ML20062L831

Responds to Requesting Assistance in Responding to Concerns Expressed in 920710,10CFR 2.206,petition Submitted by R Gary of Pennsylvania Institute for Clean Air. FEMA Will Continue to Review Offsite Plans & SOPs

ML20062L831
Person / Time
Site:	Crane
Issue date:	12/16/1993
From:	Kwiatkowski D Federal Emergency Management Agency
To:	Congel F Office of Nuclear Reactor Regulation
References
2.206, NUDOCS 9401050281
Download: ML20062L831 (26)

Text

{{#Wiki_filter:O gje'4 f59p?u,#1 Federal Emergency Management Agency Q Washington, D.C. 20472 DEC I6 1993 g $nf Mr. Frank J. Congel, Director Division of Radiation Safety and Safeguards Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Congel:

This letter responds to your memorandum dated July 22, 1992, requesting the Federal Emergency Management Agency's (FEMA) assistance in responding to concerns expressed in the July 10, 1992, 10 CFR 2.206 petition submitted by Mr. Robert Gary of The Pennsylvania Institute for Clear Air to the Chairman of the U.S. Nuclear Regulatory Commission (NRC). Mr. Gary's petition questioned the adequacy of offsite emergency planning and preparedness in the Dauphin County portion of the Three Mile Island Nuclear Station emergency planning zone (EPZ). Specifically, Mr. Gary's petition cited a number of concerns regarding the Dauphin County Radiological Emergency Response Plan (RERP) which, in his opinion, render the plan " essentially-non-operational." These concerns can be classified under the-following three major areas: 1. The Dauphin County emergency operations center (EOC) failed to maintain letters of intent for the county's transportation providers. 2. The Dauphin County RERP lists out-of-date names and telephone numbers for the bus providers and lacks after-hours telephone numbers for those providers. 3. The Pennsylvania Emergency Management Agency (PEMA) and the Dauphin County RERPs f ail to provide for th2.use of military vehicles in the event of a radiological emergency. Maior Areas of concern Summarized below for each of the three major areas of concern is (1) PEMA's response to each concern as delineated in its letter dated July 12, 1993, from Mr. Joseph L. LaFleur, Director, PEMA, to Mr. Robert J. Adamcik, Chief, Natural and Technological Hazards Division, FEMA Region III, and (2) FEMA's analysis of PEMA's response to the identified concerns and applicable portions of the February 1993 Dauphin County plan. A copy of PEMA's letter dated July 12, 1993, is attached. 4 ^ 9401050281 931216 g {DR ADOCK'05000g89

k i i 2 l 1. The Dauphin-County EOC failed to maintain letters of intent for the county's transportation providers. PEMA's Resoonsq: PEMA has begun to place more emph' sis on-a such documentation and to obtain letters of' intent, in the form of Statements of Understanding (SOU), from its' resource. i providers. PEMA's letter dated July 12, 1993, states that:. "The letters of intent are valid commitments of that' intent, although they are not, nor do they purport to be legal or' legally enforceable documents which provide a guarantee of resources. With or without the letterslof agreement, the resources will be available as previously_ demonstrated in numerous emergencies and exercises throughout'the. state." i FEMA's Analysis: PEMA has provided FEMA with SOUs dated September 1992 and October 1992 between Dauphin County _and I the three bus transportation providers. FEMA's review of these SOUs indicates that they moct the requirement of demonstrating'the providers' intent to respond to l emergencies. However, some refinement of these SOUs will be necessary for them to fully satisfy the recommendations i outlined in the FEMA Office of General Counsel's April 30, d 1993, memorandum entitled " Legal Opinion on Letters of j Agreement." i FEMA is currently in the process of developing new policies and guidance based on the FEMA General Counsel's recommendations regarding the* required content of letters of. j agreement, SOUs, etc. Subsequent to-the issuance of the new i policies and guidance,'it will be transmitted to the FEMA Regions for coordination with and implementation by the' States._ The adequacy of all individual State and local governments' letters of agreement, SOUs, etc. would then be evaluated by FEMA to determine their compliance with the updated policy and guidance relative to the content of these documents. Under the General Counsel's current recommendations, future letters of agreement, SOUs, etc. at all commercial nuclear power plant sites across the Nation would generally need to: o State that the transportation provider will make the vehicles, with drivers, available for drills, i exercises, and radiological emergencies. Specify that drivers will be provided with appropriate-o emergency response training. o Contain information en the location of the transportation resources and 24-hour points of contact. for notification and mobilization. -l

e 3 FEMA's analysis of the Dauphin County SOUs also identified some minor discrepancies, which PEMA intends to correct, between the plan and the SOUs and also identified.some language which needs clarification. These discrepancies and areas needing. clarification are as follows: o The names of the bus companies shown on the SOUs do not correspond to the bus companies named on page E-9-5 of the February 1993 Dauphin County plan. For example, Capitol Trailways, one of the bus companies named in the plan, is shown as Capitol Bus Company on the SOU. PEMA indicates that the bus company names have changed and that the appropriate changes will be made during the annual plan review and update of the SOUs so that the bus company names shown in the plan are consistent with those shown on the SOUs. Under FEMA GM-PR-1, Policy on NUREG-0654/ FEMA-REP-1 and 44 CFR 350 Periodic Requirements, October 1,

1985, State and local governments are required to review; update, as necessary and appropriate; and verify through the Annual Letter of Certification that the existing emergency response plans and Standard Operating Procedures (SOP), including SOUs, are current and reflect any plan revisions required to correct plan-related issues and inadequacies identified by FEMA at REP exercises and drills.

FEMA will review the updated plans and SOPS, including SOUs, as soon as they are received to ensure that the above mentioned changes have been made and that they are consistent. The SOUs do not indicate the average capacity of the o buses which would be made available to the county. PEMA states that the SOUs will be changed to reflect the average capacity of the buses at the time of the SOU's annual update in 1993. FEMA will review the updated SOUs to verify this information, o The SOUs state that " transportation resources identified" will be updated annually under separate cover. This statement raises two basic issues that PEMA will need to address in the next SOU update. (a) First, exactly what type of information is reflected by the " transportation resources identified" number? Does this number reflect the total number of buses owned by the bus company or the number of buses which would be made available to the county to meet identified transportation needs in the event of a radiological emergency at Three Mile Island? Realistically, it should reflect the latter number to facilitate the

