ML20212P542
| ML20212P542 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/29/1986 |
| From: | Vogler B NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| References | |
| CON-#386-560 OL, NUDOCS 8609030176 | |
| Download: ML20212P542 (19) | |
Text
'
st,o 00LKETE UstlRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '86 SEP -2 M1 :25 BEFORE THE ATOMIC SAFETY AND LICENSING;JROARDg x ;n y 00CKETING & blHVICI.
BRANCH In the Matter of
)
)
/
PHILADELPHIA ELECTRIC COMPANY
)
Docket Nos. 50-352 [b
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
NRC STAFF'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION RELATING TO THE REMANDED ISSUE REGARDING THE AVAILABILITY OF SCHOOL BUS DRIVERS FOR THE OWEN J. ROBERTS AND SPRING-FORD SCHOOL DISTRICTS The NRC staff, pursuant to 10 C.F.R.
I 2.754, and this Licensing Board's Order of July 21, 1986 as supplemented at the hearing herein on August 22, 1986 (Tr. 21.351) hereby transmits its Proposed Findings of Fact and Conclusions of Law in the form of a partial initial decision as styled above.
Respectfully submitted,
/
Benjamin H. Vogler Senior Supervisory Trial Attorney Dated at Bethesda, Maryland this 29th day of August,1986
/DESIGHTEDORIGINAIJJ Certiffed By M g 7 gg-gr 186M 8888)ha G
UNITED STATES OF AMERICA
~ -
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PHILADELPIIIA ELECTRIC COMPANY
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
NRC STAFF'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION RELATING TO THE REMANDED ISSUE REGARDING THE AVAILABILITY OF SCHOOL BUS DRIVERS FOR TIIE OWEN J. ROBERTS AND SPRING-FORD SCHOOL DISTRICTS Benjamin H. Vogler Senior Supervisory Trial Attorney August 29, 1986
Q UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES:
Helen F. Hoyt, Chairperson Dr. Richard F. Cole Dr. Jerry Harbour In the Matter of
)
)
PIIILADELPHIA ELECIRIC 03PANY
)
Docket Nos. 50-152-00
)
50-:iS3-CL (Limerick Generating Station,
)
Units 1 and 2)
)
)
August 29, 1986 i
APPEARANCES Troy B. Conner, Jr., Esq., Robert M. Rader, Esq., and Nils N.
Nichols, Esq., of Conner & Wetterhahn, P.C., Washington, D.C. for Philadelphia Electric Company.
Benjamin H. Vogler, Esq., Office of the General Counsel, U.S. Nuclear Regulatory Commission, Washington, D.C., for the NRC Staff.
Mark L.
Goodwin, Esq.
Pennsylvania Emergency Management Agency, Harrisburg, Pennsylvania, for the Commonwealth of Pennsylvania.
Michael Hirsch, Esq., Office of the General Counsel, Federal Emergency Management Agency, Washington, D.C., for FEMA.
Maureen Mulligan and David Stone, for Limerick Ecology Action.
f i
r,,y---
._--.,-m.-
_-..__.--,--,v,_.__
UNITED STATES OF AMERICA
~ -'
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PIIILADELPIIIA ELECTRIC COMPANY
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
NRC STAFF'S PROPOSED FINDINGS Ol' FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION RELATING TO TIIE REMANDED ISSUE REGARDING Tile AVAILABILITY OF SCHOOL BUS DRIVERS FOR Tile OWEN J. ROBERTS AND SPRING-FORD SCHOOL DISTRICTS I.
SCOPE OF DECISION This Partial Initial Decision (PID) addresses the remanded issue of the availability of school bus drivers for the Owen J.
Roberts and Spring-Ford School Districts in the event an emergency at the Limerick Generating Station (LGS) requires the evacuation of these two School Dis-tricts.
On the basis of the record before it, the Board concludes that there is a reasonable assurance of a sufficient number of school bus driv-ers willing to respond during an emergency at the Limerick Generating Station which requires the evacuation of the Owen J.
