ML20080A641

Offsite Emergency Planning Contentions Based on Currently Available Draft Radiological Emergency Response Plan. Certificate of Svc Encl

ML20080A641
Person / Time
Site:	Limerick
Issue date:	01/31/1984
From:	LIMERICK ECOLOGY ACTION, INC.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20080A636	List: ML20080A633 ML20080A641
References
NUDOCS 8402060176
Download: ML20080A641 (64)

Text

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1.

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of  :

Docket Nos. 50-352 PHILADELPHIA ELECTRIC COMPANY  : 50-353 (Limerick Generating Station,  :

Units 1 and 2)  :

VIII. OFF-SITE EMERGENCY __ PLANNING CONTENT. IONS Scope of Contentions Following are "off-site" emergency planning contentions, based on the most currently avai.lable draft Radiological Emer-gency Response Plan's (RERP's), as submitted to Region III, of the Federal Emergency Management Agency (FEMA) for informal re-view by their Regional Assistance Committee.

Intervenors Concur with comments contained in PEMA's trans-mittal letter dated Dec. 6, 1983, as restated below:

" The draft plans have been reviewed by the Pennsylvania Emergency

, Management Agency (PEMA) and we have provided comments to the counties to facilitate reconmended changes and additions. It should be realized, however, that these are draft plans and, due to the desire to meet the proposed sub-mission date as closely as possible, 'some of the problem areas may hot have been resolved. It is also recognized that in a ntuber of instances additional information must be developed by the counties, municipalities and school districts for inclusion in their plans. Discrepancies or omissions of this-nature must obviously be rectified before the plans are finalized for sub-:

mission to FEMA for fonnal review and approval. This will not occur until after the joint exercise and public meeting required under 44 C.F.R. Part 350,,'

Sections 350.9 and 350.10, 48 Fed. Reg. 44332, 44338-40 (September 28, 1983).

8402060176 840131 PDR ADOCK 050003S2 G PDR a

- - - _ . _ __--_2--_--_n -

O

2 Issues raised in these contentions are consistent with 10 CFR

50.47(d) as explained in the Commission's Statement of Consider-ation, 47. Fed. Reg. 30232 (July 13, 1982), which in turn refers to the pertinent standards of 10 CFR 50.47 (b) and Part 50, Appen-dix E., as well as the specific criteris in NUREG 0654; FEMA-REP-1, Rev. 1.

Abbrevist. ions

1. NUREG-0654/ FEMA-REP-1, Rev. 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Pre-paredness in Support of Nuclear Power Plants" (hereinafter "NUREG-0654")

2. 10 CFR Part 50, Appendix E (hereinafter "Part 50, Appendix E")

3. Draft County Radiological Emergency Response Plans (herinafter

" Draft County RERP's") ,

4. Draft Municipal Radiological Emergency Response Plans, as i developed by the Applicant's Consultants (herein.f ter " Draft Muni-cipal RERP's")

5. Commonwealth of Pennsylvania Disaster Operations Plan, Annex E (hereinafter-" State Plans")

6. Plume' Exposure Emergency Planning Zone (hereinafter "EPZ")

7. Ingestion Exposure Pathway Emergency Planning Zone (here .

inafter " Ingestion EPZ")

8. County Office of Emergency Preparedness (hereinafter'"0EP")

9. Emergency Operations Center (hereinafter "EOC")

10. Unmet needs to be developed (hereinafter "TBD")

11. Energy Consultants Inc., emergency planning consultant to Philadelphia Electric Company (hereinafter "ECI" or " Applicant's Consultant").

~

PLEASE NOTE: The numerical system used for the following contentions does not retain the original numerical order as those filed previous-ly, other than to retain the prefix "VIII."

l 3.

(LEA-1)

The county, municipal, school, and institutional plans as developed by Philadelphia Electric's consultants (ECI) do not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, [as required 50.47 (a)(1)] because: A) primary responsibilities for emergency response have not been assigned. 10 CFR 50.47 (b) (1) . B) Emergency responsibilities of the various supporting organizations have not been specifically established. 10 CFR 50.47 (b) (1).

BASIS 10 CFR 50.47 (b) (1)

The Plans do not meet the Evaluation Criteria of NUREG 0654 at II., Section A. Assignment of Responsibility (Organization Control), p. 31-33. Risk Counties and their Municipalities and

_ School Dsitricts within the Plume Exposure T.PZ have not promul ated F or adopted final emergency plans, nor have they approved and adopted 1

the plans drawn up by the Applicant's consultants. Therefor _e the

. specific criteria of NUREG 0654 II A.3 are not met, and there is

~

.n o assurance that the other crit.eria of NUREG 0654 II A. are met unless and until all Tiisk County, Municipal, and School Plans and those required for special fecilities have been adopted by those entities.

(3ES"fER g FD(TCGERY CDLt.Tr School Districts Chester Cotssty Plan (6)* & ntgumery Cowity Plan ( p'

• Nathactan (3)

Perkinuun Valley (3) u Maticipalities Msticipalities Portsgrove (3) in Pottstows (4) om Collegeville Borough (4) Souderten Area (3) a n. Charlestown Township (4)

Spring-Ford East Coventry Township (4) Douglass Towtship (4) (3)

,E East Nantseal Township (4) Green Lane Borough (4) Upper Perkiomen (3) yg Limerick Township e East Pikeland Township (4) (4) ou East Vincent Townshi lower Frederick Township (4) tower Pottsstuve Towtship (4) BERES COLNTY

• W North Coventry Townskp(4) (4)

'O 8 Phoenixville Borough (4) lower Pmvidence Towtship (4) *

(3)*

j.g b Schuvik121 Towtship South Coventry Township (4)

(4) lower Salford Township Marlborough Township (4)

(4)

Berks County Plan Maticipalities Spring City Borough New Hanover Township (4) in u (4) Perkiomen Township (4) kc Upper Uwchlan Towtship (4) Pottstown Borough (4) Amity Towtship (4)

1. # Warwick Township (4) Boyertown Borough (4)

Royersford Borough (4) j [ West Pikeland Township (4) Celebrookdale Townshi[, (4)

West Vincent Township (4) Schwenksville Borough (4) ea Skippack Township (4) Douglass Town hip (4) 2: o Trappe Borough (4) Earl Township (4)

• School Districts Upper Frederick Township (4) Union Township {4)

• Upper Pottsgrove Township (4) Washington Towtship(4)

Downingtown Area (4) upper Providence Township (4)

Creat Valley (4) School Districts Upper Salford Township (4)

Owen J. Roberts (7) West Pottsgrove Borough (4)

Phoenixville Ares (4)

Daniel Boone Area (3:

1'The only known exception is Perkiomen Valley School District.

4

" Assignment of responsibility" must mean a definite naming of of individuals, organizations, municipalities, counties, etc.

who will respond as the proposed plans intend and fulfill the responsibilities named therein. .In case after case we find no such assignment. Likewise, specific responsibilitics of the supporting organizations are not described and clearly agreed to in letters or agreement or contracts.

(LEA-2)

The unadopted RERP's fail to provide assurance that each principal response organization has sufficient staff to respond and to augment its initial response on a continuous basis. A listing of unmet needs for each Municipal RERP broken down by County is provided as Table #1, to indica'te the number of unmet needs yet to be determined.

BASIS 10CFR 50.47- (b)(1); NUREG 0654 Criteria A.4, Criteria C.4 1

The county and municipal draft RERP's are inadequate to protect the public in that individuals named in A-1-1 (Also App. c-5 or App. 6, municipal coordinators) of ChesCo, MontCo and Berks Co plans (as well as support county plans) have not accepted any assigned responsibility or been trained (in all cases)to fulfill duties associated with radiological emergencies, or are available on a reliable 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis (or have an adequate back up if not),

or can respond in a prompt manner in case of emergencies connected with Limerick.

F-g Y V 3. '

lg- Q Q {

t w

t t 7 % x,o t* 2 '- 1

{g Unmat needs* g e4 .=g > 1f o 2*34, a.,

• a S Cl %

e g 8 * - - > f Cga 3 Montgomery County 5y

>d dX 1 0 Fh& M o d Ql {g $ *g b 4c j d 4 b

b kid bAE {

Municipalities 8

,- {gggL f % . gDj

o. dghggh3 p.,

-0 EIlS I d * $ $b 3 b I.

do ca3333 E z d$Km m F- s s -$ 3 A. VEHICLES

1. Busesl 24 l 6 1 7 15 1 2 1 l 1M l'7 1 3l 3 2. 5 2 Il

2. Ambulances 1 0 0 I o1 20 I i I 4OO OO I i171

3. Vehicles with Loudspeakers

4. Towins 0 0 .

5 Other

. B. PERSONNEL

1. Rout'e Alerting

2. Transportation 00 0 00 0 0 0 0 0 0000

3. TCP OO 4 Special Assistance 2

5. Ambulance 20 0 I I 2

6. Communications 2. , Y Y' ' #$,"

7. Other C. EQUIPMENT Phones 3

1. Communications:

(by type) RACE 5 l 2 1 1 1 I l l l 1

2. Traffic control .

3. Life Support

4. Other 1

I Resourca' planning for buses should exclude those required for evacuation of schools.

2 Based upon an estimate of 40 persons / bus.

Note: Blank spaces on this chart will be completed as data becomes available.

• Source: [ttachment0, Consolidated Resource List, Municipal RERP'S TABLE #1-1

~

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i Chaster County 3 C Ie f, bo [ f 5h3 Municipalities 1 'g ,g M jgjyj 1$si i

l8 4- f 3M 3 E f .m !

3 2ES fc "t

.5 +a Et -65 ow5mzina i

m. 2 tItt*2,13)w

&S *u A. VEHICLES

1. Busesl 1417 8 57 5 2 ll 11111

2. Ambuiences 1 101 2 1 1 0 0001 3 Vehicles with Loudspeakers .

4 Towins 0 0 0 0 0 0 0 ,

5 other B. _PER$0f91EL

1. Rout's Alerting

2. Transportation 0000 0 00 0 000 0 3 M 1 o ^Y 2 0 4 0 0 0 0 4 Special Assistance 5 Ambulance -

0201 4 32 0 000 2

6. Cannunications 2 0 2 1 211 '

i _

7. other (ARES) 2 22 1 2 2 I I 2.

C. EQUIPPEffT Phones 2. 2 1 9 1 1 Comununications (byggES I I I I I I I I I i 1 I

{

2. Traffic Control 0 3 Life Support-

• • Nn#tercom. l ,

1 Resource planning for buses should exclude those required for evacuation of schools.

2 Based upon an estimate of 40 persons / bus.

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Iloto: Blank spaces on this chart will be completed as data becomes available.

• Source: Attachment 0, Consolidated Resource List, Municipal RERP'S TABLE #1-2 -

e 9

e

___________________----y y ,

s.

Unmat nosds# C 7 C Berks County 3 *o

• u S a o Municipalities y+ Ed c NbiO_

s ;-

$3 a 2 e

<c aa d o! ms2 A. VEHICLES

1. Busesl I !i 3  ! I 1!

2. Ambulances 1 0 1 1 000  ;

3. Vehicles with 6

Loudspeakers 0

4. Towing 0 0 0 0 1 0 ,

5. Other 0

8. PERSONNEL

1. Routs Alerting 0 -

2. Transportation 0000 0 0

3. TCP O 0 32.I

4. Special Assistance

5. Ambulance 2. O 2. 20 00

6. 22 2 2. 2.2.

Communic @ )

7. Other C. EQUIPIENT Phones 2. I

1. Communications (by type) RACE,3I I I I I

2. Traffic Control

3. Life Support

4. Other I R: source planning for buses should exclude those required for evacuation of schools.

2 8ased upon an estimate of 40 persons / bus.

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Note: Blank spaces on this chart will be completed as data becomes available.

OSource: Attachment 0, Consolidated Resource List, Mdnicipal RERP'S TABLE #1-3

e. . .e

8.

(LEA-3)

The Montgomery County RFRP fails to provide reasonable assurance that 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 assume the responsibilities assigned to it in the Support Plan, rather than use County resources to help Bucks County people first.

The Montgomery County Plan relies on the Support Plan in at least these ways:

1. facilities for relocation and mass care of evacuees

2. augmentation of emergency workers, including use of county resources, on a continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis

3. See atta'chment " Excerpts and comments on the Bucks County Draft Evacuation Plan" for additional areas of support and interface. (Exhibit #1)

It is contended that without the approval of Bucks County Support Plan, the MontCo RERP is unworkable as it now stands.