E 4 county's accurate determinction of itE unmet needs, if any, for transportation resources. If that is the case, then the term " transportation resources identified" should be changed to " transportation resources available." (b) Second, it is not clear what is meant by the statement that " transportation resources identified" will be updated annually under separate cover. The method for updating this information needs to be clarified by PEMA. Regardless of how the information is updated, the information reflected in the plan.should always be consistent with what is shown in the SOUs. FEMA will continue to work with PEMA to (a) refine the SOUs in keeping with the recommendations of FEMA's Office of General Counsel and any future policies and guidance and (b) ensure, through the annual plan review and update of the SOUs, that the information presented in the SOUs is clear and consistent with that reflected in the current Dauphin County plan. 2. The Dauphin County RERP lists out-of-date names and telephone numbers for the bus providers and lacks after-hours telephone numbers for those providers. PEMA's Response: PEMA has revised the Dauphin County RERP as of February 1993. PEMA updated the contact names and telephone numbers for bus providers. Since telephone numbers are not needed or intended to be shown in the county plan, PEMA moved this information to the SOPS for the applicable county staff persons. FEMA's Analysis: Prior to the May 19, 1993, Three Mile Island exercise, FEMA Region III telephoned the three bus providers listed for Dauphin County and verified the contact names and telephone numbers, including off-hours numbers. Region III subsequently reviewed this information in the SOPS and verified its accuracy. In addition, during the May 1993 exercise, the Dauphin County transportation staff members were observed making actual telephone calls to the three bus companies--Capitol Trailways, Schlegel, and Capitol Area Transit. The staff ascertained the number of buses available from these companies and notified the municipalities that their unmet needs would be net. According to the plan, 56 buses would be needed to fill the municipalities' unmet needs, in addition to the 96 buses already available from :ounty resources. PEMA was apprised of the county's unmet need of 56 buses and supplied (simulated) 56 buses from State resources--the D. R. Fisher, Rohrer, and Manson bus companies.

4 e 5 FEMA will continue to check the accuracy of this information during its annual review of the Dauphin County plan, SOPS, and SOUs and during the Three Mile Island biennial REP exercises. 3. The PEMA and the Dauphin County RERPs fail to provide for the use of military vehicles in the event of a radiological emergency. PEMA's Resoonse: Pennsylvania's emergency response plans do not rely upon military vehicles for the initial response during an emergency, because to do so would be more time-consuming than the process currently outlined in existing emergency response plans. Rather, the Pennsylvania Army National Guard (PAARNG) is used to support counties on a contingency basis for radiological and all other emergencies. PEMA's letter dated July 12, 1993, provides the following detailed information regarding the State and counties' acquisition and utilization of the PAARNG resources in the event of an emergency: "The Pennsylvania Army National Guard (PAARNG) provides a battalion to assist each risk and support county. Each county plan, available at FEMA, has an appendix which includes the OPLAN appropriate for that county. Dauphin County happens to be supported by one battalion with backup as necessary by a'second specified battalion. The units are directed to forward assembly areas (to be determined at notification plus two hours). It takes the units six hours to assemble and be prepared to move from their armories. Because the National Guard is not a first response organization, more definitive missions are not assigned, because they are secondary support systems in case of overload and manpower support for routine activity. Their specific tasks will be determined when the units become available and the needs of the county EMA have become solidified in light of the events as they unfold. The National Guard missions in support of civil authority are contingency oriented. The Guard is equipped with combat, combat support and-combat service support vehicles and aircraft that do not lend themselves to the safe and orderly movement of civilians. For these reasons, the Commonwealth does not plan to use National Guard trucks to evacuate civilians. We have identified more than enough civilian bus assets to accomplish that task for the portion of the population that may not have a method of personal transportation.

r e 6 The reasons for not using National Guard assets for evacuation were explained in person to Mr. Gary in an October 2, 1992 meeting with Senator Shumaker, of the Pennsylvania General Assembly, and Commissioner Sheaffer, Chairman of the Dauphin County Board of Commissioners. We further disabused him of the idea that the Army depots in the state had ' acres and acres of trucks' available for use in evacuations. The facts are that the military depots do not have assigned to them Table of organization and Equipment truck companies. The depots rely primarily on commercial haulers and, occasionally, U.S. Army Reserve truck companies using flat bed trailers during their annual summer training. To provide a list of National Guard equipment that could possibly be deployed in the event of an evacuation at TMI is not necessary, because these assets would be called up as needed and could include very little or large portions of the PAARNG inventory, if they were appropriate which is doubtful. Such guess work would not improve the plan, nor would it approach any definable level of accuracy. The entire assets of state government are available in an emergency." FEMA's Analysis: According to PEMA, the Dauphin County RERP and the computerized data base maintained at the State identify sufficient non-military sources of emergency transportation to meet the expected evacuation transportation needs of Dauphin County residents without calling upon the PAARNG. The State RERP and the February 1993 Dauphin County RERP specify that the PAARNG may provide assistance, such as emergency transportation, to the county in the event of a radiological emergency on an as-needed, mission basis. However, during the May 19, 1993, exercise, PEMA requested the PAARNG to provide as many ambulances as possible in response to a plan-identified Dauphin County unmet need of 203 ambulances. The PAARNG supplied (simulated) 60 ambulances. Howaver, since PEMA's concept of operations does not rely on the FAARNG as a first response organization, the unmet ambulance need will be pursued as an issue with PEMA. In view of (a) PEMA's statements that the PAARNG is not a first response organization, but rather a secondary or contingency-oriented responder, and that the Commonwealth does not plan to use PAARNG trucks to evacuate civilians and (b) the fact that the current RERPs-imply a more direct role for the PAARNG, the current State and county RERPs should be reviewed and modified, as appropriate, to more clearly define the exact role of the PAARNG. PEMA will be requested

O a 7 to address this issue during the next annual plan review to ensure that the plans clearly and accurately reflect the Commonwealth of Pennsylvani.a's concept of emergency operations relative to the use of the PAARNG. Additional 10 CFR 2.206 Petition Ouestions In addition to the three major areas of concern raised in the initial 10 CFR 2.206 petition, a number of questions were raised by Mr. Gary in subsequent correspondence with the NRC dated December 2, 1992; January 15, 1993; and February 14, 1993. This correspondence was forwarded to FEMA Headquarters for inclusion in its response to Mr. Gary's 2.206 petition. In reviewing FEMA Region III and PEMA's responses to Mr. Gary's additional concerns, FEMA Headquarters consolidated these concerns into nine questions. These questions are listed below. Information regarding PEMA's response to these questions, along with FEMA's analysis of PEMA's response and of applicable portions of the February 1993 Dauphin County RERP, is provided below each question in the same format used above for the three major areas of concern identified in the original 10 CFR 2.206 petition. 1. Why are we 50 school buses short in Dauphin County and what does this mean for the affected residents? PEMA's Response: The unmet needs of the county can readily be supplied by assets identified from providers maintained in the computerized data bankh in the State EOC. To engage in justifying the changing unmet needs with resources available to the State would place all concerned in an endless numbers chase. The provisions for fulfilling current unmet needs are part of the State EOC SOPS and are demonstrated and evaluated by FEMA during biennial REP exercises. FEMA's Analysis: The February 1993 Dauphin County plan reflects an overall unmet county need for 56 buses. The county plan states that unmet county needs will be reported t.o PEMA. The State plan requires the Pennsylvania Department of Transportation to develop and maintain an inventory'of statewide transportation assets for use in evacuating the risk counties. PEMA states that information about transportation providers is maintained in the computerized data banks at the State EOC and that the procedures for meeting the unmet county needs are part of the State and county SOPS. During the May 19, 1993, biennial REP exercise, the. procedures for reporting and meeting the unmet county transportation needs were exercised. During this exercise, Dauphin County submitted a request for 56 buses to the State and the State responded to the county's request by identifying 56 buses which were

