ML20106J918
| ML20106J918 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/12/1985 |
| From: | Ferkin Z PENNSYLVANIA, COMMONWEALTH OF |
| To: | Cole R, Harbour J, Hoyt H Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-595 OL, NUDOCS 8502190191 | |
| Download: ML20106J918 (32) | |
Text
m ;
p TED M COMMONWEALTH OF PENNSYLVANIA l GOVERNOR'S ENERGY COUNCIL P.O. BOX 8010 --
1625 N. FRONT STREET '
HARRISBURG. PENNSYLVANIA 17105 E OF y,
783-0220 To FB 15 N0:11 February 12, 1985 NCdl a : f( ,
~ ste Helen F. Hoyt, Esq. Dr. Richard F. Cole Administrative Judge Administrative Judge Atomic and Licensing Judge Atomic Safety and Licensing U. S. Nuclear Regulatory Commission Board Washington, DC 20555 U. S. Nuclear Regulatory Commission Washington, DC 20555 i Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing .
, Board U. S. Nuclear Regulatory Commission Washington, DC 20555 Re: Limerick Nuclear Generating Station, Units 1 and 2 Docket Nos. 50-3s2, 50-353 OL
Dear Administrative Judges:
In the course of reviewing the record of this proceeding, the pre-filed testimony of Commonwealth witnesses flippert and Taylor was bound into the hearing transcript fol. Tr. 19,498 in the incorrect order.
Enclosed please find a correctly-ordered copy of Messrs.
Hippert and Taylor's testimony. I have taken the liberty of assigning page numbers to the testimony for the convenience of the Board and parties.
Very truly yours, O h_ -
Zori G. Ferkin Assistant Counsel Enclosure cc: Service List 8502190191 850212 PDR ADOCK 05000352 T PDR 2 S03
.' . D
. MELATED CORRN i
UNITED STATES OF AMERICA g NUCLEAR REGULATORY COMMISSION '
Board ,,
Before the Atomic Safety and Licensin6 QS t
- 7
) ' 2p' '.ll In the Matter of ) 50-352, 50-353
) Docket Nos. ~
Philtdelphia Electric Company )
)
(Limerick Generating Station, )
Units 1 and 2) l I \' .
' r f . TESTIMONY OF RALPH J. HIPPERT *-
l FOR THE COMMONWEALTH OF PENNSYLVANIA ON LIMERICK ECOLOGY ACTION NS l
DEFERRED AND RESPECIFIED LEA-1, LEA-3 OFFSITE EMERGENCY PL l
l LEA-t l, o The Risk Counties, Municipalities, School Districts, and-I Institutions haven't promulgated or adopted final f radiological emergency response plans, nor have they f
j approved and adopted plans drawn up for them by Energy Electric Company. There is no is reasonable predictive assurance of final that the present state of planningthe plans are capable of being implemented.
approval, or that i
1.
During the period September through November,1983, the Pennsylvan a radiological emergency Emergency Management Agency (PENA) reviewed draf t (Berks, i
response plans submitted by the three Limerick EPZ risk count es municipal and school district Chester and Montgomery) an well as draf t l
l In connection plans provided through the respective risk counties.
d recommendations With this review, PEMA provided written comments an l or additions l
to each of the risk counties regardin6 chan8es, correction:.:
and to ensure .
to bring thh plans into consonance with the state plan Comments with regard to municipal their adequacy and implementability, and school district plans were provided through the respective counties, d'
C -
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j Sub:cquent to PEMA's initial review and comments, revised trafts were prepared by the counties, municipalities and school districts with assistance from Energy Consultants, Inc., the firm funded by Philade'phia Electric Company for this purpose.
- 3. In cccordance with this Board's Order dated May 16, 1983, copics of the revised draft plans were distributed to the Lutcry:nors. Given the timetable imposed by the Board for th3 distribution of draft plans, PEMA was unable to review the f In revised drafts prior to their transmission to the intervenors.
vicw of this distribution, PEMA opted to submit the same drafts to 3h2 FederIl Emergency Management Agency (FEMA), Region III for informal review pursuant to 44 C.F.R. Part 350. '
i o ;
4 As a result of this informal review of the pl. ins provided to it
.l p
by PEMA, FEMA Region III issued its interim findings in April 1984, I 3
FEMA indicated that, "[a]t this point in the planning process, the :
12 cal offsite emergency response plans developed for incidents . at
[
th2 Lim 3 rick Generating Station are inadequate and are not capable of .
, b, being implemented." I i
t
- 5. If the most recent drafts of the county, municipal and school b j
district plans reflect the changes, corrections and additiono
- commended *by PEMA in the fall of 1983 and the April 1984 recommendations o.
. J.;
Of FEMA, the plans should be adequate and capable of being implemented. 4
/
1
- 6. With the exception of Draft 6 for Berks County (received by PE!!A
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Oct:ber 6,1984) a'nd Draft 7 for Montgomery County (received October 23, '
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,i o f l
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A hummen 1984) PEM has not received any county, municipal or school district PEM is currently 1 drnft plans for review since the fall of 1983.
e latest drafts of the Berks and in tha process of reviewing t hes Monts:mery County plans, but is not prepared at this time to make a dIfinitive assessment of their adequacy and implementability.
l 7.
