ML20212P335
| ML20212P335 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/29/1986 |
| From: | Mulligan M, Stone D LIMERICK ECOLOGY ACTION, INC. |
| To: | |
| References | |
| CON-#386-556 OL, NUDOCS 8609030091 | |
| Download: ML20212P335 (17) | |
Text
1 W 5 56 00CHETED USNRC UNITED STATES OF Ah! ERICA --
NUCLEAR REGULATORY C0hBlISSION BEFORE Tile AT0h!IC SAFETY AND LICENSING BOARD OFFICE C5 SLJuicihus
. o 00CKETING a service BRANCet
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PilILADELPilIA ELECTRIC COSIPANY Docket Numbers 50-3 0
)
(Limerick Generating Station )
Units 1 6 2) )
LIbfERICK ECOLOGY ACTION PROPOSED FINDINGS OF EACT AND CONCLUSIONS OF LAN IN Tile FORhl 0F A PARTIAL INITIAL DECISION RELATING TO REMANDED BUS DRIVER LIMERICK OFFSITE EMERGENCY PLANNING CONTENTION Respect 1'ully submitted, Au;2st 29th,198'i David Stone 444t#4ft M Mau:*2en Mulligan O!! BEHALF OF LIMERICK ECOINI ACTIO:I 8609030091 860929 PDR ADOCK 050003S2 G PDR 2 h)
- INTRODUCTION
- 1. In ALAB 836, the Atomic Safety and Licensing Appeal Board remanded for further disposition the matter of the assurance of drivers for the school children of the Owen J. Roberts and Spring-Ford School Districts in the event of an accident at the Limerick Nuclear Generating Station. In accordance with the remand instruction of ALAB-836 to address the issue within three to four months while school was in Summer recess, the Licensing Board issued an order dated May 22, 1986 directing the Licensee to submit its proposal for l resolution of the remanded issue within 20 days of the service date of the j order. Licensee's June 16,1986 Proposal- and Stipulation was sent by First Class Mail to LEA on June 16 and was received on June the 20th. Due to the fact that the Proposed Stipulation referred to documents that LEA had not received, LEA contacted Mr. Conner's office and requested that these documents be supplied by Express Mail. The specific items requested were referred to on page 3 of the proposed 6/16/86 Stipulation and included the affidavit of Mr. Ralph Ilippert of PEMA.
On June 27, 1986, LEA received a letter from Troy Conner to the Licensing Board dated June 26, 1986 that explained that a typographical error in the l
draft Stipulation should be changed from " November 15,1985" to refer to the l June 16,1986 Proposal. That June 26 Ictter made no reference to any other changes.
l l On Monday June 30, 1986 LEA contacted Mr. Conner to determine whether LEA would be receiving the requested documents relating to the Proposed Stipulation. Mr.
Conner indicated that there was no affidavit from Mr. Ilippert, reiterated the typographical error, and asserted that there were no other major changes.
lie also informed LEA that a corrected copy of the Stipulation had been sent to LEA for its consideration.
On Tuesday, July 1,1986 a neighbor delivered to the LEA office a Federal Express package which had been left at the neighbors, and which included a letter dated June 27th,1986 which contained the Licensee's revised proposal and Stipulation.
LEA considered the Licensee's further modifications to its proposal to be signi-ficant and after reviewing the changes, discussing it with school district officials, and again reviewing the record of these proceedings; responded to the Licensce's latest proposal of June 27,1986 with the position that the remanded issue was still a matter of controversy and requesting an adjudicatory hearing as prescribed by the ASLB order of 5/22/86, 10 CFR Section 2.710 and 2.749.
Page 1
2 Subsequent to a conference call, the Licensee provided LEA with a set of the volunteer sheets of the 570 PECo volunteers who were being set forth as a solution to the unmet Owen J. Roberts and Spring-Ford School District bus driver needs. The cover letter with these forms ~which included names, workplace, home zip code but no address or home phone, was dated July 22, 1986. In the conference call of July 17,1986 which had led to LEA's receipt of this material, LEA had expressed its intention to statistically sample the existence and quality of this purported volunteers. The Board had direted that LEA could choose ten of these employees and five alternates for depositions prior to the hearings scheduled for Mon. Aug 18th.
