ML20203P862

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Intervenor Exhibit I-COMM-E-6,consisting of Re Review of Radiological Emergency Response to Incidents at Plant.Essential Detailed Info Under Development
ML20203P862
Person / Time
Site: Limerick Constellation icon.png
Issue date: 11/28/1984
From: Belser A
PENNSYLVANIA, COMMONWEALTH OF
To: Tison Campbell
CHESTER COUNTY, PA
References
OL-I-COMM-E-006, OL-I-COMM-E-6, NUDOCS 8605080261
Download: ML20203P862 (9)


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g g I PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY Mk W

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HARRISBURG. PENNSYLVANIA 17105

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"r.Y November 7, 1983

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Mr. Timothy R. S. Campbell s

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Chester County Department of "Th A

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Emergency Services u

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's 14 East Biddle Street West Chester, Pennsylvania 19380 g

's-DcarMtrell:

2 PEMA has co=pleted its review of your plan far radiological emergency response to incidents at the Limerick Generating Station (Draft 5).

It is an excellent start. As you know the plan lacks some essential detailed information which is under develop =ent.

Recognizing that shortcoming, the plan is workable as it stands, but we have made so=e comments for your consideration which are enclosed with this letter.

I believe the co==ents are self-explanatory, but if you have any questions or if we can be of any other assistance please let me know. I am C

certain that ECI will contact you very soon to go over the necessary changes and additions.

We have two principle concerns.

One is that the Tellabs 294 system of alert notification needs some kind of supplementary mechanical means to cover those people who have no telephones or who are away from their phones and inside the EPZ at a critical ti=e.

It seems that PECO may be leaning on the municipalities to accomplish that task by route alerting alone.

If so, that is an improper use of route alerting.

The other concern is that it must be perfectly cicar and understood by all concerned that private non-prof.it schools come under the school district in whose territory they are located, and that includes parochial schools.

Appropriate, reco== ended changes to Annex N are included in our attached CoC=ents.

You and your staff have done a fine job in preparing this plan with the assistance of ECI, PECO's consultant firu.

I feel confident the final product will be an excellent one that vill be practical and useful for forth-coming exercises, and for actual incidents if any should ever occur.

8605080261 841128

{DR ADDCK 05000352 PDR Adolph L. Belser Director

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Office of Plans and Preparedness ALB/TJC:jmb (Tel: 717-783-8150) d't f N M_,2,,G.

c Enclosures cc: Robert J. Casto, Eastern Area Director Roberta Kankus, Philadelphia Electric Company I1-b-James Fisher, Energy Consultants, Inc.

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,.,i' COMMENTS ON CHESTER COUNTY RERP

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YOR LIMERICK GENERATING STATION P ga Section Comments 1

II.

Add the following references to the paragraph:

1.

Emergency Plan for Limerick Cenerating Station, Units 1 and 2, Volumes 1 and 2.

2.

PA Code, Title 4, Part 1, Chapter 3, Subchapter C,

" Emergency Management Responsibilities of Departments and Agencies."

3.

Commonwealth of Pennsylvania Disaster Recovery Plan, April 1977.

~. 4. Pennsylvania Emergency Management Agency Directive 32,

" Development of a Mass Care Operational Program,"

November 14, 1980.

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2 II.C.

_After the date, add:

"with changes."

III.F.

Replace'the definition for Emergency Broadcast System (EBS)

(2 vith the definition in Annex E.

4 III.K.

Under the host school definition, will students always remain under supervision of risk school officials or could this responsibility in some instances be turned over to host school officials?

t' 5

III.O.

Change the definition to read:

"The act of bringing a staff department or agency to the strength required to accomplish its mission on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis including..."

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10 V.E.

Delete "at a mini =um."

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10 V.F.

At the end of the first sentence add:

"with an average of f

three persons per auto =obile."

11 VI.A.

Delete the last six words of the final sentence of the first paragraph.

14 VI.A.25.

Typographical error; first line, first word.

16 VI.B.1.c.

Delete as written and replace with:

"roordinate the municipal emergency response operations in the event of an incident at the Limerick Cenerating Station."

