ML20087F531

Supplemental Info on Limerick Ecology Action Offsite Emergency Planning Contentions 3,4,13,17,20 & 28 Requested at pre-hearing Conference.Certificate of Svc Encl

ML20087F531
Person / Time
Site:	Limerick
Issue date:	03/15/1984
From:	LIMERICK ECOLOGY ACTION, INC.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8403190140
Download: ML20087F531 (34)

Text

DOCKETED U%R; UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '84 MAR 15 tiO:20

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BEFORE THE ATOMIC SAFETY AND LICENSING BOnRD" In the Matter of  :

Docket Nos. 50-352 PHILADSLPHIA ELECTRIC COMPANY  :

50-353 (Limerick Generating Station,  :

Units 1 and 2)  :

Supplemental information on LEA Off-site Emergency Planning Contentions requested at the Pre-hearing Conference According to the r e,; u e s t made b.y the Limerick Atomic Safety and Licensing Board at the Pre-hearing Conference on the admissibility of LEA's Off-site Emergency Planning Contentions.

LEA hereby submits aupplemental information relating to contentions LEA-3 (VIII-23), LEA-4 (VII. 24), LEA-13 (VIII-33),

LEA-20 (VIII-41), LEA-17 (VIII-37), and LEA-28 (VIII-53).

LEA-13 (VIII-33) LEA has attached a listing"o'f-day care (including pre-school progams), day and overnight camps in the Limerick EPZ as requested at the Pre-hearing Conference on off-site Cmergency Planning contentions. Sources and references are listed. Additional informarinn may become available to provide further listings. In this ca ma, LEA will t_y to bring these to the attention of State, County and local officials.

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l LEA-20 (VIII-41) LEA has contacted Charlestown, South Coventry, and New Hanover Twps., which had not designated Municipal.EOC's in Draft #4 of their respective Draft RERP's. Information provided to LEA on March 12, 1984 still indicates that Char-lestown and South Coventry Townships in Chester County have not yet designated Municipal EOC's, although sites are still being reviewed.

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LEA-13 (VIII-33)

Berks County Dav Care

1) St. John's Pre-Kindergarten School St. John's Lutheran Church 45 North Reading Ave.

Boyertown, Pa. 19512 (369-1024)

(ages 3& 4)

2) St. Paul's Christian Pre-School Morlatton and Old Swede Roads Douglassville, Pa. 19518 (689-5090)

3) Toddler Time and Kinder Cym St. Andrews United Methodist Church RD#1, Swamp Creek Road Bechtelsville, Pa. 19505 (369-1011)

(all year, ages 1 to 5)

4) captain Kid's Pre-school Learning Center Swinehart & Second Streets Boyertown, Pa. 19512 (369-0770)

5) St. Gabriel's Epiacopnl, Hickory, Dickory Dock Rt. 422 Douglassville, Pa. 19518 (385-3710)

SOURCES USED FOR COMPILATION OF DAY SCHOOL LISTINGS' Pre-school information booklet for the greater Pottstown area American Association cf University Women (1980)

Pottstown/ Perkiomen Valley Phone Book ,,

Montgomery County Intermediate Unit Listing of Day Care Centers (1980)

"Where to Turn Directory", Community Planning Council (Montg. Co.)

NOTE: Chester County Intermediate Unit has just revised'its Day Care Center Handbook, which is currently at the printers. Rose Middleton(383-3300) informed us that it vill contain additional NEW listings for Chester County. It is expected to be available within a week.

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LEA-13 (VIII-33) i Ibn t gome ry County Day Care

1) Little People Day Care School 1561 Medical Drive Pottstown, Pa. 19464 (326-0554)

(120 children, infant to pre-kindergarten, up to age 10 after school and during summer)

2) Emmanuel Lutheran Church Pre-school Hanover & Walnut Streets Pottstown, Pa. 19464 (323-0835)

(ages 3& up, in operation 7:00 am to 5:30 pm)

3) Pottstown Dav Care Center Beech & Warren Streets Pottstown, Pa. 19464 (327-1884)

(3 months to 3 years)

4) Fellowship House Farm, Helping Hands Program (679-8885) danatoga No.,nue Pottstown, Pa. 19464 (60 physically and mentally handicapped)

(60 children / 60 adults, summer day camp),

5) Creative Plav. Pottstown YWCA 315 King Street Pottstown, Pa. 19464 (323-1888) -

(Sept. - Dec., and Feb. - May, ages 3-5) __ .. ,

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6) Enisconal Nursery School ' 'I - -

Church of the Epiphany 3rd. Ave. and Washington Street Royersford, Pa. 19468 (948-7737)

(Sept. - May, ages 3 & 4)

7) Faulkner Swamp Nursery School & Kindergarten Faulkner Swamp United Church of Christ RD#1, Swamp Pike, Box 165A Gilbertsville, Pa. 19525 (369-0474)

(Sept. to May, ages 3 & 4)

8) Grace Assembiv Day Care and Kindernarten Route 23 and Bridge St.

Spring City, Pa. 19475 (495-5279)

(year round, ages 1-5; Sept. to May, pre-kindergarten)

9) Grace Lutheran Nursery and Pre-Kindergarten Grace Lutheran Church 660 North Charlotte Street Pottstown, Pa. 19464 (323-9320)

.(Sept, to May, ages 3-5)

10) Hickorv Dickorv Dock Nursery School St. Peter's Lutheran Church Walnut & Glasgow Streets Stowe, Pa. 194f,4 (385-6125)

(ages 3-5)

11) First United Presbyterian Weekday Nursery School First United Presbyterian Church 750 North Evans Street, Pottstown, Pa. 19464 (326-4999) ,

(ages 2 to 4)

12) Roversford Baptist Church Nurserv School 452 South Lewis Road hoyersford, Pa. 19468 (948-5023)

(Sept, to May, ages 2 to 5)

13) Skinnack Church of the Brethren Nursery School Collegeville & Mill Roads Collegeville, Pa. 19426 (.489-3855)

(ages 2 to 4)

14) Swamp Creek Nurserv School (Coooerative)

Gilbertsville Area Post Office Box 201 Frederick, Pa, 19435 (754-7674)

(Sept. to May, ages 3& 4)

15) Pottstown YMCA. P.A.L.S. Program Pottstown YMCA Adams and.. Jackson Streets Pottstown, Pa. 19464 (.323-7300)

(.a g e s 3 to 5) (also pre-school programs year-round, ages 3 mo. to 7 yrs.)

