ML20087H442

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Forwards Response to NRC 840306 & 08 Requests for Addl Info Re Emergency Action Levels,Specifically,Containment Radiation Levels.Draft Changes to Emergency Plan Will Be Incorporated as Stated in Encl
ML20087H442
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/16/1984
From: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Schwencer A
Office of Nuclear Reactor Regulation
References
NUDOCS 8403210028
Download: ML20087H442 (80)


Text

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 sHitLDs L. DALTROFF (2151 841 5001

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March 16, 1984 i

Docket Nos. 50-352 50-353 Mr. A. Schwencer, Chief Licensing Branch #2 Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 5UBJECT:

Limerick Generating Station Units 1 & 2 Request for Information from NRC Emergency Preparedness Licensing Branch (EPLB)

Reference:

1) March 6, 1984, Telecon between R. E. Martin, NRC and J. T. Robb, PECO
2) March 8,1984, Telecon between R. E. Martin (NRC PM), J. Sears (NRC/EPLB),

I and H. D. Honan, R. H. Logue, W. J. Knapp & R. Hamilton (PECO)

Dear Mr. Schwencer:

Enclosed are Philadelphia Electric Compa7y's responses to requests for information f rom Mr. John Sears, NRC/EPLB, as conveyed to us in the reference (1) telecon and further specified in the reference (2) telecon.

Where the request for information I

was not contained in the form of a question, we have adapted Mr.

Sears' statement to an appropriate question format.

Therefore, we believe the information provided is fully responsive to each question.

Where responses include draft changes to the Limerick Emergency Plan, such changes will be incorporated into the plan exactly as they appear in the enclosure in the next revision.

Very truly yours, C

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oc Judge Lawrence Br:nner Jtxigo lhtnr A. Morrin iltxk o 1(i(lutral l'. Colo J

l Troy 13. Connor, Jr.,.Ea[.

Ann P. I W %, Esq.

Mr. Frank TL. Itarono Mr. Idrirn I.. Anthony Mr. Marvin 1. Iowin Charlon W. Elljot, Ecq.

'A)ri (1. 1*ork in, 10 xl.

Mr. Thanau Conisky Diroctor, luwi. litonjoney Managmnnt Agency Mr. Steven l'.

Ih rt:lury Angus Invu,10xj.

Mr. Joseph II. Wilitn, III David Wnrnon, Esq.

!Wxtrt J. !itnimisi,10xj.

Spenco W. Perry, Eng.

Jay M. Gutierrna, Esq.

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e QUESTIONS 1 Provide additional information relating to emergency action levels (specifically containment radiation levels).

RESPONSE

The Limerick EAL's for containment rad monitors were originally based on the values applied at Peach Bottom.

The relationships between the containment rad monitors and percent fuel damage (see EP-325) are different for Limerick and Peach Bottom.

For the same R/hr instrument reading the percent fuel damage at Limerick is greater.

The Limerick EAL's have been lowered as shown in the attached draft revisions to Table 4-2.

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For the General Emergency an EAL of 10 R/hr will be used; for l

Site, 4

5 x 10 R/hr; and for Alert, 4

10 R/hr.

Based on the EP-l 325 curves and EP-325-1 table, we believe the 165 R/hr satisfies the IEN 83-28 guidance relating a General Emergency to about 20% fuel damage.

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those responsible for energency direction The classification of events is included in the training ofvents as well as in analyzing events to h

to ensure a conservative approach in clannifying ot er e Counties actify county and (1) deterutno potential for the situation to becmae worse.SRP contacts the plant for a technical s (2) PER1 notifies BRP.

EsF advises PERA.

tech spec's, alara sespamme Cards, or a snaicipal officials. Actions for these eveats are prescribed in procedures, (3)

T1stna 1.

re activated.

Emergency c1==ses and events are based apaa BUnzs-0654, REAlso, smalcip combination thereof.

activated.

(4) se'as-sote 5. - Also, researces _seede4 to sepport evacuation are Same as sota 2.

(5) d procedure (7_ Law enforcement agencies respond in accordance with security plan an

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QUESTION 2 l

EP-317 should be provided to NRC.

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1 EP-317 was provided to NRC in December 1983.

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OUESTIONS 3 & 4 I

Describe siren system actuation and notification of public within 15 minutes.

RESPONSE

Per EP-105, notifications are made to the off-site authorities upon declaration of a General Emergency.

This notification includes recommended protective actions.

The off-site agencies then operate in conformance with Annex E, the Pennsylvania Emergency Management Agency-Disaster Operations Plan, to provide protective action recommendationa to the Public.

Annex E, Appendix 8, provides the concept of operations used by the Commonwealth for Public Alert / Notification.

This concept includes determination by PEMA that the sirens should be sounded, coordination with counties to time sounding, activation of system by counties, and EBS broadcast activation.

(See attached).

County Radiological Emergency Response Plan will address activation of the siren system in their next revision.

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i APPENDIX 8 PUBLIC ALERT / NOTIFICATION I.

REFERENCE Commonwealth of Pennsylvania Emergency Broadcast System Plan, January 1981.

II.

DEFINITIONS

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A.

