ML20104A706

Responds to 841226 Memo Re FEMA Support for NRC Licensing of Facilities.Clarification from PA Emergency Mgt Agency Re Nature & Scheduling of Review of Revised Plans Requested. Index to Revised Plans Requested by 850201

ML20104A706
Person / Time
Site:	Limerick
Issue date:	01/23/1985
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8502010468
Download: ML20104A706 (3)

Text

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50-353 N Federal Emergency Management Agency 1,. Washington, D.C. 20472 j O O N 23 19g5 MEMORANDUM FOR: Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S. Nuc ear Re ulator Commission FROM: R r . imm*

Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

Limerick Generating Station This is in response to your memorandum of December 26, 1984, subject: FEMA Support for NRC Licensing of Limerick Generating Station, in which you request an interim finding by March 1,1985, and as a follow-up to the conference call on January 9,1985, with the Federal Emergency Management Agency (FEMA),

the Nuclear Regulatory Commission (NRC), the Pennsylvania Emergency Management Agency (PEMA), and the Philadelphia Electric Company (PECO) regarding the Atomic Safety and Licensing Board Hearings and offsite emergency preparedness required for full power licensing of the Limerick Generating Station.

As you are aware, the offsite plans that were furnished to us in your trans-mittal of December 26, 1984, differ from the plans FEMA received earlier from PECO that were acknowledged by the State for review purposes by FEMA.

PEMA, in a letter dated January 14, 1985, to our Region III Office (attached),

has stated that they do not object to a review by FEMA of the recently revised plans submitted to us under the Memorandum of Understanding between our respective offices. However, we are seeking clarification from PEMA as to the nature and scheduling of their review of the revised plans, including the review and acceptance of the counties, municipalities, and school districts involved. We will be in continued contact with PEMA through our Regional Office to ensure, if possible, a concurrent review of the revised plans by PEMA as FEMA reviews the revised plans with the Regional Assistance Committee.

It is imperative that FEMA Region III receive an index to the revised plans no later than February 1,1985. This should allow FEMA to prepare a supple-mental interim finding to NRC on the revised plans by May 1, 1985.

Attachment As Stated 8502010468 850123 yg g

{DRADOCK05000

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5- 17 '85 16:10 FEMA REGION III PHILADELPHIA 2 P. 0 i l

O PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY P.o. box 3321 MARRISSU4o, PSNNSYLVANIA 17103 January 14. 1985 Mr. Paul P. Giordano Director Federal lhergency Management Agency -

Region III Curtis Building 6th and Walnut Streets Philadelphia, Pennsylvania 19106 Dear Mr. Giordano I sa aware that the Philadelphia Electric Company, in conjunction with its licensing application for the Limerick Generating Station, has provided the NRC with the latest draft copias of the offsite energency response plans for the three risk counties. 43 municipalities. 13 school districts and two support counties that would be involved in the event of an incident at the plant.

In accordance with the November 1, 1980 Memorandum of Understand-ing Between NRC and FEMA Reinting to Radiological Emergency Planning and Preparadness (45 Federal Register 82713. December 16, 1980), it is FEMA's responsibility "To make findings and determinations as to whether Staca and local emergency plans are adequate and capable of implementa-tion...Notwithstanding the procedures which may be set forth in 44 CFR 350... findings and determinations...may be requested by the NRC...and provided by FEMA for use sa needed in the NRC licensing process. These findings and determinations may be based upon plans current 37 available to FEMA or furnished to FEMA by the NRC."

It is my understanding that the NRC has forwarded the drafts specified in paragraph one to FEMA Region III and has requested the finding and determination authorised by the referenced Memorandus of Understanding.

The Pennsylvania Emergency Management Agency, on behalf of the commonwealth of Pennsylvania, has no objection to this review by FEMA providing that it is clearly understood and explicitly stated in the resultant finding that the offort is not to be considered as an informal review requested by PIMA and in no way comprises, or is related to, the formal review and approval process that will subsequently be requested by PEMA under the provisions of 44 CFR 350. It should also be recognized that the drafts in question were

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JAN.17 '85 16:11 FEMA REGION III PHILADELPHIA 2 P.03

' Mr. Paul P. Giordano January 14, 1985 Page 2 1

primarily prepared by the Philadelphia Electric Company's consultant, and have neither been reviewed by PENA nor, according to information provided to PENA, have they been accepted by the counties, municipalities and school districts involved. Nonetheless, these plans would, in a practical sense, l,

be the basis for the counties, municipalities and school districts responding should an accident occur at the Limerick Generating Station.

