ML20127D656
| ML20127D656 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/27/1985 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20127D660 | List: |
| References | |
| NUDOCS 8505010330 | |
| Download: ML20127D656 (4) | |
Text
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.o 4 Federal Emergency Management Agency I
Washington, D.C. 20472 MAR 2 71985 MF140RANDlM FOR: FAward L. Jordan Director, Division of Emergency Preparedness and Engineerirg
Response
Office of Inspection and Enforcment U.S. Nuclear Regulatory Counission FIO4:
a Assistant Associate Director Office of Natural and Technological P.azards Programs
SUBJECT:
Remedial Exercise at Graterford State Correctional Institution in Support of the Linerick Generating Station On March 7,1985, a reedial exercise was conducted at the State Correctional Institution, Graterford, to denonstrate that a portion of one of the Category A deficiencies cited at the July 25, 1984, Linerick Offsite Radiological Ehergency Preparedness Exercise has been corrected. The report; on the July 25, 1984, exercise was forwarded to you on Septmber 25, 1984.
The renedial exercise was conducted to more fully exercise the emergency response procedures at the State Correctional Institution, Graterford, including simulated evacuation of innates.
Ibring the exercise the Graterford authorities adequately denonstrated an understandiry of the emergency response procedures and the ability to adequately implement th m, therefore, this portion of Category A deficiency nu:nber 2 has been corrected.
As additional Category A and B deficiencies are corrected, w will notify you.
If you have any questions, please contact Robert S.
Wilkerson, Chief, Technolcgical Hazards Division, at 287-0200 Attachnunt As Stated
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Federal Emergency Management Agency g
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Region Ill 105 South 7th Street Philadelphia, Pennsylvania 19106
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,8 March 14, 1985 MEMORANDUM FOR:
Robert S. Wilkerson, Chief Technological Hazards Division ATTENTION:
Gloria Joyner u/a. w g
ames R. gasher, Chairman j
FROM:
Regional Assistance Committee
SUBJECT:
Graterford State Correctional Institution Exercise Attached is a copy of a report on the March 7, 1985 radiological emergency
. preparedness exercise held in conjunction with the Pennsylvania Department of Corrections, the State Correctional Institution at Graterford and PEMA.
As you can see from the report, we feel that the results of the exercise
-were very positive and that it resolved one of the problems identified in Category "A" Deficiency #2, as noted in the September 19, 1984 Exercise Evaluation Report of the July 25, 1984 Limerick REP exercise.
A copy of this report will be provided to the Pennsylvania Emergency Management Agency.
Attachment
rsw.28 ?BS 21:32:FD1A 1594 FED CM.2' P. E.3 o
on Thursday, Karek 74 1985, 's tiWietop exarcia a was he:4 tai tes t. emergency response procedures at the state Correctional Institution,2Crateriprd, in the: event of ad accident at the;1dmerick cenerating 8tstier.. Participating in tha esercise, warei tha :Pennsylyjst.ia Departme.:t of Correctione (inchding Craterford, and ithe support institutions of[
Iand land. the:Pennsylvd.iat Emetgency. Xandganant Agency (FEMA),
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At 1115; aptification of an alert, at 1, ism-ick was received by the Ieyarts,ent i
cf Correetions ifrom F3HAi.vfa temmercial telephone. Tas cceter.te of the l
messagaiware forwarded bt 'the t! apartment to Cratt.rford and the support institutions.: by telaphone taking! appro3 mately 10 minutes to consiste 1.he i
notifim& tion of cha' trarious:institistio=s..- Redundant.connuricalions tc olt place through the. use :of the : Commonwealth
- Law Enf or6 ament As siptance l
Netkerk; 'a teletype pystes tid into all the varione.institutir.ne.f rem tl.e s
departmentfa teacralteffical..
At 35; the tabletop.ezarcisei.eeunenced with the attached cbjectives bs:.ng it;desented. e The!Depar;.mont 'of Corrections and each.institutien establir.hed a cot = sand pos).from which~they! ran; their respe.ctiva energancy resp nace.
Energangy teams werei in attendtsca. utilizing fsciltties that presided adeq4ete.speep; lighting! and.talephones. ITr:ellent atotus: boards 1e e ou hanidiand kapti sp-to-dste. throughosat the axercios.
Tha' coce.issioner. Department eef Corrections, coordinated the overall responseiwhil's.the Deputy Warden at Oraterford was responsible for his institution.
copies of cha plaps were.available. and. consulted en a regular Laef e. It was i
evidenti that.the various;partie.ipefits were very kro tledgeable concerning their duties and performed titeir roles in a most.: conscientious and profession 61 manner.: : Continuous coordination. cook par ce betteeet -he departmenti ands oraterford.and the department. and. the.sapport instit utionn.
The Alert was reesived at 1254.:the Site Emergency at 1329: and the Cereral.
j Emerge:py at 4436*.l.
Oood: coordination toolc plach.betweern the Graterford public *nfora.ition Officer; itha Departent of Girrections and.PEHA.- The Craterford 170 eisulethd e6aitoring' ths: local radio and television statisrae, espec.ially KTW,t Montgomery Opuotys E35; station.. The inas.tes were informed shout r.he eituation at 4,iseerickland.recairedi spdates on an hourly basis.
persennel arereiplased:on it-best shifte, wehiele 1oading usama iert assembled,i inshte. and medical r4cordet had f oe d wer e packed.. As shance tema i
,,ltei prepare for dawte was eeneifrom Craterferd to[ f Corrections instructed oraterford to inewe E2 i
ralocation.; Tha Department o i
and doelmatry to staff 76reennel.
