ML20212M699
| ML20212M699 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/22/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#386-532 OL, NUDOCS 8608270060 | |
| Download: ML20212M699 (66) | |
Text
OR/GW4; UN11EU STATES O NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-352 OL 50-353 OL PHILADELPHIA ELECTRIC COMPANY (Limerick Generating.S'tation, Units 1 and 2)
O .
LOCATION: PHILADELPHIA, PENNSYLVANIA PAGES: 21292 - 21352 l
DATE: FRIDAY, AUGUST 22, 1986 l
, 0I Oy ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North CapitolStreet Washington, D.C. 20001 8o08270000 960a22 y /*Do o5C00 2 NATIONWIDE COVERAGE
21292 CR27875.0 DAV/dnw
__ UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 ,
- - - - - - - - - - - - - - - - - - -x 5 ,
6 1[n the Matter of: :
7 PHILADELPHIA ELECTRIC COMPANY : Docket No. 50-352 OL
- 50-353 OL 8 (Limerick Generating Station, :
Units 1 and 2) :
9 :
- - - - - - - - - - - - - - - - - - -x 10 Old Customs Courtroom 11 United States Customs House Room 300 12 Second and Chestnut Streets Philadelphia, Pennsylvania
()
13 Friday, August 22, 1986 14 The hearing in the above-entitled matter convened at 9:30 a.m.
16 BEFORE:
18 Atomic Safety and Licensing Board 19 U.S. Nuclear Regulatory Commission Washington, D. C.
i 20 I JUDGE RICHARD F. COLE, Member 21 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washi'ngton, D. C.
12 l 23 JUDGE JERRY HARBOUR, Member Atomic Safety and Licensing Board
,24 U.S. Nuclear Regulatory Commission
()
i c Nashington, D. C.
y '25
- -- continued --
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21293 APPEARANCES:
2 On behalf of Philadelphia Electric Company; 3 ROBERT M. RADER, ESQ.
TROY B. CONNER, JR., ESQ.
4 NILS NICHOLS, ESQ.
Conner & Wetterhahn, P.C.
5 1747 Pennsylvania Avenue, N.N.
Washington, D. C. 20006 On behalf of the Commonwealth of Pennsylvania; 8
Deputy Director, Plans & Preparedness GOODWIN 9
Commonwealth of Pennsylvania 10 ,
Emergency Management Agency l Room B-151 .
11 Transportation & Safety Building Harrisburg, Pennsylvania 12 On behalf of the Limerick Ecology Action; O 13 DAVID STONE 14 MAUREEN MULLIGAN Limerick Ecology Action 15 Box 761 Pottstown, Pennsylvania On behalf of the Nuclear Regulatory Commission 17 Staff; I
18 BENJAMIN H. VOGLER, ESQ.
j U.S. .iuclear Regulatory Commission 19 Office of General Counsel Washington, D. C. 20555 20 {
l l On behalf of FEMA; 21 MICHAEL HIRSCH 22 l .
23 l l
24 l l 25 ,
l l ACE-FEDERAL REPORTERS, INC.
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21294
-g-- l C2arsars 2
WITNESS DIRECT CROSS REDIRECT RECROSS 3
Vincent Boyer (Resumed) 4 by Mr. Stone (Further) 21297 5 Roy C. Claypool and 6 William Weliver(Resumed) by Ms. Mulligan 21310 7 by Mr. Rader 21344 by Mr. Goodwin 21349 8
9 10 ;
I 11 12 L) 13 i
14 l 15 l 16 l 17 l 1
18 j 19 l 20 l l
21 i l
22 '
23 p 24 l l
V, 25
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3 JUDGE HOYT: The hearing will ccme to order. All 4 the counsel and representatives who were present in the 5 hearing on Monday, August 18, 1986 are again present in the 6 hearing room.
7 We will continue with the proceedings involving 8 the remand in ALAB 836. On Monday, Mr. Boyer mentioned that 9 some of the employees of the company were taking an 10 examination on that day, and that he anticipated having the 11 results of that test available to this Board and the
,3 12 parties.
LJ -
13 Do you have that information?
14 And perhaps we'd better call Mr. Boyer back to 15 the stand, so it will be under oath.
16 MR. CONNER: Fair enough.
17 JUDGE HOYT: Mr. Boyer, you have previously taken 18 the oath for us in this proceeding. I will remind you, sir, 19 once again that you are still under oath. The information 20 that we seek, Mr. Boyer, is that test result of the PECO 21 employees, the bus drivers who were taking the examination 22 ,
for qualifying as a Class 4 driver in the State of i
I 23 ' Pennsylvania, the Commonwealth of Pennsylvania.
fl v
24 25 ACE-FEDERAL REPORTERS, INC.
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1s JAV/bc 1 Whereupon, 2 VINCENT BOYER 3 resumed the stand and, having been previously duly sworn, 4 was examined and testified further as follows:
5 THE WITNESS: Yes. Thirty-five people passed the 6 Class 4 License Exam on Monday the 18th, making a total of 7 58 employees who have received the Class 4 licensing.
8 The cla.ss was reduced by five or six expected 9 people due to storm trouble the night before, and corrective 10 actions that had to be taken that day. So some of those 11 people were' postponed until the next Monday.
12 We have some 45 people schedu' led to take the exam 13 next Monday. So, by the end of the day of the 25th, I would 14 expect that we would have 100 employees who have been issued 15 Class 4 licenses.
16 JUDGE HOYT: Is that August?
17 THE WITNESS: August 25th, Monday. Now, to date, 18 we have received 187 learner's permits. That is, 187 19 employees have received learner's permits, which means they 20 have had a physical examination and it's been forwarded to 21 the State and the learncr's permit has been issued.
22 : We have trained in classroom training and driver I
23 training 155 people to date. There will be two classes next 24 l week, which will possibly catch another 50 employees, 50-60
[}
25 employees.
l ACE-FEDERAL REPORTERS, INC.
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8750 01.03 21297 1 DAV/bc 1 JUDGE HOYT: Thank you.
2 Do you have any questions on that?
3 MR. STONE: Just a couple, your Honor.
4 FURTHER CROSS-EXAMINATION 5 BY MR. STONE:
6 0 How many employees flunked the test on Monday?
7 A I think thers were five who did not pass. So 8 there would have been 40 who took the test. One had side 9 vision difficulties, which I believe can be corrected with 10 glasses.
11 But, at least at that point, he was turned down.
<w 12 Two did not successfully pass the skill test on the N .]
13 highway. And two did not pass the written test. They will 14 be included the group that is to be rescheduled for next 15 Monday.
16 0 Of the 155 people you say who have been trained '
17 so far, do you know what percentage of them have 18 successfully completed their physical exam?
19 A All of those have successfully completed their 20 physical exam, or they would not have gotten that far, 21 because the physical exam is required for the learner's 22 ! permit and the classroom training.
23 MR. STONE: That's it. Thank you.
24 JUDGE HOYT:
() ,
Mr. Hirsch.
25 l MR. HIRSCH: I have no questions, your Honor.
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8750 01 04 21298 1 AV/bc 1 JUDGE HOYT:
Staff?
2 MR. VOGLER: Staff has no questions, your Honor.
3 JUDGE HOYT: No redirect, Mr. Conner?
4 MR. CONNER: No, your Honor.
5 JUDGE HOYT: Thank you very much, Mr. Boyer.
6 (Witness excused.)
7 JUDGE HOYT: Just to be on the very safe side, 8 there are a couple of problems in the transcript as I went 9 through it, on Wednesday, of those hearings that we had on 10 Monday. -
11 Let me see if there are any additions. I note gs 12 that on page 21,190, that the reporter misidentified the LEA V
13 person as Ms. Simpson. It should be Mrs. Zitzer, I 14 believe. Is that correct, Ms. Mulligan?
15 MS. MULLIGAN: Yes, Judge.
16 JUDGE HOYT: That will be on lines 16 and 17 and 17 the reporter will make that correction. I had noted that I 18 used the "Sullivan" for Mulligan later on in the 19 transcript. I misspoke identification. That was incorrect.
20 On page 21,191, I believe we've already taken 21 care of that by the testimony of Mr. Boyer concerning the 22 f number of persons that had been testifying. I think that's 23 all right now.
24 Yes, Mr. Conner?
[}
25 ACE-FEDERAL REPORTERS, INC.
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8750 01 05 21299 1 DAV/bc 1 MR. CONNER: We have a housekeeping item of the 2 same type. Following 21,189, the licensee's testimony was 3 bound in but, somehow, immediately preceding that is a 4 discovery document dated August 4, 1986, one of those that 5 we produced pursuant to the Board's Order to LEA.
6 We did not offer it. Given the trouble that has 7 occurred in the past in certain cases about exhibits, I 8 think the transcript should be made abundantly clear that 9 this was bound in by mistake, that we did not offer it.
10 JUDGE HOYT: I think we can order the removal of 11 that since it is not a document that was indicated, be
,- 12 included in the transcript at that point.
lj 13 The only portion of the prefiled testimony 14 ordered to be inserted in the record was just that, the 15 i testimony relating to remand hearing on availability of bus 16 drivers in the Owen J. Roberts and Spring-Ford School 17 Districts, testimony of the panel, Vincent S. Boyer and 18 l Robert Bradshaw.
19 I have no idea how that particular document l
20 l became a part of this transcript. I will delete it.
21 Thank you. I had passed over that one, and I did 22 l mean to include that. If there are any others between there i
23 and the next one that I had some problem with, which was on 24 21,217, Mr. Stone?
