draft RERP's would require some review

- by the rclevant agencies.

~Furthermore,.the a'c dons of local planners ~who under Pa.PL1332

.take a."something is better than nothing" approach to emergency planning and who, without close supervision by municipal officials, imay-be_doing;whatever they can to obtain much needed.cquipment paid-foriby the Utility in order to improve.their facilities, are not a basis which can predict that local government will accept-the much moro rigorous assignment of responsibilities-

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and -duties :as proposed in the RERP's, Without such specific assignment of responsibilities there is no-reasonable assurance under 10' CFR 50,47(b)(1).

' DASISr'10 CFR g 50,47 (b)(1), NUREG 0654, Criteria A(1),

' ~ NUERG 0054, Criteria A(2,a)

See al'so attached LEA Supplemental Basis, documenting the concerns of local officals.

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SUPPLEMENTAL BASIS E.

East Pikeland Twp.: Letter to PEMA from Twp. Secretary' John Doyle stating that the Township's participation in the July 25 test drill "does not in any way constitute approval of~the plan nor does it bind the town-I.

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ship to further participation in the program".

(7/18/84) (Submitted as a limited appearance statement'in~this proceeding -- a copy is attached

~with this filing for the convenience of the parties)

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Boro of - Ph'oenixvilre: ' Letter of July 25l 1984 stating that'the Boro Council was opposed to participation in phe July 25 test' drill, (served on parties to this hbd proceeding as a limited appearance statement -

a co'py has., bee'n' attache ~d to thi's, filing for the' conven'ience Jof the~ parties),

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.EMC Norman Vutz stated at a towdsh'n f

Schuylkill Township:

ib supervisors meeting on Wed. Aug. 1,1984 stated' that' h' eand e

other volunteers "wentsthrough the motions" on July 25, but' he felt that there were t! toc many r

holes' in the plan which be termed "not complete".

(Evening Phoenix, 8/2/84) (1)

. -lEalso.:

general comments stated in letter from Schuylkill s,

Township Supervisors to Mr. David Dunn, Energy.

Consultants "(7/14/83) (1)

South Coventry Twp'.: Twp. Supervisor Richard Whitlock has indicated that the township will not approve any plan until someone other.than the township pays for a l

survey of municipal emergency resources. "We're i

not_ going along with any plans until PE shows us who is going to pay for it',.*.... "There are too

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many gaps in the forms and a lot of unanswered questions", according to Mr. Whitlock. (Pottstown

' Mercury, 8/4 /83 ).- (1)

Warwick Twp.:

After Warwick Township officials notified the Chester County Dept. of Emergency Services that the township would not be participating in the. drill, their decision was reversed when a l

Philadelphia Electric employee, threatened Icgal action if he was not allowed to participate in the drill. According to township resident, Tom Bissinger who was informed by Municipal EMC Fred Hurlock, the Supervisors chose not to participate due to their belief that the plan was unworkable..Mr. Hurlock has expressed concerns about the evacuation of a nearby trailer court and'the fact that several municipalities must L

share Elverson Fire Company's equipment.

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-i Green Iane Boro:

"The plan leaves a lot to be desired -- I'm not terribly enthused about the traffic plan", stated

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Marlborough Twp. Police Chief William Rupp.

Council member Barbara Brey stated that she was disturbed that the plan did not take pay attention t6 humas needs in the event of an evacuation.

Green Lane Mayor John Balmer wanted to know-how elderly residents, who may not hav'e their own,

cars, would be transported from the borough it' it were necessary to evacuate the boroudh......

"What if we have to evacuate peop1'4 in a blizzard?"

Council member Lillian Hess questioned the idea that.the plan puts so much responsibility on borough residents to evacuate ~t6sidents. (Town and Country, 5/16/84)-(1)

,,,j, Lower Providence' Twp: The Board of Supervisors wrote a letter to Philadelphia Electric Company stating that the:

Township did not participate in the July 25 test

$kf drill because of a lack of trained staff, the failure-of PECO to provide equipment and tra.ining personnel for the drill, and other reasons stated by John Mikowychok on July 13, 1984.

(see attichments to this filing)

Perkiomen Township:

Concerns about issurance liabilities for township volunteers, as stated by the Perkiomen Township Supervisors at their August 1984 meeting

-(see article from Schwenksville Item, 8/9/84)(2)

At~their. April 1984 Township meeting, the Perkiomen Twp. Board of Supervisors refused to consider v

adoption of,the_ latest draft radiological emergency.:'

plans due to'particular concerns'about the

. adequacy of plans for Graterford Prison, and becaus'e

'of concerns expressed by Sup6rvisbr Claire Olson about the municipal responsibilities contained in the plans.

"I find these tasks impossible",

stated Mrs. Olson

'(Times Herald 4/4/84) (1) l

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Skippack'Townsh'ip:

Letter from Alan Boroff, Township Solicitor, to.

PEMA dated 6/22/84 outlining the reasons that Skippack Twp.-has not adopted its RERP, (submitted as Attachment #5, in LEA's Answers to PECO Interrogatories on July 16, 1984 -- Attached M

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again with this filing for the convenience'of.

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the parties) Skiphabk Township has expressed serious concerns about the work' ability of.the municipal plan in the absenc'efa"ssurance from PEMA that the State can provide the necessary resources t'.n_ evacuate Graterford Prison, This lack-of con,

fidence'in the municipal RERP is demonstrated by the unwillinaness nf the~ Skippack Twp. Volunteer Fire Dept. to participate in or to accept the responsibility in the RERP. ( milegeville Ondependent, 2/28/84 - attached with this filing) (1)

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Schwenksville Boro:

In November 1983, former EMC Bernard.McCollum stated "We're working on a shoestring"..."The people are in'ai state of bewilderment'.!McCollum stated that the Borough has no money for radio-contact equipment, emergency street lighting, buses or ambnlances. (Times Herald 11/23/83) (1)

Upper Providence ~Twp';: George Waterman, Township Manager cited several areas of concern about the RERP at th,e May 1984 Supervisors meeting, stating that they had a long, way to go before he could recommend that the RERP should be considered for adoption. He said that agreements were_needed with towing service's to keep the roads clear, and that more equipment was needed to set up the municipal.EOC. He diso i

raised concerns about the townshi'p's $' ability insurance. '(Evening Phoenix, 5/8/84):(1)tInrthat-sam 6rkrticle, Chairman Templeton qhestioned whether or not the National Guard would-be available to assist the township in case of a nuclear emergency.

