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Reply to Separate Answers of Commonwealth of Pa,Applicant & NRC to City of Philadelphia Revised Issues Re Emergency Planning.Certificate of Svc Encl
	ML20091R875
Person / Time
Site:	Limerick
Issue date:	06/12/1984
From:	Smolen H; PHILADELPHIA, PA
To:	;
References
	OL, NUDOCS 8406150302
	Download: ML20091R875 (20)
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yyy M SS M DOCKETE0 r,n.ac AltMIC SAFE 1Y AND LICENSIE BOARD BEETEE ADMINISIRKITVE JUDGES .g"4 J'.g! 14 N1 :34

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1awrence Bremer, Chaiman Dr. Richard F. Cole Dr. Peter A. Morris l

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In the Matter of : D03ET NOS. 50-353-OL l

50-352-OL l PHILADELPHIA ELECIRIC CCNPANY :

(Limerick Generating Station, Units 1 & 2) :. 1 l

REPLY OF THE CI1Y & PHILADELPHIA TO SEPARATE ANSWERS T THE l CCMGWEALTH OF PENNSYLVANIA, APPLICANT AND STAFF l TO THE CITY'S REVISED M9FR IN THE AREA ~

W r2t hrA Y fl.ANNDU i Pursuant to Board Order dated June 5,1984, the City of Philadelphia l

. (City) hereby files its Reply to the' separate Answers of the Ccumonwealth of Pennsylvania (Cmmonwealth or State), Applicant and Staff to the City's

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issues in the area of emergency planning. ,

d CITY 1 In reliance upon the assurances set forth in the Camonwealth's Response dated June 4,1984 to the City's revised and restated issues of concern, as well as those. set forth in the re==nnwealth's letters dated April 13, 1984 ( page 4, item 7 ) arxi May 17, 1984 (page 1, item (2) ),

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inter alia, the City hereby withdraws this issue. True and correct copies of said letters are hereto attached, made part hereof, and are marked Appendices A & B respectively.

CITY - 3 Upon further analysis of the doeur.mt containing an analysis of the effect of a liquid release from the Limerick Generating Station provid&d by Applicant to City on May 15, 1984, and'in reliance thereon; e4061503o2 e40612 PDR ADOCK 05000352 ,

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,and in reliance upon the assurances of the Connonwealth set forth in its l l Response of June 4,1984, as mil as those contained in Appendix A (letter l of April 13, 1984, pages 1-2, Water Depu nuent) attached hereto; and in i

further reliance upon Applicant's written assurance dated May 30, 1984 ;

l confirming that a Ph41*1phia Water Dep=Luent ard a Health Depuuuent i representative will be provided space and cemanications access at the Limerick Generating Station Emergecy Operations Facility, the City of Philadelphia hereby withdraws theissues contained in City - 3 only insofar as they relate to water ti-wputt model and time of connencement of water sampling. A true and correct cryf of the above-mentioned letter dated May 30, 1984 is attached hereto, made a part hereof and is marked Appendix C.

, s It nust be enphasized that the City continues to be genuinely and -

seriously concerned regarding the lack of an alternate water supply and the lack of planning therefor. )bre sp-4}4cally, the Philadelphia Water,. s Depui.u=it operates three water treatment plants.' The Bennont Plant supplies wa'ter to an area of the City west of the Schuylkill River. The Queen Lane Plant, in general, supplies water to the area west of Broad Street aid east of the Scluylkill River. Both of those plants or4142e the Schuylkill River as the raw water source.

In the event of an emergency requiring the cessation of raw water flow frcan the Schuylkill to the City's Queen Lane and Belmont Water, Treat-ment Plants, finished water can be stpplied frcan the Baxter Water Treat-

. ment Plant, which utilizes the Delaware River as a supply source, with the exception of the Belmont High Service District which has no inter- ~

connection with the Baxter distribution systen. The area served by the 2 -

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4 Belmont High Service District borders City Line Avenue and Montgomery County and serves a population of a w icmimately 100,000 people.

The Belmont High Service flow is owicud.mately 15 million gallons 4

per day and the em raw water storage basins at Belmont have a ccrnbined useable c = city of about 50 million gallons. TNs, assuning average flows, non-contamination of the basins, and that the emergency occurs !

when both basins are in service, the Belmont High Service District can be .

provided water for approximately 3 days. If one of the raw water basins is out of service, provision for water will be only 1-1/2 days. fter that

! period of time, if raw water cannot be withdrawn fran the,Schuylkill River, water cannot be provided to this area of the City.