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VI.B.2.b.

Add at end of sentence:

"in accordance with this plan."

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.s Prga Section Com=ents 19.

VI.B.10.b.

Delete as written and replace with: " Maintain radiation reports received from PEMA."

19 VI.B.10. d.

Delete. There is little if any situation analysis to be done and supply of information is covered under 10a.

19 VI.B.10.e.

Change the sentence to read:

" Coordinate the distribution of dosimetry, survey meters and radioprotective drugs in accordance with this plan."

20 VI.B '.10.

Add a paragraph h:

" Collect municipal and county radio-logical records and transmit them to PEMA as required."

20 VI.B.11.b.

Delete "and buildings."

20 VI.B.12.c.

Delete "on monitoring matters."

20 VI.B.12.d.

Delete " sheltering or."

21 VI.C.2.

Delete the words "and the Limerick Generating Station."

22 VI.E.4.

Last line, change to read: "and the Philadelphia

, Electric Company (PECO)."

22 VI.E.8.

' In the first sentence, delete " backup /."

23 VI.F.

-Change paragraph to read as follows:

1.

Provide liaison personnel to the c.ounty EOC.

2.

Provide security and man traffic control points within their area of responsibility.

3.

Develop an access control plan, coordinate the use of resources from the PSP, municipal police and National Guard to man required ACPs and activate the ACPs upon notification from PEMA.

26 VIII.D.2.g.

Change to read:

" Notify... school districts and college within the plume exposure pathway EPZ."

27 VIII.D.2.1.

Delete. Not needed'in this case since Berks County, as a risk / support county, cer'.ainly will be informed.

28 VIII.D.2.h.

Add the words, "and emergency workers decontamination stations."

.29 VIII.D.2.p.

Delete.

29 VIII.D.2.q.

Change to read:

" Notify...of Philadelphia and college of the

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Site Emergency classification.".

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-P;gy Section Comments 30 VIII.D.4.b.

Change to read:

" Notify... facilities, school districts,

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college and major... classifications."

30 VIII.D.4.f.

Change to read:

"In coordination with the Pennsylvania State Police liaison, dispatch... stations."

32 VIII.D.4.n.

Change to read:

" Relay...of KI to emergency workers if...

channels."

33 IX.D.2.

Add at the end:

"(through PEMA)."

A-1-1 App. 1 Add a second sentench to the note at the bottom of the page:

"They are reviewed and updated quarterly."

This remark should be made each time telephone numbers are needed.

.C-1 III.

The TellIabs (294) co=munity alerting system may not be adequate to alert all areas or facilities within the EPZ.

Consideration should be given to a supplemental system other than route alerting. For example, how will p'eople within shopping malls be notified as well as

."~those without telephones? In this regard, the fourth paragraph under III. on page C-2 is unacceptable because it' replaces the entire problem on the municipality to accomplish this task by means of route alerting.

C-3 V.B.6.

Change to read:

" Notify school districts and the college located...EPZ."

C-4 V.B.

Add a new paragraph 10 and renumber present paragraph 10 as 11. New paragraph 10:

" Mobilize route alert teams."

C-4 V.C.4.

Add:

"and emergency workers decontamination stations.".u-C-1-1 App. 1 As described, the public alert system places full responsi-bility for supple =entary alerting on the municipality to accomplish with their route alerting teams.

This use of route alerting system is improper.

The Tellabs 294 system must be supplemented by~other mechanical means to cover areas not properly, covered by phones.

C-4-1 App. 4

.The first par.agraph.is too. general in its reference to responsibilities of route alerting.

It implies'that route alerting will be a substitute for Tellabs 294 where the

.latter is not adequate.

There must be some type of a mechanical system developed to supplement the Tellabs system where necessary.

C-5-1 App. 5 An additional appendix is needed for a telephonic cascade notification system.

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Py Section Coc=ents

{bl II.

It was our understanding that PECO would prepare and distribute a brochure for the general public.

How did this responsibility get shifted to the county?

D-4' II.B.

Add a paragraph 3:

"If the public alert system is activated, ensure that appropriate EBS announcements are made immediately thereafter."

