ML20205A278
| ML20205A278 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/05/1986 |
| From: | Hippert R AFFILIATION NOT ASSIGNED, PENNSYLVANIA, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20205A265 | List: |
| References | |
| OL, NUDOCS 8608110340 | |
| Download: ML20205A278 (10) | |
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4 UNITED OFAMERICh N' CLEAR REGULATORY COMMISSION U
abaNtk Licensing Board
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Before the A GFFICE OF f,.fM 00CMETitv; $
In the Matter of BRt.NOi) hj, Philadelphia Electric Company
) Docket Nos. 50-352
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50-353 (Limerick Generating Station,
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Units 1 and 2)
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d TESTIMONY OF RALPH J. HIPPERT FOR THE COMMONWEALTH OF PENNSYLVANIA RELATIVE TO THE AVAILABILITY OF BUS DRIVERS TO EVACUATE SPRING-FORD AREA AND OWEN J. ROBERTS SCHOOL DISTRICTS AS REMANDED BY THE ATOMIC SAFETY AND LICENSING APPEAL BOARD UPON APPEAL BY LIMERICK ECOLOGY ACTION Draft 6 (dated 1985-86) of the Spring-Ford Area School District Radiological Emergency Response Plan.was reviewed by the Pennsylvania Emerge'ncy Management Agency (PEMA) in January 1986. As indicated in of that Plan, the District would require a total of 70 buses to effect an evacuation of the public and private schools located within the District. It is further indicated that only 44' buses are ava'lable to i
the District, leaving 26 as an unmet need to be satisfied by Montgomery County. Three of the available buses are reportedly operated by the Chapel Christian Academy, r,esulting in a balance of 41 to come from the Custer Bus
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Company, which is confirmed in Attachment 1 of the Spring-Ford School District Plan. While the validity of the Spring-Ford driver survey, wherein more than 50 percent of tho'se' contacted' failed to respond'or were uncertain, is indeed debatable, 13 individuals did agree to drive in the event of a radiological emergency (ALAB-836, page 68). Based upon the Spring-Ford Plan and the District survey there is a shortage of 28 drivers for the Custer buses.
8608110340 860003 PDR ADOCK 05000352 T
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The latest Radiological Emergency Response Plans available to PEMA for the Owen J. Roberts School District is dated December 30, 1985 and is referenced by the District as Regulation 6114.4 As indicated in, page 6114.4(annn), a one-lift evacuation would require 52 buses and only 26 are available to the District, leaving an unset need of l
26 to be met by Chester County. The buses reported as available in the l
referenced plan are provided by the Gross Bus Company. Based upon Dr.
i Claypool's conservative interpretation of his survey of 43 Gross Bus Company drivers, 18 would be available to drive buses if an evacuation became necessary (ALAB-836, page 66). This leaves a shortage of 8 drivers for the normal complement of 26 buses provided to the District by the Gross Bus Company.
i Using only the two survey results detailed above, there would be a shortage of 36 drivers for the 67 buses routinely provided by the two bus companies. To meet this requirement, the Licensee originally proposed to
~ establish from'its wor'k force a pool of 570 traine'd'and licensed school bus drivers who would be readily available if evacuation of the two school districts should become necessary. In his July 24, 1986 letter to the 4
Board and parties, Mr. Conner advised.that a reassessment of the j
requirement resulted in a reduction from 570 to a proposal for the j
establishment and maintenance of s pool of 200 employees of the Licensee to be' trained and licensed'as' school bus drivers. This reduction is t
acceptable to PEMA and is still over five times the driver shortage identified by the two school districts for the 67 buses normally provided each schoo'1 day by Custer and Gross Bus Companies.
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It is the Commonwealth's position that if an evacuation of the schools should become necessary, due to.an accident at any one of the five nuclear power plants within Pennsylvania, it is to be accomplished in a one-lift operation. To do this for Spring-Ford Area and Owen J. Roberts School Districts an additional 52 buses will be required and this has been reported as an unset need to the respective counties. Both this Board and the Appeal Board have ruled there is reasonable assurance that there are sufficient bus resources within Montgomery and Chester Counties to satisfy this unset need. With this as a given, assume a worse case situation wherein no drivers were available for these 52 buses. The shortage then becomes 36 plus 52 or a total of 88. The pool of 200 drivers to be maintained by the Licensee is still over twice this number.
In its June 30,' 1986 answer t'o the Board, PEMA did address the Licensee's proposal as an immediate solution to the question of driver availability. By the same token, PEMA, however, also indicated that the-pr'opo's'al was acceptable based upon assurances from the Licensee that all conditions and provisions contained in the Stipulation and accompanying June 27, 1986 letter to me from Mr. Conner would remain in effect until a complete long-term resolution is reached. If a better solution cannot be reached, then the Licensee has no alternative but to maintain the driver pool indefinitely. Until a better solution is developed, if indeed there
- really i one', PEMA will not agree to release the Licensee from'the conditions and provisions of the above referenced Stipulation and letter.
~A long-term solution would be one that does not abrogate the joint responsibility of the counties and school districts for protecting the health and safety of the students to another party, namely the 3
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i Licensee. Before an unset school district need is passed to the county, resources of the district must be exhausted. Within the district staff there could be individuals willing to be trained and licensed as replacements for the regular school bus drivers who were not able or willing to drive during an emergency. Has this course of action really been examined? If this approach is of no avail, the district then passes the unset need for drivers to the county and the county must exhaust its resources before turning to PEMA and the Commonwealth. This is the Commonwealth's policy for response to any emergency and is verified by Section 7504b of the Pennsylvania Emergency Management Services Code, 35 9
Pa. C.S.A.