4 j& i { p~.. { 8 available from three bus companies maintained in the State's ti inventory of! transportation assets. 2. What are the telephone numbersLof the-commanding and/oriduty. officers-who would be called to activatefthe. evacuation trucks? Where in the Dauphin County RERP cantthis? i information be found? Whichimilitary units are tasked.with-d supplying vehicles for evacuation?.-Are designated drivers- '{ and company commanders identified by name? 'What type of briefings have these personnel: received? Have specific trucks been designated for use:in evacuating Barrisburg or l other Dauphin-County jurisdictions? Rave staging; area-locations and evacuation routes for these trucks been a, delineated on Dauphin County maps? PEMA's ResDonse: Since the Pennsylvania plansLrely entirely upon civilian vehicles for evacuation in the event of a radiological emergency, and military vehicles are.only used. if the PAARNG has been activated and evacuation assistance is specifically requested, it is not necessary or-l appropriate for~the. Dauphin County plan to include the type of information' requested above. FEMA's Analysis: FEMA agrees with PEMA's position. As I stated above, PEMA will be requested to more clearly. define the exact role of the'PAARNG in the next. plan-review and j update. 3. Has a mechanism been set up to coordinate the activation and use of the PAARNG with local officials?- l PEMA's Response: The information is in.the PAARNG's SOPS'for all emergencies. FEMA's Analysis: Two sections of the' State RERP- " Department-of Military Affairs (DMA)" on pages E-21 and1E-22'and Appendix 13, " Military Support,"--also contain information-J on the use of the PAARNG, on an "as needed basis," in radiological emergencies. However, information? pertaining + to the specific mechanisms ~for' requesting the PAARNG's. assistance is not clearly presented inethese plan sections. Essentially, the State plan outlines two'different~ procedures to be followed when'a county requests the PAARNG's assistance, but fails'to" clearly identify:the circumstances triggering each procedure.- j In addition to the State plan's lack of clearly. differentiated procedures for processing county.reqpestsLfor PAARNG' assistance,-thejplan does not indicate,.upon thel Governor's ordering:of the.PAARNG to State active duty, j whether (a) the PAARUG is: activated for, and-battalions are-deployed to,.all risk counties, even if they have not a -i i

p.m 1 1 1 t; 9 1 requested PAARNG assistance, or (b) a battalion is deployed ] to a risk county only after it has submitted its initial request for PAARNG assistance. If option (a) is correct,- i then there.could be a situation where a-risk county's battalion is already in; place and that risk county's initial-request.for assistance would be directed to the battalion through the county's PAARNG representative, rather than-to-1 the Stato through the county DMA liaison officer. This portion of the State plan needs to:be revised to clearly outline the procedures to be followed in activating the PAARNG and processing county requests for PAARNG assistance. Appendix 8 of the Dauphin county plan outlines-the role of the PAARNG in. radiological emergencies and contains a copy. of the PAARNG plan', entitled "OPLAN 3-109 IN, Operation Nuke j II - Dauphin County." This plan describes the PAARNG's M procedures for mobilizing and executing support to Dauphin County in the event of an incident at Three Mile Island. I However, the county plan does not indicate the procedure to be followed by the county when requesting PAARNG assistance. 1 The Dauphin County plan also specifies that, after PAARNG-activation, the-PAARNG will provide direct support to the county and send liaison personnel to the county'EOC. Although the State plan, page E-22, specifies'that.the State DMA~ Emergency Preparedness Liaison Officer will supply a DMA representative to the risk counties to coordinate requests for PAARNG assistance, the Dauphin County planJdoes-not. 1 specify'that the State will provide a DMA. representative, describe the role of this representative, cr distinguish between the functions of the DMA representative and the PAARNG liaison personnel. The county plan should be revised to specify:- o The procedures for processing the-county's initial request for PAARNG assistance and requests for assistance after the PAARNG has been activated. 1 o That DMA and PAARNG representatives will be deployed to the county EOC, the entity responsible for their deployment, the circumstances under which'they will be deployed, and their functions at the county EOC. 4. Are there any maps which. indicate that the PAARNG will be activated for evacuation purposes, rather than for peace-keeping purposes? PEMA's Response: The information is in the PAARNG's SOPS for all emergencies. FEMA's Analysig: Information concerning the missions for which the PAARNG can be activated is also found in l

10 Appendix 8 of the February 1993 Dauphin County plan. Appendix 8 states that, once the Governor has ordered the PAARNG to State active duty, the FAARNG will provide direct support to the county to perform a variety of radiological emergency response missions as a supplement to the county's resources. Most of these missions, such as traffic control, emergency transportation, emergency fuel on evacuation routes, and emergency clearing of roads, are evacuation-related, not peace-keeping missions. A specific PAARNG battalion (3rd Battalion, 109th Infantry) and a back-up PAARNG battalion are assigned to Dauphin County for these potential missions. 5. What is PEMA doing to supervise the counties and to ensure that they are in compliance with standard procedures for emergency readiness? Is PEMA in violation of its founding statute (Title 35, Pennsylvania Consolidated Statutes, section 101) which calls for PEMA to backstop the counties and build two warehouses and stock them with emergency supplies? PEMA's Response: During an October 2, 1992, meeting attended by Mr. Gary; Senator Shumaker of the Pennsylvania General Assembly; Commissioner Sheaffer, Chairman of the Dauphin County Board of Commissioners; and Mr. Joseph LaFleur, Director, PEMA, the level of supervision by PEMA of the counties and PEMA's actions to provide supplies and equipment to the counties during emergencies were discussed with Mr. Gary. In addition, PEMA's General Counsel, in a July 15, 1992, letter to Mr. Gary, responded to Mr. Gary's specific earlier question as~to why the two regional warehouses cited in Title 35 have not been established by stating that (a) the legislature has not allocated funde for this purpose, even though the requirement is in the law, and (b) such expensive facilities are ill-advised, since PEMA has stockpiles of emergency supplies at'other departmental facilities, such as Torrence State Hospital and Pike Center. FEMA's Analysis: FEMA agre.T with PEMA's position. A copy of the letter from PEMA's Gs7eral Counsel dated July 15, 1992, is attached. 6. Are there deficiencies in the county plans, similar to the failure to maintain current information on bus company contacts and their telephone numbers, which PEMA does not know about? If there might be such deficiencies, what steps are being taken to review these plans for adequacy? PEMA's Resoonse: The cycle of plan reviews and updates was explained to Mr. Gary at the October 2, 1992, meeting. The plans are viewed as "living documents" which are never considered finished and are changed as the need arises.