At a time close to the deadline for prefiling written testimony and within days of the time LEA would have had to finalize arrangements for taking depositions from the ten to fifteen workers permitted, LEA received on July 2S in the mail a third revision of the Licensee's Proposal for Resolving the Remanded Bus Driver Issue dated July 24,1986 In this third proposal PECo reduced the number of volunteers it was providing from 500 to about 200, thus rendering any sampling of the 570 names previously provided statistically insignificant. In this context, the Licensee's proposal that all fifteen names sampled by LEA would be included in the final 200 list was meaningless. Such inclusion would, of course, not allow statistical conclusions to be drawn about the status of the 185 others not deposed, and thus not specifically slated for inclusion by the Licensee out of the original 570 names. It should be noted that it was the results of a properly conducted statistical survey which caused this bus driver issue to be remanded in the place.
Therefore, in place of depositions of individuals picked at random from a universe of 570 names 2/3 of which were now not to be used anyway, LEA asked for certain supoenas and other documentation in a filing dated Aug 10,1986. On the Fri, before the start of the hearings on Aug 18,1986 LEA received the 200 volunteer forms of the 200 JECo workers the Licensee now claimed to be those it was providing as potential school bus drivers.
Again however addresses were not provided, but in any event the timing if all this rendered the question of contacting them and deposing them practically moot. LEA also maintains that other materials requested in its Aug 10 filing were not provided. (
Page 2 a
Backgr:und from ALAB-836 To put this remanded school bus driver in conter.t , we refer to the 3.
Appeals Board decision ALAB-836 where the Board concludes " that the Licensing Board's finding of reasonable assurance of a sufficient number of bus drivers willing to respond during an emergency at Limerick is not adequately supported by the record, insofar as the Spring-Ford and Owen J Roberts School Districts are concerned. Accordingly, we reverse the Bo2rd's decision in that respect. This action necessarily vitiates the reasonable assurance finding that serves as a basis for the operating license already issued to the Limerick facility." (ALAB-836, p.72) The reason the ALAB found for LEA in this matter is set out on page 69 of ALAB-836 where it is stated.that:
"Thus, insofar as the Spring-Ford and Owen J. Roberts School Districts are
, concerned, driver surveys raise a legitimate question whether there is reasonable assurance that an adequate number of drivers would respond in an emergency. The Licensing Board did not give adequate weight to the largely negative results of these surveys, and there is little else in the record on which to base a reasonable assurance finding." (ALAB 836,p.69-70)
The ASLB's original position was found to be in error in that"the Board's concern with how many drivers stated they would not respond, and with the lack of effort to encourage a positive response, has effectively and improperly shifted the burden of. proof on this issue from PECo to LEA. . .
that means that PECO was obligated to produce affirmative evidence of an adequato number of available drivers from some source, once the survey results substantially clouded the matter with doubt." (ALAB-836p.67-68)
The ALAB further found that " provider response is not necessarily a reliable predictor of driver response." (ALAB-836,p.65) In addition the Licensing had correctly noted that driver participation is to be a voluntary, not a mandatory condition of continued employment with the bus company (LBP 14, 21 NRC at 1321)
Page 3 i
- 4. It is clear that this Board's findings must be made in the context of the accelerated and expedited hearing schedule that was imposed by the ASLB, That is, the Licensee must still meet its burden to show affirmative evidence why the bus driver shortage does not continue to vitiate reasonable assurance that the Owen J. Roberts and Spring Ford Area School children can and will be protected in the vent of a Limerick accident necessitating evacuation once school resumes on September 3 and 4th,1986. The intervenor (LEA), who suffers certain disadvantages in the accelerated hearing process, including reduced preparation time and time'for filings, such as in these proposed findings of fact, must not have effectively the burden of proof shifted to itself, as a result of those efforts to facilitate an expedited hearing.
- LEA has caused no unnecessary delay in this set of remanded hearings, even when such delay would have been arguably within its procedural rights, i
1 l
t .