Roberts and Spring-Ford School Districts, l
j
II.
BACKGROUND On May 7 1986, the Atomic Safety and Licensing Appeal Board (Ap-peal Board) in ALAB-836 U rejected this Licensing Board's conclusion in its Third Partial Initial Decision that there was reasonable assurance of a sufficient number of school bus drivers willing to respond in the event an emergency at Limerick required the evacuation of the Owen J. Roberts and Spring-Ford School Districts. U The Appeal Board found that the Licensing Board's conclusions in this regard were not supported by the record.
ALAB-836 slip op, at 70-72.
Accordingly, the Appeal Board reversed and remanded this one issue to the Licensing Board for further proceedings.
_I d.
Pursuant to this Board's Order of May 22, 1986 the Licensee on June 16, 1986, submitted a proposal for the resolution of the remanded issue.
On June 27, 1986 in response to concerns expressed by the Penn-sylvania Emergency Management Agency (PEMA), the Licensee amended its proposal. U The Licensee's amended proposal (hereinafter Proposal) consists of an affidavit from an official of the Licensee indicating that Philadciphia Electric Co. (PECo) employees have volunteered to serve as bus drivers in the event of an emergency at LGS, and affidavits from emergency preparedness officials of Chester County and Montgomery County, Pennsylvania.
The emergency preparedness officials each ad-
-1/
Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), ALAB-836, 23 NRC
, (May 7,1986).
2/
Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), LBP-85-14, 21 NRC 1219 (1985).
3/
See, Letters dated June 27, 1986, from Counsel for Licensee to the Eensing Board and to Ralph J. Hippert, PEMA.
~
vised that they have reviewed the Licensee's proposal and stated that they are satisfied that it will provide sufficient bus drivers in the event an emergency at the LGS requires an evacuation of the two school dis-tricts.
The Licensee requested that the parties sign a stipulation that its j
proposed resolution would satisfy the Appeal Board's remand.
On July 1, 1986, the Commonwealth of Pennsylvania concluded that the Licensee's Proposal resolved the matter and signed the proposed stip-ulation.
On July 10, 1986 LEA, in its response to the proposed stipula-tion, objected to the Proposal and requested that it be permitted to conduct discovery and to participate in an adjudicatory hearing on the matter.
On July 17, 1986, the Staff responded that in its view the Li-censee's Proposal complied with the May 22, 1986 Order of the Licensing i
l Board and provided sufficient information for the Licensing Board to con-clude that there is reasonable assurance that an adequate number of bus drivers will be available in the event an evacuation is necessary at the Owen J.
Roberts and Spring-Ford School Districts.
Nevertheless, the Staff advised that LEA's request for an adjudicatory hearing should be granted because LEA had placed an issue in controversy that needed to be resolved in an evidentiary hearing, b On August 11, 1986, prefiled testimony in support of its Proposal was filed by the Licensee.
Additional testimony in support of Licensee's Proposal was filed by PEMA and FEMA. No testimony was filed in opposi-tion to Licensee's Proposal.
4/
See, Response of NRC Staff to Licensees Proposal For Resolution of Einanded Issue Regarding the Availability of School Bus Drivers for
~
the Owen J.
Roberts and Spring-Ford School Districts, July 17, 1986.
i
,----.-_m-m-
,,-.n
-..e-
~ - -,
i Hearings were held in Philadelphia, Pennsylvania on August 18 and 22, 1986 A total of eight witnesses presented testimony on August 18, 1986, and two witnesses presented testimony on August 22, 1986.
All of the witnesses were cross-examined by LEA.
The following witnesses testified on behalf of the Licensee on August 18, 1986:
Vincent S. Boyer, Vice President, PECo; Robert Bradshaw, Project Man-ager. Schneider EC Management Planning and Services; and Roberta A.
- Kankus, Director, Emergency Preparedness
- Section, PECo.
l Timothy R. S.
Campbell, Director, Department of Emergency Services,
}
County of Chester, Pennsylvania and A. Lindley Bigelow, Coordinator of Emergency Preparedness, Montgomery County, Pennsylvania testified for their respective counties.
