ML20099L584
| ML20099L584 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/26/1984 |
| From: | Banning R MONTGOMERY COUNTY, PA |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20099L577 | List: |
| References | |
| OL, NUDOCS 8412010184 | |
| Download: ML20099L584 (25) | |
Text
- ' - -
RELATE ~' 'ORIE3PONCECC
- n M O NTG OM ERY CO U NTY p .;.~* .
y- =
^
g NORRISTOWN, PE , , y NSYLVANIA Come *** s siose t a s '
PAUL BARER BARTLE ALLAN C.MY ERS RITA C.S ANNING S Ok sCs?On FREDERIC M. WENTZ CoetrF CLa ma ROBERT w. G RAF BEFORE THE ATOMIC SAFETY AND LICENSING BOARD LIMERICK GENERATING STATION TESTIMONY OF RITA C. BANNING, COUNTY COMMISSIONER
~
11/26/84 My name is Rita C. Banning. I was first elected Commissioner in Montgomery County in 1979 and was re-elected in 1983. I graduated from Ursinus College in 1961 with a B.S. in Mathematics. I have taught in the secondary schools for 10 years in Montgomery County in the Norristown and Methacton School Districts and at the Abington Friends School.
,, I graduated from Villanova Law School with a J.D. in 1976, and am a member of the Montgomery County Bar Association.
I reside in Pottstown at 967 Warren Street.
A I am submitting testimony to the Nuclear Regulatory Commission because of my concerns about the lack of a work-able evacuation plan to protect the residents of Montgomery County in the event of a radiological emergency at the (lmerick Generating Station. I have reviewed the draft plans developed by the Montgomery County Office of Emergency Pre-paredness. The most recent d ra f t I have received is #7, dated October 1984. I am particularly concerned about the provisions for transportation to evacuate the schools as well as the general public. I have corresponded.with Mr.
Bigelow, the Director of the Montgomery County Office of Emergency Preparedness to request additional information documenting the status of arrangements and agreements for buses and drivers in the event that an evacuation is ordered due to a radiological emergency. On November 15, 1984 I sent a letter to the school district bus providers listed in Annex I, Appendix I-2 of the Montgomery County Plan to obtain I additional information regarding the status of agreements l
between the School Districts and the County. I am attaching i
to this testimony the respgpWFW hat I have received to date. j Montgomery County Dicentennial -
A Cele 6 ration of Ou Centuries num 8412010184 841126 ,,%ro#
_ l
m 2
.-s The Draft #7 Montgomery County Plan does.not include reliable letters of agreement to document the arrangements with support organizations and resource providers. The responses I have received from Mr. Bigelow (OEP) and the school district bus providers raise further questions about proper authorization of such " letters of understanding" and show confusion or disagreement ~ as to what the understanding
, was. ,
Furthermore, the bus providers have not been informed by the Montgomery County OEP that they indeed have a specific
" Limerick assignment" for which there drivers are expected to volunteer. To the best of my knowledge, most drivers have not been surveyed to determine their willingness to assume this responsibility, let alone properly trained.
As to the use of SEPTA (Southeastern Pennsylvania Transportation Authority) buses as a backup, I have serious doubts that they would be abic to meet the needs of such a crisis. Within the pa s't six months, SEPTA has had a shortage of bus drivers which led to the curtailing of some routes and elimination of others or an unscheduled basis. They are training more, but clearly do not have an excess of drivers.
p% As a County Commissioner I am particularly concerned about the inadequacy of the evacuation plans for the County Geriatric Center at Royersford. Draft #6 calls for evacuation by 15 coach buses and t ambulances. It should be realized that the patients at the Geriatric Center are classified as needing skilled or intermediate care nursing, and very few could ride in a regular bus without considerable adaptation.
Ambulances or vehicles adapted for transporting persons in wheelchairs would be the appropriate way to transport most of the patients at the Geriatric Center.
In Draft #6, one assumption which I am unwilling to accept is #H - that Montgomery County's u n m e't needs will be met on a timely basis by the State or other resources. It would be absolutely irresponsible to be so casual about the safety of the citizens of the County, since there is no evidence to support this assumption.
I do not believe that the' county or the municipalities involved have obtained reliable information regarding the -
number of transport dependent people who will require trans-portation assistance.in the event that an evacuation is order-ed. Using Pottstown Borough as an example, Draft #4 of the Radiological Response Plan, dated October 1983, indicated that there was an estimated 4,175 residents who would require
<~ transportation assistance in the event of an evacuation.
y m . 1
. . .; ,y ,
3
~
3
'A This information is contained in Attachment G, and it is based on estimates from the 1980 Census Data. This page notes
.that'this information will be replaced with actual public survey data as soon-as it becomes available. Turning to Draft #6 of
_. the Pottstown Borough Radiological Emergency Response Plan,
' dated September, 1984, Attachment G indicates that there are 605 residents. requiring transportation assistance in the
' event of an evacuation. This page indicates that this figure .
is based on public survey data. The plan also notes that it is understood that there may be additional individuals who will require transportation assistance at the time of the evacuation, and that these individuals are to contact the municipal EOC to arrange for pick up. .
The amount of t ~me required to mobilize, transport, and load buses to:be used to assist members of the public without-their own transportation, including school children, is an important factor affecting the reliability of the evacuation time estimates being used by both Philadelphia Electric Company and local planners. The Philadelphia Electric Company evacua-tion time estimate study for the Limerick Generating Station assumes that "up to one hour may be required to assemble, buses, transport vehicles, and to load students onto buses". (page 5-5) r%
A review of Annex I, Appendix I-2, of the Montgomery County Radiological Emergency Response Plan (Draf t #7) indicates that for most of the sthool bus transportation providers, the estimated mobilization time is approximately one hour. To the best of my knowledge this di es not include the time required for travel to the assigned destination, or loading. Using the example of the 20 buses assigned to provide evacuation assistance to the Pottstown School District coming from the Wissahickon School District, this time facto r 'could be significant, depend-ing upon the weather and traffic conditions involved.
