ML20099G496

Testimony of R Bradshaw & R Klimm Re Limerick Ecology Action Deferred Offsite Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence

ML20099G496
Person / Time
Site:	Limerick
Issue date:	11/26/1984
From:	Bradshaw R, Klimm R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
References
CON-#484-289 OL, NUDOCS 8411270317
Download: ML20099G496 (22)

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endessameESPON002 SI C UNITED STATES OF AMERICA *g4 NUCLEAR REGULATORY COMMISSION 26 d9;3g Before the Atomic Safety an'd Licensing Board' ^ --

In the. Matter of -) .

Docket Nos._50-352 OL

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Philadelphia Electric Company )

) 50-3530 (Limerick Generating Station, )

Units 1 and 2) )

APPLICANT'S TESTIMONY RELATING TO LEA'S DEFERRED OFFSITE EMERGENCY PLANNING CONTENTIONS Panel - Robert Bradshaw and Robert Klimm LEA-1 The Risk Counties, Municipalities, School Districts, and Institutions haven't promulgated or adopted final radiological emergency response plans, nor have they approved and adopted-plans drawn up for them by Energy Consultants, Inc., a Harrisburg firm hired by Philadelphia Electric Company. There is no reasonable assurance that the present state of planning is predictive of final approval, or that the plans are capable of being implemented.

1. The draft, municipal, school district and institu-tional plans were developed with the assistance of Energy Consultants and have undergone numerous reviews by Common-wealth, county and municipal emergency personnel and offi-cials of 'the respective school districts and health care facilities. No political jurisdiction or facility has stated that it will not adopt the draft plans which have been under development. (R. Bradshaw)

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2. There has never been any intent on the part of the emergency planners of the counties, municipalities or school districts to offer the draft plans for formal adoption until informal review of the plans had been completed by PEMA and FEMA and the plans had been tested in an exercise, which occurred on July 25, 1984.1/ -As expected, the July 25 exer-cise resulted in revisions to some plans and these are -

reflected in'the most recent drafts. A supplemental-exer-cise for those municipalities-and school districts which did not participate in the July 25 exercise was conducted on November 20, 1984. It .is likewise anticipated that re-visions to the plans resulting from the November 20 exercise will be incorporated in the plans. As amended, the plans therefore provide assurance that the necessary actions can 5

be taken in the event of an actual emergency.. Because the plans accurately reflect the current status of preparedness in each jurisdiction, the ability to implement the emergency plans for entities within the EPZ does not depend upon formal adoption of the plans by the various jurisdictions.

(R. Bradshaw) 1_/ Nonetheless, the Downing +. awn and Perkiomen Valley School Districts have already adopted their plans.

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LEA-2 The unadopted 'RERP's fail to provide

' reasonable-assurance that each principal response organization has sufficient-staff : to ; respond to --and to .augmenti its

-initial: response on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> continual- '

basis, or. that - the assigned staff Rcan

respond in a' prompt manner in case'of:a~.

radiological emergency'at Limerick. _

3. LPrevious:toJdevelopment of the plans,:few municipal emergency management agencies had any staff other than a design'ated coordinator. As planning. requirements were clar-

- ified,' the recruitment process began'. .Significant and steady ' progress in - this . process has b e e n m a d e ' '. s i n c e the.

first drafts!of the plans. Table 2-A summarizes the current municipal staffing--status. All but one of the.43 municipal-ities have~ a complete first shift. Most.have a complete second shift. The few remaining' vacancies can'be-filled by the mu'nicipalities, but could, if need be, be' passed on to the counties. (R. Bradshaw)

4. Attachment O of each municipal plan lists. personnel requirements for such activities as route alerting, traffic control, ambulances and communications, i.e., RACES or ARES radio operators. Some unmet municipal needs for traffic control and radio operators have been passed on to . the counties. All traffic control needs have been met, either-by the Pennsylvania State Police or county resources. (R.

