ML20128G787

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Testimony of FEMA Re Graterford Inmates Revised Contentions. Reasonable Assurance Exists That Emergency Response Training Will Be Offered to Civilian Personnel.Certificate of Svc Encl.Related Correspondence
ML20128G787
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 07/05/1985
From:
Federal Emergency Management Agency
To:
References
CON-#385-719 81-465-07-OL, 81-465-7-OL, NUDOCS 8507090322
Download: ML20128G787 (15)


Text

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' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 09tKETED uss=C Before the Atomic Safety and Licensing Board

'85 JA -8 P12 :07

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In the Matter of: )

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Philadelphia Electric Company ) Docket Nos. 50-352-OL

) 50-353-0L (Limerick Generating Station, )

Units 1 and 2) ) ASLBP No. 81-465-07-0L

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FEDERAL EMERGENCY MANAGEMENT AGENCY'S TESTIMONY ON CERTAIN REVISED CONTENTIONS OF THE GRATERFORD INMATES C. Training The inmates allege there is no reasonable assurance that emergency response training will be offered to civilian personnel such as civilian bus and ambulance drivers, rescue squads, and any other such personnel expected to assist in the implementation of the Pennsylvania Department of Corrections Radiological Emergency Response Plan in support of the State Correctional Institution, Graterford.

Planning Standard O. of NUREG-0654/ FEMA-REP-1, Rev. I and 50.47(b)(15) call for radiological emergency response training to be "provided to those who may be called on to assist in an emergency." In addition, element 0.1 states that "each organization shall assure the training of appropriate individuals." As Appendix 19 (page E-19-1) to Annex E, Fixed Nuclear Facility Incidents, to the Commonwealth of Pennsylvania Disaster Operations Plan, dated November 1981 states: "The Pennsylvania Emergency Management Agency (PEMA) has the overall responsibility for providing radiological response training programs in the Commonwealth."

Information supplied to FEMA by Donald F. Taylor, Director of the Office of Training and Education at PEMA ( Attachment 1), indicates that PEMA will be directly responsible for the training of bus drivers.

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Based upon the information supplied in Attachment 1, it is FEMA's understanding that Mr. Taylor wrote to the six (6) bus companies that will transport inmates from Graterford in the event of a radiological emergency, offering training to bus drivers. Mr. Taylor has not received a response to his offer, to date. A document entitled " PLAN OF INSTRUCTION, NUMBER SEVEN, D0SIMETRY AND DECONTAMINATION SEMINAR FOR EMERGENCY PERSONNEL, Office of Training and Education, Pennsylvania Emergency Management Agency, January 1985," (Attachment 2) has been forwarded to FEMA by Mr. Taylor. Besides the information provided in the above-referenced lesson plan, Mr. Taylor has stated (in a telephone conversation on July 2,1985) that PEMA would also be responsive to address other interests raised by the bus companies or drivers as part of the training process.

Mr. Taylor plans to personally visit the aforementioned six (6) bus companies to urge them to participate in a training session. The bus companies will be informed that the training will be conducted at a location and at a time that is convenient to the bus drivers.

PEMA has also committed to providing the same training to ambulance drivers expected to be part of an emergency response that will be given to the bus drivers.

Based upon the fact that this training has been given at other sites in Pennsylvania in the vicinity of commercial nuclear power plants and based upon the information supplied by PEMA which is site-specific to the State Correctional Institution, Graterford and the Limerick Generating Station, FEMA feels that there is reasonable assurance that emergency response training will be offered to civilian personnel expected to be involved in the implementation of the Pennsylvania Department of Correction's Radiological Emergency Response Plan.

ATTAc H ME M T I F- -

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F.--- Testimony - -

( F' Ecri Perkin i M counsel -

Governor's lhergy M- 41 L

- - , , ,, ,,,, w Oert<= of training stacathm i Se followiny items are topica on idhis I amt to testify at the rW hearings conoarning the evacuation'of fn:st the state C-+.ional Institution at Graterford. -

Please contact me at your convenience if you have any questions w- -- iT thf.s taastimomy.

1. Imtters fece ma to the mix bus carpenias that will transport prisoners fmn Gratarford in the event of an evacuation caused by an accident at the Limerick enerating  !