FINA will not certify to the adequacy and implementation of the plans or submit them to FINA for formal review and approval as required by 44 CFR 350 until the plans have been finalised, reviewed by PENA and accepted by the counties, municipalities and school districts.

In April 1984 FEMA released its interia findings of based upon plans submitted for informal review by FEMA in December 1983. adequacy FEMA has also issued its report of deficiencies observed during the July 25, 1984 exercise, as well as for the November 20, 1984 supplemental esercise. Inasmuch as the Limerick Generating station is now in a five percent, low-power test mode, PENA would agree that it would be prudent for E FRA to conduct the review requested by the NRC to datermine whether the deficiencies noted earlier by FINA have indeed been corrected.

Sincerely,

- rg MA g _

John L. Patten A

Director JLP/ALBass (Telt 717-783-8150) ces Ronorable Dick Thornburgh Covernor of Pennsylvania Robert L. Rober, Coordinator Berks Co. Energency Management Agency A. Lindley Bigelow, coordinator Montgomery Co. Office of Emergency Preparedness Timothy R. 8. Campbell, coordinator Chester Co. Department of hmergency Services Charles L. McGill, Coordinator Bucks Co. Energency Management Agency Jerry Duckett, coordinator i

Lehtsh County Civil Defense John L. Shannon Bestern Area Acting Director l

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! %o UNITED STATES NUCLEAR REGULATORY COMMISSION

{, .I WASHINGTON. D. C. 20555

%,..... December 26, 1984 HEMORANDUM FOR: Richard W. Krimm Assistant Associate Director e Office of Natural and Technological Hazards

/

Federal Emergency Management Agency FROM: Edward L. Jordan, Director

. Division of Emergency Preparedness .

and Engineering Response Office of Inspection and Enforcement ,

SUBJECT:

FEMA SUPPORT FOR NRC LICENSING OF LIMERICK l GENERATING STATION -

, l On May 8,1984, the Federal Emergency Management Agency (FEMA) forwarded an interim finding report on the offsite radiological emergency response plans for the Limerick Generating Station. At that time, FEMA identified fifteen deficien-cies in the plans and determined that the offsite emergency plans developed for incidents at Limerick were inadequate. Since that finding was submitted revised

'<' , offsite emergency plans have been developed including plans for risk and support counties, municipalities and school districts. These plans have been entered into the record (following Tr 12,848) of the hearings on offsite emergenc currently being conducted by the Atomic Safety and Licensing Board (y preparednessASL delphia, Pa. These same plans have also been provided to the NRC by the applicant in the course of preparing for the hearings. -

In prefiled testimony submitted by FEMA to the Limerick ASLB, FEMA indicated that findings and determinations on the Limerick offsite plans would be provided in an expeditious manner upon request cf the NRC. The purpose of this memorandum is to request FEMA tc ;; edd: the NRC with findings and detenninations as to whether the revised county and local emergency plans for Limerick are adequate and capable of implementation and whether the previously identified deficiencies are resolved by these plans. Although we understai.J FEMA may have already received copies of the referenced plans, a set of these plans is being furnished by the NRC for your convenience. A list of the plans being provided to FEMA is enclosed with this memorandum. Based on your December 26, 1984 telecon with Shelly Schwartz, I understand that FEMA has agreed to provide a supplemental interim finding for Limerick by March 1,1985. .

A -

wp . Jor . Director M ision of rgency Preparedness and Engineering Response Office of Inspection and Enforcement

Enclosure:

List of revised Offsite Plans . .

for Limerick cc: See Attached

-CONTACT: R. T. Hogan, IE -

492-4866 o l^^9 Qusvi( fh I @MWW /

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