ML20084B968

Status Rept on City of Philadelphia Issues of Concern Re Emergency Planning.Considerable Progress Made Toward Resolution of Issues Although Certain Items Still Remain Open

ML20084B968
Person / Time
Site:	Limerick
Issue date:	04/23/1984
From:	Bush M, Smolen H PHILADELPHIA, PA
To:
References
NUDOCS 8404260494
Download: ML20084B968 (9)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION hCED ATOMIC SAFETY AND LICENSING BOARD h APR 25 s a BEFORE ADMINISTRATIVE JUDGES g E 0 .T;pm..

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Lawrence Brenner, Chairman Dr. Richard F. Cole ('

• Dr. Peter A. Morris In the Matter of  : Docket Nos. 50-352-OL 50-353-OL PHILADELPHIA ELECTRIC COMPANY  :

(Limerick Generating Station,  : April 23, 1984 Units 1 and 2)

CITY OF PHILADELPHIA's STATUS REPORT ON ITS ISSUES OF CONCERN IN THE AREA OF EMERGENCY PLANNING w.

Pursuant to the direction of this Board, the City of Philadelphia

(" City") hereby submits the following report as to the status of its Issues of Concern pertaining to emergency planning associated with the licensing of the Limerick Nuclear Generating Station, Units 1 and 2.

Representatives of the Commonwealth of Pennsylvania (" Commonwealth" or

" State")~and the City have conferred and met on numerous occasions. The last ineeting took place on April 11, 1984. In addition, other conferences have been held among the City, Commonwealth and Philadelphia Electric Company ("PEC0").

s This process of negotiation and discussion has been productive, useful, and informative. Many issues have been resolved--some through adoption by the Commonwealth of new aspects to the Emergency Plan, some~through withdrawal of theissuesinitiallyfiledb[theCityandsomethroughincreasedunderstanding by the City of the issues Not all issues, however, have been resolved as of

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this date. The City is hopeful that conti.nuing discussions and the development I

l t 0 of additional information will lead to teiointion of most if not all of these "

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concerns. The following is a summary of the current st'atus ef Philadelphia's i issues of concern. , 2 l -

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City-1 This issue of concern relates to guidance to,the County for 9 l > ,

effectuation of sampling tnd profision of information as well as assistance in

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controi<of contaminated watergnd food.

A. With respect to the sampling 4f vetep, the Commonwealth has agreed to i s' '

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analyze.for radioactivity, two sam 3N s pi.r month from the City's Belmont Plant.

r This analysis will be of: ,

I s (1) river silt settling in the paw water basin, and E.

1, (2) 'chemicall enhanced ~- di'dge from se';tling tanks. ,.

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• l The'se testq ,will be in 6ddition torthe, existing on going State-to-City test . ,

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!* . reporting procedures. For additiocol discussion see City-3, infra. .-

< < i g With respect'to the/sampitng and control of food and agricultural s 4 B.

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products, on April 11, ,108/7 , the C,oneonwealth provided the City with the gj .r , y ,

r Department of Agricultarg'}s Plin.fdrjuriew lG and consideration. This review is

< ' ." J r not yet conglete. Ig' r,ddition, ttgCommonwealth has indicated that it will s

< q,. s incorporate into the State Plan, thd following; procedure:

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< '. +t e(1) The Bureau of Radiation Protection of the Commonwealth of

.NPennsylvacia will initially describe the ard of possible food contamination in I, ,/ the ing;estion expohure pathway. #

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y o 7 (2) Notlfication of such determination will be given by Pennsylvania

'd Emergency Management Agency ("PEMA") to the' Philadelphia Office of Emergency

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+ (3) De Commonwealth (PE'27 will fm:orporate into the state' plan, county plans, and olpe;ating procedutes for 'spt.e police that personnel manning

, access control'p61nts surroundiug }(lum _e expo'sure. pathway EPZ will stop all open trucks containidg. raw agricultural gr6 ducts from leaving the plume EPZ. State personnel will contact the StateA gr(cultural Department which will sample produces for radioactivity and dispose of products in accordance with , , . , -

established State and Ag'dicult'ure Dr.partment plans. # -

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(4) The items on such open trucks will be sampled and tested, and only if found to be uncontaminated, will be pefmitted to pass.

(5) With respect to sampling, testing, reporting, confiscation of iood products in Philadelphia, the Commonwealth has represented that it has only approximately 15 food inspectors to perform this function, at the food processor level, and that it expects that the City will use its complement of food inspec-to-s to perform the same function. An additional matter pertains to unprocessed food in the open air markets in Philadelphia. The final determination on these matters is still under consideration and further discussions are to be had. See City-8 for discu.ssion of training in this area.

