ML20086R941

Reply to Applicant & Staff Responses to City of Philadelphia Issues Re Emergency Response Plan.State Plan Does Not Contain & Is Not Based Upon Standardized Protective Action Guidance for Exposure from Feedstuffs & Water

ML20086R941
Person / Time
Site:	Limerick
Issue date:	02/28/1984
From:	Smolen H PHILADELPHIA, PA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20086R937	List: ML20086R935 ML20086R941
References
ISSUANCES-OL, NUDOCS 8403010275
Download: ML20086R941 (43)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES Lawrence Brenner, Chairman Dr. Richard F. Cole Dr. Peter A. Morris In the Matter of  : Docket Nos. 50-352 OL 50-353-OL

.PHILAnELPHIA ELECTRIC COMPANY.  :

.(Limerick Generating Station,  :

Units 1 and 2)

REPLY OF CITY OF PHILADELPHIA TO RESPONSES OF APPLICANT AND STAFF TO CITY OF PHILADELPHIA ISSUES The City of. Philadelphia hereby files its Reply to the Answer of Applicant filed February 13, 1984 and to the Response by the Staff of the Nuclear Regulatory Commission filed I.:bruary 24, 1984 to the revised Issues of Concern of the City of Philadelphia.

Preliminarily, it should be noted that PECO erroneously argues that "the sole responsibility of the' Commission and its licensing boards is to determine whether these- plans :are capable of being implemented" (Applicant's Answer at p. 4.) .To the contrary, as.a matter of law, there is a dual standard of review: whether the plans are adequate and whether there is reasonable assurance that they can~and will be implemented. An analysis of implementability without a consideration of adequacy would be a meaningless exercise by this Board. The thrust of the City's concerns is that.the lack of.

. detail presented in the State Plan renders that Plan both inadequate and

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incapable of implementation.

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- City-1: Applicant and Staff incorrectly argue that NUREG-0654 does not require the degree of specificity which the City has sought in City -1. Applicant further argues, without foundation, that NUREG-0654 does not require public information availability, that nothing in NUREG-0654 requires identification of the type, number or availability of personnel to implement the particular protection procedures outlined in NUREG-0654,Section II, Criterion J.11.

Applicant conspicuously ignores the standard set forth in 10 CFR 50.47(a)(2) that State and local' emergency plans be adequate and that there be reasonable assurance that-they can be implemented. 10 CFR 50.47(b)(10) specifically imposes, inter alia, the requirement, that

"... protection actions for the ingestion exposure pathway EPZ-appropriate to the locale have been developed." (Ersphasis supplied. ) -

Finally, 10 CFR 50.47(c)(2). states that "The plans for the ingestion pathway shall focus on such actions as are appropriate to protect the food ingestion pathway."

Applicant and Staff further overlook the planning standards set forth

.in NUREG-0654,Section II.A at pp. 31 et seq., which require, inter alia, that each Plan provide for the assignment of responsibilities for emergency response by the nuclear facility-licensee and by the State and local organizations within the Emergency Planning Zones, and further that "...the emergency responsibilities of the various supporting organizations have been established, and each principal response organization hos staff te respond and to augument its initial response on a continuous basis." (Emphasis supplied.)

.It can thus be seen that NUREG-0654 clearly requires emergency

' planning in both the plume and ingestion EP2s, and that each principal response

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organization specificallyLidentify by title the necessary response staff.

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Accordingly,.considering the nature of-the Ingestion Exposure Pathway EPZ, which

. . includes . the City of -Philadelphia, it is entirely ~ appropriate, and NUREG-0654 requires, that the Board make certain that the pacticular State response  ;

agencies-involve'd here have sufficient staff to respond and to augument its initial' response on a. continuous-basis.

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-It is enlightening to note that with regard to the. sufficiency and

adequacy-of staffing,. Applicant' cavalierly' states, "If need be, personnel could be brought into the a'ffected area from neighboring States as well as federal

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t agencies." It is submitted that-it is precisely this vague and haphazard approach to' planning which the Regulations and NUREG-0634 seek to avoid. That i

protective. action'may not need:to be as immediate in the Ingestion Exposure

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" Pathway as in.the Plume. Exposure Pathway does not mean that absence of adequate

_. Lstaffing and planning-is-condoned by the applicable regulations,..as Applicant would have the Board find.

Applicant'further incorrectly. suggests that there are no requirements in NUREG-0654 mandating t the availability of public infocmation. On the contrary, NUREG-0654,.Section D, F. Emergency Communication Paragraphs 1 and IB at p.'4,7, require, inter alia,fthat'the' communication. plans'for emergencies shall include organizational . titles ' and alternates for both ends of the communication links; thatieach organizatica establish reliable primary and

. backup 'meank of: communication for' licensee, local and State response organizations: dhat such systems be compatible with one another; and that each plan.shall inclu'de '" provision.for communications with contiguous State / local

~ .governmentsiwithin the Emergency Planning Zones," '(Emphasis on plurality cf LZones supplied.). The State Plans do not contain such systems as required by

. [NUREG-0654,Eandtherefore)isalegitimateissueofconcernto'the-City'of-Philadelphia.. ,

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. City-2: : Applicant and Staff similarly criticize City-2 by arguing that NUREG-0654-does not. require more than mere identification of procedures, and in particular, Applicant' states that,_" manpower and capability levels need not be stated because it'can be rationally assumed that, in the event of a radiological emergency, such resources can be promptly marsballed." This response again 7

Ldemonstrates an emergency planning attitude by Applicant of " Don't worry, you o

can trust us. We'll deal with it on an ad hoc basis when the situation arises."

This cannot be sufficient under the law. As stated above, NUREG-OoS4,Section II.A. at pp. I 1 3 et seq., clearly requires assurances of adequate staffing of

- responce organizations in both planning zones. NUREG-0654 at pp. 40-41 is not limited solely to the Plume-Exposure Pathway in dealing with emergency responses

' support and resources, but requires that arrangements for requesting and_using assistance' resources have been made and other organizations capable of-

-augmenting the planned response have been identified. The emergency plans must 7

Int specific.in this planning area and each offsite organization, including the State, must identify facilities, organizations or iadividuals which can be relied upon in'an emergency;to provide assistance. By reason of the fact that

' the' State Plan! fails to provide for the foregoing, this issuc is a legitimate concern to the City.

7 sCity-3: The City's concern here is that the State plan does not provide

, guidance 'for, protecting water from contamination.and preventing use. Staff "E ~ 1 agrees that this concern should be an issue in the case. Applicant alleges that there_is no basis under NUREG-0654for inclusion of this issue. NUREG-0654,

.Section II, J. 11 at p. 64, provides that c Each State shall specify the protective measures

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to be used for the ingestion pathway, including the methods for protecting.the public from i

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p consumption of. contaminated foodstuffs. This

! 'sha11' include . criteria for. deciding whether dairy -

Lanimals_should-be put on stored feed.' The-

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plan shall-indentify procedures for detecting

, contamination, for estimating the dose commitment  ;

consequences of uncontrolled ingestion, and  ;

for imposing protection procedures such as impoundment,-decontamination, processing, decay, product diversion and preservation. (Emphasis

,s _ supplied. ) .

