ML20206D805

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Affidavit of TR Campbell Supporting Util Resolution of Remanded Issue Re Availability of School Bus Drivers for Oj Roberts & Spring-Ford School Districts,Per ASLB 860522 Order.Proposed Stipulation & Certificate of Svc Encl
ML20206D805
Person / Time
Site: Limerick  
Issue date: 06/13/1986
From: Tison Campbell
CHESTER COUNTY, PA, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20206D767 List:
References
OL, NUDOCS 8606200232
Download: ML20206D805 (9)


Text

1

.c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

)

)

Philadelphia Electric Company.

)

Docket Nos.

50-352

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50-353 (Limerick Generating Station,

)

Units 1 and 2)

)

AFFIDAVIT OF TIMOTHY R. S. CAMPBELL k

My name is Timothy R. S. Campbell.

I am the Director of the Department of Emergency Services, County of Chester, Pennsylvania.

My office is at 14 East Biddle Street, West Chester, Pennsylvania 19380.

I am familiar with the Order of the Atomic Safety and Licensing Appeal Board, dated May 22, 1986, which remanded Phase Three of the proceeding to the Licensing Board for consideration of the availability of bus drivers for the school district plans for Owen J. Roberts School District.

The Appeal Board's order, as applicable to the Owen J. Roberts School District, accepted a survey by the School District Superintendent which reflected that 18 of the 43 bus company employees, who usually drive for the District, would do so in an emergency.

Based upon my knowledge and experience of emergency planning, I do not agree that this many drivers would fail to drive the buses in an emergency.

As I testified in the hearings, it is my experience that all people, when asked to help and given a task they can understand and which is within their capability, will volunteer and help.

t (TR. 19987, 2003).

F6062OO232 060616 PDR ADOCK 00000352

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Nevertheless, in order to comply with the Appeal Board finding, I have recommended that a reserve of drivers be recruited as volunteers.-

The Philadelphia Electric Company has identified individuals who would be willing to serve in this capacity. A number of Philadelphia Electric employees already possess Class 3 and, in some cases, Class 4, Pennsylvania driver's licenses.

(Class 3 licenses authorize operation of heavy equipnent Class 4 licenses authorize operation of school-buses).

Accordingly, PE has identified 300 individuals who have agreed (a) to drive school busca in Chester County as may be necessary upon my request.

(b) to take training to qualify for a Commonwealth of Pennsylvania Class 4 driver's license, which authorizes operation of school buses.

These individuals have also agreed that, upon my or my designee's request, they would report to the Chester County Transportation Staging

-Area at Exton, where they could be transported to where the buses are located in order to drive them in any evacuation; and, in particular, to be transported to the Owen J. Roberts School District to drive the buses for which drivers may not be available.

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Timothf R. S. Camptpll, Director Department of Emergency Services Subscribed and sworn to before me this d3 1 day of June, 1986.

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C Mrs. Barbara N. Bird, Notary Public W

My comeission expiresyy e._est Chester. Cnester Co. Ph.

,p,o,in,3937

UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

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PHILADELPHIA ELECTRIC COMPANY )

Docket Nos. 50-352 OL

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50-353 OL (Limerick Generating Station, )

Units 1 and 2)

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)

)

STIPULATION The Commonwealth of Pennsylvania, the Nuclear Regulato-ry Commission Staff, Limerick Ecology Action, Inc., and the Philadelphia Electric Company hereby stipulate and agree as follows:

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 in all respects except two.

The single matter remanded for further disposition is the assurance of drivers for the school buses needed to evacuate the school children of the Owen J.

Roberts and Spring Ford School Districts in the event of an accident at the Limerick Generating Station.

In accordance with the remand instruction of ALAB-836, the Licensing Board issued an Order dated May 22, 1986 directing the Licensee to submit its proposal for resolution

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of the remanded issue with 20 days of the service date of the order; other principal interested parties (Limerick Ecology

Action, Inc.

and Commonwealth of Pennsylvania) within 14 days after the service date of Licensee's sub-mission; and the NRC staff within 7 days after the service date of the last response of the principal interested parties.

Since the close of the evidentiary hearings on these

issues, Philadelphia Electric Company, the Licensee, has continued to cooperate with the appropriate Commonwealth, County and local officials in the further development of the emergency plans which involve the Limerick Generating Station.

Its efforts included identifying company personnel who might be willing to volunteer in their communities to assist in various aspects of emergency planning.

The Company maintains a list of employees who are licensed drivers.