16) St. Andrew's Nursery School Egypt & Crawford Ronds ~ ' ' ~ '

Audubon, Pa. 19407 (666-0426)

17) St. John's Nursery School 1802 Skippack Pike Center Square, Pa. 19422 (272-7163) v m

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LEA-13 (VIII-33) l Chester County Day Care

1) Phoenixville Day Care Center 310 Main Street, Phoenixville, Pa. 19460 (933-7717) 65 children enrolled, ages 3-6, Title XX Program 1

2) Phoenixville Day Care Center 412 Fairville St., Phoenixville, Pa. 19460 (935-1390)

3) Wonden Shoe Dav School Phoenixville Area YMCA (933-5861)

Pothouse Road, Phoenixville, Pa. 19460 (children ages 3-5 years)

4) Cineerbread House Day School Phoenixville Civic Center (933-7728) 123 Main Street Phoenixville, Pa. 19460

5) St. John's Preschool Kindercarten (h day program)

St. John's Circle (933-3947)

Phoenixville, Pa. 19460

6) Coventry Church of the Brethren (326-5426) 939 E. Cedarville Rd. (Coventry Nurserv School)

Pottstown, Pa. 19464 (children ages 3-4) (326-3938)

7) Cedarville Nursery School Cedarville United Methodirt Church 1092 Laurelwood Rd. Pottstown, Pa. 19464 (323-8651)

(Sept. to May, age. 3 and 4)

8) Charlestown Plav House. Inc.

RD#2, Phoenixville, Pa. 19460 (933-2762)

(October ro July, ages 2 to 5)

9) Children's House of Northern Chester County (AMT Montessori Academy)

St. Andrew's Lane Glenmoore, Pa. 19343'(458-8922)

(ages 2 to 5)

10) Congregation B'Nai Jacob Starr and Manavon Streets

. Phoenixville, Pa,.19460 (933-6467). -

l (Sept. to June, ages 3-5 years) t 11) Coventryv111e United Methodist Church Nursery School l

RD#2, Old Rt. 23 (S. Coventry Twp.)

Pottstown, Pa. 19464 (326-8533)

(ages 3-5)

12) Little People's Pre-school of Pughtown Baptist Church

! Pughtown Road RDf1 Box 340, Spring City, Pa. 19475 (326-1439)

(ages 3& 4)

13) Twin Cabies Nursery School Shankel United Church of Christ Shenkel and Unionville Roads Pottstown, Pa. 19464 (326-0589)

(Sept. to May, ages 3 to 5)

14) St. Andrews Church Nursery School St. Andrews Church Ludwigs Corner (Clenmoore) (458-5277)

15) Little School House Pre-school St. Peter's United Church of Christ Rt. 23, Knauertown, Pa. (469-9961) (469-9105)

16) Kids 'R Us Pre-school St. Peter's Village (469-6669)

(Warwick Twp.)

,(**) 17) Camp Hill Village Special Schools (W. Vincent Twp)

Box 155 Kimberton, Pa. 19442

(**) 16) Cemp Hill Special Schools (E. Nantmeal Twp.) - -

RD#L, Glenmoore, Pa. 19343 (469-9236)

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(**) These are residential schools for the mentally retarded, which are not currently included in any plans reviewed by-LEA agi 9

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LEA-13 (VIII-33)

. , Dpy/ Summer C a -- ' in the CPZ (*)

1 Baker Park Day Camn (1) Pothouse Road 150 (**)

(operated by Phoenir.- Phoenixville ville YMCA) Pa. 19466 Hideaway. Inc. Day Camp (2) Box 96 150 (**)

Arcola, Pa. 19420 (June-Aug.)

Camp Yomeca (3) 75 Hill School Rd. 100 (**)

Douglassville, Pa. 19518 (June-Aug.)

Camp Yomechas (2) Park & Cedar Rds.

Schwenksville, Pa. 19473 (287-9564)

Camp Fankanac (1) Bertolet School Road Pughtown (469-6320)

Camp Richard (2) 451 Indian Crest Dr.

Harleysville, Pa. 19438 (256-0161)

Camp Kelton Woods

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(1) Birchrunville (827-9407)

Pa. 19425 Camp Firefly (2) Spring Mount, Pa. 19478 (287-7675)

(for diabetic children)

SCF Vacation Camp (2) Collegeville, Pa. 19426 (275-3066) _

(operated by Federation of-Jewish Agencies) Capacity 150 (**).

Depending on what portions of Worcester Twp. are added to'the EPZ, there may be additions:

Variety Club Camp (2) Valley Forge & Potshop Rds. Capacity 140 (**)

Worcester, Pa. 19490 (summer)

(operated by Variety Club of Phila. - for physically handicapped children)

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(*) Due to time constraints, LEA was not able to confirm whether or not all of this list is day or overnight camping, but will work with PEMA as necessary to insure that these groups of children are included in the planning process.

Sources; Pottstown/ Upper Perkiomen Valley Phone Book, Aug. 1983 1981 Parents' Guide to Accredited Camps, Northeast U.S.

American Camping Assoc. (**)

National Direc, tory of Accredited Camps for Boys & Girls, 1974 i American Camping Assoc. (***)

County designations: (1) Chester County l

(2) Montgomery County l (3) Berks County ,

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Overnight Camps in the EPZ Camp Council, Inc. (1) 119 Camp Council Rd. 160 (**)

(operated by Camp Phoenixville, Pa. 19460 (summer) l Council, Inc., Phila.) l Camp Creen Lane (2) RD#1, Green Lane, 150 (**)

Pa. 18054 (summer)

Camp Indian Run (1) RD#2, Glenmoore, 120 (**) )

Pa. 19343 i (operated by Girl Scouts f i

of Greater Phila.)

Camo Innabah (1) RD#1, Pughtown Rd. 100 (**)

. Spring City, Pa. 19475 (winter)

(operated by United 110 Methodist Church - (summer) camping facilities available for year round use)

_JYC Camps Arthur Reeta Beker- (2) 400 (**)

.Zieglerville, Pa. 19492 (July-Aug.)