Station were mai.ted on April 4,1985. These letters oMama  ;

dosimetry training to the bus drivers Mc will be empicyed in  !;

this endeavor. Tu date, to responses fan these six b'us ~

companime have been var =4ved.

2. Se dosimet:ry training that will be provided to ,

these' bus drivers is outlined in the attached plan of ireaucuan.,,

Decontamination monitoring g1 ---- ".wes wi.11 also be examined as there is a runote poss4h414ty that, if doelmstry is Wi14=ad by these bus drivers, they will also be imolved in scue mannae with deoce#-ina+-inn nonitoring. Bis training will ensure j their knowledge of that process.

3. The dosimetry training will be conducted by PIBR. -

i Any such training that will be required is for the direct benefit of another commestwealth Agency. Thus, it is PIBM's roeptz=th414ty to do the trainirig. %s training that has been performed for local murdcipalities (cities, boroughs, townships),

school bus drivers, fire fighters, etc. should have been perrmmad by the gpropriato county. P.L. 1332 aces that roeptmaibility on the county. Bowever, due to their ility and/or tantilling-nees to conduct this training, Pb41W%ia Riectric expany espicyed a consulting fim to fulfill the training responsibilities of the involved counties. .

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Scri Perkin Jtane 28,1985 Page tw .

4. A progran designed to persuade the a- - :4. M six bus - g- Aa= to accept titis doshnetry training will be -

' implamented in lata J4y and early August,1985. Bis implamen-tation will involve personal visits by PWR personnel $se) to sects of these bus componise ao as to personally urge that to accept this m i-< 5 ,

5. training enestons that are conducted will be scheduled in a and at a time conveniant to the bus dcivers themselves. It is prestased that such trainf5 will be conducted at, or near, the bus company hea%oartars. ,

, '6. No aVQ will be made by PWR personnel tus) to -

i conteet indiviasm1 bus drivers for such trainhg in the event  ;

. the bus t--- =Biam rem it. Such an attept is not ethical and, -

omrtainly, is not within our purview. muover, every effort ,l will be made by me to persuade the bus ocupanies to accept auch ,  ;

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7. him training and refresher training will be made available yearly to the drivers of each bus oczqpeny that moospes Lt. .

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l ces John L. Petten '

Belph Hijpert I 9

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AT TA CH M E MT 2.

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PLAN OF INSTRUCTION NUMBER SEVEN DOSIMETRY AND DECONTAMINATION SEMINAR FOR EMERGENCY PERSONNEL

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Office of Training and Education Pennsylvania Emergency Management Agency January, 1985

PLAN OF INSTRUCTION ,

NUMBER SEVEN DOSIMETRY AND DECONTAMINATION SEMINAR FOR EMERGENCY PERSONNEL Rationale Despite the extraordinary precautions and safeguards in effect, there remains the possibility of unplanned radiological releases from the nuclear-powered generating plants located within the Commonwealth of Pennsylvania. In minimizing the risk to emergency response personnel who may be required to function in a potentially hazardous environment, there is a need for such personnel to know how to monitor their personal exposure to radiation, monitor exposure of other persons, and conduct proper decontamination monitoring procedures.

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Purpose This seminar is designed to provide emergency personnel with the knowledge and skills that will permit them to monitor their personal exposure to radiation and to conduct decontamina-tion monitoring procedures that will be employed in appropriate locales in proximity to nuclear-powered generating plants.

Objectives Upon completion of this seminar, participants should be able to do the following: .

1. Develop an understanding of the government response to disasters.
2. Demonstrate an ability to properly utilize the designated dosimetry.
3. Know the acceptable levels of radiation during an incident at a fixed nuclear

(, facility.

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l[ 4. Demonstrate an understanding of maintaining appropriate records.

5. Understand reception centers, mass care centers, and where decontamination monitoring procedures are utilized.
6. Demonstrate the proper use of a survey meter.

Qualifications for Attendance All county emergency management coordinators, members of the county emergency management organizations, municipal emergency management coordinators as recommended by their county coordinators, and any other person approved by the Pennsylvania Emergency Management Agency are eligible to attend this seminar.

