ML20129A227
| ML20129A227 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/10/1985 |
| From: | Kantor F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20129A204 | List: |
| References | |
| OL, NUDOCS 8507150247 | |
| Download: ML20129A227 (11) | |
Text
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
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PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352
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50-353 (Limerick Generating Station.
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Units 1 and 2)
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AFFIDAVIT OF FALK KANTOR, SECTION CHIEF, EMERGENCY PREPARECNESS BRANCH, DIVISION OF EMERGENCY PREPAREDNESS AND ENGINEERING RESPONSE, ADDRESSING APPLICANT'S MOTION FOR AN EXEMPTION FROM 10 C.F.R. PART 50 APPENDIX E, SECTION IV.F.1.
In a motion submitted to the Commission, dated June 24, 1985, the Ap p'.
. requested an exemption from the requirement of 10 C.F.R. 50, Appendix E Section IV.F.1, for the conduct of a full participation emer-gency preparedness exercise within one year before the issuance of a full power operating license. The applicable provision of Section IV.F provides that:
1.
A full participation exercise which tests as much of the licensee, State and local emergency plans as is reason-ably achievable without mandatory public participation shall be conducted for each site at which a power reac-tor is located for which the first operating license for that site is issued after July 13, 1982. This exercise shall be conducted within 1 year before the issuance of the first operating license for full-power and prior to operation above 5% of rated power of the first reactor, o
and shall include participation by each State and local government within the plume exposure pathway EPZ and each State within the ingestion exposure pathway EPZ.
Consistent with other Connission emergency planning regulations (see 10 C.F.R. 50.47 and the Statement of Considerations, 47 FR 30232 dated July 13, 1982), the objective of Section IV.F is to assure that an ade-quate state of emergency preparedness is demonstrated through the conduct 8507150247 850711 PDR ADOCK 05000352 0
- of an emergency plan exercise within one year before a nuclear plant is authorized to exceed'5% of rated power.
A full participation exercise involving the testing of Applicant, State and local emergency plans for Limerick was conducted on July 25, 1984 in expectation that a full power operating license would be issued within one year.
The offsite portion of the July 25, 1984 exercise was observed and evaluated by the Federal Emergency Management Agency (FEMA) and representa-tives of the member agencies of the FEMA Region III Regional Assistance Committee.
FEMA provided its report of the exercise on September 25, 1984.
In this report FEMA identified five " Category A" deficiencies. Category A deficiencies are defined as deficiencies of the type that would cause a finding that offsite emergency preparedness was not adequate to provide reasonable assurance that appropriate protective measures can be taken to protect the health and safety of the public in the vicinity of the plant in the event of a radiological emergency.
Since the initial exercise, a supplemental and several remedial exer-cises have been conducted to demonstrate correction of the Category A defi-ciencies. A supplemental exercise was conducted on November 20, 1984 for thuse municipalities and one support county which did not participate in the July 25, 1984 exercise.
In a report to the NRC dated January 10, 1985, a
FEMA found that all participants in the exercise demonstrated their capa-bility to respond to a radiological emergency. The non-participation of one municipality, however, was identified by FEMA as a Category A deficiency.
A remedial exercise to demonstrate the capability to implement the Graterford prison emergency plan was conducted on March 7, 1985.
FEMA informed the NRC in a memorandum dated March 27, 1985 that the exercise adequately demonstrated an understanding of the emergency response proce-dures and the ability to implement them, and that a portion of one of the Category A deficiencies identified in the July 25, 1984 exercise had thus been corrected.
On April 10, 1985, a remedial exercise was conducted to allow partici-pation by the school districts and South Coventry Township, the or.e munici-pality which did not participate in the earlier exercise. A final remedial exercise was conducted on April 22, 1985 to demonstrate the adequacy of the alert and notification capabilities of the various jurisdictions in the area within approximately ten miles of Limerick.
In a memorandum dated May 21, 1985, FEMA transmitted the exercise evaluation reports for the April 10 and 22, 1985 remedial exercises and provided its final interim finding on offsite planning and preparedness.
FE!!A stated that as result of the July 25, 1984 full participation exer-cise, the November 20. 1984 supplemental exercise, the March 7, April 10 and April 22, 1985 remedial exercises, all Category A preparedness defi-ciencies have been corrected.