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~ Thus,'this'Section of NUREG-0654, specifically requires that the State

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- plan ". . .shall identify procedures. . .for imposing protection procedures". The '

Jpresent Plan is_ inadequate in this regard especially with respect to

= impoundment and diversion (prevention of use), decontamination (recovery) and

preservation.~(protection of existing. supply).

. Applicant asserts'at p. 60:of its Answer:that under:UREG-0654 the

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, N f protective responses are' required 'only for detection purposes, and need not s- ' address-the measures-suggested by the City. This assertion is patently wrong.

r JTo.the~ contrary, protection off existing supplies and prevention of use of

. cont ainated. water and recovery by.waylof decontamination are specific goals of-e NUREG-0654. Herely.'by l'isting the? planned protection measures without identifying the meansiofLisplementation of.those measures does not meet the requirement of NUREG-0654,?Section II, J.~11.

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As .more fully ^ set forth

-hereinafter.in City-6'at p. 8 and.9,rThe Manual of Protective Action Guides and Protective Actions for Nuclear' Incidents, '(hereinafter "PAGs"), at pages 1.30, 1.'46,71.47 7 and;1.48 specifically concerns itself.with protection of existing water supplies:by prevention of contamination as well as providing for s

Jalternative- sources of 'wat'er. ?InLthis case, the-State.. plan does not' identify L Lthe- procedures for such . implementation and- thus - is 'a legitimate area lof concern Lto the~ City.

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s-City-4: 'The concern of the City here is that the State plan fails to specifically include sampling, testing and reporting contamination of aquatic life in' the food chain. Staff does not object to the Board's consideration of this issue, but the Applicant objects, arguing that City-4 is vague and lacking

.in specificity. Nothing could be more specific: the State Plan fails to provide 'for aquatic sampling, testing and reporting concerning fish which are part of the local food chain. NUREG-0654,Section I, D at pp. 9-11 specifically provides

b. Irigestion exposure pathway -- The principal exposure from this pathway would be from ingestion

.of contaminated water or foods such as milk, fresh vegetables or aquatic foodstuffs. The duration of potential exposure could rans e in length from hours to months. For the ingestion exposure pathway, the planning effort involves the identi-fication of major exposure pathways from contaminated food and the associated control and interdiction points and methods. (Emphasis supplied.)

Since NUREG-0654 contemplates that State, rather than local, response organizations will be principally responsible for the planning associated with the ingestion exposure pathway, the failure of the-State Plan to adequately address this issue is a matterLof _ legitimate concern to the City of Philadelphia.

City-5: Staff and' Applicant assert that this issue of concern lacks specificity and goes beyond' Commission Regulations. However, NUREG-0654, SI, D. 4. at'pp.

14 et seq. specifically recognizes that for atmospheric releases from nuclear power facilities: three dominant exposure modes exist:

(a).whole. body (bone marrow) exposure from

. external gamma radiation and from ingestion of rajioactive material; (b) thryoid exposure from inhalation or

'-ingestion of-radioidines; and E_

(c). exposure of other organs (e.g., lung) from inhalation or' ingestion of radioactive materials.

(Emphasis supplied.)

Moreover, as stated in NUREG-0654 at p. 6, The overall objective of emergency response plans issto provide dose-saving's (and in some~ cases immediate life saving)- for a spectrum of accident that-could produce offsite doses in excess of Protective Action Guides (PAGs). (Footnote omitted.).

Applicant' incorrectly assumes that the City's concern is limited to

1. the' distribution and administration of KI, and Staff asserts that the City's

.' issue lacks specificity. The City concerns are, in fact, broader and very

specific. NUREG-0654; Section-II, L.~ Medical and Public Health Support at p. 69 1 requires-that the State plan contain specific' arrangements for local and backup '

. hospital'and medical services, including assurance that persons providing these

. services are adequately prepared. .This Planning Standard is not specifically s

- limited under NUREG-0654,Section II,.L. to the-Plume Exposure Pathway, and therefore'aust be addressed in.the StateLPlan for the Ingestion' Exposure i

l Pathway.: The failure of -the State Plan to provide other protective measures to prevent ingestion exposure to the' thyroid, wnole: body, and' bone marrow are

._ discussed-in the other City concerns'1 through 12 and in this Reply. Other

- specific pre-exposure protective measures are more' fully. described.in City-6 of thisRep1y,-atpages7-9. 'Such other measures include, but are not limited to,

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designation of critical users'of water'and. substitution-of beverages. -(PAGs,

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-.pages 71.'47 'and .1.48) 1[n this fregard, the State' Flan fails to meet the y cNUREG-0654 requirements,;and is allegitimate' matter of concern to the City.

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F City-6: The City contends:that the State Plan fails to provide reasonable or

adequate guidelines,-methods and procedures for preventing the distribution and consumption of contaminated' processed food. Applicant, has merely responded that thc present guidelines ~are adequate and Staff asserts a lack of specificity. However, NUREG-0654,Section II, J, 9. at p. 61 provides that Each State'and local organization shall establish a' capability for implementing protective measures based upon protective action guides and other

. criteria. This shall be consistent with the recommendation of...DHEW (DHHS)/FDA regarding radioactive contamination of human food and animal feeds as published in the Federal Register of December 15, 1978 (43 FR 58790). (Emphasis supplied.)

The present Plan simply does not establish a capability for

, implementing protective measures based upon protective action guides as required by NUREG-0654,Section II', J,.9.

Moreo'ver,Section II,EJ. 11 at p. 64 of NUREG-0654 specifically provides-Each State shall specify the protective measures to be used for the ingestion pathway, including the' methods for protecting the public from consumption of contaminated foodstuffs. -This shall included criteria-for deciding whether dairy animals should be put on stored feed. The

~ plan shall identify procedures for detecting contamination, for estimating the-dose commitment consequences of uncontrolled ingestion, and for imposing protection procedures such as impound-ment, decontamination processing, dairy, product uiversion and preservation. (Emphasis supplied.)

The State Plan, with respect to the Ingestion Exposure Pathway, also ,

fails to finclude' criteria for de'ciding whether-dairy animals should be placed on stored feed. 'The State Plan does not identify as it must, the procedures, for cimposing protection measures. .A. mere listing of the protective measures availab'le does not meet the requirement of specifically identifying the

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procedures to impose protective measures. A mere issuance of an advisory to food-processors 'in no way assures th:t contaminated foodstuffs will not be introduced'into the food chain.

To be legally adequate, the Plan must be based upon the protective action guides mentioned in NUREG-0654,Section II, J. 9 at page 61 and at page 6,' footnote 3 of NUREG-0654. These guides are set forth with specificity in the

'PAGs atlpage 1.30 and recommend suggested. action to be taken in the Ingestion d

Exposure Pathway as follows:

Approximate Initiation Exposure Pathway. Action to be Initiated Time.

'4-48~ hours- ' milk take cows off pasture, prevent cows from drinking surface water, quarantine contaminated milk.

harvested fruits and wash all produce, or impound vegtables produce.

drinking water cut off contaminated supplies, substitute from other sources.

unharvested produce delay harvest until approved.

