ML20038C188
| ML20038C188 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/03/1981 |
| From: | Bronstein D BRONSTEIN, D.S., NATIONAL LAWYERS GUILD, PHILADELPHIA CHAPTER |
| To: | Brenner L Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8112100234 | |
| Download: ML20038C188 (26) | |
Text
. _,.
/l%m%
i
-C,.
{*
. R ON.3 I IN ASI) lilXK j
D cc,.,,,,N t.aw oinses
%m.
"'::::zf Third Floor
' " ' ~ ~
w;-
1425 h! nut Street
-,1 l
- 3. gg Philadelphia, Pa.19102 Donald S. Bronstein (215)563-3055 t
John A. Beck
'81 DEC -8 PS:16 f
s(([if(
December 3, 198 W
Administrative Judge Lawrence Brenner
'@\\
g
. RANCH S
Atomic Safety and Licensing Board
/2 if U.S.
Nuclear Regulatory Commission i'.
DEC9 Washington, D.C.
20555 u,,,
19g g 3-I E@cu Re:
Philadelphia Electric Company E..
4 7
(Limerick Generating Station, Unit's/f) 1 and 2); Docket Nos. 50-352, 50-353 g
i
Dear Judge Brenner:
At the request of the NRC Staff, I have enclosed copies of twelve additional affidavits from Graterford inmates.
Also
]
at the request of the NRC Staff, these affidavits have been served on the Staff, Applicant, Licensing Board, and other NRC addressees, all as listed on the attached service list.
Very truly yours, t* - c.U /
i Donald S. Bronstein, Attorney for National i
Lawyers Guild, Philadelphia Chapter l
l l
6 i
I 8112100234 811203' PDR ADOCK 05000352 C
P D_R.
m
- r.n.__. - _____ _
i z.c cccc=z :cz I
%$f;EJE0 AFFIDAVIT OF LEONARD WOMACK
'81 EC-8 PS:16
~ S EC P.E T/,p y
..f.ALTH Ol' PE *SYLVANIA:
pLi,pc & SERVICE.
ss
- STANCH cl' L L TG O: C r.Y Leonard Womack
, b.5ng duty
!.. o r n according to law, deposes and says that.:
1.
He is an inmate incarcerated at the State correctional Tnatitution at Graterford (SCIG), located at Graterford, Pennsylvania.
2.
He is not due to be diccharged from SCIG within the next ttrec l cars.
He opponcs the granting of an operating license tc the 3.
Philadelphia Electric Company for the nuclear power plants currently under construction at Limerick, Pennsylvania.
4.
He opposes the operating of such plant because, ar.ong et.her reasons, he undcrstcnds that the evacuation plans in the event of an emergency at the Limerick plants do not provide for evacuation of himself and other inmates incarcerated at SCIG.
Specifically, upon information and belief, he unders :nds that 5.
the evacuation plans provide for ev.scuation of inr.ates at SCIG only if an accident or other emergency 9ere to occur during daylight, fair wcatner hours.
6.
He is concerned for the safety, health, and well-being of himself and other inmates at SCIG in the event that an emergencj were i
to cecur at a time when there would be no evacuation of inmates.
The pro.:imity of SCIG to Limerick leads him to believe that 7.
s in the event of an emergency, his health, cafety, and well-being would be jeopardized.
[
T 2-
-f l.
1. -.
8.
The proximity of SCIG to Li: erich leads him to believe that kn normal operation of the Li:3erick plants poser a threat to his 11th, cafety, and well-being.
9.
lie authorinos the Natic.nni Lawyers Guild, Philadelphia to reprcsent him in the 1. c ceeding before the Nuclear Regulatory ircion concerning the applicatic,n of Philadelphia Electric Company.
f-perating licenses for the Limerick nuclear peecr plants.
0 s
sa:/ 4_L m-w (
eonard Womack Sworn to and subscribed before me this
-/
day o th hr(
1981.
of ff 4
m t
n Isotary g(1Tc{ [
f i
e d
9 I
I y
e-
-.n---
,3 r,.-
4
~,
.y....
.. +..,...
