ML20091N628
| ML20091N628 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/08/1984 |
| From: | Cullen E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Mulligan M LIMERICK ECOLOGY ACTION, INC. |
| References | |
| OL, NUDOCS 8406120390 | |
| Download: ML20091N628 (85) | |
Text
M.e RELATED C0r.F,ES?ONDENCE
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e-PHILADELPHIA ELECTRIC COMPANY c:c xg.r.
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-2301 MARKET STREET P.O. BOX 8699
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,,,,vult; p 'd3 PHILADELPHIA. PA.19101 C Dw ARO G. s AU ER. J R.
(2151841-4000 C -.
N*e'e7m'a'n'a'6 c'ounsa6
'NIlhfi2f"e5 R b(M fiUG ENE J. GR ADLEY assessava essamme, covsess6 DON ALD SLANKEN EUDOLPH A. CHILLEMI C. C. KIR K H ALL T. H. M AH ER CO RNELt.
June 8, 1984 PAUL AUERBACH assaavasov eussama6 sousess6 EDW ARD J. CULLEN. J R.
THOM AS H. MILLER. J R.
13 EN E A. M t K EN N A assesvase? ecumss6 Ms. Maureen Mulligan Limerick Ecology Action 762 Queen Street Pottstown, PA 19464 lte: Limerick Generating Station, Unir.s 1 and 2
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Docket Nos. 50-352 & 50-353 C L.
Dear Ms. Mulligan:
In accordance with the Board's Order of June 1l 1982, I am forwarding to you copies of correspondence and documents regarding emergency planning among Applicant, HRC Staff, the Commonwealth of Pennsylvania and other responsible governmental agencies. These documents supplement the material which was forwarded by our letter dated June 1, 1984, and provide additional correspondence covering the period May 29, 1984 through June 4, 1984.
Very truly yours,
'O Edward J. Cullen, Jr.
EJC,Jr./pkc encs.
cc: See Attached Service List 0000g/0006q 8406120390 840608 PDR ADOCK 05000352 G
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cc: Judge Iawrence Brenner (w/o encl 1sure)
Judge Peter A. Morris (w/o enclosure)
Judge Richard F. Cole.
(w/o enclosure)
Troy B. Conner, Jr., Esq.
(w/ enclosure)
Ann P. Hodgdon, Esq.-
(w/ enclosure)
Mr. Frank R. Romano (w/o enclosure)
Mr. Robert L. Anthony (w/o enclosure)
Zori G. Ferkin, Esq.
(w/ enclosure)
Mr. Thanas Gerusky (w/o enclosure)
Director, Pennsylvania Emergency (w/o enclosure)
Management Agency Charles W. Elliott, Esq.
(w/o enclosure)
' Angus Inve, Esq.
(w/o enclosure)
David Wersan, Esq.
(w/o enclosure)
Robert J. Sugarman, Esq.
(w/o enclosure)
Martha W. Bush, Esq.
(w/o enclosure)
Spence W. Perri, Esq.
(w/o enclosure)
Jay M. Gutierrez, Esq.
(w/o enclosure)
Atomic Safety & Licensing (w/o enclosure)
Appeal Board Atomic Safety & Licensing (w/o enclosure)
Board Panel Docket & Service Section (w/englosure)
James Wiggins (w/o enclosure)
Timothy R. S. Campbell (w/o enclosure)
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ENE3GY CONSULTANTS
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RIVERSIDE CFFICECENTER3 2101 N. FF.ONTST. / HARRISBURG / PA 17110 / PH.(717)236 0031 CORPORATEOFFICE: 101 SEVENTH STREET / PGT3BURCH PA l5002 3487 / PH.(412)434 5200 May 29, 1984 Mr. Don Taylor, Director Office of Training and Education Pennsylvania Emergency Management Agency Post Office Box 3321 Harrisburg, PA 17105
Dear Mr. Taylor:
Please find enclosed a copy of Energy Consultants' training schedule for the Limerick offsite emergency preparedness effort for the month of June.
Additional classes may be added to this list.
Feel free to contact Bob Patterson or me with any questions.
Sincerely, Robert T. Bradshaw Limerick Project Coordinator RTB:fr Enclosure
h ENERGY CONSUIJM:S RIVERSIDEOFFICECENTER3/ 2101 N. FRONTST. / HARRISBURG / PA 17110 / PH.(717)236 CC31 CORPORATE OFFICE: 1.'.l SEVENTH STREET. P!TTSBURGH t PA 15222 J 187 / PH.(il21131-5000 May 29, 1984 Mr. Robert L. Reber, Director Berks County Emergency Management Agency Berks County Agriculture Center Leesport, PA 19533
Dear Mr. Reber:
Please find enclosed a copy of Energy Consultants' training schedule for the Limerick offsite emergency preparedness effort for the month of June.
Additional classes may be added to this list.
Feel free to contact Bob Patterson or me with any questions.
Sincerely, Robert T. Bradshaw Limerick Project Coordinator RTB:jr Enclosure a
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%;// j ENERGY CONSUllMNTS RIVERSICEOFFICECE.VTER 3 210l N. FRONTST i HARRISBURG / PA 17110 / PH.I717)235-0031
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CORPORATE OFFICE: 121 GEVENTH STREET ' PITTSBURGH / PA 1522^ 3487 / PH.W12M34 5:00 tiay 29,1984 Mr. A. Lindley Bigelow Montgomery County OEP/ EMS 100 Wilson Boulevard Eagleville, PA 19403
Dear Mr. Bigelow:
Please find enclosed a copy of Energy Consultants' training schedule for the Limerick offsite emergency preparedness effort for the month 0
of June.
Additional classes may be added to this list.
Feel free to contact Bob Patterson or me with any questions.
Sincerely, Robert T. Bradshaw Limerick Project Coordinator RTB:jr Enclosure l
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ENEHGY CONSULTANTS RIVERSiOE CFFICECENTER3/ 21Cl N. FRONTST. / HARRISBURG / PA 17110 / PH.(717)236 Cc31 CORPORATE OFFICE: 1:l SEVENTH 3TREET, PiiT3BURCH ! PA 15220 JI87 / PH.Ml2H34 520t1 i
May 29, 1984 Mr. Timothy R. S. Campbell Director Chester County Department of Emergency Services 14 East Biddle Street West Chester, PA 19380
Dear Mr. Campbell:
Please find enclosed a copy of Energy Consultants' training schedule for the Limerick offsite emergency preparedness effort for the month of June.
Additional classes may be added to this list.
Feel free to contact Bob Patterson or me with any questions.
Sincerely, Robert T. Bradshaw Limerick Project Coordinator RTB:jr Enclosure
ENERGY CONSULTANTS x\\'
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RIVERSIDEOFFiCECDiTER3 21:1 N. FRCNTST. / HARRIS 3URG / PA 17110 / PH.(7171226-Co31
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CORPORATE OFFICE: ! : SE*/E.':TH STREET PITTSBURCH. PA 15222-3437 / PH.tal?.M34-5:00 May 29, 1984 Dr. Donald F. Taylor, Director Office of Training and Education Pennsylvania Emergency Management Agency Post Office Box 3321 Harrisburg, PA 17105
Dear Don:
This letter serves as a confirmation of,the Radiological Monitoring Instruc-tar training sessicn you have offered to conduct for us on Thursday, May 31.
The class is scheduled for 9:00 to 11:30 a.m. in the Training Room at Energy Consul tants. Our offices are located in Building 3 at 2101 North Front Street.
Upon arrival, please use the lobby elevator to reach our offices on the second floor.
Eighteen members of our staff have cc.mpleted the eight-hour practical appli-cation course and are scheduled to attend your session on May 31.
If you require any equipment or supplies beyond an overhead projector, pleast let me know.
I would like to take this opportunity to express our appreciation for your efforts to provide this training sessi6n. We look forsard to receiving your Radiological Monitoring Instructor program.
Sincerely, b
Lut.
Jaw U
A Robin Hoffman Wenger Training Services Coordinator RHW:jr 4
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LIMERICK OFFSITE TRAINING SCHEDULE JUNE 1984 PROJECTED SESSION LOCATION DATE TIME TYPE TRAINEES 1-Eagleville Hospital 6/1 2:00 pm Health Care 15 2
Red Hill 6/2 1:00 pm E0C II 18 3
Narco F0 6/4 7:00 pm EW II 22 4'
Schwenksville Borough.
6/4 7:30 pm EOC II 8
5 Lower Frederick Township 6/4 7:00 pm E0C II 12 l
6 River' Crest 6/4 1:00 pm Health Care 20 l
7 Phoenixville Hospital 6/5 9:00 pm Health Care 20 l
8 West Vincent Township 6/5 7:00 pm EOC II 10 l
9.
Amity FD 6/5 7:00 pm EW I 35 l
10 Phoenixville Manor 6/6 1:30 pm Health Care 20 L
l 11 East Pikeland Township 6/6 7:00 pm E0C II 8
l 12 Boyertown' Borough 6/6 7:00 pm E0C II 12 i
13 Royersford Borough 6/7 7:00 pm EOC II 10 14 Lehigh County 6/7 7:00 pm E0C II 20 15 Eagleville Hospital 6/7 TBD Health Care 30 l
16 Eagleville Hospital 6/7 TBD Health Care 30 17 Eagleville Hospital 6/7 TBD Health Care 30 l
18 Eagleville Hospital 6/7 TBD Heal th Care 30 19 Eagleville Hospital 6/7 TBD Health Care 30 20 Eagleville Hospital 6/7 TBD Heal th Care 30 l
21 West Pottsgrove Township 6/7 6:30 pm EOC II 8
22 Perkiomen Township 6/7 7:00 pm E0C I 6
i 23 Plymouth Ambulance 5/7 7:00 pm EW II 18 L
24 Boyertown High School' 6/11 9:15 am Bus Drivers 50 25 Boyertown High School 6/11 12:15 pm Bus Drivers 50 26 Norco VFD 6/11 7:00 pm-EW II 22
'27 Bryn Athen Ambulance 6/11 7:00 pm EW II 35 28 Washington Township 6/11 7:00 pm E0C II 6
29 New Hanover.
6/11 7:00 pm EOC II 8
30 Amity FD 6/12 7:00 pm EW II 35 31 Ridge FD 6/12 7:00 pm EW I 25 32 Frederick Mennonite Home 6/13 TBD Health Care 20
-33 Frederick Mennonite Home 6/13 TBD Health Care 20 34 Frederick Mennonite Home 6/13 TB0 Health Care 20 35 Frederick Mennonite Home 6/13 TBD Health Care
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'36 Frederick Mennonite Home 6/13 TBD Health Care 20 37 Leader Nursing Home 6/13 TBD Health Care 20-38 Leader Nursing Home 6/13 TBD Health Care 20 l
39 Leader Nursing Home 6/13 TBD Health Care 20 l
40 Leader Nursing Home 6/14 TBD Health Care 20 41 Leader. Nursing Home 6/14 TBD Health Caro 20 42-Leader Nursing Home 6/14 TBD Health Care 20 43 East Nantmeal Township 6/14 7:30 pm EOC I 10 44 Perkiomen Township 6/14 7:00 pm EOC II 6
45 Upper Salford FO 6/14 7:15 pm EW I 30 46 Frederick Mennonite Home 6/15 9:30 am Health Care 15 47 Leader Nursing Home 6/16 TBD Health Care 20 48 Leader Nursing Home 6/16 TBD Health Care 20 49 Leader Nursing Home 6/16 TB0 Health Care 20
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LIMERICK OFFS!TE TRA!NING SCHEDULE - JUNE 1984 - 2 PROJECTED SESSION LOCATION DATE TIME TYPE TRAINEES 50 Lower Frederick Ambulance 6/16 9:00 pm EW I 18 51 Royersford FD 6/17 7:00 pm EW I 38 52 Earl Township FD 6/17 7:00 pm EW I 30 l
-53 Pottstown Medical Center 6/19 7:30 am Health Care 55
'54 Pottstown Medical Center 6/19 9:00 am Health Care 55
'55 Pottstown Medical Center 6/19 10:30 am Health Care 55 56 Pottstown Medical Center 6/19 1:00 pm Health Care 55 57 Pottstu..n N dical Ceater 6/19 2:30 pm Health Care 55 58 Potts' town Medical Center 6/19 4:00 pm Health Care 55 59 Pottstown Medical' Center 6/19 7:00 pm Health Care 55 60 Pottstown Medical Center 6/19 8:30 pm Health Care 55-61 Pottstown Medical Center 6/19 10:00 pm Health Care 55 62 Ridge FO 6/19 /:00 pm EW II 25 63 Spring City Borough 6/20 7:00 pm EOC I 12 64 Lower. Frederick Ambulance 6/23 9:00 am EW II 18 65 Earl Township FD 6/25 7:00 pm EW II 30 i
66 Pottstown Medical Center 6/26 7:30 am Health Care 55 67-Pottstown Medical Center 6/26 9:00 am Health Care 55 68 Pottstown Medical Center 6/26 10:30 am Health Care 55 69 Pottstown Medical Center 6/26 1:00 pm Health Care 55 70 Pottstown Medical Center 6/26 2:30 pm Health Care 55 71 Pottstown Medical Center 6/26 4:00 pm Health Care 55 72 Pottstown Medical Center 6/26 7:00 pm Health Care 55 73-Pottstown Medical Center 6/26 8:30 pm Health Care 55 74 Pottstown Medical Center 6/26 10:00 pm Health Care 55 75 Spring City Borough
'6/27 7:00 pm EOC II 12 j
75 2,187 C
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44 ENERGY CONSULTANTS
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RIVER 5!CECFFICECENTFR1/ 2101 N. FRONTST. / HARRISBURG / PA 17110 t PH.(717)236-Co31
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CORPORATE OFFICE: 121 EVENTH STREET / PnTSSURGH PA 15222 3487 PH.t412MJ4 5200 May 30, 1984 Helen C. Kelly, R.N.
