ML19330B600

Forwards Limerick Nuclear Generating Station, Preliminary Evacuation Time Estimates in Response to NRC 791226 & 800702 Ltrs Re Evacuation of 10-mile Radius Around Plant. Comments on Rept Encl

ML19330B600
Person / Time
Site:	Limerick
Issue date:	07/31/1980
From:	Conner T CONNER, MOORE & CORBER
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML19330B601	List: ML19330B600 ML19330B602
References
NUDOCS 8008050158
Download: ML19330B600 (8)

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LAW oFFICIS

• y CONNERd: MOORE 1747 PINNSTLVANIA AVENUI. N. W.

Tan 3. CON?tER. JR. WASHINGTON. D. C. 20006 ARCX A. MOORE JR.*

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July 31, 1980 mu> sss ssa Sov anasrrran or n. c. CABLE. ADDRESS. ATOMLAW Occhet Nos. 50-353 and 50-353 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulations

. U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Limerick Generating Station Request for Evacuation Times

Dear Mr. Eisenhut:

This letter is written in response ro your July 2, 1980 letter which referred to an earlier letter dated December 26, 1979 from Brian Grimes.

The December 26, 1979 letter recuested certain time estimates and information concerning evacuation of a 10-inle radius around Limerick Generating Station. Philadelphia Electric Company en-gaged NUS Corporation of Rockville, Maryland to assist in the development of the information required. Attached are six copies of a report developed by NUS dealing in detail.with this informa-tion. Printed copies of the report will be sent to you by NUS as soon as available.

The December 26th letter also requested that comments be obtained from "the principal local officials responsible for carrying out such evacuations" so that a check on evacuation time

estimates could be made.

On March 19, 1980 a meeting was held with County Emergency Management personnel, PEMA, the State Police, and PECO at which time a draft of the NUS report was discussed and distributed, and comments solicited. Six copies of the comments en that draft of the study are attached. As a result of the meeting and the comments received several changes were made to the report. These include addition of the Montgomery County Geriatric and Rehabi-litation Center to the. institutions contacted and studied, and re-evaluation and revision of the route selection in certain sectors.

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o j~ Mr. Darrell-G. Eisenhut July 31, 1980 Page 2 As noted in the report, all of the comments of these offi-cials cannot be finally dealt with until the development of the final emergency plan. However, all of the comments provided by these officials have been incorporated in this report to the extent feasible at-this time.

Should you have any questions or need additional information, please contact us.

Sincerely, ,

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Troy . onner, Jr.

Counsel for

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Mr. Graham Leitch, Plant Superintendant .

Philadelphia Electric Company cu g jd.r/h C/0 3echtel ?over Corporation n; P '. 0 . Box A - Sanatoga 3 ranch " 2 0---

30 Potts cwn, PA 19464 ac I

Dear Mr. Leitch:

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The following cer.nents are submitted en the draft NUS studf en the L1=erick Preliminary Evacuation Ti=e Estimates:

1. I do not kncu the basis for the notification esti=a es, but believe they are overly optimistic for rural areas and for the existing siren network. Because of the siren network's inadequacy, one cust assume that decr-:c-door notification is necessary. Vnile this =ay be feasible in Po :stown in three hours, I doubt verf =uch that it can be accc=pli,hed in rural areas in less than eight hours.

2. The highway =cvement ti=es appear reasonable for fair weather, but I believe that for incle=ent weather, we =us: probably assume an increase of 100 percent in =cve=ent time.

3. The Pennhurs: escinates appear very optinistic for an institutica of that size. It would appear that a non-warning evacuation would take a minimum of four hours and perhaps as much as eight. If one adds to that the ti=e necessary to =arshal the transportation, one would see that eight hours =ight be a =cre reasonable esti= ate.

4 Ne': hav.ng studied the Graterford proble=, I cannot ce==ent en it.

5. The .'rederick Mennonite Ecce wculd probably be ene of the easies: to evacuate and I suggest you use the Montsc=ary County Geriatric Center for your planning esti=ates.