( })
25 l MR. STONE: I think, in reference to the last l
l l
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8750 01 06 21300 d bAV/bc 1 deletion, I believe, in our copy at least, following the 2 service list, distribution list, it's a three page 3 deletion.
4 I have three pages from that document.
5 Is that correct?
6 JUDGE HOYT: Yes, the three pages is the document 7 that, for some reason unbeknownst to me, was incorporated in 8 the transcript. And as I indicated, the only portion 9 ordered inserted the record was the testimony of the 10 witnesses, Boyer and Bradshaw, the prefiled testimony.
11 MR. STONE: Thank you.
,_ 12 JUDGE HOYT: Going back to 21,217, I have a 13 problem beginning at line 4 on that page. I believe the 14 transcript to be garbled at that point. I wonder if we can 15 get a correction from the licensee here, since it deals with 16 his witness, Ms. Kankus, who I believe is here.
17 MR. CONNER: We have of course started to make 18 transcript corrections. Mr. Rader can tell you what we 19 have.
20 JUDGE HOYT: Mr. Rader?
21 MR. RADER: I believe the entire answer by 22 ! Ms. Kankus to read:
23 l: " Bus drivers are provided as County management l
(-)
V 24 l workers. If the County requested us to get the County to 25 help them to get to the staging areas, I'm sure we could ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwale CoverEg3 800 33M646
8750 01 07 21301 1 bAV/bc 1 accomodate them. But they are County emergency workers."
2 JUDGE HOYT: " County emergency workers" in lieu 3 of the word " managers" on line 8?
4 MR. RADER: Yes. Managers should be " workers".
5 On line 5, " management" should be " emergency".
6 JUDGE HOYT: All right. Do you have any 7 corrections on that?
8 MR. STONE: Yes, your Honor.
9 I recollect the sense of the answer as meaning 10 that there were County emergency managers who would then '
11 deal with the section from the staging area to the schools.
12 I am not sure that the change follows the sense O. 13 of the answer. I certainly agree that the first part should 14 be changed to " county emergency workers". I sense the 15 distinction in the answer at that point was made between the 16 workers and regular county workers and managers.
17 MR. CONNER: If the court please, why don't we 18' just put Ms. Kankus back on the stand?
19 JUDGE HOYT: That's exactly what we'll do at this 20 time. Ms. Kankus, come forward and take your place on the 21 witness stand again.
22 23
(} 24 25 l
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ljDAV/bc 1 Whereupon, 2 ROBERTA A. KANKUS 3 resumed the stand and, having been previously duly sworn, 4 was examined and testified further as follows:
5 MR. CONNER: May I proceed?
6 JUDGE HOYT: Yes. First of all, Ms. Kankus, you 7 have been recalled to the stand, taking your place on the 8 witness stan.d. You have previously taken an oath in this 9 proceeding. I remind you that you are still under that 10 cath.
11 Mr. Conner, you are showing now, I hope, to the 12 witness, the transcript of the pro ~ceedings for August 18, b'
'~
13 1986, pages 21,217. And on that page, line 4 through line 14 8.
15 Ms. Kankus, let me ask you to read that through 16 and then tell us what it is that you said at t' hat point.
17 THE WITNESS: I was answering in response to 18 Mr. Stone's question; would I have my objection to the 19 company making sure that this next stage of bus 20 volunteers performing their role will be done. I said no, 21 because the bus drivers were being provided to the County as 22 County emergency management workers. The County requested 23 us to transport the workers from the staging areas to buses, 24 that we would try to work with the County to do that, as we 25 would with any request from the County agencies.
26 JUDGE HOYT: Is the suggested change starting on ACE-FEDERAL REPORTERS, INC.
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8750 01 09 21303 1 bAV/bc 1 line 4 to read as follows:
2 " Bus drivers are provided as County management 3 emergency workers." Period. "If the County requested us to 4 get the County to help them get to the staging areas, I'm 5 sure we would accommodate them. But they are County 6 emergency workers."
7 THE WITNESS: That's correct.
8 JUDGE HOYT: Thank you.
9 Mr. Stone, I think that answers your question.
10 The changes will be made as indicated. Ms. Kankus, I 11 appreciate your coming back. Thank you. You are excused.
12 (Witness excused.)
N,j 13 JUDGE HOYT: On page 21,223, I have a problem 14 beginning on line 22. I'm not sure that the figure 105 is 15 correct. Is that proper, Mr. Rader? Did you check that so 16 far as the testimony of your witness, since it was 17 Mr. Boyer who was testifying at that point?
18 MR. RADER: It should have been 205.
19 l JUDGE HOYT: That's what I understood. Very
- 20 well, the correction will be on line 22 for the figure one, 21 :
zero, five, it should be corrected to read "205".
22 l Are there any other corrections that anyone has 23 l between the pages 21,217 and 21,223?
/~'; 24 ,
MR. RADER: Your Honor, we will file suggested i s' i 25 corrections, but the ones of significance, I'd like to give
{
I 1
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("h 1s,3AV/bc 1 now, if I may.
2 At page 21,202, there's a reference to capital R, 3 capital C, small s in the question by Mr. Stone, I believe.
4 And I think he was saying RACES, which is an acronym, 5 R-A-C-E-S. And it's used several times thereafter.
6 JUDGE HOYT: That's on line 8. Is that correct, 7 Mr. Rader?
8 MR. RADER: Yes, ma'am.
9 JUDGE HOYT: Yes. I must confess, when I read 10 through, I. read " races" and I see now that it's R-C small 11 letter s. And I believe " RACES" is correct.
12 Mr. Stone, that was your question, was it not?
O V 13 MR. STONE: Yes, RACES is correct.
14 JUDGE HOYT: Where that appears elsewhere in the 15 transcript, I think we're now aware that the reporter 16 made a mistake and that it will be corrected.
17 I will take it, Mr. Rader, that you will include 18 that correction and those others that you may have, that you 19 will submit in your formal motion for correction of the 20 record.
21 MR. RADER: Yes, I will, ma'am.
22 At page 21,208 at the bottom of the page, line 23 23, the transcript reads:
24 " WITNESS BRADSHAW:: And then beginning answer:
25 "Mr. Boyer". It should be reversed to read " WITNESS BOYER:
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$hDAV/bc 1 Mr. Bradshaw will answer that question."
2 MR. STONE: Yes.
3 MR. RADER: Likewise, in the next page, where it 4 says " WITNESS BOYER:" on the top of line 1, it should be 5 " WITNESS BRADSHAW", since that was Mr. Bradshaw's answer.
6 JUDGE HOYT: Very well.
7 MR. RADER: Finally, on page 21,213 and 8 thereafter, the reporter referred to the Lineville 9 Marshland Center, when the witness of course was referring 10 to the Lionville Marshaling Center.
11 JUDGE HOYT: Ve ry well . Those corrections will 12 be noted in the record. Let me review them. That's the O 13 one -- well, I'm not going to read 21,000 over and over 14 again. It's page 208, 21,208.
15 "Boyer" for "Brandshaw" and "Bradshaw" for 16 "Boyer" on line 23, accordingly, and on 209, the 17 witness is Bradshaw, not Boyer.
18 The other change is on 213, line 22, reading:
19 "Lionville Marshaling Center", is that correct?
20 MR. RADER: Yes, ma'am.
21 JUDGE HOYT: We've got as far as 217. I beg your 22 pardon -- 23. Anything you've been reading in there that 23 you want to go through?
24 MR. RADER: They're minor typos.
25 JUDGE HOYT: Let's take the minor typos, where ACE-FEDERAL REPORTERS, INC.
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8750 01 12 21306 AV/bc 1 they might be some things used in this transcript today.
2 Let's, however, have the substitute changes made at this 3 point.
4 The typos we can take care of later on.
5 On page 234, I believe on line 2, the questioner 6 should be " Stone", not " Conner", is that correct?
7 MR. RADER: Yes.
8 JUDGE HOYT: That correction will be made.
9 A very minor one on page 264, line 7. That's 10 Owe n J . Roberts, not Robertson. I made a mistake and I 11 realize it's very dif ficult to believe, on page 268 at line 12 18, when I referred to Mr. Hippert's testimony as that of the 13 applicant.
14 That should be the testimony of the Commonwealth 15 of Pennsylvania, line 18.
16 17 18 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC.
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8750 02 01 21307 2 bAV/bc 1 I think, on 273, at line 11, this is the 2 testimony I believe of Mr. Hippert in response to the 3 questions of Judge Harbour. I believe that is "28" and 4 "8". Is that correct?
5 MR. HIPPERT: Yes.
6 JUDGE HOYT: I believe the verb should be "was".
7 We have an extra "why" in there. I didn't find in my review 8 any other questions concerning the transcript. However, any 9 substantive changes that may alter the proceedings this 10 morning, I certainly would take any motions to correct 11 at this time.
12 MR. STONE: I would just note for the record, w
13 your Honor, that we just received our copy this morning, so 14 we can't make any rdditional comments at this time. So far, 15 it looks good.
16 JUDGE HOYT: Did you have a transcript?
17 MR. STONE: We had a transcript Federal Expressed 18 that arrived yesterday morning. But we didn't get the copy 19 l until this morning when we came in.
i 20 l JUDGE HOYT: You've had ample time, however. The l
21 j licensee is going to file some changes. However, I believe, t
22 ; Mr. Stone, if you have any substantive changes, we will 23 entertain those at this time.