Recovery Room Phoenixville Hospital 140 Nutt Road Phoenixville, PA 19460
Dear Mrs. Kelly:
In re<pante to your request following our recent orientation program at the Phcenixville Hospital, enclosed please find a copy of the plume exposure pathway EPZ map for Limerick.
Please note that while the area highlighted in white constitutes the official emergency planning zone, the circle in-dicating the ten-mile radius is slightly undersized, due to a mapping error.
In response to your questions, the designated host school for the Perkicmen Valley School District is the North Penn High School in Lansdale.
Detailed information on school emergency plans will be provided by the districts begin-ning with the 1984-85 school year.
It has been a pleasure to be of assistance to you.
Sincerely, 47 yj.
John F. Long, Jr.
JFL:jr Enclosure l.
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STANDARD OPERATING PRUCEDURE CENTRAL RESOURCE RECEIVING POINT MANAGER I.
PURPOSE t
Tne purpose of this procedure is to support Chester County's response to an incident at the Limerick Nuclear Generating Station by centrally receiving and distributing incoming supplies and equipment, II. REFERENCES A.
Annex A, Chester County Limerick RERP B.
Annex I, Chester County Limerick RERP III. RESPONSIBILITIES A.
The Central Resource Receiving Point Manager snall be responsible for:
1.
Acknowledging receipt of notification and making a written record of the information received, including date and time.
2.
Assuring necessary preparation of the Central Resource Receiving Point facility.
3.
Assigning and coordinating required staff for the effective operation of the Central Resource Receiving Point.
4.
Maintaining accurate records of.tll supplies and equipment received and distributed.
5.
Maintaining regular communications with the Chester County E0C Operations Group.
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6.
Aftcr the Central Resource Receiving Point is closed, taking necessary steps to prepare the facility for return to its owner.
IV. OPERATIONAL PROCEDURES A.
UNUSUAL tvENT No action necessary.
B.
ALERT No action necessary.
C.
SITE EMERGENCY 1.
Initial notification will be received from the Chester County (time)
DES.
2.
The Communications Center will notify the Central Resource Receiving Point staff, placing them on standby status.
3.
Review procedures for General Emergency.
4.
Maintain Site Emergency status until reduction, escalation or termination of incident.
D.
GENERAL EMERGENCY 1.
Initial notification will be re.ceived from the Chester County OES.
2.
The Communications Center will notify the Central Resource Receiving Point staff, a'Jvising them of the situation and dispatching them to the Central Resource Receiving Point.
3.
Inventory and prepare necessary record forms.
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Coordinate preparation of Receiving Point facility to receive equipnent and supplies.
5.
Assign staff to tne following responsibilities:
a.
Traffic Control b.
Communicat, ions c.
Receiving d.
Recordkeeping l
e.
Distribution 6.
Notify the Chester County Operations Group when the Central Resource Receiving Point is activated.
7.
Maintain readiness..
8.
As supplies and equipment arrive at the Central Resource Receiving Point:
a.
Arrange appropriate storage location.
b.
Inventory and 109 c.
Determine distribution.
d.
Arrange distribution procedure.
e.
Log out all items.
9.
Report activities regularly to the Chester County DES EOC Operations Group.
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- 10. Maintain Gensral Emerg:ncy status until notified by DES to terminate operations.
- 11. Following closing of the Central Resource deceiving Point, prepare a final report to include:
a.
Names and addresses of all staff.
l b.
Inventory of all supplies and equipment.
h c.
Receiving and Distribution logs.
d.
Hand receipts.
e.
Message logs.
Forward this information to the Chester County DES.
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IMPLEMENTING PROCE0VRE FIELD OPERATIONS GROUP i
iI. PURPOSE t
i The purpose of this procedure is to support Chester County's response to l
an incident at the Limerick Generating Station, assuring the provision l
of expanded telecomunications within the plume exposure pathway emer-
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l gency planning zone and providing for backup telecommunications in the event of a system failure.
I i
IT. REFERENCES I
i A.
Annex B, Chester, County Limerick RERP.
t B.
Annex C, Chester County Limerick RERP.
III. RESPONSIBILITIES i
A.
The Field Operations Group is responsible for providing secondary i
and backup field communications and operational coordination in the t
i event a protective action is ordered in response to a condition at I
the Limerick Generating Station.
8.
The Field Operations group is responsible for providing tele-communications and other services as necessary to the Pennhurst j
State Facility.
4 IV. OPERATIONAL PROCEDURES t
i A.
UNUSUAL EVENT j
No action necessary.
i B.
ALERT The Field Operations Group will be notified and may be requested to i
j report to the EOC.
t C.
SITE AND GENERAL EMERGENCY I
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1.
The Field Operations Group will be notified to report to the l
Chester County' DES.
4 2.
The mobile communications unit will be prepared for service.
3.
As directed,-the Field Operations Group will report with the unit to the Pennhurst State Facility.
4.
Test all telecommunications links.
5.
Assist the Chester County Communications Center as required.
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Provide telecommunications for the Pennhurst Facility as required.
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IMPLEMENTING PROCEDURE MUNICIPAL LIAIS0N OFFICER (DAMAGE ASSESSMENT)
I.
PURPOSE The purpose of this procedure is to support Chester County's response to an incident at the Limerick Generating Station, providing for a liaison with affected municipalities and for the provision of status reports regarding the municipal response.
II. REFERENCE A.
Annex A, Chester County Limerick RERP B.
Municipal Plans for Chester County Municipalities III. PESPONSIBILITIES A.
Municipal emergency management coordinators are responsible for implementing the response of the municipality to an incident at Limerick insofar as municipal resources allow.
B.
The Municipal Liaison Officer is responsible for:
1.
Review of, and familiarity with, municipal RERP's.
2.
Establishing and maintaining comnunications with municipal emergency management coordinators at the time of an incident.
3.
Development of status reports regarding the municipal response to an incident at Limerick.
4.
Coordination of Chester County's response to municipal unmet needs with the DES Director and appropriate County EOC staff.
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o IV. OPERATIONAL PROCE0VRES A.
UNUSUAL EVENT No action necessary.
B.
ALERT EcL 1.
Report to the Cnester County 10F if requested.
(time completed) l 2.
Notify and brief the relief Municipal Liaison Officer.
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3.g,Nottf.y-and brief risk municipal emergency management coor-l dinators, directing them to notify key staff, activate their EOC, and implement the municipal RERP as appropriate for ALERT (reference Attachment A).
4.
Review procedures for SITE EMERGENCY.
5.
Maintain ALERT status until incident escalation or reduction or termination.
NOTES:
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SITE EMERGENCY 1.
Report to the Chester County E0C.
l (time completed) i 2.
Notify the relief Municipal Liaison Officer, placing on stand:y status, and prepare for extended (12-hour shif t) operations (referenceAttachmentA).
3.
Verify notification of municipal emergency management coor-l dinators, ensuring that they are activating their EOC's and are implementing their RERP as appropriate for SITE EMERGENCY (reference Attachment C).
4.
Respond to municipal unmet needs as reported by municipal EMA staff.
(NOTE: Municipal EOC staff may contact their County EOC counterparts directly via telephone. Coordinate with other E0C Officers in order to assess their response to municipal unmet l
needs.)
1 5.
Prepare status reports, on an hourly basis or as requested, detailing municipal response information, unmet needs, and steps being taken to respond to unmet needs. Forward such reports to the DES Director.
t 6.
Review procedures for GENERAL EMERGENCY.
7.
Maintain SITE EMERGENCY status until incident escalation E reduction g termination.
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D.
GENERAL EMERGENCY 1.
Report to tne Chester County EOC.
(time completed) i 2.
Notify the relief Municipal Liaison, placing on standby status, I
~and implement extended (12-hour shift) operations (reference AttachmentA).
1 3.
Notify risk municipal emergency management coordinators of the 1
GENERAL EMERGENCY.
4.
Update records of municipal unmet needs and coordinate the response with appropriate County EOC staff.
5.
Update status reports regarding the municipal response.
l 6.
If a protective action (Evacuation or Sheltering) is ordered or recomended, convey that information to municipal emergency management coordinators, directing that they employ the appropriate procedures in their RERP (reference Attachment C).
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7.
Monitor the progress of the municipal implementation of protective actions, coordinating the response to unmet needs and preparing appropriate status reports.
8.
In the event of a general evacuation, confirm the location of, alternate municipal EOC's with the risk municipal emergency management coordinators.
9.
Maintain GENERAL EMERGENCY status until incident reduction E l
termination.
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. ATTACHMENTS Attachment A:
Risk Municipal Emergency Management Coordinators Attachment B:
Municipal E0C's Attachment C:
Municipal Relocation E0C's 4
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IMPLEMENTING PROCEDURES MUNICIPAL LIAISON OFFICER (DAMAGE ASSESSMENT)
ATTACHMENT A RISK MUNICIPAL EMERGENCY MANAGEMENT COORDINATORS i
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i IMPLEMENTING PRUCEDURE t
MUNICIPAL LIAISON OFFICER (DAMAGE ASSESSMENT)
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MUNICIPAL LIAISON OFFICER (DAMAGE ASSESSMENT)
ATTACHMENT C MUNICIPAL RELOCATION EOC's g
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CHESTER COUNTY DEPARTMENT OF EMERGENCY SERVICES i
STANDAR0 OPERATING PROCEDURE i
l Monitoring / Decontamination Stations I.
PURPOSE The purpose of this procedure is to support Chester County's response to an incident at tne Limerick Generating Station, assuring effective initiation and operations of monitoring / decontamination stations.
!!. REFERENCES Annex M. Chester County Limerick RERP.
!!!. RESPONS!BILITIES A.
Chester County DES is responsible for notification of Monitoring /
Decontamination personnel.
B.
T % Chester County Radiological Officer is responsible for verifi-cation of notification, team assignments, and coorttination of radio-logical monitoring and decontamination activities.
C.
The Chester County Hazardous Materials group will support the Radiological Group.
O.
Monitoring / Decontamination team leaders will be responsiole for coordinating the operations 'of specific monitoring / decontamination stations and for maintaining communications witn the County Radiological Officers at the EOC.
E.
Radiological monitoring and decontamination team members are respon-sible for conducting monitoring and decontamination operations according to Annex M of the Chester County Limerick RERP and tnis procedure.
IV. OPERATIONS PROCEDURES A.
UNUSUAL EVENT No action necessary.
B.
ALERT 1.
Radiological monitoring and decontamination teams may be notified and placed on standby or mobilized.
2.
If placed on standby, remain available for immediate notification.
3.
If mobilized, report to assigned station.
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SITE EMERGENCY
, 1.
Nadiological monitoring and decontamination teams will De mobilized to specific locations.
2.
Inventory and check all survey meters.
3.
Issue team members dosimetry.
D.
GENERAL EMERGENCY 1.
Radiological monitoring and decontamination teams will be i
activated at specific locations, which may be Mass Care Centers or emergency worker monitoring / decontamination points, or otner locations as necessary.
'2.
Initiate monitoring decontamination activities according to I
procedures in Attachment B.
ATTACHMENTS Attachment A Chester County Monitoring /0econtamination Points Attachment B Decontamination Monitoring Procedures Attachment C Hospitals capable of Radiation Treatment Inventory Procecures f
l Attachnent E Forms i
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- O ATTACHMENT A MON!TORING DECONTAMINATION POINTS t
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MON-A-1
.S ATTACHM,ENT B OECONTAMINATION MONITORING PROCEDURES I.
GENERAL INFORMATION AND ORGANIZATION A.
Decontamination Monitoring of the Public In the event of a fixed nuclear facility incident, the public and emergency workers may have to be individually monitored to ascertain whether or not the individual is contaminated with a radioactive substance. If a person is found to be contaminated, thva he/she must be decontaminated. Teams will be advised whether or not
, decontamination monitcring is required. Decontamination monitoring will be performed upon request regardless of whether it is required.
B.
Organization at Mass Care Centers 1.
Mass care centers for evacuees will serve as points where decontamination monitoring and decor *amir.ation procedures will be conducted. When decontamination munitoring is required, evacuees upon arrival at the mass care center will be monitored and, if necessary, decontaminated, after which they will be admitted to the " general living" portion of the mass care center. Decontamination monitoring teams will conduct the monitoring, carry out decontamination procedures, and complete associated records.
2.
Decontamination monitoring teams take direction from the county radiological officer and coordinate with the mass care center manager. Decontamination monitoring.of evacuees should be completed as soon as possible; decontamination monitoring of personal belongings (i.e., clothing, personal articles, vehicles) can be accomplished after the evacuees have been processed.
3.
Decontamination monitoring teams will organize their areas and traffic flow patterns so that contaminated persons and those to be monitored will not mix with the contamination-free individ-uals already admitted to the general living section of the mass care center. For example, persons will be sent to the decontamination area (shewers) by a route that will not place them in contact with contamination-free areas. Showers used for decontamination will not be available for general use until they are decontaminated.
C.
Decontamination Monitoring Services for Persons Who Are Not Housed at Mass Care Centers.
1.
Persons wno do not intend to stay at a mass care center, but who wish to be monitored will be extended these services at mass care / decon* amination centers. The decontamination monitoring M-1-1 Draft 7
o procedures and record keeping are identical for people who stay or do not stay at mass care centers.
D.
Decontamination Monitoring Station for Emergency Workers 1.
Upon completion of his/her mission, or as directed by super-visors, each emergency worker may be ordered to report to a decontamination monitoring station to be monitored for radio-logical contamination, and, if necessary, decontaminated.
2.
Since the mass. care / decontamination centers for the public are generally located 20 or more miles from the nuclear facilities, special " decontamination monitoring stations for emergency workers" are established closer to the plume exposure pathway EPZ.
3.
Each mass care center and decontamination monitoring station is to extend its service to any requesting emergency worker of any organization.
E.
Equipment and Personnel Requirements 1.
The instrument used for decontamination monitoring is the CD V-700 Geiger-Mueller Survey Meter (range:
approximately 0.0 to 50 mR/h).
2.
A sufficient number of CD V-700 survey meters are available for each mass care center to allow one meter for each 250 mass care spaces; decontamination stations have available one CD V-700 for each 50 emergency worker's.
3.