Ralph J. Hippert, Director, ' Office of Plans and Preparedness, Pennsylvania Emergency Management Agency, Common-wealth of Pennsylvania, testified for PEMA.
James R.
Asher and l
Richard Z. Kinard testified on behalf of the Federal Emergency Manage-ment Agency (FEMA). The testimony of all of the above witnesses in this remanded proceeding supported the Licensee's proposal to resolve the i
Appeal Botrd's concern over the possible inadequacy of school bus driv-ers for the two school districts in the event of an emergency at LGS.
g On August 22, 1986, Dr. Roy C. Claypool, District Superintendent, Owen J. Roberts School District and Dr. William A. Welliver, Superinten-dent, Spring-Ford Area School District, testified on behalf of their re-j spective School Districts.
Both of the witnesses, who were subpoenaed by LEA, commented favorably on the Licensee's proposal.
l The Board has considered all of the proposed findings of fact and i
conclusions of law presented by the parties.
Those not incorporated di-rectly or inferentially in this PID are rejected as unsupported by fact or i
law or as unnecessary to the rendering of this PID.
Therefore, as dis-cussed in detail below, this Board finds that the Licensee's proposal sat-isfies the Appeal Board's remanded issue in that there will be a sufficient number of school bus drivers available for the Owen J.
Roberts and Spring-Ford School Districts in the event an emergency at LGS requires the evacuation of the two school districts.
III. FINDINGS OF FACT 1.
Plans to evacuate these two school districts are just two aspects of the overall efforts by Commonwealth, county and local officials, assist-ed by Licensee, Philadelphia Electric Company, and its consultants, to maintain adequate emergency planning and preparedness for the Limerick Generating Station.
(Boyer and Bradshaw, ff. Tr. 21,189 at 1.)
2.
Since the close of the record relating to the offsite emergency planning phase of the proceeding, Licensee has continued to cooperate with Commonwealth, county and local officials in developing additional emergency response resources for all aspects of planning and prepared-ness.
These efforts have included the enlistment of Licensee's employees who have stated a willingness to participate as volunteers in implementing various aspects of the offsite plans.
( d. at 2.)
3.
Following the Appeal Board's remand in ALAB-836, as to wheth-er an adequate number of drivers would be available for the Spring-Ford and Owen J.
Roberts School Districts, the Licensee's representatives discussed how to resolve the remanded issue with the responsible county and Commonwealth officials. At a meeting on June 5,1986 with Licensee's representatives, Timothy R. S. Campbell, Director of the Chester County Department of Emergency Services, and A. Lindley Bigelow, Coordinator
of the Montgomery County Office of Emergency Preparedness, determined that an immediate solution would be for volunteer Licensee employees to qualify and act as drivers until the counties have obtained drivers from other sources.
(Id. at 2-3).
4.
Mr. Campbell decided that the designated marshalling center for volunteers to drive buses for Chester County would be in the Exton area at the Exxon Systems facility in Lionville.
Mr. Bigelow decided that the designated marshalling center for Montgomery County would be the Li-censee's Berwyn Transportation Center.
The matter was then discussed with Ralph J. Hippert, Director of Plans and Preparedness, Pennsylvania Emergency Management Agency, who agreed to the proposal as an immedi-ate solution.
(Id. at 2-3.)
5.
In Pennsylvania, a Class 4 driver's license is required for op-eration of a school bus.
There are three prerequisites for obtaining a Pennsylvania Class 4 license:
(1) possession of a Class 4 learner's per-mit, which requires passing a physical examination; (2) classroom and vehicle training; and (3) passing a driver's examination administered by the State Police.
(Id. at 3. )
d 6.
The Licensee collated a list of volunteer employees who could respond to bus marshalling centers within a reasonable period. This pro-cess resulted in approximately 570 volunteer employees being identified.
Each volunteer was asked to execute a volunteer sheet and the supervisors of the volunteers were asked to estimate how long it would take the volunteers to reach the marshalling centers based upon their knowledge of their personnel's work locations.