(Director, Harry Schwatrz) 700 (***)

(summer) 150 (***) ~

(winter)^~

Camp Kiwanis (2) RD#2, Swamp Creek Rd. 97 (**)

Schwenksville, Pa. 19473 -(summer, but avail-(operated by able year round)

Freedom Valley Girl Scouts)

Camp Kweebec (2) Game Farm Rd. 300 (**)

Schwenksville, Pa. 19473) (June-Aug.)

(operated by Les Weiser, Director)

Camp Laughing Waters (2) RD#1, Gilbertsv111e 120 (**)

Pa. 19525 (operated by Girl Scouts of Greater Phila.)

Fellowship House Farm (2) Sanatoga Rd., Pottstown (326-3008)

(overnight conference center) also Woodrock Proiect. Sanatoga Rd . , Fagleysvill.

(323-9045) year round overnight camp Sources:Pottstown/ Upper Perkiomen Valley Phone Book, Aug. 1983 1981 Parents' Guide to Accredited Camos, Northeast U.S.

American Camping Assoc. (**)

National Directory of Accredited Camps for Boys & Girls, 1974 American Camping Assoc. (***)

County designations; (1) Chester County (2) Montgomery County (3) Berks County

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LEA-28 (VIII-53) LEA has discussed this contention with PEMA, as requested by the Board. Mr. Hippert informed us that upon reviewing the arrangements in the County Plans, it was felt that the Batallian assigned to Berks County should be changed from Philadelphia to the 109th. Batallion in the Scranton-Wilkes-Barre area, to avoid delays resulting from traveling through the EFZ to get to Berks County.

LEA remains concerned about the time factors involved in mobil-izing the National Guard.Mr. Hippert further explained that the National Guard has I wrecker, several trucks, and 1 1200 gallon tanker at the Phoenixville (Chester Co.), Norristown (Montg. Co.),

and Scranton area (assigned to Berks Co.) Batallion locations.

-LEA believes that Mr. Hippert agreed with our concern about provisions for towing, gasoline supplies, and snow renowal on "non-state" roads; s ir.c e most of this information is still marked TBD in the local municipal plans.

Although Mr. Hippert seemed confident that the National Guard had the necessary equipment to provide for towing on State Roads (with I wrecker assigned per County, and back-up equipment available outside of Harrisburg), LEA remains concerned about the time necessary for mobilization, and adequate provisions for snow removal. It is possible that additional information will be available in the next revisions of the County and Municipal plans, and that continued discussions with PEMA may satisfy our concerns. However, at the present time this is not yet the case.

LEA-17 (VIII-37) As reques ted , LEA has reviewed the Sample Tables originally submitted with this contention, and has resubmitted examples that are typical of the kinds of errors _and omissions T.EA has found in the Draft Municipal RERP's. The cumufat'iVe-effect of these kinds of defielencies results in lack of' reasonable assurance that the plans can and will be imple-mented in the event of a radiological emergency. We have attached examples from Schuylkill and West Vincent Twps.

I.EA-17 (VIII-37)

S MI P I.F OF MilN I C T P A I. RERP DEFICIENCTFS (Municipality)

West Vincent (Chester Co.) Draft 4 PAGE 9 We are confused by the organization chart with respect to police duties. Why has the Police Chief been assigned other duties and police functions made the responsibility of the EMC?

9 (B-1) Mr. G. Burnley is out of the area during most of the day at his place of employment. How can he have an essential job in the plan?

9,1 %k) , The EMC (David Monteith) is also the snow removal contractor. How can he do both jobs in this type of .

a crisis situation? We feel all essential positions must be filled with people who are in the area most of the time and must have a deputy for each job with the same criterion to be available in the absence of anyone on the organization chart.

(EPmap) We do not feel that Crawfords' Towing is a practical

14) choice for towing disabled vehicles from West Vincent Township. He is located on the evacuation route and would not be able to back track into our area.

21 (3g) Many teenagers and other children are left at home alone 21 (4 e') during some part of the day while their parents or 14 (e2) parent are at work. How do you plan to handle their transportation? It would be silly to ask them to call the EOC as that phone will be jammed. If they could find a ride, where would they be taken? How could their parents find.them?

lik) In the event of a major snowfall, we doubt the ability of state and local forces to handle the situation of snow removal and evacuation. It is not unusual to be snowc in for six to eighteen hours in the township. Many older people are not capable of driving in heavy snow conditions, llow would people who are snowed in their long driveways and private lanes be able to get out?

If this question is not effectively answered, then the whole plan is almost worthless'.

Would supervisors be willing to say that people with long drives and lancs, who are snowed in, would be left to their own devices?

TABl.E #9

'SAMPl.E nF RERP DEFICIENCIES (Municipality)

West Vincent (Chester Co.1 Draft 4 (contd.)

PAGE (P-1) The police department is part-time. How can two cars, a Chief and four officers be available? They are not available twenty-four hours a day, seven days a week.

erv (Attach F) The plans f or the hearing impaired , ~ disabled , "e 66.

being developed from information from the Chester (F-1)

County Survey. This survey is faulty, , as many residents

• did not receive the questionnaire.

(F-1)

Since West Vincent is served by Phoenixville and Uwchlan for ambultnce service, 14 (e6) we doubt they will have units available to serve us as

,they will be swamped in their own areas.

Schuylkill Township Page i The promulgation should state that the plan coordinates with other Township emergency plans.

Page lii Reviewer for annual review and certification is not clear.

On Page 8, it appears to be the Emergency Management Coordinator Responsibility for distribution of changed pages is not clear.

Page 1 A. Purpose The type of incident and the anticipated perils to the Township are not stated. A clear statement of purpose is needed, and should state more specifics than "...an incident at the Limerick Generating Station."

Page 3 In items 'a" through "c" the potential perils and their anticipated duration shauld be clearly stated. In item "d" no mention is made of incidents from mishandling of spent radioactive fuel or similar hazardous material.

Page 4 Definition 16 should Is itstate therem the 25 radiation and 75dose rem value which lev,els?

warrants action.

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LEA-17 (VIII-37) j

Page 6 in F. Objectives the first item should define the hazards and perris being planned for.

In F.2 the planned actions should be effective and worka.ble as well as current and in consonance.

In F.4 we need more than a " basis" for functional impler.enting procedures. We need the actual procedures to implement in the face of an emergency.