As to the current status on adoption of municipal and schoo is district plans by the governing bodies of these entities, it been submitted reitsrated that no municipal or school district plans have !
f 1983.
by th3 respective counties to PEM for review since the have fall o BasId upon the draft plans submitted to PEM at that time, none Any updated report besn accepted, approved or adopted at the local level.
ties cn thegadoption status of these plans must come from the risk coun in their role as coordinator and initial reviewer of the respective f h municipal and school district plans prior to transmittal by t e
[
counties to PEMA.
8.
With regard to county plans, none of the three risk or two d by support (Bucks and Lehigh) county plans has been formally accepte its respective Board of Commissioners. d s
9.
In connection with its application to FEMA for formal review an se plans, approval of the Limerick offsite radiological emergency respon 350
( ) of 44 C.F.R. Part the Commonwealth is required under Section 350.7 d tect the to certify that the plans are, in its opinion, " adequate to pro y I
public health and safety of its citizens living within the emurr, enc ;
" The Commonwealth, throuGh PEMA, will not make a r planning zone [] . . . .
=
et
1 atntement evaluating the adequacy and implementability of the radiological emergency response '
county, municipal and school district i
plans prepared in connection with the Limerick Generating Stat on, ils or submit these plans to FEM for formal review and approval, unt (a) A joint exercise acceptable to FEMA has been conducted.
This exercise was held July 25, 1984 and a supplemental Cwwh4M'M I exercise, required by FEMA,p: ::h91~' 'er November 20, 1984. ,
(b) A public meeting has been conducted in accordance with 44 C.F.R.
As a prerequisite, PEMA must ensure that the Section 350.10.
State and local plans are available in local libraries for I review by the general public at least two weeks prior to the meeting. The local plans should obviously be available into the public for review by PENA before they are put
.e A date has not yet been established for this meeting.
4 f libraries.
plans ares (c) The finalized risk municipal and school district (1) Reviewed by the respective county to ensure consonancy with its own plan; and (2)
Submitted by the county to PEMA together with the county plan, and with each containing a promulgation page indicating whether the plan has been accepted or rejected by the respective Board of Supervisors, School Board or Board of Commissioners.
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The Montgomery County RERP fails totected provide in reasona assurance that the public will be adequately proi h is essential to that the Bucks County Support Plan, wh cy not be approved.
the workability of the MontCo RERP, ma k] County little knowledge Support
[ The present Board of Comissioners have [ sic the of Plan.
the contents and implications of the Buc sThere is no ass Plan, rather responsibilities assigned to it in kthe SupportCounty l in at people first.
than use County resources to help Buc s The Montgomery County Plan relies on the Support P an least these ways:
use of
- 1. facilities augmentation of emergency workers, includ care for relocation and i mass i ng of evacuees ,
- 2. county resources, on a continuous 24-hour Bucks bas s See attachment " Excerpts and comments on the
- 3. County Draft Evacuation Plan" for additional areas
, of support and interface.
' Bucks County I It is contended that without the approvalitof now thestands.
[ p Support Plan, the MontCo RERP is unworkable as g usabsumption
/
10.
This contention appears to be based upon the erroneo the plan f decided not to accept I by LEA that Bucks County has inexplicably oximately 24,400
! developed by Energy Consultants for support of appr
?,
The Bucks County Board of Commissioners svacuees from Montgomery County.
h impact of such an i has raised some lagitimate questions regarding t ef its residents a evacuation upon the safety and well-being oDased upon a recent acknowledged the Board?s concerns.
that Bucks County would refuse l i the Comissioners, PEMA does not bel eve Rather, the ident at Limerick.
to cooperate in the event of an acc s to ensure that f l County is asking that provisions be made in the p an evacuation f rom h
its populace would not be adversely affected fromby te Philadelphia.
l Montgomery County, or by a spontaneo6s evacuation o
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- 11. Senate Bill 987, which upon the Governor's signature became Act 1984-147, the Radiation Protection Act, provides for the establishment cf a Rad [ation Emergency Response Fund from fees levied upon the nuclear power plants within Pennsylvania. This fund is to be used to defray expenses incurred by risk and support counties in d2veloping their plans and preparedness for response to a nuclear Bucks County has indicated Lts desire to be power plant accident.
continue to be a support a participant in this fund and as such must '
4 l county. The issue is thus one of assuaging the County',s present concerns by developing more explicit procedures and safeguards before the current draft plans are finalized. PEMA intends to work with Bucks County towards this objective.
I l
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UNITED STATES OF AMERICACOMMISSION NUCLEAR REGULATORY d
Before the Atomic Safoty and Licensing Boar
) ;
In the Matter of -
) 50-352 :
) Docket Nos. 50-353 /
l Philadelphia Electric Company }
)
(Limerick Generating Station, )
Units JL and 2) HE
!!IPPERT AND DONALD F, TAYLOR FOR T TESTIMONY OF RALPil J.
COMMONWBALTil OF PENNSYLVANIA '
REGARDING LIMERICK ECOLOGY ACTION PLANNING CONTENTIONS ADMITTED OFFSITE.LEA-11,EMERGENCY 12, 13, 14(a), 14 (b) , 15, 22, 26 Introduction cortain d to v The purposo of this testimony in to responAction (LEA)
Ecology by Limerick contentions raised planning for the Limerick offsite amorgency F. Taylor concerning l f Generating Station.