City-2 This issue of concern deals with the resources available at the County (Philadelphia) level to assist the State in implementing controls on foods, foodstuffs and water. State action at Access Control Points and State food inspectors, and what the City is being requested to do, is discussed under City-1 and is still under consideration. For water-related control see City-3.

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! City-3 This issue of concern relates to sampling and notification associated (i i with water contamination as well as (a) protection of supplies, (b) prevention l

of use of contaminated water and (c) alternative sources of water.

As described in City-1, the Commonwealth will perform two tests for the

', City in addition to the existing State-to-City test reporting procedures. The

@ Commonwealth has also represented to the City that both air and water g, y surveillance, monitoring, analyses and reporting will be done by the Bureau of

~{ Radiation Protection of the Department af Environmental Resources of the

y Commonwealth.

I (a) On going sampling applies to routine. releases from the plant.

Routine sampling and analyses will be continued by the Bureau of Radiation Protection (and PECO). The "in place" system will remain with regular reports

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(b) The Bureau of Radiation Protection will confer with the City's.

b Water Department. officials to arrive at a definition of a "non-routine" liquid discharge. If there is a "non-routine" discharge into the Schuylkill River, the

Commonwealth of Pennsylvania (PEMA) will notify the Philadelphia Office of Emergency Preparedness. The Bureau of Radiation Protection will sample, analyze and report contamination levels to the City Water Department expeditiously. The Commonwealth has represented to the City that the Commonwealth does have sufficient resources to perform the required tracking analysis from Limerick to the City's Water intakes and through to the taps, and, to report the results of analysis expeditiously. The tracking and time of reporting of analysis results will be evaluated by the City at the time of the July 25, 1984 exercise.

(c) Subsequent to any such "non-routine" liquid discharge, ad-hoc health physics judgments will be made as to when to relax the procedures.

(d) The Pennsylvania Bureau of Radiation Prot--+ ion is drafting a procedure, " Estimation of Liquid Release Consequences to Jownstream Water i Users." This procedure will contain the bases for decisions concerning the intake closing for downstream water users as will.the calculation method for estimating downstream concentrations. The radioactive isotopes which Department of Environmental Resources measures in river water are trituim, Ma-54, Fe-59, Co-58, Co-60, 2n-65, ZrNe-95, I-131, Cs-124, Cs-137, and BaLa-140. The City will review this material when it is received and is reviewing the list of radioactive isotopes measured.

(e) The City has requested a water transport model to be able to predict the impact on Philadelphia's water supply of any "non-routine" liquid discharge and contaminants from precipitation after an accident on Philadelphia's water supply so as to determine what emergency measures may be required. This issue of concern remains unresolved. PEMA is to request PECO to supply the model and will also arrange a conference with PECO, the City, and appropriate state agencies regarding this item.

(f) The issue of concern relating to alternate sources of water has not been resolved. One alternative being discussed is reliance on surrounding communities. PEMA has agreed to arrange a meeting with the Pennsylvania Department of Environmental Resources, the City, and bordering communities to discuss this matter. Another planning issue is development by the City of an conservation plan appropriate to severe accident conditions.

With respect to notification, the' Commonwealth has represented that it will incorporate the following procedure in its plan.

l (a) In-the event of an " unusual. event" as-defined by NRC procedures I

or any other (less severe) public notification circumstance (to be determined by PEMA),. P120L will first notify the Philadelphia Office of Emergency Preparedness which will then. institute "in-City" notification procedures.

.(b) If there has been some spill or release into the Schuylkill River, then in addition to notification, PEMA will also supply the name and telephone' number of the responsible Pennsylvania Bureau of Radiation-Protection official to the Philadelphia 0ffice of Emergency Preparedness so that direct communications can be established.

(c) If there is a " site'energency" or " general emergency" the City's Water Department and Health Department officials-are to be represented at PECO's

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I t-Emergency Operating Facility. (This is now pending a written confirmation

. letter agreement from PECO).

In addition, the Commonwealth has represented that it will cause the ,

Bureau of Radiation Protection to provide to the City a list of water and air l

l contaminants of concern; whereupon the City will assess its. capability to analyze same, and then will make a determination whether additional equipment is

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required. Finally, the Commonwealth will ascertain what equipment, if any, has been provided from any source with regard to emergency planning for any other Pennsylvania nuclear facility. (See City-12 for additional discussion J.

concerning water and air contaminant measurements.)

