ML20094E592

Amended Answers to Util First Set of Interrogatories Re Offsite Emergency Planning Contention Lea/Foe 24.Certificate of Svc Encl

ML20094E592
Person / Time
Site:	Limerick
Issue date:	07/23/1984
From:	Anthony R ANTHONY, R.L.
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20094E587	List: ML20094E579 ML20094E592
References
OL, NUDOCS 8408090263
Download: ML20094E592 (6)

Text

r .. UWi% CLEAR REGUL/ TORY COMMI:dio:. . . ATC;.I; AFETY AI:5 LICE 3ING IiOARL

.[ REr Phila. Elec..Co. Lincrick Ger..stn. Deci:e t No. 50-352,353 Units 1 nnd P July 23,1CE4 AMEUDED AESWERS SY ANTHONY / FOE TO FECC's FIEF SET OF INTERROGATORIES RE. ' OFF3ITE EMERGENCY PLANNING CONTE." TIC: LEA /?CE M.

28. (a ) Valley Forge Park abuts the .:enna. Turnpike on the scuth and the Schuylkill L R$ ver on the east. King of Prussia lies adjacent to the park

-cn the' south and cast. The park has steep hills; K.cf P. is more rolling.

(b) We' are still gathering these figures. (c) Same as b. (d) The con-

-g:stion points would be Valley Forge Park (VFP) entrances,Schuylkill Expy.

, intersection with #202, Penna. TPK. toll cooths, RTs # 23 and 252. Our anal-

.ynis of.the extent of the coricection and duration is still being compiled.

29. We do not agree with the EHM study on vehicle queuing but we have nct completed omrtotal figures.

30. The HHM study overlooks the traffic congestion and blockages Tn all the highways in the Valley Forge /X ing of Prussia area and especially nt the intersections specified in (d) above. Additional access points would n t solve this prob 1cm. The only possible answer would be:re-routing of all evacuation traffic comnletely nway frc, tne VFP/K.of P. area.

31. See ./ 30.

'32.,We disagree with Hb3 dr.tn. cvocuation time estimates,and conclu-Dions. The concidsion from our study is that there will be a panic sit-guationintheVFP/KOPareaincaseofanuclearalertandthattheaccess

t the Penna.T?E will be blocked for at 1cass 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and all the highways e

4t in the X.o P. area , including the EPWY.and RT.202 will be ,similarly blocked.

33. All traffic frodpPZ would have to move north,then east and west.

ll We expect to call the following witnesses:

ATTACHMENT #2

" R:bert L.Rowland, District Fncineer, PennDot.

VJ11ey Forge Nat. Park Manager. U.S. Nat Park Serv. Regional Director,Phila.

Manager Penna. Turnpike, Valley Force Div.

Director Penna. State Police, Valley Force Dist. .

'Piul Bartle, Chairman, Montgomery County Cormissioners.

Upper Merion Twp.: Ralph Volpe, Chairman, Ronald Wegenmann,Mgr., John R. Waters, Fire, Carl A.Mattia, Chairman, Advisory Board.

Managers of Kinc of Prussia Shopping Malls. '

C': Ju'dges Brenner, Cole, Morris, FEMA,PEMA. Re pectfully substi,ted, cthe on NRC counsel, PEcc,, Commwl. , LEA,.crv.rTat a 4. 3x / . 4 n 4 %, o nwA [ ,

f.Mnvion,po.

& a_

y - *

'Please fill out and return to: Limerick Ecology Action "o- P.O. Box 761 Pottstown, PA IS4G4 L.

gt-

'Name of School: ' Spring-Ford Area School District Contact person for evacuation planning: Dr. William A._Relliver

. Mailing Address: 199 Bechtel Road, Collegeville, PA 19426 Phone: 489-1666 Has a first draft Radiological Emergency Responso Plan for Limerick been completed? . Yes q

If not, what is the status of cvacuation planning: Initial draft is beint, s rewritten.

Is public input being incorporated into your plans? YES If yes. how? A tentative draft of the plan will subsequently be available

. for public inspection, enmment and critical review prior to any formal action by the Board of School Directnrs.