Personnel requirements are one trained monitor and one recorder (assistant to tne monitor) for each survey meter as a minimum.
Each decontamination monitor and recorder is supplied witn dosimetry (CD V-742 and TLD) and KI.
4.
Inventory, maintenance, and property accountability with regard to dosimetry, survey meters, and KI are described in this Attachment.
F.
Decontamination Monitoring Record Keeping Decontamination monitoring personnel will be responsible for completing a " Decontamination Monitoring Report Form" for each individual with a reading of 0.05 mR/h (milliroentgens per hour) or more above background, which is the action level set indicating that decontamination of the individual is necessary. The form will be completed, signed by the monitor at each of the steps [(1) initial monitoring, (2) after first decontamination, (3) after second decontamination, (4) medical referral.] Two copies of tne form will be prepared. One copy will be given to the individual when decontamination is completed or the individual is sent to a medical facility. The original will be retained by the county in a historical file.
M-1-2 Oraft 7
i G.
Progress Reports on Otcontamination Monitoring Decontamination team chiefs must verbally report at two hour
' intervals to their County Radiological Officers on the results of monitoring. The report snall include the following cumulative data: number of persons monitored; number contaminated; number decontaminated; number referred to a medical facility (for radiation decontamination / treatment); the highest reading (above 0.05 mR/h) on any particular individual; and any unusual or particularly notable findings.
I
I. PROCEDURE
S FOR DECONTAMINATION MONITORING TEAMS A.
Decontamination Monitoring Procedures Monitors performing decontamination monitoring of people should
- follow these procedures:
1.
Select a reception location for conducting the monitoring operation. Precautions must be taken to prevent contamination of the area.
2.
Use the CD V-700. Attach the headphone. This allows the monitor to observe the position of the probe and better control it while monitoring. The headphone responds more quickly to changes in radiation level than the meter.
3.
Check the operability of the CD V-700.
4.
Place the probe in a light plastic bag or cover of lightweight material to prevent contamination. This is desirable but not mandatory.
5.
Periodically determine the background radiation level of tne location where the monitoring is to take place.
If the meter indication is above background radiation with the probe shield closed, find a better location that will bring the meter indication as low as possible.
6.
Open the shield on the CD V-700 probe and put on the headphone.
7.
Place the probe two inches from the head, being careful not to touch the person.
8.
Move the probe downward on one side of the neck, the collar, the shoulder, arm, wrist, hand, underarm, armpit, side of body, side of leg, around the cuff and shoe, including the bottom of the shoe. Then monitor the inside of the leg from the cuff to the groin and continue the procedure on the other side of the body (reference Illustration 1).
9.
Monitor the front and back of tne body.
M-1-3 Draft 7
- 10. Record the information on the Decontamination Monitoring Report Form.
- 11. Assure that individuals found to be contaminated are decontam-inated.*
- 12. Monitor the individual after decontamination to determine that the contamination has been removed. Repeat decontamination procedures if contamination still remains.
B.
Thyroid Gland Screening Check for Emergency Workers 1.
In addition to the steps outlined in II.A. immediately above, emergency workers are to be screened for thyroid gland uptake of radiciodine.
' 2.
The thyroid uptake screening procedure follows:
a.
The CD V-700 is used as the screening detector for thyroid uptake of radioiodine.
CAUTION The individual being checked must be free of any contamination before tnis procedure is implemented.
- A person is considered contaminated if there is a reading of 0.05 mR/n or more above background. Do not confuse background radiation with your readings; contamination would be apparent by a sustained increase on the visual meter reading (selector switch on X 1 range), and also by a marked increase in the audible indication from the headphone.
M-1-4 Draft 7
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b.
Monitors performing the thyroid screening uptake procedure should follow these steps:-
(1)
Put the probe with the shield closed across the front of the neck just Delow the larynx ( Adam's Appl e).
(2)
If the reading is greater than or eoual to U.1 mR/hr, refer the individual to the appropriate medical facility for evaluation.
(3)
If the reading is less than 0.1 mR/hr, no further actio'n is necessary.
(4) Record the data on the Dosimetry-XI Report Form and sign in the appropriate place.
C.
Decontamination of People 1.
Contaminated persons should wash with soap and warm water; i.e.,
a thorough shower should be sufficient.
Emphasis should be i
placed on any specific spots found to be contaminated in the monitoring process. Also, special attention should be given to the hair, hands and fingernails.
2.
After thorough cleansing the individual should be monitored again.
If some contamination still remains, the individual should shower again and use a mild abrasive soap.
If monitoring after the second thorough cleansing indicates that the contam-ination is still present, the individual should be sent to the nearest medical facility capable of treating contaminated persons. See Attachment C for a list of such facilities.
3.
Care should be taken that persons who are decontaminated do not become recontaminated by dressing in contaminated clothing (the clothing they were wearing or possibly other clothing brought by them.)
If the individual does not have contamination free clothing, clothing should be issued the individual until such time as their clothing can be decontaminated.
D.
Decontamination Procedures for Wounds Persons with contaminated wounds chould be referred to an appro-priate medical facility for radiation decontamination and treatment.
+
E.
Clothing Decontamination Procedures 1.
Articles which are machine washable should be laundered with a conventional detergent, line dried in a contamination free area or machine dried, and retained until they can be monitored.
Water repellent items may be scrubbed-with water and detergent, and retained until monitored.
2.
The County DES is responsible for arranging for a laundry facility dedicated to washing of contaminated clothing.
M-1-6 Oraft 7
F.
Decontamination Procedures for Supplies, Instruments and Equipment 1.
The item in question should be monitored first to determine the extent and area of contamination by thoroughly going over the object with the CD V-700 probe (with open shield) about two inches from the surface. Decontamination of these articles is generally accomplished by wiping or washing to the extent necessary to remove the radiocontaminants.
2.
The County DES is responsible for arranging for radiation monitoring of vehicles and for decontamination. At mass care centers, monitoring teams will initially direct their efforts to the evacuees as described in (a) and (b) above. When time permits, the monitoring teams can monitor the vehicles of the evacuees where they are parked. Generally, external monitoring of vehicles will be sufficient; however, inside monitoring will also be accomplished for those vehicles found to be externally contaminated or used by persons found to be contaminated. Suit-able car washing arrangements can be made for external decontam-ination depending upon the number of vehicles contaminated and amount of radiocontamination. Vehicles with contamination in the interiors will be impounded and the county radiological officer notified.
G.
Disposal of Contaminated Wastes 1.
As described above, clothing and similar materials as well as miscellaneous equipment and vehicles can be decontaminated.
Where cleaning materials and other items cannot be successfully decontaminated, special handling is necessary.
P.
Contaminated waste materials should be packaged in a plastic bag, tied securely at the top, and placed in a metal container with a snug fitting lid (garbage can) untiil it is laundered.
If any material cannot be decontaminated by laundering, place it in the same type of plastic bag and container and store in a locked room that is not used for any other purpose until such time as the contaminated waste is disposed of by FRMAP personnel.
Accumulation of contaminated waste materials and the need for disposal should be reported through the emergency management system.
I M-1-7 Draft 7
't.
ATTACHMENT C HOSPITALS EQUIPPED TO RECEIVE RADIOLOGICAL PATIENTS FACILITY NUMBER OF BEDS 1.
University of Pennsylvania Hospital i86 3400 Spruce Street Philadelphia, PA 19104 (215) 662-3000 - Radiology (215) 662-4000 - 2203 Main Number Dr. Sheldon Jacobson - Onergency Room Chief. The University of Pennsylvania Hospital is the Definitive Care Center for Radiation contamination in the Del. aware Valley.' This hospital has been designated as the referal center for the entire Delaware Valley re91on. Local hospitals are capable of providing stabilization, monitoring and decontamination, as necessary, and are to refer severe cases to the University of Pennsylvania Hospital.
2.
Southern Chester County Medical Center 53 LR 131 West Grove, PA 19390 (215) 869-1000 3.
Chester County Hospital 290 701 E. Marshal Street West Chester, PA 19380 (215) 431-5000 4.
Paoli Memorial Hospital 188 Lancaster Pike Paoli, PA 19301 (215) 648-1000 5.
'Brandywine Hospital 209 201 Reeceville Road Coatesville, PA 19320 (215)383-9068--8049 All other hospitals.in tt.e state with this capability
(
are identified in the Commonwealth's Disaster Opera-i tions Plan, Annex E, and these resources could be used if.the primary and immediate support hospitals identified here are not sufficient.
i l
MON-C-1 l
ATTACHMENT 0 00SIMETRY AND P0TASSIUM I0DIDE (KI) INFORMATION I.
GENERAL INFORMATION A.
Each emergency worker assigned tasks within tne plume exposure pathway EPZ will be equipped with three dosimeters, a Dosimetry-KI Report Form, and a 14 day supply of potassium (KI). Two of the dosimeters are self-reading; they are tne CD V-730 or a DCA-622, both of which measure from 0 to 20 R, and the CD V-142 which measures from 0 to 200 R.
The third dosimeter is a thermolumines-cent dosimeter (TLD) which is a card type device that is read by the TLD service contractor.
B. ' Decontamination monitoring team members are issued a CD V-742, a TLD, KI and a Dosimetry-XI Report Form.
C.
Dosimeter chargers (CD V-750) which are used to "zero" or charge the self-reading dosimeters are located with, or within easy access to, each emergency organizational unit.
D.
The CD V-740 (0-100R) self-reading dosimeter is considered an adequate substitute for either the CD V-730 or CD V-742.
II. DISTRIBUTION OF DOSIMETRY-POTASSIUM IODIDE AND RELATED PROCEDURES A.
Distribution The TL0s, CD V-730s or DCA-622s, CD V-742s, Oosimetry-KI Report Form, potassium iodilie and appropriate numbers of CD V-750s in support of response to fixed nuclear facility incidents are available from the County DES. The county will dispatch a county vehicle to distribute the appropriate number of units of dosimetry-
~
KI, dosimeter chargers and survey meters to the municipalities in the risk area when the classification of ALERT is declared. For this purpose a " Dosimetry, KI, Survey Meter Distribution List" is included as Appendix 3.
This county list identifies by name and address each organization to be distributed these resources and specifies the number of dosimeters, units of KI, dosimeter chargers, and survey meters to be distributed to each agency. The using organizations ~will from the municipalities and distribute to their emergency workers dosimetry and KI upon the declaration of SITE EMERGENCY. (Note: Decontamination monitoring teams at decontamination centers and stations are not activated until SITE EMERGENCY, upon which distribution is made to the team by the County
.0ES.)
M-2-1 Draft 7
a B.
Property Control
. Property accountability must be maintained in the distribution process. The " Receipt Form for Dosimetry-Survey Meters-KI" (see Attachment E) is designed for transferral of quantities of equipment from agency to agency, such as from the county to municipalities and decontamination teams, and from municipalities to emergency response organizations (fire, police, ambulance).
" Acknowledgment of Receipt by Emergency Workers for Dosimetry-XI and Survey Meters" (see Attachment F) is designed to expedite transferral of the equipment-KI to individual users. Municipal E0Cs, fire companies, police departments, ambulance services and decontamination monitoring teams should use this form (Attachment F) to maintain accountability when distributing the equipment-XI to their individual emergency workers.
Upon termination of an incident, all equipment and unused KI must be
' returned to the county DES.
C.
Control TLD's 1.
In the event of an incident, the County DES will retain the designated " Control TLDs." Control TLDs are equal in number to about 5% of the total amount allotted for di'stribution. Each
" control TLD" is so labeled and the serial numbers are not in the same sequential batch as the TLDs meant for distribution to emergency workers. As coordinated by PEMA, the control TLDs will be forwarded to the TLD service contractor. The County DES will complete the " Control TLDs Form" (reference Attachment B) and forward it with the control TLDs.
2.
The purpose of " Control TLDs" is to allow measurement of a
" baseline" of radiation (background radiation) that the TLDs nad been e posed to at tne time the county distributed TLDs in reac+ Jn to the incident. The measurement of the accumulated J "9P hp background radiation as measured by the control TLDs will be subtracted from the reading obtained from each emergency worker in the county. This procedure can be characterized as a
" mathematical zeroing" of the TLD.
(The CD V-730s DCA-622s and CD V-742s will be zerced by the user organizations as they are put into use.)
3.
At the time of the incident the County DES will ensure that the control TLDs are not exposed to radiation otner than background radiation. Specifically, since the TLDs are stored outside the plume exposure pathway EPZ, the County DES will ensure that the control TLDs are not moved inside the EPZ.
D.
-County Distribution Time Requirements The county EMA plans to make its entire dosimetry-KI survey meter distribution to using agencies / organizations within two hours.
M-2-2 Draft 7
. s.
III. POTASSIUM IODIDE (KI)
A.. Background Information 1.
Iodine accumulates in the thyroid gland which is located at the front base of the neck just below the larynx (Adam's apple).
L Radioactive iodine is no different, i.e., it will accumulate in the thyroid gland in high concentration. Taking KI will have the effect of Eaturating the thyroid gland with iodine so that radioiodine does not lodge there in a large quantity. Hence, KI lessens the risk to the thyroid gland; otherwise, it provides no protection against radiation.
2.
The Pennsylvania Department of Health is responsible for developing policies relating to use of KI during fixed nuclear incidents. The department has procured XI tablets for emergency
~
workers and KI in liquid form for staff and patients of risk hospitals. Thyro-Block (product of Carter-Wallace Inc.) is the brand name of the KI tablets procured by the department. A unit of Thyro-Block consists of 14 tablets of 130 milligrams in size; the dose is one tablet per day.
The liquid preparation (manufactured by Roxanne, Inc.) dosage is six drops per day; for planning purposes the liquid,KI requirements are based upon a 14 l
day supply per person.
3.
The toxicity level of KI is very low and dangers in taking this drug are considered to be minimal. Nonetheless, individuals should not take more than the recommended dose. Although side effects to KI are unlikely because of the low dose and the short time period it will be taken, some side effects are possible.