(Id. at 3-4.)
7.
Based upon Licensee's desire to resolve the remanded bus driv-er issue without the need for further hearings, Licensee proposed to 4
=
make the 570 identified employee volunteers available to Chester and Montgomery Counties as needed under their plans. After intervenor Lim-erick Ecology Action rejected the proposal, Licensee conferred with the Commonwealth, Chester and Montgomery counties and the Federal Emer-gency Management Agency to reassess the number of volunteers actually needed.
Based upon these meetings the responsible planning agencies determined that a total of 200 employee volunteers, to be used by both Montgomery and Chester County, would be more than sufficient to meet any anticipated need for the Owen J.
Roberts and Spring-Ford School Districts.
The Licensee then selected 200 employee volunteers from its collated list.
The names of thie remaining volunteer employees is being maintained on file so that if they are needed as replacements for those i
already trained, they can be made available.
(Id. at 4.)
8.
Licensee has coordinated its bus driver employee efforts with the Chester County Department of Emergency Services and the Montgom-ery County Office of Emergency Preparedness.
Both counties have agreed to the program for the use of Licensee's employee volunteers to 2
receive driver training and respond in the event of a radiological emer-gency at LGS.
(Id. at 4-5. )
9.
The schedule for training and testing is as follows: two groups totaling 54 volunteers completed training August 8, 1986; two other groups totaling 47 completed training on August 15, 1986; four other groups totaling 66 will complete training in August 1986; and the remain-der totaling 33 will complete training in September 1986, subject to possi-ble unavailability due to illness or other reason.
Driver testing sessions were conducted by the State Police on August 11,1986 and 23 volunteers were issued Class 4 licenses.
Forty-nine volunteers are scheduled for
driver testing on August 18, 1986. Driver testing will continue into Sep-
~
tember as classroom training is completed.
( d. at 5.)
It is anticipated that approximately three quarters of the 200 volunteers will be qualified before the start of school in the Fall of 1986.
Licensee further expects that all 200 volunteers will be qualifted by mid-September 1986.
(Boyer, Tr. 21,217).
10.
Since the 200 volunteers could be used for either Chester or I
Montgomery County, Licensee has developed estimates of the time required for the volunteers to report to both Exxon and Berwyn.
Licensee has determined that 55 could reach Exxon in 30 minutes or less; an additional 111 within 30 to 60 minutes and 34 more within 60 to 90 minutes.
For Berwyn, 148 would be available in 30 minutes or less; an additional 27 within 30 to 60 minutes and 25 within 90 minutes. Fifty-five are regular-ly stationed at Berwyn and would therefore be immediately available.
(Boyer, Bradshaw, ff. Tr. 21,198 at 6.)
11.
Licensee has committed to Montgomery and Chester Counties that it will make its bus driver employee volunteers available under the arrangements discussed above until provision is made by the responsible planning authorities for bus driver personnel from other sources.
Ac-cordingly, Licensee's arrangements will remain in full force and effect until notification that Licensee's employee volunteers are no longer re-quired.
(Id. at 6.)
- 12. With respect to maintaining the level of volunteer bus drivers at the 200 level, the Licensee testified that approximately 220 volunteers will be on the list and that it plans to maintain that level so that volunteers will be available as people are transferred, retired, etc.
(Boyer, Tr. 21,212).
When the total number of volunteers drops below 205, the
i Licensee 'will seek more volunteers in order to maintain an adequate re-serve.
(Boyer, Tr. 21,220).
The Licensee will maintain the list of vol-I unteers and initiate action to obtain additional drivers to maintain reserves (Boyer, Tr. 21,223).
PECo's list of volunteers for offsite emer-T gency plans is updated on an annual basis and the Licensee will probably follow the same annual schedule for its volunteer bus driver list.
(Kankus, Tr. 21,224).
The Licensee is prepared to assume the above l
responsibilities ad infinitum.
(Boyer, Tr. 21,227).