..m e
w.-~-
m.--..-
REAI.O CC TCIrnz::cz b
00'.KETED AFFIDAVIT OF CARL HONEYBLUE U D *C
'81 083-8 P5:17 QAO H CRE TAh r t
g'ghtfC CO:'.MONWEALTH OF PENNSYLVANIA:
ss COUNTY Or Ma::TGOxERY Carl Honeyblue
, being duly sworn according to law, deposes and says that:
1.
He is an inmate incarcerated at the State Correctional Institution at Graterford (SCIG), located at Graterford, Pennsylvania.
2.
He is not due to be discharged from SCIG within the next three years.
3.
He opposes the granting of an operating license to the Philadelphia Electric Company for the nuclear power plants currently
'under construction at Limerick, Pennsylvania.
4.
He opposes the operating of such plant because, among other reasons, he understands that the evacuation plans in the event of an emergency at the Limerick plants do not provide for evacuation of himself and other inmates incarcerated at SCIG.
5.
Specifically, upon information and belief, he understands that the evacuation plans provide for evacuation of inmates at SCIG only if an accident or other emergency were to occur during daylight, fair i
weather hours.
6.
He is concerned for the safety, health, and well-being of himself and other inmates at SCIG in the event that an emergency were to occur at a time when there would be no evacuation of inmates.
7.
The proximity of SCIG to Limerick leads him to believe that in the event of an emergency, his health, safety, and well-being would be jeopardized.
1 2.
The proximity of SCIG to Limerick leads him to believe that even normal operation of the Limerick plants poses a threat to his health, safety, and well-being.
j 9.
He authorizes the ::ational Lawyers Guild, Philadelphia i
Chapter, to represent him in the procceding before the I:uclear Regulato/r Cor. mission cor.cerning the application of' Philadelphia Electric Company for operating licenses for the Limerick nuclear power plants.
luu) 9 /
N6hm L_.
Carl Honeyblue s
Sworn to and subscribed before ma t 1}
day of dch [.,r[hi s 1981.
'/
/
7 s
/
- of aRy >uplic l
?
o h
4 e
f t
4
nnnn ce=re::=z !
o J
9 AFFIDAVIT OF LONNIE J. JOHNSON GXKETED L iE
'81 093 -8 ' P5 :17 vu) f EC:.EIAR f
": f.G & SERVICE CO.'~F.ONWEhLTH OF PEN"SYLVANIA:
ERANCH ss col'N.'Y OF IC ?GCF.ERY Lonnie J. Johnson
, being d-sworn according to law, deposes and says that:
1.
He is an inmate incarcerated at the State Correctional Institution at Graterford (SCIG), located at Graterford, Pennt-2.
He is not due to be discharged from SCIG within the next three years.
3.
He opposes the granting of an operating license to the Philadelphia Electric Company for the nuclear power plants currentl'.
under construction at Limerick, Pennsylvania.
4.
He opposes the operating of such plant because,-among other reasons, he understands that the evacuation plans in the event of an emergency at the Limerick plants do not provide for evacuation of himscif and other inmates incarcerated at SCIG.
5.
Specifically, upon information and belief, he understands that the evacuation plans provide for evacuation of inmates at SCIG only if an accident or other emergency were to occur during daylight, fair weather hours.
e 6.
Ile is concerned for the safety, health, and well-being of himself and other inmates at SCIG in the event that an emergency were to occur at a time when there would be no evacuation of inmates.
7.
The proximity of SCIG to Limerick leads him to believe that in the event of an emergency, his health, safety, and well-being would be jeopardized.
C.
The pro.s:imity of SCIG.to Limerick Icads him to believe that even normal operution of the Lir. crick plants poses a threat to his health, cafety, and well-being.
9.
lie authorizes the National Lawyers Guild, Philadelphia Chapter, to represent him in the proceeding before the Nuclear Scgulatory Commicsien concerning the application of Philadelphia Electric Company for operating licenses for the Limerick nuclear power plants.
l 1: 3L4 Nb7 D I
~
I,onnie J./ 6hnsdn J
v J
l Sworn to and subscribed before e this 2J day of CC 7)[ p' 1981.
s i
i
/
/
vQ' )
(
/=
Notar /
ublic
[
, C,
.:,..~
o amm.
O
j.