Ralph J. Hippert and Donald Management Emergency
- Pennsylvania of the are Mt are officials profonsional qualifications (PEMA), Their ..
hk. Agency attached to this testimony.
I ff m.
nr
! !f, LEA-11
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County and
% and Montgomery in that The draft CheaterRKim ' a are defielent availabic to
- h5I School Dintrict information enough bunos lf4 l
tQ c
thoto in innufficient there will be nd private, i
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'y reasonably assure thatto evacuate the schools, both publ c a
, .s in one lift.
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2 the basic 0
structured around This contention is been made to ensure. that Have arrangements questions the available to evacuato
+
cufficient buses will be readily Ancillary questions are then posed
, schools within the EPZ7 i
' ce follows:
f j
a
- 1. What assurance is there that designated bus i
companies will actually provide the buses needed?
r 2, Are letters of agreement with bus companies
?
definitive.in setting forth the obligations of each party and can the agreements be enforced?
3.
Do the plans have to include preassignment of p
buses to specific schools?
i l J 4.
Will the normal or emergency-related bus coquirements of school districts outside the EPZ .
impede the availability of buses needed for ...
evacuation?
or should be, in place to
- 5. What procedures are, the area ensure that designated buses from outside of normal school bus resources can be timely and offectively utilizett?
ith 6.
Does Chester County have written agreements w i i bus companies to provide buses needed for
- evacuation of school childron?
9
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L. .
- 1. It is PEMA's position that should an evacuation become must be in place to ensure the necessary arrangements a timely manner by using one cotion can be accomplished in multiple bus trips. This requires a lift rather than The first stop is for f coordinated effort by many parties.
cach risk school district to determine how many buses it If will require and the number that are readily available.
school district then are not owned >y the the buses the impact of prior n must be given to consider availability .of scheduling I
by the supplier on the prompt the buses needed. After this determination has been made county as the school districts than notify their respective to the number of busca available to them and the shortages, one-lift evacuation.
I if any, that must be met to effect a ,
to Each risk county emergency management agency then tries the arrange to meet those shortages from resources within reports its county, If this cannot be done the county PEMA. It total school bus shortage ac an " unmet need" to now bocomes PEMA's responsibility, in coordination with the to fill these of Transportation, Pennsylvania Department from unmet needs by arranging to utilize bus resources If this cannot be dono the countios outside the Plumo EPX.
!?Et!A for assistance ultimate recourue is for PEMA to ask This is, and has been, the concept fl from adjoining states.
response to any emergency within to fill unmet needs for In short, the procedure the bomonwealthofpennsylvania.
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to satisfy resource shortages is for the that is in effect i
- t the county to township or borough to go to its county and j (
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. to than for direct negotiation,s -township PEMA rather (R..Hippert) b3 rough or county to county.
Pennsylvania Emergency with the
- 2. In accordance P.L. 1332, No. 323, Sec t i = 1,"
Mnnagement. Services Code, Sechn 'I tot e scq, 3 in developing plans for C.S.A., PEMA, ccdified in 35 Pa. and power with the duty charged cmergency response, is for the availability and
"<t>o plan and make arrangements services and property and, use of any private facilities, for and if in fact used, provide for payment if.necessary,
} and conditions agreed upoa." 35 Pa. C.S.A.
i use under terms and 4, responsibility 7313(10) . Given this defined 8 ctp PEMA, acting on behalf of authority it is incumbent upon thq: Commonwea,lth and in coordination with the Pennsylvania make feasible and Transportation, to Department of to ensure that any school bus l offective arrangements it by the risk counties will indeed be shortage reported to becomes necessary.. The need for filled if an evacuation emphasized in 35 Pa, C.S.A.
these arrangements is further
"ubject Section 7301( f ) (4 ) , which empowers the Governor, componnation under any applicable requirements for to
<to) commandeer or utilize any private Section 7313(10) ...
cupe with the disastor emergency.
prop'erty if necessary to (11. IlipPe r t) from
- 3. On September 10, 1984, PEMA received notification Services by Department of Emergency the Chester County that the county had an unmet ,
letter da'ted September 4, 1984 Subsequent contact with the county i need for 134 buses.
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l busos to of 80 I shortage consisted r;vealed that this the evacuation.of and 54 for school children others ovecuate tho handicapped and I
transportation, Although PEMA
' parsons without automobiles.
private I able to leave by h ld be *'
Chester County that these figuros s ouh I'b M LD PY E M R not wca advised.by cond sn 4cd3 ne rev ie !4ne -have---been, subject to change, Mn q> pro (aIncde.lg )GC b@M considered C (b $^ W Ol h D.b s c' c WC.[.C@< l .. HippertJA fW.Ed % 39 f
l R W A C C.C $ (YN04 the Montgomery County Office o f uh October 23, 1984, copios of '
- 4. On PEMA two f transmitted to Emergency Emergency Preparedness. 1984, Itadiological f
l its Draft 7, dated October at the Limerick Generation
/ .
for Incidents
\ Response Plan , Annex 0 of this plan,
/
Upon checking Appendix Q-1, buses and S t;a tion.