BASIS:

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

Criteria A.4 (LEA-4) i The Berks and Montgomery County RERP's are deficient in providing adequate protection to the public if or when the Lehigh County Support Plan is not approved by the Commissioners. The Support functions designated in the plan are important in providing resonable assurance that protective action is taken including evacuation and augmentation of emergency workers. Approval is needed in order for much of the Berks and MontCo RERP's to work as designed.

i BASIS l

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

EXERPTS (AND COMENTS) ON THE BUCKS COUMTV DRAFT EVACUATTOM PLAN FOR LIMERICK The Bucks County Draft (#4) Support Plan developed by (PECO)

Energy Consultants (with some degree of input from the Bucks County Emergency Management Agency) states that:

(pago 1) 1) This Support Plan establishes policies and procedures under which the county will operate in the event of an " incident" at Limerick.

2) ... defines the roles and responsibilities of the Bucks Count Office of Emergency Management in the event of an " incident"y at Limerick.

3) ... assures appropriate responses to protect the affected evacuated population from Montgomery County, including mobilization of County forces to support necessary actions.

(pago 7) The overall purpose of this Fixed Nuclear Facility Support Plan is to provide for the housing feeding, medical and other social

~ service needs for a maximum of 24,440 persons evacuated from Montgomery County in response to an incident at the Limerick Generating Station.

(pogo 12) (Under the heading of Bucks County Emergency Management Staff item #13 it states:)

Trained personnel from all available resources will be utilized by the Bucks County Emergency Operations staff to the fullest extent.

Trained auxiliaries and volunteer organizations will be used to augment normal government service personnel. WHAT DOES THIS MEAN7 Agreements with the Lower Bucks Red Cross and the Doylestown Branch Red Cross are under development-(App. 1, attachments A & B)

(pago 13) Traffic control points will be established to insure an orderly flow of traffic during an evacuation. Municipal pelice forces are responsible for traffic control within their own municipality....

The Pa. National Guard will provide wreckers and gasoline trucks to service vehicles along major evacuation routes. Municipalities are required to provide these services within their municipality.

See Appendix 3 for Bucks County Traffic Control Points (TCP's) and police department resources. _

'(p'ago 13) As evacuees arrive in Bucks County, the initial reception will be provided at the following locations: (also see Att. G)

Evacuation Route Reception Center

a. Route 113 County Line Plaza, Souderton

b. Route 202 Montgomery Mall (Montg. Co.)

c. Turnpike, Neshaminy Mall, Langhorne (App. 1) Letters of Agreement from Clemens Market (County L'ine Plaza) and Neshaminv Mall desi use of PORTIONS OF THE7R PARKING LOTS FOR

" RECEPTION CENTERS"gnate (Attachments C & D)

(Exhibit #1) b '- - -

FRHWART PARKING LOTS [ WHO WILL NEED HASS CARE: (MASS CARE CENTERS)

Penn' Ridge Uoper, Junior and County Lino Plaza 4697 Central Jr. High Schools Montgomery Mall 5495 Central Bucks West HS. Central Bucks East Sr. HS, Lenape Jr HS (manned by Montg. Co.)

Neshaminy Mall 14,249 Neshaminy Langhorne HS, Neshaminy Middle Jr. HS, Poquessing Jr.HS (page 13) At the reception centers, the evacuees will be provided with in-structions, directions, and a strip map that will direct them to (pago 14) an assigned mass care center. Transportation of evacuees, if necessary, from the reception center to the designated mass care center will be provided in the form of buses and vans. The Bucks County Emergency Management Agency will coordinate the support of transportation requirements with appropriate risk counties. Trans-portatio'n staging areas wi1J be established in Montgomery County at

1) the North Penn School District Bus Garage in Lansdale, 2) Fort Washington Industrial Park, and 3) King of Prussia Plaza, to pro-vide bus and ambulance support to Montgomery County. (Formal agree-ments are under development). These facilities will be operated by Montgomery County. (See Annex K, Bucks County Disaster Operations Plan and' Bucks County SOP, " Emergency Mobilization of Transportation Resources.")

WHO IS SUPPOSED TO STAFF THE MASS CARE CENTERS??? WHERE ARE EQUIPMENT AND SUPPLIES SUPPOSED TO CCHE FROM177 (C0TS, BLANKETS, FOOD, REPLACE-MENT CLOTHING FOR CONTAMINATED INDIVIDUALS, MEDICAL SUPPLIES, ETC.)

(App. 4) The Red Cross will pay the operational costs of a mass case center (s)

E-6 as an outright grant, when the center is operated by Red Cross Managers. TS THIS PAID FOR BY PEC07tt, IF NOT, WHERE DOES THE RED CROSS GET THIS MONEY 7 In situations not within Red cross purview, expenses for operations will be borne by municipal or county govern-ments. WILL PECO RETMBURSE THESE EXPENSEST (pago 15) Medical support service information is contained in Appendix 6 of this plan. It is planned to. relocate some residents of the Frederick Mennonite Nursing Home in Montgomery County to Rockhill Mennonite Community Home in Bucks County, and some of the residents of the Montco Geriatric Center to Neshaminy Manor.

A listing of Bucks County ambulance services is provided in Appen-dix 6. Attachment B. These services will be notified at the time of an incident to determine the number of units available to support Montgomery County in a radiological emergency. WHAT KIND OF AGREEMENTS AND TRAINING ARE NECESSARV!: 6-A-1 lists Bucks County hospitals that can sunnort evacuation and treatment of contaminated / irradiated indistanals. LOWER DUCKS HOSPTTAL WTLL BE THE PRTMARY ONE USED.

NO INFORMATION IS GIVEN TO DETERMINE NUMBER OF RADIATION VICTIMS ANY OF THE FACILITIES LISTED COULD TREAT AT ONE TIME.

In the event of an" emergency at Limerick,'the Bucks County Emergency Management Agency has been instructed to release the following message to radio ar.1 television media:

"THIS EVACUATION DOES NOT AFFECT THE RESIDENTS OF BUCKS COUNTY.....

' BUCKS COUNTY RESIDENTS ARE REQUESTED TO AVO1D THE FOLLOWING ROUTES AND INTERSECTIONS: ROUTE 202, ROUTE 1 13 IN SOUDERTON, AND ROUTE US 1 NORTH AT EXIT 28 0F THE TURNPIKE"

11.

(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-able assurance that the emergency plans can be implemented.

The mere 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 wtrkers, bus drivers, teachers, school officials, auxillary traffic controllers, commu-nications workers, and all other essentia emergency workers, which indicate not only generalized good intentions, but specific agree-ments to perform emergency work under the conditions of a radio-logical emergency.

BASIS (Risk) 10 CFR 50.47(b)(1), ggggg gggg, {p{geria g.j, County RERP's Annex T, Municipal RERP's, Attachment C.

(LEA-6)

The Berks, Montgomery, and Chester County RERP's are inadequate in that sufficient letters of agreement are not developed to support the protective response required.

Annex T. of the Risk County RERP's contains a listing of supporting organizations expected to provide letters of agreement.

In the Chester and Montgomery County Plans, the majority are marked (TBD). A footnote states that agreements for towing and fuel rasources within the EPZ are contained in the Municipal REPP's.

Attachment C in the Apolicant's Municipal RERP's states that these and other agreements have not yet been developed. The Municipal Emergency Management Coordinator has been assigned the responsibility

12.

I of developing these letters of agreement. Valid agreements are essential for compliance with NUP.EG 0654, Criteria A. The Mont-gomery County Plan states that a letter of agreement is under developm.ent with the Southeastern Pa.' Red Cross.

BASIS:

NUREG 0654, Criteria C.4; 10 CFR 50.47 (b) (1) , NUREG 0654, Criteria A.3 (LEA-7)

The Chester and Berks County RERP's do not reasonably assure adequate protective response in that letters of agreement which ,

do exist are not sufficient.

The Berks and Chester County RERP's include a general " Statement of Understanding" with the Southeastern Pa. Red Cross which fails to mention any problems caused by a radiological emergency caused by Limerick or any other commercial nuclear power plant.

(App. 1, Annex T.) Radiological emergencies differ from other emergencies in at least three key respects:

1. " Human response" to radiation danger is different, Volunteers willing to risk other injuries will not necessarily risk radiation exposure.

2. The area affected is larger and may involve the volunteer's own family (even if our of the formal 10 mile EPZ). That is, families well beyond 10 miles may want to evacuate, putting volunteers between caring for their families and their assigned duties.

3. Radiation injuries are not insured by regular policies. This makes volunteers much less willing to risk injury. ((Also effects of Price-Anderson))

13.

This reasoning also applies to all agreements and understandings I

in Annex T of all county plane whether actual or TBD unless such 1

ogreements resolve at least these three issues and particularly l refer to a radiological incident at Limerick. More general letters do not reasonably assure the predicted response. Thus responsibilities of this nature have not been assigned or specifically established.

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

(LEA-8)

The State, County, Municipal, Institutional, and School District RERP's do not reasonably assure adequate protection to the public in that the plans are based on unproven assumptions of the response of essential volunteer emergency workers, and thus the plans are def.icient in that they are not capable of being implemented in sufficient time to prote.ct the public health and safety during a radiological emergency. The RERP's are based on unproven assump-tions of the response of many hundreds of voluneer emergency workers including teachers and school officials, bus d-ivers, regular and additional medical support personnel, Red Cross Volunteers, traffic control personnel, telephone and radio oper-x otors, and emergency vehicle operators. Although many of these workers may normally have tasks similar to those tasks assigned to them in the Applicant's Plans, there is no assurance that they will choose to be available during a radiological emergency, at least while they are uncertain of the safety and whereabouts of their own families. Additionally, some essential professional and technical personnel may be unavailable during an emergency as happened during the evacuation after the March 28, 1979 accident at Three Mile Island.

l r ___. . , . _ . ,

14.

Human response to hazards which involve the threat of contamination or. radiation has been shown repeatedly to be qualitatively different from hazards in which the extent of the danger is more immediately determined by human senses. Radiation dangers are invisible and cannot be perceived by the human senses, nor can safety from radiation danger be perceived, unlike safety from fire, flood or most natural hazards. These factors are extremely important in determining human response to radiation emergencies and have not been sufficiently considered in the development of cne Draft -

Plans. (See, Testimony of Kai T. Erickson, ff TR 21,686; In the Matter of Metropolitan Edison Edison Company, TMI-1 (Restart), Docket 50-289)

Recent local experience when alerting warnings were accidently set '

off on Jan.4th. confirms the lack of appropriate response by local authorities and the public with regard to the human response tendency to ignore warnings of danger until there is direct confirmation by the human senses. (See, Philadelphia Inquirer.1/6/84 False alert's lack of effect worries state", P.1, Harrisburg Evening News, False attack warning sent, p.1, 1/5/84)

References rela'ted to THI Testimony of Mr. Lamison, PEMA, TR 17,826; Three Mile Island Unit #1 (Restart), Docket 50-289: "I think if we look at the example of TMI, there were some professional, technical people, as well as volunteers who were not available. Some of them possibly have departed the area."

Testimony of Kai T. Erickson, ff TR 21,686: Three Mile Island Unit #1 (Restart), Docket 50-289: Tf)n the last analysis, I think they (emergency workers) would regard their real job as tending for their families."

BASIS:

10 CFR 50.47 (b) (1); NUREG 0654, Criteria C.4

l 15.

(LEA-9)

The state, county, municipal, institutional, and school dis-trict plans fail to provide assurance that sufficient resources and funding are available to implement the plans. Limited resour-ces and insufficient equipment availability will impair the abil-ity of emergency response organizations to implement plan objec-tives. The RERP's make no provisions for provision of financial assistance from the utility for training or resources needs.

BASIS:

NUREG 0654, Criteria I.G. (page 25), NUREG 0654, Criteria 0, 10 CFR 50.47 (b) (1)

(LEA-10)

State, County, Municipal, Institutional and School District RERP's provide no assurance that adequate protective measures can and will be taken in the ev,ent of a radiological emergency due to the fact that much of the plans components remain "To Be Developed" (TBD).

Examples are provided to indicate the number of critical TBD items:

Tables #1-1, #1-2, #1-3 Unmet needs for Risk County Municipalities (pages 5,6,7) (Note the number of items not identified)

Table #2 (page 16) Schuylkill Twp., RERP, Draft #4 Table #3 ( pages 17,18) Borough of Phcenixville, RERP, Draft #4 Table #4 (page 19) Pottstown Memorial Hospital, RERP, Draft #2 Table #5 (page 20) Montgomery County Geriatric and Rehabili-tation Center, RERP, Draft #2 Table # 6 foages 21-25) Montgomery County RERP, Draft #5 BASIS:

10 CFR 50.4 7 (a) (1) , (2) (b) (1) through (16);10 CFR, Part 50, Appen-dix E; NUREG 0654 Criteria II.

16.