- When raf ayits the informatioc, ts.
preterford the ters Lt., rather than* EI W.s utilised causing aosse initial confusion A lock-down of the insstest occirrred at 1330 and, upon dir=ction 1
of, the Deveroor, ayacnation' commenced,es cr.11od Sc,r in the Graterford PI1F.t r
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The Irartow support.instatstionatedmulated arranging f or the neessuary busee; soeurity;v.nsa,idritara and other. equip,nents sad having it seat to Craterford t IFreparationsives made to house arriving.iamates.. Avefags trayal cisel f rom che happers f aatientions to Oratarford ts appretinately 1 1/* 2 hurs s s.
During the exerciser at ths. Alert stage, craterford informed the Departmet.t of Cerrecticas: of eartainesametineedor in the area of amoulances. 3e department < infbread Obiterford that,iebe *eakulances had been diu;atchen at Site: Energency;, Bo*varg this is kt wartance.with the deparaant's RER.P i
(page S-1-7) te.ich.does noti sali.fbr the dispatch of ambslances natil notifishtion of erarnation.tt The* exercise eenclufed et apprezimately 1603 upon the attuleted ralocktion of it.matest to suppor$ institutions:and[
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_ Category ?'B" R&ccamendations - (
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- 1..*.Personne* si'avgived in-tadiological energency rwspones activities should i
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become tot:117 f amiliar withf that terminology used during. an senergency to avcid:essfustoc:.i l-
- 2.
- Ambstlantes should b4 Hispatched to Craterford at an early otha (as tras dona duringi the enercise); to avoid Long delays, pptentiaJ.ly 2 nours or more3:1f as evacuation.is ordered., d.
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Federal Emergency Management Agency
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Washington, D.C. 20472 APR - 91985 MEMORANDUM FOR:
Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement 1
ssion FROM:
Richard W. Krimm Assistant Associate Director Office of Natural and Technological Hazards Programs
SUBJECT:
Supplemental, Interim Finding on Offsite Radiological Emergency Preparedness for the Limerick Generating Station Attached is a copy of the Supplemental Interim Finding on Offsite Radiological Emergency Preparedness for the Limerick Generating Station.
As stated in my memorandum to you of January 23, 1985, the Region III staff of the Federal Emergency Management Agency (FEMA) reviewed the revised plans which were s&itted to us under the Memorandun of Understanding between cur respective offices.
Also attached is an addendum to the Regional Assistance Committee's (RAC) review.
This interim finding supplements the " FEMA and RAC, Ragion III Informal l
Evaluation of the Offsite Radiological Emergency Response Plans for the Limerick Generating Station" which was transnitted to you on May 8, 1984 This report is also an olement-by-element review against Section II, Planning Standards and Evaluation Criteria, NUREG-0654/ FEMA-REP-1, Rev.1.
The remaining plan deficiencies which are expected to be addressed at the l
April 10,1985, remedial exercise are:
1.
Testing of evacuation plans for the school districts; 2.
Participation by South Coventry Township, with Chester County performing compensatory responsibilities; The remaining plan and preparedness deficiencies which will not be addressed at the April 10, 1985, remedial are:
1.
The 24-hour emergency response capability in South Coventry Township which will remain deficient due to staffing problems; w..-AI.N
. 2.
Unmet needs regarding buses and_ ambulances.
Chester County requires 132 buses and 80 ambulances; and Montgomery County requires 12 buses and 82 ambulances; 3.
The process for establishing access control points remains incomplete; and 4
Testing of the alert and notification process as well as the Berks County Emergency Broadcast System capability.
The Regional staff is working with the State to expedite a solution to these remaining deficiencies.
Based on the review of the revised plans and the results of the July 25, 1984, full-scale offsite radiologi, cal emergency preparedness exercise and the supplemental exercise conducted on November 20, 1984, the overall radiological emergency plans and preparedness are not adequate to provide reasonable
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assurance that appropriate mea,sures can be taken to protect the health and safety of-the public in the vicinity of the Limerick Generating Station in the event of a radiological emergency.
Attachment As Stated m-9 4
Federal Emergency Management Agency k
R Region III 105 South 7th Street Philadelphia, Pennsylvania 19106
_ MAR 291985 MEMORANDUM FOR:
Richard W. Krim Assistant Associate Director Office of Natural and Technological Hazards Programs ATTENTION:
ria J FROM:
P no Regional Director '
SUBJECT:
Updated Interim Findings on Offsite Radiological Emergency Preparedness for the Limerick Generating Station Attached you will find a copy of FEMA Region III's updated Interim Findings on Offsite Radiological Emergency Preparedness for the Limerick Generating Station. The report consists of an element-by-element review of the plans utilizing NUREG 0654/ FEMA-REP-1, Revision 1 and was contributed to by the Various federal agencies that make up the Regional Assistance Committee.
3 These updated interim findings are a supplement to the " Federal Emergency Management Agency and Regional Assistance Committee, Region III, Informal Evaluation of the Offsite Radiological Emergency Response Plans Site-l Specific to the Limerick Generating Station, dated April 27, 1984."
It was j
that document which resulted in.the original interim findings, sent to FEMA Head:uarters on April 17, 1994 As you are aware, because of four (4)
" Category A" deficiencies identified as part of the original Interim Findings, this office found that the local emergency response plans were inadequate and were not capable of being implemented. The full-participation exercise held on July 25, 1984 revealed five " Category A" deficiencies, three of which were confirmations of deficiencies noted as part of the planning review.
