ML20101F063
| ML20101F063 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/24/1984 |
| From: | Love A MONTGOMERY COUNTY, PA |
| To: | |
| Shared Package | |
| ML20101F061 | List: |
| References | |
| OL, NUDOCS 8412270011 | |
| Download: ML20101F063 (41) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i Before the Atomic Safety and Licensing Board In the Matter of :
PHILADELPHIA ELECTRIC COMPANY :
(Limerick Generating Station, DOCKET NOS. 50-352 Units 1 and 2) : 50-353 MEMORANDUM IN SUPPORT OF MOTION On October 23, 1979, the Nuclear Regulatory Commission published its Policy Statement on the Planning Basis for Emer-gency Responses to Nuclear Power Reactor Accidents (44 Fed. Reg. 61123). The Commission stated that it " concurs in and endorses for use the guidance contained in the NRC-EPA task force report,"
(Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants (NUREG-0396, EPA 520/1-78-016, December 1978), NUREG-0396 -- in particular, that two Emergency Planning Zones (EPZs) should be established around light water nuclear power plants. The EPZ for airborne exposure has a radius of about 10 miles; the EPZ for contami.tated food has a radius of about 50 miles. Predetermined protective action plans are needed I for the EPZs. The exact size and shape of each EPZ will be de-cided by emergency planning officials after they consider the
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specific conditions at each site. .These distance.s are considered large enough to provide a response base which would support activity outside the planning zine should this ever be needed.
The Commission further stated that, following its Proposed Rule-making concerning additional regulaticas on emergency planning, it would provide additional guidance which would:
consider how local conditions such as demography, land use, and meteorology can influence the size and shape of the EPZs and ... address other issues, such as evacuation planning.
As a result of that Proposed Rulemaking, the Commission promulgated the current final rule on emergency planning. (45 Fed. Reg. 55402 (August 19, 1980), effective November 3, 1980.)
The Commission cited with approval in Appendix E, the use, inter alia,of NUREG-0654 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants for Interim Use and Comment, January 1980) now revised as NUREG-0654, FEMA-REP-1, Rev.1) to provide guidance in developing plans for coping with emergencies and NUREG-0396 for establishing emergency planning zones (EPZs). As g far as EPZs are concerned, the Commission's final rule provides:
Generally, the plume exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles (16 km) in radius and the ingestion pathway EPZ shall consist of an area about 50 miles (80 km) in radius.
The exact size and configuration of the EPZs surrounding a particular nuclear power re-actor shall be determined in relation to l
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local emergency response needs and capabilities as they are affected by such conditions as demography, topog-raphy, land characteristics, access routes, ang jurisdictional boundaries.
10 C.F.R. s50. 47 (c) (2) .
The State Correctional Institute at Graterford is located 8.3 miles from the Limerick facility (see Emergency Plan filed March 17, 1981 App. H E4.1, also attached as Exhibit "B").
Thus, it is the responsibility of the Pennsylvania Emergency Management Agency to coordinate the development of an evacuation plan for this facility. On December 13, 1984 inmates' counsel received an unclassified plan in which "certain information has been deleted from this copy of the Graterford plan for security reasons." Accompanying the plan were to affidavits, one by Ralph J. Hippert, Deputy Director of PEMA, and one by Glen Jeffes, Commissioner of the Pennsylvania Bureau of Corrections and a Request for Non-Disclosure of Confidential Information executed by Zori Feskin of the Governor's Energy Council (see attached Exhibits "C", "D" and "E").
The inmates at the State Correctional Institute at Graterford, through their attorney, take exception to this request. In particular, we object to the analogy to site security plans. 10 C.F.R 2.790(d).specifically relates to site security, national security data and other sensitive data concerning the nuclear power plant. The inmates fail to see the relevance of this section to the Graterford plan. Thus, it should not be~used as a basis for the confidentiality request.
The request for confidentiality also cites a case'in support of their request, In the Matter of Pacific' Gas and Electric Company, 5 NRC 1398 (1973). This case involves the disclosure of a site security plan. The Atomic Safety and Licensing Commission allowed intervenors' counsel and experts to review the site security plan under a protective order. Inmates contend that the S.C.I.G. plan is less sensitive than the security plans for the site itself, and should not be held to a higher standard of confidentiality.
Furthermore, the inmates object to the overly broad interpretations of confidential information. On page E-1-7, the capacity of the prison infirmary has been censored. Inmates believe that such information is already in the public domain and should not be subject to confidentiality.
Finally, the inmates are unable to adequately develop their contentions due to the confusion created by the prior evacuation plan and the subsequent unclassified plan. The initial plan indicates when evacuation will occur. The second plan dis-cusses the possibility of sheltering or evacuating, but does not provide any details regarding when each method would be utilized.
Therefore, the inmates respectfully request additional access before being required to submit their contentions.
Res e tfully submitted, (ANGUSA R.
/\ n 4 4 A N LO E, ESQUIRE W Montgomery ounty Legal Aid e
, y, .
S.Iu.
- . ., PENNSYLVANIA BUREAU OF CORRECTION RADIOLOGICAL EMEltGHilCY RESPOllSE PLAN (RERP)
ANNEX 1-TO APPENDIX E OF TIIE BUREAU OF CORRECTIOll'S ELIEltGl!!!CY PLAN q' . .
w October 26, 1984 E-1-1 (Appendix E - Annex 1 - pago 1)
Sanitized COPY NO, bh Unclassified i
EXHIBIT "A"
____.__.m p Y .
.. GLEN R. JEFFES Commissionor O ERSKIND DERAMUs I
g ,. ' 3. % Deputy Commissionur g
PENNSYLVANIA DUREAU OF CORRECTION P. O. BOX 590 CAMPHILL (717 PENNSYLVANIA 17011 October)707 26, 1904 7480..
[ Annex 1 to Appendix E of the Bureau of Correction's Em for response to incidents at the Limerick Generating Stationerge ,
b This plan is coordinated with the Commonwealth of Pennsylv Plan, Annex E, entitled " Fixed Nuclear Facility Incidents" ania, Disastor Operations Government guidance for radiological emergency response and complies with Federal (State Correctional Institution at Graterford) .plan Further,i the risk Institution's and it Is included here as Attachment G.s coordinated with the Bureau plan This plan and the State Correctional Institution at Grutcrf
.' and changed as required by Federal Government direction as nor In the Commonwealth's Disaster Operations ecessitated ,
Plan Annex E by changes f.3 changing needs and demands in the Bureau of Correction an, Institution at Graterford.
e State Correctional G s I Cm Bureau,of Correction D s I E-1-11
- ,( .