-n
- EH C D CO. r :::; r ~,5 :
j 00lKETED AFFIDAVIT OF EDNARD LEE FEREBEE
'81 EC -8 P5:17 tM.e.
stu2TARY
-hfch COMMONWEALTH OF PE!!NSYLVANIA:
ss COUNTY OF MONTGCMERY Edward Lee Ferebee
, being duly j
sworn according to law, deposes and says that:
1.
He is an inmate incarcerated at the State Correctional Institution at Graterford (SCIG), located at Graterford, Pennsylvania.
2.
He is not due to be discharged from SCIG within the next three years.
3.
lie opposes the granting of an operating license to the Philadelphia Electric Company for the nuclear power plants currently under construction at Limerick, Pennsylvania.
4.
He opposes the operating of such plant because, among other reasons, he understands that the evacuation plans in the event of an emergency at the Limerick plants do not provide for evacuation of himself and other inmates incarcerated at SCIG.
5.
Specifically, upon information and belief, he understands that the evacuation plans provide for evacuation of ir, mates at SCIG only if an accident or other emergency were to occur during daylight, fair weather hours.
6.
IIe is concerned for the safety, health, and well-being of himself and other inmates at SCIG in the event that an emergency were to occur at a time when there would be no evacuation of inmates.
7.
The proximity of SCIG to Limerick leads him to believe that in the event of an emergency, his health, safety, and well-being would be jeopardized.
8.
The proximity of SCIG t'o Limerick leads him to believe tha-even normal operation of the Limerick plants poses a threat to his
~
-health, safety, and well-being.
9.
He authorizes the National Lawyers Guild, Philadelphia Chapter, to represent him in the proceeding before.the Nuclear Regulat ry 7
Commission concerning the application of' Philadelphia Electric Company for operating licenses for the Limerick nuclear power plants.
- /
_b blW. ), Jtl
<f Edward /1,ee Ferebee Sworn to end subscribed before e thisA3.
day of O c-l.# /
l,1981.
I t
)
J,1 / ' IJ
/_
NotgrVPhylic [
4
. E.'.
.s 4
1
~
?
-.--.,-..-.,-,.n-,
TZ iTC CCric_r:= r;;g !
I--
i
_1 20'y >.E1EE' K
AFFIDAVIT OF THERON KITTRELS
~81 DEC -8 P5:17 W
- i CRE iAR!
' h:,G & SERVitt CO!GO!; WEALTH OF PENNSYLVANIA:
AHCH ss COU:4TY OF y:.*;TGO ERY Theron Kittrels
, being duly sworn according to law, deposes and says that:
1.
lie is an inmate incarcerated at the State Correctional Institution at Graterford (SCIG), located at Graterford, Pennsylvania.
2.
He is not due to be discharged from SCIG within the next three years.
3.
He opposes the granting of an operating licence to the Philadelphia Electric Company for the nuclear power plants currently under construction at Limerick, Pennsylvania.
4.
He opposes the operating of such plant because, among other reasons, he understands that the evacuation plans in the event of an emergency at the Limerick plants do not provide for evacuation of himself and ther inmates incarcerated at SCIG.
5.
Specifically, upon information and belief, he understands the*
the evecuation plans provide for evacuation of inmates at SCIG or.ly if an accident or other emergency were to occur during daylight, lir weather hours.
6.
He is concerned for the safety, health, and well-being c' himself and other inmates at SCIG in the event that an emergency.
to occur at a time when there would be no evacuation of inmater.
7.
The proximity of SCIG to Limerick leads him to believe t:
in the event of an emergency, his health, safety, and well-being wn.
be jeopardized.
8 The proximity of SCIG to Linerick leads him to believe that even normal operation of the Limerick plants poses a threat to his health, safety, and well-being.
.9.
lie authorizes the National Lawyers Guild, Philadelphia Chapter, to represent him in the proceeding before the !;uclear Fegulatory Con. mission concerning the application of Philadelphia Electric-Con.pany for operating licenses for the Linerick nuclear po.:er plants.
uW N
Theron Kittrels Sworn to and subscribed this 73 day before mehV!f Q 1981.
of
- 6c
/
b p
Not 'r > P6b c'
9 unsw.