13.
Based on the foregoing, there will be more than enough volun-l teer bus drivers to provide support to the Chester County and Montgom-ery County emergency planning agencies as needed for the Owen J.
Roberts and Spring-Ford School Districts in the event regularly assigned drivers fall to respond.
(Boyer, Bradshaw, ff. Tr. 21,189 at 6-7.)
i
- 14. Timothy R. S.
Campbell, Director, Department of Emergency j
Services Chester County Pennsylvania and A. Lindley Bigelow, Coordina-tor of Emergency Preparedness, Montgomery County, Pet.nsylvania, testi-fled as a panel on behalf of the Licensee.
Both individuals testified that they had been consulted by the Licensee concerning its proposal for 200 PECo volunteer drivers to resolve the bus driver availability problem in j
i their respective counties, had discussions with PEMA concerning the pro-posal and that they were satisfied that the Licensee's proposal resolved the situation described in ALAB-836.
(Campbell-Bigelow.
l Tr. 21,229-233).
- 15. Both Mr. Campbell and Mr. Bigelow stated that had there been I
a need for volunteer bus drivers in their respective counties between the period Limerick had gone on line and the present time, they would have l
been able to draw on county resources to supply buses and drivers to f
the Owen J.
Roberts and Spring-Ford School Districts as necessary.
(Campbell hligelow, Tr. 21,262-263).
~
16.
Ralph J.
Hippert, Director of Plans and Preparedness for PEMA testified that while the validity of the Spring-Ford driver survey, wherein more than 50 percent of those contacted failed to respond or were uncertain, is indeed debatable, 13 individuals did agree to drive in the event of a radiological emergency (ALAB-836, page 68).
Based upon the Spring-Ford Plan and the School District survey, there is a shortage of 28 drivers for the Spring-Ford buses.
Based upon Dr. Claypool's con-servative interpretation of his survey of 43 Gross Bus Company drivers, for the Owen J.
Roberts School District, 18 would be available to drive buses if an evacuation became necessary (ALAB-836, page 66).
This leaves a shortage of 8 drivers for the normal complement of 26 buses pro-vided to the Owen J. Roberts School District.
Using only the two survey results detailed above, there would be a shortage of 36 drivers for the 67 buses routinely provided by the two bus companies for these two School Districts.
(Hippert, ff. Tr. 21,265 at 1-2.)
17.
Licensee's proposal for the establishment and maintenance of a pool of 200 employees of the Licensee to be trained and licensed as school bus drivers is acceptable to PEMA.
This reduction is still over five times the driver shortage identified by the two school districts for the 67 buses normally provided each school day by the Custer and Gross Bus Compa-nies.
Even assuming a worse case situation, wherein no drivers were available and the total shortage would be 88 bus drivers, the pool of 200 drivers is still over twice the number of drivers needed.
(Id. at 2-3.)
18.
Based on the foregoing, PEMA is satisfled that the Licensee's proposal is more than adequate to assure that sufficient bus drivers will
be available to evacuate both the Owen J.
Roberts and Spring-Ford School Districts in the event an accident at Limerick requires such an evacuation.
(Hippert, Tr. 21,267).
- 19. FEMA believes that the proposed procedures offered by the Licensee and agreed to by PEMA provides reasonable assurance that, in the event of an emergency at the Limerick Generating Station, an ade-quate number of volunteers will be available to fill the unmet needs for bus drivers in the Owen J. Roberts and Spring-Ford School Districts.
(Asher and Kinard, ff. Tr. 21,279).
20.
While the witnesses who testified on behalf of PEMA and FEMA disagreed, to a limited extent, in their analysis of the number of unmet bus driver needs for the two School Districts because of differences in the various surveys, all of the PEMA and FEMA witnesses testified that the Licensee's Proposal more than satisfied any reported unmet bus driver needs.
(Ilippert, Tr. 21,267; Asher, Kinard, ff. Tr. 21,279 at 4).