At a meeting on June 5,

1986 with Mr.

Timothy R.

S.

Campbell, the Chester County Coordinator, and Mr.

A.

Lindley Bigelow, Montgomery County Coordinator, it was determined that the immediate solution for the Appeal Board's findings as to driver availability in the Owen J.

Roberts and Spring-Ford School Districts was to obtain a reserve of qualified volunteer bus drivers in each county.

In the event an emergency developed requiring possible evacuation and it were determined that a sufficient number of regular bus drivers might not be available, the volun-teers would be immediately mobilized.

For Chester County,

E.

these drivers would report to the Chester County marshalling center at Exton and thence be transported to the various schools in the Owen J. Roberts school districts to drive the buses.

For Montgomery County, the drivers would assemble at t

the Company's Berwyn Transportation Center for similar transportation to the Spring-Ford Schools in Montgomery County.

Two hundred seventy company individuals who can reach Berwyn within 30-90 minutes of notification, and 300 who could reach Exton within 30-90 minutes have 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, 95 could arrive within 30 minutes, 25 within 60 minutes, and 180 within 90 minutes.

Specifically, each volunteer has agreed:

a.

To drive a school bus as may be necessary upon request by the Chester or Montgomery County coordinator.

b.

To take training to qualify for a Commonwealth of Pennsylvania Class 4 driver's license, which authorizes operation of school buses and to maintain it.

Based upon (1) LEA's review of the November 15, 1985 proposal and the affidavits of Vincent S.

Boyer, Timothy R.

S.

Campbell, and A.

Lindley Bigelow on behalf of the Philadelphia Electric Company, Chester county and Montgomery County, respectively, and (2) the response to the proposal and the affidavit of Col. Ralph J.

Hippert, Director of

Plans Preparedness, Pennsylvania Emergency Management Agency, LEA has determined that appropriate arrangements have been made as required by the Atomic Safety and Licens-ing Appeal Board in Philadelphia Electric Co.

(Limerick Generating Station Units 1 and 2), ALAB-836, NRC (1985)

(Slip op.

p.

49 n.

47), which provide reasonable assurance of a sufficient number of bus drivers willing to respond during an emergency insofar as the Spring-Ford and Owen J.

Roberts School Districts are concerned; and that those concerns are no longer a matter of controversy among the parties.

The undersigned parties stipulate that the Atomic Safety and Licensing Board may enter an appropriate order dismissing LEA's contention for lack of controversy, based on this etipulation.

U.S. NUCLEAR REGULATORY LIMERICK ECOLOGY ACTION, INC.

COMMISSION STAFF By:

By:

Joseph Rutberg, Esq.

Phyllis Zitzer for Limerick Ecology Action, Inc.

COMMONWEALTli OF PENNSYLVANIA, GOVERNOR'S ENERGY COUNCIL By:

Mark L. Goodwin, Esq.

PHILADELPHIA ELECTRIC CO.

Bys (

/ Leu N. &&

/$fh Counsel [forPhiladelpha Troy B.

6nner, Jr., E Electric Co.

.e I

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter.of

)

)

Philadelphia Electric Company

)

Docket Nos. 50-352

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50-353 (Limerick Generating Station,

)

Units 1 and 2)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Proposal for Resolution of Remanded Issue Regarding the Availability of School Bus Drivers for the Owen J.

Roberts and Spring-Ford School Districts," dated June 16, 1986 in the

-captioned matter have been served upon the following by deposit in the United States mail this 16th day of June, 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 s,

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

e 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, 2sq.

Philadelphia, PA 19107 325 N.

10th Street Easton, PA 18064 Spence W.

Perry, Esq.

Michael B. Hirsch, Esq.

Miss Phyllis Zitzer Associate General Counsel Limerick Ecology Action Federal Emergency P.O. Box 761 Management Agency 762 Queen Street 500 C Street, S.W.

Pottstown, PA 19464 Room 840 Washington, DC 20472 Mark L. Goodwin, Esq.

Office of General Counsel Thomas Gerusky, Director Commonwealth of Pennsylvania Bureau of Radiation P.O. Box 11775 Protection Harrisburg, PA 17108 Department of Environmental Resources Jay M. Gutierrez, Esq.

5th Floor U.S. Nuclear Regulatory Fulton Bank Bldg.

Commission Third and Locust Streets 631 Park Avenue Harrisburg, PA 17120 King of Prussia, PA 19406

F James Wiggins William A. Welliver, 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 Col. 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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Nils N. Nichols

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