14-days harvested produca substitute uncontaminated produce.

milk discard or divert to stored products,'such as cheese, drinking water filter, demineralize.

, e Morever, the PAGs at page'1.46 provide that in order to avoid population contamination from ingestion exposure, the response planner should

. with respect to food ' control, consider:

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(1) Pro'ibition a on use and substitution from uncontaminated supplies;.

(2) Decontamination; (3) -Impoundment, storage and allowance for decay of radiation levels; and (4) Destruction to prevent consumption.

As to water. control, the PAGs at pages 1.47 and 1.48 provide that the planner consider protective actions to:

(1) Prevent contamination; (2) Decontaminate water; (3) Condemn of use'of water for consumption; (4) Provide alternative sources; (5) Ration supplies; (6) Substitu:e other beverages';

(7)' Import water from other uncontaminated areas; and

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(8) Designate critical users.

It is clear from these guidelines, that the State Plan is inadequate in not establishing a capability for ' implementing protective measures and in not establishing criteria for imposing protective measures consistent with and based upon the PAGs. The City is legitimately concerned that these matters are addressed in the final Plan.

City-7: The Plan provides no guidance for recovery or relaxation of protective

- actions in the Ingestion Exposure Pathway. Applicant and Staff erroneously argue that this concern is misplaced based upon their too narrow interpretation 3

of " recovery" and their view that, such planning need only involve the Plume e

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Exposure Pathway. It is submitted that nothing contained in 10 CFR $

50.47(b)(13) relieves a recovery planning responsibility in the Ingestion Exposure Pathway. That Section provides (b) The.onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards:

(13) General plans for recovery and reentry are developed. (Emphasis supplied)

Moreover, NUREG-0654,Section II, J. 11 at p. 64 specifically provides, inter alia, that the plan shell identify procedures for decontamination and processing.. Certainly, decontamination and processing can and should be considered as in the nature of " recovery" measures. See also, 47 Fed. Reg. 47073,47083(h)(1)(V). Additionally, the PACS at page 1.30 refer to demineralization of drinking water. This, too, is a " recovery" action. The PAGs at pages 1.46, 1.47, and 1.48 also refer to decontamination of' food and water which must be considered a " recovery" effort.

The PAGs at page 1.48 also provide recommendations to the emergency

. planner concerning the lifting of food protection ccatrols when the health risks have been adequately reduced. At pages 1.49 and 1.50 of the PAGs, recommendations concerning decontamination of water, milk and food are set forth.

Although some ad hoc decision-making may be necessary and minute detailed advance planning unfeasible, the State plan should at least provide some general criteria and guidance on.the recovery actions above mentioned, as well as when and under what circumstances relaxation of protective actions in

'the Ingestion' Exposure Pathway'may be instituted. The present State Plan

-provides no such guidance, and, therefore, fails to address a matter of legitimate concern to the City of Philadelphia.

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City-8: -The Staff apparently agrees that this general issue should be

'consi red, but argues that as_ presented it lacks specificity. Applicant also ,

' \ argues'that this. issue lacks specificity and constitutes an attack upon the

^ LRegulations;J Both Staff and Applicant are incorrect. NUREG-0654,Section II, A ,

-'r at page 31 applies as aforesaid to both' emergency planning zones in dealing with

, assignment:of emergency responsibilities-to various supporting organizations.

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'Specifically, NUREG-0654,Section II, 0, deals with Emergency Response

, - Training of those'who'may'be called upon during an emergency'. Contrary to Applicant's pcsition,fthis training is not limited to personnel to be, called

.;upon during-emergencies.only within the Plume' Exposure Pathway.

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It is clear

- that-each response organization must assure. the . training of _ appropriate t . _ . .

-individsals. In the Ingestion Exposure Pathway, the State is the responsible

organization..

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Appendix _19 of the State Plan dealing with Training is inadequate in

1. : that: ,

1) . -The Appendix failsJto-adequately-define the term "affected

& ' counties" so as to include' counties such as Philadelphia in the In'gestion Exposure Pathway.

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Training-provisions of' Sections III and IV of the' Appendix-appear a.

_ to address;themselves;to.the Plume Exposure Pathway.and are not

< clear ~ asjto'whether counties such as Philadelphia in the. .

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Ingestion Exposure Pathway,)are included.

3)- Section V of the' Appendix of Annex E deals only..with training' for

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. ;the agricultural communityyin'the Ingestion Exposure Pathway, and

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faiIs to provide for. training.of' personnel to deal l with water

'} 'supplyjand' aquatic lifeLprotection. The plans do not provide-

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for the-training of personnel to measure, evaluate, lessen, and prevent radioactive contamination of the water supply.

4) Section VI of the Appendix agsins refers to "affected counties" r

without.providing a definition of that terminology. Moreover,Section VII does not clearly specify whether the City of Philadelphia is intended to be included.

Moreover, NUREG-0654,Section II, N at page 71 et seq., provides, inter alia, for periodic exercises and drills to evaluate emergency response capabilities.and to develop and maintain skills. 44 CFR $3350.9(5) provides that Ingestion Exposure Pathway emergency planning exercises should be conducted at least every five years. This'is a minimum requirement and certainly would not prevent this Board from ordering more frequent exercises here, in view of the enormity and diverse nature of the City population in the Ingestion Exposure Pathway.

In fact,_NUREG-0654,Section II, N(2)(a) requires that communication

. drills within the' Ingestion Exposure Pathway EPZ should be tested quarterly.

NUREG-0654,.Section II, N(2)(d), also requires annual drills both on-site and off-site which "shall include collection and analysis of all sample media ~(e.g.,

water, vegetation,-soil and air...)." Thus, the regulators clearly contemplated

. Ingestion Exposure' Pathway drills and exercises in certain' areas more often that thezoutside five (5) year requirement.

Appendix 20 of the State Plan does not indicate whether the City of Philadelphia is included in the annual full-scale exercise therein provided.

Although.that exercise is defined as a test, inter alia, of procedures, training, resources, staffing levels and qualifications, and equipment adequacy, Appendix 17 of Annex E does not set forth the resources, staffing levels and

qualifications and equipment required for emergency testing in the Ingestion Exposure Pathway. Likewise, while Appendix 20 provides for drills of communications in the Ingestion Exposure Pathway, Appendix 17 does not specify the communications channels and equipment to be utilized in the Ingestion Exposure Pathway. The same failure is applicable to the radiological monitoring drills mentioned in Appendix 20. No guidance is provided as to methodology and criteria for collection and analysis of water, vegetation, soil, and air samples.

It is submitted that the Plan should provide that exercises and drills in the Ingestion Exposure Pathway should and must be done as soon as possible after an Emergency Plan is adopted. It is certainly not in the public interest to have a Plan in place and not test its feasibility until five years later, as Applicant apparently contends. The City is legitimately concerned that five

. years later may well be too late.

City-9: The City'is concerned that no emergency measures and implementation agreement exists between the Applicant and the Commonwealth. Staff does not object to the admission of this issue. Applicant opposes on the incorrect

- assumption that NUREG-0654 Section IIA (3) at p. 32 applies only the Plume Exposure Pathway. :This section in fact applies to both pathways zones:

Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support _ organizations having an emergency response role within the Emergency Planning Zones.