Summary of Subject Areas Subjects Hours

( 1. Introduction and Overview 0.1

2. Government Response to Disasters 0.5
3. Dosimetry 0.9
4. Decontamination 0.9
5. Summary and Conclusion -

0.1 Total 2.5 Units of Instruction

1. Introduction and Overview O.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> The instructor will introduce all those persons who should be made known to the students. Then, through a brief lecture, the instructor will explain the purpose of this seminar and briefly review the subjects that will be discussed.

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( 2. Government Response to Disasters 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

Reference:

a. Federal Civil Defense Act of 1950, P.L.81-920. ,
b. Pennsylvania Emergency Management Services Act of 1978, P.L. 1332.
c. "The Pennsylvania Emergency Manage-ment Agency," a brochure.

Presentation: The instructor will lecture on the development of civil defense in the United States with an emphasis on Pennsylvania. The evolvement into emergency management will be explained and its present mission described. The involvement of emergency management in planning for incidents at fixed nuclear facilities will be described.

The PEMA brochure will be utilized as a hand-out.

3. Dosimetry 0.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />

Reference:

Commonwealth of Pennsylvania; Disaster Operations Plan, Annex E (" Fixed Nuclear

( Facility Incidents"); November, 1981; Appendix 16 (" Radiological Exposure Control").

Presentation: a. Through lecture and discussion, the instructor will demonstrate the proper use of the three dosimeters and the charger.

(1) CD N-730 (or DCA 622)

(2) CD V-742 (3) TLD (thermoluminescent dosimeter badge)

(4) CD V-750

b. Through lecture and discussion, the instructo'r will explain the following acceptable levels of radiation concerning fixed nuclear facility incidents.

(1) 25 R (2) 15-20 R (3) 5R L

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( c. Through lecture and discussion, the instructor will explain the proper record forms and how they should be maintained. ,

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4. Decontamination 0.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />

Reference:

Commonwealth of Pennsylvania; Disaster Operations Plan, Annex E (" Fixed Nuc1 car Facility Incidents") ; November, 1981; Appendix 16 (" Radiological Exposure Control").

Presentation: The instructor, through lecture and discussion, will examine reception centers and mass care centers. Then, decontamination monitoring procedures will be identified and demonstrated.

The proper use of a CD V-700 will be explained and demonstrated. The following will then be discussed and explained:

a. Background radiation (usually .03 mr).
b. Radiation above background of .05 mr or more will be referred to a physician.

( c. Thyroid must not exceed .1 mr.

d. Appropriate record keeping.
5. Summary and Conclusion 0.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> The instructor will briefly summarize the content of this seminar and then bring it to a conclusion.

t Evaluation All participants will be requested to complete the evaluation form that is marked ", Attachment A."

Deployment This seminar will be presented in each county within the Commonwealth that is involved with nuclear-powered generating plants.

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. Attachment A PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY OFFICE OF TRAINING AND EDUCATION Course Evaluation for Dosimetry and Decontamination Seminar I. General - Check space preceding most appropriate answer

1. My reaction to this seminar can best be described as:

( ) a. The seminar met my needs far beyond my expectations.

( ) b. The seminar met my needs in an adequate manner.

( ) c. The seminar did not meet all my needs.

( ) d. The seminar did not meet my needs at all.

2. My estimate of the instructor's capabilities can best be described as:

( ) a. The instructor was excellent.

( ) b. The instructor was good.

( ) c. The instructor met most of my needs, but some needs were not addressed.

( ) d. The instructor failed to meet my needs.

3. The room in which the instruction was conducted can best be described as:

( ) a. The room was excellent.

( ) b. The room was good.

( ) c. The room was not quite adequate.

( ) d. The room was, totally inadequate.

II. Meeting Objectives

1. My understanding of the government response to disasters can best be described as:

( ) a. I fully understand the government response to disasters.

( ) b. I understand generally the government

(, response to disasters.

( ) c. I do not understand the government response to disasters.

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([ 2. My knowledge of the proper use of dosimetry can be described ast l

( ) a. I fully understand the proper use of dosimetry.

( ) b. I understand generally the proper use -

of dosimetry.

( ) c. I do not understand the proper use of dosimetry.