4 The side effects may include: skin rashes, swelling of the j
salivary glands, and " iodism" (metallic taste, burning mouth and throat, sore teeth and gums, cold symptoms and sometimes gastrointestinal symptoms.) A few people may have an allergic reaction with more serious symptoms. These symptoms could include elevated temperature, joint pains, swelling of the face and body, and at times, severe shortness of breath which requires immediate medical attention.
1 4.
The effectiveness of KI as a blocking agent is greatest if J'
adminsitered before the time of exposure to radioiodine, but some exposure saving can be obtained by administration shortly 4
after exposure.
Information on Thyro-Slock and on the liquid XI are included in Attachments C and D to this Appendix.
B.
Pennsylvania Department of Health Policies on KI 1.
KI in tablet form is available to emergency workers (emergency management agencies, police forces, fire companies, ambulance
+
services, and farmers keeping livestock). Those emergency worker organizations and institutions that receive KI protection i
are specified in Appendix 3.
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2.
Tha Secretary' of the Deparment of Healtn is charged witn the decision to use KI during an incident.
KI should be taken only on the advice of the Secretary of the Department or Healtn.
Ine Secretary's advice will be disseminated to emergency workers througn emergency management channel s.
Upon taking KI, tne emergency worker should record this information on the Dosimetry-KI Report Form.
3.
The Department of Health will provide the public with information concerning KI.
IV. 00SIMETRY READINGS, RECORD KEEPING AND PROTECTIVE ACTION OPTIONS A.
00simetry Reading Procedures 1.
Dosimeters should be worn in the pocket of an outer garment from the time of issue until the worker is dismissed from duty or, until PEMA says dosimetry is no longer necessary.
In no case should the TLD be worn by more than one person since there is no way of ascertaining later how much of the dose recorded on the TLD was received by each individual if more than one person was involved.
2.
For practical purposes each Roentgen registered on either of the self-reading dosimeters is to be interpreted to mean that the worker has received a corresponding number of rem, e.g., a reading of 5 R should be interpreted to mean that a 5 rem dose has been received.
3.
Each emergency worker sh'ould read the self-reading dosimeters at least once each thirty minutes.
4.
Two self-reading dosimeters provide redundancy. Workers should heed the higher measurement taken from the two dosimeters.
It is possible for dosimeters of this type to have " electrical leakage" that will register a reading not caused by radiation.
Nonetheless, workers are to " err on the side of caution" by heeding the higher reading.
B.
Protective Action Guides (PAG) for Emergency' Workers 1.
Whole Body Exposure - The protective action guide for whole body exposure specified by the Environmental Protection Agency (EPA) and oy BRP is 25 rem. Workers should use the self-reading dosimeter (s) to ensure that the 25 rem whole body PAG is not exceeded. By regularly checking tne self-reading dosimeter (s),
the worker can make reasonable judgments about how much radiation, if any, has been received and at what rate it is being received.
2.
Emergency workers and supervisors are c.tioned tnat the 25 rem protective action guide snould not be construed as " license" to incur radiation exposure unnecessarily. Workers and supervisors should attempt to keep exposure as low as reasonably achievable.
M-2-4 Oraft 7
- s' m
This concept means that exposure to radiation should be kept to a minimum for all persons and that any one individual should not receive a total dose far in excess of other emergency workers if circumstances permit substitution of personnel, termination of the assignment, or other protective action.
3.
Thyroid Gland Exposure - The EPA and BRP PAG for thyroid dose is 125 rem for emergency workers but with no specific upper limit for life saving activities. An upper limit is not given for thyroid exposure since in the extreme case complete thyroid loss i
might be acceptable for a life saved.
4.
Life Saving Missions - Responsible emergency management of off-site workers dictates that exceeding the 25 rem protective action guide should not occur. However, if there should be extraordinary circumstances wherein a person's life is at stake, the 24 rem whole body dose may be exceeded in order to complete a life saving mission. The EPA and BRP specify an upper limit of 75 rem whole body dose for life saving missions, i.e.,
subject to special approval, conditions, and measures. There-fore, persons who volunteer for a life saving mission may exceed the 25 rem whole body limit set for emergency workers, but in no case may they exceed 75 rem.
Elected officials in authority may authorize, in advance, volunteer emergency workers to exceed the protective action guidelines (25 rem whole body exposure) to a maximum of 75 rem for a life saving mission. This advance authorization is intendea to avoia celay in performing a necessary life saving mission. A wide margin of safety should be maintained to avoid risk from possible adverse long term health effects caused oy radiation exposure (see paragraph C below). Decision makers (elected officials) should consider the information in paragraph C below and also ensure that the following conditions have been met:
a.
The mission is of life saving importance.
b.
Alternative solutions have been exhausted.
c.
Emergency workers should be healthy adult male volunteers, e
preferably over 45 years of age.
d.
The emergency workers selected should be person whose normal duties might involve such missions, i.e., policemen and firmnen'with suitable protective clothing and respiratory equi pment.
e.
The mission is accomplished in the least amount of " stay time."
f.
The emergency workers are knowledgeable of and accept tne increased risk of exceeding the 25 rem PAG.
M-2-5 Draft 7
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s' C.
Increas::d Risks Oue to Radiation Exposure
- Information concerning the possible consequences of emergency workers' exposure to radiation during a fixed nuclear incident is organized below into three categories - (1) immediate somatic effects, (2) long term somatic effects, and (3) genetic effects.
Somatic is an adjective pertaining to characteristics of or effects on the body, as distinguished from genetic characteristics or
?
genetic effects which are manifest' d in offspring (descendants).
e 1.
Representative Relationships Between a Brief One-Time Radiation Exposure and Immediate Somatic Effects Representative Absorbed Dose of Whole Body X or Gamma Radiation (rads)
Nature of Effect 5-25 rem Minimal dose detectable by chromosome analysis or other specialized analysis.
50-75 rem Minimal acute dose readily detectable in a specific individual (e.g., one who presents himself as a possible exposure case).75-125 rem Minimal acute dose likely to produce vomiting in about 10f. of people so exposed.
150-200 rem Acute dose likely to produce transient disability and clear hematological changes in a majority of people so exposed.
2.
Long Term Somatic Risks as a Result of a One Time Exposure to Radiation Current knowledge about the long tere health effects resulting from a one time radiation exposure below 25 rem indicates.that development of health problems, such as cancer, in adults so exposed is extremely unlikely. There is no direct clinical evidence of low level radiation (in this case meaning a one time j
exposure below the whole body dose protective action guide of 25 l
rem) causing health problems years after the exposure.
3.
Genetic Effects of Radiation l
Radiation exposure of reproductive cells of the ovary and testis causes gene and chromosome abnormalities (mutation). Persons
- Information derived from " Basic Radiation Protection Criteria," National Council on Radiation Protection and Measurements Report Number 39, Bethesda, Maryl and, March 1,1982.
M-2-6 Draft 7
d ' + '.*
cxposed to aIy radiation should avoid the possibility of concep-tion during the first few months after exposure, in order to virtually eliminate any possible genetic risk.
D.
Dosimetry and KI Record Keeping 1.
Each emergency worker is responsible for completing a Dosimetry-KI Report Form (reference Attachment A) and for returning it, along with the dosimetry, to his organization at the tennination of his services. Each emergency organization shall forward the forms and dosimetry to the County DES who in turn will deliver the TLDs and forms to PEMA. All dosimetry records will be forwarded to BRP for the purposes of record keeping, analysis, reporting and storage.
2.
BRP will retain all original copies and will be the permanent record keeper of the completed Dosimetry-KI Report Forms along with BRP's explanation of each, the TLD service contractor generated information and all related material. The records of individuals will be kept confidential 3.
BRP will use the Dosimetry-KI Report Form to select TLDs for l
immediate reading. The highest priority will be given to TLDs l
worn by persons whose self-reading dosimetry indicates 25 R or
~
more, or where medical authority has requested immediate reading, or where other circumstances warrant.
4.
If emergency workers turn in tteir TLD for reading and are later deployed in an area where dosimetry is needed, they should be issued new TLDs.
V.
FARMER ACCESS TO THE PLUME EXPOSURE PATHWAY EPZ A.
Farmers as Emergency Workers i
Farmers with livestock within the plume exposure pathway EPZ will be designated emergency workers if the EPZ is evacuated. The County DES will provide these farmers with dosimetry and KI and identi-fication enabling them to stay within or exit and reenter the.
evacuated area to tend livestock.
8.
Distribution of Dosimetry-KI and Farmers' " Pass" to the Evacuated Area 1
A " Contact and Dosimetry-XI Distribution Point for Farmers" will be
{
established at Lionville Fire Department, Village Avenue, Lionville.
If an evacuation is necessary, an Emergency Broadcast Systen (EBS) announcement will direct farmers with ~ livestock within the EPZ to report to this location. The County Agricultural Agent or his representative will distribute the dosimetry-KI to the farmers. A
" Farmer Emergency Worker Certification" form will be completed in duplicate for each fanner. The original-copy will be given to the-fanner and serve as a pass for access to the evacuated area. The M-2-7 Draft 7 e
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'. duplicate will be retained by the agriculture representative as the basis for property control.
- imitation on Farmer Access to tne Plume Exposure Patnway EPZ C.
L The farmer's emergency worker status and authorization to be in the EPZ can be suspended if the incident becomes serious enough to warrant this action.
M-2-8 Draft 7
~
e ATTACHMENT 0 INVENTORY AND MAINTENANCE PROCEDURES I.
PURPOSE This attachment sets forth procedures for inventory and maintenance of the dosimetry, dosimeter chargers, survey meters and potassium iodide (KI) intended for use in response to incidents at the Limerick Generating Station.
II. OEFINITIONS For the purpose of this appendix, the following definitions are applicable:
A.
Inspection - A visual check for physical damage and missing accessories to include batteries (for the CD V-750 and CD V-700) which should be stored separately.
B.
Operational check -
1.
Self-reading dosimeters (CD V-730, CD V-742, or Dosimeter Corporation of America Model 622) - The dosimeter is operational if the hairline can be moved to or close to zero using a dosimeter charger.
2.
Oosimeter charger (CD V-750) - The charger is operational if the light source for reading dosimeters is working and the charger 1
can move the hairline on a self-reading dosimeter to cr close to zero.
3.
Survey meter (CD V-700) - The survey meter is operational if, after turning the selector switch to the X10 range, allowing 30 a
seconds for warmup, opening the shield on the probe and placing the open area of the probe as close as possible to the opera-tional check source located on the instrument case, the meter reads between 1.5 and 2.5 mr/h.
C.
Special RERP issue - Refers to dosimeters, dosimeter chargers and survey meters that are either civil defense or commercial equipment issued to selected counties for the express purpose of response to nuclear facility incidents; this equipment is in addition to civil defense kits issued to counties as a preparedness measure for nuclear attack.
D.
Set aside - Refers only to CD V-742 dosimeters and CD V-750 dosimeter chargers originally issued as part of civil defense items have been removed from the kits (but are stored in the proximity of the kits) and " set-aside" for ready availability if a nuclear power plant incident should occur. This equipment, of course, can be placed back into the civil defense kits if nuclear attack becomes a heightened concern.
M-4-1 Draft 7
placed back into the civil defense kits if nuclear attack becomes a heightened concern.
III.
INVENTORY AND MAINTENANCE PROCEDURES i
A.
Annually, during the month of January, the Chester County DES will physically conduct a complete inventory of all special RERP issue or set-aside of dosimeters, dosimeter chargers, survey meters, KI and related forms (reference Attachment A).
Using the form provided (Attachment A), the County DES Director will report the results of the inventory to PEMA.
B.
At least once each year, PEMA will physically conduct an inventory-inspection-operational check of the special issue and set-aside equipment and KI. All such equipment and KI will be made available at a central location for this procedure.
C.
PEMA will provide an annual KI report to the Department of Health.
D.
These procedures pertain only to the special RERP issue or set-aside of equipment and KI for response to nuclear power facility incidents and in no way changes or alters other established procedures for RADEF equipment.
IV.
THERM 0 LUMINESCENT 00SIMETERS Each year, based en the original issue date, PEMA will conduct an exchange of new-for-old TLDs with the County DES. When the annual replacements are received from the TLD service contractor, PEMA will exchange the TL0s on a one-for-one basis with the county.
There are no maintenance require'ments for the TL0s and each has a usable life of only one year.
ATTACHMENT:
A.
Fixed Nuclear Facility Special Equipment-KI Forms Inventory Report Form M-4-2 Oraft 7
ATTACHMENT E CONTROL TLDs FORM When TL0s are distributed during an incident, this form should be completed by the county emergency management agency. The completed form, together with the control TLDs, should be forwarded through PEMA to BRP.
Note:
If a fixed nuclear facility incident occurs, the control TL0s should not remain in, or be moved into, the plume exposure pathway EPZ.
I County The control TLDs accompanied by this form are serial numbered " Control through " Control
" and/or " Control The TLD stock, with which the control TLDs were co-located, was stored at:
Address i
At the time of the incident, the control TLDs were moved to (if not moved, so indicate):
Address I
Date and time moved: Date:
Time:
This form completed by Signature:
X M-2-8-1 Oraft 7
- - = _ _.
ATTACHMENT A APPENDIX 4 FIXED NUCLEAR FACILITY SPECIAL EQUIPMENT-KI FORMS INVENTORY REPORT FORM CHESTER COUNTY l
I,
, certify that a physical (name of individual. conducting the inventory) inventory of the. equipment and KI issued to or set-aside by this county i
specifically for response to incidents at nuclear power plants was conducted on
,19,__ and the results of such inventory are as follows:
i-1 2
3 Quantity Total Physical Special Quantity Col umns Inventory Equi pment/KI/ Forms Issue Set-Aside 1&2 Ouantity 1.
CD V-730 self-reading dosimeter i
2.
Oosimeter Corporation of America Model 622 self-reading dosimeter (commercial equivalent of CD V-730) 3.
CD V-740 self-reading dosimeter '
4.
CD V-742 self-reading dosimeter 5.
CD V-750 dosimeter charger 6.
TLD (thermoluminescent dosimeter)
Serial numbers through and through 7.