11 FIMA's Analysis: FEMA's review of the February 1993 Dauphin County plan's provisions for emergency transportation identified omissions and discrepancies with respect to the plan's transportation and ambulance resource numbers. FEMA will continue to review the annual plan revisions to identify areas of required and recommended plan. improvements. In addition, FEMA will thoroughly review all the Three Mile Island plans, including the Dauphin County plan, when they are submitted by the Governor of Pennsylvania for the formal 44 CFR 350 plan review and approval. 7. Why-has PEMA not been more aggressive in seeking resources from the Pennsylvania General Assembly? In order to assist the counties in planning for and executing evacuation logistics, why does PEMA not obtain more resources from the-General Assembly or the nuclear licensees and make distributions of these resources to the counties? PEMA's Response: At the October 2, 1992, meeting,.Mr. LaFleur explained to Mr. Gary that there is insufficient justification from the counties to ask the utility rate payers to assume the additional $5,000,000 in costs advocated by Mr. Gary to support county radiological emergency response activities. Pennsylvania's Senator Shumaker strongly stated that he could not and would not place such a burden on rate payers when Pennsylvania was in the throes of a serious economic recession. PEMA has requested, both through State government channels and from the utilities, more funds to meet the costs of the REP Program. However, the utilities have stated that they are reluctant to provide more stockholder or rate payer funds to PEMA. FEMA's Analysis: FEMA believes that PEMA has taken reasonable steps to acquire additional resources. 8. Is a strictly delineated 10-mile emergency planning zone reasonable for Three Mile Island, considering that a highly populated area, the capitol city of Harrisburg, is just outside the 10-mile limit and is, therefore, excluded from PEMA's evacuation plans? PEMA's Response: The 10-mile EPZ concept is based upon NRC and Environmental Protection Agency studies which indicate that the area affected by significant radiation exposures from a nuclear power plant accident would be limited to an area within 10 miles of the plant. The emergency response organization within 140 miles of Three Mile Island can be extended beyond 10 miles if conditions warrant.

Also, Pennsylvania already maintains the most conservative evacuation policy--360* of the entire 10-mile EPZ--within

L 1

12 the United States. PEMA's letter dated July 12, 1993, states that "...unless FEMA and the NRC are willing to state publicly for the record that the 10-mile EPZ is inadequate and that exceptions must be made for Harrisburg and other similar EPZs near large population centers, the PEMA will continue to follow NRC and FEMA guidance regsrding such planning. Harrisburg believes...that they could handle their population if there was a widespread evacuation. The state concurs." FEMA's Analysis: FEMA agrees with PEMA's interpretation of the guidance governing the size of the 10-mile EPZ. It should be noted, however, that Steven R. Reed, Mayor of Harrisburg, indicated in a February 8, 1993, letter to Mr. Gary that contiguous areas to the 10-mile EPZ in the City of Harrisburg would also begin to evacuate, if the 10-mile EPZ was evacuated due to a radiological emergency at Three Mile Island. The Mayor also noted in his letter that the City of Harrisburg has identified and would be able to mobilize sufficient resources to support the evacuation of both Harrisburg's portion of the 10-mile EPZ and the contiguous areas of Harrisburg to the north.. In his January 15, 1993, memorandum to the NRC, Mr. Gary stated that he found PEMA's positjon of following NRC/ FEMA guidance, instead of taking the initiative and including the entire City of Harrisburg in the 10-mile EPZ'and RERPs, to be unacceptable. During a December 1, 1993, meeting of FEMA and NRC staff members with Congressman George W. Gekas of Pennsylvania's 17th District, which includes the Three Mile Island site, Mr. Robert A. Erickson and Mr. Falk Kantor from the NRC's Emergency Preparedness Branch discussed the technical basis and rationale for the establishment of the 10-mile EPZ requirement in NRC regulations. 9. What standard does PEMA seek to meet in its emergency preparedness drills? Are the drills purporting to test the equipment or the emergency responders? If the drills are to test the responders, then they should be unannounced and held at various times of the day and night and, therefore, more closely approximate an actual emergency event. PEMA's Response: During the October 2, 1992, meeting, PEMA explained to Mr. Gary that, due to funding limitations, Pennsylvania relies heavily on volunteers to staff the county and municipal EOCs and schedules the biennial REP exercises in the late afternoon to accommodate these volunteers. Although the volunteers would be willing to respond to an actual emergency at any time, they cannot afford to leave their regularly scheduled work activities for an exercise. Mr. Gary made it clear at the October 2, 1992, meeting that he wanted to impose upon the radiological emergency response program the same response standards as. a

3 4 i 13 those maintained by active military units. PEMA believes that it is not feasible to apply military standards to a civilian system which relies significantly upon volunteers. FEMA's Analysis: FEMA agrees with PEMA's position. It should be noted that under FEMA-REP-14, Radiologica} Emergency preparedness Exercise Manual, September'1991, all offsite response organizations (ORO demonstrate cheir emergency response) are required to capabilities in an unannounced inode (Objective 32 - Unannounced Exercise or Drill) and in an off-hours mode (Objective 33 - Off-Hours Exercise or Drill) once every six years through an unannounced and off-hours exercise or drill. Off-hours exercises or drills require ORos to demonstrate the capability to respond between the hours of 6:00 p.m. and 4:00 a.r on weekdays or any hours on weekends. The unannou..eed and off-hours objectives were most recently demonstrated at Three Mile Island on June 26, 1991. Subsequent to the filing of the 10 CFR 2.206 petition, Mr. Gary raised two additional issues during a telephone conversation with the NRC. Although these issues are not considered by the NRC to be a part of the original 10 CFR 2.206 petition, they were addressed by PEMA in its overall response to the 10 CFR 2.206 petition. The two issues and PEMA's responses are presented below: 1. The population numbers in the' Dauphin County plan do not reflect current (1990 Census data) population figures. The February 1993 Dauphin County plan contains 1990 Census population data. 2. Evacuation time estimates have not been revised since the early 1980s. A new evacuation time estimate study is being prepared by the licensee's contractor. A draft has been completed and the final study should be completed by mid-1994. The new evacuation time estimates will be included in the 1994 update of the Three Mile Island plans and procedures. Recognizing that (1) RERPs are dynamic, living documents which are always being changed and updated through the annual review process to reflect changes in the EPZ,. emergency management policies, and organizational relationships and (2) PEMA is actively engaged in the development and refinement of RERPs for all of its sites in compliance with established FEMA /NRC planning standards, FEMA believes that the offsite emergency planning issues identified by Mr. Gary in the 10 CFR 2.206 petition are being satisfactorily addressed. This assessment in based on PEMA's response to the specific issues raised and its continuing i J