3. My knowledge of the acceptable levels of radiation during an incident at a fixed nuclear facility can best be described as:

( ) a. I fully understand the acceptable levels of radiation.

( ) b. I understand generally the acceptable levels of radiation.

( ) c. I do not understand the acceptable levels of radiation.

4. My understanding of the proper maintenance of appropriate records can best be described as:

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( ) a. I understand completely the appropriate

( ( ) . b.

records and how they are to be maintained.

I understand generally the appropriate records and how they are to be maintained.

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( ) c. I do not understand the appropriate records or how they are to be maintained.

! 5. My knowledge of reception centers, mass care centers, and i where decontamination monitoring procedures are to be utilized can best be described as:

( ) a. I fully understand reception centers, mass

, care centers, and where decontamination t

monitoring procedures are to be utilized.

( ) b. I generally understand reception centers, mass care centers, and where decontamination monitoring procedures are to be utilized.

( ) c. I do not understand reception centers, mass care centers, or where decontamination monitoring procedures are to be utilized.

6. My knowledge and understanding of the effective use of a survey meter can best be described as:

( ) a. I understand completely the use of a survey meter.

( ) b. I understand the proper use of a survey meter,

(, but have some questions about such use.

( ) c. I do not understand how to use a survey meter.

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( III. Recommendations In the space below, please submit any recommendations you may have regarding this seminar.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 35 Ji-8 P12:07 In the Matter of ) -

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Philadelphia Electric Company ) Docket Nos. 50-35$03EId}[,(SE6VK'

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) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the Federal Emergency Management Agency's Testimony (of Richard Kinard and James Asher) on Certain Revised Contentions of the Graterford Inmates in the captioned matter have been served upon the following by deposit in the United States mail this 5th day of July, 1985.

Helen F. Hoyt, Esq. Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Docketing and Service Section Dr. Richard F. Cole U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Ann P. Hodgdon, Esq.

Washington, D.C. 20555 Counsel for NRC Staff Office of the Executive Dr. Jerry Harbour Legal Di rect or Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

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Atomic Safety and Licensing Angus Love, Esq.

Board Panel 107 East Main Street U.S. Nuclear Regulatory Norristown, PA 19401 Commission Washington, D.C. 20555 Robert J. Sugarman, Esq.

Sugarman, Denworth &

Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr. 16th Floor, Center Vice President & 101 North Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 John L. Patten, director Pennsylvania Emergency Mr. Frank R. Romano Management Agency 61 Forest Avenue Room B-151 Ambler, Pennsyl vani a 19002 Transportation and Safety Building Mr. Robert L. Anthony Harrisburg, PA 17120 Friends of th Earth in the Delawre Valley Kathryn S. Lewi s , Esq.

106 Vernon Lane, Box 186 City of Philadelphia Moylan, PA 19065 Municipal Services Bldg.

15th and JFK Blvd.

Charles W. Elliot, Esq. Philadelphia, PA 19107 325 N. 10th Street Easton, PA 18064 Thomas Gerusky, Director Bureau of Radiation Miss Phyllis Zitzer Protection Limerick Ecology Action Department of Environmer.tal P.O. Box 761 Resources 762 Queen Street 5th Floor Pottstown, PA 19464 Fulton Bank Bldg.

Third and Locust Streets Zori G. Ferkin, Esq. Harrisburg, PA 17120 Assistant Counsel Commonwealth of Pennsylvania Jay M. Gutierrez, Esq.

Governor's Energy Council U.S. Nuclear Regulatory 1625 N. Front Street Commission Harrisburg, PA 17102 631 Parl Avenue King of Prussia, PA 19406

James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commissin P.O. Box 47 Sanatoga, PA 19464 ~

Timothy R.S. Campbell, Esq.

Director Department of Emergency Services 14 East Biddle Street West Chester, PA 19380 Mr. Ralph Hippert Pennsylvania Emergency Management Agency B151 - Transportation and Safety Building Harrisburg, PA 17120 Theodore G. Otto, Esq.

Department of Corrections Office of Chief Counsel P.O. Box 598 Lisburn Road Camp Hill, PA 17011 l

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Michael B. Hirsch l

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