This memorandum will serve to sumarize the status of previously identified
" Category A" deficiencies and update the overall status of offsite planning and preparedness site-specific to the Limerick Generating Station. Besides the updated Interim Findings, we have also enclosed an addendum of general comments received by the RAC too late to be incorporated into the main document, but including items the Region felt would be of use to the offsite authorities as part of their process to upgrade the various plans.
" Category A" deficiencies identified as part of the April 17, 1984 Interim 1
Findings:
1.
In one (1) community (South Coventry Township, Chester Ccunty),
twenty-four hour emergency response continues to remain a problem due-to the fact that many essential positions are vacant. A " Category A" deficiency remains for this community.
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2.
Progress has been made in dealing with mobility-impaired / transit i
dependent individuals. A plan has been submitted for the Pennsylvania Department of Corrections (including the State Correction Institution, Graterford) and was exercised in an. adequate manner on March 7,1985.
Lists have been compiled for individuals with special medical requirements and those persons requiring transportation assistance and put on file in the municipalities. The risk counties have identified
.the necessary resources to evacuate those individuals located within ten miles of Limerick and. reported their unmet needs to the Pennsylvania Emergency Management Agency. Obtaining resources to
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fulfill those unmet needs is an ongoing concern. Chester County requires 132 buses and 80 ambulances while Montgomery County requires I
12 coach buses and 82 ambulances (these figures do not count an emergency. reserve established by Montogmery County which result in additional unmet needs of 39 buses,10 minibuses, 7 coach buses and 40 ambulances). PEMA is currently working with other state agencies to address these needs. A " Category A" deficiency remains due to an outstanding need for evacuation transportation resources, f
3.
Potassium iodide has been obtained in adequate numbers. PEMA has provided the Region with a purchase order verifying that 9,000 low-range, self-reading dosimeters have been ordered, with delivery e,xpected to begin the week'of March 31. Thermoluminscent dosimeters are also in the process of being obtained. PEMA has provided assurance to the Region that dosimetry is available in adequate numbers at other sites in Pennsylvania that could be transferred to the Limerick area in a prompt manner in the event of an emergency.
For all of the above stated reasons, FEMA, Region III feels that a " Category A" deficiency I
is no longer warranted.
I 4
The concerns regarding traffic control points have been resolved by the information contained in the current plans. Access control points continue to present a problem. As many as 39 ACPs will not be manned.
Efforts are underway between the consultants, the counties, PEMA and other State agencies to find personnel for these points. Failing that, arrangements will have to be made to establish barricades at designated locations. The process for establishing access control points remains incomplete; thus the " Category A" deficiency must continue in effect.
" Category A" deficiencies identified as part of the September 19, 1984 Exercise Evaluation Report on the July 25, 1984 Limerick Generating Station Exercise:
1.
See comment I above.
" Category A" outstanding.
2.
As noted in comment 2 above, the Pennsylvania Department of Corrections and the State Correctional Institution, Graterford, adequately displayed their capabilities to respond to an accident at, Limerick.
According to PEMA, school districts are expected to display their capabilities as part of a remedial exercise scheduled for April 10, 4
1985.
" Category A" outstanding.
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See consent 3 above, " Category A" resolved.
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'iccording to PEMA, the alert and notification concerns raised in the September 19 report will be addressed as part of the April 10 remedial exercise.
" Category A" outstanding.
5.
All municipalities within the plume EPZ have displayed adequate capabilities "to respond to an emergency at Limerick either as part of the July 25, 1984 exercise or the November 20, 1984 supplemental exercise, with the exception of South Coventry Township, Chester County. " Category A" outstanding.
Any outstanding " Category B" deficiencies are expected to be resolved through the planning and/or exercise process.
STATEMENT OF FINDINGS:
It is evident that great progress has been made over the last year in upgrading the offsite radiological emergency response plans and preparedness in the event of an incident at the Limerick Generating Station. This is due to the time and effort put into this project by individuals at all levels of government - State, county, municipal, school district, many of whom are volunteers, along with the assistance provided by the utility's consultant. However, three " Category A" deficiencies remain from a planning standpoint and thus the Region cannot make a positive statement that the plans are adequate and capable of being implemented.
i Exercises conducted to date have shown that participating jurisdictions could adequately respond to an accident at Limerick. Due to the fact that school districts and one municipality have not yet demonstrated their capabilities and elert and notification issues remain unresolved, the P,egion cannot state that overall offsite emergency preparedness is adequate to provide reasonable assurance that appropriate measures can be taken to protect the health and safety of the public living in the vicinity of the Limerick Generating Station in the event of a radiological emergency.
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FEDERAL EMERGENCY MANAGEMENT AGENCY l
i REGION III l
l INTERIM FINDINGS l
OF OFFSITE RADIOLOGICAL EMERGENCY PREPARE 0 NESS FOR THE LIMERICK GENERATING STATION MARCH 1985
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Rating Key: A = Adequate I = Inadequate PLANNING STANDARC/
ELEMENT RATING COMMENTS A.
, Assignment of Responsibility'(Organizational control)
A.1.a..
A Both the Berks and Chester County Radiological Emergency Response Plans (RERPs) have ben revised to reflect the updated terminology of the U.S. Department of Agriculture's Food and Agriculture Councils. There is no reference to this change being made in the
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Montgomery County RERP.
A.1.b.
A A.1.c.
-A
-The " Primary and Support Responsibilities Chart" in i~
the three county RERPs reflects accurate assignments.
A.1.d.
A i
A.1. e..