In F.5 it is not possible to "F.nsure that the population of Schuylkill Township is informed..." with the total lack of any description in this plan of the type of hazards anticipated and the rapidity of their development and duration of their existance.

Page 7 A. General should list all the local government jurisdic-tions impacted by Limerick. The plan draft shows no evidence that consideration was given to Phoenixville residents passing through Schuylkill Township in their evacuation. There is no evidence in the draft plan that the concluding sentence has been considered. ,

In B.2.c another statement of the " Route Alert" system Considerations should be given to a telephone network for alerting to save time, fuel, and avoid traffic congestion.

In B.2.f the whole traffic flow plan for the township and its neighbors should be stated. The flow of Phoenixville residents through the Township must be identified and made realistic with existing road capacities.

If B.3.s (2) is in fact what P.L. 11332 says, then P.L.1332 is seriously flawed. Our situation with shared fire and ambulance services does not fully qualify us to direct emer-gency services not normally administered by the Township.

Figure 2-2 should show five supervisors, should show who has route alert responsibilities, how three fire companies fit in the " Fire and Radiological" box. The " Medical and Transportation" box is logically an area function - not a '

Township function.

B.3.a (4) Outside forces on loan to the Township should be under Township supervision to assure coordination. Two police forces in the same geographic area working under different commands is an invitation for trouble.

In B.3.a (6) what are the " normal dispatch and operational procedures" to be used?

l In B. 3.b . (3) (a) it would be wise to state.that normal areas Page 9 of coverage in the Township will prevail throughout any i emergency. l l

B. 3.b. (4) (a) through (d) recognition must be given to the j fact that no one single entity covers the Township for .

Medical / Ambulance Services. It would be logical for normal j area coverages to prevail through any emergency.

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p Page 10 In B.3.b.(S)(c) who identifies what roads are to be clearod? y Who is allowed use and who is prevented from use? 3 Page 10a In B.3.b (6) no consideration is shown for the three fire services that cross Township lines. This needs much better <'

coordination for the plan. [

, in B.3.b.(7) no consideration is given to the ract that the -

Township has no explicit " Ambulance ciervice" function. CL in B.3.b.(8) is it intended for the Emergency Management Coordinator to be the communicator (telephone operator) alsnY Better planning is needed for the mechanics of communications and logging them in and the overall Emergency Management decision making process.

Page 10b In 5.4.c.(3) and (4) the Township does not have a " Fire Services Officer" and a " Medical / Transportation Services Officer" let alone a department for each. The plan as drafted for us does not recognize our situation. All staff shou,ld be designated by name also.

Page 11 In B.4.e. back-up personncI for 24-hour staffing are mentioned but not l i s t e d '. The plan should indicate all those persons to be of use.

In C.1 the EOC telephone numbers should be listed. Also In C.3. the ARES operator and his back-up should be identified. Physical room, power requirements, and antennae requirement. at the EOC should be stated.

In D.2.b. the details of " Route Alerting" must be spelled Page 12 out. This plan should set all the advance work out of the way so when an emergency arises, action can be taken without agonizing over decisions about routes, methods, etc. No Attachment E.

In D.2.c an initial list of the known Township hearing impaired should be i ncluded. Who is the " Municipal EMA" who will dispatch?

Page 13 In E.2.d. the evacuation routes require much elaboration.

i Also, Welsh Valley Road sud Diamond Rock Hill are omitted -

why?

Detailed evacuation routes, drain areas, flow capacities, Page 14 surge durations and similar data need to be shown. The influences of neighboring evacuation traffic sources ]

(Phoenixville) should be clearly shown. Schuylkill Township ,

is not an isolated island. E.2.f reference Attacaent D is incomplete, virtually blank.

l Page 14-15 In E.2.g. separate school plans are again mentioned.

Logically several evacuation plans are needed to accomodate the very different situations arising in:

(i) normal weekday incident (ii) late night incident  !

(iii) weekend or holiday incident l m., , .. -- - - . , - - . , - . - - - - - - - r-m-,---

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Page 19 in 1.2.e.

residents.

It is not clear who contacts non-ambulatory Page 22 in .i.2.e. no recognition is made for our several fire departments.

In J.2.f. no recognition is made of our local Medical /

Ambulance conditions.

Pages E-1 through E-3 The 21 hearing impaired individuals should be listed.

Sectors and team locations should be listed. Are eight sectors adequate for our Township?

Page F-1 The actual residents needing special help should be listed

! in the draft. Use of estimates based on U.S. Dept. of J llealth and I:uman Services statistics is unprofessional.

Page G-1 Specifics must be listed in the draft plan. Estimates based on 1980 Census Data are not worthy of inclusion.

Compilation of the name and address list should be part of the plan preparation.

The exclusion of schools is ill-advised. A ba s ic fi nw is that the plan does not recognize major differences between weekday, weekend, and late night evacuation situations.

Page I-l To be of any u'se the draft plan should include all names, addresses, and telephone numbers-so that a correctness check IMPLEMENTINC can be done as part of the review.

Item 16 - who decides i f the EOC must he evacunted?

Pcge P-1 List the names and telephone numbers for the 25 Fire Police.

Page 14 The logic and function of tbc traffic control and access con-AnAcM D trol points must be developed.

Page 15 The "Public Works Resource Inventory" Does this list include only the Township's lons dump truck?

Page 14 The local situation of three fire companies covering the Township is not covered, i

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LEA-3 (VIII-23) LEA has attached material to show the essential links between the draft Bucks County Sunport Plan and the draft Montgomery County RERP. We have taken exerpts from the plan itself to more clearly describe the role of the support county.

