ML20092K719
| ML20092K719 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/22/1984 |
| From: | Mulligan M LIMERICK ECOLOGY ACTION, INC. |
| To: | PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 8406290030 | |
| Download: ML20092K719 (14) | |
Text
,
~%\\
attAI c ::..r.
r::;o r:::
4 09,hQED 3:In.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 04 J[jf,7 y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
' q. ';~, f,.:p.;
c.N.
In the Matter of
~ ' ' " ".. -
l Docket Nos. 50-352 PHILADELPHIA ELECTRIC COMPANY 50-353 (Limerick Generating Station, Units 1 and 2)
LIiERICK ECOLO".Y ACTION'S FIRST SET OF INTERROSATORIES AND REnUEST FOR PRODUCTION OF DOCU':ENTS TO THE PENNSVLVANIA E"ETENCY
- WiA9E'iENT AGENCY ON LEA's AD'1ITTED "'FF-SITE" E"ERGENCY PLANNIN1 CONTENTIONS Pursuant to the Rules of Practice of the Nuclear Regulatory Commission (N.R.C.),10C.F.R.
,2.740 (b), tnd the Orders o' the Atomic Safety and Licensing Board in this proceeding, Linerick Ecology Action hereby propounds the following interrogatories to the ocnnsyivania Emergency *1anagenent Agency.
("PE'iA"), to be answered fully in writing, under oath, in accorcance with the definitions and instructions set forth below, ndditionally, pursuant to 10 C.F.P..
5 2.741, Limerick Ecology Action recuests that PEiA produce copies of thos.e documents designated by it in its respective answers below.
Definitions and_ Instructions 1.
For each interrogatory, please state the full name, work address, and l
title or position of each person providing information for the answer to tne interrogatory.
2.
The following definitions shall apoly:
- a. "?E!!A" shall refer to the Pennsylvania Emergency 'tanagenent A:ency, or any official, officer, vember, emnloyee, or consultant thereof and snali include h
,% 290030 40622 4 ADOCK 0 0003S2 o
p.
any other related agencic. v the Comonwealth, upon wnich PE'tA will rely.
I particularly.the Pa. Bureau of Radiation Protection in the Pa. Jept. of l
Environmental Resources, and the Governor's Energy Council representatives participating in this procHh
'n behalf of PEi1A.
- b. " Document" shall mean any written, ;)rinted, typed or other graphic matter of any kind or nature, computer tapes or other electronicaily storec or generated material, and all mechanical and electronic sound recordings or transcripts thereof, in the possession, custody, or control of PE'tA, or which PE4A has knowledge thereof, cnd intenos to rely upon in this proceeding.
c.
"Date" snall mean the exact day, ranth and year if ascertainable, or if not ascertainable, the best approximation (including the event's relationship to other events in the relevant context of the interrogatory).
d.
"HRC" or " Commission" shall mean either the Atomic Energy Cortission or the
-Nuclear Regulatory Commission, as appropriate, including its regulatory staff and adjudicatory boards, as indicated by the context of the interrogatory.
e.
"Specify", when referring to a proceeding before the Nuclear Regulatory Comnission, means that the answer shali set forth the proceeding, coplicant, docket number, relevant date, cnd any other dMcriptive infor ation appropriate to the request.
. f. "Speci fy" or " identify", ehen referring to an inoividual, corporation, or l
other entity, means that the answer shall set forth tne name, present or last known work address, and if a corporation or otner entity, its principal place of business, or if an individual, his or her title or titles and employcr.
unce an individual corporation or other entity has been thus identified in an answer to an interrogatory, it shall be sufficient thereafter when identifying that individual, corporation or other entity to state merely his, her or its r.ame, j
- 3..
These interrogatories request all knowledge and information in PE!iA's possession and/or knowledge and infomation in the possession of PC4A officials, officers, cgents, representativcs, consultants, and unless privilegeo, attorneys.
l
L 4.
In each instance in which an interrogatory renuests a statement of PE assertion, contention, view or opinion, the answer shall also contain a full discussion of the factual basis for the assertion or opinion INTERROGATORIES 1.
State whether or not PEliA intends to present any expert witnesses the subject matter at issue in the contentions and issues sponsored b y Limerick Ecology Action, admitted by the Atomic Safety and Licensing Board in proceeding by order of April 20, 1984 on tne issues of "off-site" emergency pl an-ning for the Plume Exposure EPZ for Limerick. The conetntions refer LEA-ll, LEA-12, LEA-13, LEA-14, LEA-15, LEA-22, LEA-26, LEA-27
, LEA-28, and LEA-24 (includes F0E-1).
2.