I am also convinced that traffic. problems, both as they currently. exist, and as they can be expected to exist in the event that an evacuation is ordered, will have a considerable impact on the response time of bus transportation providers, even if the required numberof units is available.
Appendix.K of the Montgomery County RERP lists roadway clearance / fuel resources as being all outside the 10 mile radius There are no letters of agreement for towing or snow removal in the plan. The importance of letters of agreements is clear.
There are many townships relying on the county to fulfill their towing and snow' removal needs. These include Royersford, Upper Providence, Trappe, Lower Pottsgrove, Douglass, Schwenksville, A- Collegeville, Perkiomen, West Pottsgrove,- Lower Providence, Green Lane, Marlborough, Skippack, Upper and Lower Salford, 1
1
.. .. l 4: l New Hanover, Limerick, .Pottstown.. Upper Frederick and Upper Pottsgrove. This suggests that all.but one township, Lower Frederick, will.be relying on the County to provide or coordin-ate towing and snow removal services. The County.could also use,more assurance-and/or better understanding of the resources a n'd personnel PennDot has available. To the best o f my know-ledge, at'present, none of the townships have a letter of agree-ment for towing for a radiological emergency. This is of particular concern because many of the townships have personnel dificiencies in several of the transportation and communication officers catagories. The Public Works Group is supposed to coordinate with the townships on this issue according to page 3 of the County RERP.
Also, in most cases, the townships appear to be relying on PennDot for either the-primary or secondary roles for snow removal.
Page 1 of the Montgomery County.RERP states that it is supposed to assure appropriate resources to protect the popula-tion within Montgomery County within the Plume EPZ (10 mile radius) and the Ingsstion:EPZ... including public alerting and notification, protective action guidelines, and. mobilization r5 of County forces to support necessary actions.
The Montgomery County Commissioners have not discussed Draft #7, or for that* matter, any of the other Draft RERP's for Montgomery County. It is not an approved plan, nor is it a workable plan.
m G
f' w
. . - - , , . _ - - - -12,.,
h Mercury, Pottstown Pa. - Monday, Septem ber 3,19El . ) 5 4
. , d At the Editor's Desk L'
, Junk ma.dr c
message is Unnerving The letter went on to explain how in certain emergencies the special needs of individuals with disabilities must be met. It urged everyone to complete the form as soon as possible and return (
BYBOB URBAN , it in the self addressed stamped envelcoe. It was l "Any mail today?" I asked my wife the other signed by Samuel L. Ely 3rd, the county's director i
evening when I came home from work. I was of emergency preparedness.
hungry and tired, and hoping not to find any 1 unexpected bills or other unpleasant corre-~ * *
- spondence waiting on the living room hutch. ,
She handed me a white envelope while I was I examined the forryand thought to myself that removing my coat. An old rerun of "The Bob in the 17 years I had bsen a resident of Pottstown.
Newhart Show" flashed on the television screen. never before had I neen asked to fill out a survey "Wiiat's this?" I asked. "It looks like junk of this nature - not even after the devastation of llurricane Agnes in 1972.
m ail."
- The form asked if everyone in my family
" Wait'll you read what's inside " my wife replied. "That'll be a column item for you. It's usually had private transportation available. If scary." my residence had a telephone, and if everyone in The envelope didn't look intimidating. In fact it my family understood English.
looked like hundreds of others most of us receive I was quizzed if anyone had a hearing impair-and discard with little thought. It could have been ment, a speech or dint impairment, if anyone e a flyer anrouncing a stere sale, an invitation to ' was confined to a whee' chair or bedridden. The
" borrow up to $10.000" from a finance company. survey asked if anyone would need personal cr a brochure from a politician or religious group. assistance, a special vehicle or medical equip-The er.velope had no lettering other than e ment, or an a mbulance.
postage meter 17-cent first clast stamp md a Fortunately. no one in my faatlly falls into those Philadelphia postmark. My name and ad'Iress categories. so l was told that I wouldn't have to fill were attixed on a little sticker that appeared to be out and return the form. I guess that metas that in punched out of a et,mputer. case of a nuclear accident 1*ll be on my own.
Inside was a form to be filled out (in duplicate). It's will be at hast a year before anf radioactive along with a letter under the heading " County of materials even arrive at Limerick. And despite Mc,ntgomerv Office of Emerrency Preparedness claims by PE officiaN that there's no need for and MedicalServices." s concern. many people are tough to convince.
Dear Resident,
the letter said: The Nuclear Age scares people. One extremely The Montgomery County Office of Emergency foggy morning several months ago a distraught Preparedness is presently . In the process el uoman called Tbs Mercury and, half crying.
updaling its records to better serve the public,in reported that "the two towers at Limerick disap-the event of an emergency or an incident at the peared overnight. Where could they have gone?"
Limerick GeneratingStation- She was assured that as soon as the fog lifud, the towers would reappear. ,
As Director of the Afonwomery County OEP,1 .
About a month ago tt:c paper's switchhsard lit am asking that you take a few minutes to up bec.2use esidrats and passersby were con-complete the enclosed surty form. If ap.91icable. cerned about the *' giant plume of smoke" that was Wur county Office of Em ngeccy,Freparedness spotted nuove Cooling Tower One. The callers and municipal emergency services are responsi- were informed in a ststy'%e next day tr.at the ble for developing plans to protset county resi t "ptwhe" war Just steam generated from some
.d:nts in the event of a major emergency. ThO work being done to test a water system ir.' the information gathered by this survey will remann tower. P,ut uhen the steam reappeared a few t n confidential to be used only by municiapt sid week', later, the calls started up again.
county emergency services personnel (police. ,
l Despite assuracces, the memory of Three .\ file fin, rescue. ambulance)in a time of emergency Island remains clear. And, as we continue to fill such ss fire. flood, hacardous materials incMent out emergency forms. the apprehension a6out the or protective action in the eved of an incident at Limerick Power Plant will continue to grow, the Limerick GeneratingStation.