6 14 efforts to refine the plans and correct plan inconsistencies and inadequacies as well as on FEMA's review of the plans and supporting materials. Based on the factors listed below, FEMA concludes that the offsite radiological emergency response plans and preparedness for the Three Mile Island Nuclear Station are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the public health and safety in the event of a radiological emergency at Three Mile Island. The factors are: 1. PEMA's continuing efforts in the development, revision, and refinement of the Three Mile Island RERP. 2. FEMA's review of the concerns identified in the 10 CFR 2.206 petition and related correspondence and PEMA's response to those concerns. 3. The results of the May 19, 1993, Three Mile Island exercise as presented below: There were no Deficiencies identified at the exercise, o o The draft exercise report, received at Headquarters on August 27, 1993, identified 40 Areas Requiring Corrective Action (ARCA), six Planning Issues, and three Areas Recommended for Improvement (ARFI). Four ARCAs and one Planning Iqsue were identified for Dauphin County and one ARFI was identified for the Dauphin County Mass Care, Monitoring, and Decontamination Center. These issues did not pertain to the concerns raised by Mr. Gary in his petition, Headquarters is in the process of reviewing and o providing comments on this 340-page, draft exercise report. Headquarters' comments will identify several additional State / Dauphin County ARCAs and Planning Issues pertaining to procedures used by the State and county to fill unmet evacuation transportation needs. The exercise performance also indicated some areas in which the plans and procedures for this process need clarification. The revision of these plans and procedures will improve the State and county's ability to respond to, and verify the resolution of, unmet needs. The State has also received a copy of the draft exercise report and has responded to the inadequacies identified in the report. FEMA Region III will monitor the State and local governments' correction of all exercise inadequacies. In closing, FEMA reiterates that it will continue to closely review the offsite plans and SOPS, including SOUs, for Three Mile

g H;( i i 15-l Island. Appropriate technical assistance will also be provided to PEMA to ensure that the'necessary revisions and updates are made in a consistent, timely, and orderly manner. i Should you have any questions regardingLthe foregoing material r and attachments or require further'information, please call 3 Mr. Joseph A. Moreland, Director, Exercises Division, at j (202).646-3544. t Sincerely, 4 jaw M-Dennis H. Kw atkowski Deputy Asso late Director Preparedness, Training, and i Exercises Directorate Attachments 4 cc: Congressman George W. Gekas FEMA Region III i k i i 1 1 W l i ] i 1

PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY BOX 3321 HARRISBURG. PENNSYLVANIA 17105 3321 July 12, 1993 Hr. Robert J. Adamcik Chief, Natural and Technological Hazards Division raderal Emergency Management Agency, Region III Liberty Square Building (Second Floor) 105 South seventh street Philadelphia, PA 19106 tear Mr. Ada=cik This responds to your letter of Aprii 30, 1993, regarding Mr. Gary's 10 CTR 2.206 petitien about of fsite Radiological Emergency Response Planning issues for Three Mile Island. Nuclear station. Perhaps TEMA headquarters could have been more selective in requesting information. The breadth of the information not went far beyond the issues of interest or those which have been previously addressed by the Pennsylvania Emergency Management Agency to the Federal Emergency Management Agency.. Much of Mr. Krimm's April 12, 1993, memorandum does. not pertain to acters Gary's petition (see rederal Register Vol. 57, No.157 Thursday, August 13, 1992, pgs. 36415-36416). I will indicate wherb-the issues raised have already been addressed either to TEMA or to Mr. cary directly. The fo11cwing comments are keyed to the paragraphs beginning on page three of Mr. Krimm's April 12, 1993, memorandum to Acting Regional Director Thomas. la. The recapitulation of ' Dauphin County transportation resource needs is found on page E-9-14 of Annex E, Radiological Emergency Response Procedures to Nuclear Power Plant Incidents, Dauphin County Emergency cperations Plan, which has been provided to TEMA III. These numbers change as the plan is periodically. updated. The unmet needs of the county can readily be supplied by assets identified fecm providers maintained in the computerized data banks in the State Emergency operations Center. To engag3 in justifying the changing unmet needs with resources available to the state would placa all concerned in an endless numbers chase. The provisions for filling current unmet noeds are part of the state Eoc standing operating Procedures and are demonstrated under FEMA evaluation during biennial exercises. The May 1993 TMI exercise provided good demonstration of this fact. FEMA *o exercise records for the unmet need for ambulances is a good example for the petitioner. Ib. Not all ambulance services operate 24 hours per day, hence vta referral, they correctly have the caller talk to "9-1-1" in the case of an e=argency. The county, however, has the radio pager nummer of the person on call for each ambulance ecmpany. fer 1

a,- } ~ L Pnqu 2 < 24-hour recall purposes. The statement 'that "The significance of L and rationale for certain ambulance service calls.being referred 'i to-911~ should be ascertained and appropriate explanatory narrative and/or modifications incorporated into the plane. All revised plans miatorials should he provided to FEMA Region'!II and: Headquarters for review," does not. acknowledge-the caemon-practices used all over the U.S. i There is nothing terribly new or esoteric about the use of pagers j A to summon emergency response personnel'. TEMk is aware of.-many such technologies for ooergency response. Additionally, the assertion that referral; of calls for non-24: y hour emergency services to 9-1-1 "is ' unacceptable" is specious and without merit. pennsylvania has 'been embarked' on a program for several years to expand 9-1-1 coverage throughout the commonwealth. Eight million of the nearly 12 million citizens ~inL the state are served by 9-1-1. This involves 30' counties,-three municipalities, and one regional system. Importance has provenj -l that pagers controlled by centraliked county (9-1-1) dispatchers provides an extremely rapid alert and notification system that. j represents the state of the art. The revenues from 9-1-1 -line charges. currently provida $52,000,000 per year to support public safety within the state. We have no intention of abandoning a - common national practice of employing modern and officient alert i systems. This is not a part of the 2.206 petition. l 1c. in my November. 4, 1992 - letter to Region III,.I explained-that " Reliance upon military' resources.for the ~ initial response during an emergency would be more time ' consuming : than the ~ current j system." The Department ~ of Military Affairs (DMA) provides; 1 liaison personnel to the state Eoc.- and the risk. and support I county EMAs. The pennsylvania ' Army National Guard '(PAARNG)- provides' a battalion to Assist each risk and support county. Each county plan, available. at, FENE, - has an appendix which-includes the CPI.hN appropriate. for that. county.- Dauphin County happens to be supported by one primary battalion with; backup as e necessary by a second specified battalion. The units are directed to forward assembly LareasL (to.be ' determined-at notification plus two hours). It takes.tho' units six hours to l assemble and be prepared to move from their armories. secause ~ the National cuard is not a first response organisation, - more - definitive missions are not assignedi because theyf are secondary j support systems in case of overload and ~ manpower : support for routine activity. Their specific taske will be determined when' the units become available and the needslof the county l EMA have 1l become solidifind in light.'of the events ' as they ' unfold.^ The 1 . National Guard missions.in support of. civii' authority are; i contingency oriented.. The Guard is equipped with' combat, combat j ~ support and combat - service support vehicles ; and-aircraf t that ' do J not lend' themselves to the safe and orderly' movement of j 'I civilians. For thes's reasons, the coamonwealth does'not. Plan to

A pg,- j. o = . National.. cuard ' trucks to evsouate'. civilians. We have

i use identified ' more. than: enough civilian bus assets : to accomplish that task'for the portion.of-'the population that may not have a i