The agreements ahall identify the emergency measures.to be1provided and the mutually acceptable criteria for their implementation, and specify the arrangements for exchange of information. (Emphasis supplied) m- .

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Since without an' agreement between Applicant and the Commonwealth there can be no assurance that the necesary protection measures will be taken in an emergency. The failure of the Plan to contain such an agreement is a matter of legitimate concern to the City.

City-10: The City is concerned that Implementing Procedures EP-318 and EP-319

'do not designate who is responsible to perform the measurements and calculations designated therein and do not provide for informing appropriate persons downsteam of the results thereof. Both Staff and Applicant object to inclusion of this issue. One supposed basis for objection is that this concern involves on-site planning and was late filed. It must be noted, however, that the City only received PECO Emergency Plan, Implementing Procedures EP-318 cnd EP-319 under date of December 12, 1983, (See Exhibit "A" attached), which was after the June 10, 1983 date established for filing on-site emergency planning issues. It wa s therefore impossible for the City to file this concern prior to the on-site emergency planning contention due date. There are no other porties of record in this proceeding representing the interests of the City of Philadelphia in

Ingestion Exposure Pathway, and therefore, there are no other means whereby the interests of the City of Philadelphia can be protected. The inclusion of this item in the proceeding will not unduly broaden the issues and will assist in the development of a sound record.

Applicant cites the Waterford case, 17 N.R.C. at 1106-7, to support its further position that implementing precedures cannot be the subject matter of a-contention. ' Applicant misreads this precedent. In Waterford, a complaint concerning the non-finality of implementing procedures was adjudged to be an impermissable challenge to the Commissions regulations. The City here is not raising an issue of concern 'as' to - finality, but as to clarity. While the b .-

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" finality"- of implementing procedtres may not be required for a " reasonable

' assurance'! finding, clarity is a necessary ingredient. Moreover this hearing will not become bogged down with litigation concerning this detail because

Applicant itself has stated that." carrying out EP-318 and EP-319 is part of the

-responsibilities of the' Limerick Dose Assesment Team." One wonders why Applicant does n'ot simply agree to amend EP-318 and EP-319 to change the "none" under the "Responsibiilities" heading to the " Limerick Dose Assessment Team",

cand include the references to.other pertinent applicable procedures, Instead Applicant opposes the City's attempt at clarification, and creates needless

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' litigation.

City-11: The City expresse'd'its concern that EP-287 provides no information on what levels of contamination off the Schuylkill River will warrant notification

'to;the City and other downstream users. Staff agrees that this issue'should be considered. ' Applicant again says that this concern is a late' file on-site contention.~ ,The' City only received this Implementation Procedure on'or after December 30,'1983. .Therefore, the criteria.for late-filing of this issue, and-

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the reasons for Board ~ cons'ideration of this-issue are precisely the same as "B" attached.) Applicant also

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those set.forth in City-10!above. '(See Exhibit argues that reference should be made to EP-210 and EP-312 in order to obtain clarific'ation.of EP-287. In . order to provide rapidity of response,- EP-210 and

.EP-312 should be included as a reference in EP-287. Again, the City wonders why

_ .pplicant flatly! refuses-to clarify this point, but rather seeks.a course of

. ' unnecessary litigation.

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- City-12: The City's concern here is that the State Plan does not provide reasonable assurance of implementation because there are no FEMA / EPA standardized protective action guides relating to injestion exposure. Both

. Staff and Applicant oppose consideration of this issue. However, NUREG-0654 Section II'J (9) requires,' inter alia, that the State "... shall establish a

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capability for implementing protective measures based upon Protective Action Guides...." (Emphasis supplied.). Moreover, at NUREG-0654,Section I, D(1) at p.

'6'specifically provides that 4

'The.overa11' objective of emergency response plans is.to provide dose savings (and in some cases immediate life savings).for a spectrum of accidents that could produce off-site doses in

! (Emphasis excesses of. Protective Action Guides-(PAGs).

supplied.)

These PAGs are referred in footnote 3 on p. 6 of NUREG-0654. The September 1975 PAGs were revised and now appear as TD-12.under date -of September r1981. Chapters 3 and 4 which relate to.PAGs for exposure from foodstuffs or.

' water, and-from material deposited on property, respectively, are effectively nonexistent containing the notation "(Guidance to be Developed)". The' State F , Plan'is' required by the NUREG above quoted to;be' based upon the PAGs. Since the

- relevant.1981 PAGs are effectively nonexistent, the State Plan, of, necessity,

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cannot be' based upon- those ' PAGs as required by NUREG-0654.- Even the guidance b

.provided'by'47 Fed.' Reg. 47073 (October-22, 1982) does- not appear! to have been

. the basis for the: State Plan in the Ingestion Exposure Pathway since the City is

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'M ' not aware of any. revisions to Appendix 17 of Annex E issued by the State

/ subsequent ~to October 22, 1982.

Accordingly, the State plan- is -inadequate on this -point because it

. does not 'contain'and is-not based upon the standardized protective action

~ guidance for exposure ?from foodstuffs. or water, nor is- there protective action-

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guidance ~for exposure from radioactive material deposited on property or

. equipment'as set forth in The Manual of Protection Action Guides and Protection Actions for Nuclear Incid;nt_s s(TD-12, September 1981).

WHEREFORE, the City ot uniladelphia respectfully requests that the

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^ ' Board order the relief' requested in the City's revised Issues of Concern.

Respectfully submitted, CITY OF PHILADELHIA BARBARA W.' MATHER-City Solicitor TYLER W. WREN Divisional Deputy City Solicitor MARTHA W. BUSH Deputy City Solicitor Y?

HERBERT SMOLEN-Deputy! City Solicitor p

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>. t PHILADELPHIA ELECTRIC COMPANY I 2301 M A RK ET STR E ET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. DALinorr eENEll%E,o December 12, 1983 Re Docket Nos. 50-352 50-353

-Mr. A. Schwencer, Chief Licensing Branch No. 2 -

-Division of Licensing U.S. Nuclear Regulatory Commission Washington,- D.C. 20555

Dear Mr. Schwencer:

+ Enclosed are two copie of Limerick Generating Stibtion

- Emergency Plan Implementing Procedures. These procedures,are submitted per regulations in 10 CFR 50, Appendix E, Section V.

l The procedures being submitted are the following:

EP-110, Rev.-O EP-307, Rev. 0

-EP-208, Rev. O EP-312, Rev. 0-EP-221, Rev; O EP-313, Rev. O

! EP-251, Rev. 0- EP-318, Rev. 0 l- EP-252,'Rev. O EP-319, Rev. O EP-304, Rev. 0- EP-401, Rev. O EP-305, Rev. 0 EP-500, Rev. 0-Pursuant to Section 2.790 of the Commission's

. regulations, it is hereby requested that the telephone numbers

' listed in procedures EP-252, EP-304, EP-305, EP-312 be withheld

~

from public. disclosure. An af fidavit setting forth the grounds in support.of this request is attached hereto.

g DCIIBIT A -

o

. . . ~ .