I i i
- i ,
/ s
, i j
~*
y
~
NORTH PENN SchoolDistrict
?x . =--r c== . m ___ _ -- m . u n r :: = - . .:mr: =rmummestnem -
November 20, 1984 ,' ;
j ",{ ' ,,
n- ;r[
- l. NOV P.6 /? J'l L. . ..
. . i . l ' :.1' Rita C. Banning, Commissioner County of Montgomery Court House Norristown, PA 19401
Dear Mrs. Banning:
In reference to your letter addressed to our Superintendent regarding provision of buses and drivers fo" Limerick
^ Evacuation, I am responding with the only i n fo rma ti on we have on file which does not conform to the data listed in your letter of 11/15/84.
North Penn's approved agreements were to act as. host for Perkiomen Valley School District in the event of a nuclear accident at Limerick, as well as to of fer use of district facilities as mass care shelters in the event of any disaster. This was the extent of our signed agree-ment.
Very truly'yours, BOARD OF SCHOOL DIRECTORS
- -QA- r-tf~
W. J. Jacobs, Secreta ry J
cc: G. P. Starkey, Director of Business Af f airs Dr. Frances J. Rhodes, Superintendent 400 Penn Street, Lansdale, PA 19446 (215) 368 & 00
m - -
M FT. A Upper baer1on 11ren b( eloo! 7.f.ra.
- I4 tNf O F PH U%98 4, PE N H%Y LV A NI A 99404 . (29%)137-6000
^
November 20, 1984 .
1
,I f!0V16 /p ,
y~. . ./.C , * ;.;
firs. Rita C. Banning " ' ^ ~
Montgomery County Commissioner Norristown, PA 19401
Dear Mrs. Banning:
Regarding your letter of November 15, 1984, please be advised of the following. Mr. A. Lindley Bigelow, Montgomery County Director of Emergency Preparedness, visited our school district last March 1984.
He spoke with Mr. Philip H. Mowry, our Director of Operational Services, and Mr. Walter dePrefontaine, our Supervisor of Transportation, concern-ing the need to provide transportation for evacuation of children from ,
some Montgomery County school districts in the event of an emergency at the Limerick Generating Station. Mr. Bigelow was accompanied by two gentlemen whose names I do not know who apparently represented a state agency.
Mr. Mowry and Mr. dePrefontaine informed me that they made a verbal agreement to try to supply drivers on a voluntary basis only for e assistance in this situation. They gave Mr. Bigelow the names of the people to call in our school district in the event of an emergency.
We did not guarantee anything. We merely said we would assist if drivers did volunteer to do this.
Your Ictter is the first communication we have had from anyone indicat-ing what our assignment would be in tems of location and numbers of vehicles required. If you require further information, please do not hesitate to call me.
Sincerely; .
gf.cupc/. .d e A / (/-r t d 'e (;
Charles A. Scott Superintendent of Schools svj cc PH Mowry W dePrefontaine -
1
-. . - . - . .___c__, , . - . . --- - ___ -. ,
. .: .s e e' Lower Merion School District to SS 301 Montgomery Avenue, Ardmore, PA 19003 (215)645-1800 Ogg% November 19, 1984 t
i f
I NOV 2 6,,7, e vt i i.
Commissioner Rita C. Banning " - -
t r -2 Montgomery County Courthouse ' ' " " . .d, 2 Norristown, Pennsylvania 19404
Dear Commissioner Banning:
The purpose of this letter is to confirm our conversation of this date.
On March 13, 1984 Mr. A. Lindley Bigelow and Mr. John Cunnington met with me to discuss what vehicle assets would be available for possible use in the event the Governor determined an evacuation was necessary from the area surrounding the Limerick Generating Station. On April 2,1984 Mr. Bigelow forwarded a " Letter of Understanding" and requested that the Board of School Directors execute same, thereby agreeing to " provide buses and drivers to the maximum extent possible, etc.." On April 30, 1984 Dr. James B.
Pugh, Superintendent of Schools, in a letter addressed to Mr. Bigelow, f=s indicated that "At its meeting on April 23, 1984, the Lower Merion Board of School Directors took action and indicated its willingness to cooperate with the Montgomery County Office of Emergency Prepared-ness in the event of a man-made or natural disaster. Specifically, the Board of School Directors agreed to provide school buses and drivers to the degree possible for use during an emergency."
Dr. Pugh's letter also indicated that the " Board of School Directors did not, however, find the ' Letter of Understanding' acceptable and, therefore, did not approve it."
In summary, and in response to your letter of November 15, 1984 addressed to Dr. Pugh, the Board of School Directors of the Lower Merion School District while agreeing to " assist to the degree possible", has not made a " commitment" to supply the amount of buses i indicated in your letter of November 15th, nor has the Board "guarantecc
! drivers for the buses requested.
I ho?e this inform'ation is of assistance to you. Should you have
! further questions please call me at 6 '5-1943.
i l S' cere y, l / . A. T i l ys / Director f Fransportation Copy to: /
Dr. James B. Pugh, Superintendent of School Mr. Scott Shafer, Business Manager
.r i - .
h MONTGOMERY COUNTY OFFICE OF EMERGENCY PREPARE 0 NESS l BUS TRANSPORTATION PROVIDER SURVEY n
, .,0rganization Name: Lower Merion School District Mailing Address: 301 Montgomery Avenue' Ardmore, PAi 19003 Location: Same - behind High School off Montgomery Avenue Municipality: Lower Merion Township Other Garage Facilities: No Business Telephone: ( ) 645-1943 Owner / Operator: District - Claude Matson, Dir. af Trans. 0600-1830 Emergency
Contact:
Matson - Director of Transportation Al ternate: Mr. Andre Michael 645-1944 Alternate: Mrs. Hudgeons 645-1941 Emergency Telephone: ( ) 645-1941 with recorder after 1830 Other Telephone: (Matson Home) 446-9332 Hours: 1830-0600 Vehicles Operated: Type of Fuel Number Caoacity Gasoline Diesel Propane
^ 5(48) 34(6o) 1(64)
- School Buses 58 16(72) 2(84) *19 reo. 39 Coach Buses -- --
! 5(16) 3(20)
Vans / Mini Buses 8 3(36) 8 reg.
