ML20100K189

Testimony of Rl Reber on Limerick Ecology Action Deferred & Respecified Offsite Emergency Planning Contentions. Certificate of Svc Encl.Related Correspondence

ML20100K189
Person / Time
Site:	Limerick
Issue date:	12/03/1984
From:	Reber R BERKS COUNTY, PA
To:
Shared Package
ML20100K177	List: ML20100K176 ML20100K180 ML20100K189
References
OL, NUDOCS 8412100593
Download: ML20100K189 (5)

Text

i UNITED S'IATES OF AMERICA NUCLEAR RFGULATORY COMMISSION -

Before the Atcaic Safety and Licensin'g',joard

CCMETED In the Matter of )

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Philadelphia Electric Company )

)

Docket Nos. 50-352g 50-353va -7 20 :31 (Limerick Generating Station, )

Units 1 and 2) ) (JFIE cr SEg 4.,

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ShhhCh TESTIMONY OF ROBERT L. REBER ON LIMERICK ECOLOGY ACTION DEFERRED AND RE SPECIFIED OFFSITE EMERGENCY PLANNING CONTENTIONS Int roductio n The purpose of this testimony is to respond to Limerick Ecology Action (LEA) offsite emergency planning contentions admitted pursuant to the Licensing Board's Order dated October 26, 1984 relating to Berks County.

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 capabic of being implemented.

1. The Berks County Radiological Emergency Response Plan (RERP) for the Limerick Generating Station has not been approved by the County Conunissioners because it has not yet been completed and submi tted for approval. There is no reason to believe that it will not be accepted and approved when it is submitted by the Director of the County Emergency Management Agency and the Director recommends approval.

8412100593 841203 "

PDR ADOCK 05000352 T PDR

LEA-2 The unadopted RERP's fail to provide reasonable assurance that each principal response organizat Lon has sufficient staff to respond to and to augment its initial response on a 24-hour continual ba sis, or that the assigned staff can respond in a prompt manner in case of a radiological emergency at Limerick.

2. Berks County municipalities continue to recruit personnel to staff their Emergency Operations Centers (EOC) and are making progress. As of November 20, 1984, municipal deficiencies are as follows:

Amity Townships Deputy Coordinator Boyertown: Deputy Transport Officer Douglas Townships none Earl Townships none Colebrookdale Townships Deputy Radiological Officer Washington Townships none Union Township: Transportation Officer Deputy Transportation Officer Deputy Communications Officer Deputy Radiolo61 cal Officer Deputy Fire / Rescue Officer Deputy Police Service Officer RACES operators are furnished by the county and are not part of the municipal staff. All municipalities are continuing to recruit and train staff personnel.

• LEA-5 The Emergency Response Organizations (including federal, state, and local governments and support organizations) have failed to fully document the existence of appropriate letters of agreement with support organizations and agencies. Thus, there is no reasonable assurance that the emergency plans can be implemented.

3. Derks County RERP, Draf t 6, October 1984 Annex T contains copies of agreements with all the bus providers. Ambulances , public service organizations do not require written agreements.

4. Berks County RERP, Draft 6, Annex T contains letters of agreement with RACES organization. '

5. Arrangements are complete for 24-hour Emergency Broadcast System (EBS) coverage with all five (5) county radio stations.

6. As outlined in response to LEA-28(b), the Berks County RERP, Draft 6, October 1984, Annex K, p. K-3-1 states, "a current list of wrecker / tow operators is maintained on file in the Berks County Communications Center." This facility is fully staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per-week and dispatching wreckers / tow trucks is a routine operation. If one is not available, another is called. There has never been a shortage of resources.

7. Annex K, p. K-3-1 also contains a list of service stations / operators who have agreed to stay open or open in emergencies. They have all furnished 24-hour telephone numbers for contact. There is no requirement for written agreements.