4 Page 2 Mr. A..Schwencer Two copies have been sent under separate cover to the

. Document Control Desk.

t Very truly yours,

/

,' f N (l! ( .

Enclosure-

.cc: Document Control Desk

'U.S.. Nuclear Regulatory Commission

-Washington, DC .20555 Site Inspector - Limerick Generating Station P

a f .+-

H.- *

.cc Judge Lawrence Brenner (w/ enclosure)

Judge Peter A.~ Morris (w/o enclosure)

Judge Richard F. Cole (w/o enclosure)

Troy 1. Conner, Jr. , Esq. (w/ enclosure)

Ann P. Hodgdon, Esq. (w/ enclosure)

Mr. Frank R. Romano (w/o enclosure)

< Mr. Robert L. Anthony (w/ enclosure)

Mr. Marvin I. Lewis (w/ enclosure)

Ms. Phyllis Zitzer (w/ enclosure)

Charles W. Elliott, Esq.. (w/o enclosure)

. Zori G. Ferkin, Esq.. (w/ enclosure)

Mr. Thomas Gerusky (w/o enclosure)

Director, Penna. Emergency (w/o enclosure)

Management Agency Mr. Steven P. Hershey (w/ enclosure)

Angus Love, Esq. (w/ enclosure)

'Mr. Joseph H. White, III (w/ enclosure)

David Wersan, Esq. (w/o enclosure)

Robert J.- Sugarman, Esq. (w/o enclosure)

Martha W. Bush, Esq. (w/ enclosure)

Spence W. Perry, Esq. (w/o enclosure)

Jay M. Gutierrez,- Esq.- (w/o enclosure)

Atomic Safety.& Licensing Appeal Board (w/o enclosure)

Atomic. Safety & Licensing Board Panel (w/o enclosure)

Docket &-Service Section- (w/ enclosure) 6

,e

+

w

~ COMMONWEALTH OF PENNSYLVANIA :

nu.

COUNTY OF PHILADELPHIA  :

S. L. Daltrof f, being -first duly sworn, deposen and states as

_. .follows:

.1. . Ilre is Vice President of Pliii aitolphia M i ceL c i e Gooipany to (hereinafter referred to as the " Company" ); he i u . n et h u r i v. .I execute this Af fidavit on behalf of the Company; .usd hcr hms ,

j reviewods EP-252, Rev.-O EP-309, Rev. O P.P 304, Rev. O' P.P-31*>, lhtv . O (hereinaf ter referred 'to as "the Documento"), and knows the .

contents thereof.

2. -The par t of the Documcnitn which tire nought to he withhold ' f rom public disclosure is the listinq of the home

.telephouc numbers and home addressen of employees of the Company, direct-line ' work telephone numbers of employees of the Company I which'are not listed in public toluptione diructories, and home and work numbers of emergency responue support personnel and

. or ga ni za t i on s' .

3. To the best of his knowledge, information and belief, the telephone - numbers and addresses set forth in the l'

Documents have been treated as confidential information and have been withheld from public disclosure by the Company.

4. The home telephone numbers and home addressen in the Documents should be considered by the Nuclear Regulatory Commission as confidential and proprietary information and be withheld f rom public disclosure on the grounds that disclosure of the home telephone numbers and home addresses of the employacs of the Company and emergency support personnel could constitute an unwarranted invasion of the personal privacy of the individuals involved, disclosure of the work telephone numbern of the Company's employees and of the emergency response personnel and ~ .

organizations could adversely af fect the capability of prompt noti fication in the event of an emergency; such disclosure is not required in the public interest; and such disclosure could adversely af f ect the intorests of the Company and its abili ty to ef fectively implement' the notification requirements of the

' Emergency Plan Procedures.- . ,<*

j

, , - .. (

u. . - A il l L . , j . { - -

Subscrlhed and sworn to before me this 13'" day

• • i' l

of L>

/-

,,</ (/, ;c . . . .

/

Notary Public JUDITH Y. FRANKLIN Notary Pu%c. Phda.. Pinta Co.

My Commesson Eno res July 28.1987

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

4 EP-318 Rev. O Page 1 of 8 .

VA . MPG /rgs

/e/a PRIIADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION EMERGENCY PIAN IMPLEMENTING PROCEDURE EP-318 LIQUID RELEASE DOSE CALCUIATIONS METHOD FOR DRINKING WATER 1.0 PURPOSE The . purpose of this procedure is to provide the calculation method for estimates of population exposure due to the ingestion of drinking water at various locations downstream of the plant.

'2 . 0 RESPONSIBILITIES None

.. .. .. .. s.a . --- .....u ., ...s.- .~ A- - - ~-~--- -- - - - - - - - - = - -

APPENDIC?!S ~

• 3 .'[O -

3.1 EP-318-1 Citizen Utilities Bone Water Company Intake 3.2 EP-318-2 Phoenizville Water Intake j 3.3 EP-318-3 Philadelphia Suburban Water Company Intake 3.4 EP-318-4 Norristown Water Intake l

3.5- EP-318-5 Philadelphia Belmont Water Intake.

l r

I

, 4.0 PREREQUISITES None

5. 0' SPECIAL EQUIPMENT None l

4

.-,*-m . ..w-- -.i....- ,- - .-----m ,.w- ...,e, ,,,y, - -r- -,,- --wy ., - - . . -- , , - , y m-- *<,-w, - - - - . ,.------w -.r y,-r

~

EP-318 Rev. 0 l Page 2 of 8 VAW/ MPG /rgs 6.0 SYMPTOMS 6.1 An actual or potential liauid release of radioactive material into the Schuylkill River.

7.0 ACTION LEVEL 7 .1 ' This procedure shall'be implemented when the criterion of section 6.0 is met.

8.0 PRECAUTIONS None

'9.0 PRCCEDURE 9.1 The following assumptions were utilised in this calculation: -

,,t . . , - ..~..o.--... .; w .r

. . ~ . . ~ ~ --- -- = - ~ -~

9.1.1 The Dose conversion Factor is based on the most limiting group (adult, tese, child, infant) using dose factors and consumption rates in Reg.. Guide 1.109.

t Adult 730 1/yr Teen 510 1/yr child 510 1/yr Infant 330 1/yr 9.1.2 The Decay Factor is based on the decay of the isotope over the transit time plus 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (time to-reach the population via ~

water system per Reg. Guide 1.109).

4 4

6 v.-[--+- -y m. .+._ .-~-m- ,..v.,--. ---.,++-,....r--..-- -

- - , - - - - - , _ . - . . , - . - , , - , .. + - . . . . . . . . . - .-.m--...-, .

. . - - - - . = . . n ..

.J .

EP-310 Rev. O Page 3 of 6 VAW/ MPG /rgs 9.1.3 The total dose commitment is the dose which an individual would receive after drinking water with the radionuclides present at the concentrations calculated to exist at the entrance to the water plant for a period equal to the duration of the release. Fo r example, if the release lasted 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the individual is postulated to consume 1/2 of his average daily water intake at the diluted concentrations.