I Although a significant improvement has occurred in meeting the staffing requirements at the municipal level, problems still exist in certain areas. One community (South Coventry Township) still has large I
numbers of unfilled staff positions. Several other communities (such as Lower Providence Township) have one individual as a primary in one position and the alternate in another position, implying that the person would be working round-the-clock. Others have t
instances where one of the staffing positions does not have 24-hour coverage (Washington Township as.an example).
I L
The three county plans reflect the fact that the l
county communications centers operate on a 24-hour l
- L basis. Home and business telephone numbers of l
municipal EMCs are kept on file by the counties.
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A.2.a.
A l
l A.2.b.
A l.
A.3.
I The risk county RERP's acknowledge that agreements or understandings have been entered in'.o or are in the process of being developed. No agreements have been l
included in the Chester County RERP, while FEMA has' received letters of agreements with transportation providers from Montgomery County.
Letters of agreement with other support organizations have not been received from Montgomery County. Many' communities have stated that no letters of agreements l
are necessary while others have obtained letters for the establishment of alternate EOCs. Continued attempts should be made to obtain agreements with any organization that might provide assisiance during an-emergency response.
In the case of Berks County, Appendix T-19 does not indicate which school district is being referenced.
A.4 I
Berks County has acknowledged that the County EMA Director is responsible for assuring continuity of resources. No reference to this effect could be located in the Chester or Montgomery County RERPs.
See comment to element A.1.e. concerning 24-hour response at the municipal level.
C.
Emergency Response $upport and Resources C.1.c.
A A complete statement defining the county's role vis-a-vis the. federal response effort is contained in the Berks and Chester County RERPs, Annex Q, Section.II.D.
It is recomended that additional wording be added to
- Section II.E, Annex 0 of the Montgomery County RERP to
- read as follows:
"PEMA is responsible for making the necessary arrangements to support the federal response personnel. Montgomery County.will cooperate with state and federal agencies in planning for and making all necessary support arrangements."
C.2.a.
A It is recomended that the statement that no l_
representative of Montgomery or Chester counties will be sent:to the EOF would be more apprcpriate under the -
l Concept of Operations or Direction and Control. Annexes.
l C.4.
I Annex M to the county plans has replaced the reference to IRAP with FRMAP.
See comment to element A.3. concerning the lack of completed letters of agreement.
D.
Eriergency Classification System E
D.3.
A l
D.4 A
As in the earlie'r drafts of the plans, the counties i
refer to the fact that their County Comissioners can recomend an evacuation.
However, as previously noted l
in the April 27, 1984 RAC review, the possible scurce L
of that recomendation varies from one county RERP to another. The three risk counties should agree on the same organizational sources (s) for protective action recomendations.
- E.
Notification Methods and Procedures E.1.
I Communications capabilities are clearly delinated.in Appen. dix C-1 to the county RERPs.
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The Montgomery County RERP has a " Notification Sequence" (Appendix C-2. Tab 1) and Berks County has-
" Incident Notification Procedures" in Appendix C-8 to its plan. The Berks County approach seems to be the clearest method of. describing the notification process and, in fact, contradicts the Montgomery County flow chart, implying that direct notification to Montgomery County by Limerick will not take place in all circumstances (compare page C-8-3 of the Berks County RERP to Appendix C-2. Tab 1 of the Montgomery County RERP). The Chester County RERP does not contain information regarding the organization (s) responsible for initial notification.
Initial notification, classification changes,
, protective actions and other critical information will be provided to emergency response personnel via telephone, the recall automated dialer system, or pager.
Once again, it is suggested that an abbreviated version of the " Incident Notification Form" be provided to municipalities for their use, E.2.
A For ' consistency purposes, Annex C of the Chester County plan should call for notification of health care facilities, as it does under the Concept of Operations section and Annex G.
E.5.
I The Montgomery County RERP, in Annex D,Section III.E.--
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' continues to state that coordination with PEMA in the L
matter of public information is at tne discretion of the Commissioners, the OEP Coordinator, or their i
designated alternate.
Yet, under the Site Emergency-section of Annex D to the respective RERP, all the g
l plans-state the information releases are to be i
coordinated with the PEMA PIO.
It seems unusual to put a policy ~ statement such as this under a Concept of-Operations section rather than the " Requirements" section. Also the sentence should read, "Information releases or statements are coordinated with the PEMA PIO." Once again it should be emphasized that coordination of information releases giay be critical to providing the, public with accurate information durir.g an emergency. Consistency is necessary in the plan. Both Berks and Montgomery counties have clearly established the officials responsible for activating and monitoring the EBS system. Chester County has-designated the authority responsible for seeing that the EBS system is activated but has not specifically established who is responsible for monitoring the EBS station for accuracy of messages.
Berks County has listed four radio stations which have agreed to monitor the designated ERS station, WHUM.
Hopefully, this will correct the reception problems
evident during the July 25, 1984 and November 20, 1984 REP exercises.
It is recommended that the reference to WC0J in the Berks County "EBS Station Announcement" (Appendix D-6) be. deleted as WCAU is the primary EBS station for Chester County.
All three counties have designated EBS stations th'at are operational 24-hours a day. Once Chester County has installed a remote pickup unit, both telephone and radio will be available for communications between the county EOCs and the designated EBS station.
E.6.
A The utility has installed a public alert system consisting of 166 sirens situated throughout the plume EPZ. The counties can activate the sirens within.
their, jurisdiction on an individual basis, or in their entirety.
The system can report siren activation, failure, power failure, etc. to the counties. The Great Valley School District RERP continues to refer to the telephone alert / notification system rather than the siren system.
