ML20207P730
| ML20207P730 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/12/1987 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20207P727 | List: |
| References | |
| ALAB-857, OL, NUDOCS 8701200138 | |
| Download: ML20207P730 (2) | |
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DOLMETEP USHRC UNITED STATES OF AMERICA
' NUCLEAR REGULATORY COMMISSION CFFC s 00Ch!.ib Before the Atomic Safety and Licensing Appeal Board ' '
In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Cenerating Station,
)
Units 1 and 2)
)
LICENSEE'S RESPONSE TO ALAB-857 In its decision dated January 2,
1987 (ALAB-857), the Atomic Safety and Licensing Appeal Board in the captioned matter directed the Philadelphia Electric
- Company,
(" Licensee") to submit an affidavit within ten days that its
" volunteer bus driver pool now consists of 234 fully
- trained, qualified and licensed drivers."1/
It also directed the Licensee promptly to take action to incorporate the provisions for supplying backup bus drivers "into its emergency
- plan, as well as those of the affected "2/
jurisdictions.
Attached hereto is the
" Affidavit of Joseph W.
l Gallagher in
Response
to the Request in ALAB-857 for l
l 1/
ALAB-857 (slip op. at 4 n.4).
2/
Id. at 10-11.
l 0701200138 870112 PDR ADOCK 05000352 1
0 PDR
~ \\
Confirmation of the Status of Licensee's Volunteer Employee Bus Driver Pool" dated January 12, 1987, which responds to both requirements.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
~
Troy B. Conner, Jr.
Counsel for Licensee January 12, 1987
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UNITED STATES OF AMERICA Nilt;I.H A N MMbubAlunt LUMM1331UN Before the Atomic Safety and Licensing Appeal Board In the Matter of
)
)
Philadelpha Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
AFFIDAVIT OF JOSEPH W. GALLAGHER IN RESPONSE TO THE REQUEST IN ALAB-857 FOR CONFIRMATION OF THE STATUS OF LICENSEE'S VOLUNTEER EMPLOYEE BUS DRIVER POOL Joseph W. Gallagher, being duly sworn according to the law, hereby deposes and states:
1.
My name is Joseph W. Gallagher.
I am Vice President, Nuclear Operations of Philadelphia Electric Company
(" Licensee"), owner and operator of the Limerick Generating 4
Rention.
I am responsihla for f.icensee's emergency planning and prepareduwas fur its nucicar generating stations, including
=**.....t,
.nanevation with the Commonwealth of Pennsylvania, l
the Federal Emergency Management Agency, local governments and l
the Nuclear Regulatory Commission to protect the public health and safety in the event of a radiological energency at Limerick Generating Station.
2.
As such, I am f amiliar with the status of Licensee's arrangements for establishing and maintaining a volunteer empluyee driver pool from which drivers will be nade available Lu Muntgomery County and Choctor County to
.m e e t any drivar shortages in the Spring-Ford Area School DistricJ and_0 wen Roberts School District, respectively.
[Y f
- J A N 1; ' 3 :* 16: 40 001 PEco 01-C CTE F.o a
2-3.
As of November 21, 1986, the date on which Licensee filed its brief with the Atomic Safety and Licensing Appeal Board in this matter, Licensee's volunteer bus driver pool consisted of 234 trained, qualif tad _and licensed drivers.
This number remains unchanged.
It i s Licensee's intention to maintain a pool of approximately 220 drivers so long as Licensee's drivers are needed by Montgomery County and Chester County.
Training classes for additional vulunteers will be held as needed to achieve this goal.
4.
In its Decision dated January 2, 1987, served January 5, 1987, the Atomic Safety and Licensing Appeal Board also directed Licensee "to take promptly whatever action is necessary and appropriate to incorporate its provisions for supplying backup bus drivers into its emergency plan, as well as those of the affected jurisdictions."
Inasmuch as drivers will be made available to Montgomery County and Chester County, we have discussed incorporating these arrangements into the county plans with A. Lindley Bigelow, the Coordinator of Emergency Preparedness for Montgomery County, and Timothy R.
S.
Campbell, the Director of Emergency Services for Chester County.
They have informed us that they would amend their plans as follows.
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.,_y-_
--. ~- ---
s-
.o 5.
The Montgomery Caunty plan.would be amended by adding Philadelphia Electric Company to Annex I, Appendix I-2, Tab 3 to reflect a pool of 200 drivers to be shared with Chester County.