9.2 Obtain grab sample results on the concentration of Co-60, I-131, Cs-134 and Csb137 released, from the Chemistry Sampling and Analysis Team Leader.

9.3 For each location of interest, enter the concent. ration of Co-60, I-131, Cs-134 and Cs-137 in uci/cc released and the release duration in hours on the appropriate appendix.

If the sample was taken prior to entering the Cooling Tower Blowdown Line, a diluted concentration must be determined by the following calculation

.,..,n .- . ... ., . . ~ .s: -- - - . - = ~ ~ - - - - ~~-" ---~

.do...s a.

ncentrat ion... [uct concentration Release rate to Blowdown Line

. Released

\ct Blowdown-line flow rate 9.4 Perform the calculation in each appendix for each

. location of interest to estimate the dose in millires '

for the liver, whole body and thyroid.

9.5 Report results-to the Dose Assessment Team Leader.

10.0 REFERENCES

10.1 EROL 2.1.3.6 surface Water Use 10.2 EROL.5.2.4.1 Liquid Pathways 10.3 EROL Aroendix 5.2A Radiological Dose Model-Liquid E f fluent..

L 10.4' Reg. Guide 1.109 Calculation Of Annual Doses To Rev. l' Man From Routine Releases Of Reactor Effluents For The Purpose of Evaluating L Compliance With 10 CFR Part 50, Appendix I

4 1 EP-31C Rev. O. *

page 4 of 9 -

1 1 VAW/ MPG /rqg~

~

APPEMDIX EP-318-1 ' CITIZEN IITILITIES I )ME WATER COMPANY INTAKE

~

Ibse mR/hr Concentration Decay coe.ve rs ion ' uf'T7Ec X, uct/cc it,' Factor =>

Factor Q o

e i,{ver 406:

e I. 1.0 o - ym i, 959 noly ,

r,tve r 1591 I N' whole 700 .95 2

7 H

nn.iy .

1

' thy ro ta 5.23P5 ,

$ T,t ve r 2.64P4 '

1.'O e, f

,~

y' j mio le 1.0lP4 Roly i' t~

T,t ve r 2.30P4 1.0 O wiole 5942 noav I +

i Schuylkill River Release  ;, Mixinq

Ilsage Factor X theration (hrs) X

Factor X = Dose (mR)

T,1 ve r

~

, Miole Body .4R .0118

i. '

Thyroid ,

! i Ih te : _ _ _ _ Initials: -

I 1

l  !

..). .

EP-310 Rev. O ,

Page 5 o f 9 -  ;

l VAw/ MPG /rgs APPENDIX EP-318-2 PHOENIXVILLE WATER.ifMAKE

~ '

Dose. mRfhr Concentration f Decay i Conversion uWde .X uCl/cc K', Factor = -

Factor 'I

$ Liver 406 1.0

• i l 0 Whole 959 .

Rocly I f.

t Liver 1591 ,

r p

Whole 700 ,

.92-

, ,-. Borly

e i I

' thyroid 5.23P5 '

k 4

y Liver 2.64P4 '

1.0 O Whole 1.01P4 -

3 no.1v '

i I.t ve r 2.30P4 '

1.0 S.

e- -

o Whole 5942 o g ,jy <

! \

+

Schuylk li t - River Release Mixinq

_ lisarge Factor X Duration (hrs) X}: Factor X = Dose (mR) l T.tver ,

f

whole Holy 1.0 j .0118 Th{rol'1 ..l!

thter

]

i  !

j i i .

[

, EP-310 Rev. O. .

Page 6 of 8 .

'l VAW/ MPG /rgs APPRNDIX EP-318-3 PHILADELPHIA SUBURBA WATER COMPANY INTAKE Ibse mR/hr Concentration - Decay

-Conversion iiUT/cc X uCl/ce' X t,' Factor -=

Factor ';

g Liver 406 -

0 1.0 3

0 Whole .939 B&1y ' .

Liver 1591 I H Whole 700 i .90 Os Holy  ;,

H .

f

]'

i Thyrol<1 5.23P5 -

i .s *

] . Liver 2.64P4 j- 1.0 e

j Whole 1.01P4 -

noiy * -

i S r.t ve r 2.30P4 ,

1.0 i e '

E Whole' 5942 U

Rody

+

Schuylkill River Release Mixing lisage Factor X Duration (hre) X IFactor X = Dose (mR) l Liver i i  !

l Whn t e noly .22 .0149

'. . I

{ 11tytoId

• l I

twtes

=

i l

4 f I l 4

y- .

4 EP-310 Rev. O- *

Page 7 of 8

• I VAW/ MPG /rgs APPEstDIX EP-118-4 NORRISTOWN WATER IN AKE thse mR hr Concentration  ; Decay Conversion u cc X uC1/cc X f,, Factor =

p Factor ,

i g Idver 406 ) 1.0 . >

Nhole 959 MoiY i Liver 1591 r< r i n Whole 700 .87 7

H

. Body .,

%yroid 5.23P5 , L 4

m Liver 2.64P4 - i 1.0 re -

4 8 r 0 Whole 1.01P4 Body .

N

" ]

Liver 2.30P4 j 1.0 5 Whole 5942 Body

I +

Schuylkill River Release

, Usaqe Factor X Duration (hrs) X!' Mixing Factor X = Dose (mR) l -

Liver

?

i Whole Body 1.0 .

.0091 i

%yroid -

i I

] Date: _

l i

h i

y- .

EP-310 Rev. C, -

+-

Page 8 o f 8 -

'l VAW/ MPG /rgs-

~ APPENDIX EP-318-5 PftttADELPflIA REEMON WATER INTAKE floge

~mR/hr Concentration  ; Decay Convernlon ufM7ec X uCl/cc X t, Factor. =

Factor ')

$0 Liver. l'406 k j 1.0 O Whole 959 Reiv '

Liver 1591 -

g Whole 700 I .80 m Berly .

a e i

H 1hy ro t<1 5.23P5 -

~g . t.tver 2.64P4 1.0

, s '

l E Whole 1.01P4 I-o go,iy 3 S

H f.t ve r 2.30P4 1.0 e

a whole 5942

, Bor1Y '

+

Schiiv W111 River

Release il Mixing 4

Usaqe Factor X Duration (hrs) X l Factor X = Dose (mR)

, T.tver 5

Whole noely 1.0 '

.0112

! i, 1hy ro t el . '

j __

I f thtes  ;

i i e

it . .

f EP-319 Rev. O Page 1 of 4 VAW/, MPG /rgs

"[I g PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION '

EMERGENCY PLAN IMPLEMENTING PROCEDURE IP-319 FISH INGESTION PATHWAY DOSE CALCULATION 1.0 PURPOSE The purpose of this procedure is to provide.the calculation method for estimates of the maximum population exposure due to the ingestion of fish from the Schuylkill River.

2.0 RESPONSIBILITIES None 3.0 APPENDICES

. .= _ . . . _ ...- - - -3.1 - ~- - EP-319-1-Maximum Cr r-Cron* '"Y- t::*;';orr-- c" " ~' ~-

2 4.0 PREREQUISITES.