D-S II.D.2..

Delete words "or BRP."

D-1-2 Item 2 Change to read, " Turn down air conditioners and close external. air vents to minimize intake of outside air.

Turn off fans drawing.in outside air."

D-1--2 Item 3 Change to read, "If applicable, lower the thermostat setting

' of forced' air heaters to minimize the intake of outside air."

D-2-1 Second para.

Change to read, "The Covernor...and recommends selective evacuation of pregnant..."

D-3-l' Second para.

~ Change to read, "The Governor...that a General Emergency..."

D-3-2

.After the first paragraph at the top of the page add this

' paragraph:

" Main evacuation routes are provided traffic control by the Pennsylvania State Police for your rapid movement out of the endangered area. Please follow the C

-main evacuation routes for your community.

If you will

need'a place to stay, report to the designated reception center enroute. Please follow the following main evacuation routes for your co munity."

Then change the instructions to read as follows:

" Upper portion of North Coventry Township.

Route 724 West.

Reception center is Cumru Elementary School in Shillingdin.

d Lower portion of North Coventry Township, Warwick Township east'of Route 345, South Coventry Township north of Route 23 and all of East Coventry Township. Route 23 West. Reception center is the Morgan Corporation in Morgantown.

Western portion of East Nantmeal Township. Route 401 North to Route 23 West.

Reception center is the Morgan Corpora-tion in Morgantown.

Eastern portion of East Nantmeal Township, South' Coventry Township' south of Route 23, West Vincent Townsh,ip and Upper Uwchlan Township north of the Turnpike.

Route 100 South to Route 113 South to Route 30 Bypass West to Route 322 West.

Reception center is Downington High School."

Remaining instructions written in the format shown above. 'A

,. s P232 Section Comments (7-4-1 App. 4 In the second paragraph, change to read:

" Parents with children attending school within a 10-mile radius of the Limerick Generating Station are advised that their children will be evacuated to safe locations where they may be reunited with their parents or guardians.

Students will be bused to safe locations in host schools outside the risk area. Parents are asked to meet their children there.

I repeat, children will be bused directly to safe locations in host schools outside the risk area where parents or goardians may pick them up.

Parents or guardians are urged to go directly to the host schools.

Attempting to pick up your children at the schools they attend might interfere with their safe evacuation."

E-3 V.B.4.

Change to read:

" Fire departments...should mobilize their route alert teams and review their, readiness."

Change to read:

"If relocation is necessary, after E-4 V.D.3.

~ evacuation is completed, fire and... sites."

E-1-1 App. 1 By double asterisk, indicate which of the fire companies are located inside.the plu=e exposure pathway EPZ.

E-5-1 App. 5 Add an Appendix 5, to show equipment and personnel assigned to fire co=panies located inside the EPZ.

F-1 II.A.

Change to read:

"The PSP Troop J in Lancaster is respon-sible for PSP functions in Chester County.

It will coordinate its activities with Chester County.

The PSP are responsible for control of traffic on main evacuation routes and for planning and coordinating access control."

Also, delete paragraph II.C.

F-1 II.F.

Change to read:

"The PSP, supported by the National Guard and municipal police, will control access into the plume" exposure pathway EPZ during sheltering or evacuation."

F-6-1 App. 6 Add an Appendix 6 showing manpower and vehicles in the police departments located within the plume exposure pathway EPZ.

G-1 I.

Change to read:

"To establish policies and procedures for the provision of medical support in Chester County and to assist other risk counties in the event of an incident at the Limerick Cenerating Station."

H-1 I.

In the first sentence, add the word " policies" before the word " procedures." In second sentence, change'the word "in" to "to support."

( H-1 II.B.

Add the sentence:

" Request for National Guard support

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vill be made through PEMA.".

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f 4.

P^g7 Section Comments

  • 4 V.B.6.

Delete:

"and cancelling special events / activities."

N-4 V.B.7.

Add:

" Based upon the facts of the situation, a school district superintendent may decide to close the schools during a school day or at the end of the day.