REC 0lO OF Cl!ANGES s
e
- f. .,
- CHANGE 'DATE OF DATE CHANGE POSTED BY NUMBER CHANGE ENTERED (SIGNATURE) t 1
v 9
- /$ .
V' E-1 lii-
.. TMILl! OF ColiTHilTS
- *s -
Pago #
[ TIT LE P A O E . . . . . . . . . . . . . . . . . . . . . .
7 P R O M UL O ATIO N PA O E . . . . . . . . . . . . . . . . . . . . . E-1-! ...............
RECORD OF CHANOES . . . . . . . . . . . . .........................E-1-il TA BLE OF CO NTE NTS . . . . . . . . . . . . . . . . . . . . . . . . .E-1-ill .............
E-1-lv BASIC PLAN (OF ANNEX 1 TO APPENDIX E OF 1.
D. .THE BUREAU OF CORRECTION E EMEROEN
- 10. .
IV.
'ABBREVIATIONS P U R P OS E .
AND DEFINITIONS
.... . .g).1. . . . . . .
)
V. CONCEPT OF OPE R ATIONS . . . . . . . . . . f,' ..............
VI. DIRECTION AND CONTRO VU. COM M UNIC ATIONS . . . . L . . . . . . . . . . . ...... . . . .E-1-5
... E-1-12 DISTRIBUTION OF THIS PL AN.......................
... ...... C 1-12
- TABS
- E-1-12 p (A) COEMT Representatives to the PEMA E.O.C.
k (B)
...................... E-1-15 l Pa. Bu' eau of Correction i
Tabic of Organization **'*****''''''
i E-1-16 (C)
Emergency Organization Chart E t ,y (D)
................. E-l-17 Pa. Dureau Menage of Correction, Contral Office .
RERP E-1-18
}-
- t. ATTACHMENTS
} A.
Staffing, Transportation, and Equipment
......... E A-1 abJ - Bureau Correction Agreement with j MNNNNNhhllMfddEhihgg **
h; ,
Tab B - A eement between ia E-1-A-4 W a to use a Radio Frequency ..and the Bureau 1
................ E-1-A-5 k
4*
E-1-iv
7 3
- . Ta A- dvanco harty horsonnok .. . . - 3 C- Re arty sonnel a e ... .. - - -8 l
bk e'--
. D. Radiological Exposure Control E-1-D-1 Tab A - SClo Emergency Worker Certificate . . . . E-1-D-4 Emerge c Workers for Dosime r fl . . . . . . . . E-1-D-5 and Survey Meters Tab C - Dosimetry - K1 Report ,orm . . . . . . . . . . . E D- 0 Tab D - Decontamination Monitoring Report Form. E-1-D-7 Tab E - Con t r ol T L Ds F or m . . . . . . . . . . . . . . . . . . . E D-8 E. Training, Preparedness Measures, and Exorcises . . E-1-E-1 R et o ,n t o S c i a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E . 1 . , 1 1s
- o. ggo - aadioiogical
,,,, Emergency nesponso . . . . . . . . . . E-1-G-1 a
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LIST OF Cl! ARTS IU -
Chart 1,to Attachment A - Staffing Requirements E A-5
- for Evacuation s_
Chart 2 to Attachment A - Communications and E A-6 Security Restraints in Transport Vehicles E A-7 Chart 3 to Attachment and Scheduling A - Minimum for SCIO Personnel (gyg Stg(fi{g@
Chart 4 to Attachment' A - Busses & Ambulances E-1-A-8 Chart 1 to Attachment B - MapMfyQf}i$i$lyiOfid E-1-B-3 Chart 1 to Attachment C -
t jh E-1-C-6 Chart 1 to Attachment D - Decontamination E-1-D-9 Monitoring Team Assignments and Radiological Equipment Hecds Chart 2 to Attachment D - Summary of ALL E-1-D-10 ological Equipment and Supply Needs g t
t E-1-v!!!
_._.-_-__..-g llASIC DLAN
(- I. - PURPOSE The purpose of this plan is:
A. ' To establish policy and procedures to be followed by the Bureau of Correction and the State Correctional Institution at Graterford (S010) la coordination with the Pennsylvanta Emergency Management Agency (PENIA) In the event of 'a nuclear incident' at the Limerick Generating Station (LGS) located at Limerick in Montgomery County.
B. To provide guidance to the Bureau's Contral Office Emergency Management Team (COSMT), to the State Correctional Institution at Graterford, to the supporting state correctional Institutions, and to the Bureau's response team at the Pennsylvania Emergency Management Agency's emergoney operations contor.
C. To provide guidance for the protection of the SCIG staff and inmates as well as all support personnel.
D. To establish procedures for the safe and secure evacuation of 501G to approved relocation sites.
E. To provide guidance for the safe and secure return of staff and inmates to SCIO when the emergency has ended as determined by PEMA.
!b- H. AUTIIORITY ATID REFERENCES
- A. Authority .
This plan will be Implemented under the authority of the Pennsylvania Commissioner of Corrections in cooperation with the Ponnsylvania Emergency Management Agency.
B. References .
- 1. Commonwealth of Pennsylvanla Olsaster Operation Plan, Annex E,
" Fixed Nuclear Facl!!ty . incidents", dated November 1981, with
, changes.
, 2. PEMA Agency Directive No. 32, "Dovelopment of a Mass Care Operation Plan," dated November 14, 1000.
- 3. Pennsylvania Rmergency Mnnagement Act 32:1, Pnmphlot I nw 1:1:12, 1978.
l .. 4. Pennsylvania Bureau of Correction Administrative Manual Volume b- -
OM-004.11, Emergency Plan.
- 5. Pennsylvania aureau of Correction Operation Manual, Volume VI, OM-004.
E-1-1
_(AppendixE, Annex 1.Page1) ,
L #
O.
Pennsylvanin Dureau of Corroetion Administrative Directive 201, "Use of Forca and Chemical Agents," October,1970.
( lH. ADDREVIATIONS AND DEFINITIONS See the Commonwealth of Pennsylvania Disaster Operations Plan, Anno.x H:
- 1. Basta Plan, Section !!I *
- 2. Appendix 0, Section 11 .
- 3. Appendix 13, Section !!
- 4. Appendix 15, Section 1
- 5. Appendix 18, Section 11 O. Appendix 20, Section !
A. Abbreviations B.C. Bureau of Correction i BUREAU Bureau of Correction COSMT -
During the emergency the Bureau's Central Offica Emergency Management Team, b -
CLEAN Commonwealth Law Enforcement Assis tan'ee Net work. CP--mn vertwrmnens.:;, y g , - - - m *gg 4~g e r -
CD V-100 Survey meter (Geiger counter) used to conduct decontamination monitoring.