Upper Salford Twp'.:

EMC-KehnethyHagy7. stated at the July 1984 Upper Salford Twp. Supervisors meeting,that " Philadelphia Electric Co. and the township have a long way to go" before their Limerick RERP is completed. He stated that the. township had not yet organized all the workers and equipment it would need in a nuclear emergency. "PECO has just begnn to scratch the surface of meeting the needs of Our community to" effectuate this plan", said Hagy......"I will not i

support the adoption of any plan until all possible needs have been mot, and that those needs are not met at the expense of the taxpayers of Upper Salford Twp., but rather the stockholders of PECO". TPott~stown' Mercury, 7/4/84)(1)

C st Pottsgrove'TWp.:

Supervisor Chairman Richard Bacchi stated at the August Supervisors meeting.that West Pottsgrove Twp. did not participate in the July 25 test drill j

due to a lack of volunteers, the recent resignation of municipal EMC Earl Keck,. lack of proper

~ equipment, lack of proper praparation,'andtunaccep-table evacuation plans for the handicapped residents of the township. TPottstown Mercury, 8/2/84)(2)

' Montgomery County [

Letter.from County EMC Lin Bigelow to John Patten, Director of PEMA stating his concerns about the lack of preparedness of many of the Montg. Co, municipalities with regard to participation 'in the July 25 test drill. The letter expresses the 2 purposes of the drill from the perspective of Montg. Co. :

1) demonstration.of ability to implement plans

2) an opportunity for evaluation by participants of their plans, as developed thus far, in order to identify and make changes as, applicable.

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a Montgomery County: The Montgomery County Commissioners have repeatedly expressed. doubts about the workability of the County RERP for Limerick. (see attached newsclippings)

M NOTE:

FEMA made the following comment about the July 25 Exercise:

"The County Commissioners should take a more direct interest in future exerdises"(page 21)

_ (1) Items' supplied by LEA in response to PECO Interrogatories ',

submitted by LEA in 8/13/84 Supplemental Response (2) Items supplied by LEA in repponse to PECO Interroga$orieY submitted by LEA in 8231/84 Supplemen tal Response - y 90 p

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J, ATTACIIM17/K #1 lW.

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EAST PIKELAND TOWNSHIP BOARD OF SUPERVISORS

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b k k "vUca"ce.ainwan Michael Gaydos JOHN D. DOYt2 sacy.. ins As.

e4 C NICleAi. DUILDING nares paw nono AT TMF COVEnED a nt DO E Pcnnsylvania Emergency Management Agency July 18, 1984 P.O. Box 3321 Harrisburg, PA.

17105 R s Radiological Emergency Response Plan Exercise - July 25, 1984

Dear Sir:

This is to notify you that East Pikeland Township, Chester County will participate in the Limerick radiological emergency response plan exercise scheduled for Wed-traday, July 25, 1984 with the following reservations.

A celect committee of township residents has conducted a detailed study of the proposed radiological emergency response plan submitted by Energy Consultants, of Harrisburg, PA., consultants to the Philadelphia Electric Company. In view of the cignificant concerns (attached) of the committee (concerns shared by the Planning Commission and Board of Supervisors) regarding the provisions of the proposed plan (Draft #5 dated April 1984), East Pikeland Township will not approve / adopt the plan in its present form.

Thus we wish to note for the record that the township's participation in the July 25th exercise does not in any way constitute approval of the plan nor does it bind tha township to future participation in the program.

Sincerely.

W0 6*fC.

/jdd John D. Doyle', Sec'y Chester County Ibept. of Emergency Services cc:

Federal Emergency Management Agency Division of Emergency Preparedness & Emergency Response Office of Inspection & Enforcement Nuclear Regulatory Commission Mr. George llughes, EPT Emergency Management Coordinator EPT Planning Commission

.rost orreca Aponessi ta's t rixatano vownswer, mox es xiumenton,

,a n u s,i,v a n i.

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July 6, 1984 TO the East Pikeland Township Planning Commission:

The undersigned, representing a committee investigating the EvCcuation Plan for East Pikeland, recommend that Draf t #5 of the Rndiological Emergency Response Plan (RERP) not be approved as it exiots and not be submitted for review by the Chester County Department Cf Emergency Services (CCDES), the Pennsylvania Emergency Management Ag:ncy(PEMA), the Federal Emergency Management Agency (FEMA), and the Nuclear. Regulatory Commission (NRC)until the following areas of concern be resolved.

This recommendation arises from the identification of a large number of serious deficiencies and uncertainties in our study of the RERP(Drafts #4 and #5) for East Pikeland, associated-materials, and diccussion with various parties.

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, Foremost among these concerns are:

1) TIME FRAMEWORK FOR PUBLIC RESPONSE TO A RANGE OF POSSIBLE EVACUATION EVENTS: the plan does not precisely relate effective times for evacuation to the imaginable range of radiological evente.

2) INADEOUATE ROAD SYSTEM: need to realistically review the NRC required evacuation time study recently released by PECO and prepared by HMM Associates of Concord, MA.

This computer based study indicates a total evacuation time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 15 minutes for the 74,498 residents of Chester County during the worst of possible conditions, ie.,

"a snowy winter weekday"(The Mercury, Pottstown, 6/22/84).

Township records indicate a total of 8-12 hours to plow out East Pikeland.

3) CO,-ORDINATION WITH NEIGHBOURING MUNICIPALITIES : determine the relationship and impact of the plans (particularly the evacuation routes, joint une of services. - ambulances,

' fire company, buses, tow trucks, etc.) of surrounding municipalities and school district on the East Pikoland Evacuation Plan.

This is one of the objectives cited in

• Draft #5, " Ensure that planned actions are current and in consonance with those of surrounding jurisdictions, as well as with the Chester County RERP".

4) INADEQUATE EVACUATION MANAGEMENT AND CONTROL MEC11ANISMS :

need for verified availability of equipment and services (ambulances, tow trucks, snow plows, etc.), realistic assessment of available volunteers, realistic assessment of amount of volunteers needed in time to fill one job, training program for volunteers and public, information availability and maintenance, etc.

5) COST: undefined liability of costs to the Township and public for implementation and perpetual maintenance of Plan.

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6) LIABILITY: undefined liabilities of Township, County, State, Federal Government, Philadelphia Electric and individuals,such as volunteers, against damage to person and property in the Township.

Energy Consultants, Inc( the consulting firm hired by PECO to prepar,e the RERP) suggested that we ask our solicitor to look at Pamphlet Law #1332, " Emergency. Services Code".

7)-SHELTERING: when will we be asked to shelter, is it safe, for how long, and how is it accomplished?

8) DRTLL TEST: the superficiality of the proposed test of the RERP planned for July 25, 1984, as a measure of Plan feasibility.

FEMA will be holding hearings on 1

the Drill'two days following the test. (July 27 in Pottstown)

,These points are proposed as sufficient to support the recom-s' mondOtion.

Many other concerns and deficiencies ;an be elaborated.

It 10 suggested that full resolution of the listed points be demanded by the Township before the committee should undertake study of the plan in more detail.

The committee 3.s,of course, ready.to extend or deepen it's otudy as available in2ormation may permit.

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The committee has chosen not to express opinion of the overall froibility or prachicality of the idea of an Evacuation Plan for a

-Limerick. Radiological Emergency.

.It should not be interpreted, moreover, th2t in. recommending resolution of the listed concerns the committee

.13 endorsing the concept of the Plan.