-None 5.0 SPECIAL EQUIPMENT None

~6.0 SYMPTOMS 6.1 An actual or potential liquid release of radioactive material into the Schuylkill P.iver.

7.0- ' ACTION LEVEL 7.1. This procedure shall be implemented when the criterion of section 6.0 is met.

__...u.,_ .

n- ,

EP-319 Rev. O Page 2 of 4 VAW/ MPG /rgs 3.0 P RECAUTIONS None 9.0 PROCEDURE I 9.1 The following assumptions were utilized in this

( calculation:

9.1.1 The Dose Conversion Factor is based on the most limiting group (adult, teen, child,

infant) using dose factors and consumption J rates in Reg. Guide 1.109.

Adult 21 kg/yr

'; ~ ' Teen 16 kg/yr

' ~

Child 6.9 kg/yr Infant 0 kg/yr 4- -

9.1.2 The Decay Factor is based on the decay of

• ' ' .the i,sotone over 24 .,

- ~

population per Reg., ho,ura Gulce .1.199 f timejo_,zegeh t%_ .

'. 9.1.3 The total dose commitment is the dose which

[? - an individual would receive af ter eating fish exposed by the highest concentration of

_ diluted effluent for the duration of the m  ; release .

i 9.2 Obtain grab sample results on the concentration of Co-

- 60, I-131, Cs-134, Cs-137 and P-32 released, frem the R ... '-

Chemis,try Sampling and Analysis Team Leader.

=

9.3 On Appendix EP-319-1, enter the concentration of P-32,

-- Co-60, I-131, Cs-134 and Cs-137 in uCi/cc released and

c.  ; the release duration in hours.

If the sample was taken prior to entering the Cooling Tower Blowdown Line, a diluted concentration must be

! determined by the following method:

~ .

i'5 Concentration uCi . concentration m helease rate to Blowdown Line e . me1.as.e c1 e1o. own 11ne ,1ow ra .

e (uci)

a

.. _' 4 7.

E 4

-mmm m mum m mm i mi um

r .

EP-319 Rev. O Page 3 of 4 VAW/ MPG /rgs 9.4' Perform the calculation on Appendix EP-319-1 to t estimate the maximum dose in millires for the liver, whole body and thyroid for the fish ingestion pathway.

l( 9.5 Report results to,the Dose Assessment Team Leader.

l j

10.0 REFERENCES

t

, 10.1 EROL 5.2.4.1 Liquid Pathways 10.2 EROL Appendix 5.2A Radiological Dose Model-Liquid l Effluents I

10.3 Reg. Guide 1.109 Calculation of Annual Doses To Rev. 1 Man From Routine Releases Of Reactor Effluents For The Purpose Of Evaluating Compli. nce With 10CFR Part 50, Appendix I

.- . n. . ,- .. z..>.a.- .. . . . , p. . . t ,.~a.>--- - - - ~ - ~ - -- --- -- - -~~

l .

l -

L e

se I

._r

i.

• EP-319 Rev. 0 4

. Page 4 of 4 VAW/ MPG /rgs. ,

APPENDIX-RP-319-1 MAXIMUM DOSE FROM FISH INGESTION h e Conversion Mixinq Done (mR)

Factor - x Concentration x Decay x Release x Factor =

m_R uCl Factor Duration Liver Whole Thyroid

[ u ec cc (hre) body N Liver 3.12P6 .

x

.e

.e i A Whole 2.5P6 .95 .0357 .

Smiy

@ Liver 256

s

0. Whole 614 1.0 .0357 Boiv .

t Liver 224 ,

s

! n Whole .92 .0357 i

i 7

H Body 122 j" 1hyroid 7P4

~s l " Liver 7.19P5 l E '

1.5

~

i o Whole .0357 j __ Boly 5.79P5 S Liver 5.44P5

.-i i e

{ y Whole 1.0 .0357 .

7 Boiv 3.42P5 i

DATR: Total Dose (nr) t

s T

Liver Whole Thyroid

{ Boly I

W '

Q$

g- Jsu l PHILADELPHIA ELECTRIC COMPA'NY 2301 MARKET STREET l P.O. BOX 8699 f PHILADELPHIA. PA.19101

, ,, taisi a41. cool s6sevne caseveview Ducumber 30, 1903 Rei Docket Nou, 50-352 50-353

-Dr. Thoman 3. Murley Region 1 Office of Inspection & Enforcement U.S. Nuclear Requintory Commission 631 Park Avenue King of Prussia, PA 19406

. Mr. A. Schwencer, Chief-Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commi.ssion Washington, D.C. _20555 -

GentlemenJ -

g~-

Enclosed are two copios of Limerick Generating station Emergency' Plan Implementing Procedures. These procedures are submitted per', regulations in 10 CPR 50, Appendix E,Section V.

The procedurea being aubmittod are the toL10 wing:

EP-101,.Rev. O EP-260, Rev, 0 BP-102, Rev. 1 BP-272, Rev, O l

BP-103, Rev. 1 EP-273, Rev, 0 NP-104, Rev. 1 RP-275, Rev. 0 BP-105, Rev. 1 EP-276, Rey, 0

~ RP-106, Rev. O. -

EP-277, Rey, 0 BP-231,'Rev. O BP-278, Rey, 0 BP-332, Rev. O EP-279, Rey, O

• i- WP-233, Rev. O RP-280, Rey, O BP-334, Rev. 0 BP-381, Rey, 0 RP-235, Rev. 0- RP-282, Rev._0 i RP-336, Rev 0 BP-284, Rev 0 BP-237, Rev. 0 BP-287, Rev, 0 BP-238, Rev. O BP-291, Rey, O i

RP-240, Rey, 0 RP-292,~ Rey, O EP-241, Rev. O SP-294, Rey, O RP-242, Rev.-0 BP-306, Rev, 0 EMilBIT B

- ,e -- .w -, ---,. ... , , re.----e- ---v_y, - - > - - - ~ . .,wn--,-e-.,.---. . w.~,mw--.e-,~.----.--.n.,,w- n--- -

. F l* .

Dr. Thcmas 3. Murley Page 2 nr. 4, schwencer b

NP-243, Reve O EP-316, Rev. O

BP-254, Rev. O EP-317,f Rev. 0 BP-255, Rev. O EP-325, Rev. 0

(. EP-330, Rev. 0 l Pursuant to Section 2.790 of the Commission'u L regulatione, it is hereby requested that the names and telephone numbers listed in procedures EP-102, Rev lt EP-103, Rev.1; EP-104, Rev.1; RP-105, Rev.1; EP-106, Rev.0; EP-272, Rev.0;

! EP-273, Rev,0; EP-275, Rev.0; EP-276, Hov.0; EP-277, Rov.0; l EP-279, Rev.0; BP-380, Rev 0;'EP-282, Rev.0; EP-204, Rev.0;

! EP-387, Rev.Or RP-291, Rev.0; EF-292, Rov.0; EP-294, Rov.0; l EP-306, Rev.0 be withheld from public disclosuro. /\n af fidavit setting forth the groundu'in support of this roquuut in attached hereto.

, This filing supplements my lotters of November 23, 1983 l and December 12, 1983 and completes the Emergency Plan Implementing Procedures for Limerick 1 & 2.