' Activation of the entire system will be coordinated by the Pennsylvania Emergency Management Agency.
Route alerting has been developed as a s'upplement.to the public alert system and will be implemented, as necessary, in the event of public alert system failure L
or to alert persons or areas which may not be reached l
by the public alert system. Maps of route _ alert j
sectors are to be included in the final drafts of the L
county and municipal plans, where they are not already available, l
Information on transient locations and route alert-l sector maps should be included in those plans where it i
is not currently available.
Sufficient trained "I
members will be mobilized at the time of the incident to man the-sector teams. Some communities (such as North Coventry Township) state that separate route L
alert personnel will alert the hearing impaired. This does not seem to be reflected in Attachment E, where it appears the designated route alert terms will also notify the hearing impaired.
I Those communities which have not done so (Upper and l
Lower Providence Townships, Montgomery County, Douglass Township, Berks County) should designate-specific fire departments to route alert sectors in their comunities as soon as possible.
The system is designed to meet the standards of Appendix 3 to NUREG-0654
'E.7.
A Consideration should be given to providing more precise geegraphical descriptions of areas such as Pottstown Borough, Montgomery County; Schuylkill
Township, Chester County and-Amity Township, Berks-County when relating sections within those communities
~ to specific evacuation routes in evacuation announcements and/or the emergency information br,ochure.
F.
Emergency Comunications F.1. a. -
I See coment (paragraph 2) to element A.I.e. regarding 24-hour manning of comunication links..It~is once again recomended that an alternate contact at the municipal level be added to the county RERPs.
Responsibilities established for the Communications Group under Annex C (message verification, notifying municipalities concerning siren system failure) should also be included in Annex B.
See 'coment (paragraph 2) to element E.1 regarding.the organization. responsible for notifying the counties at each classification level.
F.1.b.
I Communications capabilities of Berks and Montgomery counties, including inter-county _ communications to other risk and support counties are clearly delineated in Appendix B-1 of the respective county plans. This information was not discernible in the Chester. County plan.
No further refinement of the plans has taken place concerning Montgomery County's role as the Alternate Facility Notification.
There is not a clear statement as to'PEMA's or BRP's position in the communication chain,'if any. Since Berks and Montgomery counties may rely on PEMA or BRP for recommended protective actions, it would appear essential that PEMA and BRP should be involved in any comunication scheme.
~ ~t F.1.c.
A The county RERPs state that all communications with the federal government will be through PEMA.
F.1.d.
A All three county plans contain information regarding the Limerick Generating Station Incident Notification System. The system allows for simulta.neous notification or conferencing ameng the three risk counties, EOF, Limerick Generating Station, PEMA and BRP.
F.1.e.
A Once again, it is emphasized that the Alert /
Notification Concept of Operations for Berks County (pp C-3 and C-4) should be " fleshed out."
As an example, at Alert, RACES personnel are notified and placed on standby status. However, after that point personnel being mobilized, as necessary. This applies
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to cther personnel or 1nstitutions such as decontamiration monitoring teams, reception and mass care centers, host schools, transportation resources,
etc. A similar example in Chester County is where certain ARES personnel are placed on standby at Alert, ~
but never appear to be mobilized, if necessary, at a 1ater classification level.
F.2 A
It is recomended that Chester County add a Notification System Appendix to Annex C as has been done in both the Montgomery and Berks County RERPs, detailing the mode of notification to all applicable parties. Telephone numbers shoulci be included in Appendix 1 to Annex G to the Chester County plan or reference that they are on file in the EOC, as.has been done in the Montgomery County plan.
It is recommended that this be done in Appendix G-7 of the Berks County RERP,.as well.
F.3.
A Testing.information has.been added to Annex B of the Berks County plan, and should be added to the Montgomery County plan, as well.
G.
Public' Education and Information G.I.a.,
A A copy of the " Limerick Generating Station Emergency G.'1. b.,
Information for Berks, Chester and Montgomery G.I.c. and Counties," "What You Should Know About Nuclear Power G.I.d.
Plant Incidents (Emergency Information and Farmers Emergency Information)" has been reviewed and found to be adequate. _ At a press briefing on March 8,1985 it was announced that the public would soon receive this l'
approximately 75,000 homes and businesses.
information. The brochures are being mailed to l
G.2 A
The public information program has been dicussed with PEMA officials and is considered adequate.
G.3.a.
A L
~ G.4.a.
A There still appears to be confusion over whether the county spokesperson will brief the PIO or the PIO will brief the county spokesperson prior to the release of public information during an incident.
G.4.b.
I This issue, raised in the April 27, 1984 Informal RAC l
Review, has not been addressed.
G.4.c.
A l
G.S.
A See comment to element G.2.
H.
Emergency Facilities and Equipment l
H.3.
A All applicable municipalities have designated alternate EOCs although, in several instances, l
agreements need to be finalized with the host
~
institution.
e 2
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H.4 I
Timely activation of the facilities and centers 1
described in the plans is called for but, as noted in the comment to element A.I.e., staffing remains a concern in_certain jurisdictions.
H.7..
A All five counties (3 risk and 2 support) have determined the numbers of survey equipment (including reserves) needed to monitor emergency workers and the general public.
H.10.
x I
The plans continue to call for annual, rather than quarterly, checks of all special RERP radiological exposure control equipment. The Berks County plan now calls for equipment to be calibrated at intervals recommended by the equipment supplier.
H.11 I
Resource lists have been completed by school districts and municipalities and consolidated lists included in the county plans.