In addition, the assunpcion that the Baxter plant can serve the remainder of the City depends upon the further'assunptioris that no major c+=Es of the Baxter Plant are out of service for maintenance, no major mains, valves db pumping stations needed for the int'erconnections between the Baxter and Queen Lane and Belmont systems are out of service, and,that the average daily flows are not exceeded...T Ns, there is the possibility that other l areasoftheCityalsocouldnotbeservedwithwaterintheeve$tofan

emergency requiring dependence upon the Delaware River as a sole supply source.-

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.There is no existing plan for provision of alternate water supplies.

Since there is no plan, it is not known what the cost will be and/or whether resources are available to provide an alternate water supply to those. areas ,

of the City where the regular. water supply is unavailable.

The State's response appears to dwell upon avoidance of the need for

, an alternate water supply'through avoidance of contamination by " curtail-inent of intake during the course of the passage of the contaminated water".

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While this is certainly an inportant measure to prevent m eer contamination, it is this very preventive measure which gives rise to the need for an alternate water supply. If the Schuylkill River intakes are closed, then as aforesaid, the Belmont High Service D5 strict will be without an available a ter supply, and pos'sibly other areas of the City will be without water if )

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. c c . erns of the Baxter Plant arg out of service. Even ut-414 %g conser-vation measures, an alternate water supply and implementable plan is '

4 required in order to provide assurance that the public will be protected.

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l Staff does not object to achiasion of the issue (Staff Answer, page 4). .

Applicant, on the other hand, boldly maintains that "... there is no legal basis smder IRC's regulations of EREG-06%

for requiring contingency

plans to protect existing uter stpplies fran contamination or to provide

alternative sources of water for downstream users." (Applicant's Answer, 1 i

) p. 11). MREG-06%,Section II., J.11, page M specifically states,- -

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Each State shall specify the protective measures to be used for the ingestion pathuey, including the methods for protecting the pu:>lic from constaption of contaminated f e b effs. ... Iha plan

, shall identify r vcedures for detectina contanination, for estimating the dose cannitment consequences of uncontrolled i

ingestion, and for i= = =ing protection .

i rvcMares such as imm-dnent, decontamination, i 3 processing, decay, product diverstori, and

i preservation. Maps for reev ding survey and -

moni data, key land use data (e.g., farming),

3 dairies, rvcessirs plants, meer sheds, water supply intake and treatment oLrnes and resevoirs sM11 l i be maintained. (Buphasis supp.ied)

. i It is incw d-usible that Applicant: should maintain a position that there '

is no requirement to protect existing applies or to provide alternate , )

. sources of water for downstream users. Moreover, EREG-06%,Section II,

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. I J, 9 (p. 61) states that -

l Each State... shall establish a c e hility

for implementing protective measures based upon protective action guides and other-criteria...

p In view of the fact that the State contemplates protective actions to prevent contamination of water by issuirg timely advisories to close the l

j water intakes, and by reason of the fact that in such event, certain areas L

, i of the City may be deprived of a sater supply after a period of time, as aforesaid, and in view of the fudig fact that M.RiiGo654,Section II, J. !

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9 (p. 61) requires the State to establish a capability for inplanentirs

! protective ==== res based upon protective action nuides, and in view'of the additional fact that the PAGs at page 1.30 reconnend, inter alia, f

j action to provide alternative sources, it is clear that the State Plan is inadequate in failirs to provide an implementable plan for an ,

alternative water styply. It is not enough to tell a downstream water ;

user such as Philadelphia with' its vast :v=1= Hon to " hook i.p" or "obtain" -

l an alternate water source, That is not an hplementable pfan. "Implementabilityt' l clearly includes within J.ts definition, consideration of the " ability" to

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implement, which involves consideration of resources. In the instant i

j matter, not cmly is there not.a plan to provide an alternate source of f water, but considerat. ion of ability to implement is also wholly lacking.

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.It is significant to note that FDE, in its May 8,1984 Interim .