CD V-730 A self-roading dosimeter with a scale from 0-
- 20 R. (Roentgen).
CD V-742 A self-reading dosimoter with a scale from 0-200 R. (Rocntgen).
CD V-750 The doa' meter charger used to charge (zero)
- the D"A 622, the CD V-730 and the CD V-742 self-reading dos! meters.
COMMISSIONER Commissioner of the Pennsylvania Dureau of Correction DCA-022 Q Dosimeter Corporation of America's Model 022 self-conding dosimetor: has n 0-20 R (Rocntgan)
E-1-2 .
scale, and is the commercial equivalent of the CD V-730.
Decontamination The process of checking a person or object Monitoring with a survey meter to ascertain if the person fW f
or object is fouled with a radioactivu W.a. J substance, kaN,kehrNo$e$ tion The donning of cuter rain clothing (rain hat, coat, gloves and boots) by emergency workers as a protective mensure to prevent radiocontamination directly on the body.
m; Emergency 03ccation Center, pgp EOC h , i Environmental protection Agency EPA t !
+
Federal Emergency Management A gency.
- ) fk 't t Chemical symbol for potassium ledide, a K! prophylatic drug that offers some protection to the thyroid gland from injury due 'to accumulation of radiolodine in the thyroid. ,
(a) Sheltering - The restricted containment of Protective Actions 1.000(1 4
SC10 staff / inmate population to ACTIVITY (windows and doors closed, and
- outside air intake minimized to the highest extent possible).
(b) Selectivo evacuation - A protective action
. that will pertain to selected groups of people, e.g., preschool children and pregnant women, Very probably this protective will not pertain to SCIO.
(c) Evacuation - general evacuation of all
.. persons from the area.
Pennsylvania 17.t.wrgency Muungement Agency.
PUMA Ponnsylvania Department of Transportation.
PennDOT gg,;;,
is i.E if/R1Wd a fr& T m q (-g 7--n:ur r w-"ntamiTi.3 Status - Single housing, Program Laval i Maximum officer /employo escort required l)
E-1-3 ,
g Program Lovel 11 Close Status - Single housing, constant visual control by employe Program Level !!!
_institutional Medium status - General freedom for internal
~ programming; direct visual control by officer Program Level IV Alinimum status - Outside programming on the institutional grounds; intermittant control by officer, visual
~
Program Level V Pre-release status - Inmate allowed off institutional grounds without direct supervision (furlough; work release)
Radiolodine Radioactive lodine RERP
!!adlological Emergoney Response Plan.
REM (r)
A unit of radiation measurement that is based upon effects as measured in the human body.
In this plan, Roentgen (R) and rem (r) are considered to be ossentially the same. .
RilU i Restricted llousing Unit -
That
'. cult 3 arrangement and location which affords the maximum of security, surveillance,
'b scrutiny of the Inmate assigned to Program and Level I.
Roentgen (R)
A unit of measurement of x-ray or gamma radiation based upon effects as measured in the air (e.g. by the self-reading dosimeters).
Security Vans Bureau of Correction owned vehicles especially designed for tho transport of high security risk inmates, Outwardly they muy C appear as a bus or a van.
Correction personnel often refer to the bus Dureau uf E-1-4
-- -~
type as " maxi vans" and the vasi type as " mini
(. *
- vans"; these two ("maxl" and " mini") derive from the physical size of .the vehicles, Support Institutions Those state correctional institutions providing dir,c,c( support 6EIiLisEB% ["'S W,
$h-
, TLD* Thermoluminescent dosimeter - A crysta hne dosimeter that measures radiation by the amount of luminescence induced into it. The crystal is mounted in a card.
Unit of Dosimetry
- The number of dosimeters and the amount of K1 to be issued to each individual assigned duties within the plume exposure pa thway EPZ. Consists of: one CD V-730 cc one D C A-622; one CD V-742; one TLOT one
- Dostmetry-K! Report Form; and a fourteen n'ay supply of K1 for one person. Decontaminatich team members working outside tha plume exposure pathway EPZ will have the same items with the exception of not having the
' CD Y-730 o_r, its conimercial equivalent, the
. . . . . . . . ._. .. . D C A.-622.
IV.
CollCEPT OF OPEllATIOllS A. The officially' adopted emergency classification scheme for fixed nuclear facility incidents is the general guideline upon which the Buranu, SCIG, and supportin Station (see g SCis will respond to any incident at the Limerick Generating NUREG-0654 and Anaex E to the Commonwealth Disaster
~
Operation Plan). This four-stage emergency classification is as follows:
- 1. Unusual Event Unusual events are in process or have occurred which indicate a potential degradation of the level of safety of the plant, No releases of radioactive material requiring offsite response or minitoring are expected unless further degradation of safety systems
, occurs.
- 2. Alert Events arc in process or have occurred which involve an actual or polontial substantlui degradation of the level of safety of
'the plant. Any releases expected to be limited to small fractioits of the EPA Protective Action Guideline exposure levels.
i
- 3. Site Emergency Events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of tne public. Any releases are not expected to excocd EPA Protective Action Guldeline exposure levels except near sito boundary.
- O E-1-5
.l . General 1:aiergiyv i..ent are in peoeeis or have cecurred which involve aetuni or sanninent <an.t uitial core dei,radation or melting
> with potential fur lu.ss of cont tininent integrity, lleleases can be reasonably expected ta eveed !!:).\ i)cotec tive .\etion Guideline exposure levels off-site re: mare tinin the inunediate site area.
[ ! .M Y kt h h, N[Dh:hbIN{h)8 1 }IOMAdhhfM,ff MdMI .
higher.
c h E li .khin in .s e a$uie
'. Of a3 ine'ident cid.u i f _i ed et t A L E.11T-~or Tlic ilureau will naliti Ki..i up. cort SCI ($'jyp{M[fdg.ent status.
Also, as a redundancy :aca.iure, : .?'O will Neeive direct notification from C. The l!ldj$fMf[(dif@.'TN@,c .255I/id %J;cgi;j;W,7i((gg p?qq,+.i[ :i Llie only of ficial who inay author:.u e'.menation at .suu to tr. reivearn .;ites, e .
E. For planning purposas, the :'ig re .ud .'ar :he :otal number SClO in: natis
. For planning purpesas thW Ar w a.nes there are :>rogram t.evel !