Bradshaw)

5. Both Berks and Montgomery Counties have met munici-

- pal. unmet needs for radio operators through Radio Amateur

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Civil Emergency.. Service '(RACES) . volunteers.. Chester County-I

h'as passed a requirement for: additional radio operators on to PEMA. Sufficient radio' operators are known to be. avail-I: able in adjacent counties and their assignment 'to Chester

. County for an emergency will be. coordinated by PEMA as for any other unmet county need. (R. Bradshaw) r t

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Table 2-A MUNICIPAL EOC STAFFING Number Number Unmet Required Designated Needs Berks County Amity 24 24 0 Boyertown 16 15 1 Colebrookdale 10 9 1 Douglass 8- 8 0 Earl 10 10 0 Union 10 2 8 Washington 10 9 1 Chester County Charlestown 9 9 0 East Coventry 6 6 0 East Nantmeal 9 8 1 East Pikeland 12 12 0 East Vincent 8 8 0 North Coventry 10 10 0 Phoenixville 23 22 1 Schuylkill 8 8 0 South Coventry (data unavailable) +

i Spring City 10 10 0 Upper Uwchlan 6 6 0 i

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Number Number Unmet' l Required Designated .Needs Uwchlan 8 8 0 Warwick 6 6 0 West Pikeland 6 6 0 West Vincent 10 10 0 l

Montgomery County l-Collegeville 8 7 1 i

L Douglass 10 10 0 Green Lane /Marlborough 12. 12 0 Limerick 8 8 0 Lower Frederick 6 6 0

! Lower Pottsgrove 12 11 1 Lower Providence 14 14 0 Lower Salford 10 10 0 New Hanover 8 8 0 Perkiomen 8 7 1 Pottstown 12 12 0 Royersford 14- 14 0 Schwenksville 10 7 3 Skippack 8 8 0 l

Trappe 8 8 0 Upper Frederick 6 5 1 Upper Pottsgrove 8 8 0 Upper Providence 14 14 0

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Number Number LUnmet-Required Designated Needs Upper Salford 6 6 0 West Pottsgrove. 8- 8 . _ O_

409 389 20

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LEA-3 The Montgomery . County RERP- fails- to provide reasonable assurance that the public will be adequately protected in that.the'. Bucks County Support Plan, which is essential to the workability of the MontCo .RERP, may not be approved.

The present Board of Commissioners--[ sic]

have little knowledge of the contents and implications of the Bucks County-Support Plan. There is no assurance that the County will assume the respon-sibilities assigned to it in.the Support Plan, rather than use County resources to help Bucks County people first. The-Montgomery County Plan . relies on the Support Plan in at least these ways:

1. facilities for relocation and mass care of evacuees -

2. augmentation of emergency workers, including use of county resources, on a contin-uous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis

3. See attachment " Excerpts and comments on the Bucks County Draft Evacuation Plan" for additional areas of support and interface.

It is contended that without the ap-proval of Bucks County Support Plan, the MontCo RERP is unworkable as it now stands.

6. Bucks County is providing a support role and par-ticipating in the planning process in accordance with Commonwealth law. Energy Consultants met with the Bucks County Emergency Management Agency on October 11, 1984 to '

review their current draf t plan and obtain revisions for a i final draft. The resulting revisions were transmitted to Bucks County for review on November 1, 1984. Bucks County

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has stated that ittintends to fulfill its role as a support

-county. .(R. Bradshaw)

7. The Bucks County population is not _- at risk since the nearest portion of Bucks County ' is at least 13 miles

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from Limerick. Mass care centers in Bucks County are 'at least 20 miles from Limerick and _ are - in consonance _ with State and federal guidance in this regard. Because planning assumptions conservatively arrange for the mass care of 50 percent.of the evacuating population, adequate space would be available in the designated Bucks County mass care centers- for any residents spontaneously evacuating from areas of the county closer than 20 miles. (R. Bradshaw)

8. Inasmv0h as the designated mass care centers for Bucks County are located as close as 20 miles from Limerick, it is likely that any residents of Bucks County who choose to evacuate despite the lack of any realistic threat to their safety would relocate to areas more distant from Limerick than any portion of Bucks County. Planning ar-rangements for such individuals are well beyond the scope of planning requirements and constitute an unfounded hypothet-ical concern. (R. Bradshaw)

9. The same emergency services personnel designated in the existing Bucks County plan as capable of 24-hour re-sponse would be utilized to address the emergency require-ments of any spontaneous evacuation of Bucks County resi-dents to other areas of the county. This presents no additional burden on emergency services because the need for

e mass ' care space has been conservatively estimated. (R.

