ML20205C492

Testimony of Vs Boyer & R Bradshaw Re Remand Hearing on Availability of Bus Drivers to Evacuate Students in Spring- Ford & Oj Roberts School Districts.Certificate of Svc Encl. Related Correspondence

ML20205C492
Person / Time
Site:	Limerick
Issue date:	08/11/1986
From:	Boyer V, Bradshaw R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20205C476	List: ML20205C471 ML20205C492
References
OL, NUDOCS 8608120339
Download: ML20205C492 (10)

Text

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DOLKETED USNRC UNITED STATES OF AMERICA 11 P3:36 NUCLEAR REGULATORY COMMISSION OFFICE or n .

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Before the Atomic Safety and Licensing Board In the Matter of )

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l Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Sta' tion, )

Units 1 and 2) )

TESTIMONY RELATING TO REMAND HEARING ON AVAILABILITY OF BUS DRIVERS FOR OWEN J. ROBERTS AND SPRING-FORD SCHOOL DISTRICTS Panel - Vincent S. Boyer and Robert Bradshaw b

1. This testimony pertains to the decision of the Atomic Safety and Licensing Appeal Board in Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), ALAB-836, 23 NRC 479, 522 (1986), insofar as that decision required further findings by the Atomic Safety and Licensing Board on remand of " reasonable assurance of the availability of an adequate number of bus drivers to evacuate students in the Spring-Ford and Owen J. Roberts School Districts."

2. Plans to evacuate these two school districts are two aspects of the overall efforts by Commonwealth, county and local officials, assisted by licensee Philadelphia Electric Company (" Licensee") and its consultants, to maintain adequate emergency planning and preparedness for the Limerick Generating Station (" Limerick").

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3. Since the close of the record relating to the offsite emergency planning phase of the proceeding, Licensee has continued to cooperate with Commonwealth, county and local officials in developing additional emergency response resources for all aspects of planning and preparedness.

These efforts have included the enlistment of Licensee's employees who have stated a willingness to participate as volunteers in implementing various aspects of the offsite plans.

4. Following the Appeal Board's remand as to whether an adequate number of drivers would be available for the Spring-Ford and Owen J. Roberts School Districts, the Licensee's representatives discussed how to resolve the remanded issue with the responsible county and Commonwealth officials. At a meeting on June 5, 1986 with Licensee's representatives, Timothy R. S. Campbell, Director of the Chester County Department of Emergency Services, and A.

Lindley Bigelow, Coordinator of the Montgomery County Office of Emergency Preparedness, determined that an immediate solution would be for volunteer Licensee employees to qualify and act as drivers until the counties have obtained drivers from other sources. Mr. Campbell decided that the designated marshalling center for volunteers to drive buses for Chester County would be in the Exton area at the Exxon Systems facility in Lionville. Mr. Bigelow decided that the designated marshalling center for Montgomery County would be ,

1 the Licensee's Berwyn Transportation Center. The matter was

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. An then discussed with Ralph J. Hippert, Director of Plans &

Preparedness, Pennsylvania Emergency Management Agency, who agreed to the proposal as an immediate solution.

5. In Pennsylvania, a Class 4 driver's license is required for operation of a school bus. There are three prerequisites for obtaining a Pennsylvania Class 4 license:

(1) possession of a Class 4 learner's permit which requires passing a physical examination; (2) classroom and vehicle training; and (3) passing a driver's examination administered by the State Police.

6. In order to determine the number of employees who potentially might wish to volunteer to drive school buses in the event of an emergency, Licensee then collated a list of volunteer employees who could respond to bus marshalling centers within a reasonable period.

7. As a result of its survey, Licensee determined, as of the time of its response to the Atomic Safety and Licensing Board on the remanded bus driver issue on June 16, 1986, that 570 of its employees in reasonable proximity to the marshalling centers have volunteered to take the steps necessary to obtain a Pennsylvania bus driver's license and to drive buses as may be necessary in the event requested by the Chester County Department of Emergency Services or the Montgomery County Office of Emergency Preparedness to implement their respective emergency plans.

8. Each volunteer was asked to execute a volunteer sheet. The supervisors of the volunteers were asked to i

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estimate how long it would take the volunteers to reach the marshalling centers based upon their knowledge of their personnel's work locations.

9. Based upon Licensee's desire to resolve the remanded bus driver issue without the need for further hearings, Licensee proposed by stipulation to make the 570 identified employee volunteers availabls to Chester and Montgomery Counties as needed under their plans. After intervenor Limerick Ecology Action rejected the proposed stipulation, however, Licensee began to prepare for the hearing and conferred with the Commonwealth, counties and Federal Emergency Management Agency to reassess the number of volunteers actually needed. Based upon this reevaluation, the responsible planning agencies determined that a total of 200 employee volunteers, to be used by both Montgomery and Chester County, would be more than sufficient to meet any anticipated need for the Owen J. Roberts and Spring-Ford School Districts. A list of the names of the remaining volunteer employees is being maintained on file so that in the event they may be needed as replacements for those already trained, they can be made available.