I e
4 page 4
5 Mr. Hippert of the Pennsylvania Emergency Management Agency testified at TR 21277 that using the Spring-Ford survey results, the Spring-Ford district l short fall of drivers would be 28.
6 At TR 21275 Nr flippert calculates the Owen J Roberts bus driver shortfall using the survey results and comes to a total of 8. Ilowever, it is clear I from his calculations on the record that in reaching this total Mr. liippert i is assuming that the Gross Company drivers originally surveyed would only be called upon to drive 26 of the 52 buses Dr. Claypool would needs. If this assumption were not made, Nr. Ilippert 's reasoning would yield a 34 total .
l ' ( comp 219 C17ypool TR 21344 1* F 7 On page 3 of Mr. Ilippert's prefiled written testimony, ff TR 21265, he calculates
, that if no additional drivers were available for the 52 buses the two school 1
! districts have reported as an unmet need, the unmet need for bus drivers becomes 88, i
l g Giveri that the Licensee would achre ve its full complement of 200 licensed school bus drivers by the start of school on Sept 3 and 4th 1986, that would still leave a margin of about 112 drisers. Ilowever, since only about three-quarters of the 200 are expected even by the 1.icensee by that date, l the margin falls to around 61, and it is from this margin that all pot'ential no-shows would have to be drawn, ( Bly"", TR 211P at 16 )
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g3 Furthe rn are, Mr. Ilippert's assumptions that the 0.J. Roberts unmet needs buses would come equipped with drivers not regularly employed by the Gross Bus Co. must be viewed in the light of Mr. Campbell's assertion that the up to 30 buses that could be needed to replace those 0.J. Roberts buses taken home by regular drivers and not kept at the bus company lot would be substituted for by others at the Exxon marshalling area to be available for PECo volunteer workers to drive. .(iiippert, TR 21236 at 10) gg Mr. Campbell's approach seems to differ in concept and execution from that testified to by Dr. Claypoolt which relies on an early dismissal of students back to their homes (Plan A) and only if Plan A is not possible relies on a Plan B which somehow uses 2-way radios and extra keys to insure that buses kept at home are returned to the company lot or to the school's staging areas as the evacuation unfolds. TR21322:21337 The Licensee failed to show how this would work in concert with the proposed PECo volunteer worker plan, in fact, Dr. Claypool testified that his Plan A would not be able to use these ,
PECo volunteers because of the time factor involved. ( Claypool TR 21326 at 4) 12 Unlike in the original hearings which led to the initial reasonable assurance finding, there has been put into evidence in these hearings no school district or County plans laying out these and other details.
The lack of specific written plans seems to be not incidental, but symptomatic of a lack of needed coordination and planning at the local level and with the Licensee.
Quotations and reliance upon figures and data from unofficially transmitted emergency plan drafts not entered into evidence in this remanded hearing or in the original series of hearings in 1984-1985, does not satisfy the Licensce's burden of proof.
The copy of the plan which the school district superintendents mentioned in their testimony was not entered into evidence, nor checked to see if it was the same draft copy Mr. Ilippert and F13tA had had unofficially transmitted to them for the purposes of the' 1986 drill. ( see litpp rt. Asher-Kinard.Welliver-Claypool)
Pay e
13 Surveys done in 1983 or 1984 are no longer reliable. (Welliver, TR 21343)
The Licensee however has failed to make the needed showing that the bus driver shortfall has not remained or increased since then. No showing that the shortfall has decreased has been made either. Therefore, no reasonably accurate number exists as to tne *s of regular Owen J Roberts and Spring-Ford drivers who have not volunteered and may not volunteered to drive. Thus, the regular bus drivers who would be available in a Limerick emergency remains a quantity still clouded with doubt.
l 14 The numbers of unmet needs and thus the number of replacements needed are still clonded with doubt. IImergency planners are still relying on a generalized excess Campbell TR 21239) of (resources strategy, and not the specific assignment of responsibilities envisioned in NUREG 0654 or 10 efr 54.47(b). Especia!!y since the 200 i additional volunteers offered by the Licensee are part of a pool and not specifically designated for the 2 risk schools considered on remand, and not as potential school bus drivers being provided specifically with buses.
