ML20086L327

Responses to Questions Re Offsite Emergency Planning. Reception Ctrs Sole Purpose Is to Serve as pass-through Point.Certificate of Svc Encl

ML20086L327
Person / Time
Site:	Limerick
Issue date:	01/31/1984
From:	Ferkin Z PENNSYLVANIA, COMMONWEALTH OF
To:
Shared Package
ML20086L325	List: ML20086L323 ML20086L327
References
NUDOCS 8402080190
Download: ML20086L327 (15)

Text

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c~ ei'a UNITED STATES OF AMERICA 'C ' ED -5 P2 C5 NUCLEAR REGULATORY COMMISSION

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BEFOREjfHEATOMICSAFETYANDLICENSINGBOARD.

In the Matter of )

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PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352 (Limerick Generating Station, ) 50-353 Unit 1 and 2) )

Responses of the Commonwealth of Pennsylvania to Questions Concerning Offsite Emergency Planning Raised By Limited Appearors, October 17-18, 1983 Ms. Cremers (TR 4676): If an evacuation becomes necessary, individuals designated to use Route 23 would be directed to the Morgan Company in Morgantown. The buildings could not be used because of machinery. As of this morning (October 17, 1983 the 'Morgen Company did not know it is to be used as a reception center.

Response: A reception center is a predesignated site outside the plume exposure pathway EPZ through which evacuees will pass to obtain information and directions to mass care centers. Evacuees are not registered at a reception center and its cole purpose is as a pass-through point to control the assignment of the evacuees to mass care centers. Except for rest room facilities, little use would be required for buildings at the site , and the fact that they ccntain machinery should not be a deterrent.

8402000190 840131 DR ADOCK 05000

Page two Although the reception center at the Morgan Company is within Berks County, it will be used-solely by evacuees 1

from Chester County. The Morgan Company should indeed have known October 17, 1983 that it is to serve as a reception center, since at page T-2-1, Appendix 2, Annex T to the Chester County plan is an August 12, 1983 agreement between its Director of Personnel Safety and Berks County attesting i

to the fact.

Ms. Mulligan (TR 4710): Will Marsh Creek, which is a very large recreational area, be included in the evacuation zone now that its limits have been extended to the turnpike area?

Response: For the area in question, the Pennsylvania Turnpike is the southern boundary of the plume exposure pathway EPZ and at its closest point is more than 12 miles from the Limerick Generating Station. Marsh Creek State Park is a 1,705 acre site in northeentral Chester County approximately two miles west of the Village of Eagle on PA Route 100. In checking with the Bureau of State Parks, Department of Environmental Resources, the Pennsylvania Emergency Management Agency (PEMA) has been advised that I the entire area encompassed by Marsh Creek State park is south of the Turnpike . This places all of the park outside the EPZ and its northern boundary more than 12 miles from the power plant. In reviewing the roadnet within.the Park k.

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Page three it should also be noted that. egress, if necessary, could be accomplished in a southernly direction and without need to enter the Turnpike . Since the park is completely outside

. the EPZ,-its evacuation is not included in the emergency plans.

Mr. Blumenthal (TR 4723-25):

1. It is stated in the West Vincent Township Plan (Chester County) that in the event of a fire in the evacuation zone, that . fire company task force will go into the zone. It is further indicated suitable protection (from radiation) will be turn-out gear and self-contained breathing apparatus.

There are not enough air. bottles in all of eastern Pennsylvania to support a fire fighting task force to drive to a scene, fight a major fire and return from the evacuation zone.

2. The plans indicate that snow removal is to be by local forces and the Pennsylvania Department of Transportation (PennDot). Many of the. townships in our area don't have local forces and PennDot equipment is operated by union employees with restrictions on their hours. Will union employees go from the southern end of Chester County into the evacuation zone and how will they get there over the narrow roads?

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Page four 3 According to the plan, tow trucks are to be hired to remove stalled vehicles from the highway. The plan stipulates that the emergency management coordinator is to have a contract for this service but gives no details as to what the contract should contain.

4. If sheltering is recommended and you are in an autombile, you are told to close the windows and vents.

General Motors has not manufactured a car since 1976 without a. powered positive ventilation system and you can't shut the vents. There is no way to do it.

5. The West Vincent Plan is the same as that for every township in Berks, Montgomery and Chester Counties. It is c xerox copy and the same thing is put in each of them.

