ML20094A151

Transmittal of Testimony Re Limerick Ecology Action & Friends of the Earth Offsite Emergency Plan Contentions & City of Philadelphia Contentions City-18 & City-19. Certificate of Svc Encl.Related Correspondence

ML20094A151
Person / Time
Site:	Limerick
Issue date:	11/01/1984
From:	Rader R CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
References
CON-#484-890 OL, NUDOCS 8411060285
Download: ML20094A151 (7)

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UNITED STATES OF AMERICA '84 E?!-5 li!0:58 NUCLEAR REGULATORY COMMISSION s

Before the Atomic Safety and Licensing' Board: ,

In the Matter of )

PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

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) 50-353 06)

(Limerick Generating Station, )

Units 1 and 2) )

APPLICANT'S TRANSMITTAL OF TESTIMONY RELATING TO LEA AND FOE OFFSITE EMERGENCY PLAN CONTENTIONS AND CITY OF PHILADELPHIA CONTENTIONS CITY-18 AND CITY-19 In accordance with the Atomic Safety and Licensing Board's " Order Establishing Schedule for Offsite Emergency Planning Issues" (August 15, 1984) and " Order (Granting

// Extension of Time)" (October 9, 1984), Applicant hereby transmits its testimony relating to offsite emergency plan contentions. The testimony consists of:

1. Testimony of Robert Bradshaw, John Cunnington and Robin Hoffman Wenger, Relating to LEA Offsite Emergency Plan Contentions;

2. Professional qualifications of Robert Bradshaw,

' John Cunnington and Robin Hoffman;

3. Testimony of Robert Klimm, Relating to LEA-24/ FOE-1;

4. Professional qualifications of Robert Klimm; 8411060285 841101 PDR ADOCK 05000352 O PDR 7

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5. Testimony of V.S. Boyer, N.I. Goldman, G.D. Kaiser and R. Waller, Relating to City of Philadelphia Contentions City-18 and City-19;

6. Professional qualifications of N.I. Goldman, G.D.

Kaiser and R. Waller;1!

7. Applicant's Exhibits Relating to Offsite Emergency Plan Contentions as referenced in its written Testimony, attached as Appendix A.

Background documents included in the reference list attached to Applicant's written Testimony relating to Contention City-18 and City-19 are being sent to the Licens-ing Board, City of Philadelphia, the NRC Staff, PEMA and a-'

1/ The professional qualifications of Mr. Boyer were previously submitted and received into evidence at ff.

Tr. 9772.

2/ Pursuant to the previous Orders of the Licensing Board, Applicant has been providing the parties with copies of the emergency plans and related materials as they have been generated. Previously, the Board received some of this material, but later indicated that it did not wish to receive further updates and revisions. At the time of the hea.'ng, Applicant will offer the current versions of the emergency plans in evidence.

Accordingly, Applicant does not intend to furnish the Licensing Board with copies of these versions at an earlier time unless requested to do so. Similarly, the Evacuation Time Estimates study for Limerick, prepared by HMM Associates, Inc., was furnished to the Board and parties at the time it was made available to Applicant.

The only other exhibit to be offered by Applicant will be a model day care plan, which was provided to the Board and parties in Applicant's Answer to LEA's Respecification of Offsite Emergency Planning Contentions (September 13, 1984).

4 FEMA. There is no intention on the part of Applicant to make these references exhibits.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

Troy B. Conner, Jr.

Mark J. Wetterhahn Robert M. Rader Counsel for the Applicant November 1, 1984

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1 APPENDIX A

1. Evacuation Time Estimates for the Limerick Generat-ing Station Plume Exposure Emergency Planning Zone (May 1984), prepared by HMM Associates, Inc.

2. Model Radiological Emergency Response Plan for Day Care Facilities for Incidents at the Limerick Generating Station.

3. Offsite Training Programs: Agricultural Community (January 20, 1984); School Teachers and Staff (November

.1983); School Officials (December' 28, 1983); Bus Drivers (January 25, 1984); Introduction to Nuclear Energy and ,

Radiation (December 29, 1983), all prepared by Energy Consultants for Philadelphia Electric Company.

4. The current version of each cf the 42 municipal, 13 school district and three risk county Radiological Emergency Response Plans, as previously provided to the parties.

UNITED STATES OF AMERICA 84 !:T!-5 K1 O NUCLEAR REGULATORY COMMISSION

~ ^ ~  : :. ur In the Matter of ) u d-

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Philadelphia Electric Cor pany ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units.1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Transmittal of Testimony Relating to LEA and FOE Offsite Emergency Plan Coantentions and City of Philadelphia Contentions City-18 and City-19" and " Joint Report of the Parties With Respect to the Hearing on Offsite Emergency Planning Contentions dated November 1, 1984 in the captioned matter have been served upon the following by deposit in the ' -

United States mail this 1st day of November, 1984:

• Helen F. Hoyt, Esq. Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary

• Dr. Richard F. Cole U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission

• Ann P . Hodgdon, Esq.

Washington, D.C. 20555 Counsel for NRC Staff Office of the Executive

• Dr. Jerry Harbour Legal Director

. Atomic Safety and U.S. Nuclear Regulatory

. Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission

• Washington, D.C. 20555

• ' Hand Delivery on November 2, 1984

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Atomic Safety and Licensing *

• Angus Love , Esq.

Board. Panel 107 East Main Street U.S. Nuclear Regulatory Norristown, PA 19401 Commission Washington, D.C. 20555 Robert J. Sughrman, Esq.

Sugarman, Denworth &

Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr. 16th Floor, Center Plaza Vice President & 101 North Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 Director, Pennsylvania Emergency Management Agency Mr. Frank R. Romano Basement, Transportation 61 Forest Avenue and Safety Building Ambler, Pennsylvania 19002 Harrisburg, PA 17120 Mr. Robert L. Anthony

• Martha W. Bush, Esq.

Friends of the Earth of Kathryn S. Lewis, Esq.

the Delaware Valley City of Philadelphia 106 Vernon Lane, Box 186 Municipal Services Bldg.

Moylan, Pennsylvania 19065 15th and JFK Blvd.

! Philadelphia, PA 19107 Charles W. Elliott, Esq. , ,

Brose and Postwistilo

• Spence W. Perry, Esq.

1101 Building Associate General Counsel lith & Northampton Streets Federal Emergency Easton, PA 18042 Management Agency 500 C Street, S.W., Rm. 840

• • Miss Phyllis Zitzer Washington, DC 20472 Limerick Ecology Action

! P.O. Box 761 Thomas Gerusky, Director

. 762 Queen Street . Bureau of Radiation Pottstown, PA 19464 Protection Department of Environmental

• • Zori G. Ferkin, Esq. Resources Assistant Counsel 5th Floor, Fulton Bank Bldg.

Commonwealth of Pennsylvania Third and Locust Streets Governor's Energy Council Harrisburg, PA 17120 1625 N. Front Street Harrisburg, PA 17102 Jay M. Gutierrez, Esq.

U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 L '

• Hand Delivery on November 2, 1984

• • Federal Express

James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Timothy R.S. Campbell Director Department of Emergency Services 14 East Biddle Street West Chester, PA 19380

• • Mr. Ralph Hippert Pennsylvania Emergency Management Agency B151 - Transportation Safety Building Harrisburg, PA 1/120

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T s Robert M. Rader

• • Federal Express

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