(Reder tr 21333-4) (lloyt TR 21334 at 13) 15 The 370 other names solicited from among its employees by the Licensee are not of any probat'.ve value in this remanded issue. (Conner TR 21213)
(TR 21213 at 10-17 Iloyt,TR 21214 at 10 )
16 Additionally , the Licensee has not provided the record with any list of the workers to be part of the 200 bus driver complement, or shown that the names of them or their immediate supervisors who would contact them in the cvent of a call by the Counties for their services; are listed in any plans or l
procedures to be used as part of the Evacuation Plans.
Pa g e- 7 l
l l
17 The enrollment of the PECo volunteer workers to be licensed as school bus drivers in the Chester County and Montgomery County Emergency Management Offices has not yet ocurred. Campbell and Bigelow TR 21246 . It is ;
only at the point that they are so registered that the county wifi be ahic to Campbell-Bigelow TR 21249 at 1.8 call upon them for all emergencies including but not limited to Limerick. At-though the Counties' EMC's seem to be requesting such enrollment, the Licensee has made no showing that this will in fact occur. In fact, it was over the objections of the Licensee's attornies that the question was even asked. Thus there is still no reasonable assurance, despite the training and contact system proposed by the Licensee, that these PEco workers will in fact become part of the County Plans on a par with all other County volunteers. Anything less than such full participation and commitment by the PECo workers creates doukras to their full availability and the reasonable assurance that they will participate in County emergencies including Limerick.
18 ' Although the ALAB ruled on May6 , 1986 that the remanded issue should be addressed within the 3 4 months that school was not in session this Summer
( May, June, July, and August 1986 ), it is evident even from the Licensee's own testimony of PEco Vice- President Vince Boyer that its proposed solution to pprovide 200 licensed and qualified drivers would not be achieved by the start of school in Sept 1986 ( Boyer TR 2ilD8 a t 16 )
19 , Judge iloyt related on the record at TR 21351. that based on represen-tations made to her by County Emergency Coordinators Bigelow and Campbell that the beginning dates for school for the two school districts e at issue in this remanded proceeding was Sept 3 and 4th.
Thus, using the Licensee's own schedule as testified to by Mr. Boyer a real shortfall from the 200 driver goal would occur in the first couple of weeks of Sept.1986.
2o 200 is a number of school bus drivers in excess of the various estimates of the Owen J Roberts and Spring-Ford School District driver shortfalls as calculated using the surveys. But because of factors taken into account by Mr. Boyer of PLCo and testified to by him, that200 i number was chosen. ( Boyer, TR 21195 See LEA proposed finding 89).
Furthermore it is that 200 driver number that was offered and testified to ,
by the various parties in this case and when they found that the Licen see's proposal was adequate it was in reference to that number.
Campbell TR 21239 Ilippert TR 21267
,Th,e 200 driver figure is controlling in this matter.'3 Page 8 I
m,, . .
21 But in any event other testimony before this Board indicates that the Licensee is not even meeting Mr. Boyer's anticipated schedule. For example, at the outset of hearings on Aug. Mon. 18th, Mr. Boyer stated that 49 volunteers were scheduled to take their Class 4 license on that day. Ilowever, by the resumption of hearings on Fri. Aug 21 Mr. Boyer admitted that just 35 of the 49 scheduled had actually passed the test due to a few failures and several no shows whatever the reason. ( ff TR 21189, pg 53 TR 21296 at5 )
Likewise on Wnn the 18th Mr. Boyer was forced to revise the numbers of volunteers expected to complete varilous phases of their training and qualification downward from what his prewritten testimony had shown on Aug 11.
( Boyer TR 21186 at 10-24)
A total of 58 PECo workers who had been trained and who had passed their school bus driver license test was testified to Ey Mr. Boyer at TR 21296 at 6 Of 40 who took the test, the five who did not pass will be included in the 46 he indicated would take the test on Mon. Aug25', Boyer TR21297at6.