A method of personal. transportation.- 4 The reasons;for not using National' Guard assets for evacuat' ion - were explained in person to ' Mr.. Gary Lin < an. October. 2,--19922 meeting with-senator shumaker, of this Pennsylvania ceneral Assembly, and Commissioner Sheaffer, Chairman of the Dauphin county soard of. Coassissioners. We further disabused him.of. the. idea that the Army depots, in the state _ had "acree and acres -of 1 trveks" available for use in evacuations. The facts are that the, l military depots. do-not have.' assigned to them Table of Organisation and ' Equipment (TOGE). truck - companies. : The ' depots - rely primarily on cosusercial haulers and, occasionally,_U.S. Army. 7teserve truck companies using flat bed trailers ; during their q annual summer training. To provide a list of National Guard i equipment that could' possibly be ' deployed in the event of' an j evacuation at TH3.is not necessary, because these assets would be ~ called.up as: needed and could include very little er large portions of'th.e.PAARNC inventory, if they.were appropriate which. I is doubtful.- Such: guess work would not improve the plan,' nor would it approach any definable measure of accuracy.. The; entire i assets of state government are available in an emergency. i secause of their purposely limited nuclear power plant mission-orientation, full training schedule and turnover rate, PAARNG' soldiers need'not receive " civilian radiological" training beyond that provided'in their Army annual' training program. I 2a. The substance in the ietters of

intent, statements of.

understanding or similar documents is valid. - The names of-the -i bus. companies have changoit and will be revised,in; the plan' as 7 well as the letters during theLperiodio reviews. 'The correct names now are Megine Valley ' Lines,' Inc. ' (formerly Schlegal ( Transportation service);_ Capital-Bus : Ccapany - (Capital Trailways ~ is. the corporate name); and capital Area Transit Sus ' Company (vice capital Area Transit). i 2b. The letters of intent do indicate the number of buses. each company would make available. The letters of intent will!be 5 changed to reflect the average capacity of those busses,by their-annual update. 2c. There : ia no specific training; provided for ' bus drivers, nor -is j there.any required' in NUREG-0654 - l FEMA-AEP-1. Bus-. drivers departing.the'EPE during an evacuation are a part of~the general _ l public, which also receives no _ specific training. - posimetry will not be issued to bus drivers, because they will not be reentering. I the EPZ and'they are not emergency workers. r 'I

..Paq2 4 e The April 16, 1992, TEMA Headquarters demorandum subject: Semple' Letters of Agreement for Transmittal-to the Pennsylvania Emergency -Management Agency (FEMA) in Connection with 'the susquehanna steam Electric station.offsite Radiological Emergency Response Plan Review, that was transmitted to PIMA by the Region III letter of May 1, 1992, contained 17. examples of-letters of a sgreament that were to assist ' the -: PEMA "... in preparing pertinent letters of - agreement for. inclusion-in the offsite 1 radiological emergency response. plans, site-specific to 'the i Susquehanna steam Electric station (8858)." Only two of these examples made the vaguest references to training.- None. cf :them used the language prescribed by the TEMA Headquarters April 12, 1993, marmorandum to Region III to wits l " Review of the SOUs indicates that there is no reference to' I the training of bus drivers in regard to dealing with emergency response situations." the drivers should be trained and educated about the nature of radiological emergencias, the proper use of j dosimetry, etc." the,50Us should contain a statement that the company. agrees to cooperate with the utility and State r_nd local. governments by allowing its drivers adequate time to participate in pertinent radiological response ' training. and - exercise-related activities required under NUREG-0654/TEMA-REP-1, Revision - 1, and outlined : in Three Mile Island's State and Radiological emergency response plans." (Note that the State and local plans,for TMI 'do not outline driver training as described above.)' J As we have discussed on several occasicas, Pennsylvania is clearly being reviewed at a higher standard : han other. " nuclear. l states" that is unnecessary,,but most imports n, does not apply i in the case of Dauphin County bus assets. 'I 2d. The letters of intent are valid ;osaitments of that intent, although they are not, nor do they purport to be legal or legally 1 enforceable documents which provide'.aK guarantee of. - resources. With or without letters of. agreement, the resources will be available as previously demonstrated in numerous emergencies and exercises throughout the state. -1 As described in. paragraph 2c above, the TEMA Headquarters' 'l prescriptive language in paragraph 2d' does not appear'in.any-of the sample sous provided to wit "The language in the SOU should reflect the provider's understanding that (A) adequate vehicles ..l and drivers are available to meet the resources enumerated in the 50U and (b) drivers are fully aware of and understand their 1 individual responsibility to drive

a. bus, if required, to

. f acilitate an evacuation of Dauphin county in the event of a .j radiological emergency at Three Mile Island." Again, the topic-j J TEMA is researching is not gerinane,

[., 1Page 5 4 4;. 3a. There is neither reason'nor intention to add phone-numbers to the various ' pages of the County-. Radiological Procedures..The phone numbers are available in s0Ps used-by.the respective county staff - .l persens. In. addition, - as. mentioned in ' paragraph 1b above, the county has the ability to tone page. all ambulance 'organisations.: This issue was not raised in Mr. ' cary's 10 CFR -2.206. petition as ~ described in the Federal Register of - August -13,1992. 3b. The itame listed' in -this ' paragraph constitute _ - administrative - updates that are being addressed and will be ' cleared up -at " the next annually required update. Again, this-issue-was not raised in the 2.206 petition. Jc. This will be clarified at the next plan update. Ll t Jd. It is not necessary to label pages I-7-21 and E-9-3'through E-9-5 to *'... indicato clearly that the information reflected on these ' l pages ' pertains to Dauphin county. since the pages are in the Dauphin county Plaa and list specific Dauphin county : unique: organizations, to what other county could they possibly be ; i referring? This is a matter of style that surely can be left to the county's discretion. Ji r 3e. Your planning suggestions, while not. a part :of ths;L2.206 petition, are appreciated and will be considered at,the next plan' l update. 4. You ccrrectly noted that these items are not a part of the'2.206 hI petition.- Tor. your information, '1990 population. data' is reflected in the current'rebruary 1993 Dauphin county Annex E-(fcr. example see E-10-2). As the 1990 census data is' produced by. ~ the U.S. Census Bureau and provided to the-Penn " State Data .I center, the information is processed and provided to the county ~ for incluston. in the. subsequent. update of-thel plan 'and 1 procedures. The Ivacuation ~ Time Estimate is being prepared.by. the power plant. contractor,. The process' began.in July 1992 and l 1s estimated ~ to be completed in August 1993. The new numbers j will^ be included in the next regularly scheduled update of tho' plans and procedures.as per normal practice. 5. Mr. Gary's questions are : not relevant tol the - 2.206 Petition. Even more pertinent to the proceedings 'is~ the fact that they. are irrelevant - to the ~ current plans' for. the evacuation of the _ TMI ' pluma. exposure. pathway emergency p12nning ; sone. As. stated earlier (see para le' above), the. coausonwealth1does not need to. include the PAMU40 'in the way sought by Mr. Gary since it lis not' gernane.- The questions in paragraph 5, Lanswered above, are. in - s the sops of ' PAARNG for all' emergencies or do not ' apply. 6a.. There is no red tape f actor.that prevents the inclusion of. PAARNG in PEMh's plan for evacuation in. the event ' of. a 1 radiological emergency. As explained in paragraph lo. above, the use of ' Army trucks -for evacuating civilians ~is a poor ' option, even 'if b