Montgomery County needod 307 lea rnud" . tha t the county, and PEMA within quantity available from had that ds for the evacuation of k thus was reporting no unmet bus nee formal indication that PEMA This was the Cirst adequacy of busos, schools. County regarding from Montgomery shortage of sovon had report a did Montg'omery County those were While subsequently learned AlVkt<\h that We q'., cut m eC.Qtes ,
" coach buses," PEMA nwaxe-o-f-evacuation.
P EM A-immt O b1NM*>) -
not required for school u PrcpCMOCCd5 a rd 4 ng- thce e c' Lod. %cSMiWiGb1n7 3 MEmerks s6afh ns agreemen-us c Nai4 the - n ouuu x T,-A< freemen e,.c ccdentow&
thtn. c aru ou haI:d '7f PLfG A ts ncC au'ecm CdnbQOu,0.\L orJroemen t.
GLC wkwA-u. lad La-A n(Y/ '4ee.m2 of-tsudv amtm.htny ,
ne iho t ifo r eitc u d o r a f t 7.
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", ! YfG$atumvi.uu st D\cht C - NW D GL Tia <iM O>
m.any_
I ngreements a_t;e _ _ u n d e r
- ';dOW.fiY d Qin_ GS C .es 45 D-ahat
\0t%T Annax ?
ti t !Ypp t1 bved -
Authority ,
Pennsylvania Transportation its five
- 5. The Southeastern f buses to serve (SEPTA) maintains a largo fleet o
I. Montgomery, and t
, Chestor, Dolaware, area, Ducks, for county the logical sourco Philadelphia. SEPTA is therefore tho County, While Chester 5'~
filling the unmet bus noods of needed buses, ko commandeer the Covernor has authority to should be in l implementing procedures Cgreements and/or place to ensure that the busos are and will be PEMA available la to County, While shortage in Chester meet the the Department these arrangements, rosponsible for making to provido tho l the exportise I of Transportation has assemblage of buses, regarding l technical information transportation staging areas, travel times to estimated buses and similar procedures fair compensation for use of PEMA and the that should be addressed.
gr conditions together with their legal Department of Transportation, that could a proposed agroumont developing counsels are without the nood to h for filling the unmot needs provide the agreed--upot&
buses. If.this effort fails, dd~dh commandeer ed 9d.M CuY\%G invoked suppor Wofik IICAPthe Governor's bd.(rMW_t in 4X(dcN<L\gres proce .D}11 w be agreement is When the proposed commandoering of buses. in of Transportation, completed, PEMA and the Department SEPTA Chester County, intend to meet with conjunction with and willing to companies that may be able a'nd/or other bus hun shortages needed to effect agree in advance to meet the At present it of school children.
a one-lift ovacuation-agrooment should be between the county appears that such an lth serving gf and the bus company, with the Commonwea will be j involved The Doard its consummation, 2
as the catalyst for
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the ongoing status and progross being kept advised as to l unmet bus needs of Chester by PEMA to resolve the ,
) made i
County. (R. Hippert)' .
I LEA-12 and Derks County Montgomery, Chostor, are not RERP's The draft RERP's and the School Districtimplomented because will be there is not capable of being assurance that there staff required reasonable
)
j sufficient numbers of teachersasandschool a during a radiologica to stay at recommunded i shaltoringthat is if there,will be sufficient numbers with measure, or school staff availableof to a evacuate radiological of event not children in Therefore,the childrenERp's,are emergency.
-adequately protected by the draft R upon the is based i of this contention The thrust and school W be sufficient teachers question: ,ill there the safety of school children in staff available to ensure should be required?
or evacuation the event . sheltering Supporting questions are:
for presuming that teachers or
- 1. What basis is there stay on duty daring a school staff will radiological emergency?
Ilo'w will collective impact upon this r
bargaining agreements p ronump t ion?
tion in 2.
What is the basis for the apparent assump t for the plans that school buildings are adequa e f
sheltering as a protective action? ..
9
-- l lI5EUE t
ffective meano 3.
Are ongoing training programs.an e rring the of informing teachers and staff conco i l gical ' i nature and scope of a potential rad o o l
)
o emergency?
l district 4.
Can the capability to implement schoo ting i
plans only be demonstrated by conduc drills 7 i unannounced evacuation and sheltering staff in the teachers and school
- 6. The availability of a question that must be i k is Gvent of an accident that must schoolatdistrict Limer lovel, c and is one any c.ecolved at the officials in planning to meet be confronted by school or natural. If either majop disaster, whethor man-caused necesuary, classes sholtoring or ovacuation should become the normal thereby and not, be combined It is could be reduced.
could of students-to-teacher ratio report an alleged lack however, a feasible solution to need and expect it to bo .
as an unmet tocchers or staff Z. The time element filled by personnel from outside the EP such an alternative relying on a ,
cnd problems involved in likelihood precludo, f and in all hinder, children. (R.
would indeed of the school evacuation Prompt and safe Ilippert) that written so 1 l
school district plana are
- 7. At present, to accompany the are not only romain with teachers C school the risk l
are also to .
children '.to the host school but their parents or other ,
are picked up by they them until Y
t .
e f
- 1 Although not the procedure authorized individuals.
acceptable to and l preferred by PEMA, it is permissible if <
course of action l i districts. The desired by the school i is for the risk teachers to accompany the i t' preferred by PEMActwL % w& m h m t +o wtofficials. This children to the host schoo teachers and permits the risk teachers to be released to caro for or rejoin- their own families who may also be involved in the evacuation. While this could pose some problems at the host school, they are moru of an administrativo naturo and those confronting risk teachers do not have the impact of concerned with the safety of their own families as well as An agreement the children under their charge.
that of should resolvo between the host and risk school districts preventing use of any supposed administrative roadblocks M
This alternative might assist a this alternate procedure.