For Fri, the 24rd 49 were scheduled to take the test, but only 35 did and passed the test. TP 21196 at S This makes it reasonabic to asstme that of the 4r scheduled to take the test on Mon. 23:h including the 5 retests, some will not actually take the test and pass. Thus the record shows that at a time less than 10 days before the start of school on the 3rd and 4th of Sept 1986, fewer than half of the agreed to 200 driver pool had been provided by the Licensee. And those 10 days incl.a 3 day Labor Day holiday.
Problems have already arisen Nith vacations and so forth. 'Boyer T_R 21193 at tl) i Page Q ,
73 The Licensee's proposal to provide 200 of its workers as school bus driver volunteers is described by the PEMA witness as something other than a full-time or permanent solution to the reuanded issue.
( llIPPERT ff TR 21265 pg 3 4 )
24 Mr. Campbell's attitude'TR 21237-8 while refreshing in its frankness does not reflect upon the permanence or relative efficiency of this PECo volunteer plan, but rather reduces all such planning into a state of flux and change. This is p. chaps realistic as a generalized observation, but does not change the basic planning principle that at any point in time planning should be as speelfic and definite as possible with specfic responsibilities assigned to the appropriate organizations or individuals to be relied upon.
25 For instance, NUREG 0654 on pg 29 at J. states that " The plans should make clear what is to be done in an emergency, how it is to be done, and by whom. "
This hearing showed for the first time that Owen J Robrts District because of its concerns about the time of bus driver response and traffic around its schools, is relying on an early dismissal strategy (Plan A) which, as Judge lloyt ruled in sustaining the Licensee's objections to questions about this plan, is not an evacuation plan for the kind of emergencies at issue in nuclear emergencies
. of the type required to be planned for. TR 21327; LEA proposed finding 11 27 The Licensee has proposed no specific plan for transporting its PECo volunteers from the Exxon marshalling area to the up to 30 buses Kankus TR 21302 Bradshaw TR 21216 at 17 ) that 0.J. Roberts drivers may take home.
2g Though Mr. Campbell testified TR 21236 that he would not transport the PECo volunteers .to the regular 0.J. Robrts buses, no showing has been made tthat he will have the up to 30 buses that could be needed. The 3rd PID and ALAB 836 did not find that those buses were specifically available, since the plan to use outside PECo drivers was not brought forward unt il af ter those deelsions, in any event a predletive finding of bus adequacy in 1931 would not necessarily apply to those new arrangement s made only in the Summer of 1980 29 As Mr. Campbell himself said in another line of quest ioning, he could not talk about drivers without including buses Campbell TR 21244 at 14 Therefore, the Licensee has failed to make an af firmat ive showing that the specifie plans and arrangements have been made for the buses to be available.at the Exxon marshalling area for the PECO volunteers to drive, and in this narrow bus related issue, not previously litigated, the Licensee has failed to ;
ca'rry its burden of proof. . ,Page 10 i
30 All testimony as to reasonable assurance offered in this proceeding is based upon the assurances of others, with the ultimate source of these assurances being PECo, the Licensee. For example, FEhtA relies on PDIA, as well as FDIA's own"commoneense" look at what the Licensee has proposed.
( Asher-Kinard TR 21282 and 21280 ) : that is,if PECo does provide
- he 200 volunteers it claims to be going to provide, then there is reasonable assuratice that the unmet need for the 2 risk school districts can be net.
FDIA does not look at how the PECo volunteers reach usable buses (Asher-Kinard TR 21281 atl), or take into consideration the 200 list being a pool for other districts,or other matters which could be of concern ( Kinard TR 21286 at11 ). PDIA for its part relies up the stipulation that the Iicensee will implement and maintain what it has proposed it will do(Ilippert ff TR 21265 pg 3 second paragraph and TR 21267 at23 ). Neither FDIA or PDIA testify that they have gone out to check up on what the Licensee is doing to carry out the Licensce's proposal, not do they offer testimony
( that is, FBlA or PD1A) which predicts anything about whether or not the Licensee will carry out its own proposal. PEA!A relies too on the County Emergency blanagement Coordinators , but then as Str. Campbell testifies at TR 21231; he is satisfied only " provided PEco follows through with what they have co tted to. Likewise, the 2 School Superintendents I rely on what the County DIC's, PB1A and PECo communicate to them (Claypool TR21342, 21318 at 19, 21316 at 13-17; Welliver TR 21348 at 24; and even in Judge lloyt's position as to what these superintendents were able to testify to lloyt, TR 21334-7 PECo's objection sustained at 21337at 6 ) None of these planning officials testify so as to predict compliance or implementation of PECo's proposal. In fact, the Licensee has brought forth no testimony except its own a,ssertion that the proposal as offered will in fact be carried out. In fact , there is some evidence on the record that the implementation of the proposal is at least lagging behind PEco's own expectations.(LEA proposed findings of fact 16-12.)
