ML20094B017

Application for Issuance of Subpoena Directing R Fetters to Testify at Evidentiary Hearing on Offsite Emergency Planning Contentions Re Traffic Congestion in Marsh Creek State Park. Related Correspondence

ML20094B017
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 8411060631
Download: ML20094B017 (7)

Text

l Subpoena requested: LEA-15, LEA-24 o Robert Fetters, Jr. j UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

)

In the Matter of )

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

Units 1 and 2) ) November 2, 1984

)

MOTION ON BEHALF OF LIMERICK ECOLOGY ACTION REQUESTING THE ATOMIC SAFETY AND LICENSING BOARD TO ISSUE A SUBPOENA TO ROBERT FETTERS, JR. TO ATTEND AND GIVE TESTIMONY AT EVIDENTIARY HEARINGS ON OFF-SITE EMERGENCY PLANNING CONTENTIONS ON THE ISSUES OF TRAFFIC CONGESTION IN THE VICINITY OF MARSH CREEK STATE PARK AND ROUTE 100 SOUTH IN UPPER UWCHLAN AND UWCHLAN TOWNSHIPS, CHESTER COUNTY & THE AVAILABILITY OF BUS DRIVERS DURING A RADIOLOGICAL EMERGENCY (Contentions LEA-15 and LEA-24/ FOE-1)

Pursuant to 10.CFR g2.720, Limerick Ecology Action hereby respectfully requests the Atomic Safety and Licensing Board in the above captioned proceeding to issue a subpoena to:

Robert Fetters, Jr.

RD#2 Downingtown, Pa. 19335 (home phone 215-458-5201) requesting Mr. Fetters to appear at the U.S. Customs Court House, Second and Chestnut Streets (Room 300) in Philadelphia 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 l every day thereafter until called to testify on behalf on Limerick Ecology Action on the subject matter of contentions LEA-15 and LEA-24/ FOE-1.

l l LEA OFFERING OF PROOF l

Mr. Fetters is the owner / operator of Robert Fetters, Inc., a contracting l

company which owns and operates 28 school buses in Chester County.

l When contacted by LEA representative David Stone about the availability 8411060631 841102 PDR ADOCK 05000352 4 O PDR

of his drivers in the event of a radiological emergency, Mr. Fetters stated that it was his experience indicsoed that bus drivers should not be assumed to be available when the safety of their own families migth be at risk. His testimony would help to develop the record on contention LEA-15.

Mr. Fetters is also the Emergency Management Coordinator of Upper Uwchlan Township, the municipality which includes Marsh Creek State Park. Route 100, a major north-south evacuation route passes through the middle of the township. Mr. Fetters has informed Dave Stone that he is concerned about the adequacy of plans for traffic control around Marsh Creek State Park, as well as the road capacity of back roads onto which traffic from the park would be directed according to the latest draft Padiological Emergency Response Plan for Upper Uwchlan Township.

LFA was unable to obtain written testimony from Mr.~ Fetters and believes that his testimony would assist in the development of the record on these issues in this proceeding.

Respectfully submitted, 1LJ Swt -

David Stone

$. 1 A o L

LEA representative for LEA-24 phyllis Zitzer, President cc: Service List Subpoena Forms sent toBoard 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 of Prussia Park, Exton area. area (involving Route 100) and Valley Forge Park, King 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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). a UWCllLAN 70WNSilIP RESOLUTION NO. 84-17

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A RESOLUTION ADOPTING THE TRAFFIC MASTER PLAN AND ENGINEERING STUDY, PENNSYLVANIA ROUTES 100 AND 113 CORRIDORS .