O
j EGAID Co.._. c....w a I
00LKETE0 rii;;0 AFFIDAVIT OF MILTON DURER
'81 DEC -8 PS:17 UA IE'AETARY s SERVICE
-, y'ltacH "g
COPMOla:EALTH OF PENSSYLVANIA:
ss COUNTY OF' MONTGOMERY Milton Durer being duly cworn according to law, deposes and says that:
1.
Ile is an inmate incarcerated at the State Correctional Institution at Graterford (SCIG), located at Graterford, Pennsyi 7!
f 2.
He is not due to be discharged from SCIG within the no:
three years.
3.
i!c opposes the granting of an operating license to the Philadelphia Electric Company for the nucicar power plants curr nt under construction at Limerick, Pennsylvania.-
4.
lie opposes the operating of such plant because, among othe reasons, he understands that the evacuation plans in the event of a emergency at the Limerick plants do not provide for evacuation of himself and other inmates incarcerated at SCIG.
5.
Specifically, upon information and belief, he understands that the evacuation plans provide for evacuation of inmates at SCIG only if an accident or other emergency were to occur during daylight, fair weather hours.
6.
He is concerned for the safety, health, and well-being of himself and other inmates at SCIG in the event that an emergency were to occur at a time when there would be no evacuation of inmates.
7.
The proximity of SCIG to Limerick leads him to believe that in the event of an emergency, his health, safety, and well-being would be jeopardized.
_ 2_
8.
The proximity of SCIG to Limerick leads him to believe that normal operation of the Linerick plants poses a threat to hi::
cven health, safety, and well-being.
9.
He authorizes the t:stional Lawyers Guild, Philadelphia Chapter, to represent him in the proceeding before the Nuclear P.,
1 Coneniscion concerning the application of Philadelphia Electric C-for operating licenses for the Limerick nuclear power plants.
ab/um Milton Durer Sworn to and subscribed before me this 2J day of o c -M./ /, 19 81.
I f
/
- 1. J J
/
W~
l
.W /
c Nota 2gg'PJ2blig se
=
I N
1 f
u
I---
! T x := c-,.. %
L
^ ~~-- :::- ; g 3
CXKETET k
U E:'
g AFFIDAVIT OF TYRONE TERRELL
'81 DEC -8 P5 :17 i
W i
SECRii m 3
.h. M & SERVICE ERANCH
~
CGI'.:40D;Eli,TH OF PENNSYLVANI A:
ss COU:iTY OF u;TGO.v. CRY Tyrone Terrell
, being duly sworn according to law, deposes and says that:
D E
He is an inmate incarcerated at the State Correctional 1.
Institution at Graterford (SCIG), located at Graterford, Pennsylvania.
)
He is not due to be discharged from SCIG within the next 2.
three years.
He opposes the granting of an operating license to the s
3.
1 Philadelphia Electric Company for the nuclear power plants currently y
I l
under construction at Limerick, Pennsylvania.
[.
He opposes the operating of such plant because, among other 4.
reasons, he understands that the evacuation plans in the event of an emergency at the Limerick plants do not provide for evacuation of himself and other inmates incarcerated at SCIG.
thn Specifically, upon information and belief, he understar < -
5.
the eva'cuation plans provide for evacuation of inmates at SCIG c-if an accident or other emergency were to occur during daylight, --
weather hours.
He is concerned for the safety, health, and well-bein, 6.
himself and other inmates at SCIG in the event that an emergency w to occur at a time when there would be no evacuation of inmates.
7.
The proximity of SCIG to Limerick leads him to believe ti in the event of an emergency, his health, safety, and well-being wot be jeopardized.
8.
The pro.:imity of SC:G te Limerick 1 cads him to believe that even norn.a1 operation of the Lircrick plants poses a threat to his health, safety, and well-being.
9.
He authorizes the National Lawyers Guild, Philadelphia 1
Chapter, to represent him in the proceeding before the Nuclear Regulatory Commission concerning the application of Philadelphia Electric Company for opere. ting. licenses for the Lir.erick nuclear power plants.
Pf* ?ON
.)
g,,gg
,; {l I~ -
Tyrone Terrell Sworn to and subscribed of.oc.h
,his 2 7 before ne t day 1981.
