ML20127F836

Provides Interim Rept on NRC Request for Assistance in Responding to Concerns Re Adequacy of Offsite Emergency Planning & Preparedness in Dauphin County Portion of TMI Emergency Planning Zone

ML20127F836
Person / Time
Site:	Three Mile Island
Issue date:	10/27/1992
From:	Kwiatkowski D Federal Emergency Management Agency
To:	Congel F Office of Nuclear Reactor Regulation
Shared Package
ML20125A403	List: ML20125A401 ML20125A774 ML20127F836
References
NUDOCS 9211130056
Download: ML20127F836 (3)

Text

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ENCLOSURE u

3 Federal Emergency Management Agency i J Washington, D.C. 20472 OCT 271992 Mr. Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Congel:

In a memorandum dated July 22, 1992, the U.S. Nuclear Regulatory Commission (NRC) requested the Federal Emergency Management Agency's (FEMA) assistance in responding to the concerns expressed in Mr. Robert Gary's July 10, 1992, letter to the Chairman of the NRC regarding the adequacy of offsite emergency planning and preparedness in the Dauphin County portion of the Three Mile Island emergency planning zone. The purpose of this letter is to provide an in+.erim report on the actions which FEMA has taken to date in response to the NRC's request.

On September 4, 1992, FEMA Region III met with representatives of the Pennsylvania Emergency Management Agency (PEMA) and the Dauphin County Emergency Management Agency in order to discuss the issues raised in Mr. Gary's letter. The results of this meeting and follow-up information received by FEMA are summarized below.

o The letters of intent at the Dauphin County Emergency Operations Center were not current. However, in early August, Dauphin County sent out new letters of intent to the county transportation providers for their signature. FEMA reviewed the content of these letters and determined that they did not include pertinent information on the number and capacity of transportation vehicles available. Amended letters requesting the number and capacity of vehicles have been sent to these transportation providers, but the letters have not yet been signed and returned.

o A review of the Dauphin County Radiological Emergency Response Plan (RERP) indicates that all groups (general and special populations) requiring transportation have been identified and are current as of September 1992. However, there are discrepancies between sections of the Dauphin County RERP which are concerned with the number of buses available for general population evacuation. PEMA and Dauphin County are revising the Dauphin County RERP to include more accurate, up-to-date numbers.

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o Both the State and Dauphin County RERPs contain provisions for the deployment of the Pennsylvania National Guard to Dauphin coutly, if necessary, during a radiological emergency. However, FEMA has requested further information regarding (1) the general type and amount of resources which are available to the county through the Pennsylvania National Gue.rd during such an emergency and (2) the extent to which National Guard personnel have been trained and exercised in responding to radiological emergencies.

Although FEMA has initiated the activities necessary to respond to the NRC's request, additional time is required to (1) give the Commonwealth of Pennsylvania and Dauphin County adequate time to complete the activities which have been undertaken to address Mr. Gary's concerns and (2) allow FEMA time to review the plan revisions, signed letters of intent, and other materials provided to ensure that Mr. Gary's concerns have been adequately addressed and alleviated. FEMA will provide its findings and conclusions, including any corrective actions taken, to the NRC by December 31, 1992.

Should you have any questions or require further information, please call Mr. Craig S. Wingo, Chief, Radiological Preparedness Division, at (202) 646-3026.

Sincerely,

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Dennis Kwiatkowsk Assista t Associate Director Office of Technological Hazards

• Mr. Robert Gary cc w/ enclosure:

Michael Ross Francis I. Young 0&M Director, THI-l Senior Resident. Inspector (TMI-1)-

GPU Nuclear Corporation U.S. Nuclear Regulatory Commission Post Office Box 480 Post Office Box 311 Middletown, Pennsylvania 17057 Middletown, Pennsylvania 17057 Michael Laggart Regional Administrator, Region I Manager, Licensing U.S. Nuclear Regulatory Commission GPU Nuclear Corporation 475 Allendale Road 100 Interpace Parkway ring of Prussia, Pennsylvania 19406 Parsippany, New Jersey 07054 Robert B, Borsum  ;

Robert E. Rogan B&W Nuclear Technologies '

THI-Licensing Director Suite 525 GPU Nuclear Corporation 1700 Rockville Pike Post Office Box 480 Rockville, Maryland 20852 Middletown, Pennsylvania 17057 -

Ernest L. Blake, Jr., Esquire William Dornsife, Acting Director Shaw, Pittman, Potts & Trowbridge Bureau of Radiation Protection 2300 N Street, NW. Pennsylvania Department of  ;

Washington, DC 20037 Environmental Resources .

