ML20101K826

Informs of Schedule for Addl Limerick Ecology Action Witnesses to Be Called to Testify on 850102,03 & 04 When Hearings Resume in Philadelphia,Pa.Related Correspondence

ML20101K826
Person / Time
Site:	Limerick
Issue date:	12/28/1984
From:	Zitzer P LIMERICK ECOLOGY ACTION, INC.
To:	Cole R, Harbour J, Hoyt H Atomic Safety and Licensing Board Panel
Shared Package
ML20101K828	List: ML20101K826 ML20101K868
References
CON-#185-877 OL, NUDOCS 8501020043
Download: ML20101K826 (4)

Text

y- Rwamansmoence LEA timerick Ecology Action BOX 761 POTTSTOWN PA 19464 (215) 326-9122 y rg Helen F. Hoyt, Chairperson '

Dr. Richard F. Cole, Administrative Judge Dr. Jerry Harbour, Administrative Judge Atomic Safety'and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE: Limerick Generating Station Docket Nos. 50-352, 50-353 o t, Dec. 28, 1984

Dear Administrative Judges,

Limerick Ecology Action hereby informs the parties to the above captioned proceeding of the schedule for additional LEA witnesses to be called to testify on Jan. 2, 3, and 4, when the hearings resume in Philadelphia. LEA has discussed this matter with Mr. Rader, counsel for Philadelphia Electric Co., and Zori Ferkin, counsel for PEMA. Mr. Hassell, counsel for the NRC Staff was not reached directly at his office today, and will be called Monday Dec. 31 to insure that he has received this information. FEMA and the Board will also be contacted on Dec. 31 to verify that this information has been received.

LEA discussed with Mr. Rader and Ms. Ferkin the possibility of the following stipulations:

Dr. William Wescott, letter of Nov. 20, 1984 to Montgomery County Commissioner Rita C. Banning (attached to schedule)

Mr. Anthony D'Alonzo, Ashbourne Transportation, Inc.(being prepared)

Mr. Martin Javage, Carol Lines, Inc. (proposed stipulation being prepared)

The parties will be cont' acted about this on Dec. 31 and will be updated on the progress made by Jan. 2, 1985.

LEA also informed Mr. Rader of its plans to try to present stipulated testimony from the following:

Mr. Anthony Newman, PSEA's general counsel (relating to portions struck from testimony of Donald Morabito)

Jim Brown, Chairperson, Methacton School District Emergency Evacuation Committee (regarding survey results from bus drivers and school staff indicating unmet needs)

Michael Churchill, designated emergency coordinator for Charlestown Play House, Inc. (Charlestown Twp.)

Alice Sprague, Director of Little People Day Care School (Pottstown) 0501020043 841220 e J PDR ADOCK 05000352 O PDR - " -

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ItEuu LL w .a M LBC&

A LEA timerick Ecology Action BOX 761 POTTSTOWN , PA 19464 (215) 326-9122 l'O TP NOTE: Hearings will be held at the Old Federal Building, 9th. & Market Sts. ,

in Philadelphia in courtroom #6 ;_ .

LEA WITNESS LIST FOR THE WEEK OF JAN. 2, 1985 Jan. 2 (Wed'.) 12:00 noon to 6:00 p.m.

Sandra Hurst, Director Upattinas School Open Community Corp. (pre-filed testimony)

Dr. Paul Beck, Superintendent Upper Moreland School District (subpoenaed bus provider)

Mr. Frank Wilson, Assistant General Manager of Operations Southeastern Pennsylvania Transportation Authority (SEPTA)

, (subpoenaed bus provider)

Dr. Thomas Davis, Superintendent Springfield Twp. School District (subpoenaed bus provider)

Mr. Ed Van Artsdalen, owner l Van Trans, Inc. (subpoenaed bus provider) 1 l Jan. 3 (Thurs.) 9:00 a.m. to 5:00 p.m.

1 Roger Tauss, President (represents SEPTA bus drivers) i Transport Workers Union of Phila., Local #234 (subpoenaed witness) l l

Ilona Seidel, Director (Pottstown Center)

Day Care Association of Montgomery County, Inc. (pre-filed testimony)

Dr. William Wescott, Superintendent Perkiomen Valley School District (** stipula t ion o f fered'- see attached letter of Nov. 20, 1984)

Edward Stokes, Superintendent Hatboro--Horsham School District (subpoenaed bus provider)

Mr. Ronald Wagenmann, Upper Merion Township Manager (LEA-24)

(subpoenaed witness)

Jan. 4 (Fri.) 9:00 a.m. _to 2_:00 p.m. _

(THESE WITNESSES SUBJf.Ci TO l:0ARD APPROVAL)

Mr. Anthony D'Alonzo, Ashbourne Transportation, Inc. (** <tipulatinn b"ino Mr. Martin Javage, Carol Lines, Inc. (**)

Anthony Newman, General Counsel pSEA worim! on)

Jim Brown Chairperson, Methacton School Distrirt I e m ne 'u 1 inn ! m . 'ti Michael Churchill, Charlestown Play House, Inc.

Alice Sprague Director, Little People Day Care 'nhool THIS COMPLETES LEA'S WITilESSES ON CONTENTI0llS_kL k 11.12,.lJ,ld.lb,U o26-2H_ _ _ _ _ _ _ _ _ _ - - _

y ,.

PHONE (215) 287 7861 v.

Perkiomen Valley School District SCHWENKSVILLE, PENNSYLVANIA 'I9473 w g,g g

'Where the accent is on exrefleven November 20, 1984 "'

wiLUAM 0. WESTCOTT Ed. D. i -

Gioerintendsat ,

/

Commissioner Rita C. Banning I f f G)'/ "8) {'*

(' f twouas e. mu. m. Montgomery County Court House j~' ~ ~ ' " ~ '

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,,, Norristown, PA 19404 " " ~ '

Dear Commissioner Banning:

• "a'"""*"

In response to your setter of November 15, 1984, it appears that you are asking two questions: '

1. The first question deals with the Perkiomen Valley School District's commitment tb supply the number of buses, vans, and other vehicles

'"*",," '1"

• indicated in your letter.

To this question, the answer is "yes", we are prepared to commit the number of vehicles indicated.

2. Your second question indicated, by implication, that we were guaranteeing drivers for these vehicles.

Nowhere is our plan did we ever indicate that there will be a guarantee of drivers.

Our drivers hafe had the in-service training and we expect them to respond; but, I would never place myself in the position of guaranteeing that all drivers would show up in an actual emergency situation. I don't think that anyone could make such a guarantee.

In the drill that we participated in on November 20th, one of the items that we wanted to test was the availability of drivers. With our vehicles, we also deal with two contractors who supply buses. In total there are fif ty-two drivers involved. All of them are part-time and have other jobs or home responsibilities.

In the drill on November 20th, we attempted to reach all fif ty-two drivers.

Fourteen (14) drivers could not be reached by telephone and three (3) refused to participate in an evacuation exercise.

We would assume that in a real emergency some of the fourteen drivers would be alerted by radio broadcasts and report to their stations.

The drill did point out, however, that we would be short of drivers. This means that we must plan some alternative strategies to assure adequate driver coverage.

I hope that this answers your concerns. If you desire additional information, please do not hesitate to be in touch with me.

Sincerely, V

h ft(Ninc Y William D. Westcott, Ed. D.

$Y Superintendent WDW/tr