Two copies have boon sont undur uoparate uuvor to the Document control-Desk.

Very truly youru, Onuillal signed t>Y

& t;. OALTROFP KW8:alb -

Enclosere cca Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Site Inspector - Limerick Generating Station See' Attached Service List m wo -o a

t

. r- .

(w/onclosurel Juogc Lawrenco Dronnor (w/o enclosuru)

Judge Pocor A. Morris (w/o encionuru)

Judge Richard F. Colo -

(w/onclocuro)

Troy D. Connor, Jr. , W04 (w/onclosure)

Ann F. Hodsdon, Wuq, (w/o enclosural Mr. Frank R. Romano (w/onclosuru)

Mr. Robert L. Anthony (w/onclosure)

Mr. Marvin I. Lowtu (w/onclosuru)

Ms. Phyl.118 %1tuur (w/o unclonural Charles W' Elliott, W44 (w/onclosuru)

%ert 0..Forkin, Esq. (w/o onclosurul Mr. Thomas Occusky (w/o onclouuro)

Director, Punna. Emergency Managomont Asoncy tw/unciouurus Mr._ 8teven P. lieruhoy (w/onclosurus Angua Loyo, 204 (w/onclosuru)

Mr. Joseph H. Whicu, III (w/o unclouuep)

David Worsan, Esq. (w/o unclouurul lloborb J. Sugarman, Wuy.

(w/onclosurul Martha W. Such, Saq. (w/u wncluaurul sponco W. Purry, Wuq. (w/ unclouurul Jay M. Guttorroz, Suq. (w/u unc1ocureJ

. ALowle M41'oby & L1conuing Appuni launcti (w/o unclosure)

Atomic 34focy & Licunuing Ucued Panel (w/unclouuru)

Dockot & Sorvicu Suction ,

0 t

S e

9 a

4 e

./*-

COVEONbEALTli OF PENNSYLVANIA :

COUNTY OF PHILADELPHIA  :

S. L. Laltrof f, being fi rc.t dul y ev. ors , s'. 6 , o ti t.:.i e t e tt ., to follows .

1. He is Vice President of Philadelphia 1;j ectric Comrcr.y (hereinaf ter referred to 'as the " Company"); he ir a utho ri zoc' to execute thit. Af fidavi t on hchalf of thc Cou.pt.n r. c.s.d hc ht:r 2 revi ewed :

EP-102, Rev. 1 , EP -2 7 9, Rev. 0 EP-103, Rev. 1 HP-?HO, nc v . O EP-104, Env. 1 EP-782, f. e v . O EP-105, nov. 1 EP-PD/I, Pev. O EP-106, Rev. O EP-207, Dc v. O EP-272, Rev. O EP-291, Dev. O EP,-273, nev. 0- EP-?"2, Rev. O PP'- ? 7 T , . F 'v . P CP-?or, P t, O CP-270, Rcv. O EP-300, 1: t.v . O EP-277, Euv. 0 (hereinaf ter referrcW to oc " the Uccus.orit t " ) , i od hiot- t i n.-

contents thereof.

?. . -The part of the Docuinent e v'hi ch i r ;oucht to Pc withhold . f rom public disclosure it the lir.tino of the name Ver.d home telephone _ numbers of . employner of the Com. .6ny, di rect-J i no work telephonc nun.Lort. of employees of th c. Cor.1 c.ig vhi c.h cz o o c.c 3 i e t es' -f n pup 3 ic telerhonc di rc etc,ri ec , i.. . r.( . ei n.' bc : s o r.r' rc r1

' numbers of cmercjuncy response cuppor t pe rson ncei sn/

crenni sct i or.. .

~

[^

3. To the best of his knowledge, iiiformati on and helief, the names and telephone numbers set forth in the Documents have been treated as confidential information and have been withheld f rom public. disclocure by the Company,

4. The names and home telephone numbers in the Documents should be considered by the Nuclear llegulatory Commission as confidential and proprietary information and be withheld f rom public disclosure on the grounds that dinclosure of the names and home telephone numberc of the emjJoyecc of the company and emergency support personnel .could constitute an J

unwarranted invasion of the perconal privacy of ..the i ndividual c involved, disclosure ' of the work telephone numberr of the Company's employees and of the emergency responue pornonnel and organizations could adveracly af fect the capabili ty of prortij t notification in the event 'of'an emergency; such dicelonuro ir not roouired in the public interesti and . cuch disc 3 cc ure could adversely af f ect the interests of the Con.pany a nd ito i.1ility tc ef f ecti vel y' .imr3 ement the noti fiertion renui rc r. ent r of tl .

Emorgency Plan Proceduroc.

l(

I

l (-( .

/

/ I Subscribed and sworn to .

,o betore me thi.s d'~~ day "

ot^ jJew.,brt / N~#*

l I 0 i. i 1

/) : ,

e . t . t i , s,' . . . .

/

' Notary P Q1ic '

PATRICIA A. JONES ,

Neluy W. PIwie., Ptwis. Co.

44 Commemon Empree oot 13,1906'

p' . # .

EP-297 Rev. O Page 1 of 2

,-' VA MPG /rgs PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATIRG STATION EMERGENCY PLAN IMPLEMENTING PROCEDURE <

EP-287 NEARBY PUBLIC AND INDUSTRIAL USERS OF DOWNSTREAM WATER 1.0 PURPOSE The puroose of this procedure is to provide information to contact downstream users of the Schuylkill River.

.2. 0 RESPONSIBILITIES 2.1 The Communicator shall be responsible to contact the downstream users.

3.0 APPENDICES None 4.0 P REREQUISITES None 5.0 SPECIAL EQUIPMENT

-None Il .

6.0 SYMPTOMS None 7.0 ACTION LEVEL ,

i 7.1- This procedure can be used when there has been a

- release to = the Schuvikill Ri ver.

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8.0 P RECAUTIONS 8.1 Contact tha na '1vania Department of Environmental l Resources before using this procedure.

4.0 P ROCEDURE 9.1 1mmediate Actions l 9.1.1 The Communicator shall contact the downstream users using the following list.

9.1.2 Downstream Users

! 9.1.2.1 4+ 'tility Home Water Co.

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9.1.2.2 Philadelphia Electric Co.

Cromby Generating Station l 9.1.2.3 dhia Suburban Water Co.

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([) (Office) after 5 pm (Plant) 9.1.2.4 nixville Water Authority 9.1.2.5 National Gypsum Co.

W Conshohocken Plant 9.1.2.6 Lukens Steel Co.

hrs.

9.1.2.7 Phoenix Steel Corp.

Phoenixville Plant 9.1.2.8 Synthane - Taylor Corp.

9.1.2.9 Nicolet Industries, Inc.

l Norristown Plant l x -- 9.1.2.10 Keystone Water Co., (Norristown District) l

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9.1.2.11 City of Philadelphia, Queen Lane Plant 9.1.2.12 City of Philadelphia, Belmont Plant 9.1.2.13 container Corp. of America Phil adelchia Plant, Mill Dr.

9.1.2.14 ConnelJy Container, Inc.

ant

10.0 REFERENCES

None l'

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