The re fo re , a license condition enforced by this ASLB is needed to reasonably ensure that the P!ro proposal for 200 addit ional drivers which needs to be carried out for the testimony of all the emergency planning officals as to reasonable assurance to become in fact real. Only a license condition ordered by this Board can enforce compliance and check up on it. The only sanction the NRC has being, ultimately, the threat of a 1icense suspension should the Licensee fail in its obligations.
Page 11
LEA's Proposed Conclusion in the Form of a License Condition 31 Upon review and consideration of the various proposed findings of fact, this ASLB finds that, given the constraintslif schedule and topic imposed by this ASLB Board, LEA has nonetheless shown that the Licensee has failed to meet its burden of proof on the record in this remanded proceeding concerning the adequacy of school bus drivers for two risk school districts involving thousands of children of all ages, Even the Licensee admits, on the record, <
that it will not meet its proposal of 200 additional trained and licensed school bus drivers by the start of the school year on Sept 3 and 4th, 1986.
( see LEA proposed finding la ) In fact, the record in this case shows some failure to achieve the lesser goal of mid-September for compliance.
Therefore, the roster of 200 trained and licensed volunteers must either be achieved by the start of school and within the 3 to 4 months envisioned s by the Appeals Board in ALAB-836, or the Licensee has failed to carry its burden of proof with respect to these issues and reasonabic assurance remains vitiated for these two school district's children. The concept of a predictive finding being adequate has no validity in this context of a case heard on remand after more than a year of a full power license and nearly two years at low power. Nevertheless, the Licensee has not even provided the affirmative basis for a predictive finding. Furthermore, in the course of these hearings sufficient evidence was indicated by LEA to show that the Licensee has failed to meet its burden of proof with respect to the following parts of the school bus driver issue; which parts form components of the following multi-part license condition and conclusion.
Page 12.
t 32 The Director of Nuclear Reactor Regulation and FEMA is to verify
"~
the immediate and ongoing compliance with the following Limerick Operating License Conditions.
1
- 1) That the full complement of 200 PECo volunteers is trained, licensed, and enrolled by name and address and phone number at their respective County Emergency management Offices prior to the continued i operation Of the Limerick Power Station while school is in session at the two school districts considered here on remand; and i
- 2) That the Counties develop and assign sufficient buses from a specific and timely source not previously comitted to a use under the
{ Limerick Emergency Plan,in order to reasonably assure that upon arrival at
! the Berwyn or Exxon marshalling area the proposed PECo volunteers would in fact have a bus to drive schoolchildren with. A person with a Class 4
) License in his or her pocket does not become a real schoolbus driver under any l reasonable understanding of these emergency plans without the corresponding
! bus to drive. ;and 3] That the Counties and school districts immediately pursue a permanent l and longterm solution to the two school district's survery-indicated shortfall of drivers by utilizing conventional and local options,not extraordinary I and less reliable utility provided ones; and i 4)That a new set of surveys be conducted for the Owen J. Roberts and the
- Spring-Ford School Districts in order to update the unmet driver needs and i either confirm or dispel the " cloud of doubt" caused by the earlier survey I outcome ; and
{ 5) That if the 200 PECo volunteers are in fact to be used as part of a l general pool avq,ilable to any school district with a driver shortfall,that immediate steps be taken to ascertain by surveys what if any previously
) undetected busdriver needs could be expected in those schools as well 3 so that PECo as needed could voluntarily enlarge its volunteer driver pool or alternatively proceed to hearings if needed based on that new information.
