ML20246N411

Forwards FEMA Rept on 890614 Plant Remedial Exercise.Rept Indicates That Deficiency Identified in Lower Pottsgrove Township During 880405 full-participation Exercise.Offsite Preparedness Adequate

ML20246N411
Person / Time
Site:	Limerick
Issue date:	08/15/1989
From:	Knapp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8909080113
Download: ML20246N411 (3)

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AUG.151080 L

p y, Docket No.- 501352 License No. NPF-27 L

Philadelphia Electric Company

/ ATTN: Mr. C. A. McNeill Executive' Vice President - Nuclear Correspondence Control, Desk P. O. Box 7520 Philadelphia,l Pennsylvania 19101 Gentlemenf

Subject:

FEMA Report on'the June 14, 1989 Limerick Remedial Exercise

-This letter transmits the Federal Emergency Management Agency (FEMA) report of the June.14, 1989 Limerick Generating Station remedial exercise.

'The report ' indicates that a deficiency. identified in Lower Pottsgrove Township, during the AprH 5, 1988 Limerick full-participation exercise, regarding the overall response capability of the.Leergency Operations Center.

staff has been corrected. This has resulted in a FEMA firding that the state

-of; off-site preparedness at' the Limerick Generating Station is adequate to provide reasonable assurance that appropriate measures can be taken to protect the health and safety of the public.

If-you have any- questions concerning this matter, please contact Mr. Craig Conklin of my staff at (Eli) 337-5342.

Sincerely, ORIGINAL stGNED BY LEE H. BETTENHAUSEN.

e.Malcolm R. Knapp, DirG-tor Division of Radiation Safety

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0 and Safeguards

Enclosure:

.As stated A

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PDR ADOCK 05000352 (g F PDC .

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Philadelphia Electric Company I

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J. S. Ken.;;er, Sr., Senior Vice President - Nuclear Conste uction G. M. Leitch, Vice President - Limerick Generating Station S. J. Kowalski, Vice President - Nuclear Engineering D. R. Helwig, General Manager - Nuclear Servcies M. J. McConnick, Jr., Manager - Limerick Generating Station

'W. T. Ullrich, Manager - Limerick Unft 2 Startup A. S. MacAinsh, Manager - Limerick Quality Division G. A. Hunger, Jr., Director - Licensing Section T. B. Conner, Jr., Esquire E. J. Bradley, Esquire, Assistant General Counsel H. D. Honan, Branch Head - Nuclear Engineering Licensing Public Document Room (PDR)

Local Public Document Roori. (LPDR)

Nuclear Safety Information Center (NSIC) hRC Resident Inspecter Commonwealth of Pennsylvania bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP J. Dyer, EDO

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0FFICIAL 0FFICE COPY Conklin Lazarus Bell my K 8/l4/89 8// 89 Wh% fohY 8/A/89 8//F/89

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J. S. Kemper, Sr... Senior. Vice President - Nuclear Construction

-G. M. Leitch Vice President. - Limerick Generating Station x . S. J. Kowalcki, Vice President - Nuclear Engineering D. R. Helwig,. General Mcnager - Nuclear Servcies

l. M. J. McCormick, Jr., Manager - Limerick Generating Station W. T. Ullrich, Mansgar - Limerick tinit 2 Startup A. S. MacAinsh, Manager - Limerick Quality Division G. A. Hunger, Jr., Director - Licensing Section

. T. ' B Conner, Jr. . ' Esquire-E. J. Bradley. Esquire, Assistant General Counsel H..D. Honan, Branch Head - Nuclear Engineering Licensing Public Document Room 'PDR) local Public Document Room (LPDR)

Nuclear Safety Ir. formation Center (NSIC)

NRC Resident Inspector Connonwealth of Pennsylvania

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.. 1 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE EVALUATION REPORT FACILITY: LIMERICK GENERATING STATION OPERATOR: PHILADELPHIA ELECTRIC COMPANY LOCATION: LIMERICK TOWNSIIIP, MONTGOMERY COUNTY, PENNSYLVANIA REPORT DATE: JONE 30, 1989 EXERCISE DATE: JUNE 15, 1989 .

PARTICIPAT3NG JURISDICTIONS: LOWER POTTSGROYE TOWNSHIP NON-PARTICIPATING JURISDICTIONS: N/A REPORT PREPARED ET: FEDERAL EMERGENCY MA,NAGEMENT AGENCY AND THE REGIGNAL ASSISTANCE cot 011TTEE, REGION III, PHILADELPHIA, PENNSYLVANIA Prepared in accordance with 44 CFR 350; and NUREG-0654/ FEMA-REP-1, Rev. 1, November I980.

