ML20205C261

Prefiled Testimony of Jr Asher & Rz Kinard Re Availability of School Bus Drivers for Oj Roberts & Spring-Ford School Districts.W/Certificate of Svc.Related Correspondence

ML20205C261
Person / Time
Site:	Limerick
Issue date:	08/11/1986
From:	Asher J, Richard Kinard Federal Emergency Management Agency
To:
References
CON-#386-266 OL, NUDOCS 8608120293
Download: ML20205C261 (7)

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( UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION %IU c l

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E _A(E BEFORE THE_ ATOMIC ~ SAFETY ~AND_ LICENSING _ BOARD 11 P4 :25 g((Icfor g m g ,,

i In the Matter of ) $3dc7*'-

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Philadelphia Electric Company ) Docket Nos 50-352

) 50-353 f> [

j (Limerick Generating Station, )

Units 1 and 2) )

PRE-FILED TESTIMONY OF JAMES R. ASHER AND RICHARD Z.XINARD ON BEHALF 0F THEFEDERALEMERGENCYMANAGEMENTAGENCY(FEMA)

REGARDING THE ISSUE OF THE AVAILABILITY OF SCHOOL BUS DRIVERS FOR THE OWEN J. ROBERTS AND $PRING-FORD SCHOOL DISTRICTS ,.

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l On May 7, 1986, in ALAB.836, the Atomic Safety and Licensing Appeal Board affirmed the Third Partial Initial Decision issued by the presiding l

(

) 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 4

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 utility developed a Stipulation containing a proposed solution. Volunteers who are licensed or who have agreed to become licensed to drive buses in each county 1

(Montgomery and Chester) have been identified by the utility. The 2 '

Stipulationfurtherstatesthattwohundredseventy(270) company individuals can reach Berwyn, Montgomery County within 30-90 minutes l

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of notification and that three hundred (300) company individuals can reach Exton, Chester County within 30-90 minutes.

Each volunteer has agreed:

a. To drive a school bus, as may be necessary, upon request by the Chester County Department of Emergency Services or i Montgomery County Office of Emergency Preparedness to the Philadelphia Electric Company Office of Emergency Preparedness.

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b. To take training within 90 days to obtain a Comonwealth of Pennsylvania Class 4 drivers license, which authorizes operation of school buses and to maintain such license.

l In his June 27, 1986 letter to Ralph Hippert of the Pennsylvania I Emergency Management Agency (PEMA), Troy B. Conner, Jr., Counsel for the Licensee, has provided assurances that the lists of volunteers will continue to be maintained by Philadelphia Electric Company (PECO) and they will seek additional volunteers as may be necessary. PECO will also insure the training and licensing of any new volunteers.

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4 The Pennsylvania Emergency Management Agency, through a document signed by Ralph J. Hippert, Director, Office of Plans and Preparedness and Mark L.

Goodwin, Chief Counsel, has noted that they are satisfied that the Stipulation. as modified by the June 27 letter from Troy B. Conner, Jr.,

Counsel for the Licensee to Mr. Hippert, contains adequate assurances and commitments from the Licensee that a sufficient number of trained bus drivers would be available to evacuate school children of the Owen J.

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Roberts and Spring-Ford School Districts in the event of an emergency, such as an accident at the Limerick Generating Station.

In recent telephone conversations with an official of PEMA, and a representative of EC Planning and Management Services, a consultant to the utility, FEMA has been made aware of certain updated information.

It has now been proposed that two hundred (200) volunteers will actually be trained and licensed to drive school buses, with three hundred-seventy (370) additional names kept on file for use, if needed. Training for the two hundred (200) volunteers is expected to be completed by the end of August 1986 Based upon the surveys conducted by the Owen J. Roberts and Spring-Ford School Districts, cited by the Appeals Board in their May 7, 1986 ruling (ALAB-836), there appears to be a maximum unmet need of fifty-two (52) bus drivers for the two school districts in question. The PECO l

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approach to resolve this issue, even utilizing the new figure of two hundred (200) volunteers, produces a ratio of approximately four volunteers for every unmet driver.