As indicated in Annex Q of the Montgomery County Radiological Emergency Response Plan (Draft 9, January 1986) a' total of'426 buses (excluding coaches, minibuses and vans) are required to evacuate students and others needing transportation from the EPZ. In Annex I of the plan, school'b'us resources are listed as 1,218. The total vehicle resources for
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the organizations and companies listed is indicated as 1,783 with 1,919 full or part-time drivers. With these reported assets far exceeding evacuation requirements, it is only prudent to expect that the consummation of arrangements for.the optimum utilization of these resources could eventually eliminate the driver pool proposed by the Licensee.
While there are four risk school districts within Chester County, two are outside the EPZ but have students who live within the EPZ. In view of this, it is only the other two, Phoenixville and Owen J. Roberts School Districts, that would need buses for an evacuation. ' The two Districts, Downingtown and Great Valley, outside the EPZ have a total of 93 buses 4
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available. By delaying the normal dismissal time, these buses and drivers could be used to satisfy the shortages for Owen J. Roberts School District and would only require slightly more than one third of the drivers to volunteer to participate in an evacuation. If arrangements could ultimately be made to use these resources, the Licensee's proposed drivers pool would no longer be needed.
The solutions discussed above are of the nature referred to as a long-term resolution in PEMA's June 30, 1986 answer to the Board concerning the Licensee's "immediate solution."
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PROFESSIONAL QUALIFICATIONS
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I am the Director, Plans and Preparedness for the Pennsylvania Emergency Management Agency. The Office of Plans and Preparedness is responsible for providing guidance and assistance in the development and subsequent review of emergency plans for response to man-caused or natural disasters that may strike the Commonwealth of Pennsylvania, its counties and municipalities. This includes offsite response to an accident at any of the five nuclear power plants within the Commonwealth.
Prior to joining the Agency in July 1980 as a planner, I was involved for several months as a consultant working on the development of municipal plans for communities within the approximate ten-mile EPZ of the Three Mile Island Nuclear Station, In May 1981, I was appointed as Deputy Director, Plans and Preparedness and in that position devoted a majority of 1
time to response planning in the event of a nuclear power plant accident.
I' assumed my present position 5n April 1986.
In October 1979, I completed over 32 years of active and reserve military service, with the last seven years on active duty as a faculty member at the U.S. Army War College. I have held Army Reserve assignments from platoon leader to battalion commander to deputy commander of brigade isize units. These assignments' included respohsibility for mobilization planning and response to civil disturbances, such as the Watts Riot in Los Angeles.
i My civilian positions were: Public Relations Manager for a multi plant international electronics company; Advertising Manager for the l
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.e same concern; and Assistant to the Sales Manager for the Agricultural Division of an international chemical company.
My education includes a B.S. in Business Administration from the University of California, a M.A. in Political Science from Shippensburg State University, and graduation from the U.S. Army Command and General Staff College and the Army War College.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 the " Testimony of Ralph J. Hippert" and his " Professional Qualifications" in the above-captioned proceeding have been served on the following in the United
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i States mail, first class this 5th day of August, 1986.
4 Helen F. Hoyt, Esq. (2)
Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555
,,, Docketing and Service Section Dr. Richard F. Cole U.S. Nuclear Regulatory Atomic Safety and Licensing Commission
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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 Executive Dr. Jerry Harbour Lega1' Director Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 i
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Atomic Safety and Licensing Angus Love, Esq.
Board Panel 107 East Main Street U.S. Nuclear Regulatory Norristown, PA 19401 Commission Washington, D.C.
20555 Robert J. Sugarman, Esq.
Sugarman, Denworth and Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr.
16th Floor, Center Plaza Vice President and 101 North Board Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 Kathryn S. Lewis, Esq.
City of Philadelphia Troy B. Conney, Jr. Esq.
Municipal Services Building Conner and Wetterhahn 15th and JFK Boulevard 1747 Pennsylvania Ave., N.W.
Philadelphia, PA 19107 Washington, D.C.
20006 Spence W. Perry, Esq.
Mr. Frank R. Romano Michael B. Hirsch, Esq.
61 Forest Avenue Associate General Counsel Ambler, PA 19002 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Mr. Robert L. Anthony Washington, D.C.
20472 Friends of the Earth in the Delaware Valley Thomas Gerusky, Director 106 Vernon Lane, Box 186 Bureau of Radiation Protection Moylan, PA 19065 Departuent of Environmental Resources 5th Floor, Fulton Bank Building Charles W. Elliott, Esq.
Third and Locust Streets 325 N. 10th Street Harrisburg, PA 17120 Easton, PA 18064 Ms. Maureen Mulligan James Wiggins Limerick Ecology Action Senior Resident Inspector P.O. Box 761 U.S. Nuclear Regulatory Commission 762 Queen Street Pottstown, PA 19464 P.O. Box 47 Sanatoga, PA 19464 Jay M. Gutierrez, Esq.
U.S. Nuclear Regulatory Theodore G. Otto, Esq.
Commission Departer.nt of Corrections 631 Park Avenue Office of Chief Counsel i
King of Prussia, F;,
19406 P.O. Box 598, Lisburn Road l
Camp Hill, PA. 17011 i
Timothy R. S. Campbell Director Chester County Department of Emerge'ncy Services 14 East Biddle Street West Chester, PA 19380 A. Lindley Bigelcw Coordinator Montgomery County Office of Emergency Preparedness 50 Eagleville Road Eagleville, PA 19403 Roy C. Claypoo'1, Ed.D.
District Superintendent i
Owen J. Roberts School District Administration Building R.D. #1 Pottstown, PA 19464 William A. Welliver, Ed.D.
Superintendent Spring-Ford Area School District 199 Bechtel Road Collegeville, PA 19426 COMMONTIEALTH OF PENNSYLVANIA PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY By:
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Mark' L. Goodwin Chief Counsel l
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