Response

1. The State Fire Commissioner's Office , n'.ich is part of PEMA, investigated Mr. Blumenthal's claim with the counties involved. PEMA has been advised that sufficient equipment is available and that there are enough mobile cascade units on rescue vehicles within the area to fill the needed air bottles.

2. Throughout the Commonwealth, snow removal from roads under local jurisdiction is the responsibility of the political subdivision involved. Snow removal is a continuing process which starts with the snowstorm and should not wait until an evacuation is recommended.

PennDOT is only responsible for snow removal on r'oads and

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E Page Five highways under state control. PennDOT does at times contract with political subdivisions for snow removal on state roads ~p assing through the subdivision. The

. municipalities should not and cannot, however, depend upon PennDOT for snow removal from local roads regardless of the natore of the emergency, be it at a nuclear power plant or otherwise.

PennDOT has advised that getting its unionized employees to work extra or different hours to handle snow removal has not been a problem. In cases of heavy storms, emergency maintenance areas from the same, or other PennDOT, districts will be mobilized. But once again, PennD0T's snow removal is a continuing operation that would be underway in such a situation before the evacuation was implemented.

PennDot has no narrow roads under its control and all are passable for snow removal equipment. The question is apparently presented under the assumption that a heavy snowstorm would be coincidental with an evacuation being recommended due to a release of radiation. While perhaps a possibility, the probability is indeed remote. It is thus not a question of unionized employees going into a contaminated area, but rather one of normal ongoing snow removal operations.

3 Whether the township hires them under contract or merely has a written agreement'with tow truck operators for .

Page Six the removal of stalled vehicles from evauation routes is a matter of local option, but definitive arrangements must be made. Neither the state nor the county should dictate to a township the terms to be included in these contracts or agreements. The township emergency management coordinator knows what is to be accomplished and should seek the aid of the township solicitor, if necessary, to determine specific details to be included.

4. Sheltering is a concept to minimize exposure to radiation and closing the windows of an automobile will help to accomplish this. Admittedly, General Motor's cars and some other makes do have a position ventilation system and the vents cannot be closed. If you are in an automobile when sheltering is advised there are, however, two choices to consider. De pend ing upon the reason for being on the road at that particular time, you may wish to change your direction of travel to a point outside the EPZ and away from the source of radiation release. If it is essential to continue travel within the EPZ, then the other option would be to complete the trip as safely, but quickly as possible and seek shelter in a building providing more protection than that available from the automobile.

5. Although there was a basic format followed in the development of the municipal plans, this was to ensure that the same essential points and areas were covered in each plan. This was not meant to, nor should it have, precluded

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tha conditions and circumstances . existing in the respective municipalities from being addressed in the individual plans. I,t'is recognized that a prototype cannot be used indiscriminately for the 42- municipalities without adjustment to these 1ccal conditions. While the format was to be followed, specific information for the respective municipality was also to be included as each plan was developed. PEMA has noted to the counties in its review of the plans that this was not done and asked that corrective actions be taken.

Mc. Boyer (TR 4733): Teachers are expected to stay with children on buses until their parents call for them. Is it reasonable to' expect teachers to do this in view of a competing interested for the safety of there own families?

Response: Since Ms. Boyer is from Pottstown, the response will be based upon the Pottstown School District Plan (Draft 3). In paragraph 8, page 3, the definition of a Host School is stated as " Predetermined schools outside the plume exposure pathway EPZ to which risk students are evacuated, at which they remain under risk senool officials supervision until they are picked up by their parents or legal guardians." While this d;finition is also in the Berks, Chester and Montgomery County plans, it is not in the state plan, nor will it be found in the risk county plans for the other four nuclear power plants within Pennsylvania. It is recognized that risk school teachers

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also have a responsibility to their own families. It has thus been generally understood .that upon arrival at the host schools the children would, as quickly as possible, be placed under the control of host school officials and teachers, thereby enabling the risk school teachers to be relieved- for return to their own families. The decision as to which procedure to follow is , of course , up to the risk and host school superintendents involved. In the interest of ensuring that risk school teachers are available during a most critical time, i.e., the actual evacuation move, PEMA recommends that Berks, Chester and Montgomery Counties and their school districts change their plans to reflect the concept generally accepted by other risk counties and school districts. PEMA's concern over the matter surfaced during its review of the plans and was included in comments sent to the counties.

Mr. Reed (TR 4740): How will the Amish people be notified of an accident at the plant since they do not have telephones?

