ML20090D962

Response to Limerick Ecology Action Second Set of Interrogatories & Request for Production of Documents on Offsite Emergency Planning Contentions.Related Correspondence

ML20090D962
Person / Time
Site:	Limerick
Issue date:	07/16/1984
From:	PENNSYLVANIA, COMMONWEALTH OF
To:	LIMERICK ECOLOGY ACTION, INC.
Shared Package
ML20090D955	List: ML20090D952 ML20090D962
References
OL, NUDOCS 8407190212
Download: ML20090D962 (32)

Text

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HELATED Cha C:4DENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BO[ h [

In the Matter of  :

Docket nom 50%d El1 :59 PHILADELPillA ELECTRIC COMPANY  : 50-353 (Limerick Generating Station,  :

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c Units 1 and 2)  :

RESPONSE OF PENNSYLVANIA DIERGENCY MANAGEMENT AGENCY TO LIMERICK ECOLOGY ACTION'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS ON OFF-SITE EMERGENCY PLANNING CONTENTIONS INTERROCATORIES

1. Provide a copy,of all information relating to the PennDOT traffic

. analysis done for the Limerick Plume EPZ (cited by PEHA as the source for traf fic. flow estimates indicated on Limerick Plume EPZ maps).

Provide all information that was used to determine the vehicle number and time estimates shown on these maps. (Provide a copy of the actual study.)

Answer PEMA provided to the Pennsylvania Department of Transportation ~

1980 Census figures for municipalities within the plume exposure pathway EPZ. Using these figures and based upon an average of three persons per car, the Department of Transportation estimated the number of vehicles evacuating from each municipality. Using assumptions that were developed for the evacuation of the EPZ around ottier nucicar plants within Pennsylvania, the Department of Transportation then determined what, in their opinion, were the best main evacuation routes to be used. Documentation of these assumptions and any other relevant information will be provided in a supplemental response.

8407190212 840716 PDRADOCK05000g Q

2. Provide a map of the Limerick Plume EPZ that' reflects any changes made af ter the EPZ was slightly extended in February 1984. Please discuss how these changes were determined.

Answer Draft copies of the revised map are being printed for use during the July 25, 1984 Exercise but they are not currently .,

available. A finalised version of the map will not be printed until after the exercise. As soon as it.is available a copy will be mailed to the Service List. The original map was a

. composite of the Berks, Chester and Montgomery County maps. The cartographers apparently neglected to compensate for this in developing the scale shown on the original map. The correct scale should have been 1 (1 mile equals .588 inches). Consequently, the circle depicting the ten alle EPZ on the original map (dated June 1983) was approximately a quarter mile smaller than it should have been. The EPZ as defined in the county plans is shown as the white area on the Evacuation

, JPlan Map and follows political subdivision boundaries or recognized landmarks. The defined EPZ exceeds the ten mile circle depicted on the' June 1983 map by considerably more than a quarter mile in Chester County and the error had no impact on the established EPZ. This was not true, however, for Berks and Montgomery Counties since the additional

. quarter mile could have affected the EPZ boundaries shown for seversi municipalities. When PEMA's February 24, 1984 letter (copy attached) to the Licensing Board and Service List was prepared, there was a possibility that the EPZ could change in these two counties. The two counties investigated the matter with the municipalities involved and >

it was subsequently decided by the counties that no change in the EPZ as defined was needed. The new map will reflect a ten mile circle in consonance with the correct scale.

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3. Provide all information relating to traffic flow and congestion to the following areas below. Please indicate what analysis has been made to consider these impacts during a radiological emergency.

3a. Valley Forge National Park and King of Prussia area (unless provided e

in answers to first set of interrogatories).

Answer: See " Response of Pennsylvania Emergency Management Agency to Limerick Ecology Action's First Set of Interrogatories and Request for Production of Documents on Of f-site Emergency Planning Contentions," and specifically responses to interrogatories 51.6 through 51.11, 51.22 through 51.26 and 51.28.

3b. Marsh Creek State Park and Hopewell Village area.

Answer: In' addressing the items to be considered in'the Evacuation Time Eatinate Study, PEMA requested HMM Associates to consider traffie flow and congestion in Marsh Creek State Park and the Hopewell Village area. PINA will supplement the response to this intecrogatory upon completing its review of the HMM study and after discussion with the Pennsylvania Department of Transportation.

3c. Route 100 South from Pottstown to Exton Mall.

Answer PINA will provide a response to this interrogatory upon completing its review of the HMM study and after discussion with .

the Pennsylvania Department of Transportation.

4. Has PEMA conducted any surveys or studies to determine the effect that spontaneous evacuation outside the Plume EPZ may have on traffic congestion backing up into the EPZ7 Has this impact on evacuation times been considered? If yes, please provide any details av.silable.

If not, explain why this has not been considered by PEMA.