ITEMS MARKED TBD (To Be Developed) Examples Sample Municipal Plan Developed By Applicant's Consultants Schuylkill Twp., Chester Co RERP Draft 4 PAGE JJJL Pg i Approval by Twp. Supervisors Pg B-1 Ambulance and Transportation Coordinator Pg C-1 better of Agreement for Towing Pg C-1 Letter of Agreement for Roadway Clearance Pg D-1 Assign Police to Traffic Control Points (TCP) --

(9)*

Pg.E-1 Assign Firemen to Route Alerts -- (16)**

Pg E-4 Route Alert Sector Maps --

(8)

Pg H-1 Floor Plan--Schuylkill Twp. EOC ,

Pg I-1 Name of Deputy Police Services Officer

" Name of Deputy Fire / Rescue Officer

" Name of Ambulance / Transportation Officer

" Name of Deputy Ambulance / Transportation Officer Pg 0-1 Unmet Needs Summary:

Buses -- 5 Ambulances -- 1 '

Personnel TCP/ACP -- 4 Personnel Ambulance -- 3 Personnel Communications -- 2 ARES ARES Equipment -- 1 NOTE:

• Township has S police officers and has 7 TCPs to be covered (9 TCP's when school is in session)

• • Township has 75 firemen, but is expected to assign 16 of them to route alerting TABLE # 2

v. .

ITEMS MARKED TBD (To Be Developed) Examples Sample Municipal Plan Developed By Applicant's Consultants Borough of Phoenixville, RERP Draft 4 PAGE TBD Pg 16 Towing: No company named for removal of disabled vehicles.

D-1, Pg Traffic Control Points: No locations listed. No 15 volunteers or police assigned or which police organi-zation is responsible, or how many cen assigned.

Pg 9 Alert Team (Route Alerting): No letters of agreement for Emergency Manager, Law Enforcement, Fire Services, Medical / Ambulance Services, Public Works, Radiological, Transportation or Communcation workers are contained in the Borough of Phoenixville plan to meet 10 CFR 50.47 (b) (1 ,

requiring adequate staffing or 10CFR 50.47(b)(10) requiring a range of protective actions as well as 10 CFR 50.47 (b) {6) referring to proper communications among emergency orga-nizations. No alternate personnel listed for any key positions.

S-1, Pg Pick-Up Points: No Letters of Agreement as required by 8

NUREG 0654 II ( A) (3) or names of owner / operators of diners' l parking lots, gas sta'tions, etc. to be used are enclosed.

Att. Q-1 No support map is enclosed in Attachment Q

! Att. H No floor plan.

Att. P-1 There are only two names mentiondd with the fire department.

No alert team leader or assistant to the leader are named for any of the 8 sectors.

Att. F-1 The six residents needing ambulance transportation have not been assigned ambulance support. These numbers are

, estimates only based on U.S. Dept. of Health and Human Services not actual need in the community.

Att. B-1 There are no deputies named for the following:

1) Police Services Officer

2) Public Works Officer

3) Radiological Officer Pg. 14 No central transport municipal staying area.

Pg. 18 Emergency workers in Phoenixville have.no place to report for decontamination screening. (10CFR 5 0. 4 7 (b) (13)

TABLE #3

. - - r g____ -

18.

ITEMS MARKED TBD (TO BE DEV5 LOPED) Examples Sample Municipal Plan Developed By Applicant's Consultants Borough of Phoenixville, RERP Draft 4 PAGE TBD (Contd)

Att. G-1 There are no buses for the approximate 2,269 residents determined by the 1980 census to be in need of trans-portation in the event of an accident.

Pg 11 ,

Only one telephone number at the county level for rumor control to comply with 10CFR 50.~47 (b) (8) and 10CFR 50.47 (b) (5 Att. M-1 Total units of dosimetry required have not been deter-mined to meet 10CFR 50.4 7 (b) (13) .

Att.0-1 Buses needed, "57" is only an estimate.

Att. E-1, There are 51 hearing impaired in Phoenixville Borough ,

E 13 depending on route alerting system that has not been developed.

Att. P-1 All equipment and manpower for police, fire and ambu-lance departments are TBD as well as where each of these departments within the EPZ can relocate to. (10CFR 50.47(b)(8)

TABLE #3

19.

ITEMS MARKED TBD (To Be Developed) Examples Pottstown Memorial Hospital. RERP Dra f t 2 PAGE JUEL Att. A Appoint Emergency Management Team.

Pg 22,23,24 Location of " Montgomery County Medical Group Coordinator" not given.

Pg 23 Departure areas for patient evacuation have not been designated (ambulance, bus / van, truck, helicopter).

Notification information for hospital Emergency Management Team and Department Supervisors TBD. .

Att. B-III-1 " Letters of Agreement" from three Reading hospitals B-I -2 fail to meet evaluation criterion of NUREG 0654 II (a) (3) . They are little more than indications of willingness and are directed to the Berks County Emergency Management Agency, not to Pottstown Hospital.

Att. D-1 No figures given for numbers of patients to be evacuated. ~

Att. D-2 No figures given for how many beds available at host hospitals in Reading.

Att. E " Procedures for Medical Emergencies Involving Radiation" TBD by Radiation Management Corporation.

TABLE #4 1

o u- -

l l

20.

ITEMS MARKED TBD (To Be Developed) Examples Montcomery County Geriatric and Rehabilitation Center, Roversford, RERP Draft 2 PAGE TBD Pg 17,18 Location of " Montgomery County Medical Coordinator" 19,20,22 is not given.

Att. A Geriatric Center " Emergency Management Team" has not been designated, nor a notification roster provided.

Att. B No " Letters of Agreement" are availabic from Neshaminy Manor or from Philadelphia State Hospital, two of the three " reception facilities" designated.

The third, Cedarbrook, offers minimum medical care for 75-100 patients for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> only, if accompanied by Geriatric Center staff.

Att. C-1 No information is given on the size of the patient population,nor the number and types of vehicles needed to transport them. No information is given on the number of beds available at designated reception facilities. Unmet needs are not listed.

TABLE #5 j

ITEMS MARKED'TBD (To Be Developed) Examples Sample Draft County Plan Montgomery County. RERP, Draft S PAGE TBD 6-2 Industrial Liason Officer: No Name lunteer Groups ~

Decontamination Teams (No Names)

Other support staff C-6-1-1 Route Alerting System Design / Zone Maps - NONE D-2-1 Sheltering of selective groups, such as pregnant women and pre-school children- Locations not verified-D-4-3 No confirmed locations (Host School) for busing children

• for nxample: St. Aloysius to  ?

Hill School to  ?

Ursinus College to  ?

• Agreements are not yet developed for those that are identified.

Note: Host schools will only remain open until 8:00 PM.

~

Mass c'are arrangements are marked TBD E-3-1 Relocation Points for Montgomery County Fire and Rescue Companies Outside EPZ- Personnel and Equipment marked TBD for :

1. Upper Perkiomen H.S.

2. Indian Valley Jr. H.S.

3. Methacton Sr./Jr. H.s.

4 Burnside Elementary School E-4-1 Fire and Rescue Company Equipment / Personnel Inventory to Personnel not indicated for:*

E-4-8 1. Bryn Mawr Fire Co.

2. Worcester Fire Co.

3. Enterprise of Hatboro Fire Co.

4 Hatfield Fire Co.

S. Red Hill Fire Co.

6. Upper Pottsgrove Fire Co. #1

• Active personnel numbers given are estimates only.

In many cases, total number of members and number number of active members available are inconsistent, FABLE #6

22.

ITEMS MARKED TBD (To Be Developed) Examples Sample Draft County Plan Montgomery County, RERP, Draft 5 PAGE TBD E-S-1 Emergency Worker Decontamination Stations:

No teams assigned for or alternates, no personnel, or confirmed locations:

1. Upper Perkiomen Senior H.S.

2. Indian Valley Jr. H.S.

3, . Methacton Senior /Jr. H.S.

4. Burnside Elementary School E-6-1 Route Alerting Assigned Equipment and their Routes NONE F-3-1 Relocation Points / Emergency Worker Decontamination Stations for Po' lice Depts. Within EPZ- Personnel 6 Equipment ,

listed TBD

1. Upper Perkiomen Sen. H.S.

2. Indian Valley Jr. H.S.

3. Methaeton Sr./Jr. H.S.

• 4 Burnside Elementary School

(

• Agreements with schools not developed F-4-1 Access Control Points (Location and municipality listed but most don't state whose job it is to " man" post or how many are needed. See K-4-1)

F-5-1 Montgomery County Traffic Control Points: Feeder and Main Evacuation Routes. Appendix K-2 provides s an interim list, but most personnel needs are marked TBD.

G-3-1 Evacuation Support Facilities-Although lists are provided, no detailed information or Letters of Agreement are available.

G-4-1 Local Hospitals Outside Plume Exposure EPZ- Although number of beds is listed, no specific information is available.

G-S-1 Municipal List of Homebound Persons Requiring Ambulance Transportation- TBD, after Municipal surveys are completed.

G-7-1 Relocation Points-Ambulances within EPZ-Personnel and Equipment needs to be developed. Agreements with school Administrators not developed.

TABLE #6

23.

YTEMS MARKED TBD (To Be Developed) Examples Sample Draft County Plan Montgomery County, RERP, Draft 5 PAGE TBD G-9-1 Emergency Worker Decontamination Stations-Locations are listed although agreements have not been developed with school Adminis-trators. In addition, personnel and equip-ment needs are marked TBD.

G-10-1 Listing of Medical Facilities Outside the Plume Exposure EPZ with Radiation Exposure / Con-t a. in a'.i on Treatment Capability. No information or Letters cf Agreement stating number of patients that can be treated is available. ,

G-11-2 Census and Transportation Requirements for Health thru Care Facilities is not available.

G-11-7 I-2-1 Transportation Resources (Ambulance Services)

-Table lists total ambulance resources but fails to indicate actual numbers available for evacuation.

I-2-3 Transportation Resources'(Bus Companies)

No information is available to provide the total number of buses or the number actually I

available in the event of an evacuation.

I-4-1 Transportation Staging Areas / Resource Assignments-TBD I-4-2 Transportation Resource / Address / Contact- TBD l- I-6-1 Nap of Staging Areas and Fuel Location- TBD

- Note: Resources to support municipal needs marked TBD ( Appendix K- 3-1)

J-2-1 School District Evacuation Routes and Host Schools Agreements under development /pending approval. No information available for Ursinus College.

Route planning needed for St. Peters, St.Aloysius, Salford Hills Elem, New Life Youth and Family Services, Ursinus College.

TABLE #6 s.

, ,- ,- -.---..,.--.---,c-w,n ,--_n- , , - , - - , , -- ,- . , . - , - - -. r,, . - - - , --

24.

ITEMS MARKED TBD (To Be Developed) Examples Sample Draft County Plan Montgomery County, RERP, Draft 5 PAGE TBD J-3-1 Evacuation Time Estimates -TBD

_ Note: Final Evacuation Time Estimates are the responsib-ility of PECO and will be included when available.

K-2-2 Municipal Traffic Control Points in the EPZ K- APProximately one-half of the 118 location points

' are not designated as to which force will " man" them.

K-2-5 None of the TCP outside the EPZ are manned.

K-3-1 Roadway Clearanec/ Fuel Resources No r.esources to support municipal needs .

No resources to support county needs along evacuation routes K-3-2 Most service stations hours aren't listed for service.

K-4-2 Number of State Police available sho a real lack of available personnel to control ACP's.

L-1-1 Support County Reception Centers Malls and schools not confirmed.

L-2-1 No map of locations of reception centers, mass care centers and host schools.

L-4-1 Reception Centers not confirmed.

L-4-2 Reception Center Capacity Shelters not determined fpr Lollar Middle School, Upper Perkiomen Sr. H.S.,

Indian Valley Jr. H.S., Methaeton Sr. H.S., Burnside Elementary School.

L-4-4 No feeding centers for sheltering and school evacuation provided.

L-7-2 No mass care activity report from the Red Cross, L-8-8 Capacities of animal shelters-TBD M-1-0 Decontamination of Emergency Workers stations not confirmed.

M-2-8 Farmer Accesc to Plume Exposure Pathway EPZ Contact point for farmers to pick up K-I isn't verified.

TABLE #6

25.