8 passer.gers Handicapped Vehicles 3 3 wheelchairs 3 reg.
Other Availability: Daytime 17 buses,1/4 hour Evening 25%, I hour Weekend 10-20%, I hour Drivers: Number: 85 Availability: 20% female, 80% male, 11 full-time, 5 seasonal Mobilization Time: ,
1/4 - I hour ,
Fuel Suppli.es (Capacity): Gasoline (2000 unl.,8000 reg.) Diesel (15000 Deisel)
Propane ( No ) Supply located: Garage ,
j Radio Equipped: No Frequency: N/A Base Station: N/A NOTES:
- School bus scheduling 0545-0945, 1130-1300, 1400-1645, Late runs (1845)
Chains for all vehicles Date: March 14, 1984
...-.T..
~
. ~ . n a u&m~u@g Lower Merion School District m$8S N
A 301 Montgomery Avenue, Ardmore, PA 19003 (215)645-1800 Og April 30, 1984 Mr. A. Lindley Bigelow, Coordinator Montgomery County Office of Emergency Preparedness 1000 Wilson Boulevard Eagleville, Pa. 19403
Dear Mr. Bigelow:
At its meeting on April 23, 1984, the Lower Merion Board of :
School Directors took action and Indicated its willingness to coop-erate with the Mon _tgomery County Of fice of Emergency' Preparedness in the event of a man-made or natural disaster. Specifically, the
- Board of School Directors agreed to provide school buses and drivers to the degree possible for use during an emergency.
The Board of School Directors did not,.however, find the
" Letter of Understanding" acceptable and, therefore, did not approve it.
Last, the Bus Transportation Provider Survey has been re-viewed and appropriate corrections made. A copy of the corrected sur-vey form is enclosed.
If you have further questions or concerns, please do not hesitate to telephone me at 645-1930.
Si cerely, James B. Pug Superintendent of Schools jhp/c cc: Board of ' School Directors Mr. Claude_Natson _
,e e.=-e w[ --w
.-me-.J.~m4%.-~. -
PHONE (215) 287 7861 Perkiomen Valley School District SCHWENKSVILLE, PENNSYLVANIA 19473
'Where the accent is on excellence" November 20,1984 f
wnumu a marcorr. sa a !
= '
i
(
Commissioner Rita C. Banning l NOV3 6 / /c T A$ fN Montgomery County Court House Norristown, PA 19404 b y" ' """, i
Dear Commissioner Banning:
In response to your letter of November 15, 1984, it appears that you are asking oo,,,to a oato, two questions:
- 1. The first question deals with the Perkiomen Valley School District's
,,,,,,,,,,,,,,, commitment to supply the number of buses, vans, and other vehicles
% Indicated in your letter.
To this question, the answer is "yes", we are prepared to commit the number of vehicles indicated.
2.
Your second question indicated, by implication, that we were guaranteeing drivers for these vehicles.
Nowhere is our plan did we ever indicate that there will be a guarantee of drivers.
Our drivers has*e had the in-service training and we expect them to respond; but, I would never place myself in the position of guaranteeing that all drivers would show up in an actual emergency situation. I don't think that anyone could make such a guarantee.
In the drill that we participated in on November 20th, one of the items that we wanted to test was the availability of drivers. With our vehicles, we also deal with two contractors who supply buses. In total there are fif ty-two drivers involved. All of them are part-time and have other jobs or home responsibilities.
In the drill on November 20th, we attempted to reach all fif ty-two drivers.
Fourteen (14) drivers could not be reached by telephone and three (3) refused to participate in an evacuation exercise.
We would assume that in a real emergency some of the fourteen drivers would be alerted by radio broadcasts and report to their stations.
The drill did point ou , however, that we would be short of drivers. This means that we must plan some alternative strategies to assure adequate driver coverage.
I hope that this answers your concerns. If you desire additional information, please do not hesitate to be in touch with me.
Sincerely, n
h ft(N.w x b William D. Westcott, Ed. D.
Aif)
Superintendent WDW/tr
r I
_ i SPRING-FORD AREA SGI00L I)lSTRICT
, 199 Bechtel Road ,
Collegeville, PA 19426 p
( .
i NOV P. G M ;i
.tO ,,
"~ j Sp f L.A N .~lA -
~
PHONE: 489-1666 November 19, 1984 Ms. Rita C. Danning Montgomery County Commissioner Norristown, PA 19401
Dear Commissioner Banning:
Your letter of November 15, 1984 refers to an agreement between this school district and the county to provide buses, vans and other vehicles and drivers for the evacuation of Montgomery County school children. I am unaware of the existence of such an agreement. If such an agreement has been executed and is on file, I suspect that it exists without proper authorization.
The school to which school district-owned vehicles are identified as having been assigned is a district facility. Certainly, you may reasonably anticipate that
- with or without an agreement we would plan to use district-owned facilities to implement an evacuation plan. The issue of whether drivers will assume responsi-bilities, contractual or otherwise, in the event of an emergency is not resolved with any degree of certainty. .
A contract form was submitted to my office several months ago which indicated that the school district would provide access to drivers and vehicles to the extent
- of its ability. I declined to execute the agreement because it did not appear to establish any useful or dependable obligations on behalf of either party. I do not wish to give you the impression that the district would not look favorably on comit-l ting its facilities for general evacuation purposes after the needs of the school
, population have been adequately addressed. Ilowever, it is quite likely beyond l tl.e authority of the school district to make a similar commitment on behalf of the personnel who are regularly employed to drive district vans for district purposes.
I trust that this communication addresses the concerns set forth in your letter. If this is not the case, please contact me (480-1666)~ at your earliest convenience.
l Sincerely yours, William A. Welliver, Ed.D.