1 Answer PEHA has not conducted any surveys or studies to determine the effect that spontaneous evacuation outside the EPZ may have on traffic congestion backing up into the EPZ. The impact has, however, been considered and it could conceivably impinge upon the flow of traffic if the traffic control points did not function properly. ,,

A complete survey of the area outside the EPZ would be an enormous undertaking but perhaps a sampling could be made. PEHA, however, .

is not in a position to undertake such a project.

5. Has PENA completed its review of PECO's May 1984 Evacuation Time Estimate Study? Please provide any comments that PEMA has made about this study, including all correspondence exchanged during the development of the study.

Answer PIMA has not completed its review of the May 1984 Final

. Draft of the HMN Evacuation Time Estimate. PENA did hold meetings with HMK Associates to discuss the sco'pe and content of the study. HMK subsequently held meetings with the three risk counties to determine their input. See attached copy of March 8, 1984 letter f rom Robert D. Kliam,100( Associates, to Ralph Hippert, PENA. _ __ .

6. Does PIMA have any information available to determine the number of farmers who would be eligible to be designated as emergency workers in the event of a radiological emergency at Limerick? Provide a status report on the progress made in training farmers who reside within the EPZ. .

Answert- The Pennsylvania Department of Agriculture maintains a list of farmers with dairy herds in the area surrounding Limerick. That Department does not currently maintain a list of farmers who have other types of livestock. It is PERA's understanding that the

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I U.S. Department of Agriculture's County Agents maintain information as to various types of farmers within the county. PEMA does not, however, have the information readily available. See also response to interrogatory 9.

e.

7. Does PEHA have any information relating to possible accident scenarios .

which could result in radiation releases that might prevent farmers from being designated as emergency workers, or any other circumstances that might limit farmer access to the EPZ?

Answer: The designation of farmers as emergency workers is independent of scenarios and of corresponding off-site consequences.

Farmers are classified as emergency workers so as to innble them to accumulate more radiation dose than the population at large.in their efforts to tend to livestock and to protect that investment following reactor accidents. Severe accidents are possible, the off-site consequences of which would severely restrict or even prohibit farmers' return to some farms in the EPZ. These possibly include the more severe release categories (BWR 1-3) from the Reactor Safety Study, WASit 1400. _ . _ .

8. Does PEHA intend to present any witnesses on LEA-22? If yes, please provide information about the subject matter to be covered in any such testimony, and any information about witness credentials currently known by PEMA.

Answer PEMA has not yet thoroughly reviewed contention LEA-22.

PEMA, therefore, can not identify particular witnesses or subject matter of testimony on that contention. PEMA intends to sock witnesses on this contention from appropriate Commonwealth agencies and the three risk counties.

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9. Provide a detailed explanation of the training being offered to farmers within the EPZ. When and where have these sessions been held? Who has conducted them? How many farmers have participated?

Specifically explain what farmers are being told about the "riska" of exposure to radiation if they chose'to remain in the EPZ during ,,

a radiological emergency. What role has PEMA played in determining the content.of training sessions? Have PEMA representatives attended these training seusions? How is the effectiveness of such training evaluated?

Answer: Training by Energy Consultants, Inc., has been made available to farmers in the plume exposure pathway EPZ. It is PEMA's understanding that this training will continue to be made available to farmers requesting same. Farmers are trained in the use of the three pieces of dosimetry referenced in the risk county plans for emergency workers.

h The training provided by Energy Consultants, Inc. has been '

. scheduled in coordination with the county coordinators. PEMA does not have specific information as to when the training was conducted or how many' farmers participated; such detailed information is maintained

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at the county level. PEMA provided guidance in the development of the course content and furnished " train-the-trainer" instruction for the instructors. PENA has not attended these training sessions.

An evaluation of the effectiveness of this training can be made through conduct of the exercise. Farmers are informed in their training of the " risks" of exposure if they choose to remain within the EPZ. PEHA has been advised that in Chester County pre- and post-testing was used to determine the effectiveness of the instruction.

10. In the event of a radiological emergency, where is a farmer supposed to obtain dosimetry and KI supplies? What arrangements have been made for decontamination of farmers? What about pets and livestock?

Answer: The dosimetry and KI distribution points for farmers who wish to reenter the EPZ as emergency workers to tend their livestock will be found in the respective risk county plans.

As with other emergency workers, farmers would be decontaminated, *-

if necessary, at decontamination stations outside of the EPZ as identified in the risk county plans. PDIA has been advised by ..

the. Pennsylvania Department of Agriculture that there are currently no plans for decontamination of peta and livestock.

Dated: July 16, 1984 i +

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00W uat<HC

, BEFORE THE ATOMIC SAFETY AND LICENSI_NG BOARD c4 JUL 16 All :59 In the Matter of ) ,

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)' Docket Nos.050-352 Philadelphia Electric Company (Limerick Generating Station , ) 50-353 Units 1 and 2) ) .

AFFIDAVIT OF RALPH J. HIPPERT I, Ralph J. Hippert, being duly sworn, state as follows:

1. At present I am the Deputy Director, Office of Plans and Preparedness, Pennsylvania Emergency Management Agency.

2. I contributed to and supervised the responses to

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Limerick Ecology Action's Interrogatories 1-10.