Alert - Caining the public's attention primarily be means of a siren system supplemented as necessary by a route alert system utilizing loudspeakers and door-to-door contact.

B.

Notification - Broadcasting of an appropriate message over the Emergency Broadcast System (EBS) immediately af ter the 4

sirens have been sounded.

C.

Route Alerting - This is a supplement to the siren system and is implemented, as necessary, in the event of siren failure or or to alert persons _or areas which may not be within the sound of the sirens. Route alerting is a municipal responsibility and is to be accomplished by pre-designated route alert teams travelling in vehicles along preassigned routes delivering the following message: "There is an emergency at the Wixed nuclear facility); please tune to your Emergency Broadcast Station."

D.

Sirens or. siren system - Refers to the sirens especially installed in the plume exposure pathway EPZ (approximate ten mile radius around each nuclear power plant) for the specific purpose of gaining the attention of the people during an incident at the plant.

E.

Siren signal - A th ee to five minute steady blast that alerts the public to turn on a radio or television and listen to their 2SS station.

III. PURPOSE 4

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To establish the alert / notification system that will be implemented la rumponse to an iacident at a nuclear power plant.

IV.

SITUATION i

A.

Pf30L is the lead state agency for the'overall coordination of alert / notification in response to an incident.

B.

The alert siren system will be activated from the risk county emergency operations center E-8-1

. CHANGE 3

-NAY 1983

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coNewr UF UPEIMTIONS A.

The Eureau of Radiation Protection (BRP) provides recommendations to PEMA. PEMA will determine the necessity for activating the g

alert / notification system.

B.

At the direction of PEMA, sirens may be sounded:

(a) when there Ju slunificant information that will reassure the public of their safety; (b) when the public is to be informed of a plant status that may lead them to implement specific actions on their own; or (c) when specific actions (to include protective actions) are to be taken by the public.

C.

PEMA will coordinate with the risk counties and involved contiguous states regarding the specific protective action, the specific times for the sounding of sirens and activation of.the EBS system, and the notification message to be used.

D.

At the specific time coordinated by PEMA, each risk county will:

activate the sirens; ensure that municipalities implement route alerting, if necessary; broadcast the notification asssage over the EBS.

E.

EDS stations commence broadcasts-immediately after sirens are sounded.

F.

Immediately upon activation af the public alert / notification system, PEMA will notify the National Weather Service to broadcast a public notification message via the National Oceanic and 4

Atmospheric Administration (NOAA) Weather Radio Station (s) for he the affected area.

G.

Subsequent to the activation of the alert / notification system, PEMA will coordinate the dissemination of follow-up and continuing emorgency public information as detailed in Appendix 15 "Public Education and Information."

VI.

SYSTEM DESIGN OBJECTIVES AND TESTING A.

The minimum design objectives for coverage by the alert /

notification systems are:

1.

Capability for providing both an alert signal (sirens) and an informational or instructional i

message (EBS announcement) to the population on an area-wide basis throughout the plume exposure pathway EPZ within 15 minutes.

2.

The initial alert / notification system will assure direct coverage of essentially 100% of the population within five miles of the site.

3.

Special arrangements will be made to alert the populations within the plume exposure pathway EFZ who may nqt have received the initial alert.

E-8-2 CHANGE 3 M&Y 1983

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B.

The minimum testing requirements for the alert / notification systems are:

1.

The county siren system for the plume exposure pathway EPZ for each fixed nuclear facility will be tested as follows:

a.

A silent test k.11 be conducted every two weeks with appropriate log entry.

b.

A growl test will be conducted quarterly and when preventive maintenance is performed.

c.

A complete cycle test of the alert signal will be conducted annually and in conjunction with the annual full-scale cyarcise, to include broadcast of a test message over the county EBS station.

2.

Each risk county wilJ. provide PEMA with an annual statement certifying that the silent and growl tests were performed.

ATTACHMENTS:

NOAA Broadcast Me'ssages A.

Three Mile Island Nuclear Station B.

Susquehanna Steam Electric Station C.

Peach Bottom Atomic Power Station (PA)

D.

Peach Bottom Atomic Power Station (MD)

E.

Beaver Valley Power Station F.

Limerick Generating Station e

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E-8-3 CRANCE 3 MAY 1983-w w

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QUESTION 5 Is it possible for psrsonnel listed in Table I-l to arrive at LGS within the designated times as stated in NUREG-0654.

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RESPONSE

Table I-l is being reviewed.

Augmentation personnel are being surveyed to ascertain transit times.

This information I

will be provided at a later date.

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March 16, 1984 s

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l QUESTIONS 6 & 8 How are emergency response personnel notified by Shift Supervision?

RESPONSE

Notification to emergency response personnel is performed primarily by telephone thru a fan-out system.

The advantages of this system are simultaneous message delivery, freeing of major personnel to accomplish other duties, verification of contact and response, transfer of vital information to response personnel.

Beepers are provided as a backup contact method.

Past experience at Philadelphia Electric and a review of other utility practices, has indicated that beepers are insufficient alone.

Personnel must call back to verify notification and response, thereby busying telephone lines and personnel answering phones.

