ML20203M914
| ML20203M914 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/27/1986 |
| From: | Goodwin M PENNSYLVANIA, COMMONWEALTH OF |
| To: | |
| References | |
| CON-#386-591 ALAB-836, OL, NUDOCS 8609050168 | |
| Download: ML20203M914 (6) | |
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DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION W SEP -4 P4 :37 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFRE CF ' U t.;a v 00CKlilNG A St mi.
In the Matter of
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PHILADELPHIA ELECTRIC COMPANY
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Docket Nos. 50-352-OL
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50-353-OL 1
(Limerick Generating Station.
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Units 1 and 2)
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ALS3P No. 81-465-07-CL COMMONWEALTH OF PENNSYLVANIA'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW CONCERNING THE ATOMIC SAFETY AND LICENSING APPZAL BOARD'S REMANDED ISSUE IN ALAB-836
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In accordance with 10 C.F.R. Section 2.754, the Commonwealth of Pennsylvania hereby files proposed findings of fact and conclusions of law concerning the remanded issue of the availability of bus drivers to evacuate the Spring-Ford Area and Owen J. Roberts School Districts.
1 Introduction On May 7, 1986, in ALAB-836, the Atomic Safety and Licensing Appeal Board affirmed the Third Partial Initial Decision issued by the presiding Atomic Safety and Licensing Board except with respect to the issue of the availability of bus drivers for the school buses needed to' evacuate the school children of the Spring-Ford School District and Owen J. Roberts School District in the event of an accident at the Limerick Generating Station.
In an attempt to resolve this issue, the licensee proposed that twi hundred (200) of its employees would l
volunteer to be trained and licensed to drive school buses at the two school l
districts. Training for the two hundred (200) volunteers would be completed by the end of September 1986. The use of these volunteers would be at the request of the Chester County Department of Emergency Services or the Montgomery County l
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Office of Emergency Preparedness. The adequacy of licensee's proposal was litigated before the Atomic Safety and Licensing Board on August 18 and 22, 1986.
FINDINGS OF FACTS The Commonwealth's proposed findings of fact are set forth as follows:
1.
The licensee's proposal to train and license two hundred (200) of its employees to be volunteer bus drivers was based upon discussions with the Commonwealth and the Emergency Management Coordinators for Chester and Montgomery County. It was determined that the volunteers would obtain a class 4 license which would qualify them to drive school buses. It was also determined that a ratio of three or four volunteers for each needed bus driver would be an adequate number of bus drivers to meet the needs of the two school districts.
Tr. 21195 (Boyer). The two hundred (200) volunteers would cover a need for fif ty-three (53) bus drivers, Tr. 21211 (Boyer).
2.
As of August 22, 1968, 58 empicyees of the licensee have received a class 4 license to drive school buses.
Forty-five (45) other employees were scheduled to take the licensing exam on August 25, 1986. A total of one hundred fifty-five employees have taken both the classroom training and driver training with another fifty to sixty (50-60) employees to complete their training within two weeks (September 5,1986).
Tr. 21296 (Boyer).
3.
The licensee plans to continue its training and licensing program until it reachen a total of two hundred twenty (220) volunteers, so that it would have a reserve available to fill in as present employees are transferred or retire.
Tr. 21212 (Boyer).
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The licensee is prepared to assume the responsibility for providing bus drivers ad infinitum.
Tr. 21227 (Boyer).
5.
The Chester County Emergency Management Coordinator (Mr. Campbell) and the Montgomery County Emergency Management Coordinator (Mr. Bigelow) were consulted concerning the licensee's proposal and were satisfied with that proposal provided that it was carried out by the licensee.
Tr. 21229-21232- (Campbell and Bigelow).
6.
The Chester County Department of Emergency Services will be provided with the names and addresses of the licensee's volunteers so that they may be enrolled as emergency management volunteers and can be contacted by the county if the need arises.
Tr. 21246 (Campbell). The Montgomery County Office of Emergency Preparedness also plans to enroll the licensee's volunteers as emergency management volunteers.
Tr. 21249 (Bigelow).
7.
The Superintendent of the Spring-Ford School District (Dr. Welliver) and the Superintendent of the Owen J. Roberts (Dr. Claypool) School District stated that they were satisfied that an adequate number of school bus drivers would be available to evacuate their respective school populations in the event of a radiological emergency at the Limerick Generating Station.
Tr. 21348-21349 (Welliver and Claypool).
8.
The Director of the Office of Plans and Preparedness for the Pennsylvania Emergency Management Ageucy stated that he had reviewed the licensee's proposal and was satisfied that a sufficient number of' bus drivers would be available to evacuate both the Owen J. Roberts and the fpring-Ford School Districts in the event of an accident at the Limerick Generating Station.
He also stated that this was the position of the Pennsylvania Emergency Management Agency.
Tr.
21267 (Hippert). This position was based on a review of the Owen J. Roberts and Spring-Ford plans which revealed a need for twenty-eight (28) drivers at the
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Pcg3 4 Spring-Ford School District and eight (8) drivers.for the Owen J. Roberts School District.
Tr. 21277 (Hippert).
9.
The Federal Faergency Management Agency stated its position that it had reviewed the licensee's proposal and felt that it was adequate for reasonable assurance that the unmet bus drivers would be met.
Tr. 21282,(Kinard).
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Prg2 5 CONCLUSION OF LAW The Commonwealth's proposed conclusion of law is as follows:
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That based upon the testimony entered on the record before the Atomic Safety and Licensing Board on August la and 22, 1966 by witnesses for the Philadelphia Electric Company, the Chester County Department of Emergency Services, the Montgomery County of Emergency Preparedness, the Spring-Ford and Owen J. Roberts School Districts.the Pennsylvania Emergency Management Agency, and the Federal Emergency Management Agency, there is clear and convincing evidence to support a finding by the Licensing Board of a reasonable assurance that a sufficient and/or adequate number of school bus drivers would be available to evacuate the school population of the Owen J. Roberts and Spring-Ford School Districts in the event of an emergency at the Limerick Generating Station.
Respectfully submitted, M [ 1.b-D i
Mark L. Goodwin Chief Counsel Pennsylvania Emergency M nagement Agency a
P. O. Box 3321 Harrisburg, PA 17105 Date: August 27, 1986
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USNRC 1S5 SEP -4 P4 :50 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE 0 ;i t.--
,i n y 00CKETihb a SERvict BRANCH In the Matter of
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Philadelphia Electric Company )
Docket Nos. 50-352
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50-353 (Limerick Generating Station )
Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of Commonwealth of Pennsylvania's Proposed Findings of Fact and Conclusions of Law Concerning the Atomic Safety and Licensing Appeal Board's Remanded Issue in ALAB-836 dated August 27, 1986 in the captioned matter have been served upon the following by deposit in the United States mail on the 27th day of August, 1986:
- Helen F. Hoyt, Esq.
- Docketing and Service Section Chairperson U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Benjamin H. Vogler, Jr., Esq.
Washington, D.C.
20555 Counsel for NRC Staff Office of the General Maureen Mulligan Counsel Limerick Ecology Action U.S. Nuclear Regulatory P. O. Box 761 Commission 762 Queen Street Washington, D.C.
20555 Pottstown, PA 19464 Troy B. Conner, Jr., Esq.
Spence W. Perry, Esq.
Conner and Wetterhahn General Counsel 1747 Pennsylvania Ave., N.W.
Federal Emergency Management Agency Washington, D.C.
20006 500 C Street, S.W.
Room 840 Washington, D.C.
20472
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Mark L. Goodwin l
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