I

incerely,

[ h5LdGtt 4a l-l J. Edward Matthews s t,

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[' David.K. Adams Lindsa Brinton David Churbock Ann Ra n

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CHESTER COUNTY, PENNSYLVANIA 7A.

BoroughHatt.140Churchstreet.Phoer==ville.Pa 19460 l

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i MAYOR C U-. ' C ' " " * ' 7 July 25, 1984

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BOROUGH COUNCIL t

Bonnie K. August President He:en M. Rambo Vice President g.

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Assistant Secretary

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Nuclear Regulatory Commission

,'n [ p,),n c/o Honorable Judge Brenner John Fedora Docket #50-352 SERVED AUG 3 P?d Robert J. Gray Washington, DC 20555 Loren B. Griffath hn P. Horene

Dear Judge Brenner,

g, Robert W. Mark i am writing this letter in reference to the recent emergency

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owen J. seenhn evacuation drill held in Phoenixville on Wednesday, July 25th.

OFFICERS The Borough Council of Phoenixville went on record opposing W;llem P. Herrnan their participation in this drill. At this t*me, I would like to go on record stating that Phoenixville did participate in Pa r c a.

r n this drill as a result of the Mayor's recommendation.

Borough Secretary I

Jarnes Dunworth strongly feel this was not a sanctioned drill from the Borough Council of Phoenixville, a.id would not want to be evaluated as per draf t #5 of the emergency evacuation plans.

Should you have any questions, please do not hesitate to write or call.

i Very truly yours, BOROUGH OF PH0ENIXVILLE l

Bonnie K. August y

President of Borough Council i

BKA:pmg

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gl The Borough of Phoenixville

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CHESTER COUNTY, PENNSYLVANIA PA.

Borough Hall 140 Church S treet. Phoersxville. Pa.,19460 WW MAYOR C C_:'~ ~ ~" " *- q i."; C.3, & (* g,,,,g,,, g a July 25, 1984 Robert M. Gray C

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'0 BOROUGH COUNCIL C

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Bonnie K. August President Helen M. Rambo L.

Vice President

" ' ' ' ' f..l y

• Assistent Socratory

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Nuclear Regulatory Commission pn [p,'[

c/o Honorable Judge Brenner John Fedora Docket #50-352 Robert J. Gray Washington, DC 20555 SEPEU AUG 3 1W' Loren B. Griffith John P. Horenci Alexander C. Kovac's

Dear Judge Brenner,

Robert W. Mark Owen J. Scanhn I am writing this letter in reference to the recent emergency evacuation drill held in Phoenixville on Wednesday, July 25th.

OFFICERS The Borough Council of Phoenixville went on record opposing Wilham P. Herrnan their participation in this drill. At this time, I would like to go on record stating that Phoenixville did participate in Pa r a

,a, Borough Secretary this drill as a result of the Mayor's recommendation.

I Jame: D"aworth strongly feel this was not a sanctioned drill from the Borough Council of Phoenixville, and would not want to be evaluated as per draf t #5 of the emergency evacuation plans.

Should you have any questions, please do not hesitate to write or call.

Very truly yours, BOROUGH OF PHOENIXVILLE Bonnie K. August

(/

President of Borough Council BKA:pmg

~

CLtp3 THE SCHUYLKILL BUGLEfPAGE 3 VOL.1 NO. 6 1984.'-

- y.f,y, - _ _

e _-.-

~~

Phoenixville's full. evacuation drill. The.;

=-w Phoenixville Bmough Council

_" State OY[

has not yet reviewed Plan Five of

.p the evacuadon plans. Most p Emergency" 4 a y'

$* ""d "E" C

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A Sham-% ~

Eg_

ough officials, we are obliged to' (Q

ensure the safety and welfare of

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all borough residents, among f

s.,..A by Bonnie August,,

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Other responsibilities.

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President,, y.,

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- The borough'of Phoenixville-j Phoenixville City Council > 1 d 6-draws its water su;3 ply from thE j-The PhoemxvillejBorough

.r Schuylkill Rivgr. in.the event of j Councd,, at their July 12 monthly J ll q,,

3 meetmg; went on record; vBtmgy-gg f 17 24E a nuclear ac'cident jit Limerick,~

Mb gM lthis water' source would be con ~

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seven to four, not to participate..

<4;p.-

.'taminated for' an:. indefinite

• ~d

m the July; 25tli Emergencyf Instead,I sent a Ictter to Judge period of time. The borough has

Evacuat,on Drill. Several days LawrenceBrennerattheNuclear, inquired into alte'rnate water i

r after the meetmg, on July 17, a'

, Philadelphia Electr c Company ~

Regulatory Commission explain -

sources and found that Suburban i

ing, in detail, Council's reasons-Water' Company, which gets j representative attended a special". -

'would be too' costly for an emer$

g arks, Property and Public Safe.g for not participating in the drill water from Pickering Creek' P

ty Committee meeting of Phoe-t and the triayor's action. I ex-

~

mxville Borough Council. -

plained that I fcIt the borough i gency hook-up.

7 E The ' PECO :epresentative enteredinto the drillillegally and I strongly feel that PECO s

r spoke -so persuasively at.this. ~ noted my contention that we, as should address the many prob-2 a borough, should not be grad, I'.ms that would result from a Emeeting that he convinced' the Iinayor to declaie a " state' of' ed by either the Federal or Penn-nuclear accident at. Limerick.-

~

' emergency" for the ' drill.CThiC sylvania Emergency Manage.

problems such as af ternate water'!

hias done so that.the boroughi

? ment Agencie's. I still believe that s urces, madequate road systems

~

yvould participatein'the' drill. Ac-Othe borough participated.in the in the event of mass evacuation,;

cording to the Penniylvania State'. i drill illegally.? - '

.p[emxville and other towns m9'.

iBorough Code, a mayor can onlyh U"--

% ceoui,;ddnp,,y

~

" * ~ ~ "

i declare a-state.of ' emergency P and adjacent to the Emergency As'asf6$servif oTthe' drill,

. hen' one actually exists and it M[must'admidthat.thetmedencIiyl public meetmg will be held this w

~

an ng Zone. IIopefully, a must.be.done.in writing and ~

advertised in a local' newspaper.

icoordinator;his assistant and all.

I"II to address these and any the volunteers seerhed to be do. #

~

~

ther related problems; This was not 'done.

I consulted with Phoenixville ' iing an (xcellent job, But, I had,

In closing, I feel 1,must note T considered this a[' paper" or !

~

t Borough Solicitor James Dun-that many of the people who worth;concerning the mayor's / (" table top" drill all along and supported the July 25th emer--

actions. Mr. Dunworth's opinion. l maintained that the staff would gency evacuation drill were not was that the mayor did not have l.do an above-average job. All of present to observe it! As a pub-the jurisdictio'n to declare a state the people involved are dedicated lic official, I believe I was elected of emergency'under the existing-l to their jobs and performed them to serve the needs of the people well. Ilowever, since it was only i circumstances as no. emergency

- not my own wants. Perhaps existed and no advertisement of.

a " paper" drill,I cannot say that some officials are out of touch intention was done. My only re.. i n evacuation drill.

course,on behalf of theborough 'i t was aI objected to participating in

~.,~

~

-with this reality.

l i the drill at the July 12th and 17th-i citizens, would have been to seek a court injuncti4n 'to gsrevent the Council ' meetings ' and I still borough from participating in believe that the officials and vol-

' involved in a l

consideration, I decided agains' D,.,_unteers.were not the July 25th drill.' After muct 44

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-the injunction because of thuf..