The support County Emergency Management Agency (EMA) is the lead agency in alerting, notifying, mobilizing, and coor-dinating emergency response organizations and resources needed to support the Montgomery County nian. The organizational chart (App. 2, Att. B) shows the staffing strength of the county office which is intended to be assigned to support an evacuation from Montgomery County. However, if for any reason this staff is unavailabic for the tasks detailed in the draft suoport plau, some other provisions must be made to fulfill these roles. These functions are itemized starting on page 7,Section V.(Responsibilities) and are included under descriptions of the responsibilities of Bucks County Emergency Staff assignments, starting on page 9 (Item B. " Bucks County Emergency Managememnt Staff"). Particularly important to the workability of the Montgomery County plan.and necessary to provide reasonable assurance that the plan can and will be implemented are the following highlighted ( and circled)

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/.TTACil!'U;T E BUCI:S COU!1TY E EPGEl:CY MAf:AGEMENT AGEllCY EMERGENCY OPERATION 5 ORGAfilZAT10fi BUCI'.S COU;1TY COMitlSS10tlERS (3)

COUliTY ADMINISTRATOR (1)

CIVIL DEFEllSE DIRECTOR (1) 4 1 Ll F ADMlltib il:Alluti l FIELD OPERAT10tlS

$_,,frOPtRA110!!S l WARillflG SUPPLY FIRE

. 0:'.';Illi! CAT 10 tis (60) PROCUREMEliT (3)

RESCUE (3)

SHELTER DEFE b Bb RD (1) SECURITY (2)

I CilEMICAL INTERilAL BIOLOGICAL SECURITY (3) WELFARE (3)

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_010 LOGICAL (2)

] ' - ~ S1TUAT10il BUILDING tlEDICAL & HEALTH A:!ALYSIS (3) 1%IliTEllANCE (2) (5) 8 PUBLIC 1:WORMAT10!1(2)

MESSAGE llTER(3)

I UTILITIES C

Lc TRAllSPORTATION I INDUSTRY l' ENGIllEERING(6)

Dm 2-B-I Draft 4

w BUCKS COUNTY FIXED NUCLEAR FACILITY INCIDENT SUPPORT PLAN 5 FOT INCIDENTS AT THE I.lMERICK GENERATING STATI'ON

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1. SCOPE AND AUTHORITY A. Scope This Fixed Nuclear Facility Support Plan:

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3. Assures appropriate responses to protect the affected evacuated population from Montgomery County including mobilization of County forces to support necessary actions.

G. Mobilize - The act of bringing a staff, department, or agency to the strength required to accomplish its mission, including the pre-positioning or m>vement of equipment or personnel.

Radio Amateur Civil Emergency Services (RACES) and Amateur Radio Emergency Services ( ARES) - Licensed volunteer radio amateur (HAM)

- communications personnel, equipped anb affiliated with the County Emergency Management Agency.

p7 V. RESPONSIBILITIES ,

A. County Emergency Management Agency

1. In coordination with the Red Cross, develop and maintain a comprehensive plan for support of Montgomery County in the A event of an incident at the Limerick Generating Station.

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Develop a system for alerting county and municipal go'vernment heads, emergency management agency staff, emergency forces, i

volunteer organizations, schools, hospitals, nursing homes, and business and industry involved in the county support plan.

5. As1ure that the alert system is operable on a 24-hour basis.

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Identify and coordinate with Montgomery County and PEMA:

u a. Traf fic control points 0 b. Reception centers

c. Mass care facilities r-L d. Cer. tral resource receiving point (s)

7. Coordinate the release of information to the news media with the PEMA Public Information Of ficer.

Coordinate recommendations for changes in main evacuation routes and traffic control points with PEMA, risk countie=, the PSP and the Department of Transportation.

9. Establish and train a requisite number of radiological decon-

-J tamination monitoring teams for mass care centers within the county.

10. Register and provide radiological monitoring of evacuees at mass care cer.ter locations within the county.

11. Maintain plans for the decontamina, tion of evacuees at mass care centers.

12. I esignate D and be prepared to operate a central resource receiving point.

I 1

13. In conjunction with PEMA, coordinate plans with designated risk counties for the movement and reception of evacuees.

14. Maintain a current listing, with copy to PEMA, of any unmet personnel and equipment needs. '

16. Coordinate the reentry of evacuees with PEMA, and the risk counties. ,

Participate with risk counties in exercises conducted by PEMA.

a .

B. Bucks County Emergency Mang ement Staff The responsibilities required during emergency operations, planning, and activities have been assigned to the following members of the Bucks County Emergency Operation staff. A detailed description of each staff position responsibility may be found in the Bucks County Disaster Operation plan (00P 1980) or the referenced S0P.

Board of County Commissioners In the event that a State of Disaster Emergency is declared, the Bucks County Corsnissioners will assume the emergency authority outlined in state laws. They will direct and control all resources and actions required by emergency management operations. The Chairman of the Commissioners will be responsible for making all official announcements.

Macs Care Coordinator (Welfare Division)

The Mass Care Coordinator (Welfare Division) is responsible for coordination Lith Red Cross personnel in the establishment of mass care centers and for reception center operations. The Mass Care Coordinator will coordinat'e mass care activities with the Medical Health Group and the Fire and Rescue Group for support. (See Bucks County SOP, " Emergency Activation and Operation of Mass Care Center.")

5. Security Division Chief M The Security Division Chief is responsible for the coordination of all county police organizations and operations. He is responsible for maintaining liaison with local, state, and military authorities in order to affect his duties. (SeeBucks County SOP, " Security Police Service.") ,

Fire and Rescue Division Chief l The Fire and Rescue Division Chief is responsible for the coordination, and if necess'ary, deployment of all county fire and rescue personnel and equipment. (See Bucks County SOP,

" Fire, Rescue, and Ambulance Services.")

l l

l

,, The Medical / Health Division Chief The Medical / Health Division Chief wil) coordinate all county, i and relocated medical personnel resources, to provide primary and emergency care to evacuated persons. He will also assist

~5 risk county staf f and agencies in the relccation of patienG, staf f, and equipment from risk area hospitals, nursing homes, p and other health care facilities. (See Bucks County SOP, LU " Emergency Casualty Care.")

8. The Public Information Officer The Public Information Officer (PIO) is responsible for the dissemination of emergency information at the direction of the County Director. (See Annex F, Bucks County Disaster Operations Plan.)

The Transportation Division Deputy Chief The Transportation Division Deputy Chief is responsible for coordinating all transportation resources within the county M that will provide for the movement of people and supplies.

(See Bucks County SOP, " Emergency Mobilizatioa of Transportation Resources.") -

10.

7 The Technical Division Chief (RADEF)

-J The Technical Dvision Chief (RADEF). will coordinate and N

establish monitoring and decontamination points at each designated mass care center. He will also provide technical evaluation for situation analysis and public information disseminction. (See Bucks County SOP, " Radiological Defense Operations" and Attachments I and J of this plan.)

) The Warning and Communications Division Chief a The Warnino and Communications Chief is responsible for i

evaluating the receipt of all warnings and the issuance of said warnings upon coordination with the County Emergency Hanagement Director.