QQinmute3 of:d h Pruf.* :i: ' .:'c
. : ! hfdd(d((QijMR(I 4 Thesa inmatos
.; are considered uniximum weu.*i:y .'!J:ss, ti rogJ.a Leve , t hWi%dr. mates will be raloe iteil ti. T M p p . 'r.' ; ' a i...'.el iWMRr.M/ygg iinnntes will be relocuted@'aeli t.r' kW/ :oG!MihwM&9Md
~~
For plannliig purposes this ;,lan t ;a a .i total af @ Program Level 11 inmates; 11:e40 inmatos will ne Mysagg.sen 'i ,e i!^il la Gl&/[@ggg@ caeli to i *
,J
b This'. plan assumes there _is a total.{Mi.E Program Levels ill, IV, and V which_ will be relocated 4 wmM6N F.-
In the event of evacuation, Program Level I inmates will be transported in E = L a . w pgage p* 9 Program Levels II, III, IV, and V will be tran1 ported in 8'.IaWMAll-drivers and guards in transport vehicles will
~ be RIEM employees. Security measures for each group are specified in Attaolment @
'O.
The of SCIG infirmary has a capacity forCQpatients with a daily average an capa e ofGenerally, sitting up most of the In.a bus or infirmary van. patients are ambulatory In the event of evacuation the ambulatory patients'will be transported with their respective Program Level group with an accompanying medical attendant and housed in the
. infirmary at the relocation site, r
Bed ridden and c ambulance to the' ommunicable disease patients will be transported by Infirmary at t'EO?O The estimato _off the number of patients Emer that will require transport by ambulance is blaMMd At Site-c>,Jenoy muGM10 will notify the contracted ambulance service C_)
. .u.,4y em.; . g Jof the possible need for service and Indicate how many ambulances will be needed (this information obtained from th Bureau COEMT). -- At General _ Emergency W will request the ambulance to~ report to @ES to pick-upWWefAIdosimetry-K! for the ambulance crow, and u UMANTV> rudio.
will dispatch the ambulance with Opon notification of evacuation,IC_ J
, the patients and transport them togEn; to SClO, where it will pick up on the : _
Sultable restraints will be used
$,;/ . emiwss patients and each ambulance will be escorted by Du "9
.m e'-mh ~"S.
The ambulance cre w will undertto decontamination monitoring at Rf?F9 Inmates-who are hospitalized in a community based hospital (s) will remain there under the normal surveillance of SCIO guards. If the hospital is in the 10 mile risk area, the hospitalized inmate w!!! be moved to the hospital's relocation site as per the hospital's plan. The SCIO guards assigned : guard duty will provido security during transit and at the relocation site.
H. If support personnel are dispatched to SCIO ( ~ -
-~
SClO will house and food these personnel (approximately ersons) at SCIG until: (1) they are officially recalled, or
.. - , implemented. (2) the evacuation is in the - e = PSCIO will house n+ these personnel in mass care arrangemont
= y -e &w Return to 8C10 will take place upon termination of the incident and official clearance is given h)M@MW4Mgg J.
Q If and when inmates are at relocation sites somo normal servic
~lnmates will be suspended or soverely limited due to the extonnating E-1-7
y . .. . . . q i
i circumstunees. Some such services muy include: Training und eduention programs; counseling; normal visiting privileges; some recreational
{ , activities; library availability; certain administrative proceedings.
K. Upon declaration of ' SITE EMEROENCY yy 3yl3 gpg c hj4%gi@ e i
- 'h -
I L. The number of Bureau of Correction guards, food service personnol, ort personnel needed for medica!.
operation t.t(personnel, administrative and other.stgj$$5$
otals approximately[~
Ifl%%....%..., hM%$NORUM8 "
m estimated number of ouw , um Witi renova f1,NM503 Should the need arise for more personnel, the COEMT will obtain e necessary personnel resources from the Bureau of Correction's SCis.
M. Equipment and supplies (security restraints, radlos, dosimetry, survey geters ,9 dN@ KI) Wi specified in this plan will be stored em m %afMHO MMNM quick and orderly MTit@ip.(ggGqrSpigG
~cl3 g:dn w ma usert. 43%K@$ to
- N. Necessary restraints _b atons and radies will be assembled 6 pts ~IM ,
(hwpenw-m,9.--]
- te timo thisi g.gg.w.awrnw. enwm 44. At the equipment will bg od ety ,)
O.
_Radiolog_ical equipment and K! w!Lbe stored hilMIENEW/W4M6dlh MNMi1TMfdM@lifj@hsXYWMeleMIV Individuals will be issued the cosimeters, tu, ino survey meters us~ appropriate and cuch person will acknowledge receipt of the equipment by signing the "Acknowledgemen; of Receipt by Emerg cy Workers for osimetry-KI and Survey Meters" form included as Tab ' to Attachment -
qe hbg; n lL Essessmmmmi to @@@$,# MI KI will be turned be '
~ 3Y(,a,tnd any unuse
~
P.
The following is a general . list of preparedness measures and protectivo actions whlen the Bureau will utilize as guidelines for its level of response and preparedness at each step of the four level emergency classifiention scheme:
- 1. Classification: Ut:USU AL EVENT Unusual events are in process or have occurred which indicate u potential degrudation of the level of safety of the plant. NO release of radioactive material requiring off-site responso or monitoring is expected unless further degradation of safety system occurs.
8.C. ItESPONSE:
Q NO ACTION REQUIRED C - I -!!
_ _ _ .y
- 2. Ulnwifientlon: ,\ 1.F. l(T
- Events are in process or have occurred which involve an actual or
, k- . potential substantial degradation of the level of safety of the pinnt. !
i Any releases expected to be limited to small fractions of the EPA Protective Action Guidelines exposure levels.
B.C. Response:
)
(1) l Receive notification from PEMA.
(2) Notify S.uperintendent's _ office at kjM% $sihMh @ dhWiM Akyp!.W 3 $ w6# gSCI (3) Activate the COEMT.
(4)
Send two COEMT representatives to PEMA's EOC ff,Q.
. h 8 N{
ggggw$2MRMWMsig I N
- y
-") . (7 The dir ~ COEMT representap%y s at tyEMA EOC make will p w]ith the t WSW5thiVggh@irgesWhgijiW d5slIE COEMT reagesen auve at possible need fo euw ms cu j JgY t-MM$NdVddidhAPMjsg iL ggggggggy
@WJfiir W
The Bureau's COEMT,~ in cooperation with SClO nnd support institutions, needs NOTE:will compile a current list of unmet and special All needs will be met with Bureau resources if possible; PEMA will be notified of those needs which the Bureau cannrat meet.
3.
. Classification: SITE EMERGENCY Events are in process or have occurred which involve actual or likely major failure of plant functions nooded for protection of the public.
Any releases not expected to exceed BPA Protective Action Guideline exposuro lovels, execpt none lho site boundary.
B.C. Response:
(1)
Notify SClO and other SCl's and reloention sites of the SITE EMBRGENCY status.