ITEMS MARKED TBD (To Be Developed) Exanples Sample Draft County Plan Montgomery County, RERP, Draft 5 PAGE TBD M-3-7 No decontamination stations for Emergency Workers confirmed.

M-6-1 Radiological Staff Assignments

-Not established at all.

M-7-1 Laundry Facilities for contaminated clothing-TBD N-7-1 Special Facilities Evacuation information missing for St. Gabriel's Hall N-8-1 No map of school districts, risk building, host schools, private schools and colleges, or what router they should evacuate by. .

0-1-1 Protective Action Guide for Farmers and Food Processors- None developed by Dept, of Agriculture Q-1 Resource Requirements Central Resource Receiving Point Manager (s) -TBD No Letter.of Agreement for use of facility or specific place Q- 1 -1 Support Requirements for Montgomery County- Dis, tribution TBD q-2-1 Municipal Requirements for Equipment and Personnel not developed, Equipment, personnel, and distribution not developed for any of the townships or boroughs.

X-1-1 Industrial Emergency Planning Information No contact person or emergency shutdown times are given, Number of persons needed to shut down plant or their telephone number not developed.

X-4 1 County Parks and Recreation Area Planning Information No municipalities, contact person or special resources needed, e.g. buses, are given or specifics on Police Services group.

TABLE #6 9

26.

(LEA-11)

' The draft'Sch'ool District RERP's are deficient in that there is insufficient information available to reasonably assure that the number of buses to meet the needs of any of the schools are available, or that they will be able to reach the schools during or even before an evacuation. ,

School District RERP's II.G.3, Basic Plan, Evacuation Concepts, Logistics of Evacuation (a-f): Especially C." Sufficient transportation will be provided.to more all students inside the EPZ IN ONE LIFT" For example: Unmet transportation needs for schools were reviewed for each of the Montgomery County School Districts. The following Tables, #7 (pg.27) S #8 (pg. 28) list the number of buses needed (in addition to those available locally), as well as the additional number of students requiring transportation. According to the School District plans, 65 buses and 4 vans are known to be needed, 6021 students, 37 faculty, and 3 other personnel additional people require transportation.

Assuming that 72 passenger buses are available, apprcximately 153 buses would be needed to meet these needs.

-This-differs from the total of 104 buses listed-in the Draft Montgomery County aLkP, Draft #5, Appendix 1-3, which lists school bus needs by tunicipality.

BASIS 10 CFR 50.47 (a) (1) , (2) (b) ; NUREG 0654, Criteria D.4; School District RERP's.

/

27.

. UNMET NEEDS: Buses To Evacuate Montgomery County Schools

• POTTSGRO'!E ' SCHOOL DISTRICT Pottsgrove High School 14 Buses West Pottsgrove Elementary 4 Buses Ringing Rocks Elementary 2 Buses TOTAL 20 Buses POTTSTOWN SCHOOL DISTRICT Pottstown Senior High School 15 Buses Pottstown Junior High School 7 Buses Franklin Elementary School 4 Buses ,

Lincoln Elementary School 6 Buses West End Elementary School 5 Buses 4 Vans TOTAL 37 Buses 4 Vans SPRINGFORD AREA SCHOOL DISTRICT Oaks Elementary School 3 Buses Springford High School 5 Buses TOTAL ~ 8 Buses

-* Source: Fenool District Draf t RERP's TABLE #7 9

e

28.

O UNMET NEEDS: Montgomery County School Students Requiring Transportation

! (T BD)

SCHOOL DISTRICT _

STUDENTS FACULTY OTHER PE9KIOMEN VALLEY SCHOOL DISTRICT St. Eleanor's School 265 13 -

St. Mary's Senool 196 9 3 Bright Spot Kindergarten 40 3 -

Twin Acres Country Day School 65 - -

TOTAL 566 25 3 POTTSGROVE S,CHOOL DISTRICT St. Gabriel's School 206 16 -

St. Pius X High School 664 37 -

Greater Pottstown Christian Acad. 30 2 1 TOTAL 900 55 1 POTTSTOWN SCHOOL DISTRICT The Hill School 500 160 -

Wyndcroft School 183 22' 4 St. Aloysius School 480 37 -

St. Peter's School 95 S~ -

TOTAL 1,258 224 4 SOUDERTON SCHOOL DISTRICT TOTAL 1,355 SPRINGFOR- AREA SCHOOL DISTRICT Chapel Christian Acad. 458 24 2 Sacred Heart School 244 10 -

West-Mont Vo-Tech School 413 -- -

Collegeville Montessori Acad. 34 2 1 St. Joseph's Kindergarten 25 1 -

TOTAL 1,174 37 3 UPPER PERKIOMEN SCHOOL DISTRICT TOTAL 768 -- --

MONTGOMERY COUNTY' TOTALS 6,021 341 11

• Source: School District Dra f t RERP's

• • " ...NON-PROFIT PRIVATE SCHOOLS ARE THE RESPONSIBILITY OF THE SCHOOL DISTRICT IN WHOSE TERRITORY THEY ARE LOCATED. ALL SCHOOL PLANS, INCLUDING PUBLIC AND NON-PROFIT PRIVATE SCHOOLS, ARE THE RESPONSIBILITY OF THE APPROPRIATE SCHOOL DISTRICT SUPERINTENDENTS."

--PEMA Letter,/s/ Adolph L. Belser, Director, Office of Plans and Preparedness, 10/14/83 a

TABLE #8

29.

(LEA-12)

~

.The draft School District RERP's are not capable of being implemented because there is no reasonable assurance that there will be sufficient numbers of teachers and staff required to stay at school or with evacuated students. (Under IIV. Concept of Operations srts A-D) School District RERP II G3 Basic Plan, Logistics of Evacuation. 3(d).

BASIS 10 CFR 50.4 7 (a) + (b) ; NUREG 0654 Criteria A.

Under the concept of operations as developed teachers and staff are ,

required to stay with students during preparation, sheltering, and evacuation scenarios. Various needed tasks are assigned to them. There .

, no assurance, because of (1) human response ~ factors during rediological emergencies (2) desire to evacuate oneself or one's family first even at preliminary stages of alert (3) absence of clear, specific, and binding contracts or agreements with teachers and staff that sufficient teachers and staff will fulfill the assigned tasks need to protect this especially sensitive segment of the population. Therefore, under the present draft RERP, children are not protected in the event of a radiological emergency.

(LEA-13)

It is contended that there must be specific adequate approved plans to evacuate and protect all school children and children in day care centers or private day care. The Applicant's Draft plans are in-adequate because they fail to comply with 10 CFR 50.47 (2) 6 (b) in that children are not protected in the event of a radiological emergency.

There is no separate plan whatsoever to evacuate private day care centers that have between 20-75 children at each school inside the EPZ. No host schools have been named, transportation arranged or pick up determined. Beyond all the complications of having no plan, f

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ J

4 30.

the. psychological effects on child behavior when separated rrom paren'ts unexpectedly and subjected to changes in schedule and environment can be severe. Children become insecure, frightened.and often totally unmanageable and tramatized. With'regards to the parents, they become

' emotional about a preschool child's first experience away from home and will object to such irregularities as not being able to pick children-up directly at the school if this is the intent of the planners

If it i s,-these numbers are not reflected in the traffic patterns and control, if they have other children shipped to host schools, or in the home preparation time to evacuate (as sited in Appx. 4 NUREG 0654.

1. Montco. RERP (Draft 5)~ no provision for evacuation for private day care centers (N-2-1) Annex (N) Appendix N-2 Annex (J) .

Appendix J-2

2. Berks Cty. RERP (Draf t 5) (J 1 ) Only one nursery school .

4

mentioned and no day care facilities for EPZ (Appendix N-7 N-7-1)

3. Ches Co. RERP (Draft 6) only one kindergarten, no nursery or day care centers listed for EPZ. Appendix 1, Annex N (.N 1 )

(N-1-3)- (N-2-1) i i BASIS NUREG 0654, Criteria 0.4; NUREG 0654, Appendix 4; NUREG 0654, Criteria C.4, 10 CFR 50.4 7 (a) (1) , (2) e i

(LEA-14)

The draft School District RERP's are deficient in that there are no dosimetry supplies or KI for school bus drivers, teachers, or other school siaff who may,be expected to make multiple trips into or stay in, the EPZ because of shortnges of equipment and personnel.

This lack violates NUREG 0654 Criteria K.3.a.

See Ches Co. RERP (or other County Plan) for dosimeters Annex M -

Appendix 2 (M-2-2) B. Property Control.

e + .-e-e- * -,w --,,.--.vg , -- ,.-w.-.,,gv.- mm..,y se - , , , , , - - ----r--wr----~--m--,y. yew- y ,,y y ry- my--ni-,m y m- v--g - w aw -y w, wogm -ww--e

31.

The draft School District RERP's are deficient in that there is no reasonable assurance that school bus drivers, teachers, or other school staff are properly trained for radiological emergencies.

Neither are the training criteria for such personnel set forth or accountability programs described to assure that the requisite training is in fact received.

BASIS 10 CFR 50.47 (b) (15) ; See Methacton School District,.RERP,Section III., page 15 (same for all School District RERP's)

(LEA-1S)

The draft Schoc1 District RERP's are deficient in that no adequate being provision is made to provide bus drivers who are committed to available, or are available, during a radiological emergency, or even during proliminary stages of alert.

School District RERP (II.G.3 Basic Plan, Evacuation Concepts. Logistics of' Evacuation a-f)

School District RERP (IIK. Basic Plan,, Responsibilities e and f)

School District RERP IIV Basic Plan concept of Operations A-D

1. No letters of agreements exist with bus drivers willing to fulfill their assigned role. Agreements must be clear and binding.

2. Human response factors during radiological emergencies will affect reliability of bus driver supplies. first

3. Bus drivers will tend to evacuate themselves and their families even at preliminary stages of alert.

4. Drivers may not be able to reach buses or schools during evacuation or pre-evacuation conditions. No provision for such transportation exist.

BASIS:

10 CFR 50.47 (a) (1) , (2) ; NUREG 0654, Criteria A.3, A.4, C.4; School Dis-trict RERP's as cited above.

32.

(LEA-16)

The county, municipal, institutional end school district RERP's do not provide adequate. protection for Catholic schools, convents and'rectovies. According to the PEMA letter Jated 10/4/83, non-profit.priva'te. schools are the responsibility of the school district in whose territory they are located. All school plans, including public and non-profit private schools, are the responsibility of the appropriate school district superintendents. "Only if a private school-or. schools. refuse to cooperate with the school district super-intendent will an exception be acceptable, and, in that event, that .

fact should be duly noted_in the school district plan." Draft public ~

SCHOOL DISTRICT RERP's fail to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. In such a case, this population is likely to be overlooked; especially in such areas as the provision of buses,

~

bus drivers, training, and prompt notification.

BASIS:

10 CFR 50.47 (a) (1) , (2); NURc3 0654, Criteria A.3, A.4, C.4; Perkiomen Valley School District RERP (LEA-17)

Draft Municipal RERP's are incomplete and deficient in that there are many specific errors, contradictions, and omissions. Examples for 2 sample townships follow as Table #9 (West Vincent Twp.) and Tabic #10 (Schuylkill Twp.) (pages 33 to 41)

BASIS:

- 10 CFR 50.4 7 ' (a) (1) , (2); NUREG 0654, Criteria A.4, C.4; NUREG 0654 I .J . (page 29)

BJ.

I SAMPLF OF MUNICIPAL RERP DEFICIENCVES (Municipality)

West Vincent (Chester Co.1 Draft J PAGE 9 We arc confused by the organizatiot. ith respect to police duties. Why has the Polic een assigned other duties and police ft de the responsibility of the EMC?

Burnley is out of the area dur. g mv of the day 9 (B-1) Mr. G.

at his place of employment. How can he have an essential job in the plan?

9,1 dk) The EMC (David Monteith) is also the snow removal contractor. How can he do both jobs in this type of a crisis situation? We deel all esse. .ial positions must be filled with people who are in the area most of the time and must have a deputy for each job with the same criterion to be available in the absence of anyone on the organization chart.

(EPmap) We do not feel that Crawfords' Towing is a practical ISy choice for towing disabled vehicles from West Vincent Township. He is located on the evacuation route and would not be able to back track into our area.

21 (3sh Many teenagers and other children are left at home alone 21 (4 e') during some part o'f the day while their parents or 14 (e2) parent are at work. How do you plan to handle their transportation? It would be silly to ask them to call the EOC as that phone will be jammed. If they could find a ride, where would they be taken? How could their parents find them?

