ML20094A995

Application for Issuance of Subpoena Directing N Vutz to Testify at Evidentiary Hearings on Offsite Emergency Planning Contentions Re Traffic Congestion in Vicinity of Valley Forge Park.Related Correspondence

ML20094A995
Person / Time
Site:	Limerick
Issue date:	11/02/1984
From:	Stone O, Zitzer P LIMERICK ECOLOGY ACTION, INC.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20094A993	List: ML20094A989 ML20094A995 ML20094A999 ML20094B002 ML20094B006 ML20094B009 ML20094B013 ML20094B017 ML20094B020 ML20094B026
References
OL, NUDOCS 8411060625
Download: ML20094A995 (2)

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7 L -4 Subpoena requested: LEA '"

Norman Vutz UNITED STATES OF AMERICA 0$ff"?50 NUCLEAR REGULATORY COMMISSION

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, BEFORE.THE A *d3

-ATOMIC SAFETY AND LICENSING BOARD r--

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In the Matter of ) Docket Nos. 50-352 PHILADELPHIA ELECTRIC COMPANY November 2, 1984 (Limerick Generating Station )

Units 1 and 2) )

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M01' ION ON-BEHALF OF LIMERICK ECOLOGY ACTION REQUESTING THE ATOMIC SAFETY AND LICENSING BOARD TO ISSUE A SUBPOENA TO NORMAN VUTZ TO ATTEND AND GIVE TESTIMONY AT EVIDENTIARY REARINGS ON OFF-SITE EMERGENCY PLANNING CONTENTIONS ON THE ISSUE OF TRAFFIC CONGESTION IN THE VICINITY OF VALLEY 70RGE PARK (Contention LEA-24/F0E-1) i l Pursuant to 10 CFR $2.7.20, Limerick Ecology Action hereby respectfully requests the Atomic Safety and Licensing Board in the above captioned proceeding to issue a subpoena to:

Norman Vutz

• Country Club Road Phoenixville, Pa. 19460 (home phone 215-935-2894) requesting Mr. Vutz to appear at the U.S. Customs House, Second and Chestnut Streets (Room 300) in Philadelphia, Pennsyl-vania on November 27th., 1984 at 9:00 a.m. and to be on 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> phone alert standby every day thereafter until called to testify on behalf of Limerick Ecology Action on the subject matter of contention LEA-24/F0E-1.

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l LEA 0FFERING OF PROOF Mr. Vutz is employed by Louis T. Klauder and Associates, Transpor-tation and Mass Transit Consulting Engineers. He is the Emergency Management Coordinator and a township Supervisor in Schuylkill Township Chester County and holds a doctorate (Ph.D.) in nuclear l science. 8411060625 841102 l

PDR ADOCK 05000352 O PDR

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Mr. Vutz's dual role as Emergency Management Coordinator and Township Supervisor gives him particular knowledge of the existing traffic conditions due to the limited roadways surrounding Valley Forge National Park. In addition, the Township has been involved'in a long standing zoning dispute (Fernley, McNeil and McCracken vs. the Board of Supervisors) l which involves these same traffic problems. His professlona1 work in analyzing transportation and mass transit capacities has given him direct experience relevant to issues et traffic flow and capacity.

His professional qualifications in nuc ear science and transportation analysis make him uniquely qualified to assist in the development of a sound record on'the subject matter of contention LEA-24.

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LEA was unable to obtain written testimony from Mr. Vutz and believes that he would make a significant contribution to this proceeding if the Board grants LEA's request for a subpoena.

, Respectfully submitted, r

h David Stone Phyll Zitzer Pres dent LEA Representative LEA-24 cc: Service List Subpoena Forms sent to Board only LEA-24/F0E-1 (Lead Intervenor: LEA)

There is no assurance that plans for evacuation of the ten mile radius will not be impeded by traffic congestion in the vicinity of Marsh Creek State Park, Exton area (involving Route 100) and Valley Forge Park, King of Prussia area.

These areas should either be included in the Emergency Planning Zone or .

adequate plans for traffic control and direction should be made to avoid adverse effects on EPZ evacuaticn. _

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