3 I hereby certify that the answers are true and correct to the best of my knowledge.

Halph (. HTd5 pert,2eputy Director

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Office of Plans and Preparedness

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Notar// Public (ARL C. KUEHil ll, ilmry Public le. diana, indim Courty, pa, ny commission expires: MYCommis*Ico Exp!res April M, Mg

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00UETEP UMC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'84 JtA.18 Pi2:00 <

In the Matter of )

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Philadelphia Electric Company ) Docket Nos". 50,352' "

(Limerick Generating Station, ) 50-353 Units 1 and 2) ,

) l AFFIDAVIT OF KENNETH R. LAMISON I, Kenneth R. Lamison, being duly sworn, state as follows:

1. At present I am the '

Director, Office of Response and Recovery, Pennsylvania Emergency Management Agency.

2. I contributed to the response to Limerick Ecology 1 Action's Interrogatory 4.

3 I hereby certify that the answers are true and correct  !

to the best of my knowledge.

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Kenr.eth R. TaKIben i

sgon""""' t Director i

,7,3 ,, e Office of Response and Recovery

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Notar y Public 4 CAAL C. KugHN If, Notery Publie in$ana, Indiana County, Pa, Mr C'*"I'81** Eapirse April 29, Ites My eomaisaion expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r. .cin u.n; BEFORE THE ATOMIC SAFETY AND LICENS_ING BOARD u4 di iu P12 :00 In the Matter of ) *

) i wo.0 Philadelphia Electric Company ) Docket Nos.u50-352 r (Limerick Generating Station , ) 50-353 Units 1 and 2) ) .

AFFIDAVIT OF DONALD F. TAYLOR I, Donald F. Taylor, being duly sworn, state as follows:

1. At present I am the Director, Office of Training and Education, Pennsylvania Emergency Management Agency.

1 2. I contributed to the responses to Limerick Ecology

/ Action's Interrogatories 6, 9.

3 I hereby certify that the answers are true and correct to the best of my knowledge.

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Ddhald F. Tinylor, Diregor of Training and Education Pennsylvania Emergency Management T

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My commission expires My curatiika bptres April 29, ttes i

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UNITED ST ATES OF AMERIC A NUCLEAR REGULATORY COMMISSION ,

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HEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

'81 JLt.18 112:00 In the Hatter of )

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Philadelphia Electric Company ) Docket'Ho6il50-352 (Limerick Gonorating Station, ) 50-353 Units 1 and 2) )

AFFIDAVIT OF ROBERT C. FURRER I, Hobart C. Furror, being duly sworn, stato as follows:

1. At prosent I am a Management Analyst, lluronu of Administrativo Services, Ponnsylvania Department of Agriculturo. I servo as Emergoney Management Coordinator for the Agriculture Dopartment.

2. I contributed to the responses to Limerick Ecology Action's Interrogatorios 6, 9, 10.

3 I horoby cortify that the answers are true and correct to the best of my knowledge.

< sM W4 Itobert G. Furror 11ureau of Administrativo Services Pennsylvania Departmont of Agriculturo Subsnribo(I and Sworn to beforo mo

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day of July 1984

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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'Mh RL BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'84 JUL 18 Pi2:00 In the Matter of )

) :sL . :.i il u s Philadelphia Electric Company ) DoElfdE M M 50L352 (Limerick Generating Station , ) , 50-353 Units 1 and 2) )

AFFIDAVIT OF MARGARET A. REILLY I, Margaret A. Reilly, beings duly sworn, state as follows:

1. Atpresent'.'I$m'dhief, Ditfi on of'Enyironmental

' Radiation, Bureau of Radiation Protection , Pennsylvania

, Department; of, Environinetital Resour css.

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2. I contributed to the r,.egponses to Limerick' Ecology

-Act' ion'w .s ;y Int.errogatories 7. * -

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to the' bdht of my knowledge.

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MargareD A. Reilly, Chief i. .

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Division of Environmental R6diation

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. Bureau of Radiation Frotection, Fennsylvan'la DepartmentC 6f ' 4.- - '

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• b PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY -

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P.O. box 3321 HARR135URG, PENHSYLVANIA 17105 ,

February 24, 1984 Lawrence Brenner, Esq. Dr. Peter A. Morris Administrative Judge Adninistrative Judge , . ,

• U.S. Nuclear Regulatory U.S. Nuclear Regulatory  :,g-Commission Commission j3 Washington, DC 20555 Washington, DC 20555 ],?,',j Dr. Richard F. Cole ,. - ',}'

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Administrative Judge . .,

_- U.S. Nuclear Regulatory /

Commission f

Washington, DC 20555 In the Matter of Philadelphia Electric Company ,

. (Limerick Generating Station, Units 1 and 2)

Docket Nos. 50-352, 50-353

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Dear Administrative Judges:

On December 6, 1983 we wrote to the Board, with copics to the service _ list, regarding our review of the draf t off-site Radiological Emergency Response Plans for Limerick Generating Station and their subse-l

- quent distribution by Philadelphia Electric Company to the Board, the intervenors and the City of Philadelphia. In a continuing effort to keep the Board apprised regarding the status of these plans, PEMA wishes to inform you" l

of a recently discovered error on the Evacuation Plan Map which we published in June-1983.