3 City-4 This concern relates to the sampling, testing and reporting of contamination of aquatic life in the food chain. The Commonwealth has repre-sented that the Pennsylvania Fish Commission.will sample, test and report on the

, status of aquatic life subsequent to a radiological incident. The City, 5

however, remains concerned about the effects on aquatic life as a result of

. routine discharges into the.Schuylkill over a period of time, as well as "non-routine" releases. 'Accordingly,.the issue of testing only.after a

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radiological ~ incident is of continuing concern to the City. It is' anticipated.

that further discussions will be conducted on this issue.

i l City-S This item relates'to the City's concern regarding medical and other; protective measures. .The. Commonwealth has represented to the City that the list

, oof support hospitals in Philadelphia to treat radiological cases has been-reduced.from 32 to 22. The issue as to whether the hospitals are equippedLto handle'these needs and'whether the State should obtain specific agreements for

.these hospitals and medical services remains open. The necessity.for any other protective measures is under review by the. City.

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City-6 This issue of concern deals with the prevention of distribution and consumption of contaminated processed food. This issue is discussed under City-1(B)(5) and is still under consideration with further discussions to be had.

City-7 This issue of concern relates to relaxation of protective actions and recovery.

With respect to relaxation of protective actions concerning air and water surveillance, monitoring and analyses following an incident, ad-hoc health physics judgments will be made. As to processed food, this is more fully discussed under City-1(B)(5) and further consideration is to be given to that c

matter.

The Commonwealth represented that the Pennsylvania Department of

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Environmental Resources will provide to the City Water Department, references and recommended procedures te remove levels of radioactive contamination in a conventional water treatment plant, such as Philadelphia's. Upon receipt this material will be reviewed and analyzed by the City.

City-8 This issue of concern deals with training of personnel, exercise and drills. The Commonwealth has represented:

(a) that monitoring of the water system will be included in the July 1984 test; (b) that the Commonwealth will provide all the monitoring services required to do the tracking from Limerick to the City water intakes and at the taps and well as testing thereof.

If deficiencies in the monitoring system are discovered in the July 1984 test or thereafter, appropriate modifications in the monitoring system will be discussed.

The Commonwealth has also represented that it will coordinate the administration of the following training to designated personnel of the City.

(a) By Bureau of Radiation Protection ("BRP"): an understanding of radioactive terminology, measurement and analysis and applicable water quality standards. There exists the need to know what type of radioactive emissions can be discharged from the Limerick Plant, what type of analysis is necessary to determine their concentrations and how to interpret the water quality data.

(b) By BRP: an understanding of the predictive models and assessment of time of travel and resultant contaminant concentrations in Philadelphia as caused by an incident at Limerick. It is the City's understanding that PECO has employed a computer model to assess the impact of an incident at Limerick upon water quality downstream in the Schuylkill River. The City requires an under-standing of.that model.

(c) By BPR: an understanding of the plan of action regarding the monitoring of the water quality resulting from an event, as well as the method of communication and projected delay in receipt of water quality data.

(d) PEMA has agreed to obtain PECO's consent that the City personnel will be permitted to attend PECO's training sessions, or, if PECO does not so agree, that PEMA or BRP will give the following training: an understanding of the methods of operation of the EOF at Plymouth Meeting and the on-site assess-ments groups, as they relate to water quality. The City needs to understand exactly how it is to interface with the above-mentioned groups. The City has requested that PEMA and PECO coordinate their efforts in order to provide this training program.

(e) By BPR: an understanding of the plan of action regarding trans-

. mission.of incidents and water quality data to the press.

(f) Training for City Health Department officials in interpretation of data from air quality samples with regard to radiological releases shall be provided either by. PECO, in conjunction with existing plans for training of state officials or by the State following the State's receipt of training from PECO.

The matter of training City personnel to inspect and control food products is subject to future discussions.

City-9 The City is without knowledge as to the status of the written agree-ments specified in NUREG-0654 Section II A (3) referring to-the concept of operations developed between Federal, State, and. local agencies and oth'r e support organizations having an emergency response role within the Emergency Planning Zones, and therefore is of continuing concern to the City.

.' 1 City-10 Withdrawn.

City-11 Withdrawn.

City-12 This issue of concern relates to protective actions for exposure from foodstuffs and water some of which have been previously discussed. It also concerns short and long term protective action guidance from airborne radioactive contaminants deposited on ground, property and equipment, and includes the effects on people, water and food by ingestion and inhalation under various climatic conditions, wind patterns and soil run-off (of water) scenarios. To a large extent, emergency planning (protective actions) relating to this issue of concern requires a more detailed analysis than the State indicates it has available. The City is in the process of conducting an analysis which will assist the City in assessing emergency planning concerns in a spectrum of situations. This analysis is expected to be completed shortly at which time further discussions and conferences will be conducted.

As can be seen from the foregoing status report, considerable progress has been made toward resolution of the City's issues of concern although certain 1

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-d items still remain open for further consideration. The negotiation process is continuing with all parties participating in a cooperative mutual effort.

Respectfully submitted, h

HERBERT SM0LEN Deputy City Solicitor A. 6 MARTHA W. BUSH Deputy City Solicitor BARBARA W. MATHER City Solicitor Dated: , April 23, 1984 4

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