Incoming personnel are better prepared if informed of the situation at hand.

If the information is to get to them, it must come from the plant, thus to obtain information before arriving, they tie up vital personnel by calling back to the station.

To use the fan-out to provide information is more efficient.

March 16, 1984

QUESTION 7 Provide a draft of public information brochure.

RESPONSE

The Pennsylvania Emergency Management Agency is presently drafting the LGS brochure.

By agreement with PEMA, PECo distributes this brochure when made available by PEMA for distribution.

A copy of the PBAPS brochure (draft) is attached here for reference.

Format and wording are consistent with PEMA's proposed LGS draft.

March 16, 1984 f

l PEACH BOTTOM ATOMIC POWER STATION

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EMERGENCY INFORMATION FOR 3,

CHESTER, LANCASTER

& YORK COUNTIES Chester County Lancaster County Department of Emergency Services Emergency Management Agency Hazlett Building 14 East Biddle Street Court House West Chester, Pennsylvania 19380 Lancaster, Pennsylvania 17604 York County Emergency Management Agency Court House York, Pennsylvania 17401

important Emergency nformation m For All or Part of the Following Communities

  • s LanCaSter County Chester County Drumore Twp.

Martic Twp..

' Nest Nottingham Twp.'

East Drumore Twp.*

Providence Twp.'

Fulton Twp.

Quarryvi!!e Borough" Little Britain Twp.'

York County Delta Borough Lower Chanceford Twp.'

' Partially located in potential evacuation area.

Fawn Grove Borough

  • Peach Bottom Twp.

" Located outside the emergency planning zone.

Fawn Twp.'

This information is imporrent. Do not discard. Keep in a handy place, such as yourphone book.

soun' ed over the siren system that has been installed d

within an approximate ten-mile radius of the Peach Bottom

Dear Resident:

Atomic Power Station. This signalis a steady three to five minute signal - not a wailing or warbling signal. lf the Alert The following important information and specific Signal is sounded in your community, tune your radio or TV instructions explain what you may be asked to do to one of the County Emergenc't Broadcast Stations. A should a serious accident occur at the Peach Bottom message will be broadcast advising you what action should Atomic Power Station.

be taken. The sounding of the sirens will be monitored by The protective actions described represent specific al oWals. hM a sy fab acWam, msys mu procedures developed by, and coordinated through, wil be alerted by municipal police and firefighters using your state, county and municipal governments. Each mobile public address systems or door-to-door notification, level of govemment has prepared detailed plans to Don't use the telaphone to try to get emergency ensure a safe and coordinated public response to en information. That seldom will bring results and could tie up emergency. It is important that you respond quickly lines urgently needed for emergency operations aimed at but calm'y when notified that protective actions are to be taken.

r protection.

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THIS INFORMATION IS IMPORTANT. Please read the entire section. We recommend that you underline EMERGEfJCY BROADCAST SYSTTEMS or circle the directions for your municipality under AM FM TV "Where to Go" and refer to the map for the routes WPDC 1800 WKRZ 106.7 WGAL CH 8 that will be used. This information should also be WGSA 1310 WlOV 105.1 WLYH CH 15 reviewed with the members of your family.

WLPA 1490 WDAC 94.5 WLAN 1390 WFNM 88.7 County Board of Commissioners WNCE 101.3 WLAN 96.9 WlXQ 91.7 WPTG 90.3 EMERGENCY PLANS YORK COUNTY EMERGENCY BROADCAST SYSTEM AM FM TV State, county and municipal emergency plans have been WHVR 1280 WGCB 96.1 WPMT CH 43 developed and exercised for response to an accident at the WGC8 1440 WHTF 92.7 WGCB CH 49 Peach Bottom Atomic Power Station. The plans were WNOW 1250 WQXA 105.7 designed to coordinate and support emergency actions WSBA 910 WSBA 103.5 that may be necessary should an accident occur.

WOYK 1350 WYCR 98.5 WVYC 88.1 N

How Will You Learn Of CHESTER COWTY EMERGENCY BROADCAST SYSTEM A Nuclear Incident?

AM FM WCOJ 1420 W LIU 88.7 it there is significiant information that could affect your if you have a neighbor who is hard of hearing or visually

'l safety, or if protective actions are required to protect your handicapped, please check to ensure that this neighbor has health and safety, the standard " Alert Signal" will be received the alert and understands what to do.

This emergency information was developed by each county emergency management agency with the support of the Pennsylvania Emergency Management Agency in accordance with state law and federal regulations. This important information was placed in the telephone directory by the Philadelphia Electric Company,in cooperation with your county government.

School students will be relocated to identified host

,s schools. See the " School Section" in this brochure for specific information.

If You Are When. instructed to leave, secure your home as you Told To Take Shelter would for a three-day trip.

Should you be directed to take shelter (remain indoors),

thers will be several things you need to do:

- Close all outside doors and windows. This will help to keep out any radioactive materials which may be What to Take With You outdoors.

. You should plan to spend a ruinimum of three days away

- Turn of f air intakes such as fans and air conditioners.

from home. Bring only essential items and avoid excess baggage. Take only what you need and then in small

- If you have come in from outside, wash your face and quantities.

hands, particularly before you handle or eat any food.