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The map is a composite of the Berks, Chester and Montgomery County maps but the cartographers apparently neglected to compensate for this in developing the scale shown on the Evacuation Plan Map. The correct scale is one (1) nile equals .588 inches. Consequently, the circle depicting the ten-mile EPZ is approximately a quarter mile smaller than it should be. The EPZ, as determined by the municipalities, counties and PEMA, is shown as the white area on the map and follows political subdivision boundaries or recognizable landmarks. A review of the map indicates that our defined EPZ exceeds the ten-nile circle by considerably more than a quarter mile in Chester County and the error thus has no impact. This is not, however, true for Berks and Montgomery Counties since the additional quarter mile affects the EPZ boundaries now shown for several municipalities.

It is our intention to republish the maps and ensure that any necessary changes are made in the plans of the affected counties and munici-palities. We will not know the extent of these changes until the EPZ can be redefined for Berks and Montgomery Counties. Philadelphia Electric Company's consulting firm, Energy Consultants Inc., is currently working with these counties and their involved municipalities to determine how the E .

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s i Administrative Judges February 24, 1984 . -

Page Two EPZ boundaries should now be established to conpensate-for the quarter mile ,

extension of the ten-mile circle that appears on the June 1983 maps. . <

Although it is indeed regrettable that the error occurred, it is, '

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however, fortunate that it was discovered before the July 25, 1984 exercise - ,

and while the plans are still in draft form. We cannot at this time provide -

a date as to when the necessary changes will be completed, but please be

--assured that we will endeavor to republish the map and have necessary .i- '

changes made.in the plans as quickly as possible. Region III of the Federal ,

, Emergency Management Agency has also been informed of the error and the -

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L . action being taken. ,

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e Sincerely, .

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g Adolph L. Belser Director

' Office of Plans and Preparedness -

[ ALB/RJH:jmb (Tel: 717-783-8150)

• cc: " Attached List

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bec: Roberta Kankus James Asher-A M l

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k hm J HMM Associates 336 Baker Avenue Concord, Massachusetts 01742 (617) 371 1692 j HMM Ref. No.83-620 s

March 8, 1984 i

Mr. Ralph Hippert PENNSYIVANIA EMERGENCY MANAGEMENT AGENCY Room B-151 Transportation and Safety Building

Forester Street Harrisburg, PA .17102

Dear Mr. Hippert:

. Enclosed, for your review, is a memorandum summarizing the key issues discussed at the meeting of county officials on February 29, 1984 in Montgomery County. These issues are k primarily the same as the ones we discussed at your office on February 23, 1984. I will be contacting your office early next

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week ,to discuss any comments you may have, particularly concerning the assumptions to be used for the evacuation time estimate study.

Feel free to contact me if you have any questions.

Very truly yours, . . . _ .

Robert D. Klimm l

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MEM0RANDUM DATE: March 6, 1984 TO: Montgomery County Office of Emergency Preparedness; Chester County Department of Emergency Services; and Berks County Emergency Management Agency FROM: Robert Klimm, it4M Associateskb

SUBJECT:

Summary of Initial Meeting on Limerick Generating Station Evacuation Time Estimate Study On February 29, 1984 a meeting was held at the Montgomery Office of Emergency Preparedness,100 Wilson Boulevard, Eagleville, PA, to review the methodology and discuss assumptions and data inputs to be used in the Limerick Evacuation Time Estimate Study. The following were in attendance at this meeting:

Chester County Department of Emergency Services M. Jay Groce, III Mark A. Force

' George L. Hughes Pennsylvania Emergency Management Agency D. Lamison j Sam Boyle __

John L. Shannon l Philadelphia Electric Company Robert Logue Robbie Kankus

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Mike Mezias Russ Hamilton

! Berks County Emergency Management Agency Bob Reber l

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Montgomery County Office of Emergency Preparedness Lin Bigelow Sam Tabak Tim Hasson Energy Consultants Inc.

Henry Tamanini FM4 Associates Robert Klimm The purpose of this memorandum is to summarize the major assumptions and data irputs proposed for use in the evacuation time estimate study, as discussed during the February 29, 1984 meeting. In order to insure concurrence on the various site-specific asswptions required for the analysis, I will be contacting each county office within a week to further

~ discuss these items. If necessary, a meeting can be scheduled, locally, to

k. address any comments which may come tp.

The following ~ summarizes these data irputs and assumptions:

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1. Introduction In November of 1980, the U.S. f4Jclear Regulatory Commission (NRC) and the_.

1 Federal Emergency Management Agency (FEMA) published a revised version of NUREG-0654 entitled Criteria for Preparation ~and Evaluation of Radiological Emergency Response Plans and Preparedness in % port of Nuclear Power Plants.