^
Superintendent WAW/t
f' l Abington School District Abington. PA 19001 Phone (215)884 4700
=amme November 20, 1984 ;
l f!U V ? G M v il c
n g 5 ;
L, . m.,.,. .m.,_,,,
The Honorable Rita C. Banning Commissioner, Montgomery County Norristown, Pa . 19404
Dear Ms. Banning:
I write in response to your letter dated November 15, 1984 regarding buses and drivers for a Limerick evacuation. In that correspondence you indicated that I have guaranteed to provide drivers . You ask, "IS THIS REALLY TRUE?" On May 14, 1984, I signed an agreement that states as follows: "The Abington School District hereby agrees to provide buses and drivers to the maximum extent nossible . . . " (emphasis mine) . I stand by that commit-ment, e
Very truly yours ,
(c.>
\ .t,
\,6, Ja$1es P. McCaffery yi \
Acting Superintendent of ' Schools JFMc/mpm 1
u q
- ~* .
STATEMENT IN SUPPORT OF LIMERICK ECOLOGY ACTION'S REQUEST FOR Tile ISSUANCE OF SUBP0ENAS TO OBTAIN TESTIMONY ON THE FOLLOWING CONTENTIONS:
LEA-1, LEA-2, LEA-3, LEA-5, & LEA-23 LEA-1, LEA-2 The approval of subpoenas to be requested by Limerick Ecology Action would provide the " competent evidence" requested by the Board to"be placed in the record demonstrating the current status on adoption and implementability by local bodies of their various plans for Limerick".(See ASLB Memorandau and Order on LEA's Deferred and Re-specified off-site emergency planning contentions, Oct. 26, 1984; page 4, item 4.d.)
LEA has been unable to obtain this testimony from the municipal govern-ments involved, and hereby informs the parties of its plans to request subpoenas in order to obtain the information requested by the Board from those who have the most direct knowledge of current local concerns.
f-s LEA believes that this information is essential to the development of a sound record on the subject matter of LEA's deferred contentions.
(LEA-1. LEA-2, and LEA-5) The same applies to current staf fing deficiencies.
The possibility of PEMA conducting a survey of the '
risk' municipalities was discussed with Zori Ferkin, counsel for PEMA. When it became evident that this information would not be available to the parties, LEA inquired what type of testimony could be anticipated to be filed by PEMA in this proceeding. As of this date, i t is our understanding that PEMA intends to present testimony from Mr. Timothy Campbell, the Director of the Chester County Department of Emergency Services, and Mr. Robert Reber, the Berks County Director of Emergency Preparedness. LEA is not aware whether or not PEMA will be presenting any testimony from Montgomery County officials. For these reasons, LEA believes that the testimony of the individuals it desires to subpoena, is necessary to insure the development of a sound record on these contentions.
LEA-3 LEA intends to subpoena testimony on behalf of the Bucks County Board of Commissioners, and is providing the most current letter available to the parties with this filing, regarding the Bucks County Support Plan. (See letter from Carl Fonash to FEMA and PEMA, 11/16/84)
LEA has been unable to obtain this testimony without the issuance of a subpoena from the Atomic Safety and Licensing Board. The Commissioners
~
would be requested to designate a representative, probably including
- Mr. Milliam Rieser, the Chief Clerk.
4 4
.,,n-y wn , . -- - , , , , . . - , , - - - - -
d _
LEA-5 LEA proposes, in order to facilitate litigation of this contention, that all bus providers and School District Superintendents subpoenaed under contentions LEA-11 and LEA-15, cover any questions relating to the status of Letters of Agreement at the time that they have already been scheduled to appear to testify on those contentions.
LEA hereby informs the parties that it intends to request subpoenas to obtain testimony from the Chester County and Montgomery County Public Works Officers, in order to determine the existence and content of any Letters of Agreement, or other arrangements that they currently have on file, or have made for towing, snow removal, and the provision of gasoline supplies as is discussed in the respective County RERP's.
In addition, LEA would anticipate any municipal officials that were concerned about Letters of Agreement regarding snow removal, towing, and gasoline supplies, would have an opportunity to state their concerns when testifying on contentions LEA-1 and LEA-2, particularly if there are any unmet needs which have been passed along to the Counties.
LEA also intends to request subpoenas to obtain testimony from repre-sentatives of Teachers Associations and teachers union officials, based upon the requirement that Letters of Agreement should be considered for organizations, and not individuals. (See ASLB Order, 10/26/84; page 6, item 7.b.) It is the position of the PSEA teachers union that f, regulation, statute, or executive order, or existing teacher contracts, do not bind them as teachers to any specific performance in an emergency.
(See testimony of Donald Morabito, 11/1/84). Mr. Morabito's testimony states that the issue of such performance is a contract matter to be agreed upon during contractual negotiations, a ' Letter of Agreement' in fact. Therefore, in the event that this subject matter is not permit-ted to be litigated elsewhere, it is extremely relevant and important to consider under the subject matter of LEA-5.
LEA is following the Board's Order (10/26/84; page 6) in making a dis-tinction between school " officials" (administration) and an organization of personnel (the Teachers Association). The same reasoning would hold true for any school bus drivers represented by a union, including PSEA.
LEA-23 On November 26, 1984, LEA presented the Board and the parties.with a list of witnesses already scheduled to appear on behalf of Limerick Ecology Action. In order to facilitate the hearing, and to avoid having to call back the bus provider and School Superintendent witnesses to testify on the subject matter of LEA-23 at a separate time, LEA hereby requests permission to cross-examine these witnesses on the subject matter
^
contained in LEA-23, particularly LEA specification 1, discussed in the Board's 10/26/84 Order on page 7, item 8.a. Furthermore local officials who will be called to testify on LEA-1, particularly from the Boroughs of Pottstown and Phoenixville, have direct knowledge rela-ting to LEA-23, specification 6, and LEA requests permission to cross-examine them on this subject matter at the time they are called to testify.