Suggested items to take:

P.eferably, take a shower and wash any clothes you

- Clothing appropriate for the season were wearing while outside.

- Sleeping bags or blankets

- Take precautions with food. Immediately cover up or

- Prescription drugs put in your refrigerator any "open" foods not in covered

- Personal care items containers. This will keep any radioactive materials

- Baby s.upplies which might seep into the house from contaminating foodstuffs. While anything in cans, bottles or other For sanitary teasons pets will not be allowed.enside mass sealed containers will be safe to eat or drink, containers care centers. You are responsible for their care.

should be thoroughly washed before opening.

-- Keep pets inside, and to the extent possible shelter farm animals.

If You Need

- Keep your radio or TV turned on and listen for further Transportation emergency instructions.

If you are instructed to evacuate and you do not have

- Don't use the telephone -- leave lines open for transporiation, attempt to obtain a ride with neighbors, a emergency communications, friend or a relative who lives nearby.

- Persons traveling within the area in motor vehicles if this is not possible, transportation can be arranged by

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should roll up windows and close air vents.

calling your mur'icipal Emergency Management Agency.

For telephone numbers see the "Where To Go" saction in

- Those not at home should tske the best available this brochure.

shelter.

Stay indoors until you receive of ficial notice that it is safe to go out. Special arrangements will be made by state, s

county and municipal officials to take care of school SCHOOL INFORMATION bhililmbi children and hospital patients.

Parents of children attend.ing schools w. thin the i

emergency planning z ne are urged NOT to call or go to the Farm Animals Farmers affected by a Take Shelter or Evacuation schools when protective action recommendations, such as advisory should shelter their animals and contact their sheltenng or evacuation, have been issued. Th,s would i

county USDA agricultural agent for further instructions nly add confusinn ar,d could hinder school authorities regarding protection of !!vestock and foodstuffs.

fr m the special provisions that have been made to protect your children.

If school is in session at the time evacuation is EVACUATION INFORMATION recommendad, children attending schools located within if it is nece ssary to evacuate an area, you will be in formed the emergency planning zone will be transported by bus to by an announcement on your EBS Station. The message designated host schools outside the area. They will remain willinclude any special instructions which might be called there under school supervision until picked up by parents or for by the particular situation.

guardians. These Student Pick-Up Points have been planned to coincide with main evacuat,on routes.

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, Special arrangements will be made to take care of the Students whose homes are inside but who atter$d school sick and the disabled.

outside the emergency planning zone will not be sent home if an evacuation is advised. They will remain at the school they attend under school supervision until picked up by if You Are Told To Evacuate parents or guardians.

If you are advised to evacuate, follow instructions Spec!fic information conceming Student Pick-Up Points promptly and carefully. The msp !dentifies main evacuation will be provided to parents by school officials. lf your child's routes. Also see the "Where To Go" section in this schoolis subject to evacuation and you are not aware of the brochure which describes, by municipality, where you designated pick-up point, contact the school principal or should go for temporary accommodations and the school district superintendent and request this important highways to use.

information now. Don't wait!

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l CHESTER COUNTY - Where To Go Example West Nottingham Township Local routes to Route 1 North to PA 896 l

Municipality South to PA 131 South to:

l Routes avecuaten routes controned by police Lincoln University l

l tar effe nt movement oui of your area. once ovis.d*

(215)932 4072 the t o-mie Emergency Manneg Zone, use appropriate routes 'o your de tmation. If you need a temporary place to stay, conteus on the designated Evacuation Route to the identified Reception Center i Reception Center caeport to the ident.f.ed Receptin Center of youneed a temporary place to stay At the Recepten Center you wsN be given directions to a fled Cross Mass Care Center nearby 1 Transportation Assistance temergercy telephone numbers for those an need of transporatson assistance only )

LANCASTER COUNTY - Where To Go Martic Township Fulton Township Little Britain Township Take local Routes to Route 324 East to Take local Routes to Route 272 North to Take Route 222 Notth to Penn Grant Road Long Lane East to Route 222 South to Penn Grant Road East to Sandstone Road West to Sandstone Road North to:

Hands Herr Road to:

North to:

Willow Street Vo-Tech Schoolin Willow Willow Street Vo Tech Schoolin Willow Willow Street Vo-Tech School in WJ!ow Street Street Street (717)529-2323 (717)284-2167 (7171548-3514 East Drumore Township i

Quarryville Borough Drumore Township Take Route 222 North to Penn Grant Road Take Route 222 North to Penn Grant Road Take local Routes to Route 272 North to West to Sandstone Road North to:

West to Sandstone Road North to:

Penn Gra7t Road East to Sandstone Road Willow Street Vo-Tech School in Willow Willow Street Vo-Tech School in Willow North to:

Street Street Willow Street Vo Tech School in Willow (7171786-4544 (717)786 2898 Street (717)284-2948 Providence Township Take local Routes to Route 272 North to Penn Grant Road East to Sandstone Road North to:

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Hiiew Street Vo-Tech Schoolin Willow Street (7171786-7596 YORK COUNTY - Where To Go Delta Borough Fawn Grove Borough Lower Chanceford Township Take Main St. south to Maryland Route Take Route 851 West to Route 616 North Take local Routes to Route 74 North to:

136 West to PA Route 624 North to PA to:

Red Lion Senior High Schoolin Red Lica Route 851 West to PA Route 616 North Susquehannock High Schoolin Glen Rock (7171862-3806 to:

(7171382-4432 Susquehannock High Schoot in Glen Rock Peach Bottom Township (717)456-7133 Fawn Township Take local Routes to Route 851 West to Take local Rotates to Route 851 West to Route 616 North to:

Route 616 North to:

Susquehannock High Schoolin Glen Rock Susquehannock High Schoolin Glen Rock (7171456-7133 (717)382-4432 unicipalities with an asterisk are partially located in the potential evacuation area. See map in this brochure.

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, s How Are Accidents Classified?

What IS Radiation?

Should an accident occur at the Peach Bottom Atomic Nuclear radiation consists of energy in the form of Power Station, there are four accident classifications you invisible particles or rays given off by radioactive material.

might hear reported on radio, T V or read in the newspapers.

Small amounts of radioactive material occur naturally and So that you will understand their meaning, they are always have been part of man's environment. Radioactive,

explained in the order of their potential seriousness:

materials in varying amounts are present la the earth's Unusual Event - Unusual events are in process or crust, the sun's rays, the air we breathe, the food we eat have occurred which indicate a potential degradation and the water we drint As a result, every person has of the level of safety of the plant. No releases of radioactive materials within his body. Larger amounts of radioactive material requiring offsite response or radioactive materials are produced by and contained within monitoring are e xpected unless further degradation of a nuclear power plant.

safety systems occurs.

Man's use of radioactive materials also results in Alert - Events are in process or have occurred radiation exposure. For example, doctors and scientists which involve an actual or potential substantial have utilized X rays in medical treatment for many years.

degradation of the lavel of safety of the plant. Any The amount of radiation a person receives is measured in releases are expected to be limited to small fractions terms of radiation dose. Ths unit used to measure this dose of the Prctective Action Guideline exposure levels is called a mi//irem.

established by the Federal Environmental Protection The following table shows examples of typical radiation Agency (EPA).

doses due to natural rad;oactive materials or man's use of Site Emergency - Everits are in process or have radioactive materials compared to the worst estimated occurred which involve actual or likely major failures exposure received by an individual during the TMI-2 of plant functions needed for protection of the public, accident in 1979.

Any releases are not expected to exceed EPA Protective Action Guideline exposure levels except Millirem near the plant boundary.

Source Per Year General Emergency - Events are in process or have occurred which involve actual or imminent Color television 1

substantial core degradation or melting with potential Airline travel (typical airline passenger who 3

for loss of containment integnty. Releases can be makes 10 flights per year) reasonably expected to exceed EPA Protective Action Natural radioactive materials w.thm. the i

Guideline exposure levels offsite for more than the body 20 immediate plant area.

l Medical X rays (average patient) 20 Cosmic rays 27 Naturcl radioactive materials in the earth 46 Maximum offsite exposure during TMI RUMOR CONTROL TELEPHONE NUMBERS accident 70 "The Effects on Populations of Exposure to Low Levels of lonizing CHESTER COUNTY - (215) 4316480 Radiation." National Academy of Science,1980.

LANCASTER COUNTY - (717) 299-8378

  • Re n ome mesident's conunen on the accident amee me YORK COUNTY - (717) 854-5571 Island. October 1979 Page 32.

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-.1 QUESTION 9 4

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How will contention resolution be incorporated into the plan?

RESPONSE

s As the contentions are resolved by litigation, results of the litigation will be incorporated as revisions to the plan i

where applicable.

No plans exist for incorporating testimony i

into the emergency plan.

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March 16, 1984~

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QUESTION 10 What provisions will be made for thyroid " screening" of site personnel upon evacuation?

RESPONSE

The merits of ',' screening" site evacuees for thyroid uptake of radiciodine has been reviewed.

It may be argued that such screening will serve to reassure the evacuees.

It can be argued just as well that subjecting people to unnecessary monitoring would cause them to wonder whether a problem actually existed.

Others would resent the apparent harassment and delay in "getting home".

Assuming there was a need to evacuate non-emergency site personnel, such a decision would be made and implemented long before significant levels of airborne activity were reached.

Time of potential exposure would be short - an hour or so; therefore, intake of radiciodine would be low.

The time for the body to metabolize iodine to the thyroid would not be rapid enough for screening to detect radioiodine in the thyroid.

Our position is that the screening is not warranted because there would be nothing to detect.

The potential benefits would be very low and indeed there may be some adverse consequences.

March 16, 1984

QUESTION 11 Provide letters of agreement for technical support including Bechtel, General Electric, INPO.

RESPONSE

Philadelphia Electric is presently obtaining letters of agreement from Bechtel and General Electric.

When these letters are received and reviewed, they will be available for inclusion in the plan.

The letters specify notification procedures, responsibilities and authorities.

The Institute of Nuclear Power Operations agreement letter is attached for your use.