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. <JUL 181984.

R,A.KkNKUS LOWER PROVIDENCE TOWNSHIP 100 Parklane Drive Eagleville, PA 19403 Telephone: (215) 539-8020 July 13,1984

.Mr. C. Gregory Whitman Philadelphia Electric Company

..: t 680 Ridge Pike Plymouth Meeting, PA 19462

Dear Greg:

Please be advised that the Board of Supervisors at their

- public meeting of July 9,1984 agreed not to participate in the July 25 Emergency Evacuation Drill-as planned by PECO.

The Board's reasons for not participating include the lack of trained staff within the township at present, the failure of PECO to provide us with equipment and training personnel in time for adequate' preparation for the drill, and the-fact that our -

=

~

emergency coordination volunteer committee is just assembling and will have their first meeting on July 19.

x If you have any further questions, please contact me at your earliest convenience.

I would appreciate your contacting

.me-as to,the probability of a future drill later this sumer.

a Sincerely, j

s hn P. Mikowycho j

Acting Township Manager cc: Timothy Hasson, Montgomery County Emergency Preparedness Office Paul B. Bartle, Commissioner, Montgomery County

.. Thomas Rogers, Emergency-Coordinator.

> ~ =

...m,

_.,m,-

Bill Adam, Evacuation Comittee Board of Supervisors l

l l

OAusas ef TomasMy esamger - Smerssery

• Teammuter - Sullding* Masambing Inspessor

• 2emens Officer - l' arks and Mecreasi..a c

+

- LAT OFFICLS 13OROFF. IIAllRIS & IIELLElt eno#tsstowAt consonArio9 6So BLUE BELLWEST-5UITE 32o

z. EDWARD HELLER =

SKIPPACK PIKE MsCHAEL R. HARRIS *

• BLUE BELL. PENNSYLVANIA 19422 ALAW E.DOROFF (215)628 980o

^*""I# # " ONE HARRY T. MON 00tL

.'.'h^E* oM ff June 22,1984 Pennsylvania Emergency Management Agency

~

P. O. Box 3321 Harrisburg PA 17105 Re: Skippack Township, Montgomery County - Proposed Radiological Emergency Response Plan for Incidents at the Limerick Generating Station

Dear Sir:

This letter is being written to the Pennsylvania Emergency Management Agency at the request of the Board of Supervisors of Skippack Township.

The undersigned is solicitor for the Skippack Township Board of Supervisors.

The Board of Supervisors has made a preliminary study of the proposed radiological emergency response plan submitted to Skippack Township by Energy Consultants, of Harrisburg, Pennsylvania, consultants to the Philadelphia Electric Company.

Skippack Township has not adopted the proposed radiological emergency response plan in view of the significant concerns of the Board of Supervisors concerning the provisions of the proposed plan, being Draf t No. 5 dated April,1984, a

Among the significant concerns of the Board of Supervisors of Skippack Township are the following:

Lack of adequate personnel available to Skippack Township to provide a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1.

The Skippack Township does not have a police force.

emergency response.

Skippack Fire Co., a volunteer group, has indicated their unwillingness to participate in a radiological emergency response plan in the event of a site emergency or a general emergency.

Inability of the Township to provide adequate means to provide notice and 2.

transportation to transit dependent individuals.

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/ennsylyznia EmergIncy Managament Agsney Jun2 22,1984 i

Page Two.

1 3.

Skippack Township and its relationship to other municipalities evacuate through Skippack Township as well as evacuation of the State Correctional Institution - Graterford located in Skippack Township. The Skippack Township Board of Supervisors are concerned with the coordination of Skippack and adjoining municipalities and the State Correctional Institution with reference to potential evacuation.

4.

Skippack Township does not believe it has the means necessary to obtain the equipment and dosimetry called for under the proposed plan, even taking into account the proposed equipment funding offer made by Philadelphia Electric Co.

5.

The need for coordination among the various municipalities as well as the county and state officials with reference to evacuation and other matters, which would include proposed evacuation routes and their capacity.

6.

The need for an ongoing training program. Township participants in the radiological emergency response plan should be able to receive ongoing training through either a county or area organization as each individual township is unable to provide this.

The Board of Supervisors believe it appropriate it to submit these concerns to you, at this timo. They will continue with their evaluation of the proposed radiological emergency response plan and will condu t public hearings thereon in the near future.

Vcry truly yours, i

Alan E. Boroff 1

..P

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George Hugenin, Skippack Township Emergency Management Coordinator cc.

. Edward L. Jordan, Director, Division of Emergency Preparedness and Emergency l

Reponse, Office of Inspection and Enforcement, United Nuclear Regulatory Commission, Washington, D.C.

l l

Federal Emergency Management Agency, Washington, D.C. 20472

[

Montgomery County Emergency Management Office Mrs. Mary Wills, Skippack Township Secretary 1

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Risell',%dvided p the$ u'nanimously v6 ting n'ot to p/ [%{i at. A sublic' meeting.on# Mar. 5.wale a'r'-

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J regular twp. meetLg Mar, 22, q/.' Fire Chief Risell~said a:bl^an( sdp;7:30. p.m.,.with.the twp.e townthip supervis. rs at pthe Iticipate.in the plan.J p-Qresolution to appoint; Robert l ga th t the members of the fire co.2 needs'to be. adopted to provide h scheduled to discuss Draft 4'of, j

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accept the responsibilities for'. one'that.would risk exposuriofJ In'.other business," twpc. enh-g Siegrist;, constable

' those parts of the Radiological ' fadiation to vol. firemen.E;'It'is 7.gineeri Robert Showalterf wasgofficers to enforce

~

ct which prohibits dogs from 9

l! t Emtrgency Response Plan that n'ot;.a'e ' question; of.lackj of asked to' make a 8700 study'onip~ running : loose. ' Dogs 'already_

.would involve the risk of radia 5 :coursge6.but ' a, question.f of". the draina'ge problems 6n CreRRd. across from. 'thet 2

kcc:se'exposeure to firemen-ini, common sense,,he saidi, chief 0 smanof an emergency at 'theT Risell s

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i limirick nuclear plant.