State whether PE'tA intends to present any factual witnesses on the subject matters at issue in LEA's admitted contentions (as listed above
. If so, please identify each such factual witness and furtner state (a) his/he professional qualifications; (b) the contention and subject natter on wh witness is expected to testify; (c) the substante of the facts to which thL e
witness is expected to testify. Identify by court, acency, or other bod[
, each proceeding in which such individual rendered testimony on this subject (s) c:
3.
Identify by title, author, publisher and date of issuance or publica
[
all documents that PEMA relies upon as a basis for its position or that intends to use (by way cf reference or evidentiary proffer) he in presenting its
[
case or position, to be used for cross-examining other witnesses on "off-site" c
[
emergency planning contentions, and all documents which PEMA intends to 5
5 in conducting cross-examination of other witnesses who may testify in cg on with any such contention.
((}
m
,5
[5!
f:?
5l1 54
=
2.' '.
4.
4.
To the extent that PEMA's answer to any of the interrogatories is based upon one or more documents, (a)* identify each such document on which the answer is based; (b) identify the specific information in such document upon which PEMA relies; (c)' explain how the information provides a basis for PEMA's answer or position.
.5.
- To the extent that your answer is based upon any study, calculation,
-research or analysis, (a) describe the nature of the study, calculation, research or analysis and identify any documents which discuss or describe the study, calculation, research or analysis; (!' identify the person (s) or entity (ies) who perfomed the study, calculation, research or analysis; (c) describe in detail the information which was the subject of tnc study, calculation, or research, or analysis; (d) describe the results of such study, calculation, research or analysis; (e) explain how such study, calculation, research~or analysis provides a basis for PEMA's answer.
6.
To the extent that your answer is based upon conversations, consultations, or correspondence or other communications with' one or more individuals or entities {ahlease identify each such individual or entity; (b) state the educational and professional background of each such individual, including occupation and institutional affiliations; (c) describe the nature of each communication, including time and context, and describe the information received from each such individual or entity; (e) explain how such information provides a basis for your answer.
7.
To the extent that PE'iA possesses infomation or documents expressing facts or opinions which are relevant to the specific interrogatories below, but which do not support PEMA or the Applicant's position, or which hava not otherwise been fully provided in the answers thereto, please provide such infomation and documents.
t g
O 5
WITH REGARD TO CONTENTION LEA-ll:
8.
Supply any and all infonnation currantly available to PEMA regard the arrangements made for the-number and assignment of buses to evacuat school children in private and public schools in Chester, Berks, and Counties tithin the Limerick Piume EPZ.
9.
Provide a list of the bus companies willing to make buses available fo evacuation of Chester, Berks, and f4ontgomery County public and private sc in the event of a radiological emeroency at Limerick. Provide addresses o each company and the location from where the buses will be dispatched.
10.
Have fonnal letters of a' qreement been completed for all bus comp expected to provide buses for use in Chester, Berks,and '4ontgomery Count ff not, why not? Provide a list of the agreements still to be completed end any information available to PBiA regarding when such agreeme to be completed. (please include any information to support the basis s
answer.)If yes, provide a copy of all completed letters of agreement 11.
Indicate by company the number of buses available from each c that are expected to be available in the event of a radiological caergen y at Limerick.
12.
Who is responsible at PEMA for evaluating the " Risk" and " Support" Counties " unmet needs" regarding the sufficiency of buses and bus driver Please supply the name, title, and description of the designated perso on.
Who in PEMA is responsible for securing the necessary buses and driv that any of the " Risk" or " Support" Counties are unable to provide them?
[
13.
For each bus company expected to provide buses, please provide an infonnation available to PIMA, or any information that PEMA has knowledge gs regarding the time lapse from the notice of dispatch until buses and bus drivers 15 L.i reach their assigned destination.
d f$
14.
How many buses will be responding from within the 10 mile radius
- d busGs and drivers will be responding frc~ outside of the 10 mile radius (Plume EPZ) to evacuate persons from within tne Piire EPZ? How far must these buses travel to reach their. assigned school ' estinations?
d 15.
Who is responsible for contacting the bus companies during a radiological emergency at Liraerick?
16.
What infonnation is available to PEMA to indicate the enount of resp'onse time invoived before buses can be expected to arrive at their designated schools during a radiological emergency? Please indicate all infonnation that will be relied upon by PEMA, or that PDA has knowledge of.
FOR THE FLLLOWING, PLEASE PROVIDE AtJ T%ATION AVAILABLE TO PEA OR THAT PE'1A HAS KNOWLEDGE THERE0F:
- 17. How uill each bus company be contacted in the event of a radiological emergency at Limerick? Be specific.
- 18. riow will each individual bus driver be contacted during any perico of time covering a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. De specific. What provisions are made for notification of drivers off-cuty or enroute?
- 19. Are each of the buses that will be used eauipped with 2.tay radio egiup-
...ent? If PEliA has knowledge of details aoout the kimi of c1uipment involved, please provide any kind of infonnation that PEMA is aware of.