In su=cary, since neither I nor the three county directors have been able to make a detailed study with local emergency service groups of the i Limerick evacuation proble=, it is only possible for us to co==ent when we i see sc=ething which runs counter to what our present level of knowledge would indicate as being accurate. Therefore, we cannot concur en the study but bring these suggestions up as listed in 1-5 above.

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DEPARTMENT OF EMERGENCY SERVICES 14 East 2:ccie Street West Chester. Dennsyivania 19380 Te!echene: 2?5- 4 1-6160 April 22, 1980 Mr. Phil Duca Philadelphia Electric Ccmpar$v_

Limerick Generating Station P. O. Ecx A Sanaccga 3 ranch Potestcwn, Pa. 19464

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Dear Phil:

I have a few corntents concerning the NUS cn evacuation times in the area surrounding the proposed nuclear facility at Limerick. After thinking en the matter I find the times to be optimistic.

During normal weather the times are de' pendent en the cacacity of roads which as I am sure you are aware , are in f air to poor shape and are not what could be called major roads.

Since, as everyone made very clear, we are in the process of develcping the methodology for evacuation planning, I am not sure that we can depend en the estimates provided by normal

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transportaticn planners. In additicn , the variables of mcbil-ination time of the volunteer succor: recuired to notifv the general public and control the evacuation" is cresentiv undefin-able since it would depend to a great degree 'en the skill and scope of the evacuaticn adviscr.

Another concern is tha: cf fuel and breakdowns alcng the route of march which wculd increase the ev m 11 driving time. Another major c'encern is that of adverse weather. As you are well aware in this area in recent years we have becun to experience an increasing number of what" are commonly referred ^

to as ice storms. These storms have a far greater incact en transportation activities than that caused by the ncrmal snow storm. Utilizing snow fall as the adverse weather condition may be totally wrong. It may be necessarv to utilize condi-tiens for exampl._ as occurad en December 19, 1979 in eastern Chester County, northern Chester County, scuthern Montcomerv ~

county as more typical of an adverse weather situation.

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s o-w A -final. mijor area of concerd relates to a specific facility, that beid.c Pennhurst Stace. Center. A requirement

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for 70 ambulances to evacuate patients rom Pennhurse would recuire mobilizing ambulance reserves from Lancaster Ccunty, Chester County, Cecil Ccunty and Newcastle Ccunnv, .. It must

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be remembered that we have to maintain coverage in the areas

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tram which ambu _3 ances are movinc as we_3_, as to previce t,ncse

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being sent-to Pennhurst. Driving time for ambulances from below Elkton er in the area of the St. George's Canal must be >-rocrammed into an analysis of evacuation times.

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. Again, I understand that we are dealing with what is in effect a new science and since nobody really knows that ene-can argue almost any side of a time analysis. Therefore, although there are specific objections to the plans contained in the NUS report, I feel that my best-comment is that it is

-overall far tcc optimistic.

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1. "2 0 EAG LEVILLE, PA.19103 seC - :---- CEP 215-63151CO 5AM u d u L. s .. r , m ems 215431-5103 March 23, 1930 Mr. Graham Leitch Plant Supervisor-PE Co.

c/o SechTel Power ?! ant P.O. Box A Sanatoga Branch Po T T s T o w n., PA 19464 - .

Dear Mr. Leircn:

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As a follow-uo To our meeting of 'c.' e d n e s d a y , March 19Tn concerning planning fcr evacuation from the areas surrounding the Limerick Nuclear Generating Station and The NUS Draft Plan, I would like to express the following:

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Initially I can neither agree,with nor refute some of the information in The NUS draft report scecifically The figures on which they based their calculations. The cars per lane per hour evacuation figure, I believe, does not allow enough time for a " worst case" due to inclement weather. 'et h a t about 10" of snow?