. e w . ,
SUBP0ENA REQUESTS ANTICIPATED BY LIMERICK ECOLOGY ACTION Montgomery County Paul Bartie, Chairman of the Montgomery County Commissioners Joe Brauner )
Joe Kuntz ) Public Works Officers (for letters of agreement relating a to towing and snow removal)
Chester County Earl M. Baker, Chairman of the Chester County Commissioners ffz"9 y, Public Works Officers (for letters of agreement relating to towing and snow removal) i
- Berks County n
Donald Bagenstose, Chairman of the Berks County Commissioners i
Bucks County (LEA-3)
Board of Commissioners, or a designated representative
! Carl Fonash, Chainman William Rieser, Chief Clerk i
A PRELIMINARY LIST FOR THE MUNICIPALITIES FOLLOWS: (Chester County)
Bonnie August, President, Phoenixville Boro Council (Chester Co.)
! Norman Vutz, Supervisor and Emergency Management Coordinator, Schuylkill Twp. (Chester Co.)
Richard Whitlock, Chairman of the South Coventry Twp. Supervisors Mike Burnley, Chairman of the West Vincent Twp. Supervisors ,
! Steve Grenz, Harry Rauch, Samuel Matthews (or a designated representative)
- on behalf of.the Uwchlan Twp. Supervisors John Yeager, Chairman of the East Pikeland Twp. Supervisors
' A representative from East Coventry Township A representative from' North Coventry Township l
l
. . _ . , . _ _ _ _ - , . _ _ . _ - _ . ~ _ _ . _ . . , _ . , _ , . _ _ . _ - ,_ _ _ _ , _ . _ _ _ _ _ _ _ - -
,.-.y, .._-y
x .. .
Preliminary List Municipalities (continued) (Montgomery County)
Mike Giamo, Supervisor, Skippack Twp.
Ceasar Gorski, Chairman of the Skippack Twp. Supervisors Richard Brown, Chairman, Lower Providence Twp. Supervisors Harry J. Miller, Lower Providence Twp. Fire Dept.
Michael Conroe, Lower Providence Twp. Ambulance Hugh Kelly, Chairman Douglass Twp. Supervisors (Montg. Co.)
Virgil Templeton, Chairman, Upper Providence Twp. Supervisors George Waterman, Upper Providence Twp. Manager Ed Doman, Limerick Twp. Emergency Management Coordinator Barry Lenhardt, Chief of Police Limerick Twonship Richard Bacchi, Chairman of the West Pottsgrove Twp. Commissioners Carol Mattingly, Pottstown Boro Transportation Officer Edmund Skarbeck, President Pottstown Boro Council a representative of Lower Pottsgrove Twp.
Kenneth Hagy, Upper Salford Twp. EMC and Chairman of the Supervisors Richard Kratz, Chairman of the Perkiomen Twp. Supervisors John Salamone, Mayor of Royers ford Robert DiAngelo, Royersford EMC Richard Buckman, Chairman Upper Frederick Twp. Supervisors Charles Meehan, Upper Frederick Twp. EMC
/s (Berks Co.)
Ronald Kretzman, Donald Gutekurst, Donald Button (Union Twp. Supervirors) or a designated representative A representative from Boyertown Boro A representative from Douglass (Berks) Twp.
b
" LEA EXHIBIT" i l 4 g l COUNTY OF BUCKS A O l' It I C li O I: T il E C O M M I S S I O N ii R S A d minist r a tion lluildin g, linylestown, l's , IN901 215 MM 2911 215 752 02MI Coma,y Commissioner: %11.1.1 AM 11. RIL$ER CARL F. FON ASH. Cheirmen Coun,y Aanninistre,or LUCILLE M. TRENCH. l' ice Cheirmen JAMES M. McN AMAR A ANDREW L. WARREN
, November 16, 1984 Co a'r 3*8<i'o' Federal Emergency Management Agency Federal Center Plaza 500 C Street S.W.
Washington, DC 20472 Pennsylvania Emergency Management Agency P.O. Box 3321 Harrisburg, PA 17105 Attention: Mr. John L. Patten
Dear Sirs:
On behalf of the majority of Bucks County Commissioners, I wish to reassert, reaffirm, and clarify the 8 status of Bucks County's activities in regard to the proposed Limerick Generating Station.
From public meetings with Bucks County citizens, it is apparent that many Buckc County residents, including those within the twenty-five mile radius of Limerich, and others within a fif ty file radius of Limerick, can be c:cpected to evacuate the area. This expectation is further documented by such NRC public-ations as NUREG 0654.
Bucks County also anticipates considerable influx of evacuees from Philadelphia and Montgomery Counties, and is unable to make any reasonable or equitable basis for distinguishing among them.
In these circumutances, it is manifestly impossible for Bucks County to provide any basis or expectation for believing that facilities and personnel will be in place, or can be put in place, to accommodate twenty-five thousand shelter-seeking evacuees, either as to reception or support f acilities, as con-templated in the draf t plan which was prepared f or the County's consideration by PECo consultants. In addition, some of our citizens have developed a list of well-founded concerns, which we believe are important as well. A copy is enclosed.
r
~~ "- ~
__._.M..._
. .- s 2 November 16, 1984 !
. A The County cannot. and will not be a part.y to a charade; approval or even further consideration of the proposed plan would be a charade, misleading the public.
None of the foregoing is inconsistent with Bucks County's appropriate discharge of its responsibilities under Act 1372, and under Senate Bill 987. Bucks County will make plans to ppovide realistic emergency assistance in_ appropriate cases. On i
the other hand, Bucks County will not permit its f acilities to be utilized to create a misleading and dangerous trap.
Within the above context, Bucks County will test its telecommunications interconnections and responses on November 20, with the expectation and foreknowledge that they will not con- ,
stitute any evidence as to the appropriateness or feasibility of the draf t plan, or its concepts; those we believe to be f atally flawed.
If either of your agencies can provide us with any (l basis for creating ret listic plans, in light of the above and l
enclosed, we will conui ter such submissions.
l
- In the meanti.e, we request that your agencies provide j us with assistance in i lanning f or the necessary evacuation of Bucks County residents.
iA This letter is consistent with the conversation which Commissioner Fonash and Mr. Patten held on November 8, 1984.
]
' Sincerely, .
hN! /W~
i Carl P. Fonash Chairman, l l Ducks County Commissioners
- l r12.rjsII/sp "
Enclosures l
cc: U.S. Nuclear Regulatory Commission (
4 Philadelphia Electric Company !
, Charles McGill !