8. Host school agreements have been completed.

9. The Berks County RERP, Draft 6, October 1984, Annex 1 contains agreements for mass care centers. Agreements are confirmed for a decontamination center at Oley High School. The center at Daniel Boone High School is covered by verbal agreement, which is in the process of bein; confirmed.

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COMMONWEALTH OF PENNSYLVANIA 4 g(, p,[TE; GOVERNOR'S ENERGY COUNCIL 05.W C P O. BOX 8010 1625 N. FRONT STREET HARnlSBURG. PENNSYLVANIA 17105 84 EC-7 A10y.g, meg UNITED STATES OF AMERICA 7ss-ozzo NUCLEAR REGULATORY COMMISSION GFF.CE F f EtkIC 00CAET hc & SE6VIC1.

BEFORE THE ATOMIC SAFETY AND LICENSING BO N d In the Matter of )

)

PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies of " Testimony of Timothy R.S.

Campbell" and " Testimony of Robert L. Reber" on LEA Deferred Offsite Emergency Planning Contentions in the above-captioned proceeding have been served on the following by deposit in the

! United States mail, first class, or, as indicated by an asterisk

! through deposit in the Commonwealth of Pennsylvania's internal mail

! system, this 3rd day of December 1984:

Helen F. Hoyt Troy B. Conner, Esq.

Administrative Judge Conner and Wtterhahn, P.C.

Atomic Safety and Lt ensing 1747 Pennsylvania Avenue, N.W.

Board Washington, D.C. 20006 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Docketing and Service Section Administrative Judge Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclcar Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry Harbour Atomic Safety and Licensing Board Administrative Judge Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Benjamin H. Vogler, Esq.

Appeal Panel Counsel for NRC Staff U.S. Nuclear Regulatory Commission Office of the Executive Legal Washington, D.C. 20555 Director U.S. Nuclear Regulatory Commission

. Washington, D.C. 20555 L _ _ _ _ _ _ _ _ _ _ _ _ _

. . o*

Robert L. Anthony Philadelphia Electric Company Friends of the Earth of the ATTN: Edward G. Bauer, Jr.

Delaware Valley Vice President & General Counsel P.O. Box 186 2301 Market Street 103 Vernon Lane Philadelphia, PA 19101 Moylan, PA 19065 Joseph H. White, III Angus Love, Esq.

15 Ardmore Avenue 101 East Main Street Ardmore, PA 19003 Norristown, PA 19104 Charles W. Elliott, Esq.

• David Wersan, Esq.

Brose and Postwistilo Assistant Consumer Advocate 325 N. 10th Street Office of Consumer Advocate Easton, PA 18042 1425 Strawberry Square Harrisburg, PA 17120 <

• Thomas Gerusky, Director Martha W. Bush, Esq.

Bureau of Radiation Protection Kathryn S. Lewis, Esq.

Dept. of Environmental Resourcas City of Philadelphia 5th Floor, Fulton Bank Building Municipal Services Building Third and Locust Streets 15th and JFK Boulevard Harrisburg, PA 17120 Philadelphia, PA 19107 Phyllis Zitzer

• Director, Pennsylvania Emergency Limerick Ecology Action Management Agency P.O. Box 761 B-151, Transportation & Safety Bldg.

Pottstown, PA 19464 Harrisburg, PA 17120 Steven P. Hershey, Esq. ** Spence W. Perry, Esq.

Community Legal Services, Inc. Associate General Counsel Law Center West Federal Emergency Mgmt. Agency 5219 Chestnut Street 500 C. Street, S.W., Rm. 840 Philadelphia, PA 19139 Washington, D.C. 20472 Timothy R.S. Campbell Jay Gutierrez, Esq.

Director U.S. Nuclear Regulatory Dept. of Emergency Services Commission 14 East Biddle Street Region I West Chester, PA 19380 631 Park Avenue King of Prussia, PA 19406

,fcl 8 .)nl) h nL.l> >, a

< lori G. Ferkin Assistant Counsel Governor's Energy Council Date: December 3, 1984 I