He also will initiate all notification, as required, of County Disaster Operations personnel and County Communica-11 Draft 4 n

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I tions in line of succession. He is also responsible for initiating necessarj actions to establish communication between h county and state resources, as required.

12. County Agricultural Agent g The County Agricultural Agent will be responsible for supplying 5 infonnation and advice on agricultural matters. He will coordinate with State personne) on the effects of any radio-contaminants within the County's portion of the ingestion exposure pathway EPZ (60-mile radius from Limerick).

Trained personnel from all available resources will be utilized by the Bucks County Emergenc, Operations staff to the fullest extent. Trained auxiliaries and volunteer organizations will be used to augment normal government service personnel.

VI. CONCEPT OF OPERATIONS I A. Bucks County has agreed to provide reception and mass care center I support for a mar.imum of 24,440 evacuees from Montgomery County.

B. Evacuation Evacuees from Montgomery County will be entering Bucks County via the following routes:

Total Number Number of Route of People

• Vehicles

1. Route 113 North 9,392 3,131

2. Route 202 East 10,990 5,663

3. Pennsylvania Turnpike East 28,496 9,499 1r Draft 4

Trinsportation Transportation of evacuees, if necessary, fror the reception center to the designated mass care center will be provided in the form of busses and vans.

The Bucks County Emergency Management Agency will coordinate the support of transportation requirements with appro-oriate risk counties. Transportation staging areas will be established in Montgomery County at (1) the North Penn School District Bus Garage in Landsdale, (2) Fort Washington Industrial Park, and (3) King of Prussia Plaza, to provide bus and ambulance support to Montgomery County *. These facilities will be operated by Montgomery County. Bucks County will dispatch available trans-portation resources to each of these sites as requested by Montgomery County. (See Annex K, Bucks County Disaster Operations Plan and Bucks County SOP, " Emergency Mobil.ization of Transportation Resources.")

F. _ Mass Care Support A listing of mass care facilities is contained in Appendix 4 Bucks County will accept a maximum of 24,440 evacuees from i

Montgomery County. The Bucks County Emergency Management Agency will notify schools designated as mass care centers of emergency action levels as per Section I below.

The Bucks County Emergency Management Agency will also coordinate American Red Cross -support of the designated mass care centers with the school administration 0 for management of the mass care centers.

For sanitary reasons, pets will not be allowed inside mass care centers.

Owners are responsible for arranging for their care. A i

listing of kennel and veterinary facilities are listed in Appendix 4 Attachment H. {

The Red Cross will also activate agreements with l the local Humane Society, as necessary, in order to assist pet' owners to the extent possible. j 0 These transporation-staging areas are " proposed" at this time . Formal l

agreements are under development. i 14 Draft 4

l 0 G. Decontamination Monitoring q

d The Bucks County Technical Division /RADEF will establish monitoring and decontamination points at mass care centers. Decontamination monitoring is required only at the directinn of the Bureau of m Radiation Protection (BRPl. Otherwise, decontmination monitoring b teams will be available to perfonn monitoring upon request by any evacuee. When monitoring is directed by BRP, it shall be performed

] before registration or admittance to the general living quarters area of the mass care center. A list of decontamination monitoring

]"

assignments and procedures for distribution of dosimetry, KI, and survey meters.and other radiological exposure control procedures r are located in Appendix 5.

L_

H. Medical Sucport

.J The Bucks County Emergency Management Agency is responsible for providing appropriate medical support for the evacuees. A Medical Health Group Chief has been appointed to assist the Bucks County Emergency Management Agency with medical support of evacuees. The Ly Medical Health Group Chief will coordinate with the Rescue and Transportation Services for transpcrtation of evacuees requiring treatment. (See Annex H, Bucks County Disaster Operations Plan, and Bucks County SOP, "Emergercy Casualty Care.")

E Medical support service informa' ion is contained in Appendix 6 of this plan. It is planned to relocate some residents of the Frederick Mennonite Nursing Home in Montgomery County to Roc'khill Mennonite Community Home in Bucks County, and some of the residents y of the Montco Geriatric Center to Neshaminy Manor.

A listing of Bucks County ambulance services is provided in Appendix 6, Attachment B. These services will be notified at the time of an incident to ' determine the number of units available to support Montgomery County in a radiological emergency. Package Disaster Hospitals in the county will be made available to support health care facilities relocated to Bucks County.

15 Draft 4 5_-__--_-

a J. Student Pick-Up Points / Host Schools

, The Bucks tointy Emergency Management Agency and Bucks County have d, not been tasked with the reception of evacuated students from Montgomery County risk schools.

VII. DIRECTION AO CONTROL The overall direction and control of emergency operations will be coordinated from the Bucks County Emergency Operations Center, (E0C), located at Broad and Court Streets, Doylestown, phone (215) 348-9401.

Key operations personnel will be notified by the Bucks County EMA Coordinator in the event of an incident at the Limerick Generating Station which could affect Bucks County opertions.

Communications between the respective county emergency operations centers (E0C's), local emergency management coordinators, and reception / mass care centers, will be by telephone, RACES / ARES, cnd through the Bucks County Communications Center via the County police and fire radio net.

VIII. PUBLIC INFORMATION l

All public announcements will be those authorized by PEMA and made by the County Commissioners. All EBS and commercial radio and TV stations as well as newspapers will be alert'ed for these announcements.

Facilities will be provided at the County EOC for representatives of all news media. A media listing and pre-written public information announcements are provided in Appendix 7.

CENTRAL RESOURCE RECEIVING P0 INT I

A Central Resource Receiving Point anci distribution center for food, balk supply, and medical supplies will be established at the Doylestown Airport, Old Route 611, Doylestown.

The Bucks County EMA has appointed a Public Works Director who will w ._ coordinate with appropriate staff to operate this facility.

l APPENDIX 4 l

i ATTACHMENT D RIVAT10ft 0F RECEPTION CENTERS

1. ACTIVATION ITheordertoactivatereceptioncentersisissue the Bucks County Emergency Management Agency or his designee. Once the order to activate is issued the Mass Care Officer is notified to contact l

reception center managers (see Appendix 4, Attachment F). Reception center managers are responsible for notifying and activating their respective staffs.