~ * * { i 4 f s .o - POgO 6 i -J0 available, when we can obtain more thari enough' civilian buses to do the $cD. 6b. The FAARNG'is used to support counties on a contingency l basis for radiological and all meergencies (see paragraph Ic).. we will not I entertain inventing such dubious missions for the National Guard l $ust to keep military basse ~ open. ~ Mr. < Gary makes suspect, his. ) of ten claimed military expertise if ~ he thinks using Army ' trucks 1 for the unlikely evacuation of. the TMI EP8 would influence any congresstonal action to = save ; military bases - in Pennsylvania.- There is ample rationale relating. to military operations' to 1 preserve' our. installations if. Congrees ' is so; inclined.. I would' l note here that ' it. is frustrating to receive : such. blatantly' ill (! conceived schemes for=a formal response when this.is not part of-i the same Realignment and Closure Committee criteria nor would it 'l affect the Frasident's decisions to be forwarded to Congress. i s 7a At the October'2,.1992, meeting in senator shumaker's office (see Eb. paragraph ac), t_he level of supervision by PENA of the counties was discussed thoroughly. Similarly, our actions. to. Provide supplies and equipment to the counties during emergencies were - explained to Mr. cary. Further, specific information -about. emergency supply warehousee. in ~ response to. a question ! posed ; earlier by Mr. Gary was provided to him in - a July ~ 15, 1992, letter from the PENA Chief Counesi (see enclosure). 'As anyone 3 with intergovernmental relations experience knows, each level of

t government-(state from federal, county from state, etc.) likes to "do their own thing". 9 ' Counties. often do ' not. want',the limited j

c oversight provided by state. should this be the desire of WRC and FEMA,~ PENA will comply and provide more oversight.

l 7c.

At the same october 2, 1992, meeting, the cycle of plan' reviews and updates was. explained'to Mr. cary.' . e' explained that plans w are living documents, kept.2cose, leaf in three ring binders and ~ changed as the.need arises,- Further, we explained that a plan' is never considered " finished"; because as the planning elements and. environment change, the plan is amended to reflect-those changes. 7d. The reasons for not using military trucks for ' evacuation are. l described in detail above. 7e During the October 2,1992, meeting with.Mr. Gary, senator- -l &f. shumaker and Crman.* Loner = sheaffer I explained to ' Mr. ~ Oary _ .l e

that, in cur current - situation, there-was-insufficient justification from the counties to ask the utility rate payers to assume the additional'15,000,000 Mr. Gary - advocated ~ in; levied.:

costs through Act 147 to. support - county - radiological emergency ~i response activities.- senator shumakar forcefully stated that he could not and would not place such a burden on the. rste payers when Pennsylvania was in the throes" of a serious economia recession. commissioner sheaffer agreed. The utilities have: ~ stated they are ' reluctant to. provide more stockholder - or. rate I --LL.- n

.~. .y Pcgt.: 7 J -payer funds: to. PEMA. PEMA has requested, both through state J government channels and frcus the utilities, -more funds to meet. the increasing costs of the radiological emergency prepareaness program. 'I 79 - The answer to this question was provided to Mr. Gary ' in the PENA ' l chief counsel's letter of July 15, 1992, as follows: "Tederal studies indicate significant radiation exposures from, a n nuclear power station will be limited to within 10 miles of the facility. Tor this reason, detailed plans are in place to manage ~ l the needed protective action against exposure in that area. - In the event people need.to be protected-in areas beyond 10 miles, these actions will be extended as far. as they are - needed.i. The emergency respones organisation within 10 miles can be : extended as conditions warrant. Indeed, Pennsylvania maintains the - most ' l conservative evacuation policy for nuclear power - plants 1within the United States. While other " nuclear states" -evacuate'.in

sectors, the policy during both the. Thornburgh and' casey' administrations requires evacuating 360 degrees of the entire:

spproximate 10 mile EPE." j ~I This answer was elaborated upon in person with Mr. Gary ' during - the October 2, 1992, r.eeting. It is discouraging to note that. 1 the NRc, a major player with EPA in the development of... the 101 mile plume. exposure pathway emergency planning aone, referred this question to the consnonwealth of Pennsylvania for an answer. 7h. This questien was also abdressed in the october 2, 1992, meeting.' It was explained to Mr. Gary that - nuclear power' plant biennial' l exercises were scheduled in the. late ' afternoon hours to accommodate the hundreds of volunteers who --'staf f 7 many of the - countyLand municipal Eoc' staff and emergency re_sponse positions. ' These volunteers are willing to. respond to a true emergency at - ] any--time, but ~ they.cannot; affordito -leave' their regular employment-during business. hours $uet for drills.. ' As. you know,: 2 Pennsylvania is -heavily dependent upon volunteers to make the - omergency management; system work due to funding. limitations. Mr. Cary _ made it clearly known at this meeting that: he. wanted. to - [ impose the same standards for responseL as.those maintained by: j active - military units. such standards are not. feasible for a-civilian system that relies to' any 1significant-l degree-on' volunteers. j

e Ba.

Mayor Reed's comments on-radiological emergency response planning-l are always considered, paragraph ic above. explains state. and, 1 federal policy and plans. ab. see paragraph ac above. Sc.- some spontaneous evacuations during nuclear power plant disasters ~ 'must be assumed. However, unless TEMA and the NRC are willing.to state publicly for the record that the-10-mile'EPE is inadequate -] . i

~

4 ' '.

9 - , 4.~ -

![T,.

= > pega a ' i. 1 and that exceptions must be made'for Harrisburg and'other similar- ) EPIs near large population centers, the - PENh will-continue. to -l follow NRC and FEMA guidance regarding such planning.:.Natrisburg-believes, as conusented. - that they could handle their' population 1 if there was a. widespread evsoustion..(The state concurs.; y E 'j Sd. The February 7, 1993, ' security-incident. at'-TMI 'has been l investigated by, the NRC and conferenceal were held in Narrisburg:- d to describe the results of that ; investigation. PEMk formally. l reviewed the response by the; state and the involved' counties,and' l municipalities. It is expected that our review will be released 1 by the Covernor's office sometime.in' July.. copies will be made available to all appropriate government agencies upon request. -j i PEMA is ' also concerned about the: February 7. security breach' at ) TMI. We await eith -interest the results of the NRC consultations on design basis threat for nuclear power plants. j I 9. Regarding the point of disagreement betwean Mr. Gary and Mayor. Reed.' We agree with Mayor Reed. Full-scale. bus drills are too costly, significantly rudimentary.and unnecessary, our positions on Mr. Gary's other points are described;in detail above.- The plans to support the response to an emergency at TMI have been and-are being reviewed on a periodic basis and are-evaluated biennially. FEMA is I well aware, and 'has so affirmed in every biennial exercise, that. these plans - i provide reasonable assurance for the protection ' of ; the public ~. health - and safety. There will always be. changes, corrections, revisions and improvements - A in this ongoing process, but the plans are essentially valid., Mr. Gary's petition was filed in' July 1992. There is in the answers to his questions and the responses to his allegations nothing that can legally. ~ or' reasonaoly discredit the validity of the reasonable assurance. that. is - and-n has been provided over the many years in,the. planning and exercise' validation ' process. TEMA can affirm this to the NRC and, in turn, to Mr. Gary.- si rely,. }. yJose}pnL..Laleur Director-I JLLsJCJaj$k j Inclosure I cc commissioner Russell L. Sheaffer Dauphin; County Michael E. Wertz, coordinator Dauphin County EMA j George Giangi, GPUN j j l ^t