- 20. Are buses pre-assigned to specific scnools? If not, how and when will those assignments be made in the event of a radiological emergency? How will this information be communicated? By whom? If assignments have been made, provide all details available.
- 21. WITH REGARD TO CONTENTION LEA-15, PLEASE PROVIDE ANSWERS TO THE FOLLOWING QUESTIONS ABOVE AS THEY WOULD PERTAIN TO " BUS DRIVERS":
8, 10, 11, 20, and 9.
(For number 9, in the event that buses are available but there are insufficient bus drivers, provide information available about the number, location, status, and source of such persons that would be used to drive buses in the event of a radiological emergency.)
4
k
- 22. Has PEMA collated any data, or does PEMA have in it possession any materials, surveys or lists regarding the number of bus drivers from each company that would participate during a radiological emergency? If yes, attach the materials, lists, data or surveys, by company, indicating the dates and results.
- 23. If PE'iA does not have the infonnation referred to in interrogatory nunber 22 above, what is the basis for the assumption that a sufficient number
- of bus drivers will be available? How will PETA respond to this " unmet" need?
- 24. Have all bus drivers expected to participate received " training" for a radiological energency?
- 25. Please describe the " training" received. Where, when, and by whom have the training sessions been conducted?
- 26. Provide the dates of training sessions and the number of participants, identifying the bus company involved.
- 27. If any of the arrangements for buses are being made by anyone other than PECO or Energy Consultants, Inc., please provide the basis for the assumption that all unmet needs have been or will be sctisfied.
Answer the same ouestion with regard to arrangements for bus drivers.
- 28. Provide copies of correspondence relati,ng to the securing and committment of bus drivers and buses in emergency response planning for a radiological emergency at Limerick.
- 29. Provide any written or oral information available to PEMA that currently outlines the legal responsibilities of the bus companies and their bus drivers, to PECO, the " Risk" and " Support" counties, and to PDiA during a-radiological energency at Limerick.
If none exist, please explain how PEMA has evaluated and discussed PEC0's response to such an energency and any agreement I
L or plans for the provision of buses and drivers.
If someone atacr than PECO or Energy Consultants Inc. has made these arrangements.(such as a county office of energency prparedness) please identify the parties to, the arrangements as well as all data demont.:. rating that there are sufficient ouses and bus crivers willing to respond to local, county, and school district emergency response plans.
- 30. Provide a summary of any " verbal understandings" that PEMA has knowledge of or will rely upon as assurance that individual bus drivers will respond when contacted in the event of a radiological emergency.
Provide copies of any letters, contracts or written agreements to su?nort tnis.
31.
ilave bus drivers, school staff, any otner omergency workers been in-formed of the " risks" associated with remaining in or entering the Plume EPZ during a radiological emergency requirirg sneltering or evacuation as a protective measure? If not, why not? If yes, provide details about the infomation that has been provided to them. How and when was this infomation presented?
- 32. have promises, inducements, or ir.centives of cny kind in writing or verbally been made to' bus companies, indivicxl bus drivers or " volunteers" to obtain their services, or to obtain tneir com.it ment to provide services or participation?
(An example of this would be tr.e c?fering made by PECO to provide equipment necessary for the municipal EOC S.)
If so, please specify.
If not, please state whether PEMA will provide any communications equipment for any of the bus companies, their drivers, or any public or private schools.
Please provide any written agreements or summaries or any verbal agreements wnich encompass these understandings.
- 33. Do any such written or oral agreements for bus services with individuals, or companies contain penalty clauses for failure to comp.ly? Do any such agreements contain incentive clauses for willingness to compiy? Does PEMA have any knowledge whether or not such agreement provisions are port of the general
~
U -
~
r employment contracts for bus drivers?
34, lias PBiA collated any data from any source on whether school staff will remain on duty durihg a radiological emergency? Supply the basis
(
for this infomation, and its timeliness.
Provide any infomation, contract tems, infomal agreements or verbal understandings which support the position that sufficient school staff are available and willing to remain with students during a radiological emergency.
Provide specific information avaiiable for each school involved.
- 35. Have bus companies been infomed of any potential legal liability for failure to respond or for inadequate response of its drivers during an emergency!
How does a bus company guarantee the availability of drivers during during a radiological emergency? Does PEMA have any knowledge of verbal, contractual or l
written agreements between drivers and bus companies?
- 36. Do bus companies have comitments to provide services for more than one school district, municipality or other facility during a radiological emergency?
If so, please provide a listing of ali comitments that PE' A has knowledge of.
- 36. Have bus drivers anc their comper.;n acen in omed about the need for r
buses and drivers to remain at host schools to sucsequently provide transportaticn to mass care centers?
If so, has the matter been arranged in written or verbal agreements? If not, why not? Please provide any infomation that PEMA is aware of.