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I March 165 1984

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Institute of

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Nuclear Power

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Operations t. o....;ou 1100 Circle 75 Parkway Suite 1500 Atlanta. Georgia 30339 Telephono 404 953-3600 f

October 19, 1983 If7 N Mr. Shields L. Daltroff M

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,g Electric Production Philadelphia Electric Company

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Philadelphia, Pennsylvania 19101

Dear Mr. Daltroff:

This letter is provided to assist those utilities committed through the regulatory process to update their emergency preparedness letters of agreement annually and to outline INPO's role in the event of an emergency at a member utility's nuclear power plant.

INP0 will assist the affected utility by quickly applying the resources of the nuclear industry in meeting the needs of the emergency.

INPO, when notified of an emergency situation, will provide any resources under its authority in response to Philadelphia Electric Company's radiologi-cal emergencies, as requested. Such situations are equivalent to the " alert,"

" site," and " general" emergency conditions, as defined by NRC. Utility emer-gency response planning should include notification of INP0 via the dedicated emergency call number for these situations.

INPO will be able to provide the following emergency support functions:

assistance to the affected utility in locating sources of emergency a.

manpower and equipment b.

dissemination of information to member utilities concerning the incident applicable to their operations organization of industry experts who could advise the utility on tech-c.

nical matters To support these functions, INP0 shall maintain the following emergency support capabilities:

dedicated emergency call number capable of reaching designated INP0 a.

staff and activating INPO support functions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days per week 4

I l

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5 October 19, 1983 Page Two i

b.

designated INPO representative (s) who can be dispatched quickly to the utility emergenc/ response organization to coordinate INPO support activities and information flow 2

c.

24-hours-a-day operation of an emergency response center at INPO l

The dedicated emergency call number is (404) 953-0904,- and the alternate i

emergency call number is (404) 953-0922. An INPO duty officer will respond to the call, and the Emergency Response Center at INPO will be activated, as necessary.

4 When you call the emergency number after hours, an automatic dialing system will answer and give you the message on Attachment A, or an answering service will request this information and page the duty officer.

If requested by the utility, one or more suitably qualified members of INP0's technical staff will report to the recovery manager and will assist his staff in coordinating INPO's response to the emergency as follows:

)

a.

staffing a single position responsible to the appropriate utility manager as liaison for ali INPO matters b.

Working with the INPO duty officer in Atlanta-to coordinate all requests for assistance, INPO response, and related communications i

l' c.

assisting the utility as requested in initiating and' updating entries i

into industry information systems (such as NOTEPAO) concerning the accident status and related information of value to other utilities d.

ensuring that all emergency information released by the INPO liaison is cleared properly and formally through appropriate utility channels -

An INFO representative normally shall be capable of being dispatched on approximately four-hour notice.

l-Upon request in an emergency, INPO will provide assistance'to the-affected utility in locating and arranging additional emergency manpower, equipment, and the services of various technical experts from industry sources.

~

Analysis of operational-factors relat1ng to plant incidents will be initiated as directed in an emergency.by the president of INPO. f0n-site activities, when undertaken, will be coordinated with the on-site INPO repre-sentative.

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October 19, 1983 Page~Three To assist the utility as irdicated above, INPO requires the following action and/or information from the utility:

a.

controlled copy of.the utility's emergency plan and procedures b.

addition of INPO to' yobr mergency notification list for actual

,emergenc es and exercises at the " alert" and above action levels i

prioNnotificationofemergencydrillsandexercisessoINP0maysend c.

observers to the drill or exercise This agreement shall be effective untti such time as regulations of NRC/ FEMA permit modification or terminatian.

If'you-have any questions or comme'nts concerning INP0's role in an emer-gency, please let me know.

Sincerely,

~

P. W. Lyon Director Radiological Protection and Emergency Preparedness Division PWL:jke

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t cc: Mr. W. T. Ullrich INPO Board of Directors J

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ATTACHMENT A t

THIS IS THE INPO EMERGENCY RESPONSE CENTER THE DUTY OFFICER WILL BE PAGED AND WILL RETURN YOUR CALL AS SOON AS POSSIBLE. AT THE TONE PLEASE LEAVE:

(1) YOUR NAME, TELEPHONE NUMBER, AND PLANT NAME (2) IS THIS AN ACTUAL EMERGENCY OR DRILL (3) HOW INPO CAN HELP YOU (4) REPEAT YOUR AREA CODE AND TELEPHONE NUMBER THANK YOU.

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QUFSTION 12 What is the criter'.a for declaring that the emergency is over and that the plant is in the recovery stage?

RESPONSE

A draft of Limerick emergency ir.plementing procedure EP-410 is attached.

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1 March 16, 1984

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1%R.08 '84 15:39 FECO HQ EMERG SUP CNTR 7TH FL GP 410 P.01 Rev. 0 Page 1 of 7 RAKrkmw tONTROLLED_ APPROVED COPY-

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VolD. PREVIOUS lSSUEN Philadelphia Electric Company

?:::h 2:tta-Units and !

i l & 2-EP-Ato _ W EF-v-320 Recovery Phase Implementation

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Purpose This procedure provides guidance for implementing a recovery effort following an emergency.