CD V-700 survey meter 8.
Bottles of KI (14 tablets) 9.
Copies of " Dosimetry-KI Report Form"
- 10. Copies of "Decontaminatio.1 Monitoring Report Form"
- 11. Copies of " Farmer Emergency Worker Certification NAME OF INVENTORY CLERK:
(please print or type)
INVENTORY CLERK'S SIGNATURE:
X DATE:
SIGNATURE-COUNTY C0ORDINATOR: X DATE:
M-4-A-1 Oraft 7
RECEIPT FORM FOR 00SIMETRY-SURVEY METERS-XI ISSUED BY.
ISSUE 0 TO ADDRESS ADDRESS RESPONSIBLE INDIVIDUAL TELEPHONE INSTRUCTIONS: During a nuclear power plant incident, use this form to main-tain property and control when distributing the items listed below to munici-palities and decontamination ~ monitoring teams. This form should be used for transfer of these items in bulk form from:
(1) the county emergency manage-ment agency to risk municipalities and decontamination monitoring teams; and (2) the municipalities to their local emergency response organizations (such as fire, police, and ambulance associations).
NOTE:
Tne form listed on item 11 below should be used when issuing dosimetry-Ki to individuals emergency workers.
LINE NUMBER DESCRIPTION QUANTITY 1.
CD V-742 Self-Reading Dosimeter (0-200R) 2.
CD V-730 Sel f-Reading Dosimeter (0-20R) 3.
DCA-622 Sel f-Reading Dosimeter (0-20R) 4.
CD V-7SO Dosimeter Charger 5.
TLD (Thermoluminescent Dosimeter)
Serial Numbers THROUGH 6.
Potassium Iodide (KI) Tablets (Bottles of 14 Tablets Each) 7.
CD V-700 Survey Meter 8.
00simetry-XI Report Form 9.
Decontamination Monitoring Report Form 10.
Receipt Form for Oosimetry-Survey Meters-KI i
11.
Acknowledgment of Receipt by Emergency Workers 1
for Dosimetry-KI and Survey Meters RECEIVED BY:
TITLE:
(print name)
SIGNATURE:
X OATE:
M-2-E-1 Draft 7
ee est,tStw i ACKNOWLEDGMENT OF RECEIPT BY EMERGENCY. WORKERS FOR DOSIMETRY Ki AND SURVEY METERS PM' NO T E S: E nwegency woekees assipied to decontamination monitosing teams et decontamination moniloring DATE stalams ce centers do NOT ecceive a CD V.730 et DCA G22 (see column 21. ONLY memhees of decontamination snonetoeing teams sweive a CD V.700 survey meter Isee column 8).
NAME OF EMERGENCY ORGANIZATION INSTRJ. isONS FOR DISTRIBUTION: Enter t il oe 101 in cohemns 2 and 6. Recoed the seelal number of the RESPONSIBLE INDIVf DUAL DCA G22 in colunm 2 anel the seeial nundeer of the T LD in column 3. By signing column 8, the individual accepts sesponsehelity for each leem indicated on the respective line end eyees se setuen these items liess the K1 outhoelsed ORGANIZATION ADDRESS to be used) upon esquest end automaticeity when the nuclear powee plant incident is seeminated, to INSTRUCTIONS FOR RETURN OF ITEMS DESCRl8ED: I # ) by the cegenlantion's seiponsible Imlividual ind cates setusn of each item.
M T
C 1
2 3
4 5
8 7
8 3 mh CD V-742 CD V 730 et TLD ITHE RMO-El (POTAS$4UM DOSIME T RY.
CD V 700 N
DOstME IRY DCA G22 LUMINESCENT IODIDEI K1 REl' ORT SuelvEY INDIVIDUAL *S NAME INulVIDUAL'S SIGNATUftE g
10 200RI 80 20RI DOSIME TER) liablets)
FORM MEIER (peint legiblyl
>=
{ Lts T
iseeial Numheel 7
(Serial Numbeel f
f f
W y
D 1 each I bottle 1 each W
I each l bottle 1 each g
a- <
g i e-.,
i bonie I esci, u u e
I eacle 1 bottle I escia 3
LaJ l each I bottle I e9Ch O
E 1 eacts I bottie ieach g
mg i cach i boiile i e.ch a
$ tA.
I exto I bottle 1 each 1 each I bo'.se I each eg-I racle 8 bottle I escis 1 each I bottle I each l esi.h I bottle I each lenh I bcttle I rech e
,e O
t e
e
I DECONTAMINATION MONITORING REPORT FORM
-NOTE: THIS FORM WILL BE COMPLETED FOR EACH INDIVIDUAL WITH A READING OF 0.05 mR/hr OR MORE ABOVE BACKGROUND.
NAME of person monitored SOCIAL SECURITY NUMBER ADDRESS FIRST Radiological Monitoring Monitor's or Recorder's Signature X Mass Care Center Survey Meter Serial No.
DATE TIME E
SECOND Radiological Monitoring - to be completed after person has undergone decontamination including acquiring radiologically " clean" clothing.
. Monitor's or Recorder's Signature X Mass Care Center Survey Meter Serial No.
DATE TIME E
THIRD Radiological Monitoring - to be completed after person has undergone decontamination a second time.
Monitor's or Recorder's Signature X Mass Care Center Survey Meter Serial No.
DATE TIME E
ANATOMY FIRST MONITORING l SECOND MONITORING ! THIRD MONITORING mR/hr i
m R/hr i
mR/hr head l
face mR/hr i
mR/hr mR/hr neck mR/hr 1
mR/hr i
mR/hr rt. shoulder mR/hr I
mR/hr I
mR/hr rt. arm mR/hr mR/hr i
_m R /hr rt. hand mR/hr mR/hr i
mR/hr rt. side mR/hr mR/hr i
m.Fl/At rt. outside leg mR/hr mR/hr mR/hr rt. foot mR/hr mR/hr m R/hr rt. inside leg mR/hr mR/hr m R/hr groin mR/hr mR/hr mR/hr it. inside leg mR/hr mR/hr mR/hr It. foot mR/hr mR/hr mR/hr it. outside leg mR/hr mR/hr mR/hr It. side mR/hr mR/hr ll m R/hr it. hand mR/hr mR/hr i
mR/hr it. arm mR/hr mR/hr I
mR/hr it. shoulder mR/hr mR/hr i
mR/hr chest mR/hr mR/hr I
m R/hr -
. stomach mR/hr mR/hr mR/hr back-mR/hr mR/hr mR/hr buttocks mR/hr mR/hr mR/hr
- Medical Referral - subject to individual sent to hospital for decontamination and/or treatment at (TIM E)
E on (DATE)
.I Decontamination Team Chief's Signature X l
- Form Distribution:
Original to county emergency management agency:
copy to person monitored.
y 3
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FARMER EMERGENCY WORKER CERTIFICATIONS This is to certify that (name)
(address) is authorized access to the plume exposure pathway emergency planning zone (EPZ) surrounding the fixed nuclear facility for the period' extending from (date)
(time) am/pm to (date)
(time) am/pm.
This individual has been issued dosimetry and KI and is authorized access to the evacuated area for the exclusive purpose of tending to livestock located a't:
4 (Farm location)
Identification data:
2 Height:
Hair color:
Weight:
PA Operator's License No.:
Social Security No.:
Radiological Equipment Issued:
CD V 730, Serial No.:
CD V 742, Serial No.:
TLD, Manufacturer:
Serial No.:
i Individual's Signature: X 3
Agricultural Representative's Signature:
X 4
i M-2-G-1 Draft 7
\\
PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 12151841 4000 Junt 4,
It> 0 4 Robert tiaatillot:
Presis1ent, Police chioU,' Ausoei.itlen Of AOnlyo!! Or y Coultl'y Lo.ter doce. land Tcunship Police Det,nctinent 640 duu Liott Noast lluntisej ton Va lley, s'a. 1900G
Dear de,
L:
'rliank you 1:oc t.he opportunity to aaJeesu four sunociation.
.since there were many questions raiacti reyacaina the biatorich Stavrycney Planning Zone, Onclo.ied for yout u.e ars tuo copiou us the Pennisylvania Emergenicy !lalui'jetuent n,Jeney sh"t inap s.oc L unec ich Gi occa t ing S ta tion.
l It thcre act any further yurstionu or if we may be vi asuictatice pleaso de tiot hesitate to contact itie at (!15) 041-b /13 2.
T. [ y hi,,[f g i
R. n. itankus
- Director, dmergcncy Prepareune.i.; Svetion iluclear Generatio 1 Ulvi..!On R/ui:mlh CnC10'Ju C e S cc:
A.
L.3ulgelow m.-e.
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4' PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 121518414000 dL4114-l, J. b L.1 a
.$1 C. ti a C V l' y C. C t. L u:,. *l; Chiel ul L'GLLuc Lost ('e PO L Ld.} C0Vi
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2101 1:. iii jh s t eii t
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P ri.
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Dear Fir. Chrut.eh:
1 Thank you foc the opportunity to diacuac imer.jeocy pl.anssinia f or Liiai c icl..
incloucd are t'.Jo copies of the 2
t)O titis' 1.ils i...m c ps / e.ana4jo.nent Agt'ncy L l;ie r tck vl u..is-it o.us-i' t. t h./ :., ::.i.o t.p -ne y ? L ao.inij totie innp.
1 i.Annue in any ot hec usatino c, p i e.6 :.
4i i u.n ut-v6 C o n t a u r ale tit. ( ? l '.s ) U.: 1-5 4 3 2.
/. /!,!)c:q[ c s R. A.
Kankuc Director d!GOf(jcticy PrOparCdnudG U e c t.101:
Uuclear Cent:ca tion Diviuit,n itAK: n11h f
U ticiou u r k.';
cc: A. L. b lige Lou it. 11. Ilaml1Lua
PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8G99 PHILADELPHI A. PA.19101 12151841 4000 l
June 1e l'J U i i
f bif. Ru4.;01l 13. 1;ut.h.:. t Constable i"
30;< L1 Gilbertw iLi.e, t' < i. 1952's i
i UeL4 C 11C.
!!Ui.li.it* 11
't'li. ink you r ot enc oppor tuni ty to U L::cusu e:necge,ie,-
planni n.; a:c e b l.iie r i c k.
- Jnclosed ace two copies of tiie Penn:;ylvania duier Ja t:ey !lanage: notal Aqcncy Lt.ac ticl: P i ttn:e t'.q v urt L%t tlluu ( di.aD C J ellt/.' L 'aill1 [It!) ZOsLO
- t. 4 3..
l (2 C cao ;,c of nu 10tanctJ in aisy otinc t a:.au te r, ;, !. e
...t cotitac t i.au
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( 21.'3 ) 1141-5432.
t
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i l
l
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l Directoc l
Emcrgottcy Preparestneau Ueeticii H LICleul; tje t LO C.*i k101 131v 131011 RAK: min I
L:ticlocu cua i
cc:
A.
L. 011010' i
It. II. it a:it il t on l
s.
Y5 PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY j
/
k eff f P.o. Box 3321 HARRISBURG, FINN 5YLVANIA 17103 a
X '4-:.m W
May 29, 1984 giD;E6VFD WN
{ IU" 3 Roberta A. Kankus Director 4 g yt4KUt Emergency Preparedness Section Nuclear Generation Division Philadelphia Electric Company 2301 Market SLreet P.O. Ilox 8699 Philadelphia, Pennsflvania 19101 Deac Bobbi:
Your letter dated May 23 has been received today.
I was under the impression that the matter discrssed in your letter had already been approved.
I talked with Bob Bradshaw earlier concerning the matter of dosimetry and decontamination monitoring and we agreed that ECI personnel would complete the 16-hour radiological monitoring training course required by PEMA.
l'ollowing that, PEMA would train these monitors in the matter of dosimetry and decontamination monitoring and, further, would provide such personnel with a lesson plan. With that all completed, the trained monitors (ECI personnel) could then conduct dosimetry and decontamination monitoring classes.
I am aware that the ECI personnel have completed the 16-hour radiological monitoring class since we monitor a person's progress from beginning to end in this process.
Further, I am aware of the May 31 class here in Harrisburg since I am scheduled to teach it.
In summation, I believe that the matter cited in your May 23 letter has already been resolved.
Sincerely, Donald F. Taylor, Ph.D.
Director Office of Training and Education DFT:pmd (Tel:
717-783-8150) cc: Timothy R. S. Campbell A. Lindley Bigelow Robert Rober Robert Bradshaw L.
l PHILADELPHIA ELECTRIC COMPANY acceivec 23O1 MARKET STREET g.3 p p)g4 P.O. BOX SG99 PHILADELPHIA. PA.19101 ilA hI' (2151841-4000 May 30, 19 G /.
Bruce.9. Ainto'..'!ct MannJer,.n.ter o erution.
v
':i ty o f Ph i l aut. !ph i.
- lat.u r Du;sa t; tue a t 1130 ' tut.ieiv l %r.;c.
Building a
Phfindolphia,
- )c.
30107 Dost C i n c e..
I'h i.:- le t ts t con firnu. tha t a Philndc J.1,hiu '7a tet Do;artinent 2.ud
- s. 1.l th Depar tracn t reprocentative will bc
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Operiti
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please Sov i.ie u: i t;c nama:2, po.,1 t ion r: and N hout t e la. i:oin numhec. vi Lha rapc.. a t t. t i v c.: co-they a:;, be inclusio? on a no t i !"i e.; L ia:. i. i u..
- i. would c zp e t.iouc c. c scnLu ci ve;-
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participat.
in ene
.oc.
of thc uchcJuled y aetie.
.h 13 !
if you have any questionc regarding the faci.:.itf or Lne
'infurtiation nucJed,,jl. case contact Roberts A.
Kanhun at 215-341-5432.
f3incere17,
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.bcc: S.
L.
Daltrofi U.
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en.
A.
Kunhut
- S.. -), Goyle
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RELATED CORaiSPONDENCE
'YlR TOlmEY PINES TECHolOLOGY
)Q PO Box 85608
.b dljll l f P i :46 I'aJ t.