In fact FEMA indicated that while the Licensee's proposal provides a ratio of four volunteer drivers for every potential unmet bus driver need, FEMA would be satisfied with a one-to-one ratio between bus driver volunteers and any unmet bus driver needs.
(Kinard, Tr. 21,284).
21.
Dr. Roy C. Claypool, District Superintendent, Owen J. Roberts School District, Chester County, Pennsylvania, testified that the School District's emergency plan indicates a shortage of bus drivers.
(Claypool, Tr. 21,312).
Dr. William A. Welliver, Superintendent, Spring-Ford Area School District, Montgomery County, Pennsylvania also advised that his School District's plans indicated a shortage of bus drivers.
(Welliver, Tr. 21,312-313).
However, both witnesses stated that they have dis-cussed their bus driver surveys with their county emergency planning
representatives and have been advised that in the event of an emergency requiring an evacuation of their School Districts their unmet bus driver needs will be satisfied by their respective counties.
(Claypool, Tr. 21,316; Welliver, Tr. 21,318).
Neither witness expressed any reser-vations about the use by their respective counties of Licensee's volunteer bus drivers to meet their needs provided they were properly licensed by the State of Pennsylvania.
(Claypool-Welliver, Tr. 21,321).
22.
Both Dr. Claypool and Dr. Welliver testified that they were reasonably satisfied that in the event an emergency at Limerick required the evacuation of their students there would be a sufficient number of bus drivers available to carry out the evacuation.
(Claypool-Welliver, Tr. 21,348-349).
Conclusion 23.
Based on the evidentiary record before us, this Board has rea-sonable assurance that there is a suffielent number of school bus drivers available to respond in the event a radiological emergency at the Limerick Generating Station requires an evacuation of the Owen J. Roberts and Spring-Ford School Districts.
IV.
CONCLUSIONS OF LAW In reaching this decision, the Board has considered all the evidence of the parties and the entire record of this proceeding on the remanded issue including all proposed findings of fact and conclusions of law pre-sented by the parties.
Based upon a review of that record and the fore-going Findings of Fact, which are supported by reliable, probative and substantial evidence, the Board, with respect to the remanded issue in
controversy before us, reaches the following conclusion pursuant to 10 C.F.R. I 2.760s:
The Licensee's Proposal provides reasonable assurance that an ade-quate number of school bus drivers will be available to drive buses in the event an emergency at LGS requires the evacuation of the l
Owen J. Roberts and Spring-Ford School Districts, i
j V.
ORDER WHEREFORE, in accordance with the Atomic Energy Act of 1954, as amended, and the Rules of Practice of the Commission, and based on the foregoing Findings of Fact and Conclusions of Law, IT IS ORDERED that:
Pursuant to 10 C.F.R. I 2.760(a) of the Commission's Rules of Prac-tice, this Partial Initial Decision will constitute the final decision of the Commission forty-five (45) days from the date of issuance, un-less an appeal is taken in accordance with 10.C.F.R. I 2.762 or the Commission directs otherwise.
See also 10 C.F.R. Il 2.764, 2.785 and 2.786.
Any party may take an appeal from this decision by filing a Notice of Appeal within ten (10) days after the service of this decision.
Each appellant must file a brief supporting its position on appeal i
within thirty (30) days after filing its Notice of Appeal (forty (40) days if the Staff is the appellant). Within thirty (30) days after the period had expired for the filing and service of the briefs of all appellants (forty (40) days in the case of the Staff), a party who is not an appellant may file a brief in support of or in opposition to the appeal of any other party.
A responding party shall file a 4
single, responsive brief regardless of the number of appellant briefs filed.
See 10 C.F.R. I 2.762(c).