~ ll w.' PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY BOX 3321 i HARRISBURG, PENN8YLVANIA 17105 3321 I L ~ .} / July 15, 1992 Mr. Robert cary P. O. Box 1637 1 Harrisburg, Pennsylvania 17105-1637 j

i

Dear Mr. cary:

This letter responds to the questions / concerns that you raised about radiological emergency response planning in your letters of June 12,17, and 29,. 1992. The answe'rs to those questions / concerns are as follows: j 1. Questions why is all of cor.ter city Es,rrisburg not included in the-Emergency Evacuation zone?

Response

The Ir.orgency Evacuation Ione referred to is technically f , described es tht. Plura Exposure Pathway Emergency planning Sons (EPE). 'j ' Tederal studies indicate significant radiation exposures from a nuclear power station will be limited to within 10 miles of the facility. For this reason, detailed plans are in place to manage the needed protective action against exposure in that area. In the event people need to be protected in { areas beyond 10 miles, these acti&ns will be extended as far as they are j needed. The emergency response organisation within 10 miles can be extended as conditions warrant. Indeed, pennsylvania maintains the most conservative evacuation policy fonl nuclear power plant accidents in the j United states. While other " nuclear utility states evacuate in sectors, 1 the policy during both the Thornburghs and casey administrations requires - evacuating 360 degrees of the entige approximate 10 mile EP3.- i I 2. Question: Why does PIMA not maintain'a file of letters of intent from resource providers 7 {

Response

I,etters of intent, mutual aid agreements, etc. are negotiated and maintained by the risk counties where the resources are to be used. Both the rederal Emergency Management Agency and PEMA have recently begun to place more emphasis on such documentation to further refine our plans.- This effort will continue, along with a, number of other plan refinements-q well into the next fiscal year. In this regard, it should be understood that planning for nuclear power plant off. site safety, lika any other form of emergency operations. Planning, never ends. Such plana are living documents, maintained in loose leaf binders, and are constantly being refined, added to, or changods: because, situations and conditions in the environment addressed by the Plans change. These changes range from simple name and telephone number revisions to new techniques and methods of parr'orming response and recovery i i

b,. .C r,? Rob:rt Scry ~ t( M D, _. E, "]uly:15,-1992-VI ~ Y,. . 9ste 3 ,1 i y ? e operations'that-have been glas.ned from studies and exercises..In a '] practical-sense, one'can say that no plan for anticipated operations is ever complete.~ Further, planning is time consuming, labor intensive work that requires the cooperative participation of. federal, state,' county.and sounicipal levels of government. We'in PE R work very hard to maintaia continuous and effective casumanications with the plamainq jurisdictions in l the casunonwealth. This does not mean that at: any given time some elements i of.a plan will not need to be updated. j 3. Questions why have the two regional warehouses cited.in Title 35.have'not been establishedt Response: The short answer is that funds have not been allocated by the legislature for this: purpose, even though the, requirement is in the. law. -{ This is not unusual' particularly for capital esponditures.1 Large projects i inserted into law often fall victim to the prioritiaation of finito-i resources. The more thoughtful response is that.such expensive facilities are ill advised, since Pzu has stook piles of various emergency supplies d at other departmental facilities such as Torrance State 50 spital, Fike ~ center, and other locations. 4. enest.e 9n s why not use trains and aircraf t to evacuate?

Response

First, as explained above, the evacuation of Barrisburg is not. l necessary. ' secondly, the fastest methods ef^eveountion in the time available are private automobiles and busses. Evacuation of sissable populations by train and aircraft

• is 'a far more complicated and tino c;

consuming operation to plan and' execute than using automobiles and busses, to say nothing of the prohibitive-costs involved. ' C-141: aircraft are operated only by the Air Force. They are set,. as your letter suggests, j also found~ in the Army, Navy. and katine Corps. ~ Thees planes, of lialted number, are deployed world-wide enta jaily basis,1 To sarsha1' sufficient aircraft to effect an evaeustion would take days, net' hours,;and only after 'the Deslaration of Emergency by ths' 7 resident. ' The possibility of the - l Department of Defense participatir.h.eusk an evacuation'aission isihighlyE i unlikely. Even then, the use of Capitai city Airport'wesad be'impossibles i because, that Airport, like Harrisburg Katernattomal, is within tho' Plume -j Rwposure Fathway EP3.of TNI..Even if sufficient beddown space at Capital! City were available, and it-is'not,lfa:ilities for operating C-141s from { this airiistd.(including length of. runways)_are inadequate. ~Your 'i suggestion that C-141s could stage out of the Norshey airport (identified as Reigle airpor1: on air navigation charts) won't work.. The field'is woefully inadequate in all. categories including its short runway of ~ 1900 feet.. C-141s require runways well in'essess of'5000 feet for safe-operations. suffice to say that mass population evacuations by aircraft and trains would far exceed the evacuation time estimates we now have for 'l automobiles and busses.

5.. Question: Why are census figures in the Plane not updated every yeart

= -~.- = . =..

.. ~ -f.'j ,,,Mr. Robert Cary~ ,7f: ',, July;15, 1992

• -*
• u

_p:q2.y c: W 4 .C

Response

In the past, we have used regional'populatten estimates isr-updating planning figures. The 1990 census showed these estimates to be very _ inaccurate and actually painted a fmise picture -. usually predicting - steady growth when in' fact the populations held constaat er declined. Here Japortantly, they did not realistically capture the de1nographic shifts within the Cameonwealth. yhe 1990 census figures are in hand and are being factored into all of our planning. 6. Questions ' How are the ises collected under sections 7320(c). And (d)- of the. Emergency Management Services code-(35 Pe. c.8. $7101 et,seg.) expendast Responses All of the fees collected under those two eeotions are used by. PEMA to carry out the many radiological emergency response preparedness'and planning functions _and duties.that are placed.upon the Agency by Sootion 7320(b) of the code. This includes the payment of salaries; and benefits - for those PENA employees who are directly involv4 in carrying out these. radiological emergency response and planning acMulties. Thank you for your. expressed interest in the above diemussed radiological emergency response planning issues.

ac Sincerely, b-Mark L. Goodwin

, chief Counsel .<ts i d j s (Tal: 717-783-8150) cc: Joseph L. Larleur 7, 9 e e 5 i e '%.}}