Bradshaw)

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.The . Emergency. Response Organization (including -federal, state,- .and local governments and support organizations) have- failed. to_ fully .. document the- - s existence of appropriate -letters of agreement.with support organizations and agencies. . Thus, - there' is . no reasonable assurance that the emergency _ plans can:

be-implemented.

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10. Agreements _ have _ been sought and obtained for such :

support functions as host schools, host health-care facil .

ities, bus providers,' reception' centers, Red Cross support, Emergency- Broadcast . System support and l decontamination.

stations. Mass care agreements have been developed in each county in accordance with the particular arrangements in' existence between the counties and their respective Red ,

Cross Chapter. Those arrangements have been completed for each county. (R. Bradshaw)

11. RACES and ARES agreements are unnecessary since the sole purpose of these organizations is to assist in emergen-cy situations. They are considered extensions of the' county; emergency management agencies and have a close working relationship with those agencies. Furthermore, the ARES'and RACES organizations demonstrated their commitment to assist in a radiological emergency response by their participation in the July 25 and November 20, 1984 exercises, - including necessary staffing of' municipal EOC's.as prescribed by the j i

municipal and county plans. (R. Bradshaw)

12. Agreements for road clearance services are not  ;

required and unnecessary. The county emergency management l

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~ I agencies routinely dispatch tow' trucks. Extensive resources are available and are'on~ file in the county EOC's. Further, additional road clearance resources are - available from'the National Guard and PennDOT as discussed- in ' response to LEA-28. (R. Bradshaw)

13. Table 5-A compiles the current' sta'tus of all agreements for the county, municipal, school and health care facility plans. The overwhelming majority of these agree-ments are complete. (R. Bradshaw)

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Table 5-A b .

[X AGREEMENP STNIUS Verbal Agreements . Agreement-With Written Renaining Total No. No. Agreement Drafted To Be OrganiEation/ Purpose Agreements Cm pleted J& Awaiting Sianature Developed Schools Host Schools 19 g I 17 2 0 Health Care '

Facilities -

Y Host Facilities 21 .

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• 0 Support Counties Mass Care / Red Cross 12 12 0 0 Reception Center 2 -2 0 0 Montgcznery County Transportation 33 2

21 12_/ 0 Red Cross l l' 1 0 0 EBS .5 5 0

, .. _ 0 Relocation Pts./

t Decon. Stations ~3 2 1 0

, Peception Center 2 2 0 0 i Central Resource Pt. 1 1 0 0 t.

Transportation Staging Area 3 3 0 0 Hcmebound Host 2 2 0 0 l Alternate EOC 1 1 0 0 i

2/ Two agreements provide for the use of reserve buses only. Accordingly, those

, agrements will re:nain verbal.

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Verbal Agreements Agreement-With Written Renaining Total No. No. . Agreement Drafted To Be Organization / Purpose Agreenents Cm pletet & Awaiting Signature Developed Berks County Transportation 5 5 0 0

. Mass Care 11 11- 0 0 Reception Centor 3 3 0 0 Radio Operators 3 3 0 0

, Red Cross 1 1 0 0 Relocation Pt. 2 1 1- 0 Transportation Staging Area 2 1 1 0 EBS 3 3 0 0 Medical Support 1 1 0 0 Decontamination Stations 2 1 1 0 Chester County Red Cross 1 1 0 0 EBS 2 0 2 0 Transportation - - - -

Reception Center 4 2 2 0 Transportation Staging Area 1 0 1 0 Decontamination Stations 3 0 2 1 Municipalities Snow Removal 1 1 0 0 Transportation l

Staging Area 2 1 1 0 l

EOC 2 0 2 0

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Verbal Agreenents Agreements With Written Panaining

.. Total No. No. Agreement Drafted. To Be PS' Organization / Purpose Agreements Cmpleted & Awliting Signature Developed Fire Cmpany Support- 2 0 1 1 Township Support 1 0 1 0 Roadway Clearance. 2 0 .0 2 Total 159 123 32 4 1

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=w-The draft county. plans .are\ deficient.

because they - do not; contain reliable

, evacuation. time estimates.