71E A'IG1IC SAFE 1Y AND LICD? SING BOARD Helen F. Hoyt, G airperson AININISTRATIVE Jt0GE Richard F. Cole AININISTRATIVE Jt0G j
t Jerry Harbour A211NISTRATIVE J10GE Dated at Bethesda, Shryland this day of
, 1986 1
00LKETED USNPC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION "o6 SEP -2 N1 :25 I
BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 9FFICE 0.5
'. tat !m 00CKETmG & SEPylCL BRANCH In the Matter of
)
)
PHILADELPHIA ELECTRIC COMPANY
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
l Units 1 and 2)
)
CERTIFICATE OF SERVICE l
l I hereby certify that copies of "NRC STAFF'S PROPOSED FINDINGS OF l
l FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL l
DECISION RELATING TO THE REMANDED' ISSUE REGARDING THE i
AVAILABILITY OF SCHOOL BUS DRIVERS FOR THE OWEN J. ROBERTS AND SPRING-FORD SCHOOL DISTRICTS" in the above-captioned proceed-ing have been served on the following by deposit in the United States mail,- first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by a double asterisk by use of hand-delivery, this 29th day of August, 1986:
Helen F. Hoyt, Chairperson (2)
Mr. Edward G. Bauer, Jr.
Administrative Judge Vice President a General Counsel Atomic Safety and Licensing Board Panel Philadelphia Electric Company U.S. Nuclear Regulatory Commission 2301 Market Street Washington, D.C.
20555**
Philadelphia, PA 19101 l
Dr. Richard F. Cole Troy B. Conner, Jr., Esq.
Administrative Judge Mark J. Wetterhahn, Esq.
I Atomic Safety and Licensing Board Panel Conner and Wetterhahn U.S.' Nuclear Regulatory Commission 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20555**
Washington, D.C.
20006 Dr. Jerry Harbour Ms. Phyllis Zitzer, President Administrative Judge Ms. Maureen Mulligan Atomic Safety and Licensing Board Panel Limerick Ecology Action U.S. Nuclear Regulatory Commission 762 Queen Street Washington, D.C.
20555**
Pottstown, PA 19464 Mr. Frank R. Romano Charles E. Rainey, Jr., Esq.
Air and Water Pollution Patrol Chief Assistant City Solicitor 61 Forest Avenue Law Department, City of Philadelphia Ambler, PA 19002 One Reading Center 1101 Market Street, 5th Floor Philadelphia, PA 19107
Thomas Gerusky, Director Barry M. Hartman Bureau of ' Radiation Protection Governor's Energy Council Dept. of Environmental Resources P.O. Box 8010 5th Floor, Fulton Bank Building 300 N. 2nd Street Third and Locust Streets Harrisburg, PA 17105 Harrisburg, PA 17120 Spence W. Perry, Esq.
Director Associate General Counsel Pennsylvania Emergency Management Federal Emergency Management Agency Agency Room 840 Basement, Transportation & Safety 500 C Street, S.W.
I Building Washington, D.C.
20472 Harrisburg, PA 17120 Robert L. Anthony Gene Kelly Friends of the Earth of the Senior Resident Inspector Delaware Valley U.S. Nuclear Regulatory Commission 103 Vernon Lane, Box 186 P.O. Box 47 Moylan, PA 19065 Sanatoga, PA 19464 Atomic Safety and Licensing Timothy R. S. Campbell, Director Board Panel Department of Emergency Services U.S. Nuclear Regulatory Commission 14 East Biddle Street Washington, D.C.
20555*
West Chester, PA 19380 Atomic Safety and Licensing Appeal David Wersan Board Panel (8)
Consumer Advocate U.S. Nuclear Regulatory Commission Office of Attorney General Wcshington, D.C.
20555*
1425 Strawberry Square Harrisburg, PA 17120 Docketing and Service Section Office of the Secretary Jay Gutierrez U.S. Nuclear Regulatory Commission Regional Counsel Washington, D.C.
20555*
USNRC, Region I 631 Park Avenue Angus R. Love, Esq.
King of Prussia, PA 19406 Montgomery County Legal Aid 107 East Main Street Theodore G. Otto, III Norristown, PA 19401 Chief Counsel Pennsylvania Dept. of Corrections P. O. Box 596 Camp Hill, PA 17011
/hy9 G
tm Benjamin H. Vogler Senior Supervisory Trial Attorney