I Tk) In the event of a major snowfall, we doubt the ability of state and local forces to handle the situation of snow removal and evacuation. It is not unusual to be snowed in for six to eighteen hours in the township. Many older people are not capable of driving in heavy snow conditions. How would people who are snowed in their long driveways and private lanes be able to get out?

If this question is not effectively answered, then the whole plan is almost worthless.

Would supervisors be willing to say that people with long drives and lanes, who are snowed in, would be left to their own devices?

' TABLE #9

34.

SAMPLE OF RERP DEFICIENCIES (Municipality)

West Vincent (Chester Co.) Draft 4 {contd.)

t PAGE (P-1) The police department is part-time. How can two cars, a Chief and four officers Jbe available? They are not available twenty-four hours a day, seven days a week?

Will the Chief Icave his wife and small children to serve West Vincent? Will other officers leave their families

.and stay to work in an evacuation? We feel that in order to be listed, they must really be "available" and have signed agreements to show they will come into West Vincent to work in case of a Radiologicial emergency.

(NUREG 0654, Criteria A.3)

(C-1) We feel that the contracts with all concerned must have ,

clear and honest information that the contractor er police officer will be expected to come into and work in an area where they may bs exposed to radiation.

Any contracts without this disclosure are worthless in our opinion.(* C-1 contains no Letters of Agreement as required by NUREG 0634 II A3)

(Attach F) The plans for the hearing impaired, disabled, etc. are (F-1) being developed from information from the Chester County Survey. This survey is faulty, as many residents did not receive the questionnaire. Are you aware of this?

Do you plan to inform the Chester County EMC of this problem?

(F-1)

How will ambulances enter our area when they would have 14 (e6) to buck traffic the whole way? Since West Vincent is served by Phoenixville and Uwchlan for ambulance service, we doubt they will have units available to serve us as they will be swamped in their own areas.

Seg,EP If there is going to be danger from radiation in West Vincent and Upper Uwchlan township, why is there not' going to bc danger from radiation at Downingtown High School?

TABLE #9

f

! 35.

DETAILED COMMENTS Schuylkill Township Page i The promulgation should state that the plan coordinates with other Township emergency plans.

Page iii Reviewer for annual review and certification is not clear.

On Page 8, it appears to be the Emergency Management Coordinator.

Responsibility for distribution of changed pages is not clear.

Page 1 A. Purpose The type of incident and the anticipated A clear statementperils to the is of purpose Township are not stated. "...an incident needed, and should state more specifics than at the Limerick Generating Station."

B. Scope The statement of compliance with Federal Guidelines, as ,

well as Commonwealth of Pennsylvania and Chester County The plans is not sufficient to provide an effective plan.

authors must think and devise a logical plan to avoid con-fusion in the actual emergency.

The statement that the plan applies to the plume exposure Elsewhere pathway implies coverage of airborne perils only.

in the plan other perils are implied but nowhere are they clearly stated.

Reference to th,e Map, Figure 2-1, should include its page, Page 11.

Page 2 Definitions should be added for:

EMC - Emergency Management Coordinator EOC - Emergency Operations Center Both of these definitions should clearly show if the item is at the County, Area, or Township level.

Page 3 In items "a" through "c" the potential perils and their In item "d" anticipated duration should be clearly stated.

no mention is made of incidents from mishandling of spent radioactive fuel or similar hazardous material.

Page 4 Definition 16 should state the radiation dose value which warrants action. Is it the 25 rem and 75 rem levels?

indication Page 5 Definition 25, State of Disaster Emergency has no of how this ties in with (or conflicts with) the local plan.

TABLE #10 l

36.

Page 6 In F. Objectives the first item should define the hazards and perils being planned for.

In F.2 the planned. actions should be effective and workable as well as current and in consonance.

In F.4 we need more than a " basis" for functional implementing procedures. We'need-the actual procedures to implement in the face of an emergency.

In F.5 it is not possible to'" Ensure that the population of Schuylkill Township'is informed. . ." with the total lack of any description in this plan of the type of hazards 1:

anticipated and the rapidity of their development and duration of their existance.

Page 7 A. General should list all the local government jurisdic-tions impacted by Limerick. The plan draft shows no 4

evidence that consideration was given to Phoenixville residents passing through Schuylkill Township in their evacuation. There is no evidence in the draft plan that the concluding sentence has been considered. .

In B. Municipal Government Emergency Operations 2.a it is ,

implied that this is a township function. No indication of the next higher level of authority is given.

In B.2.b the statement should read, " Develop radiological emergency response plans to protect residents in consonance with the county plan."

, In B.2.c another statement of the " Route Alert" system?

Considerations should be given to a telephone network for alerting to save time, fuel, and avoid traffic congestion.

In B.2.f the whole traffic f1bw plan for the township and its neighbors should be stated. The flow of Phoenixville residents through the Township must be identified and made realistic with existing road capacities.

In B.2.g no guidelines for volunteer training are indicated.

Federal, State or County assistarce would be proper due to the commonality of the situation to all nuclear plants.

Page 8 In B.3.a (1) there is no indication of how Phoenixville residents passing through the Township will be protected.

If B.3.a (2) is in fact what P.L. 11332 says, then P.L.1332 is seriously flawed. Our situation with shared fire and ambulance services does not fully qualify us to direct emer-gency services not normally administered by the Township.

Figure 2-2 should show five supervisors, should show who

has route alert responsibilities, how three fire companies fit in the " Fire and Radiological" box. The " Medical and

. Transportation" box is logically an area function - not a Township function.

i TABLE # 10

, -. . - - , ,, --.....,.-,,,y- 7,.-.,-.-,r---*

w- m v-t----r--wv----+ =--v'--me -v,w,----+ve--*+-~^--**-~--'e w-- --

-~-f - - '

i -37.

B.3.c (4) Outside forces on loan to the Township should be under Township supervision to assure coordination. Two police forces in the same geographic area working under different commands is an invitation for trouble.

In B.3.a (6) what are the " normal dispatch and operational procedures" to be used?

In B.3.b (1) (a) the cost responsibility to develop and maintain the Schuylkill Township RERP need to be stated.

Logically PECO should defray the cost since they are causing the worry.

Page 9 In B. 3.b (1) (e) the expense records purpose should be stated.

Logically it would be for PECO reimbursement.

In B. 3.b. (3) (a) it would be wise to state that normal areas of coverage in the Township will prevail throughout any emergency.

B. 3.b. (3) (b) need much work on details to provide a good definition. Attachment E is TBD but Tellabs design process -

no longer relevant.

B. 3.b. (4) (a) through (d) recognition must be given to the fact that no one single entity covers the Township for Medical / Ambulance Services. It would be logical for normal area coverages to prevail through any emergency.

Pago 10 In B. 3.b. (5) (c) who identifies what roads are to be cleared?

Who is allowed use and who is prevented from use?

Pcgo 10a In B. 3.b. (6) no consideration is shown for the three fire services that cross Township lines. This needs much better coordination for the plan.

In B.3.b.(7) no consideration is given to the fact that the Township has no explicit " Ambulance Service" function.

In B.3.b. (8) is it intended for the Emergency Management

-Coordinator to be the communicator (telephone operator) also? Better planning is needed for the mechanics of communications and logging them in and the overall Emergency Management decision making process.

Pago 10b In B.4.c.(3) and (4) the Township does not have a " Fire Services Officer" and a " Medical / Transportation Services Officer" let alone a department for each. The plan as drafted for us does not recognize our situation. All staff should be designated by name also.

Page 11-1 There is no excuse for not including a physical floor plan sketch in the draft. This information 6xists as a real building now in use.

Page 11 In B.4.e. back-up personnel for 24-hour staffing are mentioned but not listed. The plan should indicate all those persons to be of use.

In C.1 the EOC te'aphone numbers should be listed. Also TABLE #10 .

.. .. I

y sufficient phone lines should be indicated.

In C.3. the ARES operator and his back-up should be identified. Physical room, power requirements, and antennae vequirements at the EOC should be stated.

In C.4. the telephone number for rumor control must be listed. If a rumor control number does not exist at the time the plan is being drafted, it is unprofessional to include a non-existant service.

Page 12 In D. 2. a . (1) no indication is given of the PECO alert system. Is it sirens, sky rockets, or similar means?

Also, the EBS radio and TV stations should be identified for our location.

In D.2.b. the details of " Route Alerting" must be spelled out. This plan should set all the advance work out of the way so when an emergency arises, action can be taken ,

without agonizing over decisions about routes, methods,

~

etc. No Attachment E.

In D.2.c an initial list of the known Township hearing impaired should be included. Who is the " Municipal EMA" who will dispatch?

Pego 13 In E.2.a. a better identification of perils is needed. The term " hazards of radiation" covers both immediate, short-term perils as well as long-term cumulative hazards.

In E.2.d. the evacuation routes require much elaboration.

Also, Welsh Valley Road and Diamond Rock Hill are omitted -

why?

Page 14 In E . 2.e . (3) indication of who to contact and what tele-phone number should be given.

Detailed evacuation routes, drain areas, flow capacities, surge durations and similar data need to be shown. The influences of neighboring evacuation traffic sources (Phoenixville) should be clearly shown. Schuylkill Township is not an isolated island. E.2.f reference Attacment D is incomplete, virtually blank.

Page 14-15 In E.2.g. separate school plans are again mentioned.

Logically several evacuation plans are needed to accomodate the very different situations arising in:

(i) normal weekday incident (ii) Iste night incident (iii) weekend or holiday incident For each of the above, the locations, activities and mobilities of all evacuees will be very different.

TABLE #10

Page 15 In E.2.i no allowance is made for farmer access to care for livestock that was not evacuated. The Township contains both dairy and horse farms whose livestock are valuable ar.d which cannot be left unattended. The plan must address this situation to be of any use.

Page 15-16 In E . 2.1. (1) it is not clearly stated which of the Townships' three fire companies will relocate equipment. This is a basic flaw in the plan. A more logical approach for Limerick would be to plan around the existing fire and emergency squad coverages and administrations instead of imposing an arbitrary Township boundary approach during a nuclear emergency.

In E.2.m. mentions tending of livestock. Apparently pro-visions for livestock care will be made after an emergency is declared with the USDA county agent being the deciding judge. It would be better to at least have the guidelines stated in the plan so that farmers have a planning basis.

Page 16 F. Radiological Exposure Control should clarify the perils that necessitate this plan. If these were made clear, the stated responses might make more sense.

In F'.1.b. DEMA is not defined. Distribution of dosimeters and similar materials is not clearly stated. A well-formed plan would at least state e.uidelines for issuance and use of such materials.

Page 17 Both pages cover the accounting for monitoring materials, but do not give any help concerning their use.

In F.1.d. (2) guidance on' reading dosimeters is given. It should be expanded to include logging the readings to locate hotspots in the Township.

Pege 18 In F.1.e. the specifics of the locations of the monitoring /

decontamination sites should be stated. Without specifics, this draft plan is useless.

Pages 18-19 In G.2.b. and G.3 the term EOC is used loosely and ambiguously. The EOC in G.3 is apparently the Township EOC.

Page 19 In I.2.e. it is not clear who contacts non-ambulatory residents.

In 1.2.f. generalities are stated about institutions /

facilities located in the Township. Specifics must be given to make the plan useful.

Page 20 In I.3.f. TCP's-and ACP's should be defined and candidate locations stated.

Page 21 In I.4.e. no indication of who will take the indicated actions and who will receive assistance. The lack of focus of this plan is its major flaw.

Nowhere in 4. General Emergency is the care of livestock covered.

, TABLE #10

_ _ _ - _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~

I Page.21 In J.1.a. the question of cost for plan development and maintenance is not addressed. Hopefully PECO will cover the costs of all this unusual activity arising from their Limerick facility.

Pege 22 In J.2.e. no recognition is made for our several fire departments.

In J.2.f. no recognition is made of our local Medical /

Ambulance conditions.

In J.2.g. a municipal library is mentioned. No Township library is known to exist.

Page C-1 In II. A. through D. broad responsibilities of the Schuylkill Township Emergency Management Coordinator are stated.

Financial responsibility is not clarified. Logically PECO should bear the costs for setting up and keeping the plan, procedures and agreements current. Also, this section pro-vides no guidance or basis for drawing up agreements. The County would be a logical unbrella for all this instead of ,

leaving it up to each municipality.

Page D-1 Access control points must be stated to make the draft plan useful.

Pages E-1 through E-3 The 21 hearing impaired individuals should be listed.

Sectors and team locations should be listec. Are eight sectors adequate for our Township?