For an Unusual Event or Alert only minor recovery actions should be required.

However, for the emergencies with more severe consequences Site and General complex recovery actions may(be required.

Emergencies),

Reference s fe-,.a. &nfM

1. A Emergency Plan, Sectton-5T4 2.

NUREG 0654, Section M. 2 and M. 3 3.

EP-C-203 4,r

'a, wic-drwery *-~s,,Afen Action Level, 1.

The Emergency Director, the Site Emergency Coordinator, Emergency Support Officer, the Senior Vice President -

Nuclear Power wil1 decide when an on-site recovery offort is required.

Federal / State hvernment Liaisons should be appraised of the decisaon to enter the recovery phase.

2.

The following guidelines should bs used to determine when the emergenc implemented:y is under control and a recovery effort may be Radiation levels.are steady or decreasing with time.

a.

b.

Any release of radioactive materials to the environment has ceased or is controlled within technical specification limits.

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  • s MAR.08 '84 15:41 PECO HQ EPERG SUP CNTR 7TH FL gg gf.g0 P.02 Rev. 0 Page 2 of 7 RAKtkmW 6/10/82 l

c.

Fire, flooding, or similar emergency conditions no longer' constitute a hazard to the plant or plant personnel.

d.

Measures have been successfully taken to correct or compensate for malfunctioning equipment.

e.

Reactor core is being adequately cooled.

Procedure 1.

Initiate a conference call between Emergency Support officer, Site Emergency Coordinator, Emergency Director and Senior Vice President - Nuclear Powel.

2.

Analyze reactor, containment, and critical system status using the attached plant status sheet.

The reactor, containment, and critical systems should be analyzed for present condition and capability to perform intended functions.

(Refer to Appendix A) 3.

Develop a list of acceptable or unacceptable plant conditions and systems or equipment failures.

Identify corrective actions to be taken.

(Refer to Appendix B).

Based upon the analysis of these plant conditions, decide whether entry into the recovery @ase is justified.

If recovery justified, proceed to the steps below.

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Review the plant status with the NRC, FEMA,A PENA,-a #

JLEMCR4 and address their concerns.

The Site Emergency Cocedinator should notify all parties listed i'n the EP-105 am"1"dD call list appendix of the intent to enter into the recovery phase.

6, When the ascovery phase is formally implemented, the Recovery manager should obtain the assistance of the Site Emergency Coordinator, Energency Director, and Denior Vice President - Nuclear Power 'in resolving the,following recovery instructions.

(a) Review the Recovery Acceptance checklist ( Appendix B) and determine the priority of recovery work.

(b) Prepare an outline of major tasks and establish the organisation responsible for implementation.

(c) obtain participation of General Electric, Bechtel, catalytic and other firms as appropriate.

O

g-4to t1M.08 '64 15:43 PECO HQ Et1 ERG SUP CNTR 7TH FL J/3 -d 09 P.03 Rev. O Page 3 of 7 RAK:kmW 6/10/82 (d) Establish a schedule for monitoring plant parameters, such as reactor coolant, drywell atmosphere, liquid and gaseous effluents, etc.

(e) Verify personnel radiation exposures received during accident conditions.

(f) Review and assess plant accident events, data logs, etc.

to develop a comprehensive accident report and a recovery plan summary for submittal to regulatory agencies.

(g) Consider available manpower sources and arrange through headquarters or the Planning Coordinator necessary l

personnel.

(Work through INPO as necessary).

(h) Review emergency and plant supplies as well as warehouse atock levels to ensure inventories are returned to pre-emergency levels.

(1) Establish what activities will require procedures and develop them accordingly.

(j) Determine the number of personnel needed to continue

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maintaining the plant.

(k) Establish an Environmental monitoring schedule.

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t%R.03 '84 15:45 PECO HQ EMERG SUP CNTR 7TH FL P.04 Mev. U Page 4 of 7 RAK:kmw 6/10/82 Appendix B UNIT #_ RECOVERY ACCEPTANCE CH3CKLIST A.

Reactor Parameters Acceptable Unacceptable Remarks 1.

Power 2.

Level 3.

Pressure B.

Containment Parametcra Acceptable Unacceptable Remarka 1.

Drywell Press 2.

Drywell Temperature gartf5 Level [

3.

T g Temperature h w O 4.

5.

Cont. Oxygen 6.

Cont. Hydrogen C.

Reactivity Control Acceptable Unacceptable Remarks 1.

Control Rods 2.

SBLC-D.

Pressure Control Acceptable Unacceptable Remarks l

1.

Bypass valves 2.

SRV's l

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M.:n.09 '84 15:46 PECO HQ D1 ERG SUP CNTR 7TH FL F fI h

P.05 SP-C-120 Rev. O Page 5 of 7 RAKakmw 6/10/82 E.

Level Control and Heat Removal Acceptable Unacceptable Remarks 1.

Feedwater 2.

CRD 3.

HPCI 4.

BCIC 5.

Condensate 6.

Core Spray 7.

RHR S/D Cooling 8.

LPCI 9.

H PSW 10.