Firmiing on the Offsite RadiologLeal' Bnergency Response Plans (Rl!RP) for the Limerick Generatirs Station, served ein the City by the lac Staff on May 15, 1984, specifically includes, inter alia, the availability of ,

resource.s in the consideration of " ability to implement" protective i measures. (Page 9 of FDE Interim Finding)'

This lack of ability to 5-n a ..-- , - - r- , n., .------m---,,--..,-.-r- -.-n--.r,-- , _ , n .- w m - - , . - - - , - - - - - - -=- - - - . . . - , - , - - - - - - -- -

implement and lack of resources was one of the factors in FDWs interim finding that the Protective Response plaming. standard is incomplete at present. (Page 11 of FDR's Interim Finding). .

Applicant alleges (p. 11 of its Answer) that "the protective actions for water can be either to prevent contamination or des utaminat'on i or condemn the use of water for constaption. If contamination is prevented by i

shutting off water intakes, then an alternative water supply must be planned for. Aithough Applicant cites decontamination as a rem ==nded i P5G planning option, it objects to decontarLnation plaming. In essence, what Applicant appears to be saying is that if you shut-off water intakes 4

to prevent contamination, you don't need an implementable alternative source of water plan. This has been demonstrated to be fallacious. Moreover,

'if cont mmtnation is through aiduue particulate, and/or failure ofi notice

{ to close intakes, and/or due to run-off, then obviously an implementable i

j decontamination plan is needed. Applicant's position is clearly untenable.

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Since there is no implanentable alternate water supply plan, protective 1

j actions owsuyslate for the Philadelphia Ingestion Wm Pathuey have -

3 l not been developed, as required by IOGIM)654, and the Ph:s, and there can j .

be no reasonable assurance that the State Plan can be implemented (there 3

being none as to an alternate water supply), and thus there can be no assurance that adequate protective actions can and will be taken.

(10 CFR $50.47 (a)(1), (2); (b) (10); (c)(2))

4 CITY - 7 The City's concern here is that the State Plan is inadequate I

i l in that it fails to provide a water supply and water systan decontamination plan that is implementable.

In objecting to the Board's consideration of the issue of the lack of 6 --

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a water supply and water system decontamination plan, Applicant states, inter alia, that it is unaware of an NURE-06.% requirement for same.

(Applicant's Answer, page 12) Applicant further asserts that such .

i action imolves long-range considerations. Indeed it does, but the State Plan gives no consideration to it whatsoever, despite the mandate of NUREG-0654,Section II., J. 11 (p. M ). Moreover, Applicant's position is clearly inconsistent: on the one hand, it maintains that long-range considerations are involved, Wille on the other hand, it also asserts that gi,-hoc decisioomaking is necessary on the issue. To decontaminate the City's water supply and water distribution system is clearly not an ad-hoc decisionmaking process. 'Ihere nust be p_anning awmiate for the locale. 'Ibere is absolutely none. .

Staff takes the position, as does'Applicint, that there is no basis, for requiring a decontaninaticn plan. It bears repeating that NUREG-0654,Section II., J.ll1(p. 64) specifically. requires that the State Plan contain

! planning and procedures for decontamination and processing. A full reading

. of this section clearly indicates that water supply intakes, treatment plants and reserwirs are incitried., 'Ibe PAGs Manual not only lists decon-tamination as a protective action (PAGs Manual, page 1.30) but also as a restorative action (PAGs Manual, pages 1.49-1.50). Applicant's position therefore that " recovery and reentry" actions only concern the plume EPZ is clearly contradicted by the PAGs Marmal designation of decontamination 1

of water as'a restorative action. l

'Ibe Ccmnonwealth responds by averring that its plan is adequate to determine when controls on water may be' lifted. Clearly, this does not, address the issue'of the lack of a decontamination plan. 'Ihe Ccanonwealth further states that it has provided technical reference material to the 7 -

City (one such doctanent) and that the subject, to the State's knowledge, has not received extensive treatment; and finally, admits that is the reason for the paucity in the Ccmnonwalth's emeryancy pinn nn the topic. That the State has provided the City with all relevant infonnation knom to it, does not meet the stardard of an implementable plan spywysiate to the locale. As aforesaid, "implementability" clearly includes within its definition, consideration of the " ability" to implement, ditch involves consideration of resources. In the instant matter, not only has "implementability" been overlooked, but in fact, there is no State plan .

for. decontamination of the ater supply and water distribution systen.