(2)
Complete theabove, classification appropriate preparations elted under the Al,EttT b E-1-9
7-I3I kf1h_..ddWDd"GlWk'YiMNNNEbhMNb'h/
L .
(4) Assemble all support personnel _ and eautomentaqp.i G L
t (5) Confirm with PEMA the arrsngements for PSP and National Guard. COEMT representative at EOC will request PSP to dispatch two PSP escort vehicles to respective support SCI.
1 (0) 1 1 y.j ' P/fpi pick up busses from transport sitos and assemble
(! i t, 4 i t The supporF p'_usses and vans will rendevous wl_th Q/gg.g;j vehicles _ ypn%ffygpihW.4 With their %,.t A scort, tne' su ort ij ausses and vuns wn! proceed _on r gMj n;W$A l to SClO a;gM;@i%rggMggy q} g
\$ @RWM 5 Mk WA & M56&Wh n* M M P M W IM1]L&f _
(7) _Upon if$dsn!%iffjjirection, supporting MM@@y$p{ A Jill dispatch their personnel to their respective DssignmenLs %(({iyG(;ygggg.jlg[%
s g (B) The Bureau will provide PEMA status repot ts received frqm SCIO and __su o.
- nde vay
&y1,.}$hgiR gtlL.]' :
is ?6 - compiefe; special conditions to inMude firstitution climate (mood of inmates / staff]).
(9) If appropriate, request (through PEMA) U.S. Department of Energy response team plume monitoring representatives l;c se:it to SCIG (see Attachment D, section I.B.).
(10) Upon receipt of prote tivo.go e.g., sheltering, the dti%Wihgsp aib willrecommendations direct SCIG to implement from PEMA,
=
the appropriate protective action.
(11) The ilurean will confirm with SClO the distribution of dosimetry-lit to staff anil report this information buel; to PE M A.
(12) Upon recommendation by the Pennsylvania Department of floalth to take KI, the Dureau will relay the K! recommendat!on to
, SCIO which, in turn, will notify its staff to take K! and offer KI to the inmates.
(13) The Bureau will confirm that the transport busses with drivers, C restraints, communication equipment, ant.QMgghj@ ascort L-1-10 -
. . . _ . _ _ . ~
have reported to SClO. Thi Ir: formation will be trui:Smitted to PEMA.
(14)
The Bureau will coordinate with the relocation sites about the necessary preparations to recalve SCIO Inmates and inform SCIG and PEMA of the readiness status of relocation sitos.
(15)
, Vf1Mid5GKW%%t1bA!MlM1fl@N,QnggyAss 5
- (10)
The Bureau will essist o location sites as necessary.
(17)
The Bureau will direct ((t@QMt(Did[fM@dihi)i@$ffy .
(18) The Bureau will alert emergency food vendors of the possible need for TV dinners (approximately 6000 meals) for transit !
M/MidtsM435fMSM'illiM)}/%i@$MWiggjNMMfggqvgjg h
- 4. Classification: GENERAL EMERGENCY Events are in process er have occurred which involve actual o'r imminent substantial core degradation or melting with potent!al for loss of containment integrity. Release can be reasonably expectoci to exceed EPA Protective Actic:i C. sideline, exposure levels offsite for more than the immediate site area, f
Q B.C. Response: '
(1)
Notify SCIG and relocation sites @M@@jf$gsggg) of GENERAL EMERGENCY status. -
(2) Complete the appropriate preparations cited under the ALEllT and SITE EMERGENCY classifications above.
(3) Upon t o protective ectica recommendation (s) from ek a['JM,f PE MA, I hTi(CitrdWfwill diroet SCIG to shelter or evacuate, ~as appropriate.~
(4) Dispatch the required numbar (21 of ambulances _
SCIO to teans sort to ncn-ambulacory/comn ug'g patients to($ MQM@gM1ftW'MT3 !%
3 h,,
(5) Provide to 18tml A rotfreSS "eports on the evneuntion of SClii.
,, i 1 . R 75 (6) Notify relocation sites hjj[(t$$f9)M(&Vf@fbf commencement of evacuation from SCIG. -
(7) Notify other state eocrootional evacuation, Institution i of S CIG '.<
b (8)
Notify PEMA of SCIG's arrival at relocation sites; specify any unmet noods as they arise. .
E-1-il
- 19) Tint llureiin will statil'y Einerip ney loud tiervice Ventlor: tititt ortler nt
. lciuit t wo tinys uf.TV tluniern (nt teutil 0,000 'dinners) for
' site. Other related and/or support equipment (e.g. %'61) relocation 6
Med trucks ote.), will bc dispatched SGQJp@Q:g,}g;.g@, rggipjgg{,gy,)
(
- V. 1HilECTION AND .')HTROL A. Direction and control will be implamented COEMT "
animemawrige***=a*by the**aa M*
B.
VL GlihtPAMytgtp4 Wig;-g8p.ib@h4hMVW6sMdihi@f)fnlN1.N COMMUNICATIONS 65t 74 , m I ^
B. Back-up Communications:
1.
The isback-up SCI's @)5 #$ihEJE,,y(OggMSFJd;sa@NMcommun 2.
.q u WBack-up SfihF/h M communications #eM55'W@@n%Q24WiffiEW between the lBurea 3.
Back-up communications with relocation sites will ba:
- a. Thro _ ugh PEMA E5IEhEdfEN/ -
- b. By g Messenger ~,
O 4.
Central Office Activate the RERP Message Processing System '
- a. RERP Log
- b. RERP Message forms @i[@@M(TdMN VII.
DISTRIBUTION OF TilIS PLAN A.
Bureau of Correction Copies to: Q N ??
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B. PEMA: Copies to:@
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{ ATl'ACil. MENT A STAFFINO, TRANSPORTATION, AND EQUIPMENT GENERAL CONCEPT OF EVACUATION SCIO inmates will be evacuated to 73 a;,msnavata9Gr$N6EiGliM4d4WasM#Al#M%uMMr!> 6 .
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b) k h Mhb bhb!kfkkh h h h h Support QuaidMT) will provide all necessary services to SCIG inmates relocated to their respective ,QyNgpQggg;r gsgi;giy y f%:.;Lg[y y
I '
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STAFF 1HO AND TRANSPORTATION 111.
RADIOLOGICAL EQUIP. MENT AND Ki A.
Dosimetry-Ni and Survey .ileters (see Attachment D) 1.
SClO staff - Each staff person at SCIC will be issued at the SITE EMERGENCY level a unit of dosimetry-K! which consists of: one CD E-1-A-1 (Appendix E. Anne.x 1, Attachment A, Page 1)
f K1 V-730-or one DCA-622; one CD -V-712; one TLD; one bot tablets; and ono Dosimetry-K! Report Form.