Cond. Transfer 11.

Refuel Transfer 12.

E!M 13.

SBLC F.

Tank Levels tcceptable Unacceptable Bemarks 1.

C ST 2.

RST 3.

%pmif"Dewater Tank 4.

Main Condenser 5.

Emerg. Cool. Tower G.

Containment Control Acceptable Unacceptable Remarks

i t%R.08 '84 15:48 PECO HQ EMERG SUP CNTR 7TH FL P.06 l

Rev. O I

Page 6 of 7 l

RAKakmw s

6/10/82 (2.1-1.

Cooling

2. j w.--C7A jbauer Spray 3.

D/W Spray l*

4.

SBGTS H.

Containment Isolations Acceptable Unacceptable Remarks 1.

GRP I 2.

GRP II 3.

GRP III 4.

GRP IV 5.

GRP V I.

Power Supplies Acceptable Unacceptable Ramarks 1.

Offsite #2 2.

Offsite #3 3.

El Diesel 4.

E2 Diesel 5.

E3 Diesel 6.

E4 Diesel 7.

El Bus 8.

E2 Bus 9.

E3 Bus 10.

E4 Bus l

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MAR.08 '84 15:50 PECO HQ EMERG SUP CNTR 7TH FL 8

P.07 Rev. 0 Pge 7 of 7 RAKakmw 6/10/82 J.

Radiological Parameters Acceptable Unacceptable Remarks 1.

Medin St2ck Release

.bul4 2.

W Stack Releases 3.

D/W Rad. Monitor Level 4.

Refuel Floor Whaust 5.

Radwaste Exhaust 6.

Air Ejector /Off Gas Release 7.

Main Stack Flow 8.

Vent Stack Flow K.

Meteorological Parameters Acceptable Unacceptable Remarks 1.

Wind speed 2.

Wind direction 3.

Precipitation i

4.

Stability Class L.

Regulatory Contact Acceptable Unacceptable Remarks 1.

NIC 2.

PEMA 3.

FEMA W

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APPEND]J !,

y 4dshammL PLAF STNPUS - UNIT #

SHEET m.

l REACTOR n.dAMETERS - time RADIOLOGICAL PARAMr?FFAi - time METERDI4X.TCAL PARAMETERS - time N.:n

1. Power
1. Mnst Stack cps ar/hr
1. Avg. Wind Speed uph
2. Level inches
2. I/^ --.- _

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2. Avg. Wind Direction (from) i-
3. Pressure PSIG
3. U/? "

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3. Avg. Radiatien rds.

y/hr

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h. D/W Rad Monitor R/hr
k. Avg. Ambient Temp.

F m

CONTAIMEET PARAMETERS - time

5. Refbel F1r Exh mr/hr
5. Precipitation g

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6. Air Eject Off Cas ar/hr
6. Stability Class 6

F o

7. Radwaste Monitor cre
7. Avg. Wind Speed (320)

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2. Drywell Temp.

F

8. Jhan Stack Flow CFM
8. Avg. Wind Speed (75)

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3. Drywell Press.

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b* Containment NV81

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6 REACTIVITY CONTROL - time LEVEL COFPROL - time CONTAIBGNP COlFPROL - time

1. # of roda not inserted past 06 SYSTDi INJ UNAVAIL/HEASON RHR TOHUS TORUS D/W S/D UNAVAILA P. W.

A COOL SPBAY SPRAY COOL RRASON p, m m

m y m /nua w C

B o

g CRD A

C

3. SBIE Tank Level B

D BPSW ON UNAVAIL/ REASON N

A P

ymL9pmu COM14DL - time COND A

B

1. # Bypass Yalves Open C

c D

2.

SRYS A B C D E F CIE J K L C. S.

A DPEN i

B ISOMOE Im/meOBS 3IASED l l l

C GHP I D

II LPCI A

POWER SUPPLTER - time B

GHP V INNHICE SUPPLYIM',

UNAVAIL/puan M N

B SBCTS ON UNAVAIL/ REASON B-1 W2 COND TRANG C

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REFUEL T2ANS TRAIN A SBIE B

to POWER SUPPLY l

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QUESTION 13 Describe locations of pre-selected offsite sampling points.

RESPONSE

Proposed sampling sites are being developed.

A map indicating prospective sampling locations will be provided at a later date.

These maps will be provided to personnel responsible for off-site sampling.

The Commonwealth Plan commita Bureau of Radiation Protection to sample the Ingestion Exposure EPZ.

a March 16, 1984

~

QUESTION 14 Provide an updated evacuation time study for NRC review.

RESPONSE

This evacuation time study is underway with completion o

expected in about 4 weeks.

Copies will be provided when available.

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9 QUESTION 15 Describe dispatch of fire companies.

RESPONSE

As presently stated in the procedures, Linfield Fire Company is called by Shift Supervision in the event of a fire.

The fire company recently switched to county dispatch.

LGS procedures will be modified to reflect this.

An agreement letter has also been obtained with Limerick Fire Company.

Thus in the event of a fire at LGS, County dispatch would then send Linfield or Limerick Fire Companies or both to the site.

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i March 15, 1984

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