An implementable decontamination plan is a vital concern'to the City.

It is clear that since there is no implementable water supply and water distribution sys' tan decontanination plan, protective actions and recovery and restorative actions ayywpulate to the Pb41-41phia Ingestion Exposure Pathway have not been developed as required by -

NUREG-0654, the PAGs and,10 CFR $ 50.47, and there can be 'no reasonable assurance that the State Plan 1:an be implemented (there being none relating to decontamination of water supply and distribution system),

and thus'there can be no assurance that adequate protective actions can and will be taken. (10 CFR $ 50.47 (a)(1), (2); (b),(lO); (c)(2) ).

l i CITY - 9 Withdrawn. In withdrawing this issue, it must be noted that although Applicant asserts that the City "has evidently' overlooked" an existiing Letter of Agreement dated Febnaary 29, 1984, this latter-

Agreement was apparently executed by Applicant on March 16, 1984, but never was supplied to the City until the City, on July 7,1984 received the .

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M M th's response to the City's revised issues. It must also be noted that the lack of such an sa ,c-2 was an issue raised by the City in its initial filing of issues dated February 1,1984 and nferred to again in the City's Reply dated February 28, 1984. The City did not " overlook" the letter-agreement. It was never informed of it. It may be that the City's concern voiced on February 1,1984 and February 29, 1984 regruding the lack of such an agreement prmpted the parties to expedite its av e +1on.

Raspectfully sutmitted, BARBARA W. MNDER City Solicitor MARDIA W. BUSH

, Deputy City Solicitor maixt exd Deputy City Soliciter

y. b . ,m- ,.O Attorneys for the City of Philadelphia Dated: Jtme 12,1984

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COMMONWEALTH OF PENNSYLVANIA l GOVERNOR'S ENERGY COUNCIL -

1625'N. FRONT STREET I i HARRISBURG, PENNSYLVANIA 17102 -

j execuma omes 7ss.eesa April 13, 1984

. l Herbert Smolen !

Deputy City Solicitor Cityy of Philadelphia. -

i Law Department l 15th Floor, Municipal Services Bldg,. !

Ph,iladelphia, Pa. '19102

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. . 1 Re: City of Commonwealth 4/11'/84 meeting on City's Limerick offsite emergency p,lanning contentions

Dear Herb,

N City's Theissues following is La'uperstanding of the status of the as a resu1 J, la,st Wednesday!s meeting. l Referencesare to " Items for ITFsoussion with the Comm',onwealth" J first pre,sented at 3/22/84 C.ity-Commonwealth meeting. 1 1

Water Department s

1. State agrees to analyze for r,adiosotivity two samples per, i month of sludges in Belmont water treatment plant.

Sample 1: river silt settling in raw water basin Sample 2: chemically-enhanced sludge from Belmont settling tanks Samples to be analyzed and reported to City at same time and in addition to existing reports.

Dear Herb:

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1 The following constitute: the Commonwealth's response '

regarding four issues you and?I discussed following our meeting on Monday, May 14: _,,, jg ,

(1) In the event the City d'avelops concerns regarding (he

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Commonwealth's emergency plan _as a result of the radiological emergency response exercise for the Limerick Generating Station scheduled for July 25,w1984, City and Commonwealth representatives shall discuss whether modifications to the Commonwealth's plan are warranted, and shall agree on such modifications as appropriate.

In the event the parties are unable to reach agreement, the City may pursue outstanding issues as it sees fit. See City-8; Tr.

9891-93 (2) Access control points for the Limerick Generating Station plume exposure pathway emergency planning zone will be set forth in the emergency response plans developed by the risk counties. .

The.countie's are currently revising their plans based on, inter alia, comments by PEMA 'provided to. the counties in late 1983 The counties will submit their plans to PEMA for review. Such review will i'nclude the access control points designated by the counties.

As a general matter, access con' trol points are located on main evacuation routes. . Access control' points on nain evacuation routes are manned by Pennsylvania State Police. Access control l points not on main evacuation routes, to the extent they are designated for a particular plume EPZ, are staffed by the appropriate municipal police. In th'e July 25, 1984 Limerick exercise, some, if not all, of the access control points for the Limerick plume EPZ will be activated.