NUREG-0654 requires that each nuclear power plant licensee's offsite emergency plan contain time estimates for evacuation within the Plume Exposure Emergency Planning Zone (EPZ). Appendix 4 of NUREG-0654 provides detailed guidance on what must be included in an evacuation time estimate study.

In response to NUREG-0654, Philadelphia Electric Conpany has retained FNM Associa.tes of Concord, Massachusetts, to develop the evacuation time estimates for the Limerick Generating Station (LGS) EPZ in Limerick, Pennsylvania.

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The evacuation time estimates will be developed using existing population

' data and the ETVAC computer simulation model. The NETVAC program was developed specifically to provide evacuation time estimates and related information for use in emergency planning. Evacuation times will be estimated for various areas, times, and weather conditions, as suggested by Appendix 4 ,

of NUREG-0654, Rev.1. These evacuation times represent the time Iequired for conpleting the following actions:

1. public notification; .

2.- preparation and mobilization; and

3. actual movement out of the EPZ (i.e. , on-road travel time, including delays associated with vehicle queueing).

2. Evacuation Roadway Network As indicated at' the February 29th meeting, the evacuation roadway network h.

to be used in the evacuation time estimate study will be consistent with that identified in the current county energency response plans. Routings from the various townshios will also be the same as that presented in the county plans, as sunmarized below:

MONTGOERY COUNTY Collegeville Borough:

, o Local routes to Rt. 422 East to PA Turrpike to Exit 27 to Willow Grove Industrial Park Douglass Township:

. o Local routes to Rt.100 North to Rt. 29 North to Emmaus High School Complex

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Green Lane Borough:

o Local routes to Rt. 63 East to Rt.113 North to County Line Plaza Limerick Township:

o Local routes to Rt. 422 East to PA Turrpike to Exit 27 to -

Willow Grove Industrial Park Lower Frederick Township:

o Local routes to Rt. 29 North to Perkiomenville Rd. to Rt. 63 East to Rt.113 North to County i.ine Plaza Lower Pottsgrove Township:

.o Local routes to Rt. 663 North to Rt. 309 North to Southern Lehigh School Cmplex Lower Providence Township:

o, Local routes to Rt. 363 South to PA Turrpike to Exit 28 to __

Neshaminy Mall Lower Salford Town 2ip:

o Local routes to Rt.113 North to County Line Plaza Marlborough Township:

o Local routes to Ht. 63 East to Rt.113 North to County Line Plaza

~ New Hanover Township:

o Local routes to Rt. 663 North to Rt. 309 North to Southern Lehigh School Conplex Perkiomen Township:

o Local routes to Rt. 29 South to Rt.113 North to Rt. 73 East to Rt. 202 North to Montgomery Hall Pottstown Borough - NE:

o Local Ioutes to Rt. 663 North to Rt. 309 North to Southern Lehigh School Complex Pottstown Borough. NW:

o Local Ioutes to Rt. 100 North to Rt. 29 North to Emmaus High

! ~ School Conplex l g Pottstown Borough - SW:

o Local routes to Rt. 422 West to Reading Mall _-

I Pottstown Borough - SE: .

i l o Local Ioutes to Rt. 724 West to CumIu Elementary School Royersford Borough:

l 0 Local Ioutes to Main St. to Lewis Rd. to Walnut St. to Township Line Road to Rt. 422 East to PA Turrpike to Exit 27

( to Willow Grove Industrial Park l

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Schwenksville Borough:

o Local Ioutes to Rt. 73 East to Rt. 202 North to Montgomery Mall Skippack Township:

o' Local Ioutes to Rt. 113 North to Rt. 73 East to Rt. 202 North .

' to Montgomery Mall Trappe Borough:

o Local Ioutes to Rt.113 North to Rt. 73 East to Rt. 202 North to Montgomery Mall; or o Local Ioutes to Rt. 422 East to PA Turrpike to Exit 27 to Willow Grove Industrial Park Upper Frederick Township:

o Local Ioutes to Rt. 63 South to Rt. 113 North to County Line Plaza Upper Pottsgrove Township:

o ~ Local Ioutes to Rt.100 North to Rt. 29 North to Emmaus High

. School Conglex Upper Providence Township:

o Local Ioutes to Black Rock Rd. to Egypt Rd. to Rawlings Rd.

to Audubon Rd. to Rt. 363 South to PA Turrpike to Exit 27 to Neshaminy Mall i

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Upper Salford Township:

o Local routes to Rt. 63 East to Rt.113 North to County Line Plaza West Pottsgrove Township:

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o Local routes to Rt. 422 West to Reading Mall .-

CESTER COUNTY Charlestown Township:

o Local routes to Rt. 29 South to Rt. 202 South to West Goshen Shopping Center East Coventry Township:

f- Local routes to Rt. 23 West to Morgan Corporation

.o East Nantmeal Township - West:

o Local routes to Rt. 401 West to Rt. 23 West to Morgan -- .