() 24 You certainly had in that length of time, had v
25 l ample opportunity to make any corrections.
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8750 02 02 21308 hDAV/bc 1 MR. STONE: Your Honor, to further clarify, due 2 to an error of the Federal Express, it arrived at our office 3 with --
4 JUDGE HOYT: It arrived at an office whose 5 address you gave to the reporter, Mr. Stone?
6 MR. STONE: No, it didn't.
7 JUDGE HOYT: How would the reporter have had that 8 address.? It had to be the address that you gave to the 9 reporting company, Mr. Stone.
10 MR. STONE: Not to belabor the record, it was 11 simply a matter where they delivered it to the office on the 12 same floor; we didn't know it"was there by the close of work 13 yesterday.
14 By the time Ms. Mulligan had made several 15 phonecalls to Federal Express, they told us they delivered 16 it to this other office, at which point tIhat office was 17 locked and somebody went over and got it. So that's the 18 situation, not to belabor the record.
19 JUDGE HOYT: Not to belabor the record, 20 Mr. Stone, you have had ample oppertunity to have received a 21 l copy of the transcript and made those changes. Very well, 22 l we will proceed. We only have two additional witnesses to 23 call this morning, and those are your witnesses, Mr. Stone.
r's 24 Are they ready?
Rj' 25 MS. MULLIGAN: Judge Hoyt, I'd like to recommend i
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8750 02 03 21309 1hbAV/bc 1 for the expedition of the hearing this morning to call both 2 witnesses as a panel, considering most of the questions are 3 mutual to both.
4 JUDGE HOYT: Do you have any objection to that?
5 MR. RADER: Licensee has no objection.
6 JUDGE HOYT: We'll try that, Ms. Mulligan.
7 However, the thing that disturbs me is that these two 8 witnesses are dealing with two different school districts; 9 two different bus companies are involved in each of the 10 problems concerning the drivers.
11 There were two different surveys made. And you 12 may call them as a panel, but I caution that I'm not going
( )
13 to have this be like a bouncing ball, where we can't 14 determine what district we're dealing with and what bus 15 companies we're dealing with.
16 I'll be happy to try it, but I must say that it 17 appears to me a little bit of a difficulty. If I don't feel 18 at any time that it's getting information that we have to l
19 l have on this record, we will separate them.
20 So, with that caution, yes.
l 21 i MS. MULLIGAN: I'd like to call Dr. William 1
22 Welliver and Dr. Roy Claypool.
23 JUDGE HOYT: Gentlemen, if you'll come forward, 7y 24 I please, and take your place on the witness stand here.
N-]
25 l Please be seated.
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)llpAV/bc 1 Gentlemen, I must first of all remind you that 2 you have previously, some time ago, taken an oath here in 3 this hearing. However, I will remind you at this point that 4 you are still under that oath.
5 Gentlemen, I must confess that time has dulled my 6 memory as to which ones you are here. So, please identify 7 yourself.
8 WITNESS CLAYPOOL: I'm Roy Claypool.
9 WITNESS WELLIVER: I'm Dr. Welliver.
10 JUDGE HOYT: And, Dr. Claypool, you are from the --
11 WITNESS CLAYPOOL: Owen J. Roberts.
12 JUDGE HOYT: And Dr. Welliver, you are within the
- J
(
i 13 Spring-Ford School District?
14 WITNESS WELLIVER: Yes, that's correct.
15 JUDGE HOYT: All right. Ms. Mulligan, they're 16 your witnesses. Please proceed with direct.
17 Whereupon, 18 ROY C. CLAYPOOL and WILLIAM WELIVER 19 resumed the stand and, having been previously duly sworn, 20 l were examined and testified further as follows:
21 l REDIRECT EXAMINATION 22 l BY MS. MULLIGAN:
23 0 Dr. Claypool and Dr. Welliver, most of the
,x, 24 l questions will be for both, and I will indicate if trty're 25 l separate questions. Plesase state your titles. You've l
26 already stated what school districts that you represent.
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8750 2 05 21311 d bAV/bc 1 A (Claypool) Superintendant of Schools, 2 Owen J. Roberts.
3 A (Welliver) Superintendant of Schools, Spring-Ford 4 Area School District.
5 0 Thank you. Please tell me what your involvement 6 has been in emergency planning for the Limerick Nuclear Power 7 Plant to date; just a rough background of what your 8 responsibilities are.
9 A (Claypool) According to Owen J. Roberts' 10 plan, I am the architect of the plan itself. I'm 11 responsible to carry out the plan.
12 O Dr. Welliver?
)
(~J
\ 13 A (Welliver) In the Spring-Ford Area School 14 District, I am primarily responsible for the development of 15 the plan and the orientation of the staff, and the 16 subsequent implementation of the plan.
17 O Are the bus drivers from your school district, 18 your respective school districts, under contract with your 19 schools?
20 Dr. Claypool, if you will answer first, we'll do 21 it that way.
22 A (Claypool) I'm sorry. Would you repeat the 23 question?
24 0 Yes. Are the bus drivers from your school 25 district under contract with your school?
26 A (Claypool) No. They are employees of an ACE-FEDERAL REPORTERS, INC.
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8750 02 06 21312 MllDAV/bc 1 independent contractor, Gross Bus Service.
2 O Dr. Welliver?
3 A (Welliver) The same is true at Spring-Ford, 4 except the contractor is Custer's Garage.
5 Q Are these the same buses and drivers that you 6 would rely on in an emergency at Limerick?
7 A (Claypool) Yes.
8 Q Dr. Welliver?
9 A (Welliver) These are some of the buses and 10 drivers we would have to rely on.
11 Q Are you aware, Dr. Welliver, at this time, what 12 are the other bus drivers that you would be relying on in K/ 13 an emergency?
14 A Not specifically. I could not identify them.
15 Q Back to Dr. Claypool: do you feel you have a 16 shortage of bus drivers should there be an emergency at 17 Limerick?
18 A (Claypool) Our current plan indicates both a 19 shortage of buses and drivers.
20 Q Dr. Welliver?
21 A (Welliver) Our plan indicates that resources 22 will have to be made available through the Montgomery County 23 Office of Emergency Preparedness.
7.s 24 JUDGE HOYT: I'm sorry, sir. I did not hear that
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~ l 25 l ACE-FEDERAL REPORTERS, INC.
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8750 02 07 21313 1llAV/bc 1 answer. If you'll speak directly into that mike.
2 WITNESS WELLIVER: Our plan indicates that there 3 are certain ummet needs that will have to be addressed by 4 the Montgomery County Office of Emergency Preparedness.
5 BY MS. MULLIGAN:
6 Q Dr. Claypool and Dr. Welliver, what do you base 7 your information on shortage of buses on -- bus drivers on, 8 excuse me.
9 A (Claypool) There was a survey taken in 1983.
10 There was a meeting with PEMA, the Chester County 11 Emergency Services and the task force on August 1, 1984, 12 That's part of the record of this hearing. All parties s .
(^'/
\- ' 13 agreed that those were the unmet needs, based on the survey.
14 Q Dr. Welliver?
15 A (Welliver) We have a contract for 44 buses, with 16 a deficiency of 26 buses. The maximum number of drivers 17 that could be provided by Custer's Garage would coincide 18 with the number of buses. I do not know how many they could 19 provide. The maximum number available would be those they 20 have contracted or employed to drive those 44 buses.
21 Q This is based on your survey information, Dr.
22 ; Welliver?
23 A (Welliver) No. It is based on the number of
,_ 24 buses they operate for us. I do not consider the results (L ,
25 ;
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s 8750 02 08 21314 qllpAV/bc 1 of any survey as presently being valid.
2 MS. MULLIGAN: I'd like to take this time to hand 3 to the witnesses a copy of an affidavit by Timothy Campbell.
4 That will be going to Dr. Claypool. And one affidavit from 5 Lindley Bigelow, going to Dr. Welliver.
6 BY MS. MULLIGAN:
7 0 I would like to turn your attention to paragraph 8 3 of the affidavit of Timothy Campbeil, Dr. Claypool. I 9 show you the last half of the line. It says:
10 "I do not agree that this many drivers would fail x
11 to drive the buses in an emergency."
12 Did you realite that the County Emergency Manager 13 felt that way concerning the need for -- well, excuse me.
14 Strike that.
15 Did you know that the County Emergency Manager 16 believes that drivers will drive in an emergency?
17 MR. RADER: I object to that question as 18 irrelevant. I think the beliefs of the Director of 19 Emergency Services for Chester County as to whether or not 20 volunteers would or would not respond in an emergency is 21 irrelevant to the issue here, which is what raeasures have 22 been taken to secure an adequate number of drivers.
23 This affidavit, of course, was prepared and 24 submitted in connection with the licensee's proposal or n,
(j#
25 stipulation, which was rejected by LEA as not a part of this 26 hearing.
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8750 02 09 21315 jlgDAV/bc 1 And Mr. Campbell was here to be cross-examined by 2 LEA, and this was not even examined upon.
3 JUDGE HOYT: On the latter grounds, to ask this 4 witness what the witness had testified to when that 5 individual had been presented earlier in this hearing, I 6 think that was the time to have made the questions available 7 on that.
8 MS. MULLIGAN: I think I can ask it another way, 9 because Dr. Claypool said that he has had meetings with the 10 emergency coordinator.
11 JUDGE HOYT: Let's try it from that point of 12 view, Ms. Mulligan. But, the objection, as phrased by Mr.
( 13 Rader, is sustained.