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_ _ _ . _ APPENDIX B _ __ _ _ __

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Letter to Herbert Smolen -

Page two l (3) Twenty-two support hospitals in Philadelphia are to be' listed l in the Commonwealth's emergency response plan. These hospitals are equipped to handle radiologically contaminated patients on the basis that they are " comprehensive" hospitals -- that is, they l have the capability to provide " total emergency care." The ,

l Commonwealth Department of Health has designated these hospitals

l based on its knowledge that these hospitals are capable of providing service to radiologically contaminated individuals. No agreements are currently in place ~between the Commonwealth *'and any -

one of these hospitals that pertains specifically to that l hospital's response in the event it is asked to provide emergency j

care to patients contaminate,d in a nuclear incident at Limerick.

l (4) As previously discussed and agreed to by the Commonwealth, i PEMA shall now include Philadelphia in the list of counties that PEMA notifies in the event of an incident at Limerick. PEMA shall

, provide initial notification to the city as well as notification i

of change (s) in the classification level of the nuclear incident,

! as appropriate. Notificationiwill include 3 information as to

, recommended protective actions; in accordance with NRC guidance, l the Commonwealth's plan -provfdes for recommendation of protective i actions by the public within 4ine= plume exposure pathway' planning w

, zone. Notification to Philadelphia shall include any information j that could directly impact on the City. ~"

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} I trust this inforhation corresponds to our discussion. ,

Please let me know if I can be of further assistance.

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Sincerely -

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(_, y b~ ^

Zori G. Ferkin i

i j cc: Adolph Belser '

Julia Cox

Margaret Reilly -

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 y,,,,oy,, azisi s4i 4soo .

c::. vics ... ..=v

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May 30, 1984

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Bruce S. Aptowicz Manager, water operations , .

City of Philadelph,ia - -

Water Department 1180 Municipal Services Building

Philadelphla, Pa. 19107 , ..

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Dear Bruce:

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l This letter confirms that a Philadelphia Water

Department and a Health Department representative will'be ---

provided space and communications access at the LGS Emergency Operations Facility located at- the Plymouth Service Building. -

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To . facilitate your parf M pation at this facility, ,- -

please provide us the. names, positions and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> telephone numbers of the representatives-so they may be included on a notification list. We would expect your representatives to participate in one or more of the scheduled practice drills.

If you have any questions regarding the facility or the information nee'ed, d please contact Roberta A. Kankus at 215-841-5432.~

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,. Sincerely, e

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APPENDIX C j l

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UNI 1ED SLGES T # ERICA -

.' MJCLEAR REGUUGORY COMESSION -

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AltNIC SAFEIY AND LICENSING BOARD l BERRE THE AININISIRATIVE JUDGES

. Lawrence Brenner, Chairman .

Dr. Richard F. Cole Dr. Peter A. Morris -

In the Matter of: ,

PHILADELPHIA EECIRIC COMPANY : DOCKER NOS. 50-353-OL (Limerick Generating Station, , 50-352-OL

, Units 1 & 2)

', CERTIFICATE & SERVICE ,

I hereby certify that a true and correct copy of the Reply of the City of Philadelphia to Separate Answers of the en=nnnwealth of Pennsylvania ,

Applicant andStafftotheCity'sR[visedIss5sintheArea of Emergency Planning, in the above-captioned pu-:=='4g have been served on the following persons named on the attached service list by hand delivery e

) or by Federal Express Mail, or by causing the same to be deposited in j envelopes addressed to said persons, ,

first class, postage prepaid, and I

deposited with the United States Postal Service at Philadelphia, .

Pennsylvania.