Similarly, the Chester County plan will be amended by adding Philadelphia Elect.ric cum,vany to Annex I, Appendix 1 (Bus Resources) to reflect a pool of 200 drivers to be shared with Montgomery County.
In both plans, the same information will be added to Annex Q, which specifies county resources and requirements.
Also, Annex T of both plans (provider agreements) will refer to Philadelphia Electric Company as a provider of volunteer bus drivers.
A copy of this affidavit will be kept on file by each county to reflect Licensee's agreement.
ine arctonvic tst
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t~.aa.a..
.w.
agreements listed in Appendix A of Licensee's emergency plan.
%J hff- -
Jo eph W.
Gs11a er Vice Prosident bubscr1Ded and swutu Lu before me this /) W day
,of January, 1987.
& f.&pn Notary Public /
MELANIE R. CAMPANELLA hotary Mt c. PriateTis. Phlese';.Ys Co, My commis L:n Ences retrasq ll lit:
==
e s
1 4:
+a UNITED STATES OF AMERICA 0 %"~ N NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal *gbaA8314 P2 :12 In the Matter of
)
Philadelphia Electric Company
)
Docket Nos.
bd
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of a letter to the Appeal Board, " Licensee's Response to ALAB-857, " and Affidavit of Jopseh W.
Gallagher in Response to the Request in ALAB-857 for Confirmation of the Status of Licensee's Volunteer Employee Bus Driver Pool" all dated January 12, 1987 in the captioned matter, have been served upon the following by deposit in the United States mail this 12th day of January, 1987:
Christine N. Kohl, Esq.
Dr. Richard F. Cole Chairman Atomic Safety and Atomic Safety and Licensing Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry Harbour Gary J. Edles Atomic Safety and Licensing Atomic Safety and Licensing Board U.S. Nuclear Appeal Board Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Howard A. Wilbur Appeal Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Docketing and Service Section Office of the Secretary Helen F. Hoyt, Esq.
U.S. Nuclear Regulatory Chairperson Commission Atomic Safety and Licensing Washington, D.C.
20555 Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
2 Benjamin H. Vogler, Esq.
Angus Love, Esq.
Counsel for NRC Staff 107 East Main Street Office of the General Norristown, PA 19401 Counsel U.S. Nuclear Regulatory Robert J. Sugarman, Esq.
Commission Sugarman, Denworth &
Washington, D.C.
20555 Hellegers 16th Floor, Center Plaza Atomic Safety and Licensing 101 N. Broad Street Board Panel Philadelphia, PA 19107 U.S. Nuclear Regulatory Commission Director, Pennsylvania Washington, D.C.
20555 Emergency Management Agency Basement, Transportation Philadelphia Electric Company and Safety Building ATTN:
Edward G. Bauer, Jr.
Harrisburg, PA 17120 Vice President &
General Counsel Kathryn S. Lewis, Esq.
2301 Market Street City of Philadelphia Philadelphia, PA 19101 Municipal Services Bldg.
15th and JFK Blvd.
Mr. Frank R.
Romano Philadelphia, PA 19107 61 Forest Avenue Ambler, Pennsylvania 19002 Spence W.
Perry, Esq.
General Counsel Mr. Robert L. Anthony Friends Federal Emergency of the Earth of Management Agency the Delaware Valley 500 C Street, S.W.,
Rm. 840 106 Vernon Lane, Box 186 Washington, DC 20472 Moylan, Pennsylvania 19065 Thomas Gerusky, Director Miss Maureen Mulligan Limerick Bureau of Radiation Ecology Action P.O.
Box 761 Protection 762 Queen Street Pottstown, PA Department of Environmental 19464 Resources 5th Floor, Fulton Bank Bldg.
Charles W.
Elliott, Esq.
Third and Locust Streets 325 N.
10th Street Harrisburg, PA 17120 Easton, PA 18042 Gene Kelly Jay M. Gutierrez, Esq.
Senior Resident Inspector U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission P.O.
Box 47 Region I Sanatoga, PA 19464 631 Park Avenue King of Prussia, PA 19406
a...
Mark L._Goodwin, Esq.
Pennsylvania Emergency Management Agency P. O. Box 3321 Harrisburg, PA 17105-3321 Timothy R.S. Campbell Director Department of Emergency Services 14 East Biddle Street West Che; iter, PA 19380 Mr. Ralph Hippert Pennsylvania Emergency Management Agency B151 - Transportation 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 e
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Rob'brt M.
Rader
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