Corporation East Nantmeal Township - East:

o Local routes to Rt.100 South to Rt.113 South to Downington.

High School East Pikeland Township:

o Local routes to Rt.113 South to Gordon Drive to Rt.100 South to Exton Mall l l

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East Vincent Township:

o Local routes to Rt. 23 East to Rt.113 South to Gordon Drive to Rt. 100 South to Exton Mall North Coventry Township - North:

l o Local routes to Rt. 724 West to CumIu Elementary School North Coventry Township - South.

1 o Local routes to Rt.100 South to Rt. 23 West to Morgan Corporation Phoenixville Borough - North:

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o Local Ioutes to Rt. 23 East to Rt. 202 South to West Goshen

. Shopping Center Phoenixville Borough - South:

o Local routes to Rt. 29 South to Rt. 202 South to West Goshen

- Shopping Center ,_

Schuylkill Township - East:

o Local Ioutes to Rt. 23 East to Rt. 202 South to West Goshen i Shopping Center Schuylkill Township - West:

o Local routes to Rt. 29 South to Rt. 202 South to West Goshen Shopping Center South Coventry Township - North:

o Local Ioutes to Rt. 23 West to Morgan Corporation

=, , '

-9 South Coventry Township - South:

o - Local routes to Rt.100 South to Rt.113 South to Downington

.High School Spring City Borough:

o Local routes to Rt. 724 East to Rt.113 South to Gordon Drive to Rt.100 South to Exton Mall

@gerUwchlan/UwchlanTownship:

o Local routes to Rt.100 South to Rt.113 South to Downington High School Warwick Township:

Local routes to Rt. 23 West to Morgan Corporation f -o West Pikeland Township: ,

o Local routes to Rt. 13 South to Gordon Drive to Rt.100 South to Exton Mall _ _ _

West Vincent Township:

o Local zoutes to Rt.100 South to Rt.113_ South to Downington High School IEfES COUNTY Amity Township:

o Local routes to Rt. 662 North to Oley Valley High School; or o Local routes to Rt. 662 South to Rt. 442 West to Reading Mall.

c .. ... - - . - ___ a

Boyertown Borough:

o - Local route to Rt. 73 West to Oley Valley High School Colebrookdale Township: ,

o Local routes to Rt. 73 West to Oley Valley High School; or o ~ Local routes to Rt.100 North to Emmaus High School Douglass Township:

o Local routes to Rt. 662 North to Oley Valley High School; or o Local route to Rt. 562 West to Rt. 662 North to Oley Valley High School Earl Township:

k o Local routes to Rt. 562 West to Rt. 662 North' to Oley Valley High School Union Township: __

o Local routes to Rt. 724 West to Cumru Elementary School-Vashington Tcanship:

o Local routes to Rt.100 North to Emmaus High School For traffic flow simulation purposes, sevecol additional " entry" links will be l added to the network. These additional links will not alter the existing, designated evacuation routirgs, but will allow for a more detailed assessment of potential traffic problems during an evacuation, particularly in the more j

-dense areas of the EPZ (i.e., Pottstown).

l l

i

= _-

I  ;.

During the weeks of February 27 to March 2, and March 5 to March 9, roadway fielo data will be collected for tte entire evacuation network. These include operational data, such as travel speeds and traffic control; as well as geometric data sucn as lane widths, lateral clearances and lane configurations. .

3. Population Data Federal guidance (NUREG-0654) indicates that three population categories should be considered for the evacuation time estimate analysis: permanent residents, transients and persons in special facilities (such as schools, medical facilities, nursing homes, etc.). Population data will be developed for 1980 conditions using the following sources:

o Permanent' residents: Data presented in the current County / local plans, and 1980 Federal Census of Housing data.

f o . Transient population: (a) Work Force - Data presented in County / local plans and available from ECI, stpplemented by FM4's surveys as required; (b) Recreational - Data available from Countplocal plans, and discussions with local / state emergency preparedness officials, (c) Overnight accommodations (i.e.,

hotels / motels) - Data to be developed from information available _

from ECI, supplemented with Chamber of Commerce data.

o Special Facility: Data to be used is that contained in the current County and local plans, supplemented with data available from ECI.

4. Proposed Vehicle Demand Data and Occtpan:y Assunptions Vehicle occtpancy assumptions which will be used to estimate total vehicle demand are as follows:

Permanent Residents - 3 persons per vehicle.

Transient - 1 Vehicle /enployee 1 Vehicle / campsite 1 Vehicle / hotel-motel room special Facilities - Vehicle demand to be developed based tpon ,

identified transportation resources, County / local plans, and data previously collected by ECI.

5. -Evacuation Analysis Cases

' Pursuant to NUFEG-0654 guidance, evacuation time estimates will be prepared for the area within approximately 2 miles of the LGS; for areas U

approximating 90 sectors from 0-5 miles, and 0-10 miles of tte plant; and for the entire EPZ. It is anticipated that the s'ector areas will be defined to correspond to various combinations of Townships within the EPZ.