'h bYete- teachers risk school district to ensure that more of the children during the would be available to superviso evacuation phase only. (R. Hippert) raised about the
- 8. In response to the question buildings for sheltering, tho suitability of school Pennsylvania Department of Environmental Resources, Bureau l
in paragraph 10.2.2,2, of Radiation Protoction staton the Commonwealth's Disastor Appendix 12, Annex H to l climate of the that, "in the general l Operations Plan which is reasonably winter i l Commonwealth, any building and doors tightly worthy, will suffico, with windows action is a topic closed." Sheltering as a protective I
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I has been in the training that is available, and k in cddressed teachers and. school' staffs participating presented to P this training. (R. Hippert)
LEA-13 plans for and adequate There must in be specific nursery and pre-school day care, children provide roasonable assurance of the programs in order toparticularly sensitive segment that this population is adequately protected.the basic question:
The contention is contered around been accomplished to and specific planning Hcs adequate day care, and protection of children in cnsure the safety facilities? Additional questions nursery and preschool arq: ,
to evacuato day
- 1. Havo the transpor tation needs facilities been care, nursory and preschool determined and can they be met?
identify all 2.
Do municipal and county plans nursery
' licensed, as well an unlicensed day caro, and preschool facilities within the EPZ?
f 3;
Have arrangements been made for preassignment to o
the transportation resources needed to ovacua those facilition?
implomont
- 4. What will be the basis for a decision to
, sheltering at those facilities? ,
o f
4 h
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nursery and preschool with A model plan for use by day caro, in coordination
- 9. by PEMA fccilities has been developed and Public '
of Education Dopartments of ,
tho Pennsylvania subsequently sent copios and These two departments care, nursory l Walfare. to their licensed day EPZ and model plan ths the Limerick Plume within for procchool facilitica a plan of preparing of the necessity Unlicensed facilities cdvised' them ik advised responso to an accident at Limer c . have boon have subsequently been identified and ed for a plan and how to t N sgh -the risk counties of 'the (n. ne Ilippert) obtain help in developing one.
guidelines, recommended of an The mcdel plan providos policy B
in the event for notifying parents to be taken procedures listing of actions a detailed A samplo lotter to eccident and Id ' emergency classification. plan with explicit under each in the model the included by parents is be taken I
action that would P as to the
~
reference ..
(n. 1lippert) in the model plan facility.
have been made
- 10.
Although provisions i childron at a parents to be notified to pick up the rdirector also has for the facility General Emergency, at the Alert stago.
i for thin a. tion Site or to the option of arranging facility director the responsibility of the event the in host the children It is d host determine a location to Reference to the designate y they evacuation is necessary. letter to parents, and .-
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the site.is to be included in F
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children at this ,
to pick up.their cra cxpressly advisod (n. !!ippert) location if an evacuation takes place. ,
that transportation the model plan indicates
- 11. While the is the responsibility of evacuation required for facility to contact its the fccility, it also advises county or the municipal emergency management coordinator assistanco cmcrgency management agency, if necessary, for plan must be The facility developing a plan.
e in and prudent and municipal plan with the CCordinated should result in partion
[ rccponsible action by the
- two If not,
) transportation difficulties.
rocel,ution of any senso approach common rofor'ral to the county would be the to moeting#
the need. , (R. Ilipper t) and preachool f care, nursery of day
- 12. A listing f f in the respective municipal plans >
facilities should appear effort ]
j -
county plans. In view of the .I cnd corresponding ,
. C' . identify both the licensed and rec:ntly to exppnded why this --
l.
I unliconaed facilities, there in no viable reason ,
cannot be done. (R. Ilippert) l l
3 l LE A-14 (a) '
t the Choster, RCRP's and The School District are deficlont of provinions uniLa Dorks, and Montgomury County itMite'uinadequato becauno of douimetry-Ki there are for uchool buu driveru, teachera, i staff who may be required of timeto orremain who may in or school the EPZ the EPZ for . prolonged make periodsmcitiple trips into to
..be, required to a radiological emergency due d 4n tho, event of shortages of equipment and personnel. .- l l-
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. :r This contention raises the specific question: and Berks, Chestor, districts and Why do not school issuing ,
provisions for County plans includo M:ntgtmery teachers, and school bus drivers, dC91mstry and KI to cchool staff. Accompanying questions are:
1.
Will all school buses be required to pass through the transportation staging area before reporting If not, how will tho to schools being ovacuated? ,
n drivers obtain dosimetry and KI?
2.