Il 11. C0f1 CEPT OF OPERATIONS A. UN'JSUAL EVENT:

,g No action required.

C B. ALERT:

0 1. County Coordinator notifies the Mass Care Coordinator.

Mass Care Coordinator notifies Rec 6;ftion Center Managers

, informing them of the emergency status and instructing them to contact their respective staffs assuring availability..

3. Reception Center Managers notify staff and make preliminary assignments, m -

Mass Care Coordinator coordinates with County Warning and Communications Division Chief and Security Division Chief on assignment of a RACES tean and traffic control personnel at reception centers.

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4-D-1 Draft 4 f

LJ .

1 APPENDIX 4 ATTACHMENT E ACTIVATI0rl 0F MASS CARE CENTERS

1. ACTIVATI0ri ORDER The order to activate one or more class care centers is issued bv the County Emergency Management Agency Coordir.ator or his designate in his absence. Once the order to activate is issued, the Mass Care Officer or designated alternate is notified, who in turn notifies the appropriate g Hass Care Center Managers.

APPENDIX 4 ATTACHMENT F I ._

RECEPTION CENTER STAFF Reception centers will be manned by Bucks County Deputy Sheriffs. All deputies will be trained in the operation of such a facility.

Ill.

The reception center team, in addition to the manager, should include at least four individuals for distribution of maps and internal traffic flow.

Arrangements for harricades, traffic cones, signs, flashlights, etc., should be made )y the reception center manager through appropriate municipal government sources and/or the county EMA.

O 6

4-F-1 Draft 4

F ._ -

\

1.

Emergency Action Level Operations 1

j 1.

When an Unusual Event is declared, no actions are neces The County will receive no notification.

2.

When an Alert emergency classification is declared , PEMA Eastern Area Headquarters will notify the County Emergen Management Agency (EMA), and the following actions will be taken:

a. Officially log message, b.

The County Communications Center notifies the County Emergency Management Coordinator or his assistant if he is not available.

c.

Notify the Chairman of the Courity Commissioners .

m

% Alert key personnel of the County EOC staff and the Co American Red Cross Chapters.

Selected key personnel i designated by the Emergency Marigement Coordinator port re to the E0C.

Alert Radio Amateur Civil Emergency Service (RACES) .

Open radio communications nets with Montgomery County .

g.

Establish E0C security.

3 When a Site Emergency classification is declared , PEMA Eastern Area Headquarters will notify the County EMA. Upon notifica-tion, the following actions will be taken:

I a.

Same action as for Alert.

b.

Mobilize the County EOC staff.

] 1e Draft 4

l Mobilize appropriate fire, police, and ambulance services throughout the county.

Mobilize the County Red Cross staff and alert volunteers.

Place reception centers and primary mass care centers on standby status. The Mass Care Center Manager is responsi-ble for mass care operations including the assignment of space and facilities for Decontamination Monitoring Teams and the reception center team in the event the mass care center also serves as a reception center.

f. Distribute survey meters, dosimeters, and KI to decontam-ination monitoring teams.

Mobilize decontamination teams and have them report to assigned locations. (Mass Care Centers incJude decontami-nation teams whether or not radiological bohitoring is

~

required.)

~

Open RACES communications nets among the County E0C, American Red Cross, primary mass care centers and reception N centers,

i. Issue public information statements to inform the public about the situation. PEMA will cacrdinate information releases with the nuclear facility, Governor's Press Office, and risk and support county Public Information Of fi cers'.

Notify School Districts providing mass care facilities of

a. t,. _ g _ ,and ,.c.pt,on _ ., ,ac,, ,, _ s. ,

Notify police to make traffic control assignments in the event of evacuation. '

17 Draft 4 L . - -

l

m .

4. When a General Emergency classification is declared, PEMA Eastern Area Headquarters notifies the County EMA. Upon y

notification, the fellowing action will be taken:

a. Same action as for Site Emergency.

Active County reception and primary mass care centers and place remaining mass care centers in standby status.

Man traffic control points in preparation for receipt of evacuees.

4

d. As each primary mass care center is filled, sequentially upon remaining centers.

Notify School District Superintendents of the need to utilize school facilities for mass care, f.

If applicable, activate the Emergency Broadcast System and make appropriate announcements.

5.

Upon recommendation to initiate reentry, the following actions will be taken:

Activate traffic control points.

Announce reentry plans to evacuees in mass care centers and release appropriate public information announcements (Appendix 7. Attachment D).

c. Report any damages caused by the evacuation and reentry, and any extraordinary costs of operations, to the County Emergency Management Coordinator who in turn will report. to the PEMA Eastern Area Headquarters.

18 Draft 4

m APJPCNDIX 5 ATTAClil,4ENT B t -

00SIMETRY AND P0TASSIUM IODIDE (KI)

II. DISTRil1UTION Ur DOSITETRY, POTAS3IUM IODIDE AHO RELATED PROCEDURES A. Distribution At the ALERT stage, the County Technical Division Chief (RADEF) will report to the E0C to prepare dosinetry, survey meters, KI, and necessary report forms for distribution to decontamination monitor-ing tcoms (generally fire services personnel). At SITE EMERGENCY, the Technical Division Chief (RADEF) will contact the County Fire fiarshall's Office for assistance in distribution of the dosimetry I and other radiological equipment resources to decontamination monitoring teams throughout the County.. Upon receipt, each organizatio~n shall distribute to in'dividual team members and -

mobilize teams to their assigned locations.

To facilitate'this distribution, a "00simetry, KI, Survey Meter.

Distribution List" is contained in Attachment D to this Appendix.

I The list indicates the receiving organizations and the required

, number of each item.

APPENDIX 7 ATTACHMENT A- -

V.

A Rumor Control Center (RCC) will be established by the County EMA whenever the E0C is activated in suoport of this plan. The PIO is responsible for the staffing and operation of the rumor control telephone. The rumor control telephone number for Bucks County is 215-348-9401. {

7-A-1 Draft 4 l

LEHICH COUNTY SUPPORT PLAN .

LFA-4 (VITI-24) The Lebigh County Support Plan parallels the Bucks County Support Plan as previously discussed in LEA-3, in addition to the responsibility of coordinating the host schools for evacuated students from Montgomery and Berks ,

Counties. (page 15, Lehigh County Support Plan).

Exerpts follow.