Unmet needs still exist in certain-areas of critcal importance, such as bus and ambulance resources.
-The various lists should be cross-referenced against
'one another for accuracy..For example, Douglass Township reports the need for 3 TCP/ACP personnel while Union Township's plan reflects the need for 1 TCP/ACP person. Yet, the Berks County RERP (Appendix Q-9) states that the risk municipalities in Berks County will require 26 individuals for TCP/ACP manning and that all these resources are locally available.
Differences appear in Chester County, as well, most notably'in the area of radiological exposure control t
equipment.- The numbers of kits in East Nantmeal, Uwchlen, West Vincent, Upper Uwchlen and West Pikeland differ to a large extent between the municipal and county plans.
In the case of the latter two s
communities, the numbers reflected in the county plan is less than what is shown in the municipal plans.
Equipment and personnel figures listed in the Chester County Consolidated Resource List are consistently l
lower than those figures obtained from the municipal plans.
In addition, East Pikeland and East Coventry Townships and Phpenixville Borough reflect an unme't need of 11 ambulance personnel. This is not evident in the county list.
1 Numbers in the Montgomery County plan should be
~
checked, as well. Collegeville Borough cites the need for 2 buses and 4 ambulances.
Yet Appendix I-3 to the county plan shows that 6 buses and 0 ambulances will be supplied to Collegeville.
In the same appendix, certain school districts are shown requiring ambulances, but this information does not appear to be reflected in the respective school district plans (see Spring Ford Area School District as an example).
\\
It is suggested that a summary of police services s
personnel and equipment be included in the county plans as has been done wi.t,h the fire services in the Berks and Montgomery County plans. Chester County should include both items in their plan.
H.12.-
A I.
Accident Assessment I.7.
A I.8.
A J..
Protective Response J.2.
A-See comment to this element. in the April 27, 1984.RAC
- review, J.9..
I Alth'ough it is' obvious that improvement has taken place in many areas, the ability to implement protective measures is still-of concern for a couple of reasons.
First, as noted earlier, staffing at several municipalities is' lacking to a significant.
degree. Secondly, some resources, such as buses and ambulances to evacuate certain population groups, and radiological exposure control equipment for emergency workers, have not been obtained in adequate numbers.
J.10.a.
I Maps of planned evacuation routes have not been included in the current county and runicipal RERPs
~
(with the exception of the Berks County plan -
Appendix W-4).
Berks County _ includes a composite map of reception centers, mass care centers and host schools, although it'is basically illegible. Separate maps are developed by Montgomery County for distribution and are available at the EOC. Chester
'i -
County is in the process of _ developing maps depicting reception and mass care centers and host schools.
They are scheduled to be placed in the plan upcn completion, o
All communities except East Nantmeal Township and South Coventry Township have included completed evacuation support maps in their plans.
Evacuation plan maps will be placed in the final draft of the municipal plans.
School district plans still do not contain any type of evacuation map in their plans.
J.10.b.
A Berks and Chester counties have included a population distribution plan map in their plans.
J.10.c.-
.I see comments to element E.5.
+-
m,,__m,--,
r
^.,l J.10.d.
I Plans have been received from the Commonwealth of
-Pennsylvania for the State Correctional Institution, l
Graterford, been reviewed and found to be adequate.
Municipalities have developed lists cf homebound-individuals needing ambulance transportation, based upon a public survey, and have identified institutions where those individuals will be relocated to. The numbers requiring transportation are sumarized in the county plans.-
Annex M to the Montgomery and Chester County plans state that the evacuation time for certain~
institutions (Montgomery County - all risk hospitals and designated nursing homes; Chester County -
Phoenxiville Hospital) are expected to be greater than that for the general population, and thus the staff and medical complement will be provided dosimetry and KI. The plans have not established a clear-cut policy as to hcw this increased evacuation time will effect protective action decisions. Will the designated institutions evacuate or will they shelter?
'No further information has-been provided to the Region
'concerning the issues raised,in the April 27, 1984 RAC review comments on the Pennhurst Center's plan.
The concern regarding this element continues to lie in the resource area.
Significant numbers of ambulances continue to be listed as unmet needs by Montgomery and
,Chester counties.
-J.10.e.
I It is apparent from Appendix M-2 to the Montgomery County RERP that radiological exposure control equipment will be predistributed to risk municipalities and health care facilities.
The number of dosimetry /KI kits has been determined by 3
the three risk counties and included as-an appendix to Annex M.
It is suggested that Chester County differentiate the numbers of equipment needed at specific decontamination mass care centers for the general public as has been done in the Berks and Montgomery county plans.
In Berks County, dosimetry /KI equipment will be distributed to municipalities via County Sheriff's Department staff and vehicles, at the time an Alert is declared. Municipalities are responsible for distribution to user organizations.
FEMA is aware that the necessary dosimetry /KI is in the process of being obtained.
In discussions with PEMA, the Region has been informed that 9,000 DCA-622 l
~
dosimeters (0-20R) have been ordered, with delivery to commence the week of April 1.
It is our understanding that an adequate supply of KI has been obtained and g
that the TLDs are on order.
__,..z.__
J.10.f.
A
'J.10.g.
I The means of evacuation are in the process of being resolved. Berks County reports all bus and ambulance needs have been met.
Letters of agreement are contained in the plan from the various bus companies referenced in Appendix I-1 as providing needed resources.
Chester County is currently identifying an unmet need of 132 buses, approximately 80 of which are needed to evacuate schools in one lift.
