ML20203P806

Applicant Exhibit A-E-98,consisting of 840816 Response to Concerns Expressed in Re Draft 5 of Proposed Radiological Emergency Response Plan Submitted to Shippack Township,Pa by Energy Consultants,Inc

ML20203P806
Person / Time
Site:	Limerick
Issue date:	01/17/1985
From:	Patten J PENNSYLVANIA, COMMONWEALTH OF
To:	Boroff A BOROFF, HARRIS & HELLER
References
OL-A-E-098, OL-A-E-98, NUDOCS 8605080186
Download: ML20203P806 (4)

Text

" .

- &M O '- g- Sculul- 599 wwce'L 7/sr  %

I* '

PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY _

o N P.O. sox 3324 s ,

HARA155URG, PINN5YLVANIA 171ll$ $

August 16, 1984 fYq &V "

[

~ A Mr. Alan E. Boroff g91 Q Boroff, Harris & Heller ( '

3 g 650 Blue Bell West - Suite 320 V Blue Bell, Pennsylvania 19422 g -Q v

Dear Mr. Boroff:

In response to your June 22, 1984 letter regarding the proposed radiological emergency response plan submitted to Skippack Township by Energy Consultants, I first wish to assure you that the delay in acknowledging the letter has not been due to a lack of concern for the issues that have been raised.

The concerns you have expressed on behalf of the Board of Supervisors about Draft 5 of the proposed plan are certainly real and indeed should be resolved before the plan is adopted by Skippack Township. .

The real issue, however, is how this can best be accomplished. It obviously will require coordination between the Township and Montgomery County, as well as with the Co=monwealth. Perhaps the following discussion of the specific concerns will be help ful.

1. Personnel staffing to provide a 24-hour response is a problem that every municipality must face at the local level if it is to meet any emergency that might arise, and not only in the event of an accident at the Limerick Generating St'ation. Few, if any, municipalities have a paid staff large enough to provide such personnel and they must rely upon volunteers for augeentation.

A determination needs to be made by the Township as to __

how many individuals are really needed to can an emergency operations center for a municipality the size of Skippack. Using 12 rather than 8-hour shifts can often ease the problem. The fact that Skippack does not have a police force is indeed a problem but can it perhaps be solved by an agreement with whomever is charged with providing such service under normal conditions? If this is not possible, is it feasible to utilize some type of auxiliary police? The unwilling-ness of the volunteer Skippack Fire Company to participate in the event of a radiological emergency is unusual and a position not previously encountered as plans were developed by municipalities around the other four nuclear power plants within the Coc=onwealth. Aside from their normal functions, the additional task usually assigned to a fire company during a radiological emergency is to 8605000186 850117

($&,[-%

PDR ADOCh 05000352 O PDR )(

W- - - - _ -~- - - . . _

s t

j

• b o 4 ,a 1

\ -

,l j, I- a .

41' '

e!.3 "I g. l I ll y a = '11 I%

.il h U 8 5d E%4 l,h lH O 'il '

j

. ;g h 'lf

! .5I

b l

,1. \

1 Mr. Alan E. Boroff I August 16, 1984 Page Two l

provide route alerting in the event the sirens should fail, or in areas where they cannot be heard. If the fire company is ada ant in its refusal to participate s perhaps an agreement could be reached with a neighboring company. What has been presented here are but possibilities or suggestions since the concerns expressed regarding the availability of personnel can only be solved at the local level in consultation with the county emergency management agency. ,

2. Transit-dependent individuals would be alerted and notified through sounding of the sirens and ounty announce-ments over the Emergency Broadcast System. *iince the Township does not have the transportation r.ssets needed for evacuation of these individuals, Montgv=ery County should be advised in writing of the nu=ber of buses, and a=bulances if necessary, that would be required. If the County cannot arrange for the needed transportation then the shortages are reported by the County to the Pennsylvania E=ergency Management Agency (PEMA) and arrangements would be made with the Pennsylvania Depart =ent of Transportation to obtain the buses.

3. The exact nature of the concern regarding . evacuation routes through Skippack and the relationship of the Township to other municipalities that would be evacuating through Skippack is not clear. The concern as to the impact the evacuation of the State Correctional Institution Graterford would have on Skippack is certainly valid. We are still working on resolution of the problen and expect to be able to provide definitive information to the Skippack ~

Board of Supervisors the first part of September. As I am sure you will understand, identification of the evacuation routes for Craterford is a sensitive subject and not one that can, or should be, discussed in open forum.

4. Some of the dosicetry required by Skippack has already been issued from PEMA's stock to Montgomery County. PEMA has recently signed an agreement with Philadelphia Electric Company whereby the latter will fund our purchase of additional dosimetry for county and municipal emergency workers that would be involved in the event of an accident at the plant. The dosimetry will be ordered as soon as the required legal and biddi(k procedures have been completed.

It is difficult to respond ed the Township's lack of means to obtain other equip =ent without knowing specifically what is involved. As centioned previously, essential equip-ment shortfalls should be reported in writing to Montgomery

e. .. .

6 4 Mr. Alan E. Boroff August 16, 1984 Page Three County. If the County cannot fill the requirements then they are reported as unmet needs to PEMA and we will take whatever action is necessary. Neither ,

Montgomery County nor ?EMA can do anything without a specific list of essential equipment needed to respond effectively to an accident.

5. Here again it is difficult to determine what =atters the Skippack Board of Supervisors believe need = ore coordination.

The capacity of roads in the area was deter =ined by traffic engineers from the Pennsylvania Department of Transportation and from this the main evacuation routes were determined in consultation with the counties. Since the counties and municipalities are core keenly aware of their own circum-stances, designation ci secondary routes leading to the .

main evacuation routes was left to them. PEMA stands ready to provide specific coordination whenever it is needed and requested. To be effective, bovaver, it should .

progress from Skippack Township to Montgomery County and then to the Co=monwealth, if necessary.

6. While an ongoing training program is indeed essential, the framework for one is already in existence and needs only to be utilized. Energy Consultants, under contract with Philadelphia Electric Company, has developed training courses covering the various types of offsite response that would be required should an accident occur at the power plant.

The municipalities need only request this training through their county emergency management agency. All training for municipal emergency personnel is to be coordinated through the county. If there is a void somewhere in the training, _

please let the Montgemery County Emergency Management -

Coordinator know and he in turn will discuss it with us.

I hope that with this rather lengthy letter I have been able to clarify some of the concerns that have rightfully been troubling the Skippack Board of Supervisors. If not, perhaps you would like to arrange a meeting through Montgomery County to discuss the matter further with the Skippack Board of Supervisors.

Sincerely, il WM John L. Patten Director JLP/RJH:jmb (Tel: 717-783-8150) cc: George Hugenin, Skippack Township Emergency Management Coordinator Edward L. Jordan, Nuclear Regulatory Commission

, Federal Emergency Management Agency, Region III A. Lindley Bigelow, Montgomery County Office of Emergency Preparedness Mrs. Mary Wills, Skippack Township Secretary