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5 EXECUTIVE

SUMMARY

The following la a report on Preparedness (REP) Exercise conducted. on Radiological Esercency

' a remedial June 14, 1989, for the Limerick Generating Station, involv.ing Lower Pottsgrove Township. This report has been rrepared in accordance with 44 L CFR 350 and NUhEG-0654, REP-1, Rev-1.

The remedaal exercise was necessitated by a deficiency identified during the April 5, 1988 REP Exercise in which the Township officials and EOC staff did not participate to the ext.ent necessary to ineure appropriate actions were taken and adequate resources were available to care for the residents of the Township. The remedial exercise was conducted in a tabletop format, and' was designed and controlled by the Pennsylvania Emergency Management Agency.

The performances demonstrated by the Lower Pottogreve Township Officials and EOC staff edequately addressed the deficiency identifle.d during the April 5, 1988 exercise. Lower Pottsgrove i

Township staffed its EOC with personnel who proved themselves j committed to, and capabie of, providing protective measures for the residents of the townshlp. All objectives were adoquately

o. demonstrated to the extent applicable to township responsibilities and permitted by the tabletop format of the exercise. Of special note is the extent of planning that has gone into the development of special needs lists.

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L TABLE OF CONTENTS PAGE(S)

EXECUTIVE

SUMMARY

..........................................-.1 i TABLE OF CONTENTS..........................c........... ..i1 l .I. INTRODUCTION............................... .....,. 1-3 4

A. BACKGROUND.................................... 1-2 B. EVAT,UATION CRITERIA USED.............. ......... 3 II. OBJECTIVES.................. ......................s4-5 A. LIST OF OBJECTIVES..........s..................4-5 D. OBJECTIVES NOT ADEQUATELY DEMONSTRATED.......... 5 o

III. EXEfiCISE RESULL'.......... ........................ 6-8 A. LOWER POTT 5 GROVE TOWNSHIP. . . . . . . . . . a . . . . . . . . . . 6-7 B.

SUMMARY

LIST OF ISSUES...........................'8 APPENDICNS................................................ 9 PARTICIPATING JURISDICTIONS.......................... 9 .

EVALUATOR ASSIGNMENTS................................ 9 ii

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1. INTRLDDCTION A. BACKGROUND As requ17ed by the provisiona of 44 CFR 350.9(c)(5),

State and Acea2 governments will participate in remedial exercises when iheir perforLancee in joint, biennial Radiological Emergency Preparedness tREP) exGrctwes result in findings that offsite emergency preparedness is not adequate to incure that protective measures con he taken for the residents living in the vicinity of a nuclear pouer fDcility in the event of a radiological emergency (see a3so FEMA Guidance Memornadae EX-1, July 15, 1985). The remedial Gxercise conducted on June 34, 1989, involving the participation of Lover Pottegrove Town 4 hip, As the result of a deficiency identified during the April 5, 1988, Limerick Generating Station joint biennial REP exercjoe. The Deficiency (LIMX-88-ID) is described as -

follows:

"The overall response capability demonstrated by the

, Lower Pottsgrove Township EOC staff was not adequate to ensure that the health and a fety of the residents could be protecteo. Although the Montgomery County staff simulated taking appropria te actions i'or the municipality, 44 CFR 350 states that all localities must participate 13 an exercise every two years. In addition, that participation must adequately demonstrate the ability to protect the health and safet.y of the residents of that locality. The Emergency Operations denter was never properly staffed.

Those staff senbers that did arrive later, except for the Police Representative, Fire Representative and the RACES operator, did not display adequate energency operations training and knowledge. Due to this lack of trained and knowledgeable staff, specific functions and objectives applicable to this local jurisdiction were -

either not met or were simulated at best. Those staff l members that did arrive af ter Site Area Emergency was declared did so only because the EMC and staff at Montgomery County were succeesful in getting one public official and s.everal other staff members to report to l the EOC. It is impera tive that the County and officials from the ToReship recruit and train staff members who will be available to respond in au

, emergency. The Township should demonstrate a i

capability to protect the health and safety of its residente as soon as possible.