Page E 4 A sector map must be provided to make the draft plan worthy 1

of further review.

Page E-4 If as alleged there are 21 hearing impaired persons in the Township, it would be logical to give each a personalized, specific message instead of the drafted bureaucratic one.

Page F-1 The actual residents needing special help should be listed in the draft. Use of estimates based on U.S. Dept. of Health and Human Services statistics is unprofessional.

Page G-1 Specifics must be listed in the draft plan. Estimates based on 1983 Census Data are not worthy of inclusion.

Compilation of the name and address list should be part of the plan preparation.

The exclusion of schools is ill-advised. A b a s ic flaw is that the plan does not recognize major differences between weekday, weekend, and late night evacuation situations.

TABLE #10

\

41.

Page I-1 To be of any use the draft plan should include all names, addresses, and telephone numbers so that a correctncss check can be done as part of the review.

No recognition is given to the fact that three fire companies sers one township.

Implementing Procedures. The many pages of the draft procedures are flawed by the lack of specifics and details that parallel the omissions of the draft plan. A detailed review at this time is not justified. Some specific criticisms are as follows:

Item 0-1 should list all resources that require checking. A general statement is not appropriate in an implementing procedure.

Page A-19 Item 9 - see above comment on Page A-12, Item 10.

Page A-20 Item 14 - appropriate action will depend strongly on time of day and day of week. The procedure is deficient as is the '

basic plan.

Item 14e - requires more explicit detailing for inclusion in a procedure.

Page A-23 Item 16 - who decides if the EOC must be evacuated?

Page B-5 Item 2.b. (5) - specify the alternate location. It apparently will be the Valley Forge Fire Company. Let's be specific in a procedure!

PaBe B-1 List the names and telephonc numbers for the 25 Fire Police.

Page'B-2-1 The logic and function of the traffic control and access con-trol points must be developed.

Page B-3-1 The "Public Works Resource Inventory" is a grand sounding term.

Does this list include only the Township's lone dump truck?

Pages C-1 The local situation of three fire companies covering the through Township is not covered.

C-5 Page C-2-1 In I.A. quantify the number of sectors.

In III.A. it states that Chester County communications will dispatch route alerting. Elsewhere, on Page A-20, Item 13e route alerting is stated to be activated by the fire department.

Which is correct?

Page D-1 Identify the Medical / Transportation. offices. In Item 3 the lists of special transportation needs should be keyed to time of day and day of week.

TABLE #10 J

r-42.

The state, county, municipal, institutional, and schcol district RERP's are. deficient in that the conduct of and planning for drills and exercises ir not sufficiently detailed in the plans. There is no assurance that such. exercises and drills provide a sufficiently realistic test of emergency plans and response capabilities. Indeed, to the extent that participants in such drills and exercises have prior knowledge of the dates, times, and other details about such drill and exercises, such drills and exercises do not test preparedness, but rather provide only a minimal test of the ability of the involved organizations to follow procedures.

See Ches Co RERP Annex S S01 S-2 S-3 See Montco RERP Annex R, Annex S BASIS: 10 CFR 50.47 (b) (14)

NUREG 0654 Evsluation Criteria (0) 2 (LEA-18)

The state, municipal, institutional, and school district draft RERP's are deficient in that there is no assurance that there exists the capability and re. sources at each level to accomplish the training required in NUREG 0654 Evaluation Criteria (0)4 a-j. Particularly footnote #2 under this section states:

If State and local governments lack the capability and resources to accomplish this training, they may look to the licensee and the Federal government (FEMA) for assistance in l this training.

l h'e have no reasonable assurance that each response organization has made or will make adequate funding arrangements or other l

' arrangements needed to insure that the training requirements are met.

BASIS 10 CFR 50.47 (b) (15) ; NUREG 0654, Criteria 0.4 (a)-(j)

43.

(LEA-19)

The state, county, municipal, school district and institutional RERP's are deficient in that the applicant's Plans fail to demonstrate that sufficient and diverse communications capabilities exits between and among the emergency response organizations to assure effective emergency response under a wide range of conditions, including heavy traffic on commercial communications, adverse weather conditions, and loss of normal power sources, as is required by 10 CFR 50.47 (b) (6) .

The Communications Network as described in Annex B of all county plans cannot handle the amount and complexity of information inherent in any evacuations or pre-evacuation preparations sanario, expecially considering the following:

1. Spontaneous evacuation even of areas outside the EPZ, even during preliminary stages of alert and preparation.

2. Problems with volunteers (CBers, RACES, etc) in radiation risk situations (as previously discussed)

3. Jamming of phone links at all stages of alert, by sheer numbers of calls from within and without the EPZ.

4. Possible blackouts subsequent to electric generation failure.

10 CFR 50.47 (b) (6)

5. No assurance is provided of the operability of county-local go-v.ernment communications links on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.

BASIS: 10 CFR 50.47 (b) (6) ; NUREG 0654, Criteria F.

(LEA-20)

The following municipal RERP_'s are deficient:

Charlestown and South Coventry Townships in Chester County have not yet designated E0C's. New Hanover Twp. in Montgomery County has not yet designated an EOC. No Montgomery County municipality in the Plume Ex-posure EPZ has designated an alternative EOC.

BASIS:

NUREG 0654, Criteria H.3; 10 CFR 50.47, Part 50, Appendix E . 9 (a) S (c)

/

44 (LEA-21)

The state, county, municipal, institutional, and school district RERP's do not provide reasonable assurance that. prompt communications exist among principal response organizations in that "the primary means of conmunicating to/from the Municipal Emergency Operations Center (EOC) will be the t e l-e ph o n e . " (eg. Union Township RERP Draft 4 page 11 (c.

conmunications 1.) (Also West Pikeland RERP #4 page 11 C.1) (as in all nunicipal plans).

Interface between the municipal EOC and other response organi:ations is critical to the adequacy of all RERP's. Integrated communications is required Municipal Emergency Operations Centers (EOC's) have inadequate telephone lines to accomodate the volume of calls (incoming and outgoing) that will be made in the event of a radiological emergency.

For example, Union Township's EOC has 1 phone line.

BASIS:

NUREG-0654, Criteria F.1(a) thru (e) , Criteria F.2, Criteria H.4; 10 CFR 50.47, Part 50, Appendix E.9(a) 6 (c)

(LEA-22)

The state, county, and municipal RERP's are inadequate since farmers within the Plume Exposure Pathway EPZ who have livestock to tend to are considered as " emergency workers", but have not been provided communications and support (including dosimetry, KI, and decontamination facilities.'The County Agent, as designated, has no such resources, BASIS:

NUREG 0654, Criteria H.7  ; 10 CFR 50.47(b)(6).

G

d5.

(LEA-23)

The Applicant's Draft Co,unty Plans are deficient because they do not contain reliable evacuation time estimates, as described in NUREG 0654 Appendix 4. Pr'evious studies by the Applicant were not based o'n present or final emergency response plans, planning assumptions, or on the state of emergency preparedness and conditions existing at the time of an accident.

BASIS

• Appendix J-3 of the Berks and Montgomery County Draft RERP's state

'that final evacuation time estimates are the responsibility of PECO' and that information will be included in the plans when avai.lable.

Appendix J-3 of the Chester County Plan lists the co'nclusions of a traffic analysis conducted by PennDOT. This information appears ,

to represent a traffic analysis, which in no way provides any basis for determining the acutal times needed to effectuate an evacuation of the a r e a'. The Chester County Draft RERP states (J-2-1) that, ,

"A more detailed analysis of evacuation time estimates is being commissioned by Philadelphia Electric. When completed, it will'be reviewed in comparison to the PennDOT data, evaluated, and included in this Annex."

Previous studies have failed to adequately consider the impact of adverse weather conditions, particularly snow, ice, and fog. LEA contends that any reliable evacuation time estimate should consider j all possible weather conditions, and that evacuation time estimates I should reflect the impact of these adverse conditions. LEA reserves the right to review and comment on any additional evacuation _ time estimate studies, and will file more specific contentions on this 1 -

subject as additional information becomes available. ,

BASIS:

NUREG 0654, Appendix 4., 10 CFR 50.47 (2) e

n

• 46.

(LEA-24)

The RERP's are inadequate in that the plans do not include certain recreation and commercial areas contiguous to the EPZ, which would, during an evacuation and also in the preliminary stages of alert, significantly affect warning times, traffic flow, and complications resulting from human response.

Also, since many of the users of the areas reside in the EPZ, a particular traffic flow problem arises when the users attempt to return to their homes before attempting to evacuate (for instance, in order to pick up other family members, valuables, or pets).

Tble 1 pg 17 NUREG 0654, CFR 50.47 Nureg 4-3 Nu-Reg p 11, p 17 -

specifically the non-inclusion of the following areas cause the plans to fail.

Marsh Creek )

French Creek ) Issues of traffic patterns and notification Horseshoe Trail ) are not discussed. Estimates of transient Valley Forge Park ) population (0654-4 3b, CFR 50.47 c(2) are Malls Exton .

King of Prussia ) not made Note: Shc1tering will not work in many of these situations.

BASIS:

NUREG 0654, Appendix 3, page 16.; NUREG 0654 I.D. page 8; 10 CFR 50.47 (c) (2)

(LEA-25)

The plume exposure pathway Emergency P1anning Zone for the Limerick Generating Station should be expanded to . include the City of Philadelphia and surrounding metropolitan area in order to provide for pre-planned protective responses aimed at reducing total population exposures, thereby limiting the number of latent cancer fatalities caused by severe accidents at the Limerick Generating Station.

47.

BASIS The U.S. Nuclear Regulatory Commission (NRC) and the Federal Emergency Management Agency (FEMA) have established an approach to radiological emergency planning and preparedness' based on the establishment of two

" Emergency Planning Zones" (EPZs).1,2 In a joint NRC/ FEMA report , NRC and FEMA set forth an overall objective for radiological emergency response plans, which is "to provide dose savings (and in some cases immediate life saving) for a spectrum of accidents that could produce offsite doses in excess of Protective Action Guides (PAGs)".

The principal radiological health effects considered in the establishment of NRC and FEMA guidance were doses in excess of the Environmental Protection Agency's (EPA) Protective Action Guides 4 and doses -

capable of causing early fatalities and early injuries. The two EPZs established by the NRC and FEMA are a " plume exposure pathway" EPZ and an

" ingestion exposure pathway" EPZ. The establishment of such EPZs was recommended in a joint NRC/ EPA report.5 According to NRC and FEMA regulations, the plume exposure pathway EPZ shall consist of an area about 10 miles in radbas and the ingestion pathway EPZ shall consist of an area about 50 miles in radius. ~

This guidance was established on a generic basis, but the exact size and configuration of the EPZs surrounding a particular reactor site shall be determined in relation to local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries.6 The exposure sources for the plume exposure pathway are whole-body external exposure to gama radiation from the plume and from radioactive materials deposited on surfaces during plume passage, and internal exposure resulting from inhalation of radioactive materials during plume passage.7 Latent cancer fatalities were not explicitly considered in the development of the NRC and FEMA amergency planning zones. This is ouite clear based on a close reading of NUREG-0396, which is exclusively concerned with avoidance of doses in excess of PAGs and avoidance of early health effects (early fatalities and radiation sickness). In addition, this is explicitly stated in an internal NRC memorandum prepared by one of the members of the Task Force on Emergency Planning which authored NUREG-0396.0 f

9 NUREG-0396 did explore the variation of consequence magnitudes with .

distance for early fatalities and early injures, but these evaluations assumed a uniform population density of 100 persons per square mile. These results are based on an earlier Sandia Laboratories study using the CRAC accident consequence code.10,11,12 13 A more recent study , using a ' revised version of the CRAC code designated CRAC2 14 did examine latent cancer fatalities, also based on 'a uniform population of 100 persons per square mile. For a large occident source ters (designated SST1, release involving 45% of the iodine group inventory,' 67% of the cesium group inventory, 64% of the tellurium group inventory, 7% of the barium-strontium group inventory, and 5% of the ruthenium group inventory), and a hypothetical uniform population distribution of 100 persons per square mile, less than 20% of the cumulative number of latent cancer fatalities are encompassed within 50 miles of the site.

For a densely populated site (Indian Point), however, the results are dramatically different. While it is obvious that the consequence magnitude would be higher at the more densely populated site, the distribution of the cancers is drastically different, with approximately 50% encompassed within 50 miles of the site for the SST1 source term.