ATTACHMENT #3 a

1

e e

• O W-

- . . - - - - +

ll - .

y COUNTY OF MONTGOMERY mal

• t PA ,.,y.

m r A K E F % r*u. a .l h 4-, 31f h _g A U.A .'4 . M YL E S a t A C. a; ANNING

• '7d * 'gg.'s OEPARM EN T OF PUULIC WORKS Mgg/6 A. W e ' A R W. P E, L;sicToa OFFICE OF EMERGENCY PREPAREONESS DIV!SION OF PUEUC SAFE

1o0 WILsCN BOULCVARD JOSEPH D. HAM 3L*CN. D;k1COR EAGLEVILtE. PENNSYLVANIA 19403 (215) 8531 $1oo A.12.*DLEY BIGtLDW, COOsbDe ATOR July 10, 1984 ,

Mr. John L. Patten, Director Pennsylvania Emergency Management Agency P.O. Box 3321 Harrisburg, PA 17105

Dear John:

With the exercise of t.he Limerick RERP scheduled for July 25, 1984, only two weeks away, I have advised the County Co=missioners of the status of our plan and my estimation of our ability to adequately imple=ent it. In short, there 1~ insufficient time remaining f or many municipalities to receive the additional training needed to properly demonstrate icple=entation of the RERP.

S veral local Emergency Management Coordinators are " going it alone" ; they lack in EOC Staff of any kind. In other municipalities cnly minimal staf f is on hand and a lack of altemates or depth at key posittens -as evident. * ~

Locally, more training is still needed f or Radiological Monitoring / Decontamination tea =s Staff, , Police Departmen ts , Pire Co= panics , Ambulance Squads , and cu .icipal EOC in the area of facilities and equipment, there is still much to be done; ie.,

tTlephone equipment, signs, dosimetry, etc. I have conce ns that the munici-

'. p lities could demonstrate that these plans can be implemented, without having the physical resources in place and operable.

As I understand it, this exercise has a two-fold purpose: 1) to demonstrate an ability to im;rlement emergency plans effectively to Federal authorities, and 2) to provide the participants with an opportunity to evaluate their emer-gency plans as they have been developed so far, in order to identify and make

.hanges as applicable.

~

At

• this writing, I believe only five municipalities will be suf ficiently staf fed and r. rained to merit an evaluation by Federal observers. Perhaps another ten will grade:1.

be minimally staffed and would be willing to participate, but not to be

• ATTACHENT #4 vun

[ k3

~

Menroomery County Siuntennial

1. ~; f N, ~'S X Celefratica of We Centuria

%s";f *

~~ '

f ce 1

Thursday, Anril26,19M Philadelphia Inquirer 21-M EDUCATION -

Board ~ won't sign evacuation pact fly Maura C. Ciccare!!! ,

spaw = rne imm,

• 'he

. Lower Merion school board s0Wer Mer10n has refused to sign an emergcncy.

evacuation agreement with the' ral disasters, including an incident Montgomery County Office of Emer. at the Limerick Generating Station."

gency Preparedness but has agreed The board voted unanimously to to let the county use its buses and drivers in the event of a natural send the letter in lieu of the signed disaster agreement, deleting "an incident at Therejectedagreementwaspartof . the Limerick Generating Station" a Philadelphia Electric Co. evacua. and keeping

• man.made or natural tion plan in the event of an accident - disasters."

at the Limerick nuclear power plant "Of course it would be our natural in Montgomery County. Instinct to help" in the event of a At Monday's meeting. board mem. disaster, Mrs. Senes said.

bers Meridyth Senes and J. Roger Williams said,"I would feel better Williams Jr. said that a letter from dustsending aletter. enclosing forms the board would offer the county use saying,'This is what buses, facilities of buses and facilities in an emergen. and equipment we have. It's here if cy. But the board, Mrs. Senes said, you need it' We would use our best would not be" meeting PE's needs"to efforts to help the evacuation plan."

get the Limerick plant approved. Pugh said the board would review Philadelphia Electric must bave a final copy of the letter before send.

complete evacuation plans for the 10 ing in itother to thebusiness, county agency, the board ap-mile radius around the plant to be certified by the Nuclear Regulatory proved an amendment to the atten-Commission, said James B. Pugh, the dance policy for students who live near Iower Merion liigh School.Stu.

Tchool superintendent. Lower Mer. dents from the Welsh Valley MJddle ion is 27 miles from Limerick, but School. will be affected by the the Montgomery County office has asked for help from all school dis. change. Most stucents go through thePenn tricts in the county, he said.

The company has been asking Valley Elementary School and the middle school with the same group neighboring communities to help in of classmates. When a class gets to the evacuation planning and has re.

ceived a great deal of resistance from high school, it is split up. Students who live within walking distance of local authorities.

The requested agreement called 14wer Merion go to that school and for the school district to " provide. the rest go to flarriton fligh School.