Basis for the preecding proposed license conditions 1 LEA proposed findings 5-22, 30 i
2' LEA proposed findings 6, 10,24 -30 3, LEA Proposed findings 23 301 4 LEA proposed findings 13, 14, 20 ,
j 5' LEA prposed findings 14, 24 , 30
- Page 13 i
~
a 00LMETLD USNPC
) UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '86 SEP -2 All :29 In the Matter of ) OC fifNG pylft'
) ORANC6i Philadelphia Electric Company ) Docket Nos. 50-352
) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I
I hereby certify that copies of IEA's Proposed Findings of Fact and Conclusions of Law regarding bus driver availability have beer. delivered
{ by hand and by first class mail on August 29, 1986.
i
- Helen F. . Iloyt , Esq. 4 Atomic Safety and Licensing Chairperson Appeal Panel
- g Atomic Safety and U.S. Nuclear Regulatory
/ Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dockating and Service Section
- Dr. Richard F. Cole U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory
- Conmission Benjamin H. Vogler, Jr. Esq.
! Washington, D.C. 20555 Counsel for NRC Staff Office of the Executive
- Dr. Jerry !! arbour Legal Director Atomic Safety and U.S. Nuclear Regulatory Licensing Board commission
- U.S. Nuclear Regulatory Washington, D.C. 20555 t Commission Washington, D.C. 20555
" Troy B. Corvur, Jr. isact.
- Iland deliver'/ hit J. Wettettmhn, Esci.
Cotuer a 'lettets
. wa a, 1747 Pennsylvania Avenue, N.W.
Washington, D.C. 20006
)
Atomic Safety and Licensing Angus Love, Esq.
g Board Panel 107 East Main Street i q( U.S. Nuclear Regulatory Norristown, PA 19401 Commission
' Washington, D.C. 20555 Robert J. Sugarman, Esq.
Sugarman, Denworth &
Philadelphia Electric Company Hellegers 16th Floor, Center Plaza ph ATTN: Edward G. Bauer, Jr.
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 aldg.
15th and JFK Blvd.
Charles W. Elliott, Esq. Philadelphia, PA 19107 325 N. 10th Street Easton, PA 18064 >{$SpenceW. Perry, Esq.
Michael B. Hirsch, Esq. I
); Associate General Counsel Limerick Ecology Action Federal Emergency P.O. Box 761 Management Agency 762 Queen Street 500 C Street, S.W. ;
Pottstown, PA 19464 Room 840 (
Washington, DC 20472 Mark L. Goodwin, Esq. .
Office of General Counsel Thomas Gerusky, Director Commonwealth of Pennsylvania Bureau of Radiation P.O. Box 11775 Protection Harrisburg, PA 17108 Department of Environmental Resources Jay M. Gutierrez, Esq. 5th Floor U.S. Nuclear Regulatory Fulton Bank Bldg.
Commission Third and Locust Streets 631 Park Avenue ,
Harrisburg, PA 17120 19406 King of Prussia, PA I
/l 3-William A. Welliver, Ed.D.
c/ James Wiggins Senior Resident Inspector Superintendent
} U.S. Nuclear Regulatory Spring-Ford Area School Commission District P.O. Box 47 199 Bechtel Road 19464 Collegeville, PA 19426 Sanatoga, PA Col. Ralph liippert Pennsylvania Emergency Mar.agement Agency B151 - Transportation and Safety Buildinn
!!arrisburg, PA 7120 Thcodore G. Otto, Esq.
Department of Corrections Office of Chief Counsel P.O. Dox 598 Lisburn Road Camp !!ill, PA 17011 Timothy R.S. Campbell Director Department of Emergency Services 14 East Diddle Street West Chester, PA 19280
- 1, A. Lindicy Bigelow Coordinator of Emergency Pruparedness Montgomery County '
50 Eagleville Road Eagleville, PA 19403 Roy C. Claypool, Ed.D.
District Superintendent Owen J. Roberts School District Administration Building P.D. 1 Pottstown, PA 19464 h .' Ob :
~* / )L k W l % { }$st thVD
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1