The proposed analysis cases for the evacuati6n time estimate study are summarized in Table 1. This table also indicates tre population categories to f be included in each analysis case.

Fair weather refers to cunditions where roadways are clear and dry and visibility is not inpaired. Adverse weather Wring summer periods is defined as a rainstorm condition where visibility is impaired and roadway capacities are reduced by 20 percent. Adverse weather Wring winter periods is defined as a snowstorm condition where roadway capacities are reduced by 30 percent. _ _

The various population conponents which will be incorporated in the evacuation analysis are summarized below:

1. Winter Day: This situation represents a typical day period during the winter when school is in session and the work force is at full daytime levels. Assumptions on the population levels for this condition irclude the following:

o Permanent residents within the EPZ will evacuate from their place of residence; o Major work places are fully staf fed at typical daytime levels;

- . - - _ _ _ _ _ n

-13 TABLE 1 EVACUATION ANALYSIS CASES (Proposed)

Fair Weather Adverse Weather Adverse Weather Winter Weekday Summer Other*

Population Winter Winter Summer (Mochrate Weekend Segment Weekday Weeknight Weekend Snow) (Rain) (Flooding, Icith)

Permanent Residents X X X X X Seasonal Residents X X Transient

- Work Force X X X X X

- Recreational X X

- Overnight Accommodations X X X X X Special Facilities 7

- Schools .X X

- Nursing Homes X X X X X e - Hospital X X X X X

- Analysis Area o 0-2 Mile N X' X X X X o 0-2 Mile S X X X X X o OL2 Mile E X X X X X o 0-2 Mile W X X X X X o 0-5 Mile N X X X X X o 0-5 Mile S X X X X X o 0-5 Mile E X X X X X o 0-5 Mile W X X X X X o 0-10 Mile N X X X X X o 0-10 Mile S X X X X X o 0-10 Mile E X X X X X o 0-10 Mile W X X X X X o Full EPZ X X X X X

• To be developed based tpon discussions with County / State Emergency Preparedness Officials.

o The LGS site enployment is at a typical daytime level; o Schools are in session; o Hospita'Is and rursing homes are full; l o Hotel and motel facilities are fully occtpied; and l

! o Recreational facilities are at winter daytime levels.

l 2. - Winter N'ight: This situation reflects a typical night period when permanent residents are home and the work force is at night-time l levels. - Assunptions on tiu population levels for this condition include the following:.

o PeImanent residents within the EPZ will evacuate from treir plac~e of residence; o Major work places are at typical night-time levels; i o The LGS site enployment is at a typical night-time level; o Schools are closed; _ __

o Hospitals and nursing homes are fully occtpied at night-time

' levels; and l

o Hotel and motel facilities are fully occtpied.

3. Summer Weekend: The summer weekend situation represents a daytime

! period when permanent Iesidents are home and major workplaces are at typical weekend levels. Assumptions on the population -levels for this condition include tre following:

o Permanent residents within the EPZ will evacuate from their place of residence; i

s ;

0 Seasonal residents will evacuate from their place of residence; o Major work places are at typical weekend levels; o The LGS site is at an estimated weekend level; l

o Scruols are closed; o- Recreational f acilities are at a peak weekend level; l l

o ' Hospitals and nursing homes are fully occmied; and l l

0 Hotel and motel f acilities are fully occtpied.

6. Notification / Preparation / Mobilization Time Distributions

-Initial Notification i

The EPZ surrounding the Limerick Nuclear Generating Station will have' a notification system consistent with NUREG-0654/ FEMA-REP-1 Appendix 3 guidelines.- This system will be used by County and local officials to alert the population to turn on their radios and television sets. Pursuant to NUREG_.

0654 guidance, notification messages will commence on the designated television and EBS radio stations virtually immediately. The system will have 1 the capability for providing both an alert. signal and an informational or instructional message to the population within the EPZ, within 15 minutes. ,

J Evacuation Preparation Times ard Deoarture Distributions It is assumed that no vehicles will begin to evacuate during the 15-minute initial notification period. It is also assumed that there would be a minimum preparation / moollization time of 15 minutes for all population sectors. Accordingly, in the model simulations no vehicles begin to evacuate until 30 minutes following the initial notification. Network loading distribution assumptions for the permanent population, transient population, ard special facilities are described below:

.r*

1 p.- ,

Permanent Population

< Permanent residents with access to automobiles will take varying amounts ,

of time to begin evacuating. Some persons would leave as quickly as they could; most would take some time to prepare, pack valuables and clothes and

' then depart; and some would take added time to secure property before o departing. In addition, actual departing and preparation times may vary according to the perceived severity of a particular evacuation order.

It is assumed that there would be a two-hour period over which the permanent residents would begin to evacuate. That is, permanent resident households would begin to evacuate between 30 and 150 minutes after the decision to notify the population to evacuate is made. It was further assumed that 15 percent of the peImanent population would begin to evacuate between 30

~

and 60 minutes following the evacuation decision,' 40 percent would begin to evacuate between 60 and 90 minutes, an additional 40 percent would begin to evacuate between 90 an'd 120 minutes, and the remaining 5 percent would begin

.to evacuate between 120 and 150 minutes of the decision to evacuate.