FEMA concluded that offsite radiological emergency planning and preparedness is now adequate to provide reasonable o
assurance that protective measures can be implemented to protect the public health and safety in the event of a radiological emergency at the Limerick t'
Generating Station. " Category B" deficiencies (i.e., deficiencies of a lesser significance) identified by FEMA during the July 25, 1984 exercise are being addressed by the Comonwealth and local planning agencies.
. Based on a review of the FEMA findings and determinations on the.ade-quacy of state and local emergency plans and preparedness, and on the NRC assessment of the adequacy of the licensee's onsite emergency plans and preparedness, the NRC staff has concludeo that the overall state of onsite and offsite emergency preparedness provides reasonable assurance that ade-quate protective measures can and will be taken in the event of a radiolog-ical emergency at the Limerick Generating Station.
Since the July 1984 full participation exercise, the Commonwealth of Pennsylvania has participated in a full participation exercise at the Susquehanna facility on May 1, 1985 and is scheduled for another full par-ticipation exercise at the Three Mile Island facility in November 1985.
In addition, the Commor. wealth participated cn a partial basis at the Peach Bottom exercise on October 17, 1984 and is scheduled to participate on a partial basis at the Beaver Valley exercise in September 1985. The Connon-wealth is then scheduled to participate in the next full participation exercise for the Limerick facility in April 1986.
FEMA has advised the Staff that revising the exercise schedule to accomniodate a full participa-tion exercise at Limerick would be extremely difficult due to the Common-wealth's establisheo schedule (which has been coordinated with FEMA, the utilities, other States and the NRC) and the large number of local response crganizations involved. NRC Region I has also confirmed the difficulty of rescheduling an exercise for Limerick.
The capability of local response organizations has been satisfactorily demonstrated through participation in the July 25, 1984 exercise and the subsequent supplemental and remedial exercises conducted between November 20, 1984 and April 22, 1985, as indicated above. The Applicant also notes in its motion that Chester County, one of the three counties in the plume exposure Emergency Planning Zone (EPZ), participated in the Octo-ber 1984 exercise for the Peach Bottom facility and that Berks County, another county within the EPZ, will participate in the Three Mile Island exercise.
The Applicant has assisted in the development and maintenance of local response capability, as indicated in the applicant's motion, by making available planning and traffic engineering consultants to assist offsite authorities in the development of emergency plans and evacuation time esti-mates. The Applicant has also provided an extensive amount of training for local emergency response personnel (approximately 8,500 persons in over 500 training sessions through June 21,1985) including school administrators and staff, emergency workers such as police, fire and ambulance personnel, emergency operations center staff, and radiation monitoring personnel. The Applicant states that extensive physical resources requested by offsite authorities have also been provided in order to upgrade the preparedness of counties, municipalities and school districts within the plume exposure EPZ.
In addition, the Applicant has provided monitoring, security and communications equipment and training assistance for the Graterford insti-tution. The Applicant has also agreed to fund the procurement of 10,000 o
thermoluminescent dosimeters and 1,000 self-reading dosimeters for offsite emergency response personnel.
A second exercise of the Applicant's emergency plan was conducted on April 3, 1985. No significant deficiencies were identified by the NRC observation team in this exercise, which was an onsite exercise only (See inspection Report No. 50-352/85-17 dated May 31,1985). The Staff concluded that, within the scope and limitations of the scenario, the Applicant's performance demonstrated that it could adequately implement its emergency plan and procedures.
The Applicant has provided information in its motion on its ongoing program to maintain and demonstrate emergency preparedness prior to the scheduled exercise for April 1986. This effort will include monthly commu-nication drills with the State and local agencies; a plant environmental and radiological monitoring drill involving field monitoring and analysis activities; a health physics drill involving response to, and analysis of, simulated elevated airborne and liquid samples, and direct radiation mea-surements in the environn.ent; and practice exercises for emergency organ-ization personnel using the Limerick emergency response facilities.
Based on a review of the Applicant's exemption request, the Staff finds that the following factors support the granting of the requested exemption:
1.
The conduct of a full participation emergency prepared-ness exercise on July 25, 1984 together with supplemental and remedial exercises through the period November 20, 1984 to April 22, 1985 leading to a favorable FEMA finding on uffsite preparedness on May 21, 1985.
o 2.