The amendment will permit stu.

buses and drivers to the maximum - dents to choose which high school cxtent possible, for the use during an they want to attend if they live near emergency, for transportation of in.

IAwer Merion. If students choose dividuals should an evacuation be Ilarriton, they will be bused from required of Montgomery County rest. Lower Merion to liarriton.

dents affected by man.made or natu.

7l 0 /**? ;y 0

• Q Mif}E .. l$ @ Q t% f f":7 7 'V Cf9"10?Yht?

%r t.0f fiD @hs W b MiHM WOO u

$l0h.9$% O 4 . (Continued from page one)

.,n another matter at .tast week,s contact oth the LCB in Harrisburg. which to pay the fine.

and they had stated their office had in addition Friel said a recend set township meeting, resident Deborah been in touch with the Iower Salferd of charges is pending against the Brown asked about the township's Township police about their jurisdie- Lederach Station in connection with participation in this Wednesday's tion in the matter. Township Police additional charges about noise and emergency response drill being co..

Chief Terry Scholl said he had been sales on Sunday m a citat on dated ordinated by the Pennsylvania Emer -

gency Management Agency. The contacted by the LCB wh;ch reiter- June 18. He said a hearing date for drill is for a response plan in the sted the fact that the township police the June 18 charges is pending. but, event of an emergency at the-have the jurisdaction over areas with the backlog of cases, it could Limerick nuclear power plant.

l outse6e the tavern and the LCB has take four to six weeks to set up a Mrs. Brown said, "The more I've ?

control over things lealde the build- hearing in Philadelphia. read 'about the plan the more ing. Scholl added.. "It's not my Friel explained that under the concerned I've become. A section of

._ ' Q for what goes on state Liquor code if an establish- this township is in the.10-mile radius I

. indle."

Su , Jay Moyer added, ment has three separate citations of the Limerick plant I see problems "We@re doing everything within the within a four.ycar period, the LCB with this plan even though it's jus has the right to suspend or revoke paper drill."

law to control the problem, I'm very the license o' that establishment. Chief Scholl said, "We, like most disappointed with the" operation When the LCB was asked why the townships, are just getting set up for there." Moyer added that Simone citation and hearing process for the an emergency response. We will be had been called supervisors in different on two to talk toocca.

the Lederach Station has taken so many participating in a learning sense. '

months. Bruce Bicken, assistant Some of our peroncel have gone to ..

sions and he thought it was a waste counsel for the LCD noted, "The training sese,ns, but we are not of 'ime to ask hins to come in again. citation process can take four to six ready at this point to implement a Roth told the. ressdentas that the mooths..Following an investigation, . -reallmass evacuation." Chief Scholle township would be la touch with p;

i John T Hale director of the Bureau the LCB legal office may take up to . said the township has asked that they ^

90 days to determine if there is be allowed to participate but not to .

' of Enforcement of the LCB, to press sufficient information to proceed. be graded at this point.

him for a hearing date for the . The LCB will then decide if a hearing

- citations against the lederach Sta- date should be set."

tion and **to see what kind of clamp Mrs. Brown said she was con- Y Joe Simone, who was contacted by cerned that if this was the only drill ~ c3 we ens 'put on it." Roth said the phene this week said "I've spoken conducted by the PEMA, the obser. - T township would consuler sending to a lot of people living around me. vors mayconclude thatlowerSalford traascripts of the. recent township and they're not making a big deal is ready to respond in case of an , fca.k

, meetings for evidence at the upcom- about it. It's only these two couples. SV

lag LCB hearings. I'm trying to solve the problem. This emergency. However, both Supervi. '

Garrity said they will inform the is not like living next door to a home. sors Roth and Moyer said they did.

township residents when the hear. this is a 250 seat club. I don't know if not think the drill was to see if the4 N

s es lag is scheduled and they would Ican get to a point to satisfy them." township was ready, but as a start for. :l C

.' encourage concerned residents to Simone said since receiving the an emergency plan. '

attend. complaints from the neir.hbm. he [p The supervisors also reported they has covered over the hay window and Chief Scholli added that the town- G' had received a copy of a letter from the glass door in the foyer. He said ship was asked by the county to set  ?

Rep. Raymond Bunt, Jr. (R.147th) he had also contacted Wargo Interior up an active emergency rnanagen ent 5 which had been sent to Hale concern. Systems of Hatfield. an accoustical team, which the chief currently en ing the ongoing noise problem at the - contractor, to come out to the heads. Using a plan devised by a Imderach Station. Rep. Bunt agala restaurant and make a proposal on private contracting firm, Energye,

, . urged the LCB to espedite action what could be done to better sound-

' against the sightclub and to set a proof the building. f

- heerlag date.