10. Licensee has coordinated its bus driver employee efforts with the Chester Cou,nty Department of Emergency Services and the Montgomery County Office of . Emergency

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Preparedness. Both counties have agreed to the program for the use of Licensee's employee volunteers to receive driver

training and respond in the event of a radiological emergency at Limerick.

11. Initially, training was provided by the Chester County Intermediate Unit, which is a regional governmental cooperative that provides services to local school districts. Licensee and vendor employees received training as instructors which qualifies them to teach other volunteers. Training of 21 instructors began July 15, 1986, and was completed July 23, 1986. Thereafter, these instructors will teach other volunteers in groups of approximately thirty. The State Police will then conduct Class 4 driver tests at Berwyn. The training of all volunteers will include the same training offered for drivers for all school districts and school bus providers.

(See Appl. Exh. E-64, Training Module for Bus Drivers.)

12. The schedule for training and testing is as follows: two groups totaling about 60 volunteers completed training August 8, 1986; two other groups totaling about 60 will complete training by August 15, 1986; and the remainder totaling about 80 will complete training by August 22, 1986, subject to possible unavailability due to illness or other reason. Driver testing sessions have been scheduled with the State Police for August 11, 18 and 25, 1986. Any volunteers who are unable to complete training as prescribed will be trained in a follow-up session beginning August 25, 1986. A follow-up testing session has been scheduled for September 8, 1986.

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13. Since the 200 volunteers c,uld be used for either Chester or Montgomery County, Licensee has developed estimates of the time required for the volunteers to report to both Exxon and Berwyn. Licensee has determined that 55 could reach Exxon in 30 minutes or less; an additional 111 within 30 to 60 minutes and 34 more within 60 to 90 minutes.

For Berwyn, 148 would be available in 30 minutes or less; an additional 27 within 30 to 60 minutes and 25 within 90 minutes. Forty are regularly stationed at Berwyn and would i

therefore be immediately available.

14. Licensee has committed to Montgomery and Chester Counties that it will make its bus driver employee volun-teers available under the arrangements discussed above until provision is made by the responsibile planning authorities for bus driver personnel from other sources. Accordingly, Licensee's arrangements will remain in full force and effect until notification that Licensee's employee volunteers are no longer required.

15. In my capacity as an employee and officer of the Philadelphia Electric Company, I have had extensive experi-cnce with our employees. I am confident that if an employee has stated that he will participate in an emergency response by driving a bus in the event that school evacuation is required, he will do so.

16. Based on the foregoing, there will be far more than i

enough volunteer bus drivers to provide support to the I Chester County and Montgomery County emergency planning i

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agencies as needed for the Owen J. Roberts and Spring-Ford School Districts in the event regularly assigned drivers fail to respond.

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00lMCIE0 USNRC UNITED STATES OF AMERICA W AIE 11 P3:37 NUCLEAR REGULATORY COMMISSION Xi[ SM-In thc Matter of ) BRANC

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Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Testimony Relating to Remand Hearing on Availability of Bus Drivers for Owen J.

Roberts and Spring-Ford School Districts" dated August 8, 1986 in the captioned matter have been served upon the following by deposit in the United States mail 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 General

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

• Federal Express

e 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 &

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 Spence W. Perry, Esq.

General Counsel

• Maureen Mulligan Federal Emergency Limerick Ecology Action Management Agency P.O. Box 761 500 C Street, S.W.

762 Queen Street Room 840 Pottstown, PA 19464 Washington, DC 20472 Mark L. Goodwin, Esq. Thomas Gerusky, Director Philadelphia Emergency Bureau of Radiation Management Agency Protection P. O. Box 3321 Department of Environmental Harrisburg, PA 17105-3321 Resources ,

l 5th Floor Jay M. Gutierrez, Esq. Fulton Bank Bldg.

U.S. Nuclear Regulatory Third and Locust Streets Commission Harrisburg, PA 17120  ;

631 Park Avenue King of Prussia, PA 19406 1

• Federal Express l

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'a James Wiggins William A. Wciliver, Ed.D.

Senior Resident Inspector Superintendent U.S. Nuclear Regulatory Spring-Ford Area School Commission District P.O. Box 47 199'Bechtel Road Sanatoga, PA 19464 Collegeville, PA 19426 Ralph Hippert Pennsylvania Emergency Management Agency B151 - Transportation and Safety Building Harrisburg, PA 17120 Theodore G. Otto, Esq.

Department of Corrections Office of Chief Counsel P.O. Box 598 Lisburn Road Camp Hill, PA 17011 Timothy R.S. Campbell, Esq.

Director Department of Emergency Services 14 East Biddle Street West Chester, PA 19380 A. Lindley Bigelow Coordinator of. Emergency Preparedness Montgomery County 50 Eagleville Road Eagleville, PA 19403 Roy C. Claypool, Ed.D.

District Superintendent Owen J. Roberts School District Administration Building R.D. 1 Pottstown, PA 19464

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Robert M. Rader

• Federal Express