ML20203P916

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Intervenor Exhibit I-LEA-E-48,consisting of Notifying of Intent to Participate in Radiological Emergency Response Plan Exercise.Ltr Listing Concerns W/Plan Deficiencies Encl
ML20203P916
Person / Time
Site: Limerick Constellation icon.png
Issue date: 11/28/1984
From: Doyle J
EAST PIKELAND TOWNSHIP, PA
To:
PENNSYLVANIA, COMMONWEALTH OF
References
OL-I-LEA-E-048, OL-I-LEA-E-48, NUDOCS 8605080332
Download: ML20203P916 (3)


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July 18, 1984 P.O. Box'3321 Harrisburg, PA.

17105 Re: Radiological Emergency Response Plan Exercise - July 25, 1984

Dear Sir:

This is to notify you that East Piheland Township, Chester Ccunty will participate in the Limerick radiological emergency response plan exercise scheduled for Wed-nesday, July 25, 1984 with the following reservations.

A select committee of township residents has conducted a detailed study of the proposed radiological emerget:cy response pl.ui subr.at ted by Energy Consultants, of Harrisburg, PA., consultants to the Philadelphia Electric Company. In view of the cignificant concerns (attached) of the committee (concerns shared by the Planning jommission and Board of Supervisors) regarding the provisions of the proposed plan (Draft #5 dated April 1984), East Pikeland Township will not apprnve/ adopt the plan in its present form.

Thus we wish to note for the record thrit the township'4 participation in the July 25th exercise does not in any way constitute approval of tha plan nor does it bind the township to future participation in the program.

Sincerely,

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John D. Doyle, Sec'y cc: Chester County Dept. of Emergency Services Federal Emergency Management Agency Division of Emergency Preparedness & Emergency Respon'se Of fice of Inspection & Enforcetaent 50-352-OL n,d{hE-48 wg Nuclear Regulatory Commission phila. Elec. Co.

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! July 6, 1984 r

To tha East Pikeland Township Planning Commission:

The' undersigned, representing a commdttee investigating the

, Evacuntion Plan for East Pikeland, recommend that Draft #5 of the Radiological Emergency Response Plan (RERP) no't be approved as it

exists and not be submitted for review by the Chester County Department
of Etnergency Services (CCDES), the Pennsylvania Emergency Management

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. Agnncy(PEMA), the Federal Emergency Management Agency (FEMA), and the NuclGar, Regulatory Commission (NRC)until the following areas of concern be rocolved.

This recommendation arises from the identification of a large swuber of serious deficiencies and uncertainties in our. study of the.

RERP(Drafts M and #5) for East Pikeland, associated-materials, and discussion with various parties.

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, Foremost among these concerns are:

1) TIME FRAMEWORK FOR PUBLIC RESPONSE TO A RANGE OF POSSIBLE EVACUATION EVENTS: the plan does not precisely, relate effective times for evacuation to the imaginable range of radiological events.
2) INADEQUATE ROAD SYSTEM: need to realistically review the NRC required evacuation time study recently released by PECO and prepared by HMM Associates of Conco2.d, MA.

This computer based study indicates a total evacuation' time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 15 minutes for the 74,498 residents of Chester county during the worst of possible conditions, ie., "a snowy winter weekday"(The Mercury, -Pottstown, 6/22/84).

Township records indicate a total of 8-12 hours to plow out East Pikeland.

3) CO-ORDINATION WITH NEIGEBOURING MUNICIPALITIES:

determ'ine the relationship and impact of the plans (particularly the evacuation routes, joint use of services. - ambulances, fire company, buses, tow trucks, etc. ) of surrounding municipalities and school district on the East Pikeland j

Evacuation Plan.

This is one of the objectives cited in j

  • Draft #5, "Pnsure that planned actions are current and i

in consonanc.e with those of surrounding jurisdictions, as well as with the Chester County RERP".

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4) INADEQUATE E7ACUATION MANAGEMENT AND CONTROL MECHANISMS:

need for verified availability of equipment and services I

(ambulances, tow trucks, snow plows, etc.), realistic assessment of available volunteers, realistic assessment l

of amount of volunteers needed in time to fill one job, training program for volunteers and public, information availability and maintenance, etc.

5) COST: undefined liability of costs to the Township and public for implementation and pe'rpetual maintenance of Plan.

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6) LIABILITY: undefined liabilities.of Township, County, State ~ Federal Government, Philadelphia Electric and individuals,.such as volunteers, against damage to person and property in the Township.

Energy Consultants.

Inc( the consulting firm hired by PECO to prepar,e the RERP) suggested that we ask our solicitor to look at Pamphlet Law #1332, " Emergency. Services Code".

7) SHELTERING: when will we be asked to s telter, is it safe.

for how long, and how is it accomplished?

8) DR1LL TEST:.the stiperficiality of the prbposed test of the RERP planned for July 25, 1984, as a measure of Plan feasibility.

FEMA will be holding. hearings on the Drill two days following the test. (Jt2fy27-in Pottstown)

.These points are proposed as sufficient to support the recom-mendation.

Many other concerns and deficiencies can be elaborated.

It in' suggested that full resolution of the listed points be deinanded by the Township before the committee should undertake study of the plan in more detail.

5 The committee is,of. course, ready to extend or deepen it's ctudy as available information may permit.

The committee has chosen not to express opinion of the overall f=cibility or practicality of the idea of an Evacuation Plan for a Lim 2 rick Radiological Emergency.

It should not be -interpreted, moreover, thnt in recommending resolution of the listed concerns the committee' io ecdorsing the concept of the Plan.

1 Sincerely, LL)G.f.

Q J. Edward Matthews 4

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David K.. Adams Lind.%ay Brinton

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