Limerick Ecology Action-Intervenor P '
e B
i
[
. ~ .
?%
INADEQUACIES OF THE BUCKS COUNTY (ECI) FIXED NUCLEAH FACILITY INCIDENT SUPPORT PLAN FOR INCIDENTS AT THE LIMERICK GENERATING STATION
- 1. Monitoring / Decontamination. The proposal to send evacueer on from reception centers to mass care centers (primarily ochools) before monitoring /decontam-inntion procedures has been otrongly criticized by FEMA in its report on the drill.of July 25, 1984. Revision would require masoive changen in the cen-tral EPZ plan as well an in all support plano. These changes would necensi-tate widespread reallocation of fire department and other emergency personnel.
- 2. Plume / Ground Contamination. The Pinal Environmental Statement-Limerick (NRC Staff) states that in a number of accident / weather sequences, people ao far as 25 miles from Limerick would be oubjected to a 24-hour doos of ground radiation alono in excoan of the total permitted (once only) for emergency workers. Thic done would, of courne, be in addition to that from the cloud passing overhead, and would remain nn n continuing ground doce for a long period of time. Without being removed, residents would be subject to fatal-ities and nevere health conocquencen.
- 3. Improper Center Siting. The plan devinnnten two reception centers and a num-ber of mano care centero in Central Ducks which lie within or just outside the 25-mile zone. Those contero are inherently unouitable, becauno Bucks County emergency serviceo could face the double task of reevacuating the evacueen cicultaneously with moving out their own Duckn County citizens.
- 4. Traffic /Meteorologien1 Conoiderationn. Like the EPZ plan, the support plan ja, fails to take into account that both Philadelphia and Lower / Central Bucks lie statiotically very significantly downwind from Limorick. The major evac-untion route to and through Bucko in decignnted to be the Penncylvnnia Turn-pike, much of which lies along the ningle highest plume risk direction.
Turning back westbound tractor-trailer traffic and dioposing of it would create a problem coepounded by the designntion of the Philadelphin-Route 1 Interchange an exit point for the EFZ ovneuern. One or two jack-knife acci-dento on the Turnpike enot of that potat would impede or halt the 25,000 evacueen projected to continue to uanpocified pointo in New Jersey.
- 5. Locintien/unterici. The support plan, no well ao the EPZ plan, presuppones the dispatch of emergency cupplien for maos care from the Rod Croon warehouse in Northeast Philadelphia. Given the conditions of evacuation traffic at the Turnpike /U.S.1 interoection and the possibility of attempted celf-evac-untion from Northeast Philadelphia through Bucko County, thero in a clear risk of supplies not reaching their destination for many houro, even days.
Furthermore, they might become contaminated en route.
6 Logistics /Dintribution Center. The support plan designates the Bucko County Airport no a staging center for receipt of supplien. It lies on the peri-phery of the 25-mile zone. Not only is no fall-out-proof facility available for storage or loading, but emergency personnel as well as material could be unnecessarily oubjected to serious contamination in nome accident / weather sequenceo.
- 7. Transportation /Puel. The only mode of emergency transport from risk arena io nosumed to be by motor vehicle. Predictably, an evacuation from the r EPZ into/through Ducks County would doplate stocks of gasoline and replace-ment tires. Given the NRC's accumed average evacuation opeed of 2.5 mph, cars otarting with leon than full tanko would nood refueling upon arrival in Ducks County. No study han been dono nor have plano been made for the
fuel neede of Bucko ronidento if plume pannage required thn, to move from jn, the 25-mile zone or from contaminated arean contiguous to it. Especially, there are no emergency plans for the non-inntitutionalized disabled nor for people who may be temporarily or regularly without automobile transport.
8 Volunteers. The plan does not aHress the difference in volunteers' avail-ability and w1111ngness to nerve under nuclear accident conditions, as dis-tinguished from more limited and predictable disanters, such as Mississauga.
,Nor does the plan verify such volunteers' 24-hour, 365-day active status.
The plan takes for granted the corvices of employees of bus and trucking .
companies, school dintricts, hospitals, etc. No individual letters of agree-
' ment are required; the arrangemente presupposed are often at variance with other contractual obligations of the employer as well as lacking individual informed concent.
- 9. Sheltering. The plan liste Sheltering as a protective action. The PENA Director, John Patten, however, acknowledgod in a recent meeting in Bucks County what has also been pointed to in the G.A.O. Report on Further Actionn Needed to Improve Emergency prernrednenn Around Nuclear Poworpinntn simply
- that choltoring is uceloso after two houro.
- 10. Public Information/ Route Alertinc. The pinn makes no provinion for notify-ing Bucko residento to prepare to move out from under a potential plume.
i Quite the contrary, the prepared radio announcement advises them that they are,not affected. No route alerting whataoover in pinnned within the 19-to 25-mile aren in order to advico of any change in conditions that would warrant evacuation. Indeed, the peraonnel for such alerting would be un-
- available because of being aircady n=oigned to cupport functions on behalf of the EPZ plan. There in no nroesem'nt of the number of-location of the hearing disabled nor of those people living independently who are never-tholoca incapable of appreciating and responding to such an emergency. Child care centers, prisono, honpitalo, geriatric facilities, and other inotitu-tions would have to rely on their own generni emergency plane, if any.
- 11. Schools. The support plan precupponen contradictory nequencen of events if An accident should occur chile cchocle nre in neonion in Buckn County. The practice of school authorition in to hold ntudents nt school in the event of weather or other emergencien and to contact parents before sending them home. Contrary to that practice, the plan requires that studente be dis-missed immediately. Sinco most cchooln operate on a three-shift bus sched-ule, buses would not be instantaneously available as posited in the plan.
Contaminated persons and vehicles might conceivably be singled in the school buildings and parking areas with students retained at school pending contact with parents. (Handling of such a situation during the 7/25/84 drill in l Montgomery County was alarmingly inept.)