14 BY MS. MULLIGAN:
15 0 Dr. Claypool, was Mr. Campbell the representative 16 from the Emergency Management Office recently when you had 17 meetings on your plan, the school district plan?
18 MR. RADER: I must object again for lack of
- 19 foundation. I believe the witness said that he met with the 20 Director on August the 1st, 1984.
,. 21 MS. MULLIGAN: I will restate the question, 22 leaving out "recently".
-> 23 JUDGE HOYT: August 1, 1984. Previously I think 24 that Dr. Claypool testified on 1983.
O'*' j 25 MR. RADER: Yes, ma'am.
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8750 02 10 21316 yllpAV/bc 1 JUDGE HOYT: All right. Do you want to try it 2 again, Ms. Mulligan?
3 BY MS. MULLIGAN:
4 0 Dr. Claypool, have you met with any of the 5 officials involved in the emergency planning over this past 6 summer concerning evacuation?
7 A (Claypool) I am not sure that it's been 8 this summer. This spring, I did. I met with officials 9 after the last drill. We had a post-drill review. And I'm 10 .not sure if Mr. Campbell was present, but we certainly sent 11 him a communication af terwards giving him the update for our 12 status.
13 0 Are you aware of Mr. Campbell's 14 position that there are enough bus drivers to drive buses?
15 A Yes.
16 l 0 Does this information affect how you feel about 17 the County's commitment to securing more drivers?
18 A Yes, it does.
19 l 0 In what way?
i 20 ' A Positively.
21 ,
O Can you clarify that?
l 22 , A Yes. If the Director of the Emergency Services 23 is saying that we will (a) probably have more drivers than we
,_ 24 anticipate; secondly, that more
('^' )
l 25 j ACE-FEDERAL REPORTERS, INC.
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'jlhDAV/bc 1 drivers will be there for unmet needs. It certainly is 2 more reassuring, than if he had said, no, we cannot provide 3 them.
4 0 Then, the fact that drivers -- let 5 me strike that and ask the same question of Dr. Welliver.
6 MR. RADER: I must object to the form of the 7 question because the question related to discussion with 8 Chester County, or a post drill meeting with Chester 9 County.
10 JUDGE HOYT: I think, Mr. Rader, Ms. Mulligan 11 intends the question to be directed towards Dr. Welliver 12 concerning Montgomery County.
(~)J k- 13 Is that correct? You are Montgomery County?
14 WITNESS WELLIVER: Yes.
15 BY MS. MULLIGAN:
16 0 Dr. Welliver, have you met with 17 your County Emergency Manager? When was the last time you 18 did, or have you discussed this issue of drivers?
19 A (Welliver) It was at some point during I
20 l this summer. I do not recall the date.
i 21 0 Do you have any concerns about whether bus 22 drivers -- strike that.
23 Did Mr. Bigelow bring up to you the f act that he 24 felt that there were a suf ficient number of drivers in spite
~ l 25 - of the surveys that were originally taken?
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8750 02 12 21318 gIV/bc 1 A Yes.
2 O Do you have any concerns about the 3 fact that drivers -- strike that. I'm sorry. I'm having 4 a hard time rephrasing this.
5 Did you know that Mr. Bigelow believes that 6 drivers will drive in an emergency, in spite of the survey?
7 You're saying yes, you do?
8 A Yes.
9 0 I think I'll go on to my next question. Did you 10 ask then why the use of PECO volunteers as a short-term 11 solution to meet bus driver use? That is, the common 12 coordinator.
K/ 13 A Did I pose that question? No, I did not.
14 Q Did you, Dr. Claypool?
15 A (Claypool) No, I did not.
16 0 Do you have any concerns that this is a 17 short-term solution? That is, the use of PECO volunteers, 18 Dr. Claypool? Or, Dr. Welliver?
19 A (Claypool) As I read the material sent to my 20 office in the last few months, I think the overall plan is 21 to try at least 200 drivers. I've been assured by the 22 County, as long as those things are on file and they're I
23 perpetually upgraded, I do not consider that certain 7s 24 l short-term.
( ) !
25 i
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8750 02 13 21319 1()AV/bc 1 0 Do you think that is the most efficient solution 2 to the shortage of bus drivers' needs?
3 MR. RADER: Objection. That's irrelevant.
4 Efficiency is not the issue. The only issue is whether or 5 not the solution is adequate and provides reasonable 6 assurance.
7 MS. MULLIGAN: Judge Hoyt, I feel that it is 8 relevant in the sense that if there's another solution and 9 considering the ultimate responsibility comes down to these 10 two superintendants of school districts, that they should be ll, heard on this.
12 JUDGE HOYT: The objection is sustained.
13 BY MS. MULLIGAN:
14 0 Dr. Welliver, do you have any knowledge from your 15 conversations about what other proposals are being considered 16 to resolve the unmet driver needs for a permanent solution?
17 MR. RADER: I object to that as irrelevant. The 18 gentlemen have testified that they are satisfied with what 19 is in place, as has been testified to by the licensee's 20 witnesses and the witnesses provided by PEMA and the 21 Counties.
22 MS. MULLIGAN: Judge Hoyt, I don't believe either 23 of these witnesses said they are satisfied at this point.
24 JUDGE HOYT: I wish we could get the response to O 25 ACE-FEDERAL REPORTERS, INC.
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8750 02 14 21320 A j t ,DAV/bc 1 that question, but I think you're simply asking the same 2 thing over again. And the original objection that was 3 sustained is still in effect.
4 I will permit this one opportunity that you may 5 wish to have on the record -- for what purpose, I'm not 6 certain -- but, at any rate, the witness may answer.
7 MS. MULLIGAN: Do you remember the question?
8 WITNESS WELLIVER: I would like to have it 9 restated.
10 BY MS. MULLIGAN:
11 0 Do you have any knowledge from your conversations 12 of what other proposals are being considered to resolve the
( 13 unmet driver needs for a permanent solution?
14 A (Welliver) I have no knowledge of plans for a 15 permanent solution.
16 17 18 19 20 21 22 23 (1) 25 ACE-FEDERAL REPORTERS, INC.'
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8750 03 01 21321 ks.DAV/bc 1 0 Dr. Claypool?
U 2 A (Claypool) I have no knowledge of so-called 3 permanent solutions. There's a so-called interim solution.
4 I'm aware of one. That's the plan to train approximately 5 200 drivers.
6 0 Do you have any problem with the use of PECO 7 volunteers to drive? Both Dr. Claypool and Dr. Welliver.
8 A (Claypool) As long as they're Class 4 drivers, 9 no.
10 0 Dr. Welliver?
j 11 A (Welliver) I have no concerns in relation to 12 their operating the vehicles.
() 13 0 Dr. Claypool, do you have any
- concerns about the 14 time it would take volunteers to reach the staging area and i
15 then your school if there's an accident at Bolton?
16 MR. RADER: I believe that cuestion would require 17 some foundation. It hasn't been established that the 18 witness has that knowledge.
19 JUDGE HOYT: If you wish to lay the foundation on 20 that, you may, Ms. Mulligan. I'll sustain the objection and 21 permit you to lay the foundation for the cuestion.
22 BY MS. MULLIGAN:
23 0 Dr. Claypool, do you have any knowledge of the 24 times that it would take, say, as shown
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8750 03 02 21322 1 in the file, as to how long it would take bus drivers, PECO jgpAV/bc 2 volunteer drivers to reach your school?
3 A (Claypool) Yes.
4 0 Do you have any concerns relating to the tims it 5 would take to get these bus drivers to your school in case 6 of an accident?
7 A Yes. We have addressed that in our plan.
8 0 How have you addressed this in your plan?
9 A In our plan which was approved by my office in 10 the summer of 1985, Plan A is, at the first communication 11 from the Emergency Services, and that we will bring all of 12 our drivers and buses to our main campuses, with four buses
() 13 to our one elementary center.
14 We have installed two-way radios in all buses in 15 my office, and we will have two-way radios in all the 16 principals.
17 At that point, we can determine our own unmet 18 needs. If we get Plan A, the authority from the Central 19 County Emergency Services, to return our children to their 20 homes, we will do that in Plan A.
21 If we are not permitted to do that, we will 22 .
activate Plan B, which is to be in a holding pattern. At l
23 that point, we will communicate with Chester County as to
?.4 25 ACE-FEDERAL REPORTERS, INC.
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[^1DAV/bc 1 how many unmet needs we would have.
\_/-
2 In our exercises to date, when we have simulated
~
3 a bus and/or driver needs, it has been'approximately 45 4 minutes to one hour from the time we have called until they 5 have physically arrived at our facility.
6 That's the background on that.
7 O So, to answer the question then, do you feel 8 that the time it would take, or do you know how long it 9 would take the PECO volunteers to get to your school?
10 A I do not know that.
11 0 Dr. Welliver, at that point, I'd like to stop 12 there and ask you the same questions.
() 13 Are you aware of the time it would take to get 14 PECO bus drivers to your school district in case of an 15 emergency?
16 A (Welliver) No, I am not aware.
17 0 Dr. Claypool, to what extent does your current 18 school district plan rely on early dismissal?
19 MR. RADER: Objection. Irrelevant.
20 JUDGE HOYT: I'm sorry. May I have the cuestion 21 again?
22 MS. MULLIGAN: To what extent does your current 23 school district plan rely on your early dismissal?
24 He just testified to early dismissal was a part 25 ACE-FEDERAL REPORTERS, INC.
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?'SDAV/bc 1 of his plan.