No agreements have been provided in the Chester County RERP. An unmet need of 58 ambulances is being referred to PEMA.
Montgomery County's Appendix Q-1 states that all bus needs have been met. However, in the " Transportation Assignments" list, (starting on page I-2-5).
In some instances, the Limerick Assignment / Units exceeds the Units Available for Mobilization (example CMD Services). However, reserves have also been
, considered in the process. Letters of agreement with transportation providers have been provided to FEMA from Montgomery County. The county is also reporting a minimal unmet need of 12 coach buses and 82 ambulances.
Information on Earl and Washington Elementary Schools is not included in all areas of Annex N.
They are not included in Appendices N-1 and N-3.
J.10.h.
I The estimated number of evacuees requiring mass care is consistent between the various county plans, both risk and host.
Internally, however, the Berks County plan appears to be contradictory and confusing. The resident population for the Berks County section of the plume EPZ is said to be 17,089 (page 8).
- Yet, l
further down on the page it states that a plan is required for mass case for approximately 17,400.
If f
this figure refers to the total mass care requirement, it differs with the 18,076 figure also given on that page.
J.10.1 A
A detailed evacu,ation time estimate has been prepared by HMM Associates, under contract to the Philadelphia Electric Company. A complete copy of the evacuation time estimate is maintained on file in the risk counties' EOCs.
m 9
9 w
- - - ~
A J.10.J.
I Access Control Points (ACPs) have been designated in the three county plans.. The updated Montgomery County plan now designates.the responsible agency for manning the various locations, although Appendix K-4 seems to imply that further points are warranted.
In discussions with PEMA, the Region has been made aware that as many as 39 ACPs may only utilize barricades to restrict traffic from the plume EPZ. Continued attempts are being made to obtain the necessary 4
personnel for these points, or failing that, establishing the process for implementing a plan involving barricades only.
J.10.k.
I-Removal of disabled vehicles from evacuation routes will basically be accomplished by services dispatched through the counties, although the Berks County. RERP appears to contradict this approach (along with their municipal plans), stating that municipalities are responsible for providing wreckers and gasoline trucks.
Snow and other debris on evacuation routes will be
, removed by PennDOT and municipalities. The National Guard will provide supplemental support, as necessary.
Roadway clearance resources and fuel resources are either on file in the EOC or listed in the plans (Appendix K), with the exception of Chester County where reference to these facilities was not noted.
The municipal RERPs and county plans should be double-checked for accuracy in regard to the establishment of Traffic Control Points. Differences exist between the municipal and county plans in certain instances (Montgomery County - Skippack Township, Lower Salford Township, Upper Frederick Township, Marlborough Township; Berks County -
Boyertown Borough; Chester County - Phoenixville
'I Borough, South Coventry Township, Spring City Borough, Uwchlan Township).
'J.10.1.-
A A time estimate study has been prepared by HMM Associates under contract to the Philadelphia Electric Conpany. A summary of the results is included in the county plans and.a complete copy of the study is maintained at the county EOCs.
The assumption that was utilized to develop the estimated mobilization time for the risk school districts is contained in Annex N to the Berks County plan. This information should be added to the other risk county plans.
h
f J.12.
I A Mass Care Registration Form has not been included in the Chester County RERP, although the plan does state that the standard "American Red Cross Disaster Shelter i
Registration" form will be utilized.-
A listing of veterinarians, kennels and/or animal shelters have been added to the Chester and Berks counties' plans.
Neither Chester nor Montgomery counties has made monitoring / decontamination team assignments for decontamination sites as has been done in Annex M, Appendix 2 to the Berks County plan. The numbers of-necessary equipment for decontamination mass care centers for the general public is now included in the Montgomery County RERP.
Berks County has called for decontamination monitoring personnel to complete a " Decontamination Monitoring Report Form" for each individual monitored, while Chester and Montgomery counties will-do so only for an
-individual with a reading of 0.05 mR/h or more above
< background. The latter two counties should consider adopting a policy similar to that of Berks County.
Annex L. Appendix 4,Section II.I. of the Chester County plan appears to be in error as it calls for monitoring and decontamination (if necessary) prior to evacuees arrival at mass care centers.
Appendix L-4 of the Montgomery County RERP needs to be updated as presently it is showing mass care cer.ters with a cumulative capacity of 5,700 spaces, while the county has delineated a need for 6,925 spaces.
K.
Radiological Exposure Control p
K.3.a.
I An adequate supply of dosimetry is not currently i
available.
FEMA Region III should be informed when all necessary equipment has been obtained and distributed.
All municipal plans now contain the location of the applicable decontamination station for emergency
}
workers, although in several instances it is noted that agreements are still under development.
K.3.b.
A K.4.
I See coments for this element in the Regional Assistance Committee's April 27, 1984 Informal Evaluation.
_ K.5.a.
A K.5.b.
A L
C s.
_L.
Medica 1'and Public Health Support L.1.
A Berks County has added a istatement to Appendix G-7 to the effect that "each facility has trained, professional staff adequately qualified to treat radiation exposure and deal with contaminated -
individuals." A similar statement should be added to the appropriate appendix of the Montgomery and Chester county plans.
A statement defining the Hospital of the University of Pennsylvania's role in dealing with contaminated individuals (such as is contained in Annex G, Appendix 2 of the Chester County RERP) should be included in' Appendix G-10 of the Montgomery County plan.
Both Montgomery and Berk counties discuss radiological training for emergency medical technicians and the fact that they will-coordinate or encourage participation by appropriate response organizations.
A similar statement needs to be included in Annex R to
,the Chester County plan.