. 3 the' assumption exposeure.,The ditions have'been 1SPCA'in' Perkiomenville. Own-

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Tha vote was taken at the i equipment has not been tested"? where icy conthis. winters, Thejgers nAist a ' problem and. the consultants 'do - not"' study must be started inuned.(( dqgs back.' '

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rdgular fire' co meeting ' held

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~ 101 A C. BANNING COUNTY OF MONTGOMERY

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co.nessiowens b -:.*

PAUL BAKER BARTLE ALI.AN C. MYERS DEPARTMENT OF PUBLIC WORKS -

A. W. MARTIN, F.E* DruCTOR OFFICE OF EMERGENCY PREPAREDNESS DIVISION OF PUBLIC SAFETY 100 WILSON BOULEVARD -

.. JOSEPH D. HAMILTON,DinECTom EAGLEVILLE, PENNSYLVANIA 19403 (215) 631 5100 A. UNDLEY DIGE!DW,CoonDo4 Tot July 10, 1984 i

Mr. John L. Patten, Director Pennsylvania Emergency Management

' Agency

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N P.O.~ Box 3321 Harrisburg, PA 17105

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Dear John:

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With' the ' xercise of t,he Limerick RERP scheduled for. July,25, 1984,. only two e

-weeks away, I have advised the County _ Commissioners of,.the status of our plan

[-

and my; estimation of our ability to adequately implement it.

In short, there is insufficient' time remaining for many municipalities to receive the additional

~ training needed-to properly demonstrate implementation of thei. RERP.

~

Several 1ocal Emergency Management Coordinators are " going it alone"; they' lack

~

- an EOC Staff of any kind.

In other municipalities only minimal staff is on hand and a lack of alternates.or depth at key positions -Ts evident.

~

Locally, more training'is still needed. for Radiological Monitoring / Decontamination teams, Police Departments, Fire Companies, Ambulance Squads, 'and municipal EOC Staff.

-In the area of facilities and equipment, there is ~still much to be done; ie.,

telephone equipment, signs, dosimetry, etc.

.I have concerns that the munici--

2 ',... -.palities could demonstrate.that these plans can be implemented..without having L

the physical resources in place and operable.

"As:I~ understand it, this exercise has a two-fold purpose:

1) to demonstrate Jan ability to implement emergency plans effectively to Federal authorities, l~

and 2) to provide the participants with an opportunity to evaluate their emer-L a,,gency_ plans.as,they,have,been developed so far, in order to-identify and make l_.

changes'as applicable.

.At this writing, I believe only five municipalities will be sufficiently staffed and trained to merit an evaluation by Federal observers.

Perhaps another= ten will be minimally staffed and would be willing to participate, but not to be

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graded.

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Menloomery County $icentennial

% Cele 6 ration of Odo Centuries l.

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i Station, che"(-1)

-Mass Care Center, one (1)' Emergency Worker Relocat on one (1) Nursing Home, and one (1) Hospital.

I expect.

School District, the County EOC to be fully staffed at each position, however, additional training will be needed subsequent to the drill.

Mo'ntgomery County is willing to participate in the' exercise but wis' es to

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.Your early response will be

' advise'you of the limitations outlined above.

greatly appreciated.

Very truly yours, Du A. Lindley Bigelow C5ordinator' 6

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I gj$ h municipalities to be trained to I[ h*.

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gesEga:.j "23S.K2]uS M.2 8 W.JB02 y2 scale exercise.".

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.g 6 =,,, T j 3 $ 2 2 3Ga].3 am8' The U.S. Nuclear Regulatory 3

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Commission (NRC), as part of

' sn't. It would be a total farce "Perhaps the Jul 25 dr!!! will i

D its licensing procedure, requires and complete deceptior. for them be at least a start. fhope we can "a

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evacuatinfimerick in case there. evaluate the county based on residents within 10 eral observers should should to the people."

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replied: "We are responsible in the exercise may not accurately ca 8*

E To t NRC permission so op-Montgomery County for the reflect implementation of the etate{imerick at full power, PE, coordination of the movement of plan under real emergency con-y 43 8.*

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must demonstate next Wednes-people in case of a disaster."

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day that power plant employees "It is our responsibility to be "How you can say it's a full-O S

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3 and community emergency brepared to assist munici allties scale exercise when not one bus 4

33

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d 26 evacuation of residents.

Myers said he thinks the 21

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s in the county withm l0 "It looks to me like it's com-townsh!fLimerick are " making a pletely a paper test. I don't inow u

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what it's supposed to prove at 8 g maua-II8 mea would be evaluated during the velop a workable plan."

all.

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. exercise, the drill should not be "It's ultimately really a mu-

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" 8 38 counted as part of the licensing nlcipal responsibility the use this as an exercise saying, requirement.

county's responsibility is to 'This is going to be a full-scale I

"My concern is PECO is going coordinate the municipal ef.

exercise and we get our 16-

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LEA-2 The unadpoted RERP's fail to provide reasonable assurance th a't each principal. response organization has sufficient staff to respond to

' and,to augment its initial response on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> continual bas.is, or that the assigned staff can respond in a prompt manney in case of a radiological emergency at Limerick.

A survey of volunteer personnel assigned to emergency response roles inside the Plume Exposure EPZlshould be made to determine:

1-the availability of such personnel by time of day; the existence of family commitments of such, personnel, which could interfere with their ability or willingness to respond in a radiological emergency; 3-the willingness of such personnel to respond in a. radiological emergency within the Plume EPZ.

Specifically, The Draft #5 of the Municipal RERP's, dated April 1984 indicate the following staffing needs have not been met, therefore the current plans fail to provide reasonable assurance that the municipal emergency operations centers

'can-be: activa ted: dhd s ta f f ed in a timely fachion,-and that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day response capabilities have been provided.

(A)) deficient:

In Montgomery County, the following municipalities are Collegeville Boro m,ust provide a Deputy EMC a Transportation Officer (Attachments I'and 0) a Deputy Transportation Officer rand 2 Commut

• cations persdnnel Do6g1 dss Twp. must provide 2 RACES personnel (Attachment 0) a.

Green Lane Boro msst provide a Deputy-EMC a Police Service's Officer a Deputy Police Services Officer (Attachments I and 0)

a. Fire / Rescue Officer a Deputy Fire / Rescue Officer a Transportation Officer a Deputy Transportation Offi.cer and 2 Communications personnel Lower Salford Twp. must provide a Deputy EMC (Attachments I and 0) and 2 RACES personnel Limerick Township must pro. vide a Deputy EMC a Police Services Officer Deputy Police Services Officer a

-(Attachments I and 0)

Fire / Rescue Officer a

a Deputy Fire / Rescue Officer a Transportation Officer a Deputy Transportation Officer and 2 RACES personnel u

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Lovar-Frederick Twp. aust' provide a' Deputy EMC m

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a Deputy Fire / Rescue-Officer

-(Attachments I and 0) a Deputy Medio,al Officer 2 RACES personnel and 4 TCP presonnel Lower Pottsgro've must provide ~ a Deputy EMCL Twp..

a Deputy Communications Officer a Deputy Public Works Officer

..and 2 RACES presonnel lMarlborough Twp..needs'a Deputy EMC a Police Services Officer I and: 0) {a a Deputy Police Services Officer (Attachments Fire / Rescue Officer