(J 2 JUDGE HOYT: I'm aware of that. The objection is 3 overruled. Answer the question.
4 WITNESS CLAYPOOL: The basis for early dismissal 5 was from a citizens task force. Their recommendation is to 6 unite the parent and the child as soon as possible. We have 7 a plan that would be for chemical spills or anything else.
8 We would proceed to unite the parents and the child by 9 telephone communication.
10 We would not send anyone home unless we had 11 vertification that the parent or somebody else will take 12 that child.
rh
() 13 So I'm not sure how I can answer your question.
14 Would you restate it?
15 BY MS. MULLIGAN:
16 0 You pretty much did in terms of to what extent 17 does your school district plan rely on early dismissal.
18 A (Claypool) That is Phase A; the immediate phase, 19 depending on the time of day, weather conditions, et cetera, 20 is to unite the parent with child.
21 0 Have you discussed with anyone associated with 22 getting PECO volunteers, such as in your conversations and 23 meetings with the County Board, PEMA, to drive buses in the 24 early dismissal plan?
25 ACE-FEDERAL REPORTERS, INC.
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8750 03 05 21325 E wDAV/bc 1 A Yes. At each drill. At each drill, we've had a
! )
2 post-drill session where we've discussed Plan A and Plan B.
3 O Did you ask and do you feel that you could rely 4 on PECO volunteers to drive buses at this early stage of 5 alerting?
6 WITNESS CLAYPOOL: Plan A, probably not. I think 7 we would probably be doing an early dismissal, which we do 8 now with our own buses, 43 buses. And it takes us about an 9 hour to an hour and a half to notify the drivers to be 10 prepared for early dismissal.
11 And, at that point, we have two cycles. One in 12 the secondary schools, and one in the elementary.
() 13 O Are you aware' at what stage of alert you would 14 want to evacuate school children in an emergency?
15 A Our plan is that as soon as we receive a 16 telephone call, we will ask Chester County permission to 17 return children home. If we are refused that activity, we 18 will go into Plan B, which is to have all of our drivers and 19 buses on site.
20 ' At that point, I will take the responsibility if 21 there are congestions on the road to immediately begin 22 moving children to the Twin Valley School District.
23 I Will not wait until the last second because I'm 24 25 ACE-FEDERAL REPORTERS, INC.
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8750 03 06 21326 7DAV/bc 1 not assured of traffic control.
U 2 O So, at that point, you state that you would not 3 ask for PECO volunteers to drive buses?
4 A No, I did not say that. Plan A, I don't believe 5 the time would be adequate for them to provide the drivers.
6 However, if we were in Plan B and the situation worsens, I'm 7 sure I will ask the drivers immediately and use our drivers 8 to evacuate the elementary schools, as our plan calls for.
9 Then use the PECO drivers or unmet need drivers to evacuate.
10 0 Is it your feeling that the County Emergency 11 Management Coordinator -- in other words, Mr. Campbell --
12 would not make the buses available from PECO, or not alert
() 13 the PECO volunteers if you decided to use your Plan A, which 14 calls for earlier dismissal?
15 MR. RADER: I object to this cuestion as callina 16 for speculation as to what Mr. Campbmell might or might do 17 if called upon to do so by the witness, unless the witness 18 has specifically asked him.
19 JUDGE HOYT: Ms. Mulligan, I'm having difficulty 20 letting this line of questioning go on. We're dealing with 21 so many speculations about early dismissals here.
22 MS. MULLIGAN: Judge Hoyt, I will ask him --
23 JUDGE HOYT: May I finish my comment? Thank you.
24 25 ACE-FEDERAL REPORTERS, INC.
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! 7 mDAV/bc 1 The thing I'm concerned about is that the k_)
2 emergency plan that would have been implemented would 3 certainly not be related to the early dismissal plan that 4 the witnesses are testifying to which does not meet such 5 emergencies that we're dealing with in this particular 6 hearing.
't 7 I'm not clear as to why it is you want to pursue 8 this particular line of questioning. Perhaps you can 9 enlighten us as to what it is you're seeking to obtain so 10 far as the availability of bus drivers -- in this emergency 11 now. That's all that we're dealing with, and I think we're 12 just getting too far afield.
() 13 MS. MULLIGAN: Judge Hoyt', I'm trying to 14 determine whether the PECO drivers will be available at an 15 earlier stage, even though the County usually says that you 16 would not evacuate until a later stage.
17 And I'm just trying to determine whether this has 18 been discussed, or if there's an answer for this.
19 JUDGE HOYT: Ms. Mulligan, I think that is of
~
20 course the issue that we seem to be getting confused about 21 with the early dismissal problems that these gentlemen have 22 testified about, because these are not the individuals who 23 are called up in an emergency. The drivers -- the county 24 coordinators, Mr. Bigelow and Mr. Campbell, for their
- 25 respective counties.
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8750 03 08 21328 1 I don't believe these witnesses have that type of PAV/bc 2 testimony available. Indeed, if they did have it, it would 3 simply be speculation, their own judgments, which might not 4 necessarily be pertinent to our issue of whether or not 5 there are going to be available drivers.
6 MS. MULLIGAN: Only in the sense that Dr.
7 Claypool is taking some initiative here and trying to, at a 8 very early stage of alert, trying to possibly --
9 JUDGE HOYT: I believe, Ms. Mulligan, Dr.
10 Claypool's testimony was in relation to Plan A, which is 11 early dismissal. And that is not necessarily an emergency 12 plan, as I understand his testimony.
( 13 The objection is sustained.
14 BY MS. MULLIGAN:
15 0 I'd like to ask Dr. Welliver the same cuestions.
16 Dr. Welliver, to what extent does your current 17 school plan rely on early dismissal?
18 A (Welliver) Well, only in that secondary students 19 who have boon authorized to use their personal automobiles 20 l to depart from school would be allowed to do so at the early I
21 j stace.
22 We have no provision for an early dismissal using 23 j contracted transportation vehicles.
24 0 Dr. Welliver, do you have a parent r^3 '
25 !
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8750 03 09 21329 1 DAV/bc 1 chain of telephone calls for alerting parents in an 2 emergency?
3 A No.
4 MR. RADER: Objection, your Honor.
5 JUDGE HOYT: Ms. Mulligan, we are dealing with 6 bun drivers. The objection is sustained.
7 MS. MULLIGAN: This would only be as part of an 8 early dismissal.
9 JUDGE HOYT: The objection is sustained.
10 BY MS. MULLIGAN:
11 0 Dr. Welliver, as you understand it, does the 12 present PECO volunteer program put PECO volunteers under
[) 13 your supervision, control and responsibility while they 14 are loading, transporting and delivering school children?
15 MR. RADER: Objection. That's irrelevant as 16 well. The question here is the availability of an adequate 17 number of bus drivers from any source to transport school 18 children in the event of an emergency.
19 JUDGE HOYT: Ms. Mulligan, we have the witness' 20 testimony directed toward these issues that we are involved 21 with here so far as meeting the needs of the remand that we 22 , have in force here.
l 23 MS. MULLIGAN: Yes, Judge Hoyt.
24 JUDGE HOYT: Let me refresh your memory. In
(_) 25 l
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- gDAV/bc 1 ALAB 836, the Appeal Board was concerned with the s-)
2 availability of the drivers, of the surveys that these 3 gentlemen had conducted, which I believe go back, at least 4 in Dr. Claypool's case, to the survey of 1983.
5 I would like for you to direct your questions in 6 that vein. I think we are just getting too far afield here.
7 I also believe that some of the questions that you're 8 asking are those that should better have been handled with 9 the witnesses prior to this formal hearing, in your own 10 preparation of the case.
11 I believe we can't permit the preparation of the 12 case to be done on the record. So I'm going to sustain the
() 13 objection and ask you if you will direct your questions 14 toward the issue of bus driver availability and whether or 15 not these two gentlemen, as the representatives of the two 16 school districts involved in ALAB 838, Spring-Ford School 17 District, and the Owen J. Roberts School District, and the 18 availability of bus drivers and whether or not these 19 gentlemen find any unmet needs in light of the testimony and 20 the documents they have found in the case, to indicate how 21 the licensee and the county intend to proceed to meet those 22 unmet needs.
23 MS. MULLIGAN: Judge Hoyt, these witnesses also 24 have to know what their responsibility is and where their 25 responsibility lets off.
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8750 03 11 21331 1-~DAV/bc 1 JUDGE HOYT: That's correct, Ms. Mulligan, but O 2 that responsibility is not an issue in this hearing. The 3 availability of bus drivers to meet the needs of these 4 gentlemen in evacuating their school students is the issue.
5 The availability of the bus drivers in these two districts.
6 BY MS. MULLIGAN:
7 0 Dr. Claypool, do you have any concerns that PECO 8 volunteers from outside the area might not know the roads 9 very well when they evacuate school children?
10 A (Claypool) Yes.
11 MR. RADER: We object to that as well. The 12 training of the bus drivers is not known to these gentlemen 13 and is not an issue in this hearing.
(])
14 JUDGE HOYT: Training is an issue, yes. I agree 15 that it is one that we will have to have, but I don't 16 believe these two gentlemen have been charged with the 17 responsibility of that training.
18 Indeed, I believe it is the licensee and the 19 county representatives. Those witnesses have been on the 20 stand. If you wish to recall them, Ms. Mulligan, you 21 certainly may.