The participation of the Comonwealth of Pennsylvania in a full participation exercise at Susquehanna in May 1985 and the scheduled participation at Three Mile Island in November 1985. The Conrnonwealth also partially participated at the Peach Bottom exercise in October 1984 and is scheduled to partially participate at the Beaver Valley exercise in Sep-tember 1985.
3.
The participation of local response organizations in the full participation exercise for Limerick and subsequent sup-plemental and remedial exercises plus the involvement of these organizations, with the assistance of the Applicant, in an ongoing training and development program.
4.
The conduct of an onsite emergency preparedness exercise in April 1985 and the scheduling of various drills testing elements of the Limerick emergency plan, some of which in-volve offsite response agencies.
This assessment is based on the staff's expe:tation that the appli-cant will be authorized to operate at levels above 5% rated power prior to conducting another full participation exercise currently scheduled for April 1986.
Therefore, the conclusions of this assessment are only valid until April 1986.
(
(_
-,~M Falk Kantor n
Subscribed and sworn to before me this loth day of July,1985.
e
-u./a h.)
Mt o &
Notary Public
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My coninission expires:
July 1, 1986
PROFESSIONAL QUALIFICATIONS OF FALK KANTOR EMERGENCY PRE /AREDNESS BRANCH DIVISION OF EMERGENCY PREPAREDNESS AND ENGINEERING RESPONSE OFFICE OF INSPECTION AND ENFORCEMENT I am employed as a Section Chief in the Emergency Preparedness Branch, Division of Emergency Preparedness and Engineering Response, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission.
I am responsible for coordi-nating and providing technical supervision for the Section's efforts in reviewing and evaluating radiological emergency plans submitted by reactor applicants and licensees to assure proposed plans meet the regulatory requirements and guidance of the Commission.
I also function as a team leader and team member on emergency preparedness teams engaged in the onsite inspections of the implementation phase of licensee emergency programs.
I observe nuclear power plant emergency drills and exercises involving state and local government response agencies and parti-cipate in. interagency critiques.
I received a BS degree in Industrial Engineering in 1958 from the Pennsylvania State University. Upon graduation I entered the U.S. Air Force where I attended the Basic Meteorology Program at St. Louis University in St. Louis, Missouri.
Following the completion of this program in 1959, I served as a weather officer in the U.S. Air Force.
In 1963, I began employment with the Westinghouse Electric Corporation at the Eettis Atomic Power Laboratory in Pittsburgh, Pennsylvania. My duties included the design of radiation shielding for nuclear power reactors for both landbased and shipboard applicants.
I participated in field tests at Federal reactor facilities to evaluate the effectiveness of shield design features on operating reactors.
I entered graduate school in 1967 at the University of Pittsburgh on a U.S. Public Health Scrvice Fellcwship and received a MS degree in 1968 in Radiation Health (HealthPhysics).
Following graduation I was employed by the NUS Corporation in Rockville, N ryland, an engineering and environmental consulting organiza-tion.
I have been a member of the NRC (AEC) Staff since January 1973.
From that time until June 1980 I held the position of Site Analyst in the Accident Analysis
^
Branch. My duties included the review and evaluation of the radiological con-sequences of postulated design basis accidents, the effectiveness of proposed engineered safety features, the population density and growth characteristics in the site environs, and the possible adverse effects on plant safety of nearby industrial, transportation and military facilities.
From Septenber 1980 until March 1981 I was a member of the NRC's onsite technical support section at the Three Mile Island facility.
I have participated in the detailed review of over i
thirty nuclear power plant sites with the primary objective being to ensure public health and safety through the application of Coninission regulatory 1
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requiren.ents and guidance on reactor siting.
I have presented testimony on siting and emergency preparedness issues at public hearings on licensing of nuclear facilities and appeared before the Advisory Committee on Reactor Safeguards.
In addition to my formal education, I have attended training courses sponsored by the NRC on reactor systems and operation and emergency preparedness.
In May of 1979 I attended the course titled " Planning for Nuclear Emergencies" at Harvard University and in September 1980 I participated in the Radiological Emergency Response Operations Training course at the Nevada Test Site.
I am a professional member of the Health Physics Society and the American Meteorological Society.
I am a member of the Air i:ational Guard and hold a current certification from the U.S. Air Force as a weather forecaster.
o e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION o
BEFORE THE COMMISSION s
In the Matter of
)
QEdED PHILADELPHI. ELECTRIC COMPANY Docket Nos. 50-352
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50-353 a83 JJ* 12 All 52 (Limerick Generating Station.