The Limerick Generating Station is situated in the second most densely populated site region in the U.S. At 20 miles, Limerick is roughly four times more densely populated than average, and at 30 miles is roughly seven times more densely populated than average.15,16 Based on data contained in the

~

Applicant's " Severe Accident Risk Assessment" , much of the population within 20-30 miles of the Limerick site is concentrated in a few compass sectors containing the Philadelphia / Camden metropolitan area (roughly 40-60% depending upon the distance). Similar latent cancer distribution results to Indian Point would be expected for the Limerick site.

It would seem, therefore, that minimal emergency response measures such as sheltering, ad hoc respiratory protection, and relocation from radiological hot spots couuls substantially reduce latent cancer fatalities in areas beyond the present 10-mile plume exposure pathway EPZ. Such planning for the Limerick site would seem to be entirely feasible.

40 l

It should be noted, moreover, that the Applicant's PRA studies I 'Ib assume some emergency response to distances of 25 miles or more. Thus, in ,

order to realize the consequence predictions in those studies, emergency response at considerable distances from the Limerick site will be necessary, or accident consequences will be more severe than already predicted in the PRA studies for Limerick. The best way to assure adequate offsite response is through advance planning.

Emergency response plans for distances beyond 10 miles from the Limerick site need not be elaborate. Prompt response would be dependent upon prompt and reliable communications among all response agencies and 'idequate radiation monitoring capabilities. Since some degree of governmental involvement with the ingestion pathway EPZ plans already exists, only mirimal additional effort would be required to expand these pl ans to account for plume exposure t considerations. Such planning would help assure that in the event of a severe radiological release from Limerick, the total population dose would be limited, thus limiting the number of latent cancer fatalities in the decades following the release.

R E F E R EN C E 5

1. 10 C.F.R. 50.47(c)(2); 10 C.F.R. 50.54(s)(1); 10 C.F.R. Part 50, Appendix E; 45 F.R. 55402-55413, August 19, 1980.

2. 10 C.F.R. 350.7(b); 48 F.R. 44332-44341, September 28, 1983.

3. NUREG-0654, FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, November 1980.

l

4. EPA-520/1-75-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Office of Radiation Programs, U.S.

Environmental Protection Agency, September 1975, Revised June 1980.

5. NUREG-0396, EPA-520/1-78-016, Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of i

Eight Water Nuclear Power Plants, Task Force on Emergency Planning, U.S.

Nuclear Regulatory Commission and U.S. Environmental Protection Agency, December 1978. .

6. 10 C.F.R. 50.47(c)(2); 10 C.F.R. 350.7(b).

t

w 1

50. l

7. Ref. 3, page 8.

k

8. NRC Memorandum dated 1/28/82 from Roger M. Blond to Ronald M. Scroggins,

Subject:

" Emergency Planning anj Source Term Developments".

9. Ref. 5, page I-48, Figures 1-17 and I-18.

10. NUREG/CR-1131, SAND 78-0454, Examination of Offsite Radiological Emergency Measures for Nuclear Reactor Accidents Involving Core Melt, D. C.

Al dri ch , P. E. McGrath, and N. C. Rasmussen, Sandia Laboratories, prepared for the U.S. Nuclear Regulatory Commission, June 1978, pages 106-107.

11. WASH-1400, NUREG-75/014, Reactor Safety Study: An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants, U.S. Nuclear Regulatory commission, October 1975, Appendix VI, "

Calculation of Reactor Accident Consequences".

12. NUREG-0340, Overview of the Reactor Safety Study Consequence Model, I. B. ,

Wall, et al., U.S. Nuclear Regulatory Commission and Sandia Laboratories.

October 1977.

13. NUREG/CR-2239, SAND 81-1549 Technical Guidance for Siting Criteria Development, D.C. Aldrich, et al., Sandia National Laboratories, prepared for the U.S. Nuclear Regulatory Commission, December 1982.

14. NUREG/CR-2326, SAND 81-1994, Calculations of Reactor Accident Consequences Version 2 CRAC2: Computer Code (User's Guide), L. T. Ri tchie, J . D.

Johnson, and R. M. Blond, Sandia National Laboratories, prepared for the U.S. Nuclear Regulatory Commission, February 1983.

15. NRC Memorandum dated 9/29/83 from Harold R. Denton to Edward S. Fay,

Subject:

" Congressional Staff Request for Information".

16. NUREG-0348, Demographic Statistics Pt etaining to Nuclear Power Reactor Sites, U.S. Nuclear Regulatory Commission, October 1979.

17. Report No. 4161, Severe Acci(ent Risk Assessment: Limerick Generating Station, NUS Corporation, April 1983, Tables 10-2 and 10-3.

18. Probabilistic Risk Assessment, Limerick Generating Station, Rev. 5, September 1982.

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g-m 9-ynw.-;----ewyy--.yy----%-4 **pms.--r.>g- -p w-.r-i 9 m v4-+--

- _ - - ~- ~_ - . - _ - .

51.

(LEA-26)

The Applicant's Emergency Plans are deficient in that they E do not comply with 10 CFR 50.47 (b) (5) because there is no prompt alerting system operative and in place (such as a siren alerting system), there is no assurance that emergency worker can be desig-nated or notified promptly, and there is no demonstrated adequate -

"means to provide early notification and clear instructions to the populace within the Plume Exposure EPZ".

BASIS 1

The Applicants Plano indicate that a Tellabs 294 alerting l

system was planned as the primary public alert system for the Plume Exposure EPZ. On Nov. 30, 1983, the Applicant notified PEMA that a decision had been made to install a conventional siren system with a verification capability in each Risk County. No additional information has yet been provided to LEA or is reflected in the Applicant's Plans. The siren system has not yet been installed or tested.

, It is proposed that route alerting will be used as a supple-ment to the public alert system wher.e there is a known system fail-f l ure. Route alerting as presently described in the Applicant's Plans is an insufficient method of prompt public notification and cannot be implemented because there is no assurance that there will be sufficient personnel and the plans contain no route alerting sector maps. There is no indication of the time route alerting would take to implement, including preparation times, and there is no indication that there are sufficient vehicles with loudspeakers available. There is no basis to determine whether or not route alerting is in fact an effective method of notifying the public. The criteria of NUREG 0654 II E.6 are not met, nor is there compliance with Appendix 3 (NUREG 0654) including Section B. Criteria for Acceptance.

No adequate means of notTTVIng emergency works within and outside Ine the EPZ is initial described.

alert /norirications procecures in annex U or the Applicant's Plans do not comply with the guidance of NUREG 0654 Appendix 3 at C.2 Notification of Response Organizations, p. 3-7.

The notifications in the plans are made sequentially, and time is taken between each call for handwritten logs. This is contrary to the guidance cited which states that, " Warning points cannot be

52.

encumbered by sequential call down processes nor can response organizations accept the time lost by such processes". Ten sequential

, sets of phone calls, each consisting of numerous separate conver-sations, must be made before the activation of the public alerting system is commenced , according to Annex C, page C-2 of the Chester County Draft #6, RERP. Under such circumstances, there can be no assurance that a oublic alerting system, once installed, would be activated within 15 minutes, as is required by NUREC 0654, Anpendix 3, B.2.a (page 3-3).

A siren system, which is being installed, must be properly l designed, laid out, and tested (See NUREG 0654 Appendix 3-1.

i However, -

the EBS is not sufficient to complete the notification system especially in ChesCo where the use of WG07 (a non-24 hour EBS station) is planned. '

(LEA-27)

No plans are currently available for Spring Mountain House, a nursing home in Uppersalford Twp., Montgomery County, Camp Hill Village School - located in West Vincent Twp., Camp Hill Special School-located in East Nantmcal Twp. It is expected that RERP's for these health care facilities will be developed.

BASIS:

10 CFR 50.47 (a) (2) , (b) (1)

53. '

(LEWIS)-1 The Draft Radiological Emergency Response Plans are not adequate to protect the health and safety of the public because the plans do not refer to who will have to be. called in off-site manage-ment declaring any level of emergency.

BASIS The requirement that Reactor Operators (R0s) contact offsite management before declaring an evacuation emergency renders the emergency plans unworkable. At 3AM in the morning, the plant operator would have to telephone the management in case of an emergency. (Verbal communication,. Bob Searles, NRC, to Lewis.)

If this emergency were a major breach of containment, minutes .

would be 'ecious. Many of these minutes would be lost in con-tacting of offsite management. The phone numbers of offsite management are confidential. Also, those phone numbers are not published in the public copies of Emergency Plans. The requirement

! to contact offsite management and unavailability of their phone numbers are barriers to implementation of emergency plans.

There will not always be sufficient senior personnel on site to be willing to declare a' site emergency without the approval of higher level personnel. There is still a definite need for oper-ating personnel to contact off-site personnel, and this contention remains viable despite omission of this topic in the draft emergency and implementing plans.

(LEWIS)-2 The Draft Radiological Emergency Response Plans do not require administration of KI soon enough to assure the health and safety of the public.

BASIS According to the FDA, "an important factor in obtaining satisfactory blocking of peak radioactive iodine uptake is the temporal relation of stable iodide administration to radioiodine exposure." Background Material for the Development of the FDA Recommendations on thyroid Blocking With KI, FDA HHS Publication 81-8158, Marc'h 1981, p. 2.

1 h

9

. - - ~ - , - - - - - - - - -

- - - -,,--.--,e w-,wg, w ,en e-,- - - - + < - -

w---m ,-

54.

This intervenor's contention has not been settled in part or in whole by any submittal or by any part of the emergency plan. In fact the emergency plan does not require or mention administration of KI (potassium iodide) to the general public at all. There is a half hearted mention of administration of KI to emergency workers "when available" and at the direction of the Secretary of the Pennsylvania Department of Health." Draft 4, Page 17, East Nantmeal Township, Chester County.

(WHITE)-1 As a person who works within the Plume Exposure EPZ and is sub-ject, as part of my regular working conditions, to one or more of the following on a daily basis: traveling from job to job in a truck, on an unspecified route, to a destination or destinations not predetermined, without (and without access to) radio, telephone, or electricity (while working at each destination), often with little money and no food, I as an employee for a professional moving company am not provided adequate notification, shelter or evacua-tion as required by 10 CFR Part 50, Appendix E (part D, sections 2 i and 3). Thus for me and others in my situation, the Applicant's Emergency Plan doesret heet the requirements of NUREG-0654, Criterion E.6; Criterion G.1, 2 and 5: or Criterion J 10(c).

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BASIS l Appendix E, part D, sections 2 and 3; NUREG-0654, Criteria E.6, l

G.1,-2, and -5, and J.10(c).

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55.

( ANT 110NY) - 1 There is a lack of emergency planning for the Valley Forge Na-tional Historic Park and the King of Prussia area.

This contention concerns the traffic and use patterns for Valley Forge Park and related commuter and shopping and business traffic to and from King of Prussia. All of this is dependent on and interrelated with the highway nexus which focuses long distance travel, medium distance and regional and local traffic on this spot.

Although King of Prussia comprises onc of the most severe traffic concentrations within a radius of 30 miles from the Limerick nuclear site, it is also representative of perhaps fifty such concentrations within 30 miles where 3.8 million live and many more thousands travel for work, school, shopping, etc.

The effect of the operation of the Limerick plant and any accidental release of radioactivity on the people who live in and travel in and out of the thirty mile radius was not given significant considera-tion in PECO's decision to build at that site. In PECO's application for an operating license, inadequate attention has been focused on the s'afety of those people and possible evacuation in case of a l Limerick nuclear emergency. No study of emergency planning for the King of Prussia area or any other of the population concentrations

'in the thirty mile radius is seriously considered in the application.

There should be no possibility of operating Limerick until the safety of the 7.2 million people in the entire 50 mile radius is assured in case of an accident.

To get an impression of the size of this responsibility, the traffic and use figures for Valley Forge Park are included, and the means i of emergency exit are related to the use and peak congestion on the expressways and major highways adjacent to the park. The park records show the total use of the park by 11-1/2 million individuals in a year, including visitors, commuters, groups, and recreational users. Complete emergency plans must be in order, to protect these people. This fact has not been addressed by PECO, nor has the impact of Limerick on the park as a national historic monument.

- 56.

The northern tip of Valley Forge Park is 10 mil'es south-east of the Limerick plant, and the southern tip on the river about 12-1/2 miles.

The King of Prussia business, manufacturing and shopping area is al-most contiguous to the east, at 13 to 15 miles from Limerick.

