ML20199E513

Forwards Affidavits of AL Bigelow & Vs Boyer Re Availability of Volunteer School Bus Drivers for Oj Roberts & Spring-Ford School Districts in Event of Evacuation,Per

ML20199E513
Person / Time
Site:	Limerick
Issue date:	06/19/1986
From:	Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Cole R, Harbour J, Hoyt H Atomic Safety and Licensing Board Panel
References
CON-#286-670 OL, NUDOCS 8606230318
Download: ML20199E513 (1)

Text

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4-LAW OFFICES oi g

CONNER & WETTERHAHN. P.C.

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CABL 3: ATOM LAW Helen F. Hoyt, Esq. Dr. Richard F. Co 4 /

Chairperson, Atomic Safety Atomic Safety and Licensing and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry Harbour

Atomic Safety and Licensing Board U.S. Nuclear Regulatory

Commission

! Washington, D.C. 20555 I

In the Matter of Philadelphia Electric Company (Limerick Generating Station, Unit 1)

Docket Nos. 50-352 and 50-353 - d C

Dear Board Members:

On June 16, 1986, I forwarded to the Licensing Board i " Licensee's Proposal for Resolution of Pemanded Issue Regarding the Availability of School Bus Drivers for the Owen J. Roberts and Spring-Ford School Districts," as required by the Board's Order dated May 22, 1986. At that time, I indicated that the originals of the affidavits of "

Mr. A. Lindley Bigelow, Coordinator of Emergency Prepared-

ness for Montgomery County, Pennsylvania, and Vincent S.

Boyer, Senior Vice President Nuclear Power, Philadelphia Electric Company, would be forwarded as soon as they were

! received. In accordance with that letter, enclosed please

. find copies of those documents, the originals of which have been sent to Docketing and Service.

Sincerely, L

e6%2ggy e%p$ga g g 1N 6 . %)L./* j PDR Troy B. Conner, Jr.

O Cou'sel n for the Licensee i

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I UNITED STATES OF AMERICA O'l I Q NUCLEAR REGULATORY COMMISSION O 4 Before the Atomic Safety and Licensing E D

d Dy - h In the Matter of ) JUN 2 019865-lr

) Doca nua a Philadelphia Electric Company ) Docket No h.f50T35'2:7 0-353' Oct /Q[f

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(Limerick Generating Station, ) -g //yw'. ,. .i\" ' .Q Units 1 and 2) ) L ii' AFFIDAVIT OF VINCENT S. BOYER VINCENT S. BOYER, being first duly sworn, hereby deposes and says:

My name is Vincent S. Boyer, I am Senior Vice President, Nuclear Power, Philadelphia Electric Company, owner and operator of the Limerick Generating Station.

I am familiar with the Order of the Atomic Safety and Licensing Appeal Board, dated May 7, 1986, which remanded Phase l Three of the proceeding to the Licensing Board for.

consideration of the availability of bus drivers for the school district plans for the Owen J. Roberts and Spring-Ford School Districts.

Since the close of the record in this proceeding in 1984, our Company has continued to cooperate with the State, county and local authorities in implementing their emergency plans involving Limerick. Our efforts included the developing of ,

volunteers from the Company for various aspects of the plans.

Among these efforts was the identification of employees who

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posses drivers licenses, who would volunteer to drive buses, if needed, in the event an actual evacuation were ordered.

On December 28, 1984, Chester County had specifically requested Philadelphia Electric Company to determine what additional volunteers might be available to assist in emergencies. Various discussions occurred concerning Chester County's developing efforts, as well as those of Montgomery County.

At the time the Appeal Board Order was issued, Philadelphia Electric Company intensified its program to obtain volunteer bus drivers. As of this date we have numerous drivers who could reach the marshalling center for Chester County at Exton and the Company's Berwyn Transportation Center, from which drivers can be dispatched as appropriate for i

Montgomery County.

At the present time there are 570 Philadelphia Electric employees who have volunteered to do the following for Chester and Montgomery Counties:

(a) To drive school buses as may be necessary in the event so requested by the county coordinator under the county's emergency plans.

(b) To take training to qualify for a Commonwealth of Pennsylvania Class 4 driver's license which applies to the operation of school buses and to maintain such license.

8 Two hundred seventy Company individuals who can reach Berwyn within 30-90 minutes have now volunteered to serve as school bus drivers in the event of an emergency requiring evacuation. The estimates show that for Berwyn, 105 could arrive within 30 minutes, 40 within 60 minutes and 125 within 90 minutes. For Exton, 300 have volunteered; 95 could arrive within 30 minutes, 25 within 60 minutes and 180 within 90 minutes.

A13ei 44 t Vincent S. Bofer Subscribed and sworn to before me this /3 P-day of June, 1986 l

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Notary Publyc Y

MELANIE R. CAMPANELt.A Notary Public. Philadelphia. Philafef;hla Co.

My Corrmission FJpires Fe6tua012.1930

4

( (D 9 UNITED STATES OF AMERICA g 4 NUCLEAR REGULATORY COMMISSION w., ,n

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• Before the Atomic Safety and Licensing Bodd JUM 2 9 198 F [ '

&' ect ~50 4; 'I i In the Matter of ) 32 ' ~%f

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Philadelphia Electric Company ) DocketNos.50-352/Jy M\p

) 50-353 C- i*

(Limerick Generating Station )

Units 1 and 2) )

AFFIDAVIT OF A. LINDLEY BIGELOW A. LINDLEY BIGELOW, being first duly svorn, hereby deposes and says:

My name is A. Lindley Bigelow. I am the Coordinator of Emergency Preparedness for Montgomery County, Pennsylvania. My office is at 50 Eagleville Road, Eagleville, Pennsylvania, 19403:

I am familiar with the Order of the Atomic Safety and Licensing Appeal Board, dated May 7, 1986, which remanded Phase Three of the pro-ceeding to the Licensing Board for consideration of the availability of bus drivers for the school district plan for Spring-Ford School District.

That order, as applicable to the Spring-Ford School District, suggests that only 57 5% of the drivers for the school district would, in fact, perform in the event of an emerency. Based on my experience, I do not agree that the drivers would fail to perform their duty.

Tr. 1h293 Moreover, I have made arrangements with other bus companies out-side the EPZ to provide buses and drivers if necessary for an evacuation.

The total number of buses available in Montgomery County, as reflected in our latest annual survey, is 1,257 (does not include 242 minibuses, M

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4 205 vans, and 79 handicapped vehicles) and the total number of drivers is 1,919, recognizing that these numbers change continually. On this basis, I am confident that there would be no shortage of drivers for any evacuation of the Spring-Ford School District.

In addition, the Philadelphia Electric Company has advised me that it has identified 270 individuals, each of whom has agreed (a) to drive school buses in Montgomery County as may be necessary upon my request.

(b) to take training to qualify for a Commonwealth of Pennsylvania Class k driver's license, which author-izes operation of school buses, and to maintain it.

These individuals have also agreed that, upon my request, they would report to the Berwyn Transportation Center, where they could be transported wherever needed in Montgomery County, to include the Custer Garage, to drive any buses as may be necessaryin the Spring-Ford School District. Further, Philadelphia Electric has advised me that it estimates that 105 of the volunteers could arrive at Bervyn within 30 minutes, h0 within 60 minutes, and 125 within 90 minutes if needed.

(b -f A. Lindley Bigelow'

/

Subscribed and swo to before me this /

day of June, 1986.

( NM // N/ nc Y Notary Public My commission expires

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