I am also concerned as to how the figures for notification times were obtained. I feel thar additional time could be need-ed to notify The less densely populated areas of the evacucTion sectors in Montgomery County.

The evacuation Time for Pennhurs7 seems To be extremely optimistic at two hours. I feel 4-8 hours would be more real-istic. In conjunction with this thought the Montgomery County Geriatric Center would be a much more logical facility to use as a problem in evacuation rather than the Frederick Mennonite Home.

Also a consideration, would be The mobilization time needed for ambulances to take The non-ambulatory patients out.

This survey seems reasonable but i realistically feel that this is a preliminary study and alot more planning and disTri-bution will be needed for a final overall approved plan.

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Sincerely, _

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S el L. Ely l!

PHcNE: 24 HoVA SERVICs Oecactor

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Commi'ssioners SERKS COUNTY EMERGENCY ?.1ANAGEMENT AGENCY ,

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l UMERICK GEN. STATIGIF Mr. Graham Leitch R ^= C ~ VED Plant Superintendent- PECO '

c/o Bechtel Power Corp. MAR % 81980 -

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P. O. ' Box A

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SUBJECT:

Comments by the Berns t,o unty r mergency Agency RE: The overall PECO Emergency Plan for Limerick Station as pe- your .

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reouest at meeting held March 20, 1980 at your Limerick Plant Site The overall basic plan as discussed en March.20, 1980 is feasible and

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a good base to start from for the three counties involved within the 5-10 mile radius.

The plan certainly'needs alot of kinks removed to make it efficient and workable.

A final draft of the Berks County Emergency Management Agency Plan

- should be completed for your approval prior to the January 1, 1981 date with all of the pieces of the jig saw pu le in place and workable.

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The following are some of my personal observations and constructive

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criticisms which need much more clarification prior to final draft.

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1 The 15 minute warning to all of the residents residing within the 5 mile radius will not work unless a much more specific warning 7 system is devise'd than what was discussed at the meeting.

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2. At one' of our meetings during the early part of 1979 mentioned was the use of powerful. sirens to be installed that would reach all of the residents within the rural areas within the 5 mile radius. Most of the area within the. 5 mile radius in Berks County is rural. What is the status of the sirens? Will PECO foot the cost of the sirens ? If not, other means of dissemination of a possible. disaster must be devised which will reouire more time for notification. -

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3. Another device mentioned was a direct line from the plant to each Emergency Management Agency ( E.M. A. ) of the counties involved. Is that a possibility by the PECO ? y

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4. The maps that were shown to us on March 20, '.980 certainly were about as clear as mud. Why befuddle the issue by giving strange numbers to designated highways which are well known to the iesidents and -

traveling public ? Let U.S. 422 be known as 422W or 422E or whatever direction it heads and not as N-6 or N-7 or some other confusing number.

Let well enough alone. Make a suitable size map with the three county areas large enough to designate readable highways well marked and symbols for Hospitals Fire Departments- Police Stations- Rehabilitation homes etc.

clearly marked.

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5. Burks County Emergency Management Agency should have a Central Communications System under way by the latter part of 1980. At the present time we rely upon telephones and teletype for our communications. We do have a total of 7 different telephone companies which must be fused into one system which will be the 911 when finalization of our Central Communications System is a reality.

6. We must tie in all of the loose ends into our final plan which as I stated should be finalized prior to January 1, 1981 We will be discussing some of the pitfalls with you as we progress with our plan conce rning all aspects of the overall plan for the possible evacuation of residents ;vithin the 5 mile radius, should the need arise as a result of a disaster at the Limerick Plant. .

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Thanking you for. the opportunity to pass on some of the obstacles that

. .ast be overcome in such a short time with a shelter staff consisting of myself-Director of the Berks County Emergency Management Agency and one Administrative Assistant-Robert L. Reber.

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Respectfully yours, ,

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Philip F. hu ick Director-Coordinator PFC/ sjm -

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