How many units of dosimetry /KI will be availablo
/
at tho transportation staging areas for 3erks, the
,e Chester, and Montgomery Countios and what was basis for dotiormining that this amount would be i l.
adequato? N l
3.
Sinco sheltering could be recommended shouldn't teachers and school staff be issued dosimetry and .
f r ,
trained in its use? it is PEMA's ll explained in response to LEA-ll it
- 13. As be the school childron evacuation of position that f in a'ono-lift bus movo, and PictlA has no reason accompl'ished prevLounty accomp11uhed. An this can be to doubt thnt being taken to onouro that I indicated, definitive action fu This will noods can bo filled. I reported unmet bus ;
trips and necessity for multiple IC therefore preclude the dosimetry or KI .
need to have
' accordingly there is no Dj.
t,
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W-Once drivers, teachers or school staff.
evailable for bus is effectively [
the school children evacuation of tha are enroute to host schools, thero underway and all buses l
teachers or staff to remain at the 10 no requirement for within the Eez, and thus no nood rick school district or Dosimetry or KI.
be issued either dosimetry for them to l
only to emergency workers, and school bus cnd KI are issued not considorod in drivers, teachers and school staff aro (11. Ilippert) this category for the reasons indicated above. .
only to the concept pertains not
- 14. The one-lift all persons to be ovccuation of school children but also to the This in principle would eliminate ovrcuated by. bus. l 4 or KI available at the :
nrc:ssity for having ,any dosimetry .'
a contingoney there is I staging atuaa. An transportation limited supply of a
cortainly nothing wrong in maintaining a area for potential uso in staging dosimetry and KI at the of a f,f The maintenance 'l manting an unforeseen development. ,,
is, of drivers of vehicles !
for routine iusue /
supply concept. '
one-lift however, not necessary in view of the i
(11. Itippert) 1.
l!
atated earlior, school staffa are not conaldered
- 15. As Lanued will not bb workern and therefore cmergoncy If l trained in ita uso.
need not be douimetry and ,' u}
dociaion will be upon sheltering becomes necessary the ' '
protection, of Radiation recommendationo from the nureau federal .
own sources, utilizing onitoring data from its . ,
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Similarly, the decision to itself.
cggncios and the plant from the same
.be basod'on data general tarainato shaltocing wouldare considered part o'C the a I
.caucces. School staffs populace as and dosimetry is not issued to the public termination the initiation or
' ;pr: condition to determining (n. Hipport)
I of cheitering as a protectivo action.
! LE.4-14 (b) -
County School and Montgomery The Chestor, aerks,fall bus to provide reusanable j District RERP's drivers, teachers, or for that school, properly trained assurance staff are t
l other school radiological emergencies.
question part of this contention the school For the.second teachors, and a drivers, Have the school bus to respond ist adequato training to enable them What J staff recolved radiological amargency?
a I) of fectively in the ovent of Follow-on questions is the basis for this determination?
cre: .
to deal with contaminated 1.
Have they been trained individuals and equipment?
d of Have they been advised as to the hazar s
- 2. to the use of equipment radiation expouure and onnuro their safuty?
f the
- 3. Do teachers andomplex staff know what areas o are to be used for I,
, school building or c .
- sheltering?
t l' ,,, \ .*- s yI: j:: .
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l b
the 4.
Has any training been accomplished asi to ty that handling of the potential-stress andf d anxduring e a f could be displayed by the school chil ren
}
radiological emergency?
I t they are i
I 5, Are bus drivers familiar with the rou es ,
to use?
drivers, ,
needs of school bus I 16.
Training specific to the to an accident at and school staffs for rosponse It is f trachers be offered.
has been and continues to amergency management al Limerick the 1 through contact with
- cvailable (D. Taylor ,
/
agency for the respective risk county.
l R pnippert).
- will i teachers drivero, school staffs and
- 17. School bus ecloose of radioactive I prior to any no have been evacuated there is N Hence, from the Limerick facility. persons material with contaminated dealing need for training in Further, in the remote for those groupa. the and/or equipment decontamination may beco ne necessary, to possibility that equipment would be referred and involved individuals the plume EPZ, periphery of decontamination centers at the (D. Taylor) ,
or at the masa care centers.
be inuued school staff personnel will not similarly, 10 ., have been evacuated prior to any ,
do&etry m because they will llence, material from the facility, release of radioactive *
- for instruction in the use of dosimetry. .
no need there is (D. Taylor) s
, r
{ n they routes If bus drivers are not familiar with theto provide t
thom
> 19.
then provisions must be made cro to travel (R..Hippert) ,
with strip maps.
f LEA-15 the and Montgomery County RERP's andcapable of being are not to The School ChesterDistrict RERP'sthe provisions mado to being because committed implemented drivers who areradiological emergency, or j! provide bus during a of alert are available stages during preliminary even inadequate.
[ deals with the LEA-11, this ' contention Like t an evacuation of availability of suf ficient buses to ef fec raising becomes more definitive by will the school children but Even if sufficient buses are available, Follow-on questions i
thei; question:
.) man them?
there be enour)h drivers to y are:
w the bus 1.
Are thoro lotters of agreement with buuou?
companies to provide drivers as well as ..
thorize or 2.