22 MS. MULLIGAN: Judge Hoyt, we're talking about 23 these superintendants' concerns.
24 JUDGE HOYT: Their concerns, as I understand the
() 25 ACE-FEDERAL REPORTERS, INC.
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8750 03 12 21332 7"NDAV/bc 1l ALAB 836, were with the concerns of bus driver availability.
X.J' 2 MS. MULLIGAN: As to how this affects the time, 3 this is still a very pertinent issue to the quality of this 4 plan.
5 JUDGE HOYT: Ms. Mulligan, again, these gentlemen 6 are not charged with that responsibility of the training. If 7 you wish to ask them other cuestions on it, perhaps those 8 would not be objectionable. At least, an objection would 9 not be sustained.
10 But I think what you're trying to elicit from 11 these witnesses is information that the witnesses simply do 12 not have.
() 13 BY MS. MULLIGAN:
14 0 Dr. Claypool, to the best of your knowledge, from 15 your meetings with the agencies involved, are the volunteers 16 being made available.to drive the buses part of the general 17 pool of drivers, or specifically for your school?
18 A (Claypool) I don't know.
19 0 Dr. Welliver?
20 A (Welliver) I'm not sure.
21 0 Dr. Claypool, is this a concern to you, that 22 these drivers would be part of a general pool?
23 MR. RADER: Objection. Let me restate my 24 25 ACE-FEDERAL REPORTERS, INC.
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8750 03 13 21333 7'wDAV/bc 1 objection of last time. I'll put it a little better this U
2 time.
3 At the last hearing, we had testimony from the 4 County witnesses and the Licensee's witnesses as to how 5 unmet needs for bus drivers would be met. The testimony was 6 very clear that the drivers would be and the buses would be 7 assembled in a pool and would be supplied from any given 8 source to any other source, but not predesignated.
9 That was upheld as proper and providing 10 reasonable assurance for bus drivers and buses as to the 11 entire EPZ.
12 LEA cannot relitigate that issue now as to these
() 13 two school districts as regards'to PECO drivers.
14 15 16 17 18 19 20 21 22 l 23 24
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$lhDAV/bc 1 MS. MULLIGAN: Judge Hoyt, these solution for 2 these two particular school districts are purported to be a 3 solution for their school district specifically.
4 I think it's important that both the 5 superintendants are able to assess whether this is part of a 6 general pool that would be a concern for all school 7 districts, or specifically the plans for their school and 8 these bus drivers are specifically selected for their 9 schools.
10 JUDGE HOYT: Ms. Mulligan, I don't understand why 11 we can't move the issue along here on the testimony these 12 witnesses do have available.
13 I sustain the objection again, Ms. Mulligan.
14 BY MS. MULLIGAN:
15 0 Dr. Claypool, to your knowledge, are the bus 16 drivers being assigned to your school as the result of the 17 survey?
18 MR. RADER: Objection. That's irrelevant for the 19 same reason. It doesn't matter whether drivers are coming 20 from Wissahickon or from PECO. Bus drivers will be provided 21 from the pool of drivers developed by the counties. That 22 was upheld in ALAB 836 and can't be challenged again here.
23 JUDGE HOYT: Ms. Mulligan, 836 was concerned with 24 the availability of the drivers. That was the only issue, 25 as I understand it, that the ALAB 836 was directed to.
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$lhDAV/bc 1 In the survey, for example, Dr. Claypool cited 2 that in there. I believe you're getting into an apparition 3 there, one not concerned with this hearing. Those were 4 matters litigated earlier. We are not involved with that at 5 this point.
6 The only indication that these witnesses have to 7 have, these superintendants, is whether or not there are 8 adequate drivers to fulfill the needs for the evacuation of 9 their student populations. That's what we're interested 10 in. Those are the questions and the direction that we would 11 point you to, to see if we can get their interpretations of 12 whether or not these drivers, once established on this, 13 would that be the number that you need.
14 We're dealing with a very concrete fact. We're 15 not dealing with concepts here; we're dealing with literally 16 numbers.
17 MS. MULLIGAN: We're also talking about their 18 responsibility.
19 JUDGE HOYT: No, ma'am, we are not. And that is 20 where I think your problem is occurring here. You insist 21 upon talking about their responsibilities. And their 22 responsibilities as school superintendants are to provide 23 transportation, to be sure that transportation for their 24 student populations are adequate, and they determined by 25 their surveys or by other means in the original hearings ACE-FEDERAL REPORTERS, INC.
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8750 04 03 21336 hllpAV/bc 1 that they do not have that assurance.
2 Now, the Appeal Board has said, that's correct, 3 we don't think they do. Now, we're nere to find out the 4 whether the numbers of drivers have been provided and all of 5 that.
6 And that could have been obtained, all of that, 7 through the testimony of the other witnesses, the county 8 representatives, whether they've been able to fulfill that 9 requirement.
10 These superintendants have a very limited role 11 here and that is 12 If we provide you with X-number of drivers to
.f')
13 fulfill all the needs, will that suffice to serve to 14 evacuate your school populations in the event of a 15 radiological emergency at the Limerick generating station?
16 That's the sole issue.
17 MS. MULLIGAN: Judge Hoyt, Mr. Campbell did 18 testify, he did say on page 21,237 on Monday -- I'm starting 19 ;
on line ll:
20 l "I do not see us as being out of the school 21 l district. We are in support of the school district l
22 operation."
23 ! JUDGE H0YT: That's correct.
rs 24 ! MS. MULLIGAN: Therefore, the testimony and the
(' )
25 ! responsibility and the opinions of these gentlemen are of ACE-FEDERAL REPORTERS, INC.
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8750 04 04 21337 1 hAV/bc 1 utmost importance in determining whether the bus drivers 2 will arrive, and if they are satisfied with all the aspects 3 of this plan.
4 JUDGE HOYT: Ms. Mulligan, I don't think that we
- 5 can ever convince you that this is not a relevant matter.
6 The objection is sustained.
7 BY MS. MULLIGAN:
8 Q Dr. Claypool, do any of your bus drivers take the 9 school buses home?
10 A (Claypool) The contracted services, there are a 11 number of drivers that do take buses home in the evening.
12 0 Do you or the County EMC have any way of reaching O 13 them once they take their buses home?
14 MR. RADER: Objection. That's irrelevant.
15 JUDGE HOYT Objection overruled.
16 WITNESS CLAYPOOL: Yes. There will be an alarm i
17 system for the drivers. In addition, we have spare keys
! 18 which are required to be in the main parking lot where they 19 houso the buses on Route 1.
I 20 JUDGE HOYT Thank you.
21 MS. MULLIGAN: Thank you.
I 22 I BY MS. MULLIGAN:
F 23 Q Dr. Wellivor, do any of your bus drivers take
?
24 their buses home?
! 25 A (Wnlliver) No, they do not.
i ACE-FEDERAL REPORTERS, INC.
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8750 04 05 21338 hAV/bc 1 0 Thank you.
2 JUDGE COLE: Ms. Mulligan, I'd like to ask a 3 question here while we're on the subject of taking buses 4 home.
5 Do any of your bus drivers, Dr. Claypool, take 6 the buses home during the day after they drop the kids off 7 at school?
8 WITNESS CLAYPOOL: Yes.
9 JUDGE COLE: Thank you.
10 BY MS. MULLIGAN:
11 0 Dr. Claypool, if PECO volunteers were needed to 12 driv"o those particular buses, have any arrangements been 13 made to do that?
14 A (Claypool) Yes, they have.
15 MR. RADER: I have the same objection. It 16 doesn't matter whether it's a PECO driver or another 17 volunteer driver from some other school district or some 18 other school provider, the same principle would apply.
19 The issue here of whether or not there are 20 adoquato drivers for thoso school districts which would be 21 mot by the PECO pool in particular has no bearing on that l
22 question.
23 l JUDGE HOYT: I believe the question was answerod, l
p 24 l Mr. Rador, and it has boon voided. In any event, se'11 25 j leave tho answor on the record.
26 l Proceed, Ms. Mulligan.
1 ACE-FEDERAL REPORTERS, INC.
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8750 04 06 21339 jlhDAV/bc 1 BY MS. MULLIGAN:
2 O Dr. Claypool, can you explain that method to us?
3 A (Claypool) Yes. Back in '83, when the survey 4 was taken, there were 19 buses -- 43 out of the lot, and 24 5 were taken home every evening. I contacted Gross Bus 6 Service yesterday. There were 43 buses on his lot. There 7 will be 28 housed at the lot and 15 taken home.
8 So there is a reversal on that procedure.
9 All buses have a spare set of keys which are controlled by 10 the coordinator of the contractor. They're at the root 100 11 housing lot, and they have a communications system with each 12 driver where he or she works in the event that they cannot
' 13 get back.
14 The argument on numbers, if I may, in the 15 testimony of Mr. Campbell, was the issue of 18. The survey 16 originally in '83 found 25 who would drive. However, 17 because a number of those took their buses home, this was a 18 back down to a, quote, " conservative", close quote, figure 19 of 18.
20 The argument or debate between the Chester County 21 and our district was the difference between 18 and 25. On 22 the record for the plan, it was the conservative figure of 23 18. We will also have maps for outside drivers, regardless 24 of who they are, where they're coming from on the evacuation 25 for Twin Valley.
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8750 04 07 21340 llhDAV/bc 1 Or, if they have to run a route toward the 2 school, that's all in place.
3 MS. MULLIGAN: Can I take a minute to check my 4 notes?
5 (Pause.)