Response: Although Philadelphia Electric Company (PECO) had originally intended tc use a telephone system to alert the public, its plans have changed since this question was raised. They now plan to install sirens throughout the EPZ as the basic public alert system. PEMA, nevertheless, contacted the National Executive Coordinator ,

Mr. C. Nelson Hostetter, of the Mennonite Disaster Service

Page Nine to determine whether there were any Old Order Amish or Old

-Order Mennonite living within the EPZ. It is only the Old Order that use the horse and buggy and are without  :

telephones or radios. The extent of the EPZ was explained

'to Mr. Hostetter and he advised that while there were some old Order in .the western end of Chester County, there were I

none within the established EPZ. Mr. Reed's question thus becomes moot.

Ms. Dukes (TR 4969-70): The- people in Collegeville at the

! Municipal Building had no idea they were supposed to evacuate to Doylestown.

! Response: According to the transcript, Ms. Dukes' contact at the Municipal Building was "the secretary." Ms.

Dukes ~ reportedly received the in formation about Doylestown from the NRC. All of - Collegeville is within the EPZ and as indicated on the Evacuation Plan Map, published by PEMA and dated June 1983, evacuees from the Borough are to go to the reception center at Willow Grove Industrial Park. This location is also specified in paragraph II. E2d, page 14, Borough of Collegeville Radiological Emergency hesponse Plan, Draft 4, dated October 1983 Information regarding l-this plan should be available from the Emergency Management Coordinator for- the Borough.

Ms. Graham (TR 4994): When I talked to the coordinator about the geriatric center, he was not able to tell me that l

there;was an agreement between his office and the host

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Page Ten facilities. One would be the Philadelphia State Hospital.

Another would be Nashamana Manor. And he was not able to tell me that there was a written agreement so that we would know there was a viable place for the patients to be taken to.

Response: It is difficult to determine from the transcript which coordinator Ms. Graham contacted, but presumably it was the county office. The Center in question is the Montgomery County Geriatric and Rehabilitation Center in Ro yersford . As indicated on page G-3-2 of the Montgomery County plan, the host facilities for the Center are to be Neshaming Manor (Nashamana is incorrect spelling), the Philadelphia State Hospital and Cedarbrook, which is the Lehigh County .Home . It is also stated on page .T-2 of the plan that " Agreements, as developed, are maintained on file at the Montgomery OEP Office and will be included in subsequent drafts." Draft 2 of the Radiological Emergenc y Response Plan for the Mongomery County Geriatric and Rehabilitation Center contains a written agreement dated September 7, 1983 with the Philadelphia State Hospital and one dated May 18, 1983 with Cedarbrook. The agreement with Neshaming Manor is under development.

Ms. Hoos (TR 5008): I also would like to bring to your attention that in our area we have the Geriatric Center, which was mentioned before. There are at least two

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a which was mentioned be fo re . There are at least two hospitals. There-are several nursing homes. There is a i state prison. And we also have Pennhurst.

Response: The question regarding the Mongomery County Geriatric and Rehabilitation Center was addressed in the response. to Ms. Graham. Plans for the hospitals and nursing homes have been developed by Energy Consultants, Inc. (ECI) under contract to PECO and have been made available to the intervenors by the applicant. The Board has specifically requested the Commonwealth not to respond to the question relative to the State Prison at Graterford

' (TR 5030). A response plan for the Pennhurst Center has been developed by- the Pennsylvania Department of Public Welfare in conjunction with PEMA. Copies will shortly be provided to the Board and intervenors, as well as FEMA.

Mr. Ortiz ~(TR 5017-18): What provisions have been made in emergency planning for persons who do not understand or speak English with sufficient fluency and must depend upon l-the Spanish language?

Response: PEMA discussed this matter with ECI to determine what action PECO had taken and what they additionally planned to do. PECO has conducted a public survey to identify those individuals within the EPZ with impaired hearing and those requiring ambulance or other medical support, as wall as those needing transportation assistance in the event evacuation becomes necessary.

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Page Twelve Althou6h PECO has now had the survey questionnaire translated into Spanish, they have not as yet been able to develop a feasible method for ensuring its distribution to the Spanish-speaking population within the EPZ. PEMA has been advised that FECO is also agreeable to publishing the required Emergency Information Brochure in Spanish as well as English . Additionally the EBS announcements to be used

- by the risk counties in the event of an accident at the plant will similarly be recorded, as necessary, in both English and Spanish.