Do employnient or union contracts au conversely prohibit, the utilization of bus drivers to evacuate school children during athe If authorized, have radiological emergency?
p e u ist u n t i I? i cil ?
I deivoca been some of them may bc
- 3. Are bus drivers aware that the needed af ter the ovacuation to transport antors?
)
1
- children f rom host schools to masa care c s
O G
3 .
g '
J gi ,
l0 .
R . ,
sibility
' Have considerations been given Z may to give the pos a I 4. ,
that drivers living within the EP
' families e
higher priority to evacuating their own out of the i ;
i than to transporting school children ?
[ is to preclude this from happening EP37 What j ,
equired to 5.
Has the possibility of drivers being r evacuation been
) make multiple trips to ef?act the ,
programs?
j I . addressed in the ongoing, training Chester County has
,. response to LEA-11, l
As stated in In .the I 20.
PEMA the County's unmet bus needs.
identified for County has advised PEMA by Montgomery County, the no unmet bus case of are v #7 that there nature, copy of Annex 0, Draf t include the does not needs. This information co unty/ bus company 9 of any existing V or language position to comment T number in a In Therefore PEMA is not agreements. in this contention.
on the specific points raised unmet needa PEMA will fill reported drivo(~
making arrangements to a l
established to provido ensure that proceduros are arranging to fill When for each bus being made availablo. to thase necessary for the PEMA gives priority cognirement for unmet needs The school children. of of evacuation the unmet buo necdu l to fill both will be identifiable conources la recognized and general public schools and the (R. Hippert) handled accordingly. .
e f
l [
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AA '
L1A h
. RERP's are County, and Municipalmay be designated to State, who tend The order to radiological inadequate because farmersin of a as emergency workers ovent the provided adequato in been I livestock emergency have not ,
j ,
training and dosimetry.
Have farmers who is:
this contention the issue cuation to For j emargency workers after an eva and will training rocnter the EP3 as adequate t,
received questions o
tend livestock collow-on
/
be available?
0 dosimetry l cufficient ..
,3 ares ho would be in
- 1. Have the actual number of farmers w this category been identified?
allow vailable to 2.
Will sufficient dosimetry be a for multiple reentrios?
fl livestock" include?
- 3. What does the definition of "
be issued to -
- 4. Will an informational brochure and how often?
If so, when farmers?
training will refresher 5.
In addition to ongoing a regular basis?
training be offered to farmers on in the EPZ as w i t:h liventuck recognizing Carmera to limit the
- 21. In made no attempt workers, PEMA has what is meant by a emergency trict l i lture
/ ggg definitionoflivestocpnortoresthe U.S. Department of Agr county USDA ,
f armer , with livestock to responsibility of the It is the I
' (USDA) list.
l
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1 .
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1-- 1. .. .
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and the management agency county emergency agent, the comprehensive list and tunicipalities . involved to develop a Dosimetry must possible.
i cn2ure that it is as complete as identified.
than be available for the number dditional of farmers so dosimetry It is not' necessary, however, to have a replunishmont of multiple reentries or Each available for expendable items.
Dosimeters are not a supplies. self-reading dosimeters and two former will be issued as KI and a as well '
f dosimeter, EPZ.
parmanent-record d access to the.
i f' Docimetry-KI Report Form when author ze again, if can be used over Tha self-reading dosimeters the b9 dosimetry chargers located at n3cessary, rezoroing on dosimeters are to be The permanent-record iscufng poin.ts . originally issued, and ha' ured only bd the individuals to whom that ' person until no furthur '
by are to be retained (R. Hippert) ;
into the EPZ.
rcentries are to be made livoutock farmers with, or who keep, f
- 22. The reference to to the commonwealth's is found in several places in Annex B II .M. (6) page See paragraphs Disaster Operations Plan.
9, Tab G, Attachment D on '
E-16-2, V.A. pagos E-lG-D-3 and In none of the and VI.C.1, page E-17-8. '
Page sE-16-D-6-1 type the pbs:ano limited or restricted to any 3 references in (H. Ili ppo e t) of 11vostock. of the training provide for PEMA will the 23, While it is of instruction,
' instructoqs or a course train municipalities and T. of the counties to
); responsibility
,[.
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- L N
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organizations in their respective areasfeeparagraphII, Commonwealth Disaster Operations l I;
Annex E, App ndix 19, This would include training for farmers in the use li
.. Plan).
of an Emergency Workers Pll of dosimetry. The existence paragraph Instructor Course is specifically referenced in Such training f r III.H, page E-19-2 of Annox E. (It . Hippert) B farmers
- is currently available and has been offered to - ,
F Such training will continue to be affected by Limerick.
(D. Taylor) g cido available to all . farmers in the plume EPz. i G
a prepared by the
- 24. An informational brochure was s distribution to Pennsylvania Department of Agriculture for Island the plume EPZ of the Three Mile
, farmers within -1 be adapted by the I
Station. The brochure could
, then print and distribute the brochure within the. Limerick
),
' EPZ, as was the case in the TMI area.