Post Office Box 2063 i Chairman Harrisburg, Pennsylvania 17120 l Board of County Commissioners of Dauphin County Mr. T.- Gary Broughton, Vice President >

Dauphin County' Courthouse and Director - THI-1  :

Harrisburg, Pennsylvania 17120 GPU Nuclear Corporation  !

Post Office Box 480-Chairman Middletown, Pennsylvania 17057  !

Board of Supervisors  ;

of Londonderry Township  !

R.D. #1, Geyers Church Road  :

Middletown, Pennsylvania 17057 t

Mr. Dennis H. Kwiatkowski Federal Emergency Management Agency 500 C Street, SW Washington, DC 20472 l

Mr. Paul P..Giardano, Director Region III  :

Federal Emergency Management Agency '

Liberty Square Building .

105' South Seventh Street Philadelphia, Pennsylvania 19106-3316 Mr. Joseph LaFluer, Director l Pennsylvania Emergency Management Agency Transportation & Safety Building,.Rm. B151 ,

. Forster & Commonwealth Avenues  :

Harrisburg, Pennsylvania 17120 l

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o,, g . August 5, 1992 Docket No. 50-320 Mr. Robert Gary Pennsylvania Institute for Clean Air P.O. Box 1637 Harrisburg, Pennsylvania 17105-1637 i

Dear Mr. Gary:

I am writing to acknowledge receiving your letter of July 10, 1992, on behalf of the Pennsylvania Institute for Clean Air, and addressed to Chairman Selin, requesting that the U.S. Nuclear Regulatory Commission (NRC) take action with regard to the GPU Nuclear Corporation, licenseo for the Three Mile Island-Nuclear Station, Unit 1 (TMI-1). The Petitioner requests that the Federal Emergency Management Agency (FEMA), as soon as possible (preferably within 5 working days), examine certain transportation-related discreaancies alleged by Mr. Gary in the Dauphin County Emergency Evacuation Plan. T1e petitioner also i requests that, once the discrepancies are verified by FEMA, the NRC order GPU i Nuclear Corporation to " power down" the THI-l plant and not permit the plant to generate commercial power until the discrepancies are corrected and until a valid, workable, operational emergency evacuation plan is ]roduced.

Petitioner asserts, as bases for these requests, that in tie event of a i radiological emergency, the Dauphin County Emergency Evacuation Plan could not operate because:

(1) letters of intent from private transportation companies were not on -l file at the Pennsylvania Emergency Management Agency (PEMA) headquarters or at the Dauphin County Emergency Operations Center in Harrisburg as  ;

represented by Chief Counsel, except for a single letter of 1985 from Capital Area Transit that cited as the sole source of payment a statute since repealed and superseded; (2) the Radiological Emergency Response Plan (RERP) maintained at the l Dauphin County Emergency Operations Center accounted for 450 buses, l 70 with Capital Area Transit, aid 320 with Capital Trailways Penn l Central Station, and executives at Capital Area Transit and Trailways  !

Penn Central listed by the RERP had left-the companies in 1984 and 1987, respectively; (3) no "after hours" telephone numbers were listed in the RERP for use in i the event of a radiological emergency; (4) the Dauphin County Emergency Operations Center staff states that they have no authority to request military vehicles from the National Guard, Mechanicsburg, or Indiantown Gap, although PEMA does; l

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Mr. Robert Gary August 5, 1992 (5) PEMA states that its responsibility lies only in communications and coordiaation and not in the use of military vthicles, and PEMA has no

, plan to call for the use of military vehicles; (6) the Dauphin County Plan contains no reference to the use of military vehicles because the county believes that the State has exclusive jurisdiction in that area; (7) despite actes of trucks within 15 miles of Harrisburg, neither the State nor the county written plans refer to any use of such vehicles; and (8) permission to operate nuclear reactors at Three Mile Island is premised on the existence and continued maintenance of an operational radiological emergency evacuation plan for Dauphin County.

On July 22, 1992, the LRC staff requested assistance from FEMA and gave it a copy of your request to examine the discrepancies you allege in the Dauphin County Emergency Evacuation Plan. This would have been the NRC's normal course of action, even if you had not specifically requested it.

To address your verbal telephone request to Ms. Jenny Longo on July 22, 1992, the NRC staff will give you a copy of any response to your Petition by GPU Nuclear Corporation.