Respectfully submitted ,

, ,/

I Zori Ferkin Assistant Counsel Commonwealth of Pennsylvania Date: January 31, 1984 l

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y .1 4 UNITED S'T'ATES.0F AMERICA j NUCLEAR REGULATORY COMMISSION i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 6 ,

In the Matter of ) .

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PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

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50-353

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(Limerick Generating Station, )

Units loand 2)

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CERTIFICATE OF SLRVICE

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I hereby certify th(t copies of "3ESPONSE OF THE COMMONWEALTH OF PENNSYLVANIA" in the abov'e'-captionoa? proceedinghave been served on the following by deposit in -the United States mail, first class, or, as indicated by an asterisk through deposit in the Commonwealth of Pennsylvania's= internal maib system, this 31st day of January 1984:

v Lawrence Brenner (2)'I , Docketing and Service Section Administrative' Judge. ,

Office of the Secretary Atomic Safety and Licensing U. S. Nuclear Regulatory Board

s. Commission U. 5. Nuclear' Regulatory' .' Washington, D.C. 20555 Commission- '.

Washington, D.C. 20555 4

Richard F. Cole Mark J. Wetterhahn, Esq.

Administrative Judg2 - Conner and Wetterhahn Atomic Safety cnd Licensin'g 1747 Pennsylvania Avenue, N.W.

Board Washington, D.C. 20006 U. S. Nucl. ear Regulatory Commission ~ Atomic Safety and Licensing

~ Washington, D.C. 20555.' Board Panel U. S. Nuclear Regulatory Commission 20555 Washington, D.C.

' Ann P. Hodgdon, Esq.

Peter A. Morris Benjamin H. Vogler, Esq.

Administrative ~Jud6s Atomic Safety and Licensing ,

Counsel for NRC Staff Office of the Executive Legal U. S. Nuclear Regulatory Commission Director Washington, D.C.

20555 U. S. Nuclear Regulatory Commission Washington, D.C; 2.0555

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- .________L: .___Y_____ _

l Atomic Safety and Licensing Philadelphia Electric Company Appeal Panel ATTN: Edward G. Bauer, Jr.

l U. S. Nuclear Regulatory Vice President &

Commission General Counsel Washington, D.C. 20555 2301 Market Street Philadelphia, Pa. 19101 Frank R. Romano # David Wersan, Esq.

61 Forest Avenue Assistant Consumer Advocate Ambler, Pa. 19002 office of Consumer Advocate 1425 Strawberry Square Harrisburg, Pa. 17120 Robert L. Anthony Steven P. Hershey, Esq.

Friends of the Earth of Community Legal Services, Inc.

the Delawa , Valley Law Center West P. O. Box 186 5219 Chestnut Street 103 Vernon Lane Philadelphia, Pa. 19139 Moylan, Pa. 19065 Marvin I. Lewis Angus Love, Esq.

6504 Brad ford Terrace 101 East Main Street Philadelphia, Pa. 19107 Norristown, Pa. 19104 Judith A. Dorsey, Esq. Joseph H. White, III 1315 Walnut Street 15 Ardmore Avenue Suite 1632 Ardmore, Pa. 19003 Philadelphia, Pa ._ 19107 Charles W. Elliott, Esq. Robert J. Sugarman, Esq.

Brose and Postwistilo Sugarman & Denworth 1101 Building Suite 510, North American Bldg.

11th & Northampton Sts. 121 South Broad Street Easton, Pa. 18042 Philadelphia, Pa. 19107 Jacqueline I. Ruttenberg # Director, Pennsylvania Keystone Alliance Emergency Management Agency 3700 Chestnut Street B-151, Transportation and Philadelphia, Pa. 19104 Safety Building Harrisburg, Pa. 17120

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1. Thomas Gerusky, Director -

Martha W. Bush, Esq.

Bureau of Radiation Kathryn S. Lewis , Esq.

Protection City of Philadelphia Department of Environmental Municipal Services Bldg.

Resources 15th and JFK Blvd.

5th Floor , Fulton Bank Bldg . Philadelphia, Pa. 19107 Third and Locust Streets Harrisburg, Pa. 17120 Spence W. Perr y , Esq.

Associate General Counsel

. Federal Emergency Management

. Jay M. Gutierrez, Esq. Agency U. S. Nuclear Regulatory 500 C Street, S.W., Rm. 840 Commission Washington, D.C. 20472 Region I 631 Park Avenue King of Prussia, Pa. 19406 7

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' Zori G. Ferkin '

3' Assistant Counsel Governor's Energy Council Date: dc.,w m 3l (q W 4

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