_ ja Deputy., Fire / Rescue pflicer

a. Transportation Officer 2 'a Depu ty - Transportat, ion 0,f fice,,r j

and 2.. communications personn.el

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.Perkiomen.Twp. needs'a Deputy EMC a Fire / Rescue Officer

-(Attachments a Deputy Fire / Rescue Officer a Transportation Officer I and O) a DeputyeTransportation Officer and.2 communications personnel

~

New Hanbver'Twp. needs a Deputy EMC (Attachments a Fire / Rescue Officer I and O) a Deputy Fire / Rescue Officer

~

a Transportation Officer a Deputy Transportation Officer and 2 RACES. personnel Schwenksville" Boro-needs'a Deputy EMC (Attachments a Deputy Fire / Rescue Officer I and. O).

a Deputy Transportation Officer 4

2 Communications personnel West Pottsgrove'Twp. needs 2 communications personnel

^

(Attachment 0)

Upper Salford Twp. needs a Deputy EMC a Fire Rescue Officer

~

a'DeputycFire Rescue-Officer (Attachments I and 0) a Transportation Officer

~

a Deputy Transportation Officer 2 Communications personnel Upper Provid ence' -Twp. needs a1 Deputy Police Services Officer a Medical Services Officer a Deputy Medical Services Officer (Attachments I and 0)'

a Transportation Officer a Deputy Transportation Officer yg.

a Communications Officer a Deputy Communications Officer

~

a Deputy Public Works Officer 2 Communications personnel

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. A. (continued)

Upper Pottsgrove Twp. needs a Deputy EMC

a. Police Services Officer a Deputy Police Sgrvices Officer (Attachments I and 0) a Fire / Rescue Officer Deputy Fire / Rescue.0fficer a

.j-a Transportation Officer a Deputy Transportation Officer 2 Communications Personnel

~

Upper Frederick'Twp. needs a Deputy EMC

~

a Fire / Rescue Officer

'(Attachments I and 0) a Deputy Fire / Rescue Offic'er Transportation Off* feer

- a a Deputy Transportation Of,ficer

' ~ ' ~ ~ ~ ' "

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- 2 Communication ~s,Per,sonnel Trappe. Boro-7needs

~a Transportation Officer 4-.

a Deputy Transportation Officer" (Attachments a Deputy Transportation Officer I and 0) 2 Communications Personnel

~

Skippack Twp. needs a-Deputy EMC a Fire / Rescue Officer a Deputy Fire /Rescus Officer 2 Communications Personnel

'4 TCP Personnel Lower Frederick Twp. needs a Deputy EMC a Deputy Fire / Rescue Officer a Deputy Medical Officer 2 RACES Personnel 4 TCP Peruonnel

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{ deficient: In Berks County, the following municipalities are Amity Twp. needs a Deputy EMC a Communication Officer Deputy a Public Works Officer Deputy (Attachment I) a Radiological Officer Deputy Colebrookdale Twp..needs a Deputy EMC a Police Service Officer & Deputy a Fire / Rescue Officer & Deputy (Attachment I) a Transportation Officer & Deputy Douglass Twp. needs a Police Service Deputy Fire / Rescue Deputy a Transportation Officer Depu'ty (Attachments I a & 0) and 2 RACES and 3 TCP personnef ". ' ' h Washingt'on' Twp. needs 2 RACES (; Attachment 0) . Union Twp. needs a Deputy EMC Fire / Rescue Deputy a Transportation Officer & Deputy a Communication ^ Of ficer & Deputy (Attachment I & 0) a Radiological Officer &' Deputy ~ and 2 RACES and 1 TCP personnel' Earl Twp. needs Fire / Rescue Deputy a Transportation Deputy (Attachment I a Communicati6n Officer Deputy' & 0) a Public Works Deputy and 2 RACES ((} In Chester County, the following municipalities are deficient: Charlestown Twp.vneeds a Deputy EMC a Fire / Rescue Officer & Deputy a Transportation Deputy (Attachment.I & 0) and 2 ARES East Coventry Twp. needs a Deputy EMC Fire / Rescue'. Deputy a (Attachment I & 0) a Transportation Officer & Deputy a n-d 2 Communications personnel East Nantmeal Twp. needs a Communications Officer Deputy a Public Works Deputy (Attachment I 2 ARES and 2 ACP personnel & 0)

C. (continued) East Vincent ~Twp. needs a Deputy EMC a Police Services OfTicer Deputy a Fire / Rescue Officer & Deputy (Attachment I & 0) a Transportation Officer &-Deputy and 2 ARES and 1 TCP personnel l North Coventry Twp. needs a Deputy EMC a' Police Services Officer Deputy (Attachment.I & 0) - 'a~ Fire / Rescue Deputy-a Radiological Deputy and 2 Commnnications per'sonnel ~. need's a Police Services.Depddy"h Schuylkill Twp. a Fire / Rescue Services Deputf (Attachment I & 0) a Transportations Officer & Deputy ~ and 2 ARES 1 ^^ South Cov-entry Twp. needs Police Services Deputy and all other staff 3 TCP personnel and'2 Communications (Attachment I & 0) personnel Spring City needs a EMC & Deputy ^ including 2 ARES and:all other personnel (Attachment I -& 0) ^ Uwchlan and Upper Uwchlan Twps. needs a Fire / Rescue Deputy a Medical. Officer & Deputy (Atachment I~ & 0) a Transportation Deputy and 2 Communications personnel Warwick Twp._needs a Fire / Rescue Deputy a Transportation Officer & Deputy and 2 Communications personnel (Attachment I & 0) West Pikeland Twp. needs a Police Services Officer & Deputy a Fire / Rescue Deputy (Attachment I & 0) and '2 ARES West Vincent ~Twp, needs 2 ARES (Attachment I) ,e-,e ,~ew-- -e ,s--,

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r-($) The Chester and Montgomery County RERP's fail to pr'pvide reasonable assurance that the Pa. State Police hav~e sufficient staff to carry out the responsibilities outlined in Annex F ~ of the respective County RERP's, (1)S'ecifically, the Chester County RERP fails to provide reasonable p assurance that Troop J in Lancaster County can carry out the functions outlined on page F-1 of the County RERP in a prompt manner. Also: Chester County RERP, Draft'#8,' June 1984 Annex F, Chester County Access end Traffic.C,0ntroh, Points F-4-1 and 2: 22 State Policemen required f6r ACP.'s' F-5-1 and 2: 42 State Policemen require 4,fh'rT0f's T . ~. (2)Specifically, the Montgomery County RERP fails to provide reasonable assurance that Troop K in Limerick can carry out the ( ~ functions listed on page F-1 of the County RERP in a prompt ~ ,. manner. (F-1 II. Responsibilitics) s Alsos Montgomery County RERP, Draft # 6,.'. A p r i l 1984 1nh.Ex "K, Montgomery County Access and Traffic Control Points K-4-1: shows 7 ACP's with staffing needs TBD K-4-2 to 4show that-20~ACP's have not yet had staff assigned to man them -BASIS: 10 CFR 50.47 (b)(1); NUREG 0654 Criteria A.4, Criteria C.4, Criteria A.2a, FEMA Report on the July 25 Limerick Exercise (pages xvi-xvii discussing non-participating jurisdictions, page-135i Class "A" deficiency #1, page *136, Class "A" deficiency #2,*and page 137, Class "A" deficiency #5)