The Medical Health Group Chief will coordinate with the Rescue and Transportation Services Group Chiefs for transportation of evacuees requiring treatment. Medical support service information is contained in Appendix 6 of this plan.

The primary f acility for treatment of irradiated individuals in Lehigh County will be the Lehigh Valley Hospital Center.

Trained personnel from all available resources will be utilized 013. by the Lehigh County Emergency Operations staff to the fullest extent. Trained auxiliaries and volunteer organizations will be used to augment normal government service personnel.

VI. CONCEPT OF OPERATIONS A. Lehigh County has agreed to provide reception and mass care center support for approximately 17,000 evacuees from Montgomery and Berks Counties.

It is planned to relocate residents of the Pottstown Leader Nursing Home in Montgomery County to the Bethlehem /Easton Leader Centers and a portion of the Montco Geriatric Center to the Cedarbrook Facility. The County may be requested to provide ambulance support in this regard.

A listing of Lehigh County ambulance services is provided in Appendix 6, Attachment B. These services will be notified at the time of an incident to deter.nine the number of units available to support Montgomery County in a radiological emergency.

Student Pick-up Points / Host Schools Lehigh County will receive approximately 8,200 school students from l

Montgomery and Berks Counties should an evacuation be required at a time when school is in session. Appendix 8 lists those schools l

planning to evacuate to Lehigh County, the designated host 3 hools I

(student pick-up points), and policy relevant to school evacuation.

. #WruiU1A 4 ATTACHMENT B g LEHIGH COUNTY CIVIL DEFENSE ORGANIZATIONAL CHART d

$ LEHIGH COUNTY EXECUTIVE 2 . DAVID BAUSCH m LIAISON t-

' LEHIGH COUNTY CIVIL DEFENSE DIRECTOR _. . PEMA

$ JERRY DUCKETT PSP g COUNTY AGENT U

5 DEPUTY CIVIL DEFENSE DIRECTOR E STAFF ASSISTANT CLINTON MAC INNIS ADMINISTRATIVE ASSISTANT jl MADELINE H. MUTH . THOMAS NERVINE 1

I l l l l POLICE FIRE MEDICAL

' COMMUNICATIONS SUPPLY JOSEPH DAKES WILLIAM GERNARD GEORGE N0ERKIRK BRIAN K. MC KITTRICK SIDNEY MAHLER CARSON GABLE (A) ERNEST TOTH (A) ,

DALE DAUBFRT l

RED CROSVNASS CARE RACES PUBLIC HORKS RADEF NORM EDM0ND RANDY LILLY RAYM0ND CRAMSEY ERNEST NEIMEYER HARRY BIS.00 (A) DONALD LAUER 4

4 PUBLIC INFORMATION TRANSPORTfTION -

At RABER VACANT ,

1 I

2-B-1 Draf t 4 i

1

CERTIFICATE OF SERVICE DOCKETEC

\

UMA:

l I hereby certify that the foregoing additional information T Off-site Emergency Planning contentions spensored by Limeric MR 15 N0 :29 l Ecology Action was hand-delivered to the following parties marked (*) on March 13, 1984. The remainder c,f the parties 0Ideid Eidt n served by first class class mail, postage pre-paid on March p3T 0C G Epw -

, 1984.

l Lawrence Brenner, Chairman (2) Ann P. Hodgdon, Esq.

'J{ Administrative Judge hpOfficeoftheExecutiveLegalDirector U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission .

Commission Washington, DC 20555 .

W2chington, DC 20555 Benjamin Vogler, Esq.

Dr. Richard F. Cole Office of the Executive Legal Director

g Administrative Judge U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Wachington, DC 20555 Troy B. Conner, Jr., Esq.

Conner and Wetterhahn Dr. Peter A. Morris 1747 Pennsylvania Ave., NW

-gg Administrative Judge Washington, DC 20006 U.S. Nuclear Regulatory -

Commission Wachington, DC 20555 PhiladelphiaElectricCompanyh h Attn: Edward G. Bauer, Jr. /

VP and General Counsel Docketing and Service Section 2301 Market St.

Office of the Secretary Phila., PA 19101 U.S. Nuclear Regulatory Commission Thomas Gerusky, Director W20hington, DC 20555 Bureau of Radiation Protection, DER 5th fl, Fulton Bank Bldg.

Atomic Safety and Third and Locust Sts.

Licensing Board Panel Harrisburg, PA 17120 U.S. Nuclear Regulatory Commission Spence W. Perry, Esq.

W:ghington, DC 20555 Associate General Counsel l FEMA l Atomic Safety and Room 840 Licensing Appeal Panel 500 C St., SW U.S. Nuclear Regulatory Washington, DC 20472 Commission Wachington, DC 20555 Zori Ferkin, Esq.

Governor's Energy Council l P.O. Box 8010 l 1625 Front St.

l Harrisburg, PA 17105 e

, _ - . . . - - ~ ~ . , , , _ - - ,

Jay M. Gutierrez, Esq. Robert Sugarman Esq.

U.S. Nuclear Regulatory Commission Sugarman and Denworth Region 1 Suite 510 631 Park Ave. North American Building King of Prussia, PA 19406 121 S. Broad St.

Phila., PA 19107 Director, PEMA Basement, Transportation David Wersan, Esq.

and Safety Building Assistant Consumer Advocate Harrisburg, PA 17120 Office of the Consumer Advocate 1425 Strawberry Square Angus Love, Esq./Myg,g;1CAid) ,

ardsburg, PA 17120 10 7 East Main St Norristown, PA 19401 Gregory C. Minor Robert Anthony MHB Technical Associates 103 Vernon Lane 1723 Hamilton Ave.

Moylan, PA 19065 San Jose, CA. 95125 Martha W. Bush, Esq.

Kathryn S. Lewis, Esq. Timothy C. Campbell Solicitor's Office Chester County DES City of Philadelphia 14 E. Biddle Street Municipal Services Building West Chester, Pa. 19380 Phila., PA 19107 ,

Steven Hershey, Esq.

community Legal Services 5219 Chestnut St.

Phila., PA 19139 Marvin I. Lewis 6504 Bradford Terrace Phila., PA 19149 Frank Romano 61 Forest Ave.

Ambler, PA 19002 Joseph H. White,III 15 Ardmore Ave.

Ardmore, PA 190Q3 March 13, 1984 _ ,

P_7_ , .

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