Your Petition has been referred to my staff for action in accordance with 10 CFR 2.206. As provided by 10 CFR 2.206, the U.S. Nuclear Regulatory Commission will take appropriate action on your request within a reasonable time. I have enclosed a copy of the notice that is being filed with the Office of the Federal Register for publication.

Sinc? rely, Orig.inal si6ned :y Thocm83entriey Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

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. Mr. Robert Gary cc w/ enclosure:

Michael Ross Francis I. Young OM1 Director, THI-1 Senior Resident Inspector (TMI-1)

GPU Nuclear Corporation U.S. Nuclear Regulatory Comission Post Office Box 480 Post Office Box 311 Middletown, Pennsylvania 17057 Middletown, Pennsylvania 17057 Michael Laggart Regional Administrator, Region I Manager, Licensing U.S. Nuclear Regulatory Comission GPU Nuclear Corporation 475 Allendale Road 100 Interpace Parkway King of Prussia, Pennsylvania 19406 Parsippany, New Jersey 07054 Robert B. Borsum Robert E. Rogan B&W Nuclear Technologies THI Licensing Director Suite 525 GPU Nuclear Corporation 1700 Rockville Pike Post Office Box 480 Rockville, Maryland 20852 Middletown, Pennsylvania 17057 Ernet L. Blake, Jr., Esquire William Dornsife, Acting Director Shaw, Pittman, Potts & Trowbridgs Bureau of Radiation Protection 2300 N Street, NW. Pennsylvania Department of Washington, DC 20037 Environmental Resources Post Office Box 2063 Chairman Harrisburg, Pennsylvania 17120 Board of County Commissioners of Dauphin County Mr. T. Gary Brotshton, Vice President Dauphin County Courthouse and Director - THI-l Harrisburg, Pennsylvania 17120 GPU Nuclear Corporation Post Office Box 480 Chairman Middletown, Pennsylvania 17057 Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, Pennsylvania 17057 Mr. Dennis H. Kwiatkowski Fedaral Emergency Management Agency 500 C Street, SW Washington, DC 20472 Mr. Paul P. Giardano, Director Region III Federal Emergency Management Agency Liberty Square Building 105 South Seventh Street

Philadelphia, Pennsylvania 19106-3316 l Mr. Joseph LaFluer, Director Pennsylvania Emergency Management Agency l Transportation & Safety Building, Rm. B151 l Forster & Comonwealth Avenues Harrisburg, Pennsylvania 17120

J 7590-01 U.S. NUCLEAR REGULATORY COPNISSION DOCKET NO. D-289 GPU NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 1 LICENSE NO. OPR-50 RECEIPT OF PETITION FOR DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby given that by Petition dated July 10, 1992, Mr. Robert Gary, on behalf of the Pennsylvania Institute for Clean Air (Petitioner), requested that the U.S. Nuclear Regulatory Commission (NRC) take action regarding the GPU Nuclear Corporation, licensee of the Three Mile Island Nuclear Station, Unit 1. Petitioner requests that as soon as possible (preferably within 5 werking days) (1) the Federal Emergency Management Agency (FEMA) examine certain transportation-related discrepancies alleged by Mr. Gary in the Dauphin County Emergency Evacuation Plan and (2) the NRC order the licensee to " power down" the plant and not permit the plant to generate power until the discrepancies are corrected, and until a valid, workable, operational emergency evacuation plan is produced.

Petitioner asserts, as bases for these requests that, in the event of a radiological ecargency, the Dauphin County Emergency Evacuation Plan could not operate because: (1) letters of intent from private transportation companies were not on file at Pennsylvania Emergency Management Agency (PEMA) headquarters or the Emergency Operations Center of Dauphin County, in Harrisburg, as represented by Chief Counsel, except for a single letter of.