6 BY MS. MULLIGAN:
7 0 Dr. Claypool, I'd like to go back to one 8 question. Do you know whether Mr. Campbell, in making the 9 assessment you referred to, the excess of drivers, accepts 10 or rejects the survey results?
11 A (Claypool) Would you repeat that, please?
12 JUDGE HOYT: When you ask that question, f
\ 13 Ms. Mulligan, I want to know what survey results you're 14 talking about.
15 BY MS. MULLIGAN:
16 0 Do you know whether Mr. Campbell, in making the 17 assessment you referred to of the excess of drivers, accepts 18 or rejects the survey results from your school district?
19 A (Claypool) Point of clarification.
20 Are you talking about the difference between 25 21 and 18?
22 0 Just generally speaking.
23 MR. RADER: I think that question is hopelessly 24 confused.
25 JUDGE HOYT: Do you understand the question, Dr.
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hgpAV/bc 2 WITNESS CLAYPOOL: I think I can clarify it, if I 3 may.
4 JUDGE HOYT: Well, wait just a minute. Do you 5 understand the quastion? I want you clarifying that 6 question.
7 WITNESS CLAYPOOL: I believe I understand the 8 question.
9 JUDGE HOYT: Let's hazard an answer then, sir.
10 WITNESS CLAYPOOL The original survey indicated 11 25 bus drivers would drive. It was not taken into 12 consideration on that raw data that 24 of the drivers took 13 the buses home after they went to work.
14 Therefore, the questions came up with our 15 citizens committee: Can we get all 24?
16 A figure was reached that it would not be 25 bus 17 drivers available, but 18. This was communicated with 18 Chester County in a formal letter, which is part of this 19 record.
20 Mr. Campbell and I, in discussions, he has said 21 over and over that when a real situation occurs, you will l
22 l probably have 25 versus 18. That is the difference.
23 He has not, in my professional opinion, rejected 24 the survey that was taken only to debate as to whether or 25 not it would be 25 or 18.
(} 26 JUDGE HOYT: One moment, Ms. Mulligan.
27 Dr. Claypool, the survey we're talking about is l'
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$lhDAV/bc 1 the survey that you earlier testified this morning was 2 conducted by you in 1933.
3 Is that correct?
4 WITNESS CLAYPOOL: That is correct. '
5 JUDGE HOYT: Thank you.
6 BY MS. MULLIGAN:
7 0 Dr. Claypool, do you think that the evacuation 8 plan for your school district is adequate to protect --
9 reasonably adequate to protect the school children in an 10 emergency?
11 MR. RADER: Objection. It's irrelevant.
12 JUDGE HOYT: Overruled.
h/ 13 JUDGE COLE: You can answer the question.
14 WITNESS CLAYPOOL: I can't really answer that 15 unless there is an actual situation. I have no experience.
16 I do know, however, that all of our training and in all of 17 our simulation drills, we have received outstanding reports 18 from Chester County PEMA, FEMA and Citizen Observers.
19 The issue of whether or not we receive unnet i
20 needs, i.e. bus drivers and/or buses, is a projection that I 21 can't answer. I don't really know what will happen.
I 22 BY MS. MULLIGAN:
23 0 Dr. Welliv9r, I'd like to ask you the same 24 question. Do you think that the evacuation plan for your 7- l
- 1) I 25 i school district is workable to give reasonable assurance ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coserage 800 336-6646
i 8750 04 10 21343 llllbAV/bc 1 that school children are protected if there is an emergency 2 at Limerick?
3 A (Welliver) You've slightly restated the 4 question, but I'll respond to it in its original form.
5 Our plan is not designed to protect. It is 6 designed to minimize risk and to put in place a systematic 7 process for responding to an emergency.
8 We do not make the assertion that our plan will 9 protect anyone.
10 0 Dr. Welliver, why do you feel that your early I
r 11 survey results are no longer accurate?
12 A (Welliver) I'm not very good on dates. The
(_ 's . .
."#' 13 record would show what was performed. And I don't recall s
either '83 or '84. I'm not aware as to how many of those 14 l 15 people are still driving for our contractor.
16 I would imagine there would be considerable 17 change.
18 In addition, I've never been able to interpret 19 the intent of those who did not respond to the survey, which 20 I recall as being a subs".antial number of drivers.
~
21 I had reservations concerning the validity of the 22 survey when we tabulated the results.
23 They are greater at this point than they were p 24 then.
U 25 MS. MULLIGAN: No more questions.
ACE-FEDERAL REPORTERS, INC.
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8750 04 11 0 21344 1llbAV/bc 1 JUDGE HOYT: I think we'll start off with the 2 Commonwealth. We'll give you the next to last shot, Mr.
3 Rader. We'll give the Staff the last opportunity, as is 4 customary in these hearings.
5 Commonwealth of Pennsylvania?
6 MR. GOODWIN: I have no questions, your Honor.
7 JUDGE HOYT: Mr. Hirsch?
8 MR. HIRSCH: I have no questions.
9 JUDGE HOYT: That's on behalf of FEMA.
10 Mr. Rader, on behalf of the Licensee.
11 CROSS-EXAMINATION
~
12 BY MR. RADER:
b)
'~'
13 Q Dr. Claypool, has your school district requested 14 any bus drivers as an unmet need to Chester County?
15 A (Claypool) Yes, in our plan we have.
16 O How many bus drivers?
17 A There would be a total of 34.
18 Q Do the 34 represent bus drivers which would be 19 ,
driving buses for unmet needs as opposed to your survey 20 results? Or, how does that break down?
21 A The results of the 34 is, according to our plan 22 ;
for '86 '87, we would need 52 buses. The survey indicated 23 18, which is a questionable figure. So the difference would 24 be 34.
p),
N..
25 JUDGE HOYT: Thirty-four?
ACE-FEDERAL REPORTERS, INC.
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I 8750 04 12 . 21345
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WITNESS CLAYPOOL: Thirty-four. That is found in
,2 our plan, which I think has been submitted as part of the 3 record. And I believe it's page 8840, document 6, or 4 attachment 6.
5 BY MR. RADER:
6 0 Has Mr. Campbell indicated that bus drivers will 7 be made available to you?
8 A (Claypool) Yes, he has.
9 MR. RADER: I have no further questions.
10 JUDGE HOYT: For the Staff?
11 MR. VOGLER: Your Honor, the Staff has no 12 questions this morning.
O' N' 13 JUDGE COLE: Dr. Claypool, really just one 14 question, which I believe you at least partially answered i
15 earlier today. It's with respect to how you would determine 16 what your unmet needs would be for buses and drivers during 17 the time of an emergency.
18 Could you describe to me how you would assess 19 what your needs with respect to the buses and drivers would 20 be, on how you would then communicate that to whomever you 21 would wish to communicate that to?
22 WITNESS CLAYPOOL: Yes, sir, that is part of our .
23 official plan. That is why we have Plans A and B. Plan A s 24 ! basically is when we receive the first communication from
)
25 Chester County or some other agency that there is a problem ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-33M64
8750 04 13 21346 m
1s _)AV/bc 1 at the Limerick generating station, that we will activate 2 all of our drivers and buses at that point. Not later, but 3 at that point.
4 Physically appear at a predetermined location.
5 We have a two-way radio system in our buses in my office 6 and all my principals. So we would then have a telephone 7 communication to see if the drivers who are working will be 8 able to get to our schools.
9 That would determine the issue that you're 10 talking about here as to unmet needs for drivers and/or 11 buses.
12 And then, according to our plans, I contact O 13 Chester County's intermediate unit, for two reasons. One, 14 to notify them of these unmet needs if we have them, 15 and which plan they recommend, we enact (a) which is maybe 16 in the morning where we can actually get the children home 17 based on what the situation is at the Limerick plant; or (b) 18, do not send them home but prepare for your sheltering or 19 evacuation to Twin Valley.
20 21 22 23 l gs 24 I 25 l
ACE-FEDERAL REPORTERS, INC.
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I 8750 05 01 21347
?^1DAV/bc 1 JUDGE COLE: Thank you.
V 2 Dr. Welliver, the same cuestion.
3 How would you determine what your unmet needs 4 would be in the time of an emergency?
5 WITNESS WELLIVER: At the alert stage, we would 6 place our contractor on notice and ask him to survey his 7 personnel to determine whether they would be available to 8 work in the event of an evacuation; feed that information 9 back to us; and, on that basis, we will advise the 10 Montgomery County OEP of the Montgomery OEP of the unmet 11 needs.
12 JUDGE COLE: Thank you. Thac's all I have.
() 13 JUDGE HOYT: I believe, Dr. Welliver, your survey 14 was conducted in the spring of 1984.
15 WITNESS WELLIVER: That's richt.
16 JUDGE HOYT: And it appears in the transcript 17 from the previous testimony. Have you conducted any survey 18 since then?
19 WITNESS WELLIVER: No, I have not.
l 20 ! JUDGE HOYT: Dr. Claypool, have you conducted any 21 survey?
22 WITNESS CLAYPOOL: No, I have not.
23 JUDGE HOYT: I'll ask both of you gentlemen to 1
24 comment as to why you have not.
I s
\ 25 WITNESS CLAYPOOL: First, I think our survey was ACE-FEDERAL REPORTERS, INC.
E-347-3700 Nationwide Coserage 804 336 6686
8750 05 02 21348 dlhbAV/bc not conducted by the Superintendant of Schools, but a 1l 2 special task force of citizens which was commissioned by the 3 school district to survey this, based on Labor Law FI-95.