(R. Hippert) li LEA-26 f aro The Draft County and Municipal 'RERP's 10 g deficient in that they do not comply with no ,
because there is 50.47 (b) (5)
C.F.R. notification of emergency i g
assurance of prompt be in place before an evacuation 'j s workers who must implemented, and there is no :
al' ort can be assurance of aduquato capability to conduct touto , (l alerting. 'f I
!G developed under the 25, This contention was apparently must be fully l and municipal EOCs assumption ,that county -
in-place, before the mobilized, and emergency workers n s
O g s -
> h' I
d system.
be alerted by activation of the siren public can be activated from the communication centers, The sirens can In 24-hours a day, in each of the risk counties. so manned that an accident escalates the unlikely situation any, can be if only minimal mobilization, 1
rapidly that by on-duty could be activated achieved, the sirens telephonic the communication centers, after personnel in and the risk county coordinators.
coordination between PEMA order acomplished, however, only upon Activation would be and coordinator to his communication conterof the of'the county as to the validity appropriate verification after ~
case situation and is
.rder.
o .This would indeed be a worst of omorgency worker the degree gsed only to illuuttato that to the capability for has little relation mobilization alerting would not be sirons. While route j ) activating the scenario, it is but a this worst-case possible in (R, Hippert) to be used if necessary.
supplemental system ,
of the sirens is to
- 26. The sole purpose of activation EDS, to the the public to tune their radios or TVs a alert evacuate, In to It is not an automatic notification above, as that referenced moving as fast situation feasible option and really be a ovacuation would not action to ho be the protective sheltering would EuS mouuage over the Droadcast of such a recommended. county without mobilization of the could also be handled EOC, jn. Hippert)
- H .
' _1)% ' .
i 4
- I
Appendix paragraph V. B., page E-0-2, 27, As indicated in Operations l Commonwealth's Disaster 3 of Annex E to the Plan, the sirens may be sounded:
- 1. When there is significant information that will ,
i l
reassure the public of their safety.
2., When the public is to be informed of a plant status that may load them to implement specific actions on their own.
- 3. When specific actions (to include protective actions) are to be taken by the public, erroneously to equate e
This contention appears "28.
airens only to "an ovacuation alert",
activation of the i t While an orderly and effective evacuation would necess ta o emergency workers, the sirens nearly full mobilization of the purposes enumerated above could be activated for any of well before thii3 degree of mobilization is coached. _
(R. Hippert) a 9
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9
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,ti [I PROFESSIONAL QUALIFICATIONS y ,' t
! .n MalPh J. Hippert a :.
il 4 a
y I am the Deputy Director, Plaas and Preparedness for the j.
d I am involved in planning f. '
Pennsylvania Energency Management Agency.
i 3
response to man-made and natural disasters at the State, countyl and .
amicipal level with emphasis on potential accidents at fixed nuclear 4:l '
l facilitics. 7ll w
I Joined the Pennsylvania Snergency Management Agency in M July, i
j ,
t
- 1980, as a planner in the areas refere'nced above and assumed myk presen '
For several months prior.to that I was a I Position in May,1981. ;,
consultant working on municipal preparedness plans for consnunities '
surrounding TMI.' , -
I In October,1979, I completed over 32 years of activo and t reserva military ' service with the last seven years on active duty as a I have held Anny Reservo '
G faculty member. at the U.S. Army War. College. mander l.
- assignments from platoon leader to battalion commander to deputy com , . . ,
i g These assignments. included responsibility for of brigade size units.
r.obilization planning and response to. civil disturbaaces, such as the liatts Riot in Los Angeles.
Public Relations Manager for a multi-My civilian positions were: ll plant international company; Advertising httnagerf an i for the same concern; (j j and Assistant to the Sales htinager for the Agricultural liivis on o ;
international chemical company.
I hold a B.S. in Business Administration fromllege. the Univeisity of i California and p M.A. in Political Science from Shippensburg h
~
State Co '
I ma a graduate of the U.S. Army Command and General Staff Coll l
t
[ Amy liar Co11cgo. ,
- i
.n . ,
s
- 7 ,. .
J O
. D.
BIOGRAPHY OF DONALD F. TAYLOR
- b Donald F. Taylor is prcsontlyManagement the Director of Training and Agency. His office i I
,Iducation for the Pennsylvania Emergencyis in Harrisburg, but he conducts a w . ;Ehrou6 h out the Commonwealth. :
r: Mr. Taylor, a native of western Pennsylvania, in Beaver received his Falla, ' it . nachelor's 'dsgram from Gansva college, which is locatedHe completed {'
% ylvania. at the University ,of Pittaburgh.
'a doct:rato 4-His employment with the Commonwealth of Pennsylvania began
~
h' Jia April,1977 when he was named as the Nuclear Civil Protection J0fficer cdd charged to develop the Pennsylvania Crisis Rolocation Plan. f L!n F sad Education. July,1978, Mr. Taylor was promoted to head the Office of Train hensiva training program in the field of emergency management. Mr. Taylor has experience as a high school teacher, a* He has also managed g 3 llege administrator. h writer. In addition
, solloca teachar and a co ! -
c political campaigns and has been a political speec for both ucus- : P to being the editor of two newsletters, he hun writtenHa served au the directorf, of a re I papera and magazinea.Mr. Taylor has also been active in several busincas ventures. ,f, Ltenter. He presently resides in New Cumberland, Pennsylvania. a
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