1985 from Capital Area Transit, which cited as the sole source of payment a statute since repealed and superseded; (2) the Radiological Emergency l l

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Response Plan (RERP) maintained at the Dauphin County Emergency Operations Center accounted for 450 buses, 70 with Capital Area Transit, and 320 with Capital Trailways-Penn Central Station and executives at Capital Area Transit.

and Trailways Penn Central listed by the RERP had left-the companies in 1984 and 1987, respectively; (3) no "after hours" telephone numbers were listed in the RERP for use in the event of a radiological emergency; (4) the Dauphin County Emergency Operations Center staff-states that'they have no authority to request military vehicles from the National Guard,'Mechanicsburg, or Indiantown Gap, although PEMA does; (5) PEMA states that its responsibility lies only in comunications and coordination and not in _the use of military vehicles, and PEMA has no plan to call for the use of military vehicles; (6)-

the Dauphin County Plan contains no reference = to the use of military vehicles because the county believes that the State has exclusive jurisdiction in that area; (7) despite-acres of trucks'within 15 miles of Harrisburg, neither the

( State nor the County written plans refer to any use of such vehicles; and (8)^

L permission to operate nuclear reactors'at Three Mile Island is premised on the existence and continued maintenance of an operational radiological emergency evacuation plan for Dauphin County.

The Petition has been referred to the Director of the Office of Nuclear-Reactor Regulation pursuant to 10 CFR 2.206. As provided by Section 2.206, appropriate action will be taken on the specific issues raised by the petition in a reasonable time.

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A copy of the Petition is available for inspection at the Cornission's Public Document Room at 2120 L Street, NW., Washington, DC 20555, and at the Local Public Document Room for the Three Mile Island facility located at the Government Publications Section, Stcte Library of Pennsylvania, Walnut Street and Commonwealth Avenue, Box 1601, Harrisburg, Pennsylvania 17105.

FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 5th day of August 1992

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Federal Emergency Management Agency Washington, D.C. 20472 (LT ?T E Mr. Frank J. Congel, Director Division of Radiation Protection t

and Emergency Preparedness of fice of' Nuclear Reactor Replation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Congelt,

In a namorandum dated July 22,.1992, the U.S. Nuclear Regulatory Commission (NRC) requested the FederGl' Emergency Management.

Agency's (FEMA) assistance in responding to the concerne- '

' expressed in Mr. Robert Gary's Ju?.y 10, 1992, letter to the Chairman of-the NRC regarding the adequacy of offsite emergency planning and preparedness in the Dauphin County portion of the Three Mile Island emergency planning sone. The purpose of this, letter is to provide-an interim report on the actions which FENA e has taken to date in response to the NRC's request. .

l On Septemba- 4, 1992, FEMA Region III met with representatives of the Ptnns) .nia Emergency Management Agency (PEMA)'and the Dauph!r. C6'.sy Emergency Management Agency in order to discuss the issues raised in Mr. Gary's letter. The results of this meeting below. and follow-up information received by FEMA are summarised i

o The letters of intent at the Dauphin County Emergency. '

operations Center were not current. However, in early i

August, Dauphin County sent out new letters of intent-to the 1 county transportation providers for their. signature. . FENA  :

reviewed the content of these letters and determined'that-  :

they did not include pertinent information on the number and capacity of transportation vehicles available. Amended 1 letters requesting the number and capacity of vehicles have been sent to these transportation providers,-but.the letters-  !

havs not yet been signed and returned.  !

o A review of-the Dauphin County Radiological Emergency i Response Plan.(RERP) indicates that all groups special populations) requiring transportation na(general and  !

identified and are current as of. September 1992. ve-been However,

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there are discrepancies'between sections of the Dauphin i County RERP which are-concerned with the number of buses available for general population-evacuation. PEMA and L Dauphin County are revising the Dauphin County RERP to j include more accurate, up-to-date numbers. i

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!- Both the state and Dauphin County RERPs contain provisions for the deployment of the Panasylvania National Guasi to Dauphin emergency.County,'if-necessary, during a radiological However FEMA has requested further information regarding (1) the ge,neral type and amount of resources which are available-to the county through the Penns

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i National Guard during such an emergency and (ylvania- 2) the and extent to which National cuard personnel have been trained exercised in responding to radiological emergencies.

. Although FEMA has initiated the activities necessary to respond to the NRC's request, additional time is required to (1) give the I consonwealth of Pennsylvania and Dauphin County adequate time-to complete the activities which have been undertaken to address i Mr. Gary's concerns and (2) allow FENA time to review the plan  !

revisions, signed letters of intent, and other materials provided-  !

to ensure and that Mr. Cary's concerns have been adequately addressed a11 evicted. FEMA will provide its findings and conclusions including 31, 1992. any corrective actions taken, to the NRC by Deceaber ,

Should you have any questions or require further information, please Division,call atMr.

(202)Craig S. Wingo, Chief, Radiological Preparedness 646-3026.

Sincerely, Dennis W[ Kwiatkows Assistan Associate irector Office of Technological Hazards

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