.+{.? 3 i
a m
Noda y PQ2blic
.p 's
l F21.IrDCCrrrr:::rnczl l
1
,]
[
(i COCKETED y P::'
AFFIDAVI" OF JAMES S. "JHYATT f
'81 DEC -8 P5:17 l
80-I iEC^.ET W:
.G k 5.ERVICE 7
CO!GONWEALTH OF PENNSYLVANIA:
uiA!Cn t
ss I
COUNTY OF !ONTGOMEkY James S. Whyatt
, being duly h
i sworn according to law, deposes and says that:
I 1.
He is an inmate incarcerated at the State Correctional I
Institution at Graterford (SCIG), located at Graterford, Pennsylvania.
l 2.
He is not due to be discharged frcm SCIG within the nes' three years.
3.
He opposes the granting of an operating license to the Philadelphia Electric Company for the nuclear power plants currers under construction at Limerick, Pennsylvania.
4.
He c pposes the operating of such plant because, among othi.
he understands that the evacuation plans in the event of c
- reasons, emergency at the Limerick plants do not provide for evacuation of himself and other inmates incarcerated at SCIG.
Specifically, upon information and belief, he understands t.
5.
the evacuation plans provide for evacuation of inmates at SCIG only fair if an accident or other emergency were to occur during daylight, weather hours.
6.
He is concerned for the safety, health, and well-being of himself and other inmates at SCIG in the event that an emergency were to occur at a time when there would be no evacuation of inmates.
7.
The proximity of SCIG to Limerick leads him to believe that in the event of an emergency, his health, safety, and well-beir.g would be jeopardi::cd.
_2_
8.
The proximity of SCIG to Limerick leads him to believe that even normal operation of the Limerick plants poses a threat to his health, rafety, and well-being.
9.
IIe authorizes the !!ational Lawyers Guild, Philadelphia Chapter, to represent him in the proceeding before the Nuclear Regulatory Ccnmis.sion concerning the application of Philadelphia Electric Company for operating licenses for the Limerick nuclear power plants.
l r
s
\\
f
- //>
/,_.,.v.....A
/ James S. Whyatt k
I.. /
Sworn to and subscribed before me this4 4 day of O Cdu l> f/
1981..
l D.]
o r
i IV Nora rQ* MDfiC
..u,
l r
,c.,,.-__.-_..,..__.,_______3...r.-._,_, _, _., _
r.
~
.,_,,,.y
, runs c:===:===z DOCKETED U3GC AFFIDAVIT OF RANDALL HALL
'81 EC -8 PS :17 8/Y)-
0 (C L.JALTH OF PU::.MSYLVANIA:
E D El/,7 ss h,3dTNCE f.;TY C# MONTGOMERY Randall Hall
, being duly s.orn according to law, deposes and says that:
1.
He is an inn. ate incarcerated at the State Correctional Insti tution at Graterford (SCIG), located at Graterford, Pennsylvania.
2.
He is not due to be discharged from SCIG within the
. ext three years.
He opposes the granting of an operating license to
- he 3.
Philadelphia Electric Company for the nuclear power plents turrently under construction at Limerick, Penncylvania.
4.
He opposes the operating of such plant because, among other reasons, he understands that the evacuatien plans in the event of an
(.nergency at the Limerick plEnts do not provide for evacuation of himself and other inma tes incarcerated at SCIG.
5.
Specifically, upon information and belief, he underrtands that 1
thc evacuation plans provide for evacuation of inmates at SCIG only fair if an accident or other emergency were to occur during daylight, ueather hours.
6.
He is concerned for the safety, health, and well-being of himself and other inmates at SCIG in the event that an emergency were to occur at a time when there would be no evacuation of inmates.
7.
The proximity of SCIG to Limerick leads him to believe that in the event of an emergency, his health, safety, and well-being would be jeopardi: ed.
7 E
r S.
The proximity of SCIG to Li:,erick leads him to believe tha*
I; vcn normal operation of the Limerick plants poses a threat to his
- alth, safety, and well-being.
3
?.
He authorizes the National Lawyers Guild, Phihdelphia ipter,.to represent him in the prceecding before the Nuclear Regulatory l
T.ission concerning the applicaticn of Philadelphia Electric CD:.'phny 6
. rating licenses for the Limerick nuclear power plants.