- 12. Highwayo/ Bridges. The inadequacy of roada to the north and of bridges to the east across the Delaware turn Bucks County into a bottleneck, which could on the one hand receive several hundreds of thousands of people from outside its border in addition to the several hundred thousand of its own population who would also seek to leave. Given fuel shortage and the absence of firm contingency pinnning, the result would be unacceptable disorder.
Experts on plume characteristico and evacuation behavior affirm that appro-l priate plans well beyond the EPZ are necessary to mitigate the ruffering 1
and loss of life and property that would occur during an unplanned evacua.
tion.
. 3 . ,
- 13. Other Jurindictions. No formal plano have been entered into with New Jersey or other states, although PEMA is charged by law to develop such plans when appropriate.
- 14. Drills / Testing. The GAO has criticized as inadequate the procedures used
. for testing emergency / evacuation plans for commercial nuclear accidents.
Not only are teste preannounced, known long in advance to state and local" participants, but also the parameters cet for accident simulation are limited to sequences resulting in a risk radius of no more than 10 miles from the plant. This practice is no doubt convenient for the licensee and the emergency " players" but of little use in demonstrating capability to protect the public in some of the more cevere but credible accidents.
Seldom have adverse weather conditionn been incorporated into the tests, nor is participation required along the 25-mile potential plume radius.
(By inadvertence, readings conrictont with auch a plume were once issued in a tests the emergency workern " evacuated" to the expected 10-mile dictance and sat down to congratulate themccivco on their performance, when in fact they would have been dead at the readings they hnd recorded and ignored.)
Nothing in the EPZ plan or the support plan tooto capacity to remove "promptly" (See Finni Environmental Statement, Limerick, N-3) that part of. Bucks Countians at rick, impacted ac the nrea is by population and geographical location.
A e
6
A REFERENCES
- 1. Bucks Draft plan 5-a-1 paragraphs a & b; 5-e-1; FEMA, p.22
- 2. FES, N-3
- 3. Bucks Draft plan 4-c-1
- 4. FES 5-79 Bucks plan, page 12; 4-c-1; 3-a-1
- 5. Bucks plan 1-a-1
- 6. Bucks plan page 19
- 7. Bucks Plan 12-13; FES N-3
- 8. Eucks plan page 14, paragraph c; 14 paragraph f; 15 thragraph h; 6-a-1
- 9. GAO page 4; Bucks plan page 5, paragraph k-1
- 10. Bucks plan 7-c-1
- 11. Bucks' plan 14 paragraph F
- 12. Dr. Jan Beyea.
- 13. 35 p.S.g 7 70 3, pagcc 132,133
- 14. GAO chapter 3, pages 26-40 r13.rjsII/sp
m I
CERTIFI C AT T: OF F.rRVirr I hereby certify that I have served the following information on the enrire service list below on this 26th. day of November, 1984 by hand delivery to those attending the evidentiary hearings in Philadelphia, or by deposit in United States mail, first class postage prepaid:
Testimony of Commissioner Rita C. Banning Notice of LEA's plans to request additional subpoenas to obtain testimony on LEA's deferred contentions on off-site emergency planning contentions LEA's schedule for witnesses whose testimony has,been previously submitted, and clarification of Mr. Wagen: nann 's subpoena :
Judge Helen lioyt , Chairwoman Ann P. Ilo d o d o n , Esq.
Administrative Judge of f ico of the Executive Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission wanhinoton, DC 20555 Washington, DC 20555 neniamin Voqler, Esq.
Dr. Richard F. Cole orrien of the Executive Legal Director Administrative Judge U.S. !!uc] car Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission
/^ Washington, DC 20555 Troy n. Conner, Jr., Esq.
Dr. Jerry IInrbou" Connor and Wotterhahn 1717 Pennuylvania Ave., NW Administrative Judge Webiwr'nn, DC 20006 U.S. Nuc1 car Regulatory Commission 1" Ivin1phia Electric Company Washington, DC 20555 Me n: t:<twa rd G. Bauer, Jr.
Docketing and Service Section VP and General Counsel 2301 flarket St.
Office of the Secretary Phila., PA 19101 U.S. Nuclear Regulatory Commission Thomas Gerusky, Director Washington, DC 20555 Bureau of Radiation Protection, DER 5th fl, Fulton Bank Bldg.
Atomic Safety and Third and Locust Ste.
Licensing Board Panel liarrisburg, PA 17120 U.S. Nuclear Regulatory Commission Spence W. Perry, Esq.
Washington, DC 20555 Annociate General Counsel FEMA Atomic Safety and Room 840 Licensing Appeal Panel 500 C St., SW U.S. Nuclear Regulatory Washington, DC 20472 Commission Washington, DC 20555 Zori Forkin, Esq.
Governor's Energy Council P.O. Box 8010 -
1625 Front St.
Ilarrisburg, PA 17105 ,
l
. . u -.'
4 5
J. Gutferrez, Esq. Angus Love, Esq.
U.S. NilC flegion 1 101 East Elain Street 631 Park Ave. Norristown, Pa. 19104 King of Prussia, Pa. 19106 Director, PEMA Thomas Gerusky Halph liippert Bureau of Radiation B-151, Transportation & Safety 111dg. Protection, DER liarrisburg, Pa. 17120 Sth.. Floor, Fulton Bank Timothy Campbell, Director Third and Locust Streets liarrisburg, Pa. 17120 Chester County Dept. of Emergency Servicon Robert Anthony / FOE 14 East Biddle Stre' P.O. Box 180 West Chester, Pa. 19J80 103 Vernon Lane Moylan, Pa. 10065 Martha Bush, Esq.
City of Philadelphia Municipal Services Bldg. Itobert Sugarman , Esq.
15th. and JFK Blvd. Sugarman & Denworth Philadelphia, Pa. 10107 101 N. Broad Street 16th. Floor Charles Elliott, Esq. Phila., Pa. 19107 i
Brose & Postwistillo 1101 Building lith. & Northampt on i;I reet ..
Easton, Pa. 18012 es 2
DATE: Nov. 26, 1984 lb!, 9
( l'h. I I kitz.r,hresident LEA) 4 l
.-m- w