Consultants of Harrisburg, lower i #j Paul Fetch, vice president of Salford has been given directions for ;

i- William Fransenhed also provided Wargo, said he had been out to the 'its portion of the plan from the Q  %

' the - _pL with acopyof aletter laderach Station several weeks ago, Montgomery ' County Emergency ,, d j dated July 6 from Hale outlining the and he is row in the process of Management Agency. t E L ettellos action agalast the getting a proposal together to " keep i Station for: sales ca Sun , the sound down." Chief Scholl added that a siren hasi I}2, b day after 2 a.m.1 permitted ester. been set up in the area of Hoffman g , x Sirnone added, "The , residents road, primarily as a warning device's c.d

teinment when sale of alcoholle ' make statemens about' turning the for an emergency at the LimerickW is prohibited; sale of band down, but you have to have a plant. He said the Hoffman road area M N@

[ beverages during prohl. ' certala volume to entertain. Obvious-

' . -bited, hours and the use of lood- ly scenething has to be worked out. plus other sections of the township [C <j

' fallinto the 10. mile EMZ(emergencyy , . i 1 speakers whereby the sound of mask Any club which has music, you're management zone). , qk.

' could be heard outside. goin to hear it outside the build-

,, A check with the LCB office in , lag.'g' The chief also reported that theg,-

.. township police committeeis looldag - *.

6 Harrisburg this week showed that '

• Simone said he felt he was trying lato the wording of a Dew ordinancek the Imdersch Station has already to cooperate with the neighbors, which would limit the use of firearmsQ pleaded guilty to the charges listed adding that he had put a trash can- in the townshipc The chief said the$:

above stemming frora incidents in out front, and he had an employee purpose of the ordinance would be tow

• . Apr5 and May of this year. Frank who daily went about 11 e area with a . limit rather than prohibit the use of /*,

Friel, LCB assistant supervisor, said tra-h bag. The club owner noted, firearms. - . 'W"-

thatthe Imderach Station had waived "The residents should be a little Chief Scholl said, "This is not a e ,

the rimht of a hearing, and on July 13 more tolerant, they could be a lot rural farming community anymore. I?,,

the LDB imposed as $850 fine. Friel worse off with something else know residents like hunting, but this '

said the estebushuseat had 20 days la there." . ordinance is now necessary." ' (,,, .

2 _e _ -

p.. ,

(,.

).

J CERTIFICATE OF SERV CE

. C+90KETEn USkRC I, J4aureen Mulligan, hereby certify that I have served the

. foregoing supplemental responses to interrogatories rgguested by. Philadelphia Electric Company upon the following sMvi66-31#R)':21 lar deposit in first class mail, postage prepaid., expect for those

- marked -(*) who have been served by express mail, thisfth., day of August 19%. -

00c Q ;g ,, g .,

= u t:Cr I Lawrence Brenner, Chairman (2) Ann P. Hodgdon, Esq.

b ,, Administrative Judge F Office of the Executive Legal Director U.S..Nuplear Regulatory U.S. Nuclear Regulatory Commission ,

-Commission Washington, DC 20555

W

:Thington, DC 20555 Benjamin Vogler, Esq.

E.Dr. Richard F. Cole Office of the Executive Legal Director Administrative Judge U.S. Nuclear Regulatory Commission

' UoS. Nuclear Regulatory Washin'g ton, DC 20555 Commission-Wrchington, DC 20555 Troy n. Conner, Jr., Esq.

Conner and Wetterhahn

~ Dr. Peter A. Morris 1747 Pennsylvania Ave., NW

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

Philadelphia Electric Company

=Wrchington, DC 20555 Attn: Edward G. Bauer, Jr.

'*P .ind General Counsel Docketing and Service Section 2301 finrket St.

' Office of the Secretary Phila., PA 19101

-U.S. Nuclear Regulatory Commission Thomas Gerusky, Director W21hington, 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. .

W2chington, DC 20555 Associate General Counsel FEMA Atomic Safety and Room 840 Licensing Appeal Panel 500 C St., SW Washington, DC 20472 U.S. Nuclear Regulatory

. Commission ~

W20hington, DC.20555 Zori Ferkin, Esq.

Governor's Energy Council, P.O. Box 8010

1625 Front St. '

Harrisburg, PA 17105 e

m... .

.