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, f d' 4 . 3 The Pennsylvania Emergency Management Agency (PEMA) responded to thfs finding eith the following statement:

"The mundelpal EMC and deputy were out of town on V

businesc and beyond the range of their pagers during i the night of the exercise. The police representative E on the EOC staff received notificatf on and assumed the j EMC's position. The initial notifiestion was verified, i but the County was. not notified untAl such later that a  !

problem existed because it kaan't apparent at that time. Operations were further complicated and hindered by an oil spill and a bajor fire. This depleted the firm and police emergency workers who would normally sup;> ort the exercise. The County staff , as called for in the State response plan, took steps to correct the snortfalls. The FEMA evalua tors may not have been j

aware of the special procedures implemented by the i

County; and the fact that a County operations officer i set up in a sepa rate office in order to provide l

individual oversight of Lower Pottsgrove Township's  !

operatAons. The Township's unset need for three buses

)- and one ambulance was coordinated. Through mutual aid, o police and firefighters from other municipalities were acheduled to man the TCPs and route alerting teams.

The latter were not deployed or demonstrat6d because this was an exercise not a real emergency . There, therefore, was no relaxation of the legal and 31 ability implications. Although full staffing was not achieved, and it is evident that additional training

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and volunteers who nre sore readily available would be belpful, it should be noted that the FEMt. evalua tor's conclusion was, "Drerall adequate steps were taken by Montgomery County to incure that response actionc ucr4 completed for Lower Pottsgrove Township. " See page 57 ,

of th6 FEMA report. It also appears that the 7EMA evalua tor at the township was not aware of the 'f additional support provided by the County. For the above reasons, recomman6 that the Deficiency be changed to an Ares Requiring Carrectiv_e Action, and the fjret and last sentences of the finding be deleted.

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,, 4 r' e B. EVALUATIOF' CRITERIA USED The performance .of 1,ower Pottsgrove participating in Township, in the remedial exercise were,evt.luated

relationship to their. ability to responc to an incicent as- outlined in their plans. The plar4s utilized during the response are as listed below:

Lower Fottsgrove Emergency Operations Plan These plans were prepared in ' accordance with NUREG-0654/ FEMA REP-1, Rev. 1, " Criteria for Preparation and Evaluat$on of Radiological Emergency Response Plans and Preparedness in Support of Nuclear November 1980. Power Plants".

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I IL OBhECTIHJi Thr following object.tves were submitted by tne Pennsylvania 7

7mergency- Maaagement Agency to correct the beficiency identified .in the bimerick Exercise Report for the exercise helb or. April bs 1388:

-1 70 demonstrate the timely activation of the municipal YOC.

2. To demonstrate the effectiveness of t?.e deciclon-mak'ing proctas and the. ability to transmit and coordinate the decisions into emergency response ections.

3, To d6monstrate the.edequacy- of communications systems among and within cmergency response organization and between designated facilities and fic3d activities.

4. To demonstrate the ability to conduct route alerting-under county coordination by a roote alert sector team in the risk municipality of Leuer Pottsgrove Township.

The t; municipality will be prepared to display and o discuse with the FEMD evaluator procedures for developing and maintaining a list of individuals with

$mpaired hearing, non-English speaking, homebound, and their notification by a route alert team.

5. To demonstrate the internal _ message and information flow (co)1ection, analysis, and dissemination) in the

, municipal EOC.

6. To decor.Etrate the conduct of an unannounced, after-hours exercise. For this exercise, the Alert stage will begin after 1800 hoare (6:00 p.m.) and only the week (not the day) of the exercise will be identifled for all porticipantes.

7. 70 demonstrate the implementation of municipal

. emeigency plans and the provisions for direction and 1

control of response end prote&bive actions to ensure that the publje health and safety is protected L

thrcughout the EPZ.

8. To demonstrate the existence and adequacy of emergency facilities and resources to support the response operation. The risk municipal EOC will demonstrate the er.istence and operation of an emergency power source (generator).

B. To demonstrate that action locations can alert, no t11'y ,

l 6nd mobill e response personnel in a timely manner.

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10. To demenetrate that all FOC positions shown in the municipal plans ui31 or can be manned on i basic.

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11.. To,4cmenstrate the abilities of municipal governments to' provide traffic centrol and control of access to selected restricted areas. One municipal TCP'per risk municipal!ty will be demonstrated.

j D. 010ECTIVES NO7 ADEQUATELY ITMONSTRATED All . o~ojectives were adequately demonstrated.