Wi!EREAS , considerable development activity has already taken place and much more is anticipated throughout the Township during the next ten (10) years; and WHEREAS, the Board of Supervisors of Uwchlan Township, foreseeing major traffic problems in the future without improvements to the existing road system in the  ;

northeastern portion of the Township, commissioned a comprehensive traffic  !

engineering / master plan study; and WHEREAS, said study was recently completed by Orth-Rodgers and Associates, Inc.,

Philadelphia, which firm developed various recommendations for solving the anticipated traffic problems; and WHEREAS, said Board of Supervisors deems that the cost of the traffic recommenda-tions as outlined in the attached document should be borne equally by the parties j creating the demand for traffic improvements, with payments for same *o be made in accordance with the schedule contained therein, NOW, THEREFORE, it is hereby Resolved by the Board of Supervisors of Uwchlan Township, Chester County, Pennsylvania, that the Traffic Master Plan and Engineering Study attached to this Resolution is hereby adopted as the Township's official Traffic Plan.

This Plan may be amended, from time to time, by Resolution of this Board of Supervisors.

RESOLVED AND ENACTED this 12th day of March , 1984 .

UWCHLAN TOWNSHIP BOARD OF SUPERVISORS

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/44.%t . Gtt C I, b.

hChairman Attest: - /

7 O re Y $

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l TRAFFIC ENGINEERING MASTER PLAN STUDY PA. ROUTE 100 AND PA. ROUTE.113. CORRIDORS UWCHLAN TOWNSHIP,

- CHESTER COUNTY,. PENNSYLVANI A 1

! PREPARED BYi 7 ORTH-RODGERS & ASSOCIATES, INC.

FEBRUARY, 1984 1

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LIST OF ILLUSTRATIONS FIGURE No. PAGE No.

1 Location Map, Uwchlan Township, 2 Chester County, Pennsylvania -

2 Potential Land Development Areas 5 3 1983 Estimated Average Daily Traffic (ADT) 8 Uwchlan Township, Chester County 4 Existing (1983) Traffic Volumes 10 Morning Peak Hour Uwchlan Township, Chester County (7:30 A.M. to 8:30 A.M.)

5 Existing (1983) Traffic Volumes -

12 Evening Peak Hour Uwchlan Township, Chester County

- i (4:45 P.M. to 5:45 P.M.)

6 Existing (1983) Levels of" Service - 17 Uwchlan Township, Chester County -

7 Uwchlan Township. Master Plan 20 PA Route 113 (L.R. 270) and PA Route 110 (L.R. 147)

Accidents 1980-1982/ Township Records 8 Potential Land Development by 1993 24 Uwchlan Township, Chester County 9 Direction of Approach / Departure 28 New Development Generated Traffic Uwchlan Township, Chester County * '

10 1993 Morning . Peak Hour Traf fic Volumes 31 with Crump Road Extension Uwchlan Township, Chester County 11 1993 Evening Peak Hour Traffic Volumes 32 with Crump Road Extension Uwchlan Township, Chester County

o s.

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LIST OF II.LUSTRATIONS l

-FIGURE No. PAGE No.

I 12 Proposed Master Plan Improvements 37 Route 100 and Route 113. corridors Uwchlan Township, Chester County 13 Typical Cross-Sections 3S Proposed Widening Along ~

-PA Route 100 and PA Route 113 14 Proposed Master Plan Improvements for the Intersection of PA Route 100 and PA Route ll3 Uwchlan Township, Chester County

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TABLE OF CONTENTS l

PAGE NO.

INTRODUCTION 1 EXISTING CONDITIONS 4 ROADWAY CONDITIONS 4 EXISTING TRAFFIC VOLUMES 7 LEVEL OF SERVICE AND f

VOLUME / CAPACITY RELATIONSHIPS 11 ACCIDENT HISTORY 19 FUTURE GROWTH AND DEVELOPMENT AND ANTICIPATED TRAFFIC IMPACT 21 FUTURE REGIONAL GROWTH' 22 FUTURE DEVELOPMENT 22 .

THE FUTURE TRAFFIC SITUATION 30

! FUTURE PROBLEM AREAS 34 THE TRAFFIC IMPROVEMENT PROGRAM 36 PROGRAM COST AND IMPLEMENTATION 44 I

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