- 7 SCIO will distribute '. s k KI) one
- i; "
,2. SCIG inmates - Inmates _ will receive KI tablets.
(upon receiving noticeh of the Department of g I notation of individunis who do not' take t e Attachment). '
Support hIEf5I5I$f3 - Each support fMN;DifNhstaff prior to departure personCD V-respondin
'3.
SClO will be issued by their respective t KI a unit of dosimetry-K! (one CD V-730 or on Also, decontamination monitorMg teams DCA-022).
f nu c at support Form).
will be distributed dosimetry - K! (less the CD V-730 or See Attachment 6SL
)
IV. SECURITY EQUIPMENT (See Charti l be 2 secured to this Attach j A.
Inmate Restraints - If evacuation is necessary, inmates w lG for transportation Shg@yf.;.dM;$g$)$@gyg, h
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.. ....J ATTACilllENT D
( PROTECTIVE ACTIONS AND RADIOLOGICAL EXPOSURE CONTROL A1BASURES I. PROTECTIVE ACTIONS A. Two Basic Protective AMons The two primary protective actions specified for the general public are sheltering and evacuation; these protectiv.e actions apply to State
, Correction Institution Graterford (SCIG). -
B. Sheltering Upon PEMA's recommendation to shelter, inmates will be kept indoors, wir. dows and doors will be closed, and outside air intake will be minimized to the extent possible.
During the sumace months when high ambient temperatures and humidity may necessitate opening of windows in the inmates cells in order to prevent serious medical problems, "s' 21tering" as specified here, may not be fully implementable.
will request, through PEMA, that a DOE plume monitoring team persons be sent to SCIG.
This DOE team's mission will be to provide continuous air monitoring outside and inside the cell blocks, and based upon the actual readings at SClG, advise the SCIG Superintendent with regard to the actual need for sheltering.
sheltering is officially recommended for the entire 300'-10 mile radiusFo EPZ, as the team at SCIG could assure the superintendent, and the Inmat'es well, I
t.' d only background levels are detectable (if that's the case, of course) and vlindows could remain open. In like manner, the team will .
Indicate if a radioactive plume reaches SCIG, and how long it stays before dispersing or decaying.
to the SClO Superintendent as well as its own reporting The channel Superintendent will relay the information to PEMA via the COEMT and will take interim actions as per his best judgment. After, consultation
- with BRP, PEMA will issue instructions for the institution to follow and these will be official actions which the Institution will implement. Note:
The special arrangement for the DOE team at SCIO pertains only to open (closed) windows when ambient temperature sheltering has been recommended during the high months.
C. Evacuation if general evacuation is recommended by the Governor (or PEMA), SCIC will commence with evacuation planned. (MFhemmmo>w *of inmates to the relocation sites as ypjmj % elaw4ih m: q ., , ym.;nm PW "E 4M e mm e m'=sw"~Th L,1M b > ii= ,,e m w ?.MR**~~ . !?i_.: ai oe "9PTWN jQ WMmimW&rgry.~ r Q g r A m E fi W i l y @ ~% . 3 t_ t h -
?y_-phy a e,;We y wrO r w:Ngmy w-m 4
jiF , : ,{ jidign cd Q t co m fey p W W w e n.* wn m m m y -- w ywf 6 ._=q 3
nWMim p,metID special Q rovisions for the staff and inmates of SCIG and for support personnel ( and Bureau employces from supporting E-1-D-1 -
( _ - .
~
' CING3 are made in this pinn. Dosimetery and Potassium iodide (KI)
._ will be provided to all employees and Dosimotors will be placed in
.Q stationary locations inside SCIG so as to allow close estimato of total doses that inmates may be exposed to, also, inmates will be offered Kl.
~
. Busses will enter the compound and inmates will be boarded with minimum exposure to the outside environment. .Socurity hardware will be installed on the inmates while under shelter.' Windows of busses will remain closed while the bus is inside the plume. exposure pathway emergency planning zone.'-
II. SPECIAL MEASURES FOR CONTROLLING RADIATION EXPOSURE
- A .' Staff Each SCIG staff person and each support SCI employee responding to SCIG will receive two self-reading dosimeters (one CD V-730 or DCA-622 and one CD V-742), one thermoluminescent dosimeter (TLD), clic bottle of potassium lodide (KI) tablets -(14 tablets; a 14 day supply), and a Dosimetry-KI Report Form (see Tabs B and C).
B. Inmates ,
KI _ tablets will be available for inmates and when appropriate (the Department of Health recommends when KI should be tal:en) will be offered to each inmate.
Additionally, in each cell block and other areas utilized by inmates, two t4 se!f-reading dosimeters (a CD V-730 or DCA-622 and a CD V-742) and' a TLD will be placed in suitable stationai'y locations and read at least each 30 minutes by staff personnel. A record of the readings from the self-reading dosimeters and their respective locations will be maintained.
C. Decontamination Monitoring
, Should evacuation.be implemented each employee and inmate will undergo decontaminati'on monitoring at the relocation site.
Decontamination monitoring is merely the process of checking each person
. with a Ociger Counter (CD V-700 survey meter) to ascertain if- the individual has radioactive contamination on his person or clothing. If an
. : Individualis found to be contaminated he/she will undergo decontamination (shower and clean clothes) (see Tab .D).
( Decontaminution monitoring procedures for people, supplies, equipment and
& vehicles will be as specified in the Commonwealth's " Fixed Nuclear Faci!!ty Incidents" plan, Appendix 16, Attachment A. Decontamination monitoring
(;
- teams for FIO and each support !nstitution will receive dosimeters (one 1 CD V-742 and one TLD), K1, and a Dosimetry-KI Report Form. The i numbers of survey meters and team members (monitors and recorders) are
[ indicated on Chart Q to this Attachment, g E-1-0-2 i
~
s
. - - , , . , .---.n - - , .
g D.'
n' Double Clothing and improvised Respiratory Protection
(
Should the situation warrant, additional clothing and emergency re
..,.. protective measures can be implemented (see the Commonwealth's " Fixe Nuclear Facility Incidents" Plan, Appendix 16, sections VI. C. and D.).
Ill.
RELATED ADMINISTRATIVE PROCEDURES Each -8C1 will follow the guidance of the' Commonwealth's " Fixed Nucl Facility Incidents" plan, Appendix 16 with regard to (a) control TLDs,
'inventory dosimetry and KI record and maintenance keeping, (c) property control and (d) equip procedures.
- e e. ,
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Graterford Prison is an-1,300-inmate,' maximum security,
= state-prison facility that ccmes uader the purview of_the Pennsylvania Commissioner of Corrections. The prison is approximately 8.3 miles from the_ Limerick Station with as much. underground space as abcveground c. pace.: This ender-
. ground space was previously used for Civil Defe..se.