The park has five traffic counters at entrances to the park. The highest eastbound recording on Rt. 23 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is about 9000 ve-hicles and the average annual daily is about 8000. Westbound the peak day is 6400 and the average 5500. The commuter traffic peaks from 6:30 to 8:30 in the morning, and afternoon pea'- comes between 4:00 and 6,:00. Sightseers and group visits to the park taper off in the fall and start again in the spring. Recreational use of the park continues year round. School and other groups visiting the park reach a peak of 700 at any one time, with at least 20 buses in the parking lot. The majority of visitors enter at the main park entrance on the east.

EMERGENCY TRAFFIC: In case of a nuclear accident at Limerick, there would be little chance to move vehicles in and out of the park ex-cept in the first few minutes after an alarm. Rts. 23 and 252 with only two narrow lanes would become choked almost immediately. Any vehicles reaching the PA Turnpike entrance or Rt. 202 would become immoveable in a massive traffic jam which would extend all the way to Philadelphia, south, Rt. #30 west, and Rt. 202 southwest. Traf-fic on the Turnpike would not move for miles both west and east.

The same would be true of Rts. 202 and 363 east, i.e. interchange blockades and accident pile-ups.

Up to now there is no emergency plan for evacuating Valley Forge I

Park. PECO has not made the attempt, perhaps in the belief that there is no plan that could work because there will be no roads j free to travel. The highest concentrations of traffic at King of Prussia occur early morning to mid-evening but heavy traffic con.

tinues during the evening and on weekends. The extent of this use is indicated by an increase from Sept. to Oct. in 1981 of 33,000 vehicles, when a new shopping mall was opened.

l Since the park is located in both Montgomery and Chester Counties, any emergency planning would have to be coordinated through twc counties and the five townships involved. Although PECO is responsi-ble for seeing that emergency plans are made, there is no way to provide for the safety of residents in the King of Prussia area or the users of the park except by removing the threat of a nucicar accident at Limerick. This means denying an operating license.

b1T5Tb H 53, y ss w IJm EAR N N I XILL D M VALO Y RT t O #5 M~

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V The diagram above shows the relation of Valley Forge Pz.rk to Limerick, King of Prussia, and highways. VALLEY FORGE PARK: The park is a national historic monument administered by the National Park Service under the Dept. of the Interior. The north edge of the park lies along the Schuylkill River, the south edge abuts the Pennsylvania Turnpike. It includes 2600 acres of rolling hills. Two state high-ways cut across the park, Rt. 23 in an east-west direction and Rt.

252 north and south. These are two-lane, high crown, winding, hilly l roads only 25 feet in width. There is steady truck traffic along l these roads and passenger vehicle use is continuous. The park guards are called often to pull trucks off the road when they break down on l

the steep grades. During the morning rush hours, traffic is frequently stalled by school buses. There is a SEPTA public bus line on Rt. 23.

Serious accidents necessitate re-routing an average of 2-3 times a year.

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58.

SUMMAPY: The traffic figures on the map indicate the average daily travel on the east-west and .. orth-south principle highways in the Schuylkill Valley between Pottstown and Conshohocken. In almost daily experience at peak hours, traffic an two lane highways such as Rt. 23 and Rt. 252 can be clogged by the breakdown of even one vehicle or unfavorable weather conditions. The Schuylkill Express-way routinely has daily peak travel tie-ups. Rt. 202 presently has less volume but traffic and congestion is increasing fast, especially at traffic light bottlenecks in King of Prussia and Norristown.

In the event of a Limerick accident alert, evacuation from within the 10 mile r'dius area would move up or down the river and west or a

east away from -i t . We estimate that movement east or north from the Pottstown area might be possible, as well as west, in the first hour; more likely half hour only. Any movement from the Collegeville area on Rt. 422 toward the Penna. Turnpike east, or Rt. 202 would in half an hour be blocked on this congested, densely built-up, two and three lane highway. Evacuation of the Phoenixville area to the south would not be open because of panic and blockages in Valley Forge Park and the commercial and office and manufacturing concentrations )

at King of Pru.ssia. A part of the Park is within the 10 mile radius.

Visitors would be trapped there and through the whole park. Vehicles attempting to escape from panic- conditions and blockades on the Turn-

. pike, Rt. 202 and the Expressway, and the whole Park / King of Prussia scene would clog the highways north and south along the river and east and west from it.

Evacuation from within much of the 10 mile radius will be cut off via highways of limited capacity north and south and blocked east and west by the massive traffic jams on the expressways, overflowing onto the narrow feeder roads. We therefore conclude there is no way to move more than a small fraction of the people by highway out of l the valley south from Pottstown.

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59.

(LEA-28)

The state, County, municipal, school district and institutional RERP's are deficient in that although the Pa. National Guard is supposed to provide tow wreckers trucks and gasoline along evacuation routes inside the EPZ, the Plan doesn't state where the Guard will find tow trucks, fuel and fuel truck.s or the time needed for National

! Guard to arrive at site considering heavy traffic or adverse weather i

conditions. NUREG 0654 Appendix 4 ChesCo. Draft 6 RERP (J 1 ) sites need for more detailed time analysis. Tow trucks within the EPZ are not readily available, i

-as shown by the deficiencies from sample plans shown on next page.

BASIS:

NUREG 0654, Appendix 4.; NUREC 0654 Criteria C.4 4

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60.

Items Marked TBD (to be determined) and Other Towing Deficiencies based on Sample Plans (LEA-28)

Draft 4 W. Pikeland Township Roadway clearing TBD P* 15 Fuel supplies (Ch. Cty. - Annex K)

TUD

p. 16 Snow and Other Debris:

PennDot - no contracts sited Private Contractor TBD Drdft 4 Borough of Spring City-

p. 15 Snow and Other Debris:

PennDot - no contracts sited Borough of Spring City - there are no letters of agreements, personnel specifically assigned at the municipal level or alternate transportation coordinator if the transportation manager is the person ultimately responsible.

- c.--

Draft 4

p. 15 So. Coventry Township:

All areas TBD

, Draft 4 Charlestown Township-

p. 16 Snow and Other Debris:

Responsibility is left up to an unnamed road master and there is no township building in Charlestown to easily locate this person.

Draft 5 Berks County Plan (K-2-3) a) Roadway Clearing (K-3-1) Only a list exists on file with the Communications Center of towing companies but no definite contracts are confirmed.

1 b) Fuel Resources Mentions lists for outside the EPZ only with no contracts or letter of agreement given. These fuel resources aren't l

definite but if they are to be used the trucks are to be mobilized by the Public Works Department. No ..ention about how the public works office coordinates withThe themunicipal County or other relevant transportation workers.

gas needs are not mentioned in the plan or coordinated with the county's in case of duplication.

Draft 6 Chester County Plan (Annex K) a) Roadway Clearing Pa. National Guard are left responsible for providing towing and gasoline trucks yet the Pa. Department of Transportation is responsible for assisting with the I

clearance of obstacles yet this has to be coordinated by the Public Works Group. No mention of how these functions are to be coordinated.

Many of the boroughs are dependent on PWD for snow r e n:o v a l , such as Spring City, W. Pottsgrove, Boyertown at i .e same time that they are responsible for mobilizing buses.

b) No gas stations listed.

61.

(LEA-29)

The state, county, municipal, school, and institutional plans cannot be relied on or implemented not only because of the failure of any one of its elements but especially because of the combined effect (synergistic effect) of this misfunction of several overloaded systems, (e.g. traffic and roads, communications, emergency worker supply, data retrieval and processing, equipment supply.) The sheer volume of things which are happening causes the plan to fail. More sophisticated technology might help (data processing, interconnected computers, advanced communications) but the technology as presently described in the plans will fail. '

The important point here is that even if theoretically each system could do the intended job, even if just barely, the interconnection of all systems operating at maximum or more than maximum capacity makes it inevitable that the whole system will fail.

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'D.ata processing cap' abilities of tle plans as proposed cannot fulfill the requirements of"(CFR 50 App EG

" provisions to maintain u'p to date",1 CFR 50.47 (b) (8) " adequate facilities and equipment are provided ar.d maintained procedures for notification of public and volunteert'-CIR 50.47 b (5).

BASIS:

10 CFR 50.4 7 (b) (1) , (b) (5) through (b) (8) , (b) (16)

NUREG 0654 I.J. (page 29) i

, (LEA-30) 62.

1 -

The Berks, Montgomery, and Chester Coun?y RERP are inadequate to protect the public with reasonable assurance in that there has been developed no tri-county regional plan as recommended in Nureg 0654 p 19, 20 E (multi-county plan is preferable to state). The i " activating official" as described in the state and local plans

is not, under the present arrangements, "responsibic to the community" (0654 3-15), This is because a governor is not responsible to the evacuated community as such but to state-wide interests i

and concerns often unrelated to the local situation. Furthermore, (Nureg 0654 p 19,20 E) factors of distance and time from Harrisburg to the site geometrically reduce any plans workability and present opportunities for mistakes. There should exist:

1 separately prepared and bound tri-county plan 1 regional EOC (not the off-site utility provided one) 1 integrated c'ommunications system -

1 responsible emergency planner (not 3 independent and county planners) i A) There exists no multi-county co-ordinator or regional co-ordination as recommended in NuReg 0654 1.E example 1., p. 20, which states that "an integrated multi-county level emergency response 3

plan is preferable. The response organizations...can be integrated by mutual agreement into the overall multi-county emergency response plan". PEMA's role does not satisfy this requirement since " state government resources may be too far away to be of much irmediate help for a plume exposure problem in the early hours of an accident."

NuReg 0654 1.E, exampic 1, p. 21. Also " Local government emergency plans should be made a part of the state emergency plan" NuReg 0054 1.E example 1, p. 21, not, as we see it, imposed on, or developed by, l

or substituted for, by some state plan.

I B) The authority of the Montgomery, Chester, and Berks County Commissioners to recommend, but not compel , an evacuation (MontCo.

Draft 5, p. 8, VI A, Chesco) is vague and does not represent an assignment of responsibility or authority to act. Also how can nine commissioners convene in three countics in order to decide these matters in a reasonabic amount of time?

BASIS: NUREG 0654, I.E., example 1

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CERTIFICATE OF SERVICE

.g4 gg _g q7 34 I hereby certify that the foregoing of f-site Emergency; Planning no .w,.-..

Contentions were served upon the following by first cTdssjyphhF postage prepaid, with hand delivery, on January 31, 1984 made to those on the service list beside whose names appears an asterick (*):

• Lawrence Brenner, Chairman (2)

• Ann P . Hodgdon, Esq.

1 Administrative Judge Office of the Executive Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington,. DC ,20555 Washington, DC 20555 jp Benjamin Vogler, Esq.

Office of the Executive Legal Director

• Dr. Richard F. Cole Administrative Judge U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555

• Troy E. Conner, Jr., Esq.

Conner and Wetterhahn

• Dr. Peter A. Morris 1747 Pennsylvania Ave., NW Administrative Judge Washington, DC 20006 i U.S. Nuclear 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 i U.S. Nuclear Regulatory Commission Thoman Gerusky, Director l Washington, DC 20555 Bureau of Radiation Protection, DER 5th 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 Washington, DC 20555 Zori Ferkin, Esq.

Governor's Energy Council P.O. Box 8010 1625 Front St.

Harrisburg, PA 17105 l-

. _ _ . _ _ _ _ _ _ _ . , _ . ~ _ _ _ - , . . _ . _ _ _ , , , _ , _ _ _ _ . _ _ _ _ _ , . , _ . , _ . _ _ _ . _ _ _ _ _ _ _ . . - _ _ - -

i Jay M. Gutierrez, Esq. Robert Sugarman, Esq.

U.S. Nuclear Regulatory Commission Sugarman and Denworth Region 1 Suite 510 631 Park Ave. North American Building King of Prussia, PA 19406 121 S. Broad St.

Phila., PA 19107 Director, PEMA Basement, Transportation David Wersan, Esq.

and Safety Building Assistant Consumer Advocate Office of the Consumer Advocate Harrisburg, PA 17120 1425 Strawberry Square Angus Love, Esq. Harrisburg, PA 17120 101 East Main St.

Norristown, PA 19401 Robert Anthony 103 Vernon Lane Moylan, PA 19065 -

Martha W. Bush, Esq.

Kathryn S. Lewis. Esq.

Solicitor's Office City of Philadelphia Municipal Services Building Phila., PA 19107 Steven Hershey, Esq.

community Legal Services 5219 Chestnut St.

Phila., PA 19139 Marvin I. Lewis 6504 Bradford Terrace Phila., PA 19149 Frank Romano 61 Forest Ave.

Ambler, PA 19002 Joseph H. White,III 15 Ardmore Ave.

Ardmore, PA 19003 (I -

January 31, 1984 PHYLL (S ZITZER