ML20094B009

Application for Issuance of Subpoena Directing T Fewlass to Testify at Evidentiary Hearing on Offsite Emergency Planning Contentions Re Traffic Congestion within & Bordering Valley Forge Natl Park.Related Correspondence

ML20094B009
Person / Time
Site:	Limerick
Issue date:	11/02/1984
From:	Stone D, 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 8411060629
Download: ML20094B009 (4)

Text

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~ Subpoena requested: LEA-24 Chief Ranger Fewlass United States of America Nuclear Regulatory Commission BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station

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November 2, 1984 Units 1 and 2)

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s Motion on behalf of Limerick Ecology Action requesting the Atomic Safety and Licensing Board to issue a subpoena to Chief Ranger Thomas Fewlass (Valley Forge National Park) to attend and give testimony at evidentiary hearings on off-site emergency planning contentions on the issue of traffic congestion within and bordering Valley Forge National Park (Contention LEA-24/ FOE-1)

Pursuant to 10.CFR @ 2.720, Limerick Ecology Action hereby respectfully requests the Atomic Safety and Licensing Board in the above captioned proceeding to issue a subpoena to:

Chief Ranger Thomas Fewlass Valley Forge National Historical Park P.O. Box 953 Valley Forge, Pa. 19481-0953 (215-783-7900 office) requesting Chief Ranger Fewlass to appear at the U.S. Customs House, Second and Chestnut Streets (Room 300) in Philadelphia, Pennsylvania 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/ FOE-1.

LEA OFFERING OF PROOF Through conversations with FOE representative Bob Anthony, Chief Ranger Thomas Fewlass has shown a hands-on knowledge of existing traffic problems within the park, including the practical limitations of the roads.

8411060629 R41102 PDR ADOCK 05000352 4

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i Whereas the numerical data as to traffic flows can be extrapolated b

f from reports and statistical data as suggested in the attached letter from Valley Forge National Park Superintendent Elms, the real 3

consequences and frequency of heavy traffic flows can best be described by local experts with acutal experience and knowledge

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of local conditions, such as Chief Ranger Fewlass. In order to properly evaluate the sufficiency of proposed evacuation routes 7

through and bordering the park, existing conditions must be taken P

into consideration. Chief Ranger Fewlass' testimony will greatly z

contribute to the development of a sound record on this issue.

Based on his experience with crowd management and large number of visitors in the park, Chief Ranger Fewlass can provide valuable 7

information to the Board in this proceeding. LEA has been informed by Mr. Anthony that a subpoena would need to be issued to obtain this testimony. For the above reasons, LEA and Friends of the Earth request that the Atomic Safety and Licensing Board grant 3

our request to issue a subpoena for the testimony of this witness on contention LEA-24/ FOE-1.

Sincprely

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David Stone P

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LEA representative es e

for LEA-24/ FOE-1

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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 i

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 evacuation.

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United States Department of the Interior 1

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NATIONAL PARK SERVICE VALLEY FORGE NATIONAL HISTORICAL PARK g

P. 0. Boz 953 os an.Y mann To:

VALLEY FORGE, PA 19481-0953 N4615 VAFO(S)

October 31, 1984 Mr. Robert Anthony Box 186 Meylan, Pennsylvania 19065

Dear Mr. Anthony:

We have reviewed your request for detailed information relating to the park's response to a potential emergency at the Limerick Nuclear Plant.

As you are probably aware, only the northwest tip of Valley Forge National Historical Park lies within ten miles of the Limerick Nuclear facility.

The only visitor facility within the ten-mile circle is a small trailhead parking lot.

However the state and county emergency preparedness agencies have designed the state highways that pass through the park as evacuation routes for those persons residing within the ten-mile radius.

Our planning efforts have been and will continue to be directed primarily toward assisting the counties in implementing their evacuation plans.

To this end we have met with emergency planning officials of both Chester County and Montgomery County to discuss, in general terms, the park's role in a general evacuation. Another meeting with officials of both counties is scheduled for November 7, 1984. We anticipate that more specific guidance will be obtained at that time.

Valley Forge National Historical Park does not have the staff expertise to determine the carrying capacities of the state highways that would be used should an evacuation be necessary.

You are welcome, however, to the statistical data we have in our files relative to counts of vehicles using park roads.

Records are available, by date, for incoming traffic on each of the roads entering the park.

Hourly counts are not available, however, visual observation confirms that travel

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is heaviest between 7:00 a.m. and 9:00 a.m. and between 4:00 p.m. and 6:00 l

p.m. on weekdays.

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To summarize, we will work with Montgomery and Chester counties and rely prime.rily on their plans for guidance in actions taken by the park in the the event of a nuclear emergency at Limerick. We would also be glad to provide factual information from our files; however, we are unable to spe-culate obout matters beyond our expertise.

Sincerely yours, rm Superintendent ec: Limerick Ecology Action

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