~
The Commissioner of Correcticas has had the experie..co of planning for-and estimating the approximate.evaccation time lof'an 1,100-inmate facility in Camp Hill. He was required to formulate these plans for the C:..ap Hill f:.cility because of the Three Mile Island incident.
The State Commissioner of Corrections estimated a total ovacuation time of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 30 mit.utos .~or Grater"ord, if the evacuation order is given in the daytime. (Priscaers would not be moved cutside the prison 'at .kight for security reasons.) Mobi'.ization' time (i.e., time to got buses to the site and get the prisoners ready to load onto the busas)
-is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 15-minutes. Loading and driving' tin.e to beyond the 10-mile limit was estimated at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes. This estimate assumes the availability of 90 buaes.
If the order to evacuate was given just after sunset, the mobilization would commence 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 15 minutes before sunrise, and loading and departure would begin at first light.
Other planning information and details are proprietary, n
dc4 4-3 -
EXHIBIT "B" NUS COPPCAWMON h_ .-
7 9
' UNITED STATES OF AMERICA NUCLEAR REGULATORY CONHISSIDH i BEFORE THE ATOMIC SAFETY AND-LICENSING BOARD
-In the Matter of Philadelphia Electric Company Docket Hos. 50-352 (Limerick Generating Station, ) .
50-353 Units 1 and:2) J
_ AFFIDAVIT OF RALPH J. HIPPERT
-1, Ralph Hipport, being duly sworn, stato as follows:
- 1. At present I am the-Deputy-Director Office of Plans and Preparedness, Pennsylvania Emergency, Management Agency.
! 2. I h' ave. read the Pennsylvania Dureau of Correction, Radiological dated October Emergency 26, 1984, Response Plan, Annex 1, Appendix E including the Request to withhold portions of the foregoing Plan from public disclosure.
- 3. . l.hereby certify that the statements and matters set
' forth therein are true and correct to the best of my knowledge.
~
Ralp_[Hippert, ff*
Deputy Director Office of Plans and Pre]aredness Pennsylvania Emergency J1anagement Agency Subscribed and Sworn to before me this-l V day of December 1984 Y[kwd
~' '
.; N t. \>ts Notafy_P0blic JULIA M.13005. fl0fARY PUDLIC My Cummr.wu t9un July I J. JUu/
My commission expires: Hanisture. PA caupan coumy EXHIBIT "C"
AFFIDAVIT OF GLEN R. -JEFFES
~ I, Glen R. Jeffes, being duly sworn according -to law, hereby depose and state the following:
1.
11 am the Acting C'ommissioner of Corrections of' the Commonwealth of Pennsylvania.
2.
I have had extensive training.and experience in the field of corrections.
- 3.
1 received a Bachelor.of Arts Degree from Michigan State University in 1957.
~ I graduated with a major in personnol and a minor in Social Science.
_4..
1 roccived n -Master of Arts Degree from Michigan State University in 1902.
My course of studies in this degree program included a major in counseling and guidance and a minor in ps'ychology.
5.
I have also completed advanced graduate work at the University of Tennesseo in' 1902, where I studied counseling techniques and psychology, and at Northwest Missouri State College in 1965, where I studied diagnostic testing.In addition, I have attetided numerous seminars in correctional management.
6.
Ilhave held various positions in the field of corrections in a career which has spanned more _ than twenty years.
- 7. - From 1964 to 1969 I was employed by the Board of Control and Department of Social Services of. the Stato of ' Iowa in the following positions:
4 a.
Psychologist at Iowa Stato Penitentiary, where I assisted in psychological evaluations und con' ducted individual and group counseling sessions; b.
Superviser of Minimum Custody Treatment, Iowa State Penitentiary, in which I supervised, developed and conducted all treatment programs for 4
-inmates assigned outside the prison walls; EXHIBIT "D" 1
y
- e.
Personnel Administrator, Central Offlee, lown Division of Corrections, with the ' responsibility for developing a total Bureau personnel program for four adult and -two juvenile institutions; and
- d. ~
Administrative Assistant to the Director of Corrections, with responsibility-for developing-and establishing written policies and procedures for the 4
' Burea'u.
8.'
From 1969 until 1972 I served as the Associate Superintendent for Programs
- at the Idaho State Penitentiary. The Idaho State Penitentiary was Idaho's only adult maximum security correctional institution housing all convicted felons over age sixtcon.(10), in iny position as Associato Superintendent for Programs ~1 was responsibla for all treatment and enstodial programs within the institution.
9.
Prior to my appointment us Associate Superintendent for Programs, treatment programs were non-existent. I developed casework services, work release and an accredited high school and college program. In addition, psychologient rmd psychiatric services were implemented and chaplaincy serviced broadened. The institution changed from ond custodial to treatment oriented.
-10.
While serving as ' Associate Superintendent, I was also a voting member of the
' idaho Commission for Pardons and Paroles.
11.
In 1972 I was appointed First Deputy Superintendent for Treatment at the -
State Correctional Institution at Rockview. In that capacity I was responsible -
for all treatment programs at Rockview.
- 12. From 1973 to 1983 I served as Superintendent of the State. Correctional Institution at Dallas. The institution provides a wide range of programs and
~
services for 1200 Inmates at un annual operating budget of approximately twelve million dollars ($12,000,000).
2
= _ , - . .
.i-j .' , ...
013.1 From February .1,1983:until July <l,1983 I served as Superintendent. of the ,N 1
State Correctional' Institution at Graterford.
'14. .From July'4,1983 until the pecsont, I have served as the - Acting Commissioner of Corrections of the Commonwealth of Pennsylvania.
157 I;have authored a variety of articles in the field of corrections including the following:
- a. The Use of Inmate Panels by Adult Correctionnt Institutions, Iowa,1968;
. b .' Institutional and Community llesources, Idaho Peace Officers' Magazine, September 1971;
- c. - The Support Team Concept: A New- Appronch in Pennsylvania's CorrectionalInstitutions. The Quarterly, Autumn 1973, the Pa. Assoclution L
, of Probation,~ Parole and Corrections, Co-editor, Corecetionn! Classification and Treatment, American d.
Correctional Association, W.A. .nderson Publishing Company, Cincinnati, Ohio, May 1975; and
- e. Co-editor, Correctional Law, Pennsylvania Prison Wardens Association, May - 1979.
' 16. - I have' been a member of a number of professional associations including the following:
- a. American Correctional Association;
- b. . American Correctional Association Technical Assistance Committee;
- c. - Approved Technical Consultant for Adult Institutions, American Correctional Association;
= d.~ Pa::t President of North American Association of Wardens and
' Superintendents of the american Correctional Association;
. c. - Board of Directors of North American Association of Wardens and Superintendents; 3
m
_.1 ..