14 . -- Up to ~ one ? hour :-is ' estimated for : positioning of buses -- at schools for - evacuation. - . This estimate -is based-1

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upon discussions.with county emergency management' personnel-Lwho have experience in such matters ~ and' who.: have , arranged -

for the assignment of buse's-for' schools in their respective Therefore, - one ' hour is' a - realistic estimate.

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counties.-

Further, school and county plans call for-prepositioning'of buses at' the general- emergency stage 'in advance ' of : any-deci'sion to evacuate. This will further reduce mobilization times. See Section V.D. l.c of the school district plans;Section VI.D.2 of the Berks and Montgomery County Plans; and Section V.D.2 of the Chester County Plan. (R. Bradshaw and R. Klimm)

15. As stated at page 5-5 of the ETE, it was assumed, based upon discussions with County- emergency preparedness officials, that up to one hour following notification may be required to assemble school buses, transport vehicles to schcols, and load students onto buses. The ETE assumes that

[ .it will take 15 minutes from the time a decision to evacuate

! is made to the completion of notification to schools.

Vehicles stationed at the facilities at the time of the

-ordered evacuation could be loaded in as little as 15 I

minutes following notification. Accordingly, for prepara-tion- of the ETE, school buses were loaded onto the L

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evacuation network for ' the period from 30 to 90 minutes following the decision to evacuate. As a practical matter,

,an assumed loading period of even two hours - for schools would~not significantly affect the evacuation time estimates

'because these estimated times are less sensitive to as-sumptions on preparation and. mobilization than they are to total vehicle demands and area roadway characteristice. (R.

Bradshaw and R. Klimm)

16. -The special needs (medical, transportation, noti-fication) of the resident - population ' within the Limerick Generating-Station plume exposure pathway emergency planning zone were determined by means of a public- survey. The survey was conducted by the three risk counties through the respective emergency management agencies and utilized a two-part form. A cover letter was provided to explain -the survey and a pre-addressed / pre-posted envelope was enclosed for a response. Individuals were instructed to return.the form if they or any member of their household had a special need. Individuals with questions were advised to contact

, the county office of emergency management. (R. Bradshaw)

17. Survey materials were distributed by mail to addresses in the EPZ. County social services agencies and municipal offices also made the survey available. The news media provided information about the survey. Responses were then compiled and needs were listed for each municipality.

Names, addresses, telephone numbers and the indicated special needs were catalogued. The lists, were filed in the

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respective municipal ~ emergency; operations centers'foriusefat

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'the ' time . of' any: L emergency.

Many of: Lthe; municipalities

-:revieweditheir'listsiand> verified their-accuracy during the!

fJuly. 252land November ' !20, 1984 GLimerick -- exercises'. : '(R. -

Bradshaw)i

18. -_ Original estimates 1for: transit dependent-population

were obtained from the 1980. Census iof Popul5 tion and Hous--

I ing,_ Work andiTravel,to Work Characteristics. DEsti'ates m for-mobility-impaired : individuals were 'obtained L.through ' a ' United -

States Department . . of Health , and t Human ~ Services -document, t

entitled Prevalence of - Selected - Impairments -

U.S.- 1977..

)_ .(R. Bradshaw) 19 . - Previous? estimates for mobility-impaired;individu-

<als, based upon the federal estimates, closely [ approximate actual survey results, supporting the comprehensiveness 'of the -survey. The difference between transportation statis-tics in the U.S. Census'and the ~ transportation needs de-a i

J termined by-the county surveys is explained by-the fact that the U.S. Census lists households without. personal transpor--

tation, while the survey asks if the household has private  !

i transportation "available" on a 24-hour basis.