Conversely, he might decide to keep the scheels open during the Alert classification."

N-4 V.C.3.

Change to read:

" School services officer will request-report of unmet transportation needs from risk school districts and the Valley Forge Christian College."

N-4 V.C.5.

. Change to read:

" School district superintendents assure readiness of appropriate vehicles, and' keep host school districts advised of the situation. Any requirements for transportation beyond the district % capability are reported to the county EOC."

N-5 V.C.9.

Add a new paragraph 9.

" Based upon the facts of the

. situation, school district superintendents may decide to'close the schools during a school day or at the end of the day while being particularly careful to avoid sending

.the children home when a requirement to take shelter or to evacuate may be imminent."

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7-1-3 III.B.

Valley Forge Christian College is shown as under the

-Phoenixville School District jurisdiction. This is not Colleges have their own plans and are their own so.

jurisdiction for RERP.

0-1 II.C.

Delete this paragraph.

0-2 III.A.

In first line, delete " assisted by the state government" and add at the end of the sentence "as advised by PEMA,."_,

.=

0-4 IV.B.

It is suggested that farmers should obtain their dosimetry-KI forms at the same time that they o~otain their Emergency Worker Certification Form and at the same location.

0-1-1 App. 1 Change the note to read:

"To be developed by Pennsylvania Department of Agriculture."

P-6 IV.C.1.

Change to read:

"Frepare to resume school operations."

R-4 IV.

Add the title:

" Refresher Training."

S-4 III.B.

Change to read:

"For small-scale exercises in.which Chester County participates, the Pennsylvania Emergency Management Agency is responsible for the development of exercise scenarios in coordination with the Limerick Generating Station."

~7-h

P"g7 Section Comments II.D.

Delete the word "normally" in first sentence.

(

1-1 I-2 V.B.4.

Who are the transportation providers to be notified?

~I-5-1 App. 5 Need an additional Appendix showing municipal pickup points.

K-1 III.

In second line, change the word " primary" to " main."

K-3 IV.D.2.a.

After the word " Chief" add "in coordination with the PSP liaison officer, ensures..."

L-2 IV.C.6.

Add:

" Decontamination monitoring teams pick' up their equipment and go to their assigned locations and report to the mass care coordinator.

Decontamination monitoring teams advise the mass care coordinator concerning monitoring and decontamination."

L-2 IV.C.7.

Add: " ARES operators report to their assigned mass care centers and prepare to operate the alternate means of communication."

L-1-1 App. 1

.After Morgan Corporation add:

(Morgan Corporation is located in Berks County, but it is used and operated by Chester County.)

C

-1 N

II.A.

rChange to read: "The Chester County Director of Emergency Services will monitor and coordinate the development of. radiological emergency response within the school districts of Chester County af fected by an

. incident at the Limerick Generating Station.

Non-profit private schools, including parochial schools, are the responsibility of the school district superintendent in whose territory they are located."

N-1 II.B.1.

Change to read: " Developing radiological emergency response plans for the school district and requiring acceptable plans from each school in the district including non-profit private schools."

N II.B.2.

Change to read:

" Coordinating plans with individual risk schools, appropriate municipalities, host school districts, and host non-profit schools as appropriate."

N.2 IV.

Change the title to read:

" Policies."

N-3 V.B.3.

Change to read: " School district superintendents notify host school' districts.

Direct communications between risk and host school districts are opened and maintained."

V.B.S.

Delete:

" order cancellation of special events / activities."

(N-4 Reason - although this is an option open to the school officials, it should not be directed in the plan because it is a premature action during the Alert classtfication of incident..

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P 'ga Section Comments

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'-I 8,9,10 This category (host schools) is not required because it is an appropriate part of each school district plan.

U-1 I.D.

Change the title to read:

"Non-Profit Private Schools" and show what school districts they are under.

U Add: Pennsylvania State Police Troop J.

U-2 F.

Add a new 5:

"Pennhurst Center RERP."

G-6-E-1 Add a note:

"Pennhurst is a state institution and it is supported entirely by the Pennsylvania Department of, Welfare.

See Pennhurst Center RERP."

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