rm vsysgeg. s ELEA-3'- -The Montgomery County RERP. fails to provide reasonable assurance ethat'.the public will.be adequately protected in that the Bucks County Support Plan, which is essential to the workability of the .MontCo RERP, may not be approved..The present Board of Commissioners -have little knowledge of-the contents and implications of the Bucks . County; Support Plan.- There is no assurance that the County will icssumefthe responsibilities assigned to it in the Support Plan, rather .than-use. County resources to help Bucks County people first. -L Th'eyMontgomery County Plan relies on the Support Plan in at least othesel ways: - 1. facilities for-relocation and mass care of evacuees 2. ' augmentation of emergency workers, including use of county-resources,:on a continuous 24 hour basis 3.- See attachment " Excerpts and comments on the' Bucks County Draft EvacuationtPlan" for additional areas of support and ' interface. (Exhibit _#1) I Itnis1 contended that without;the approval of' Bucks County Support Plan,.the MontCo RERP is unworkable as-it now stands. t.m. Furthermore, on July 17,'1984, the BucksfCounty Commissioners 7 rote to PEMA. Director, John Patten advising him that Bucks County was concerned about the potential' conflict between their role as a " Support" County to the Montgomery ~ Co. RERP and their concerns about the need to fulfill Otheir legal responsibilities to protect the people of Bucks County, during 's1 radiological emergency at Limerick. Given the stated concerns of the Bucks 1 County Commissioners, (see attached letter), it cannot be assumed that Bucks wilL assume and carry out its support role to Montgomery County. -. BASIS:

10'CFR 50.47 (b) (1), NUREG 0654, Criteria A 3, Criteria C.4,

~ Criteria A.4 Bucks County Commissioners letter to John-Patten 7/19/84 The_ASLB 4/20/84 stated that on March 14, LEA filed papers which show to mtheir satisf action that Berks and Mont omery Counties would rely a great deal ASLBOrder.) ren Buck.and Lehigh in an emergency. Page 31

• ~

BASIS; LEA-3 COUNTY OF BUCKS OFFICE OF T il E COMMISSIONERS Administration Ruilding. Dnylestaa n. Pa. 15908 215.MN.2911 215 752-02MI Cennty Commissioners WILLIAM H. RIESER CA'L F. FONASH. Chakman County Administrater LUCILLE M. TRENCH Fire-CAskman JAMES M. McNAM AR A ANDREW L. WARREN CemnffSoliciter July 17, 1984 Mr. John Patton, Director Pennsylvania Emergency Management Agency P. O. Box 3321 Harrisburg, PA 17120

Dear Mr. Patton:

The undersigned Bucks County Commissioners have been advised that your counsel, Mrs. Zori Ferkin, has indicated to the Nuclear Regulatory Commission that Bucks County has no reason not to approve the plan for evacuation relative to the Limerick Nuclear Generating Station. This assumption is erroneous. While we were willing to consider a neighborly undertaking with Montgomery County, we presumed that no inferences would be drawn relative to this consideration of the plan. After initial review of the draft plan, the Commissioners are con-cerned about the lack of consideration for the residents of our county. In case of an accident at Limerick, there is considerable risk to Bucks County also and the obstacles to be overcome would be insurmountable. Although we are very concerned fo anyone who might be affected by an accident at Limerick, the Commissioners' responsibility under PL 1332 is to care for our own citizens who may seek to evacuate in large numbers. This would place a substantial burden on County resources. We cannot unknowingly assume responsibility for citizens of other counties and at the same time caring for our own citizens. In view of its statutory responsibility, as well as its common law fiduciary responsibility, Bucks County must deploy its resources to handle the evacuation of its own citizens. We are requesting our Emergency Planning Director and PEC0's employed consultant to determine the extent of potential evacuation from Bucks County, as well as those in transit through the County, and establish the direction of each evacuation, routes to be used, shelter requirements, and personnel and equipment required for management. With the results of such a study, Bucks County will be in a position to determine its ability to assist residents of other counties. V m e ,.,-n. --.-,y- ,.,- -. - ~ -,.

Page Two July 17, 1984 - We are also concerned about evacuees from Philadelphia compounding the burden we are being requested to assume from Montgomery County.. We are apprehensive that our support system and highway sytem would be overwhelmed by an exodus from the Philadelphia area. We anticipate substantial adverse public reaction to the plan which has been drafted because of the significant burden it would place on our residents. Under emergency conditions, this would not prevent the Commissioners from fulfilling our public responsibility. However, we believe the apparent obstacles would impede or deny opportunity to achieve reasonable success in the fulfillment of our responsibilities. As a result of the foregoing concerns, the Bucks County Commissioners find it necessary to inform all agencies that Bucks County is not prepared at this time to participate further in the limited planning and testing process including the planned drill on July 25, 1984. You are requested to acknowledge receipt of this letter, advise all concerned agencies of the contents hereof, and to advise Bucks County if there are any additional steps it needs to take in order to make its position clear. Sincerely, d k. E ca.cu b.. ~' Carl F. Fonash, Chairman Bucks County Comissioners b. Lucille M. Trench, Vice Chainnan i Bucks County Comissioners CFF:LMT:jtb cc: Federal Emergency Management Agency Nuclear Regulatory Commission Montgomery County Commissioners i -n., ,.w..,,_.,,~, --~-,,n .-,n.

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1 - LE A-4 -~ " Withdrawn" LEA-5: The Emergency Response Organizations (including federal, state, -and local governments and support organizations) have failed to fully document the existence of appropriate letters of agreement with support organizations and agencies. Thus, there is no reason-ablesassurance that the emergency plans can be implemented. The.nere listing of employees contained in the the unapproved County.and Municipal RERP's is completely insufficient to assure adequate staffing for the hundreds of emergency. workers needed during a radiological emergency. There must be staff commitments from-all of_the principal and supporting response organizations, -including police, fire personnel, medical workers, bus drivers, teachers, school officials, auxillary traffic controllers, commu-nications workers, and all other essential emergency workers, which indicate.not only generalized good intentions, but specific agree-ments to perform. emergency work under the conditions of a r dio-a logica1' emergency. Specifically, the Risk County RERP's are deficient becaus c-e' Ley lack necessary' required Letters of Agreement for the following support organizations and agencies: ( a )' all transportation providers, especially buses and ambulances (b) RACES and ARES Communications Personnel. .(c). Finalized arrangements for 24 hour EBS coverage '(d) Towing.and-Snow Removal services (for both the County and Municipal RERP's). (e) Host School Agreements for School District RERP's (f) Decontamination Centers and Mass Care-Centers . BASIS ~ (Risk) . 10 CFR 50.47(b)(1), ggggg gggj, {pigepig g.j, County RERP's Annex T, ' Municipal RERP's, Attachment C. LEA-6; " Withdrawn" ~