)
Units 1 and 2)
)
grr'CE Or SECRt TA -
00CXLi'NG 4 SERWU.
OR CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO APPLICANT'S MOTION FOR AN EXEMPTION FROM 10 C.F.R. PART 50, APPENDIX E SECTION IV.F.1" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this lith day of July,1985:
San.uel J. Chilk Herzel H. E. Plaine, Esq.
Office of the Secretary General Counsel U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, D.C.
20555*
U.S. Nuclear Regulatory Commission Washington, D.C.
20555*
HelenF.Hoyt, Chairperson (2)
Mr. Edward G. Bauer, Jr.
Administrative Judge Vice President & General Counsel Atomic Safety and Licensing Board Panel Philadelphia Electric Company U.S. Nuclear Regulatory Commission 2301 Market Street Washington, D.C.
20555*
Philadelphia, PA 19101 Dr. Richard F. Cole Troy B. Conner, Jr., Esq.
Administrative Judge Mark J. Wetterhahn, Esq.
Atomic Safety und Licensing Board Panel Conner and Wetterhahn U.S. Nuclear Regulatory Commission 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20555*
Washington, D.C.
20006 o
Dr. Jerry Harbour Mr. Marvin I. Lewis Administrative Judge 6504 Bradford Terrace Atomic Safety and Licensing Board Panel Philadelphia, PA 19149 U.S. Nuclear Regulatory Commission Washington, D.C.
20555*
Joseph H. White, III 15 Ardmore Avenue Mr. Frank R. Romano Ardmore, PA 19003 Air and Water Pollution Patrol 61 Forest Avenue Ambler, PA 19002 Kathryn S. Lewis, Esq.
1500 Municipal Services Blog.
Ms. Phyllis Zitzer, President 15th and JFK Blvd.
Ms. Maureen Mulligan Philadelphia, PA 19107 Linierick Ecology Action 762 Queen Street Pottstown, PA 194C4 L.
- Thomas Gerusky, Director Zori G. Ferkin Bureau of Radiation Protection Governor's Energy Council Dept. of Environmental Resources P.O. Box 8010 5th Floor, Fulton Bank Building 1625 N. Front Street Third and Locust Streets Harrisburg, PA 17105 Harrisburg, PA 17120 Spence W. Perry, Esq.
Director Associate General Counsel Pennsylvania Emergency Management Federal Emergency Management Agency Agency Room 840 Basement Transportation & Safety 500 C Street, S.W.
Euilding Washington, D.C.
20472 Harrisburg, PA 17120 Robert J. Sogarman, Esq.
Robert L. Anthony Sugarman, Denworth & Hellegers Friends ~of the Earth of the 16th Floor Center Plaza Delaware Valley 101 North Broad Street 103 Vernon Lane, Box 186 Philadelphia, PA 19107 Moylan, PA 19065 James Wiggins Angus R. Love, Esq.
Senior Resident Inspector Montgomery County Legal Aid U.S. Nuclear Regulatory Commission 107 East Main Street P.O. Box 47 Norristown, PA 19401 Sanatoga, PA 19464 Charles W. Elliott, Esq.
Atomic Safety and Licensing Brose & Poswistilo Board Panel 325 N. 10 Street U.S. Nuclear Regulatory Commission Easton, PA 1PO42 Washington, D.C.
20555*
Atomic Safety and Licensing Appeal David Wersan Board Panel (8)
Consumer Advocate U.S. Nuclear Regulatory Commission Office of Attorney General Washington, D.C.
20555*
1425 Strawberry Square Harrisburg, PA 17120 Cocketing and Service Section Office of the Secretary Jay Gutierrez U.S. Nuclear Regulatory Commission Regional Counsel Washington, D.C.
20555*
USNRC, Region I 631 Park Avenue Gregory Minor g
King of Prussia, PA 19406
.MHB Technical Associates 1723 Hamilton Avenue Steven P. Hershey, Esq.
San Jose, CA 95125 l
Comunity Legal Services, Inc.
l 5219 Chestnut Street Timothy R. S. Campbell, Director Philadelphia, PA 19139 Department of Emergency Services 14 East Biddle Street West Chester, PA 19380 b
et Y. hpS Stephen H. Lewis Deputy Assistant Chief Hearing Counsel I