I
- f. . Pennsylvania Prison Wardens Association; g.
Permanent Standing Committee on Classification of the American i:
Correctional Association;-
L h.
Northeast ' Regional Advisory Committee, Pennsylvania Commission on Crime and Delinquency, June 1976 to 1980;
- 1.'
Board of Directors, Crime Clinic of Wyoming Valley, Pennsylvania; j.'
Approved Auditor for Commission on Accreditation for Corrections-Adult Institutions;
- k. Pennsylvania Council on Crime and Delinquency; and 1.
Pennsylvania Council on Crime and Dc!!nquency, Prison and dail Overcrowding Task Force Committoo.
17.
I have also served as a lecturer in the field of corrections at Dolse State College; King's College in Wilkes-llarre, Pennsyivimin; Marywood College und Luzerne Community College.
18.
It~ is my opinion that there are sound penological reasons for requiring the confidentiality of all classified parts of our State Correctional Institution at Graterford (hereinafter SClG) ovucuation plan, which have been deleted from our unclassified version of the plan offered to counsel for the inmates.
- 19. . SClO is one of three maximum-security walled institutions maintained by the Pennsylventa Bureau of Correction.
The continuous thirty-foot (30') high concrete wall surrounds the entire institution and presents a formidable obstacle to escape.
20.
As of .the last day of OeLober IDU 1, SU10 confined G05 offenders convicted of murder (310 of which were murders in the first degree and fifteen of which were awaiting execution),616 offenders convicted of robbery and 206 offenders convicted of forceful rape in its inmate population.
m 1
T~ ,
4 4
- 21. 13y providing inmates with any parts of the classified information in the plan, i ., i q
they will be able to make plans to foil the smooth operation of the plan and 3 .. .
p-Furthermore, they will be f$t3 to plan escapes' during the operation of the plan.
I' d f
able to' tell their friends and family what the plan is, thus providing further All of 'these actions I . opportunities to disrupt the plan or to plan an escape.,
would place the public at an unnecessary risk during the operation of the plan.
22.
The development of the plan required expertise in corrections, knowledge of a
the physical plant of SCIG and knowledge of the physical plant of our support 1
This knowledge and expertise is not available to anyone outside institutions.
the Pennsylvania Bureau of Correction. Thus, review of the classified parts E of the plan would be fut!!e. G 23.
There have boon occurrences where attorneys have, or have been suspected Thus, there of, divulging to inmates innterials almost as sensitive as this plan.
is a reasonable suspicion that, even though we are given assurances by an
} attorney for the inmates that the plan will not be divulged, that it will bc divulged to the inmates in some form or another.
24.- If this plan becomes compromised to any significant degree, the Per.nsylvania llureau of Correction will be required to change the plan, thus delaying the operation of the Limmerick plant and needlessly expending tax do!!ars to change the plan. This would be required so that we can be assured that the public is adequately protected.
25._
Due to the substantial risk to the public if the classified parts of this plan are disclosed to the inmates as compared with the ' futility of any kind of meaningful review of the classified parts of the plan by anyone outside the Pennsylvr.nia Bureau of Correction, it is my expert opinion that only the unclassified version of the evacuation plan be disclosed to anyone without a need to know, particularly to counsel for the inmates or anyone else with connections with the inmates.
5
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- 1. N.t ., /,[ , '\V- k.,A 4.
~
' Glen it. Jeffes ')
. v Acting Commissioner
' Sworn and Subscribed Before Me This M Day ,
'of /).en//,-i+ ,1984. .
$aA2f/$>A.,/Ab$'
'Motary - Public
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^
UNITED: STATES OF~ AMERICA NUCLEAR-REGULATORY' COMMISSION
.7 ~Befo're'the Atomic-Safety and Licensing Board.
o In-the Matter 1of2 F
' Philadelphia Electric' Company J)
) Docket Nos. 50-352
[ (Limerick Generating Station. .. 50-353
( 1 Units ~1Dand 2). J)) -
% l y'
Request'for Nondisclosure of Confidential Information.
D'
~0y letter dated today, the Commonwealth is providing-to' counsel.for'the intervenor-Graterford inmates an unclassif.ied copy of the Pennsylvania Bureauoof Correction Radiological Emergeacy. Response Plan prepared for response, by:the State l Correctional Institution of Graterford to incidents at the Limerick Generating Station.
Pursuant-to Section 2.790 of1the-Commission's
- 1 regulations-it'is hereby requested that the following.
-information'be. withheld-from public-disclosure: Attachment-6.(support: f acilities), Attachment C.. Attachment E
-(training,. preparedness measures, and exercises),
LAttachment at"Graterford),. F Attachment (return to the State Correctional G (Radiological. Institution response
. procedure's), Attachment 11, Attachment I,- Attachment J, and .
Attachment X as1well as-references regarding. relocation sites,. number of inmates and their-classification level.
. .ItDis' the-position o'f the Bureau of Correction that
'the.Information
-security breach. sought to be withheld could result in a.
if released to. individuals and organizations other1than on-a strict "need to know" basis.
"The' attached affidavit from the' Bureau explains the basis 1 for concern with'rgard to the Graterford facility-in particular.
The Bureau hasLmade this. position known to the Pennsylvania Emergency Management Agency
- in turn making this plan available for rev(PEMA), which is iew by counsel for the Graterford inmates.
.Graterford In viewfacility, of the maximum security nature of the.
the emergency responso plan isthighly csonsitive ;nd a should be. accorded protection from disclosure alongfthe same' lines as an ' applicant's site security plan.
Under Sec' tion ~2.790 L, '
security. plans are "(d) of the Commission's regulations, deemed to be [ protected) commercial or financial information." Like an applicant's security system,' access in and out of the Graterford facility is EKHIBIT "E" e
l 9<e, 1 1
-controlled. mechanisms are in place to detect unauthorized access an'd/or egress from the facility, and the facility maintains a security 10 C.F.R. 73.45, organization, including' guards. See 73.46.
I The form of the plan provided to counsel for the-inmates here provides relevant information regarding i emergency response by the Graterford facility and is in accordance with the guidelines for release of a security plan outlined in Pacific Gas-and Electric Company .(Diablo Canyon Nuclear Power Plant, Units 1 and 2, ALAB-410,'5 NRC
~
1398-(1977). By the same token, releasa of the information in the Graterford plan described above would be directly contrary to the public interest'in protection from a security breach of the Graterford facility.
Respectfully submitted, p
l (h
Y ori G. Ferkin LA Assistant Counsel
,,a Governor's Energy Council Cated: December 13, 1984 l
L