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- dents-did not request assistance even if-they had no "per-sonal" t'ransportation 'because other private transportation 1

j was available-to them through friends, neighbors, or rela-1 tives.--The-survey data supports this interpretation of the l

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difference between the Census and actual- survey data on

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-'available transportation in that the largest differences-4 e'm

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l were in urban : areas _ where more . friends, . neighbors or rela-tives ' would live in close proximity. In less populated-areas, the survey results.and Census estimates are compara-ble. (R. Bradshaw)

20. The needs survey data conducted by the counties provides more appropriate data for planning purposes than data from the U.S. Bureau of Census. Empirical data from past evacuations indicate :that many households- without access to vehicles will-obtain rides with friends or neigh-bors and will not rely upon public transportation assis-tance. In any - event, utilizing the vehicle demand data associated with this population ' from the 1980 Census would (R' Bradshaw and

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not affect the evacuation time estimates. .

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UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ~

In the Matter of )

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Philadelphia Electric Company. ) Docket Nos. 50-352

)- 50-353 (Limerick Generating Station, )

Units l 'and 2) )

j CERTIFICATE OF SERVICE 6.., 2 I ! hereby certify that' copies of " Applicant's-Testimony

^ V R e-l'a t i n g to LEA's Deferred Offsite Emergency Planning Contentions," dated. November 23, 1984 in the captioned matter have been served upon the following by deposit in the United States mail-this 23rd day of November, 1984:*-

Helen F.-Hoyt, Esq. Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary Dr. Richard F. Cole U.S. Nuclear Regulatory

.. Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Ann P. Hodgdon, Esq.

Washington, D.C. 20555 Counsel for NRC Staff Office of the Executive Dr. Jerry Harbour Legal Director Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Copies were also hand served upon the members of the Licensing Board and the parties present at the hearing on Noven ber 26, 1984.

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Atomic Safety and Licensing Angus Love, Esq.

Board Panel 107 East Main' Street U.S. Nuclear Regulatory Norristown, PA 19401 Commission Washington, D.C. 20555 Robert J. Sugarman, Esq.

Sugarman,.Denworth &

Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr. 16th Floor, Center Plaza Vice President & 101 North' Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 Director, Pennsylvania Emergency Management Agency Mr.-Frank R. Romano Basement, Transportation 61 Forest Avenue and Safety Building Ambler, Pennsylvania 19002 Harrisburg, PA 17120 Mr. Robert L. Anthony Martha W. Bush, Esq.

Friends of the Earth of Kathryn S. Lewis, Esq.

the Delaware Valley City of Philadelphia 106 Vernon Lane, Box 186 Municipal Services Bldg.

Moylan, Pennsylvania 19065 15th and JFK Blvd.

Philadelphia, PA 19107 Charles W. Elliott, Esq.

325 N. 10th Street Spence W. Perry, Esq..

Easton, PA 18042 Associate General Counsel Federal Emergency Miss Phyllis Zitzer Management Agency Limerick Ecology Action 500 C Street, S.W., Rm. 840 P.O. Box 761 Washington, DC 20472 762 Queen Street Pottstown, PA 19464 Thomas Gerusky, Director Bureau of Radiation Zori G. Ferkin, Esq. Assistant Protection Counsel Commonwealth of Department of Environmental Pennsylvania Governor's Energy Resources Council 1625 N. Front Street 5th Floor, Fulton Bank Bldg.

Harrisburg, PA 17102 Third and Locust Streets Harrisburg, PA 17120 Jay M. Gutierrez, Esq.

U.S. Nuclear Regulatory Commission 631 Park Avenue-King of Prussia, PA 19406 I

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James Wiggins ..

Senior. Resident Inspector U.S.' Nuclear Regulatory' '*

Commission' P.O. Box 47 Sanatoga, PA 19464 Timothy R.S. Campbell Director-Department of Emergency Services 14 East Biddle Street West Chester, PA 19380 -

Mr. Ralph Hippert Pennsylvania Emergency Management Agency B151 - Transportation Safety Building Harrisburg, PA 17120 rat Nw. R*A Robert M. Rader l

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