FEMA believes that the proposed procedures offered by the utility and agreed to by PEMA provides reasonable assurance that,'in the event of an emergency at the Limerick Generating Station, an adequate number of volunteers will be available to fill the unmet needs of bus drivers in the Owen J. Roberts and Spring-Ford School Districts.

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a DOCKETED USNRC UNITED STATES OF AMERICA NE 11 P4 :25 NUCLEAR REGULATORY COMMISSION OFFICE 0 3i c t :44<

00CKEilhu & 3E6vlCf.

BRANC4 In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

I hereby certify that copies of " Pre-filed Testimony of Richard Kinard and James Asher on Behalf of the Federal Emergency Management Agency -

(FEMA) Regarding the Issue of the Availability of School Bus Drivers for the Owen J. Roberts and Spring-Ford School Districts" in the above captioned matter have been served upon the following by deposit in the United States mall this 8th day of August, 1986:

• Helen F. Hoyt, Esq. Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and U. S. Nuclear Regulatory Licensing 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 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 Executive

• Dr. Jerry Harbour Legal Director Atomic Safety and U. S. Nuclear Regulatory Licensing Board Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555

• Hand Delivery f

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\ Col. Ralph Hippert Angus Love, Esq.

Pennsylvania Emergency 107 East Main Street Management Agency Norristown, PA 19401 8151 Transportation & Safety Bg.

Harrisburg, PA 17120 Robert J. Sugarman, Esq.

Sugarman, Denworth &

Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr. 16th Floor, Center Plaza Vice President & 101 North Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 John L. Patten, Director Pennsylvania Emergency Mr. Frank R. Romano Management Agency 61 Forest Avenue Room B-151 Ambler, Pennsylvania 19002 Transportation and Safety Building Mr. Robert L. Anthony Harrisburg, PA 17120 Friends of the Earth in -

the Delaware Valley Kathryn S. Lewis, Esq.

106 Vernon Lane, Box 186 City of Philadelphia Moylan, PA 19065 Municipal Services Bldg.

15th and JFK Blvd.

Charles W. Elliott, Esq. Philadelphia, PA 19107 325 N. 10th Street Easton, PA 18064 Troy Conner, Jr.

Miss Maureen Mulligan Conner and Wetterhahn, P. C.

Mr. David Stone 1747 Pennsylvanta Ave., N. W.

Limerick Ecology Action Washington, D. C. 20006 P. O. Box 761 762 Queen Street Thomas Gerusky, Director Pottstown, PA 19464 Bureau of Radiation Protection Mark L. Goodwin, Esq. Department of Environmental Office of General Counsel Resources Commonwealth of Pennsylvanta 5th Floor P. O. Box 11775 Fulton Bank Bldg.

Harrisburg, PA 17108 Third and Locust Streets Harrisburg, PA 17120 Jay M. Gutierrez, Esq.

U. S. Nuclear Regulatory William A. Welliver, Ed. D.

i Commission Superintendent 631 Park Avenue Spring-Ford Area School

King of Prussia, PA 19406 Olstrict 199 Bechtel Road James Wiggins Collegeville, PA 19426 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 47 Sanatoga, PA 19464

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Theodore G. Otto, Esq. Timothy R.S. Campbell, Esq.

Department of Corrections Director Office of Chief Counsel Department of Emergency P. O. Box 598 Services Lisburn Road 14 East Biddle Street Camp Hill, PA 17011 Westchester, PA 19380 A. Lindley Bigelow Roy C. Claypool, Ed.D.

Coordinator of Emergency District Superintendent Preparedness Owen J. Roberts School Montgomery County District 50 Eagleville Road Administration Building Eagleville, PA 19403 R.D. 1 Pottstown, PA 19464 ff, . A /f .../

Michael B. Hirsch -

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