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lF IV. . EXERCISE RESOLTS 1

' Obj ective . 1, 'the tamely of the Lower Pottsgrove Township 'EOC was adequately actiration demonstrated. The Lower Pottsgrove EMC was notified at his hore of an Alert Genersting Station by the Montgomery County EMC at 1900.

at the Limerick arrived at the Lower Pottegrove The EMC EOC at 1912 ar;d immediately verified the message with Montgomery County and bdvised them that t'ne EOC was activated.

l Objec tive 2, the ability to make decisions, and decisione into emergency response actions was to coordinate those adequately.

demonctrnted as . applicable to the municipal Context of the table-top exercise. At 2020, the EMC was advised EOC and An the that sirens would be sounded at 2035. Se lumedlyte3y infoimed the Fire Representative te notify route alert teams to standby in cace o.t a . siren -failure. ht 293.0, the Fire Representative informed the route alert teems te begin notifying hearing impaired residents at 2035. A typed pre-scripted message was provid&d for each hearing-Japadred person.

Objective 3. the ability to communicate amcas and

, emergency response wea adaquetely demonctrsted. within equipped with a beeper The EUC was for initJn1 notification. 3t addition, fire rad 2os, police radioz, a FACEB operator and telephones are eva11able.

Objective 4, the ab513 tv to conduct rovte alerting, both back-up to siren failure and for t.b e hearing impaired individuals was J adequately demonstrated.

Objective 5, Anternal

. adequately demonstrated.

messagt and information flow cas appropria te Ali tessages were recorded on message fo7ms, logged, b9ard as appropriate.

and included on the status The responsible staff rembers were provided copAes of action messages.

Objective 6, the ability to conduct en unannounced, after-hours

. exercise was adequately demonstrated.

Objective 7, the inp3ementation of municipal emergency plans and the provisions for direction and of response and control protective actions protected throughout to ensure that the public health and safety is the EPZ was adequately demonstrated.

Complete, detailed liste of all special needs residents was available and reviewed during the exercise. The EMC directed the response efforts in.a dedicated canner, insuring that all unnet needs were addressed to include, buses, ambulances, additional '.

personnel, etc.

Objective B, the availability and adequacy of emergency facilities and resources to cuppoit response operations was I 6

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< ,- . i-adequately ' d emono tra ted . The EOC faci),ity comfortably: arrange 6.

le large and A backup power generator was ava12able, as well ac a' copy machine. The appropriate radiological equipment was provided to a31 availchle and written emergency wos kers -.

instruction on its use vere All applicabic maps and charts were post 6d in clear view, Objective B, the abilAty to alert, notify ond mobilize response personnel in a timely manner was adequately d emons tr6 +.ed .

stated under .cbject.fve 1, As the EMC was notified at ;Gno that an Alert had been- declared by the- Sdeeijck Generating Station He began notification to Township officials and staff at 1913. By 1930, the Ireputy EMC, Polices Public Works, Radiological Officer and Fire ' representative and Security were all present.

Objective 10, the_ ability to demonstrate that all positions in the EOC can be banned for a 24-hour PGriod was adequately dem0nstrated. Not all positions are nanned by Township personnel, however, additionel manning is provided by Montgomery County, ao provided for in the plan.

Objective II, the ability to provide trsffic control waa

• adequately demonstrated.. The County provides these personnel as called for in the zundelpal L?an.

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IL SUMMAM L ST OF ISSUK3 The issues listed for each evaluated location or activity have beeb suttarised and classified according to the following categories; Deficier cles are demonstrated and observed inadequacies that cause a f4nding that offsite emergency prep.. redness was not adequate to provide reasonable assurance that appropriat.e

.of protective. measures can be taken to protect the health and safety the public living in the vicinity of the Limerick Generating Station in the event 62 a radio'iogical emergency. Because of the potential depact of deficiencies on emergency P. preparedness, they are rescited tu be promptly corrected through appropriate

<1 remedial actions including remedial exercises, drills or other actions There were no deficiencies identified during this exercise.

Arese Recoirinc correcti ve_4ction are demonstrated and observec inadequacies of performance, and although their correction is reguired during the next scheduled biennial exercise, they are not considered, by themselves, to adversely impact public health and safety. There were no Areas Requiring Corrective Action identified during this exercise.

Arear Recommended for 1merovement are problem areas observed during an exercise that are not considered to adversely impact public health and safety. While not required, correction of these would enhance an organizations level of emergency Preparedness. There were no Areas Recommended for Improvement identified during this exercise.

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APPENDICES g

4' ' APPENDIX ONE PARTICIPATING JURISDICTIONS

-a, koser Pottsgrove Township APPENDIX TWO .

.EVALUATO?t ASSIGNMENTS Lower Pottsgrove Teunship .7bret E. *uamb, FEMA

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