L.4 A
' Montgomery and Chester counties have designated those ambulance companies located within the plume exposure EPZ. Montgomery County also has noted those ambulance -
services located outside the EPZ but serving areas of the EPZ.
. M.
Recovery and Reentry Planning and Post Accident Operations M.1.
A N.
Exercise and Drills N.1.a.
A The Chester and Berks County plans reflect the fact i
that full-participation exercises will take place every two years. Montgomery County's RERP continues to utilize the out-of-date language of full-scale and small-scale exercises.
N.1.b.
A Any reference in the Montgomery County plan to full and small scale exercises should be updated.
N.2.,
A N.2.a.
N.2.c.
I Medical emergency drills are to be held annually.
None of the county plans have adequately addressed this point. Berks County's plan goes so far to state that the medical emergency drill will take place only once every two years.
E
~
N.2.d.
I Radiological monitoring drills are to be conducted annually.
None of.the county plans have adequately addressed this point. Berks County's RERP states that the radiological monitoring drill will take place only once every two years.
N.3.a.
A N.3.b.
A N.3.c.
A
~
N.3.d.
A N.3.e.
A N.3.f.
A 14.4.-
A N.5.
A
~
0.
Radiological Emergency Response Training 0.1.
I While Montgomery and Chester counties will " coordinate and encourage" (in the case of the forner) and
" actively promote and coordinate" (in the case of the latter) the participation of appropriate personnel -in training activities, Berks County merely states it will " encourage" participation.
Berks County should take a stronger role in promoting the training of response personnel, Under the Responsibilities section of the municipal plans it calls for training for all volunteers operating in the emergency management agency of the municipality. Yet the Training section does not appear to go that far, calling only for the local emergency response personnel to be " familiar" with their responsibilities.
0.1.b.
A The three county plans reflect the fact that county sponsored training will be made available to all response organizations, including those departments and organizations which have mutual aid agreements with risk municipality departments and organizations, as deemed appropriate.
The contents of the training program are contained in the risk county RERPs.
.0.4.a.
A The county plans note that training needs are determined on an ongoing basis as part of
~
recruitment / orientation of emergency workers.
Refresher training requirements will be determined at the conclusion of the initial training cycle.
s.,
0.4.c.
A The three county plans call for training in decontaminat{on procedures for appropriate emergency workers. The word " monitoring" has been deleted from Annex R of the Montgomery County plan even though these personnel are referred to as monitoring / decontamination teams.
0.4.d.
A See comment to, element 0.4.a.
0.4.f.-
A See comment to element 0.1.b.
0.4.g.
A See comment to element-0.4.a.
0.4.h.
A See comment to element 0.4.a.
0.4.j.
A See comment to element 0.4.a.
0.5.
I Montgomery County will require initial and refresher training each year.
Chester and Berks counties do not address this issue.
P.
Responsibility for'the Planning Effort:
Development, Periodic Review anc Distribution of Emergency Plans
. P.1.
A i
P.2.
A P.3 A
s P.4 A
The Chester County plan should call for an expanded role of coordination of any plan changes with school districts, special facilities and other counties.
P.S.
A P.6.
A
.i P.7.
A P.8.
A P.10.
A Telephone numbers of critical organizations or individuals will be updated quarterly, according to the Berks and Montgomery County plans. Chester County should make provisions to ensure that the list of municipal EMCs is updated quarterly (Appendix C-5).
aus
~
ADDENDUM TO REGIONAL ASSISTANCE COMMITTEE'S INTERIM FINDINGS ON OFFSITE RADIOLOGICAL EMERGENCY RESPONSE PLANS SITE-SPECIFIC TO THE LIMERICK GENERATING STATION 1.
Radiological ' Exposure Control Will emergency workers be " ordered" to take KI, or is that voluntary upon instruction from the Secretary of Health? KI, if it is to be
-used, should not await completion of tasks before being taken as implied from sequence of steps.
- Potassium Iodide (KI) --- KI is not a radioprotective drug, i.e., it does not " offer protection to the thyroid gland from injury due to accumulation of radiciodine in the thyroid."
It bl6cks the thyroid with stable (non-radioactive) iodine to prevent'the uptake of radioactive iodine in the thyroid.
The CD V-742 dosimeter is essentially useless for decontamination team use.. ; Exposures of SR or less.will not be detectable.with this 0-200 R l
chamber.
.Two.. inches between the probe and the surface being monitored is
- excessive. Further, the readings should be compared with background measurements made with the detector shield open also.
There is no need to send individuals to a hospital for a thyroid reading in excess of 0.1 mR/hr (or residual skin contamination in excess of.0.05 mR/hr). Little can be done/ observed at a hospital at these levels that can't be done by a radiation specialist at the decontamination center. Follow-up for additional monitoring or bicassays might be warranted.
It is important that injuries be treated (whether or not contaminated),
~
to the extent that the patient is stablized prior to movement to a
. medical facility.
The projected thyroid dose commitment level at which the Pa. Dept. of T
Health is to recommend KI to emergency personnel should be stated.
Without such information, consistency with the FDA guidance cannot be evaluated..
2.
Protective Response L
What provisions are made for emergency workers access to ' areas secured by the Access Control Points? Similar considerations need to be made for members of the general public who may be attempting to return home to shelter or'to pick up family members for evacuation.
3.
Recovery and Reentry The plans should recognize that if there was a contaminating release, it may not be desirable to allow reentry into some areas because of residual contamination. Other areas may be re-entered as soon as
~
significant releases have terminated and the piant is stable.
i i
i