"an D.cyo. Cahtorr a 02138 t'epnone; t610) 455-2654 A oms.on of GA Technologies Inc.
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TFT:005:FDC:84
. June 1, 1984 f6 -352 ]WOD Philadelphia Electric Ccmpany ccmr mc o. a '..-.,. -- ~ ~ ~........-
2301 Market Street S25-1 eo&
Philadelphia, PA 19101 Attention: V. S. Boyer, Sr. Vice President Nuclear Power Gentlemen:
The enclosed status report of the Independent Design Review of Limerick Gen-erating Station Unit No.1 Core Spray System covers the initial period ending May 31, 1984.
Per our previous discussion a copy of this report is being sent directly to the representative of the U. S.
Nuclear Regulatory Ccamission.
Please call me if you have any questions regarding the contents of this report.
Sincerely, 1# C
[
8 F. D. Ca nter FDC/dn Project Manager Encl.
cc: PECO:
R. A. Mulford N2-1 E. C. Kistner J. Moskiwitz L. B. Pyrih G. J. Beck Bechtel:
S. J. Ployhar USNRC:
Jim Milhoan, Chief Licensing Section Quality Assurance Branch, Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission EWS-305A Washington, DC 20555 i
cc:
Copy to' Limerick Service List
{
lyeof 4
INDEPENDENT DESIGN REVIEW 0F LIMERICK GENERATING STATION UNIT 1 CORE SPRAY SYSTEM Bi-Monthly Status Report #1 Period Ending May 31, 1984 i
Introduction This is the first of six planned bi-monthly sta.tus reports.
This report includes a samary of historical information leading to the contract for Torrey Pines Technology to conduct an independent design review of Limerick's Core Spray Systems.
Status Report #1 smmarizes the work performed in the initial stages of the program.
Information on accomplishments to date is presented for each.aubtask with overall milestone achievements smmarized in Table I.
~
Historv Torrey Pines Technology (TFT) sutmitted a proposal (GACP 42-176) on February 16, 1984 at the request of Philadelphia Electric Ccmpany to conduct an indeper>-
dent design review of Limerick's Core Spray Systcm (CSS).
Subsequent discus-sions between PECO, TFT, and the NRC resulted in a program plan which was presented to PECO on May 4,1984.
The following week the program plan was presented at a May 9,1984 public meeting in NRC's Bethesda, Maryland office.
A May 15,1984 letter to Philadelphia Electric Ccmpany found the program plan acceptable subject to a few programmatic clarifications and protocol modifica-i tions.
The original program plan. dated May 7,1984 was changed to incorporate the NRC clarifications and was issued as Revision A.
Detailed Status i
i On May 15,1984 Torrey Pines Technology's project team leadcrs held a kick-off meeting in San Francisco at the Bechtel office.
In attendance 'were project and/or technical representatives frcm Bechtel, GE, PECO, and the NRC.
The TPr project team presented and explained the program plan and the five level review process for potential findings.
Specific design docments and information initially required for the design review were requested of designated represen-tatives.
The TPr project office initiated the independent design review program plan on May 21, 1984 when concurrence to the revised Program Plan was given by the NRC.
Initially the project organization was established in response to the proposal.
Assembly of the project manager and task leaders followed with specific selec-tion of the supporting technical staff.
Project specific procedures were initiated after indoctrination training of assigned personnel in the project scope and objectives.
A Quality Assurance Program Doctment (QAPD-2524) was 4
generated, reviewed, approved internally, and sent to PECO on May 17,1984 for their approval before publication. The detailed status for each subtask identi-fled in the Program Plan is presented below.
A w
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Task A' Desian Procedure Review Al Procedure 2524-PD-1 was completed and issued on 5/24/84.
A2 A detailed description of the complete structure of the design control procedures applicable to the CSS design work is in progress.
On-site visits A3 TPr has received some copies of the design procedures. '
will be required to. complete the selection.
^
A4 A request was made of Bechtel to identify the design control procedures used for the Limerick plant to those used for the Palo Verde plant.
A5 No activity to date A6 No activity to'date.
A7 No activity to date.
Task B Design Procedure Imolementation Review B1 Procedure 2524-PD-2 was completed and issued on 5/24/84.
f B2 No activity to date.
B3 No activity to date.
B4 No activity to date.
B5 No activity to date.
+
j Task C Technical Review Cl Procedure 2524-PD-3 was completed and issued on 5/29/84.
C2 The prepa' ration of the design chain which identifies the major design organizations and their interfaces for major structures and components in the Core Spray Syste was initiated.
C3 The initial selection of specific components and major features have been identified for the detailed design review.
C4 Obtaining current design docments fra Bechtel continues.
Obtaining design docments fra GE is pending until the confidentiality agrement is signed.
A visit to Bechtel's offices on May 23 and 24 was productive in screening drawings and calculations for review purposes.
Specific calculations and/or portion of calculations for piping, pipe supports, process flow, and high/ moderate energy pipe breaks were identified.
Responsibilities were also established for the qualification of GE and Bechtel furnished components.
The technical design review of ASE Class 1 piping design was initiated.
05 No activity to date.
C6
_ No activity to date.
~,
di*'
l Task D Physical Verification I
D1 Procedure 2524-PD-4 was prepared and approved.
Publication date was 5/31/84.
D2 The portions of the CSS to be physically verified in an on-site walkdown have been identified.
D3 ne walkdown will commence the week of June 3,1984.
D4 No activity to date.-
Task E Potential Findings F1 Ee project manager established the Potential Findings Review Car.mittee on May 18,1984.
The committee menbers are senior techincal personnel with broad experiences in engineering.
We committee members are as follows:
S. L. Koutz, Qiainnan Chief Engineer F. O. Hall Mgr. Mechanical & Electrical Engineering R. G. Wunderlich Mgr. Component Engineering
'T. R. Colandrea Director, QA and Compliance A. M. Harris Senior Technical Advisor l
This committee will be responsible for the processing of any potential findings as described in Task E of the program plan.
E2 Re criteria for determining the degree of impact of Potential Findings on the design adequacy of the Limerick Core Spray System has been estat>-
lished and is docunented in a detailed procedure under Task E3 E3 Procedure 2524-PD-5 was completed and issued on 5/30/84.
NOTE:
All milestones for Task E are complete.
Future status reports will include data on potential findings.
Task F Administrative and Reoorting Project Management's initial effort has involved the selection, indoc-trination, and training of personnel to the program, the developnent of schedules and cost data to achieve task objectives, a Quality Assurance Program Docunent (QAPD) and Project Directives for direction and guidance. A procedure, 2524-PD-6, on protocol for maintaining independent relationships in communication betwcon PECO, Bechtc1, GE and TFT was written and will be issued by 6/1/84.
6
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TABLE I CORE SPRAY SYSTEM INDEPENDENT DESIGN REVIDI TASK / MILESTONE STATUS Milestone Subiect
.Scb Actual Document Al Procedure / Checklist 5/30 5/24 2524-PD-1 A2 Procedure Structure 6/15 A3 Access Desii;n Frocedures 6/15 A4 Bechtel Review 7/05 A5 PECO/GE Review 7/05 A6 Time-period Procedures 7/10 A7 Task Sunmary 7/24 B1 Procedure / Checklist 5/30 5/24 2524-PD-2 B2 Docunent Selection 6/ 15 B3 Docunent Location 7/01 B4 Docunent Review 7/27 B5 Task Sunmary 8/10 C1 Procedurc/ Criteria 5/30 5/30 2524-PD -3 C2
' Design Chain 6/08 C3 Feature Selection Cont 2524:ENG:02:AS:84 C4 Design Review 8/10 C5 Independent Analysis 7/27 C6 Task Sunmary 8/17 D1 Walkdown Procedure 5/30 5/31 2524-PD-4 D2 Item Selection 6/04 5/29
. 2524-ENG :03:AS:84 D3 Ccrnplete Walkdown 6/27 D4 Task Sunmary 8/10 El Establish Ccanmittee 5/30 5/18 Proj. Directive #3 E2 Define Criteria 5/30 5/25 2524-PD-5 E3 Procedure 5/30 5/30 2524-PD-5 E4 Processing PFRs Cont F1 Management / Cost Cont F2 Protocol Procedure 6/01 F3 Status Reports Cont F4 Information Compilation 8/15 F5 Final Report Draft 8/24 F6 Final Report-Issue 8/31 e
9 e
'aqf*
cc: Judge Lawrence Brenner Judge Peter A. Morris Judge Richard F. Cole-Troy u. Conner, Jr., Esq.
Ann P. Hodgdon, Esq.
Mr. Frank R. Romano Mr. Robert L. Anthony Zori G. Ferkin, Esq.
Mr. 'Itlomas Gerusky Director, Pennsylvania Emergency Management Agency Charles,W. Elliott, Esq.
Angus Inve, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Martha W. Bush, Esq.
Spence W. Perry, Esf.
Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal uoard Atomic Safety & Licensing uoard Panel Docket & Service Section James Wiggins Timothy R. S. Cam,@ ll 4
i e
d O
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l j
~
-RELATED CCRRZ5?CNDENCE 2CC,(Err, us;;s:'
PHILADELPHIA ELECTRIC COM PANY g
2301 M ARKET STREET P.O. BOX 8699
,;. _,hf,;
b 7 lbb4 PHILADELPHIA. PA.19101 JOHN S. KEMPER vic s-en ess O E NT EM64mEEnome aMD HEREanCM Mr. A.
Schwencer, Chief Docket Nos.:
50-352 d <-
~
Licensing Branch No. 2 50-353d4 Division of Licensing U.
S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Limerick Generating Station, Units 1&2 SER Confirmatory Issue #1
Reference:
NUREG-0991 File:
GOVT l-1 (NRC)
Dear Mr. Schwencer:
Confirmatory issue
- 1 of the reference requires Philadelphia Electric to revise FSAR Tables 3.2-1 and 3.2-2.
Attached are draft FSAR pages that will be included in FSAR Revision 34 which will be submitted in July.
The attached pages provide additional information describing Limerick compliance with Regulatory Guide 1.26, Revision 3, and the codes and standards used in construction.
Providing this information satisfies the SER requirement to enable closure of confirmatory issue #1.
Sincerely, l
j-H JLP/gra/060584925 cc:
See Attached Service List i
J
- sw cc
- Judge Lawrence Drenner (w/o enclosure)
Judge Richard F. Cole (w/o enclosure)
Troy B. Conner, Jr., Esq.
(w/o enclosure)
Ann P. Hodgdon, Esq.
(w/o enclosure)
Mr. Frank R. Ibtano (w/o enclosure)
Mr. Robert L. Anthony (w/o enclosure)
Charles W. Elliot, Esq.
(w/o enclosure)
Zori G. Forkin, Esq.
(w/o enclosure)
Mr. Thanas Gerusky (w/o enclosure)
Director, Penna. Emergency (w/o enclosur,e)
Managenent Agency Angus R. Love, Esq.
(w/o enclosure)
David Wersan, Esq.
(w/o enclosure)
Robert J. Sugarman, Esq.
(w/o enclosure)
Spence W. Perry, Esq.
(w/o enclosure)
Jay M. Gutierre::, Esq.
(w/o enclosure)
Atanic Safety & Licensing (w/o enclosure)
Appeal Board Atanic Safety & Licensing (w/o enclosure)
Board Panel Docket & Service Section (w/o enclosure)
Martha W. Bush, Esq.
(w/o enclosure)
Mr. James Wiggins (w/o enclosure)
Mr. Timothy R. S. Canpbell (w/o enclosure)
Ms. Phyllis Zitzer (w/o enclosure)
Judge Peter A. Morris (w/o enclosure) 9 B
l 1
}*
i REl.ATED CC.UES?ONDENCE
$0 PHILAD ELPHI A ELECTRIC COM PANY 23O1 M ARKET STREET sE7/ ll P1 :45 P.O. BOX 8699
, yr c,
000,. [,-},gh,;
PHILADELPHIA. PA.19101 J O H N *p 8( E MP C H w sC C Pfe C SIO C *e f
....u
......s....
Mr.
R.
G.
Page, Chief JUN 7 1904 Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS
'f;((,] p- ' -... s.......g y
U.
S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Limerick Generating Station, Unit No. 1 Special Nuclear Material License Application
Reference:
- Letter, B.
L.
Serini (NRC) to S. F.
Payton (PE) dated April 25, 1984.
File:
GOVT l-1 (NRC)
Dear Mr. Page:
In reference letter, Mr. Serini of your staff requested additional information regarding our Special Nuclear Material (SNM) license application.
We have reviewed this letter and have included the requested additional information to our SNM license application. to this letter includes the pages to our application that have been revised as a result of the additional in formation requested.
All revisions to the text each page are indicated by a vertical line in the right on hand margin of the page. includes copies of the applicable parts of the Limerick FSAR referenced in the revised acetions of the licenso application.
In preparation for movement of new fuel to the fuel floor we have need to acquire additional calibration sourceu containing special nuclear material and source material.
A replacement page to our application (included in attachment 1) contains the information regarding thene sources.
A..
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Our current construction schedule calls for fuel to be moved from the outdoor new fuel storage area to the refueling floor on July 9, 1984.
To support this date we request that the remaining portion of the license authorizing the movement of fuel to the refueling floor for inspection and storage in the fuel pool be issued by July 2, 1984.
If,you should have any questions or need clarification of any of this information please contact S.
F.
Payton (215-841-6384).
Thank you for your cooperation.
Sincerely, Q0D.L __
d Y
SFP/gra/053084145 Attachments cc:
See Attached Service List s
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o cc: Judge lawrence Brenner (w/encionure)
Judge Richard P. Cole (w/ enclosure)
Troy B. Conner, Jr., Esq.
(w/cnclosure)
Ann P. Ilodgdon, Esq.
(w/ enclosure)
Mr. Frank R. Pcmino (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Charles W. Elliot, Esq.
(w/ enclosure)
Zori G. Ferkin, Esq.
(w/ enclosure)
Mr. Thmus Gerusky (w/ enclosure)
Director, Penna. Emergency (w/ enclosure)
Management Agency Angus R. Iove, Esq.