. LEA-23 The draft county plans are deficient because they do,not,contain reliable evacuation time estimates. ~ 1. There is no basis for the assumption in the Applicant's HMM Evacuation Time Estimate Study that "up to one hour may 'be required to assemble buses, transport vehicles and to load students onto buses". (page 5-5) On June 8th, 1984, Dr. Claypool announced an early dismissal of the Owen J. Roberts School District, which indicated that unless bus _ drivers were notified while they were physically in their buses, that at least a 2 hour de-l lay should be anticipated before'Owen J. Roberts School District would have enough buses for an early dismissal. (See Attachment til of LEA's 7/16/84 Response to Philadelphia Electric Company Interrogatory Responses ---- Memo from Dr. Claypool, District Superintendent, dated 6/12/84) NUREG-0654, Rev. 1, Appendix 4, requires as follows (NUREG-0654, Rev. 1, page 4-2): -2. "A descroption of the methodology of analyzing the evacuation times shall be provided. If computer models are used, a general description of the algorithm shall be provided along with a source for obtaining further information or documentation." It is not clear that the ETEs meet this criterion. The evacuation time estimates do not include an estimate of evacuation times for 3. evacuation time estimates (ETEs)g to NUREG-0654, Rev.1, Appendix 4, these carthquake conditions. A.ccordin will be used by those emergency response .an emergency (ged with recommending and deciding on protective actions duringAccor personnel char NUREG-0654, Rev. 1, page 4-1). contribute about 13% of overall core melt frequency -- total core melt frequency is 4.4 x 10(-5) and seismic core melt frequency is 5.7 x 10(-6) (SARA, Vol. 1, page 12-22, Table 12-1). Moreover, seismically-initiated accident sequences rank 6 8, 9, and 13 of the top thirteen accident sequences contributing to core melt frec uency (SARA, Vol.1, pages 12-23 through 24, Table 12-3). Thus,-it woulc seem possible to argue,'both quantitatively and on a policy basis, that ETEs should include estimates for seismic cases, taking into , account both the lack of the siren warning system and subsidiary damage to . the evacuation network caused by the seismic event.

4. The study assumes that sudden rainstorms reduce effective roadway (capacity by 20% and that snowstorms reduce effective roadway capacity by 30% HMM, page

'2-3). How realistic are these reduction factors for actual local conditions in the Limerick vicinity? Will not these reduction factors vary according to the size of the roadway and the amount of traffic attempting to use each road-in a given period of time? 1

1 . n.f ((LEA-23),

5. No calculations'of time estimates for situations involving

-route alerting has been made. 45' minutes is allowed for route alerting according to--regulations vs. 15 minutes for siren notification. .Sinceta_high. percentage (43%) of the serious accident possibilitics .e involve: blackout conditions and there is no back-up siren power 'such. route alerting situations represent a significant factor. pg 5-2 'HMM Time Estimate Study 6. The survey. performed for ECI through the Counties and upou .which the number (3,039 HMM pg3-2) used by Umm.to estimate evacuation times for-transit dependent populations varies considerably from the -U.S. Census figures used in earlier draft plans. The larger Census . figures, arguably more accurate due to large. con-response to the survey or its non-receipt by many, would affect evacuation time estimates 1for particularly urban areas, making them more realistic. BASIS: NUREC 0654, Appendix 4, 10 CFR 50.47 (2) ~

.\\ ~ y ras. s. A CERTIFICATE OF BERVICE ~ I'hereby' certify that Limerick Ecology Action's Respecification 'of " Deferred" Off-site'Emergenc'y Planning Contentions were hand delivered.to the following parties to this proceeding below' marked. -(*),and were' served on'all other parties by deposit in.Che U.S: sail, first class postage prepaid on this 1st, day of Octob'er 1984.. Those marked?(**)'were served by Express Mail.

• ;... j,

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Hoyt,l Chairman (2) (*) Ann P.-Hodgdon, Xs Q Helen'F. (c) -Administrative'Jddge'. Office'of~the~Ex6 cut.tve.I,egal Directo! ~ U.S. Nuclear-Regulatory U.S. Nuclear Regulat'.ory Commission -. Commission-Washingt'oni DC 20555~ Washington, DC 20555 (*) Benjamin Vogler, Esq. -(0) Dr. Richard F. Cole Office of the Executive Legal Directos Administrative Judge U.S. Nuclear ~ Regulatory Commission Washington, DC 20555 U.S. Nucl' ear Regulatory P Commission-Washington, DC 20555 (*) Troy H. Conner, Jr., Esq. Conner and Wetterhahn ~ 1747 Pennsylvania Ave., NW .(c) -; Dr.- Jerry 11aEbour ~ Washington, DC 20006 Administrative Judge U.S.INuclear-Regulatory-Commission-(*) Philadelphia Electric Company Washington, DC 20555 - Attn:- Edward G. Bauer, Jr. VP and General Counsel Docketing and Service Section 2301' Market St. Office of_the Secretary Phila., PA 19101 U.S. Nuclear

• Regulatory Commission.-

Thomas Gerusky,-Director, Washington, DC 20555 Bureau-of Radiation Protection, DER ~ Sth fl, Fulton Bank Bldg. Atomic' Safety and Third and Locust Sts. Licensing Board Panel Harrisburg,.PA 17120 U.S.-Nuclear Regulatory Commission Spence W. Perry, Esq. Washington, DC 20555' Associate General Counsel FEMA Atomic Safety and. Room 840 Licensing Appeal Panel 500 C St., SW U.S.' Nuclear Regulatory Washington, DC 20472 Commission 4 . Washington, DC 20555 (**) Zori Ferkin, Esq. Governor's Energy Council P.O. Box 8010 1625 Front St. Harrisburg, PA 17105 .., _ ~, - .-._,.._-,-...----._,.__,-._-.m.-,--

l.... -Jay M.'Gutierrez, Esq. Robert'Sugarman, Esq. U.S. Nuclear-Regulatory Commission Sugarman and Denworth 101 Broad Street, 16th. Floor 3 Park Ave. King'of Prussia, PA 19406 Philadelphia, Pa. 19107 ( * *) Director, PEMA - Basement, Transportation-and. Safety Building Harrisburg, PA~17120 Angus Love, Esq./Myggggy Aid) C 107 East Main'St. Norristown, PA 19401 .: t ?

• i Robert Anthony 1~103 Vernon Lane Moylan, PA 19065 Martha W. Bush, Esq.

Timothy Campbell Kathryn S.-Lewis, Esq. Chester County Dep$t. Solicitor's Office f Emergency Services City of' Philadelphia _ 14 East Biddle Street Municipal Services Building West Chester, Pa. 19380 Phila., PA 19107 Frank Romano 61 Forest Ave. Ambler, PA 19002 a Oc toher 'l f.1984 PhyllWs ZitzEr President Limerick Ecology Action .r}}