AS*: 'QV
//s:/,l
\\
4 J
M y
i fc. wy ay
- e.,7 g -^" ' /^!t. /f. y 5 <,. _,
n n
Sworn to and subscribed before pe,thjs %f day Randall Hall of e ch l,, s /
1981.
I
/
voa=gw
\\
h 9
l F.Eh*.7 a
S AFFIDAVIT OF BEBLEY C. NELLS, Jit'.CKETED
'MC
-j
'81 DEC -8 P5:17 M
-j
.OtaiE.;LTH OF PE!;NSYLVANIA:
_SE :E7;.gy y
ss
. 1,S,ERV:CE
[
iTY OF MO!;TGOMERY
~'
l Bebley C. Wells, Jr.
being duly l
3
~.
n according to lau, deposes and says that:
1 He is an inmate incarcerated at the State Correctional l
1.
t
.an at Graterford (SCIG), located at Graterford, Pennsylvania.
b He is not due to be discharged from SCIG within the next J.
3ars.
He opposes the granting of an operating license to the 9.1phia Electric Company for the nuclear power plants currcntly
~ i. i l:
i
.ader construction at Limerick, Pennsylvania.
among other He opposes the operating of such plant because, 4.
i reasons,-he understands that the evacuation plans in the event of an I
cmcrgency at the Limerick plants do not provide for evacuation of himself and other inmates incarcerated at SCIG.
that Specifically, upon information and belief, he understands 5.
SCIG only the evacuation plans provide for evacuation of inmates at fair if an accident or other emergency were to occur during daylight, weather hours.
and well-being of 6.
He is concerned for the safety, health, himself and other inmates at SCIG in the event that an emergency were to occur at a time when there would be no evacuation of inmates.
leads him to believe that 7.
The proximity of SCIG to Limerick his health, safety, and well-being uould in the event of an emergency, be jeopardized.
w----
+,
q
_2_
J G
1 s
2.
The prcximity of SCIG to Limerick lends him to belicvc that
.ornal opcration of the Limerick plants poses a threat to his evt health, safety, and well-being.
9.
He authorizes the National Lawyers Guild, Philadelphia Chapter, to represent him in the procceding before the Nuclear Pegulatory j
Conc.ission concerning the application of Philadelphia Electric Coropany for operating licenses for the Lirnerick nuclear power plants.
//
Bebley C. Wel s, Jr.
i/M-0253 P.O. Boz.244 rworn to and subscribed Graterford, Penna. 19426 hefore ge,this -/
day of Oc pp(f 1981.
(
o ?
l I
7
- s
. _w GOta] i ubJ iC r-m I
e f
i
~
l murc:rrb: Ercs !
f l
AFFIDAVIT OF WILLIAM CORNISH Ug{EfED
'81 DEC -8 PS:18 N
C 2MO!;.iEALTH OF PENNSYLVANIA:
--'~ ' F 3EIARY
. d h SERVCE ss i
3AllCH COUNT? OF MONTGCMERY William Cornish being duly svorn according to law, deposes and scys that:
1.
He is an inmate incarcerated at the State Correctional i
Institution at Graterford (SCIG), located at Graterford, Pennsylvania.
He is not due to be discharged fror. SCIG within the next l
2.
three years.
He opposes the granting of an operating license to the 3.
Philadelphia Electric Ccmpany for the nuclear power plants currently under construction at Limerick, Pennsylvania.
among other 4.
He opposes the operating of such plant because, rensens, he understands that the evacuation plans in the event of an c=ergency at the Limerick plants do not provide for evacuation of
.self and other inmates incarcerated at SCIG.
Specifically, upon information and belief, he understands that 5.
evacuation plans provide for evacuation of inmates at SCIG only fair n accident or other emergency were to occur during daylight,
. :scr hours.
2.
He is concerned for the safety, health, and well-being of
- 61-If and other inmates at SCIG in the event that an emergency were tur at a time when there would be no evacuation of inmates.
The proximity of SCIG to Limerick leads him to belic re that in ths event of an emergency, his health, safety, and well-being would jeopardized.
ve L
_2_
that S.
The proximity of SCIG to Limerich icads him to believe even nc.rn.a1 operation of the Limerick plants poses a threat to his health, safety, and well-being.