(w/ enclosure)
David Wersan, Esq.
(w/ enclosure)
Pobert J. Sugarman, Esq.
,(w/ enclosure)
Spence W. Perry, Esq.
(w/ enclosure)
Jay M. Gutierrez, Esq.
(w/ enclosure)
Atcmic Safety & Licensing (w/ enclosure)
Appeal Board Atcaic Safety & Licensing (w/ enclosure)
Board Panel Docket & Service Section (w/ enclosure)
Martha W. Bush, Esq.
(w/ enclosure)
Mr. James Wiggins (w/ enclosure)
Mr. Timothy R. S. Canpbell (w/ enclosure)
Ms. Phyllis Zitzer (w/ enclosure)
Judge Peter A. Morris (w/ enclosure) i 4
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permit night surveillance of the fuel.
The first core of fuel for Unit I (764 assemblies) will be stored in three (3) piles with sixty-four (64) containers in each pile stacked four (4) high and sixteen (16) across; and four (4) piles with f orty eight (48) containers in each pile stacked four (4) high and twelve (12) across.
A spacing of twenty-five (25) feet will be maintained between any two piles and between each pile and the How Fue! Storage Area fence.
The fuel wi!! be stored in the outer wooden Reactor Assemblies (RA) containers and each pile of fuel wi!! be covered by a five-sided box manufactured out of corrugated metal.
As a further precaution against fire, sufficient hose line will be available such that water can be directed to the fuel from two different locations.
Lightning protection will be provided by an overhead transmission line.
The weight of each pile of fuel is sufficient to withstand windstorms of 100 year mean recurrence interval.
l.2.2 Activities in Adlacent Areas In the areas adjacent to the New Fuel Storage Area there exist permanunt buildings.
In addition th9re is a permanent building that wi!!
be used for of fices or a change house.
There is also a substation adjacent to the New Fuel Storage Area on the north side.
Activities in adjacent areas will be of a nature such that the safety of the fuel will not be affected.
Equipment used to unland and inspect new fuel is located in the areas adjacent to the spent fuel pool, as we!! as reactor vessel components and shield plugs.
Novement of fuel and certain reactor vessel components and shield plugs is administratively controlled so that the safety of the fuel wi!! not be affected.
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i 1.2.3 I n do o r-S t o r a rt e Facilities and Env i r> men t The Spent Fuel Pool, as illustrated in Figure 1.2-14 of the Limerick Final Safety Analysis Report (FSAR), is on integral structure within t he React or Enclosure.
The fuel storage facilities and handling equipment are designated 1
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1 wi t h t he issue of the ASIM specifications in effect in March 1979, as applicable.
The quality assurance program in use at the time of procurement and fabrication of the containment cans and boral conformed to the requirements of 10CFR50 Appendix 8 and to ANSI H45.2.
A chemi al analysis'or neutron attenuation test was performed on each boral sheet to confirm the 8-10 loading was within specifications.
Physical characterist ics of the boral plat e such as width, length, thickness, squareness and flatness were 100% inspected to assure compliance with neut ron absorber plate specifications.
The containment cans were 100% dimensionally checked for length, width and thickness.
All containment can welds were inspected and the containment cans were leak tested in accordance with the speci f icat ions prior to rack assembly.
+
To con f i rm t hat t he po i son can s meet t he design specifications before and after their installation in the racks, a!!
poison cans were inspected by a rack supplier 9.C. Inspector for dimensions.
weld quality and the presence of boral before the cans were installed in the racks.
After the poison cans were installed and the rocks assembled, a
final inspection was performed on the rack for dimensions and functional checkout.
The functional checkout tests consisted of a dummy bundle drag check for' obstructions f or each can.
The results of t hese inspections were documented and retained as permanent records.
Upon receipt at the Limerick job site, the fuel rocks were reinspected for e
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o dimensions, weld quality, cleanliness, etc.
- Also, en independent 100% boral presence test and full length dummy bundle check for obstruction were performed.
These test results were' recorded, reviewed and are maintained as permanent records.
The controls to ensure that the poison cens are installed in their location in the racks before fuel assemblies are stored in the rocks are as follows:
Each poison can is serialized and the location of each is recorded on a can location map'byia rock supplier 9.C.
Inspector.
These maps become part of the final documentat.fon package and are reviewed by the rack supplier Q. A.
Engineer for the project and the responsible PECO'. project engineer.
Upon receipt..at.the Cimehick; job site the location of thisIpoikon cans was verif, led. 'The"tgo'IVon0can's will not be removed:st.'Limedick. Generating Station at anystide.' JE 6
1.2.3.2 Reactor Enclosure Crane The reactor enclosure crane is a bridge crane mounted on' runway rafts that are supported by the reactor enclosure superstructure. The reactor enclosure crane is designed to handle loads with a maximum weight of 125 tons while maintaining a minimum safety factor of 5.
There is also an auxiliary hoist with a design capacity of 15 tons.
The i
reactor enclosure crane is designed to rt/
prevent movement of the crane over the new fuel and spent fuel storage areas in t he absence of speci f ic act ion by t he 4
crane operator to allow such movement.
Figure 1.2.3.2 illustrates the areas of l
j restricted crane movements.
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o addition, the movement of loads heavier than fuel assemblies over the spent fuel pool, utilizing the reactor enclosuure crane, is prevented by the use of administrative controls addressing the guidance of HUREG-0612 and by electrical interlocks (see applicable Limerick FSAR Sections 9.l.2.3, 9.l.5.2.e, and 9.1.5.43.
l.2.3.3 Fuel Servleina Enuloment The fuel servicing equipment consists of apparatus as described belows a)
New Fuel Insnection g6and The new fuel inspectin stand (Figure 1.2.3.3(a)) serves as a support for the new fuel' bundles undergoing receiving inspection and provides a working platform for technicians engaged in performing the inspection.
b)
Chann e l Handline Tool The -1.annel handling tool (Figure 1.2.3.3(b)) is used in conjunction with.the fuel preparation machine to remove, instatt, and transport b
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4 1.2.4 Fire Protection 1.2.4.l How Fuel Storace Area The fire protection in the New Fuel Storage Area as described in Section 1.2.1.1 of t hi s appl icat ion cons i st s o f five-sided boxes manufactured out of corrugated metal placed over each pile l
of fuel.
In addition, sufficient hose lines,will be available such that water can be directed to the fuel from two different locations.
Access to this area will be controlled as described in the Physical Security Plan (see Sect ion f.3 of this applicat ion).
A fire hydrant or portable fire extinguishers will be available for use during the i
transfer of the new fuel from the New 4
Fuel Storage Area to the Reactor Enclosure.
1.2.4.2 Reactor Enclosure The fo11 ewing fire protec, tion components will be operative prior to new fuel i
being moved within the Reactor Enclosure.
At least one of two water
- sources, i.e.,
cooling tower basins (see Section 9.5.1.2.2.1 of the Limerick FSAR), and two fire pumps (see Section 1.5.1.2.2.2 of the Limerick FSAR) capable of providing necessary water flow rates and pressures to the hose stations or hydrants protecting the Reactor Enclosure airlock and the refueling floor will be available.
l.3 Phvelcal Protection Ap'plicant's plan for the Physical protect ion of the i
material to be received pursuant to the requested license is contained in a document entitled " Limerick Generating Station, Physical Security Plan for Protection of Special Nuclear Material of Low Strategic I
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r Significance" dated April, 1983 and subsequent amendments which is Exhibit 2 ta this App!icat ion.
Since the Security Plan contains Saf eguards Information detailing Applicant's security measures for the physical protection of special nuclear material, the Security Plan was transmitted under separate cover with a request that it be withheld from public disclosure.
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2.0 HEALTH AND SAFETY 2.I Radiation Con M This Section provides information regarding radiation safety at Limerick Generating Station.
i 2.1.1 Minimum Qualifications for Positions Hevina j
Radiation Safetv Resoonsibilities The minimum qualifications for the Senior Health Physicist (Rediation Safety Officer), are those outlined in Section 4.4.4 of ANSI /ANS-3.5-1978, "American Hattonal Standard for Selection and Training of Nuclear Power Plant Personnel." Any Individual who would temporarily replace the 4
Senior Health Physicist.allt have the minimun i
qualifications described in Section 4.4.4(d) of ANSI /AN5-3.1-1978.
The Applied Health Physicist and Support Health Physicist (Assist R50's) will have as a minimum a 4 year degree in Health Physics or a related field and at least 24 months applied Health Physics experience, i
2.l.2 Resnonsibilitten for Radiation Safetv Personnel The responsibilit ies for the key radiat ion safety i
personnel are described by the following
" Radiation Safety Program" description.
4 The radiation safety program will be directed by the Senior Health Physicist.
Assist ing the Senior Hemith Physicist are the Support Health i
Physicist and t he Appl ied Heal t h P hys ic i s t.
B o t h o f t he se po s i t ion s have t he au t hor i t y t o ac t i
for the Senior Health Physicist in his absence.
The object ives of health prysics operat ions are to:
s.
Detect, Identify, and define radiation hazards.
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b.
Provide protection for personnel against
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Control plant-related radiation exposures (occupational and general h
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public) to levels as low as reasonably achievable (ALARA),
d.
Conduct plant activities in conformance wi t h aut hor i zed procedures and applicable regulations.
These object ives are accomplished or enhanced by 9
the various training programs, by the use of prepared Health Physics operat ing procedures, by periodic review and revision of procedures, by evaluation of activities for ALARA purposes, and by the control of plant operations to minimize occupational exposures and releases to the environment.
Health Physics operat ions include the posting, notification, and reporting provisions of 10CFR, Part 19, and General Employee Training or, in some cases task specific instruction, provides the requisite instruction to workers.
Health physics operat,lons conform with the guidelines of Regulatory Guide 8.2 (Rev. 0) and of ANSI Nf3.2-1969, Guide for Administrative Practices in Radiat ion Mo.."oringi with the clarificat ion that controlled areas which are locked or otherwise prevent personnel access are not required to be surveyed at a specific periodicity.
Sections 13.1.2.12, 13.1.2.13 and 13.1.2.14 of t he L imerick F5AR describe the responsibilit ies of the Senior Health Physicist, Physicist-Applied, and the Physicist-Technical Support respectively.
These positions are and will be functional during receipt and handling of SNM.
Section 13.2 provides a description of various training programs at LOS.
Although the programs described in this section do not apply specifically to Health Physics requirements of the 5HM License, all t ec hn i c ian s involved in the receipt and handling of SNM are trained and quillfied in those Health Physics procedures
,ociat ed wi t h SNM act ivi t ies. ' Sections a
13.5.l.21 and 13.5.2.2 of the Limerick FSAR address the preparat ion and use o f Heal t h Physics il F-
e procedures.
Those procedures used for the receipt and handling of SNM have been prepared and used in accordance with these sections.
Section 12.1 of the Limerick FSAR describes the policy, design and operation considerations of the LGS ALARA program.
Although not specifically addressed in Section 12.1, the receipt and handling of SHM will be consistent with the considorations set forth in this section and implemented through station HP procedures.
Section 17.2A of the Limerick FSAR describes the quality assurance program during the operations phase and addresses the administrat ive controls for various operational activities, including Health Physics.
These controls are implemented in administrative procedures which address approval of procedures, training, control of survey equipment, etc.
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The portion of the ifualth Physics program colated to special nuclear materials is outlined as follows:
RADIAff0N PROTECTION PERSONNEL Senior Heal t h Phys le i s t (Radiation Safetv Officer)
The Senior Health Physicist report s through the Assistant Station Superintendent to the Station Superintendent and receives technical direction and support from the Offsite Director-Radiation Protection Section.
The Senior Health Physicist corresponds to the Radiation Protection Manager as desctibed in Regulatory gude 8.8-1977 (Revision 3) and 8.10-1977.
His duties / responsibilities in this capacity includes Developing and implement ing an ef f ect ive a.
radiation exposure control end measurement program in consonance with the PECO ALARA policy.
b.
Ensuring that exposure measurement and control programs are periodically reviewed and that appropriate revisions and corrective actions are taken when the results of these programs Indicate t hat such act ions are needed to conform to the PECO ALARA policy.
Preparing and reviewing procedures for c.
implementing the ALARA policy.
d.
Ensuring t hat the resources needed to implement the ALARA policy are evallebte and used.
Participating in reviews, including e.
design and procedure reviews at the Plant Operat ' ens Review Commit t ee( PORC) r l a.
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level, of facilitlose activitles, and equipment i
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that enn affect potential radiation exposuros.
(Note:
The PORC functions to advise the Station Superintendent on matters related to nuclear safety.
The Committee consists of plant staff members as described in Lsmerick FSAR Section 13.4.2.
Qualification requirements for plant staff members are as specified in ANS!/ANS-3.1-1978 and Regulatory Guide 1.8 (Rev. 1) as described in Limerick FSAR Section 13.l.3.1.
Relative to the SNM license, the PORC is responsible for the review of procedures, and changes t hereto, t hat affect nuclear safety).
f.
Supervising radiation, surface contaminallon, and airborne activitity surveys end supervising the review of resulting data to identify locations, operat ions, and condit ions that have the potentist for causing significant exposures and devoleping appropelate means for reducing such exposures.
g.
Part icipat ing in the development of training programs related to the ALARA program to ensure that personnel ere aware of PECO management's commitment to ALARA and are instructed in ways of reducing exposur2s that are related to work in radiat ion areas or that involve radloactive materials.
h.
Supervising the radiation surveillance program and the collection, analysis, and evolution of data from radiological surveys and from personnel exposures and doses, including the use of the radiation work permit data.
B 6.
Supervising and training of the health physics staff.
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Providing appropriate dnta and information related to the ALARA program, and results, to the Station Superintendent and to the Director-Radiation Protection Section to keep company management informed about the
- program, k.
Acting as Radiation Protection Manager.
In his absence, a person temporarily filling this positten will have a BS r
degree in engineering or science with two years experience in radiation protectlon, one year of which shall be 1
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The radiation hazards associated with the receipt and movement of SNN are minimal.