4 P'

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i HematKI .9 GEN

, Deputy City Solicitor l

Dated: June 12, 1984

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SgtHC_E__ LIST

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! Honorable Lawrence Brermer (PE). Mr. Frank R. Ecemno -

l . Jdninistrative law Judge 61 Forest Averme

Atomic Safety & M-ing Board Ambler, Pennsylvania 19002

! U.S. Nuclear. PT'1=tm Ccuatission l Washington, D. C. 20555 i .

l Honorable Richard F. Cole (FE) Mr. Gqm Minor Jdninistrative law Judge MiB Technical Associates i i i Accanic Safety & Licensing Board 1723 Hamilton Avenus s j j U.S. Nuclear Regulatory e-m4 ==4m San Jose, California 95125 )

. Washington, D. C. 20555 i ,

Honorable Peter A. )brris (PE) Egene J. Bradley Administrative Law Judge Philadelphia Electric Company i Atomic Safety & Licensing Board Associate General Counsel ,

i U.S. Nuclear Regulatory c-nf ==4m 2301 Market Street !

l Washigton, D. C. 20555 Philadelphia,: Pennsylvania 19101.

i i Docketing & Service Section Eduard G. neuer, Jr.

i Office of the Secretary Vice-Piresident & General Counsel , .

U. S. Nuclear FT'1=tm c==4 =af m ~

Philadelphia Electric C m .y i Washington, D. C. 20555 2301 Market Street - -

i- Thiladelphia, Pennsylvania 19101 .

Benjamin H. Vogler, E==di '(IE)~ i, T i ,

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, 0.E.L.D. Mr. Vincent Boyer

U.S. Nuclear ne'1=tm Ccuatission -

Senior Vice President '

Washington, D. C. 20555 . :.. Itaclear tions

. Philadel Electric Ccapeny .

Hark Wetterhatm, Esquire (PE) 2301 Marcet Street

Troy B.~ Conner, Jr., L=ad u Philadelphia, Poinnsylvania 19101 j . Nils N. Nicholas, Esgaire ,

i Conner & Wetterbahn Mr. J. T. Robb, N2-1 e l 1747 Pennsylvania Avenue, N.W. Philadelphia Electric Ccapany .

1 Washington, D.C. 20006 . 2301 Market Street .

j Philadelphia, Pennsylvania 19101 Ecbert L. A.r.1 my *

! 103 Vernon lans ~ . Honorable laurence Cc=hlim ,

Moyland, Pennsylvania 19065 House of Representatives a Corgress of tbs United Seices 1 Phyllis Zitzer

Washington, D.C. 20515 Limerick Ecology Action Post Office Box 761 Frank Hippert, Director -

Pottstoun,. Pennsylvania 19464 Pennsylvania Emergency -

1

. Managemene Agency a-151 l Zori G. Ferkin (FE) T.-si i.ation and Safety Building i Assistant Counsel Harrisburg, Pennsylvania 17120

i Governor's Energy Cot 1cil , **

1625 North Front Street Roger B. Reynold, Jr., Esquire P.O. Box 8010 324 Swede Street Harrisburg, Pennsylvania 17125 Norriscoun, Permsylvania 19401 9

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O TLnochy R. S. e 9 11 k. Marvin I. Imwis

% e of Basrgency Serives 6504 Bradford Terrace 14 East Riddle Screet 1*d1=d=1%4=, Pennsylvania 19149 West Chester, Pennsylvania 19380

. Cowey Solicitor Norristoun, Pe m sylvania 19404 Angus love, M d n 101EastMain$creet norriscoun, Pemsylvania 19401 l Mr. J H. thite, III 8 North r Avenus

. Bryn Mawr, Pennsylvania 19010 Robere t.. Suge=.n, sd,

. 9&, Danuorth & Hallegers 16th n oor, Center Plaza

.. . .~101 North Broad Street S *Phliadelphia, Perraylvania 19107 Charles W. Elliott, Esquire

1101 Bull.dirr,

,Eascon. Penwylvania 18042 -

Spence W. Perry, T = d m l Associate General Counsel Federal 6 wy Managmenc Agency Roas.840 -

500 C. Screet, S. W.

- Washington, D.C. 20472 U. S. N. R. C. Region I 631 Park Avarue Kirs of Prussia, Pemsylvehta 19406

. 'Damas Gerusky, Director Bureau of Radiation Protection

. Dept. of Environmental Resources 5th noor, Mton Bank Buildiru

. Ihird & locuse Streets Harrisburg, Pennsylvania 17120' ,

. Accad.c Safety & 1.icensing Panel

. S. Nxlear Regulatory Ccemission 4 Washington, D. C. 20555

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ML20091R875

Contents

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Dear Herb,

Dear Herb:

Dear Bruce:

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ML20091R875

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Dear Herb,

Dear Herb:

Dear Bruce:

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