9.
He authorizec the National Lawyers Guild, Philadelphia Cha, er, to represent him in the proceeding before the Nuclear Pegulatory r
Cc mission concerning the application of Philadelphia Electric Company for operating licenses for the Limerick nuclear power plants.
//d W &,:.
r ?,.
' William Cornish Sworn to and subscribed befcre this 7-/
day of o
kt [, 1981.
ul t
r notr.)h g Lic{
i
.e e
e m
99 9
e O
T. L.*.I:D CCF_'..C:::::CE
}--
-- -.mc._ _ _
00CKETED pa m.~
h AFFIDAVIT OF REGINALD MAYS E
=6i DEC -8 P5:18 g
. 3 3;,:,g fay CO!*JtGr.EALTH OF PENNSYLVANIA:
- 3 ', SERV;CE
- . i ss 3 RANCH
.NTY OF MONTGOMERY Reginald Mays being duly t
according to law, deposes and says that:
n i
!!e is an inmate incarcerated at the State Correctional f
1.
itution at Graterford (SCIG), located at Graterford, Pennsylvania.
He is not due to be discharged from SCIG within the next 2.
i
- cars.
He opposes the granting of an operating license to the iphia Electric Company for the nuclear power plants currently r
anstruction at Limerick, Pennsylvcnia.
u. 2 -s.
among other He opposes the operating of such plant because, 4.
in the event of an he understands that the evacuation plans
- :a so:ss, e..ergency at the Limerick plants do not provide for evacuation of T
himself und other inmates incarcerated at SCIG.
1 Specifically, upon information and belief, he understands that 5.
the evacuation plans provide for evacuation of inmates at SCIG only fair if an accident or other emergency were to occur during daylight,
[
weather hours.
~
and well-being of He is concerned for the safety, health, 6.
himself and other inmates at SCIG in the event that an emergency were to occur at a time when there would be no evacuation of inmates.
leads him to believe that The proximity of SCIG to Limerick 7.
in the event of an emergency, his health, safety, and well-being would l
t be jeopardized.
O
-'N
-- -.=
u,
~ * " " ~ ' * * "
- ,-=.p-
,y
C 2-U E
E The proximity of SCIG to Lim.2 rick leads him to believe that h
E even normal operation of the Limerick pInnts poses a threat to his E
6 j
hcalth, safety, and well-being.
9.
He authorizes the 7:ational Lawyers Guild, Philadelphia Chapter, to represent him in the proceeding before the !;uclear Regulatory B
Cor.ission concerning the application of Philadelphia Electric Company 2
for operating licenses for the Limerick nuclear power plants.
L E
5 k
i h
(c
- 777wr Recjinald Mays
' [
h i
Sworn to and subscribed
[4 j
before.e this S-/
day
{
of e fr
, 1981.
e 1[
I f
I E
TC~C%T iic i
L i'
9 q.-
l i
~.
i l
1 i
O O
_._.m._
.m_.
WERWicLE LXst b
d.pinistrative Judge Lawrence-Brenner Philadelphia Electric Co.
tomic Safety and Licensing Board Attn: Edward G.
Bauer, Jr.
.S. Nuclear Regulatory Commission Vice President & General Counsel
.shington, D.C.
20555 2301 Market Street Philadelphia, PA 19101 1
dministrative Judge Richard F.
Cole Atomic Safety and Licensing -Board Panel tomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
.S.
Nuclear Regulatory Commission Washington,D.C. 20555
'ashin gton,
D.C.
20555 l
i
)
dministrative Judge Peter A. Morris Atomic Safety and Licensing Appeal Paneld tomic Safety and Licensing Board U.S. Nuclear Regulatory Commission i.S. Nuclear Regulatory Commission Washington, D.C.
20555 d"
shin gton,
D.C.
20555 a
ounsel for NRC Staff Docketing and Service Section ffice of the Executive Legal Director Office of the Secretary i
.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission ashin gton,
D.C.
20555 Washington, D.C.
20555 iroy B. Conner, Jr., Esq.
nner & Wetterhahn 747 Pennsylvania Avenue, N.W.
?'
ashington, D.C.
20006 I
,_wg
,m,
+-
_ ~
_.t*
_