However, in keeping with management's policy that radiation exposure to station personnel and the general public be kept "As Low As Reasonably Achievable" (ALARA). the fo!!owing steps are taken A.
During transfer of fuel from the storage area to the refuel floor.
HP will be providing full coverage of all activities including surveys and smears of the shipping containers and their inner containers.
B.
A continuous air monitor (CAN) shall be.present and operable on the fuel floor prior to and during the handling of new fuel assemblies.
C.
During the inspection and handling of the new fuel, HP will also be providing full coverage of all activities including surveys and smears inside the inner container lid, the outer surface of the plastic sleeve, and the fuel assemblies.
D.
During the transfer, handling and inspection of new fuel, access is restricted to only those individuals t hat have a need to be in the area as defined by an Access Control list, thereby reducing ex po vs r o s.
Personnel on the list will have received training on the necessary radiological precautions to be taken.
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e 2.1.3 Traininn end Ewoariance The experience of the Health Physicists is presented in Figures 2.1.3(a) - 2.1.3(z).
The training ne~cessary for Hoolth Physicists is outlined in Section 12.5. 3.5 o f t he Limerick FSAR.
2.1.4 Procedures and Eauioment for Checkina Contamination The Health Physics personnel will be not ified when a shipment of new fuel or instrumentation containing Special Nuclear Material arrives on site.
Health Physics personnel sha!! perform complete radiation and contamination surveys of the outside of the transport vehicle to ensure t hat the radiat ion levels are within acceptable limits.
If all survey data is within limits, the vehicle will be moved to the New Fuel Storage Area,to proceed with unloading.
If survey data is above established limits, appropriate actions, as defined in Plant Operations Review Committee (PORC) approved written station procedures, will be fo!! owed.
2.1.5 Calibration and Testina of Instrumentation All instruments sha!! be tested and calibrated routinely in accordance with approved station procedures.
The portable survey instruments that are used during the receipt and handling of all SHM are calibrated every six months.
Instrument 1
calibration will be performed by qualified I
station personnel or through a vendor.
Each instrument will bear a sticker indicating the i
date when rece!Ibration is due.
2.i.6 Procedures and Enulomont Used to Meet Anolicable Sections of 10CFR Part 20 The Limerick Generating Station will be operated and maintained in-such a manner as to ensure that occupational radiation exposures are ALARA and 1
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that protection against radiation is in accordance wit h 10CFR, Part 20.
Health Physics procedure SHP-210 " Administrative Dose Limits, Guidelines and Hotification Requirements" provides the methods by which exposures are contro!!ed at the Limerick Generating Station.
It is PECD policy to maintain exposures of personnel at LGS to radiation below the limits specified in 10CFR20. lot.
The Administrative Exposure Guides in effect at Limerick Generating Station are as fo!!ows:
Whole Body; head, trunk, active blood forming organs, lens of eyes, or gonads.
A.
100 mrem /9uarter for Hon-PECO personnel without a current HRC Form 4.
8.
1000 mrem /9uarter for PECO personnel without a current NRC Form 4.
C.
2500 mrem / Quarter with a current NRC Form 4 and lifetime accumulated dose which will remain less t han 5 (N-18) Rem where N is the individual's age in years at his last birthday.
D.
300 mrem / day if Quarterly balance is great er t han 400 mrem.
100 mrem / day if quarterly balance is less t han or equal to 400 mrem.
E.
No entry into the Radiologically Controlled Area without Senior Health Phys icist approval if quarterly balance is less than or equal to 100 mRom.
F.
There will be no work in high radiat ion areas (great er. t han 100 mrem /hr) by individuals with remaining permissible quarterly balances less than 400 mrem ISA 6
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unless approved by t he Senior lleot t h Physicist.
G.
Ho PECO employee's yearly dose will exceed 4500 mrem without prior opproval of the Station Superintendent or his alternate.
H.
Prior authorization must be obtained via e dose extension to permit exposures in excess of the Daily Guides which are as follows:
Hand and Forearms; Feet and Ankles 1.
1,500 mrem / day 2.
15,000 mrem / Quarter Skin of Whole Body I.
600 mRim/ day 2.
6,000 mR'em/ quarter The minimum frequency for reading p'ersonnel dosimeters (TLD's) is one month unless otherwise specified by t he Sen ior Heal t h Phys ici st.
In addition, individuals will also be provided with direct reading dosimeters so that exposures may be estimated on a daily basis.
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2.l.7 Provisions for Disnosal of Radionctive Wastes Radioactive wasto will not normally be discarded prior to plant operation.
The small quantities of radioactive waste generated in the survoying of SHN items for contamination will be stored in the Source Storage Room or other approved location until a contract with a commercial wasto disposal service is established.
Shipment of radioactive waste is strictly controlled by Health Physics Procedures which comply with 10CFR71 and 49CFR 171-178.
2.2 Nuclear Criticalitv Safetv 2.2.1 Minimum Qualifications for Positions Havina Nuclear Criticality and Fuel Handlina Resoonsibilities The key posit ion having nuclear crit icality safety and fuel handling responsibilities is the Reactor Engineer.
He is responsible in as much as he generates procedures for fuel handling that incorporates nuclear criticality safety guidelines.
These procedures are t, hen reviewed and approved by the PORC.
The minimum qualification for the Reactor Engineer are those stated in ANSI /ANS-3.1-1978 Section 4.4.1.
2.2.2 Resoonsibilities for Personnel Havina Huclear Criticalltv and Fuel Handlino Resoonsibilities The key personnel responsible for nuclear criticality safety and fuel handling is the Reactor Engineer.
The Reactor Engineer reports to the Technical Engineer and is responsible for determining and monitoring core performance and for establishing appropriate operating guides and procedures to ensure safe, economical reactor operation in compliance wit h t he operat ing license and technical specifications.
The Reactor Engineer provides technical advice and i
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e stored no higher than a four high configuration.
The criticality analysis to support the safety of the above describod array can be found in a May 4, 1978 letter (and i t s at tachment s) from A.
L. Kaplan (Genocal Electric Company) to L. C. Rouse (Huclear Regulatory Commission).
An area survey at the final temporary storage location shall be perf ormed by ifeal t h Phys ics personnel on an as required basis.
The minimum distance betwoon a pile of loaded shipping containers on the refueling floor; and the unloading stat ion, inspection stand, and open shipping containers will be five (5) feet.
The minimum distance from the spent fuel racks to a pile of loaded shipping containers on the refueling floor will be 23 vertical feet.
By maintaining a minimum distance of five (5) feet between the pile of loaded shipping containers and the other areas where fuel assemblies will be handled precludes the' possibility of accidental criticality.
2.2.5.4 Removal of Fuel Bundles From Shionina Containec and Insooetion Before fuel bundles are removed, the metal RA containers (lids comoved) are upended and placed in the unloading station located near the new fuel inspection stand.
The metal container end piece is then comoved.
Health Physics personnel make a survey of removable contamination on the outside of the plastic bag covering the bundle.
The bundle is then visually inspected for damage.
The respective fuel bundle is comoved via the auxiliary hoist or cherry picker and transferred to and secured in the new fuel inspection stand.
The acceptance inspection is w
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perf ormed wi t h ei t her one or two fuel bundles in the vortical position.
Fuol bundles that do not pass acceptance inspection are returned to their shipping containers.
A Defective Tag w i l'1 bo placed on the exterior of the shipping container and the discrepancies noted.
2.2.5.5 Channeling in the New Fuel Insnection Stand Upon completion of the fuel inspection, each bundle is channeled in the New Fuel Inspection Stand.
A channel is selected and positioned above the fuel bundle.
The channel is lowered onto the fuel bundle and secured with the Channel Fastener Assembly.
Following the completion of the channeling process, each assembly is transferred to a 4
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o storage location in the ' Spent Fuel Storage Pool by the refueling bridgo.
2.2.6 Exemntion 2.2.6.1 Criticalitv Ageidant Rcouiraments The procedures and storage facilities described in this application provide assurance that inadvertent criticality cannot occur during receipt, possession, and storage of new fuel assemblies at Limerick Generating Station.
The General Electric shipping containers in which fuel will be received meet the Fisslie Class I requirements defined by 10CFR71.
In addition, the Spent Fuel Pool is designed to ensure suberiticality by at least five (5) percent A k under all condit ions (see Section 2.2.4.3).
Furthermore, the procedures for unloading and inspecting the new fuel are based in part on the prevention of criticality during these operations.
The total mass of SHM contained in all instrumentation (see Section 3.0) is less t han 15 grams.
Accordingly, no l
special precautions to prevent criticality are required when handling the neu instrumentation.
Based en the above discussion, Philadelphia Electric Company requests exemption from the requirements of 10CFR70.24 as provided in 10CFR70.24(d).
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c 2.3 Accident Analvsis 2.3.1 New Fuel Storace Area In the New Fuel Storage Area, only one shippin~g container at. a timo will be handled by any single fork-lift truck during loading and unloading of the flatbed truck.
General Electric Company has conducted hypothetical accident condition tests of the inner metal shipping containers in the sequence specified in Appendix B to 10CFR71 and the inner metal containers passed the acceptance criteria as described in NRC Certificate of Compliance USA /4896/ for'the General Electric RA Series Shipping Package.
2.3.2 Soont Fuel Pool No adverse reactivity effect is expected from dropping a fual assembly on top of a fully loaded storage rack during handling because of the large water thickness (approximately 10 inches) existing between the top of the assemblies already inside the cavities and the dropped assembly resting on top of the rack.
The dropping of an assembly outside the rack is a possible event because of the unobstructed water ocea exist ing betwoon the periphery of the -
storage rock and the side wa!!s o f the pool.
The K ef f for this case was 0.8861, an increase of k:0.003 over the same geometry without the dropped fuel.
A more detailed discussion of this case can be found in Section 9.1.2.3.1.5(b) of the Limerick Generatng Station FSAR.
The structure of the racks is designed to remain functional and to maintain the required spacing between stored fuel assemblies in the event of impact of a fuel bundle dropped on the racks from an elevation of 36 inches.
(The maximum height that-a fuel assembly will be carried over the j
spent fuel racks is 36 inches).
See Section 1.1.2.3.2.1 of the Limorick Generating Station 1
9 43
{L.
l FSAR for a more detailed discussion of this case.
In addition. Section 9.t.2.3.2.5 of the Limerick b
o?s A
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e FSAR addresses the analyses of a dropped fuel bundle.
Extreme caution is exercised during fuel handling to prevent the fuel assembly from striking another fuel assembly or other structures.
In tho unlikely event that a fuel assembly would be dropped, a!! fuel. handling activities would be stopped.
An assessment of the damage would be made and appropriat e correct ivo act ion taken prior to authorization to continue fuel handling activities.
The new fuel assemblies will be stored in the spent fuel pool either underwater or dry.
The determination of whether the new fuel will be stored wet or dry is dependent upon construction schedulding considerations at Limerick Generating Station.
3.0 Other Materials Recuirina NRC License 1
i The following instrumentation (and spaces as required to j
replace defective instrumentation) will be shipped to the Limerick Generating Station site c'ommencing upon issuance of the Special Nuclear Material License.
We anticipate requesting 43 LPRM's (four detectors per LPRM)$ in September, 1983 and 21 or 22 spares for installation
)
following the Operat ional Hydrostat ic Test of the reactor vessel.
SRM, IRM and TIP detector shipment and installatin is to be deferred until a time closer to fuel load to minimize the possibility of damage.
Storage duration of the detectors at the site is scheduled to be as short as possible.
3.1 Instrumontation The following instrumentation contain uranium enriched in the U-235 isotope (as indicated below) in sealed units.
2 a)
Source Range Monitors (SRM):
8 detectors (4 per unit) at 2.7 mg U-235 each (21.6 mg total), > 90%
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Intermediate Range Monitors (IRM): 16 detectors (8 per unit) at 0.75 mg U-235 each (12.0 mg total), > 90% U-235.
c) local Power Range Monitors (LPRM): 344 detectors (172 per unit) at 0.22 mg U-235 each (75.7 mg total) and 0.83 mg U-234 each (285.5 mg total).
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l and.02 mg U-238 (6.9 mg total), with a weight percent composition of 20.6% U-235, 77.6% U-234 and 1.8% U-238.
d)
Traversing-In-Core Probe (TIP):
10 detectors'(5 per unit) at 0.75 mg U-235 each (7.5 mg total), >
90% U-235.
The following instrumentation contain either Pu-239, Th-230 or U-238 in the form of plated sources.
a)
Two calibration sources containing a total of no more than 1500g of depleted U-238.
b)
Two calibration sources containing a total of no more than 50 micrograms of Pu-239.
i c)
Seven calibration sources containing a total of no more than 10 micrograms of Th-230.
l 3.2 Storaae and Handlina Conditions Upon receipt, the LPRM's will be taken to the refueling floor.
In case of unanticipated scheduling problems where the LPRM's cannot be stored on the refueling
)
floor, the LPRM's will be moved to the Stores Warehouse.
SRM, IRM and TIP detectors will be received and l
initially stored on the Limerick Generating Station site in an area located in the Stores Warehouse.
The calibration sources described in Section 3.1 will be j
stored in the Calibration Source Room or other area where access can be similarly controlled.
All storage areas are approved by the Senior Health Physicist.
Access to, authorized use and accountability of these sources are outilned in existing PORC approved plant F
procedures (HP-700 and HP-711).
The sources will be tested in accordance with 10CFR31.5(c)(2).
l-An area on level 253' in the southwest section of the l
Unit i Reactor Enclosure will be temporarily established l
for the storage prior to reactor load of SRM, IRM and l
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l possibly TIP detectors.
An additional area on level 253' in the northeast corner of the Unit i Reactor Building will be temporarily established for the storage of TIP detectors prior to reactor load.
The final location ~that the SRM's IRM's and LPRM's wi!I be stored is in tho reactor vessel.
The final storage location of the TIP detectors will be within the TIP machines and associated tubing.
Spaces and defective equipment (if any) will be stored as described above.
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