4 If they felt that the Superintendant was in 5 charge of the instrument, we would be getting a very biased 6 report, we have not done that before, I repeat, because our 7 plan will answer for us in a real emergency what the real 8 unmet needs are versus a simulation of a survey of drivers.
9 JUDGE HOYT: Dr. Welliver, will you respond, 10 please?
11 WITNESS WELLIVER: Yes. I consider it to be an 12 exercise in futility. I'm more concerned about the number
'- 13 of buses that park in the school door in the event of need 14 than I am someone's perception of their actions well in 15 advance of an emergency.
16 JUDGE HOYT: Dr. Claypool, are you satisfied that 17 in the event of a radiological emergency at Limerick in 18 which evacuation would occur that the school population 19 under your charge could be evacuated with the appropriate 20 amcunt of bus drivers available.
21 WITNESS CLAYPOOL: Given sufficient time, a 22 i qualified yes.
23 JUDGE HOYT: Dr. Welliver?
s 24 WITNESS WELLIVER: On the basis of the
( )
v 25 information presented and the assertions of others, I feel ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 804336-6646
r 8750 05 03 21349 P~DAV/bc 1 that a plan can be implemented satisfactorily.
V 2 JUDGE HOYT: Dr. Welliver, are the others that 3 you referred to in your response those officials in the 4 County of --
5 WITNESS WELLIVER: Montgomery.
6 JUDGE HOYT: Montgomery. Mr. Bigelow and his 7 staff?
8 WITNESS WELLIVER: Yes.
9 JUDGE HOYT: Thank you. I have no further 10 questions. Any other cuestions from any other members?
11 (No response.)
12 JUDGE HOYT: Gentlemen, you can be excused. Oh,
() 13 I'm so'rry. Mr. Goodwin, you indicated you may have a 14 question.
15 MR. GOODWIN: Yes, your Honor. We would just 16 like to clarify the numbers of buses that Dr. Claypool made 17 reference to from his school plan.
18 FURTHER CROSS-EXAMINATION 19 BY MR. GOODWIN:
20 0 You made reference to page NNNN?
l l 21 JUDGE HOYT: I believe that was another witness 22 who made reference to that page.
i l 23 BY MR. GOODWIN:
I 24 l 0 Do you have the plan in front of you?
25 A (Claypool) Yes, I do.
ACE-FEDERAL REPORTERS, INC.
i 202-347 3700 Nationwide Coverage 80N36-6646
8750 05 04 21350 T'tDAV/bc 1 0 Could you look down at the very bottom where it V
2 makes reference to the unmet needs are provided as follows, 3 and it lists a high school and a middle school, with the 4 numbers: High school, 16, and middle school, 10?
5 A Yes.
6 O That gives us a total of 26. I believe you 7 stated in the answer to Mr. Rader that you had a total of 8 34.
9 A You're confusing, I believe, sir, buses and 10 drivers. There are 26 buses. However, we will need 26 11 drivers, plus we will need an additional eight drivers to
-12 drive existing buses.
(")s
(_ 13 As I read in the paper, the argument would be 14 eight. That's the reconciliation I would have for the eight 15 drivers.
16 -
(Pause.)
17 O The only point I wanted to make then is, 18 basically, if we look strictly at the Gross Bus Company, 19 which is your contractor, using your figures, we would have 20 an unmet need of eight drivers.
21 Is that correct?
22 A That is correct. That's the 18 conservative versus
~
23 the 25 that the County says.
24 MR. GOODWIN: Thank you.
O 25 JUDGE HOYT: Are there any other questions in 4
ACE-FEDERAL REPORTERS, INC. H 202-347-3700 , Nationwide Coverage _ _
800-336-6646 , _
8750 05 05 21351 1llbAV/bc 1 redirect?
2 (No response.)
3 JUDGE HOYT: The response appears negative. May 4 these witnesses be excused?
5 Very well. Gentlemen, thank you for your 6 testimony.
7 (Witnesses excused.)
8 JUDGE HOYT: Ve ry well, let's go off the record 9 for a moment here.
10 (Discussion off the record.)
11 JUDGE HOYT: During the off-the-record time, the 12 Board and all the parties to the proceedings discussed
( 1
~#
13 filing of findings of fact and conclusions of law. It was 14 determined that there would be simultaneous filings of facts 15 and conclusions of law in the form of an initial decision, a 16 proposed initial decision, by close of business on Friday, 17 August 29, 1986.
18 It is the intent, as the Board has indicated to 19 the parties, to have at least a preliminary decision prior 20 to the opening of the school districts. In the case of 21 Spring-Ford, on September 3, as represented by Mr. Bigelow, 22 who is also present in this hearing room at this point; and 23 in the case of the Owen J. Roberts School District by
,cs., 24 l September 4th, which is the opening date of the school
'n )
25 district there.
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8750 05 06 21352 1 AV/bc 1 If there are no other concluding matters that 2 need to be discussed, do the parties wish to make any 3 additional representations?
4 (No response.)
5 JUDGE HOYT: None having been heard, this hearing i
6 is closed. The record is complete. Thank you.
7 (Whereupon, at 11:10 a.m., the hearing was 8 adjourned.)
9 10 11 12 O 13 14 15 16 17 18 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC.
. . . - a:~m . _ ~w~m- - . m>m . -.
CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)
DOCKET NO.: 50-352 OL 50-353 OL PLACE: Philadelphia, Pennsylvania b DATE: Friday, August 22,.1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt) ' /
(TYPED)
DAVID L. HOFFMAN Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation O
~
, . RtH6 '9513:02 T-l.!!a.El E F - 5100 #359-02 j3 INITED STATES OF AMIRICA V} NUCLEAR RH3UIATORY C0fEISSION Befere the Atemic Safety and Lice 2 sing Board In the Matter of )
)
Ebiladelphia Deetric Cocrpany ) Docket Nos. 50-352
) 50-353 (Limerick Gererating Statien )
Units 1 and 2) )
AFFIDAVIT OF A. LINDLEY IiIGELCW A. LINDLEY BIGELOW, being first duly sworn, hereby deposes and says:
My name is A. Lindley Bigelev. I am the Coordinator of Energency Preparedness for Montgcmery County, Pennsylvania. My office is at 50 Engleville Road En.gleville. Pennsylvania, 19k03.
I am familiar with the Ordar of the Atomic Safety and Licensing C
U Appeal Board, dated May 7,1906, which remanded Phase Three of the pro-ceeding* to the Licensing Board for consideration of the availability of bus drivers for the schcol district plan rer Spring-Ford School District.
1 tat order, as applicable to the Spricg-Ford Sebool District, suggesta that only 57.5% of the drivers for the school district would, in fact, perform in the event of an emerency. Based en my experience.
I do not gree that the drivers vould fall to perform their duty.
Tr. Ih293 Moreover, I have nade arrangrerents vi th other bus crepenies cut-side the EPZ to provide bures and drivers if necessary for an evucuatien.
The total nu: ster of buses available in Fontecaery Ceunty, as reflected in cur latest annual survey, is 1,257 (aces not include 2h2 minibuses, 1
. D ~f~
.c_ w . r .as)Tr.f.ro 1
i 205 vans, and 79 handicapped vehicles) and the total nunber of drivers is 1,919, recognizing that these nimbers change continually. On this basis, I am confident that thera vould be no shcrta6e of drivers for acy evacuation of the Spring-Ford School District.
In addition, the Philadelphia Electric Coc:pany has advised me that it has identified 270 individunis, each of vbcn has agreed (s) to drive school buses in Mentgemery County as ::ay be necessary upon sy request.
(b) to take training to qual.ify for s Coc:zonwealth of Pennsylvania Class b driver's Itcense, which author-izes operation of school buses, and to =aintain it .
These individuals have also agreed that, upon :y re. quest, they would report to the Ber r/n Transportatien Center, where they could be transported wherever needed in Montgccery County, to include the Caster Garage, to drive any buees as say be necessary in the Spring-Ford School
)) District.
Further, Philadelphia Electric has advised me thst it estimtaa h
that 105 of th* volunteers could arrive at Bervyn within 30 :ninutes ,
LO within 60 :ijnutes, and 125 vithin 90 ninutas if needed.
t
/ .A <
4 A. L1rdley pigelev( ~
Subscribed and svo to before me this /
day of June, 1986.
[ O
'l{u/lL //)./ t< &b Notary Public
."y eccaissicn er; ire.s Pl%ul . 1 S. 19ff .
mul v m3. *** M*:
ne..wwn, ertrm CeA Pt g W nussabf.ms8d A.IN "J t' t*
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- s- , . e, , s t
,' i UNITED STATES OF AMERICA 4
NUCLEAR REGULATORY COMMISSION j' ) Before the Atomic Safety and Licensing Board In the Ma*.ter of )
)
Philadelphia Electric Company ) Docket Nos. 50-352
) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
AFFIDAVIT OF TIMOTHY R. S. CAMPBELL 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 M 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 th'e 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.
(TR. 19987, 2003).
m
t
))
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 equipment; Class 4 licenses authorize operation of school buses).
Accordingly, PE has identified 300 individuals who have agreed (a) to drive school buses 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
_y/ 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.
~
s-i Timothf R. S.Camplhll, Director Department of Emergency Services Subscribed and sworn to before me this /d 1 day of June, 1986.
lb h-ttu < LL
} / Notary Public
, Wes My comm ,ssion expirerp. c~t Chester,
-: Chester Co., Pa, Ges reo. 40,1937 g