Transient Populat' ion it is assuned that the work force would receive initial notification promptly. It is also assuned that the majority of the work force could, and t

would, be released expec.. :iously (i.e. , within 30 minutes subsequent to ._

L ' notification). The actual preparation and mobilization time distrit,utions to be used in the- analysis will be based tpon discussions with major employers in the area, and tpon data already gathered by ECI.

Special Facilities It 'is assumed that special facilities (i.e. , schools, hospitals, nursing i homes', jails) within the EPZ would also receive initial notification

promptly. Preparation and mobilization times for special facilities will be based tpon the existing energency response proceciJres and existing transporation resources.

e

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'u!n vTA:

In the Matter of ) 84 JM 18 R2:00

)

PHILADELPHIA ELECTRIC COMPANY ) Docke.tfNos'. 50-352

) "" kOC 5.0;353.

y mR Me (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Response of Pennsylvania Emergency Management. Agency to Limerick Ecology Action's Second Set of Interrogatories and Request for Production of Documents on Offsite Emergency Planning Contentions" in the above-captioned proceeding have been served yon the following by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Commonwealth of Pennsylvania's internal mail system, this 16th day of July 1984:

Lawrence Brenner (2) Docketing and Service Section Administrative Judge Office of the Secretary Atomic. Safety and Licensing U. S. Nuclear Regulatory Board Commission U. S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C.- 20555 Richard F. Cole Mark J. Wetterhahn, Esq.

Administrative Judge Conner and Wetterhahn Atomic Safety and Licensing 1747 Pennsylvania Avenue , N.W.

Board Washington, D.C. 20006 U. S. Nuclear Reg ulator y Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Peter ~A. Morris Ann P. Hodgdon, Esq.

Administrative Judge Benj amin H. Vogler , Esq.

Atomic Safety and Licensing Counsel for NRC Staff U. S. Nuclear Regulatory Office of the Executive Legal Commission Director

- Washington , D.C. 20555 U. S. Nuclear Regulatory Commission l Washington, D.C. 20555 i

, y _g _- _ -e -+ -J-- - - _ - -- L-~-- m-

?~ ~

Atomic Safety and. Licensing Philadelphia Electric Company Appeal Panel ATTN: Edward G. Bauer , Jr .

U. S. Nuclear Regulatory Vice President &

Commission General Counsel Washington, D.C. 20555 2301 Market Street Philadelphia, Pa. 19101 Frank R. Romano # David Wersan, Esq.

61 Forest Avenue Assistant Consumer Advocate Ambler , Pa . 19002 Office of Consumer Advocate 1425 Strawberry Square Harrisburg, Pa. 17120 Robert L. Anthony Steven P. Hershey, Esq.

Friends of the Earth of Community Legal Services, Inc.

the Delaware Valley Law Center West P. O. Box 186 5219 Chestnut Street 103 Vernon Lane Philadelphia , Pa . 19139 Moylan, Pa. 19065-Marvin I. Lewis' Angus' Love, Esq.

6504 Bradford Terrace 101 East Main Street Philadelphia, Pa. 19107 Norristown , Pa . 19104

' Joseph H. White , III Maureen Mulligan 15 Ardmore Avenue Limerick Ecology Action _ -

.Ardmore, Pa. 19003 P. O. Box 761 Pottstown , Pa . 19464

Charles W..Elliott, Esq. Sugarman, Denworth & Hellegers Brose.and Postwistilo 16th Floor Center Plaza

-1101 Building 101 North Broad Street 11th & Northampton Sts. Philadelphia, Pa. 19107 Easton , JPa . 18042

1. Director, Pennsylvania Emergency Management Agency B-151, Transportation and Safety Building Harrisburg, Pa. 17120 ,

1

^' '

4 1

1. Thomas Gerusky, Director Martha W. Bush, Esq.

Bureau of Radiation Kathryn S. Lewis, Esq.

Protection City of Philadelphia

. Department of Environmental Municipal Services Bldg.

Resources 15th and JFK Blvd . o. -

5th Floor , Fulton Bank _ Bldg. Philadelphia, Pa. 19107 Third and Locust Streets Harrisburg, Pa. 17120 Spence W. Perry, Esq.

Associate General Counsel Federal Emergency Management Jay M. Gutierrez, Esq. Agency U. S. Nuclear Regulatory 500 C Street, S.W., Rm. 840 Commission Washington, D.C. 20472 Region I 631 Park Avenue Gregory Minor King of Prussia, Pa. 19406 MHB Technical Associates 1723 Hamilton Avenue San Jose, CA 95125

~

Ti moth y.R. S. Campbell Director Department of Emergency Services i 14 East Biddle Street

/ West Chester, Pa. 19380 i .

Zori G. Ferkin Assistant Counsel Governor's Energy Council 9

Date : July 16, 1984 I