- 37. Does PEMA have any knowledge of bus drivers or companies unwilling or unable to provide bus drivers for transportation from host schools to mass care centers? If yes, what arrangements have been or will be made to provide transpor-tation from host schools to mass care centers.
WITH REGARD TO LEA-13:
- 38. What provisions have been made to provide transportation for pre-school and day care children outof the EPZ? Provide any infomation that supports the position that these transportation needs have been identified and will be act.
(This refers to children within the EPZ at the time of an emergency.)
- 39. If local munici a11 ties are making tMse arrangements, provide all information that PEMA has knowledge,of regarding these arrangements.
If PEMA or a county have made any'such agreements attach all letters of agreement developed to insure that adequate transportation _will be available.
Provide copies of any other written agreements or summaries of any verbal agreements which encompass same.
'40. What priority,.if any, has been given to the transportation needs of pre-school / day care children among the " pool" cf transportation needy people, which includes the elderly, inandicapped, or these. otherwise without transportation means to evacuate?
- 41. Will buses 'or private nergency vehicles be used to evacuate pre-school /
day care children? Have they been numbered ano identificc? Have th:y Deen assigned?.If so.'please specify.
If no. why not?
- 42. What information does PEMA have regarcing the response time of bus drivers or other emergency volunteers to a'rrive at a designated day care center after notification' has been made? How will crivers be dispatched?
43.
How many buses or' emergency venic'es wili be needed to evacuate tne identified pre-school / day care centers? Have e.greements been reached with bus drivers or " volunteer" drivers to evacuate these chilacer.?
If yes, please provide a copy of any such written agreement or a summary of any.varbal understanding.
If not,
- when are these arrangementsexpected to be co?pleted?
If such agreements are not contemplated, why not?
- 44. Are pre-school / day care staff expectea to remain with children until parents arrive?
If yes, upon what is this assumption basec? If not, what arrangements have been made to supervise, transport and care for these children until their parents pick them up during a radiological emergency.
- 45. Has PEMA any information, data or studies on the effect that the use of
" stranger" volunteers will have on the transportation of pre-school and day care children? Will parents be asked to authorize tne release 'of their pre-school or
~
si uay care children to the care of unidentified, unnamed people in the event of a radiological emergency? What special training, if any, will such volunteers or emergency workers receive in dealing with pre-school evacuees?
- 46. How will parents be notified of their children's whereabouts?Will
_ _ carents be allowed [to enter the EPZ to pick up their children during a_
radiciogical emergency? Will parents otherwise be permitted tc pick up their children at school before they are evacuated from the EP2? Has this facter be:n considered by PDM in traffic congestion studies (especially for the larger day care centers)? Fcr exampic, han the effect on road access been censidered? Will cdditional traffic control points be necessary? Has the additicnal stress on existing tr:ffic control points been considered?
- 47. Will pre-schoolers be evacuated as efficiently and effectively as other school district pupils? What is the status of emergency response planning for day care end pre-school children in Chester, Berks, and Montgemcry Counties? Picase provide cny information PDM has on the current status of Iccal and county plans for pre-sch:01 children, as well as any " unmet needs" that PE.'m will br addressing in this regtrd.
48.' What consideration has been given to the capability of day care and pre-school buildings in the event that sheltering is the protective measure that is recommended?
'How will the adequacy of these buildings for sheltering purposes be determined? hhat infcrmation is available to determine if sheltering is an acceptabic protective measure in the event that there is not sufficient time to evacuate during a radiological emergency?
- 49. What measures will be or have been taken to insure that such centers (day care E4 6 pre-school) have adequate radio /TV/ phone communications for receiving information to dstermine appropriate response during c radiological emergency?
- 53. Who is the designated official from PDM that is responsibic for reviewing s
{
" unmet needs" on the issue of emergency response planning for children in pre-school and F
[
day care programs?
=
l l
12
~
51.
WITH RECARD TO CONTENT 12 LEA-24/F0E-1, PLEASE PROVIDE ANSWERS TO ANY OF THE F O I.f.0 W I N G OIICSTIONc, THAT PEMA HAS K N Oh'1.E D G E OF:
- 1. A part of Upper Merion Township is within the 10 mile zone. Was "pper_Merion cffered an opportunity to be includel in Ecergency Plann'ing for the township ?Countyl
- 2. If not, why not ?
Wil'. Upper Merion be included in EM.PL. now?
How soon ?
- 3. Has there been contact with U.M. 's township Mgr. ? The Emerg. Planning officer ?
- 4. If there has not been contact, how soon will this be initiated.?
- 5. Has the present traffic study by U.2. been considered in evacuation plans ?
~
- 6. How many vehicles daily travel into the King of Prussia area.?
- 7. How many vehicles (& people) terminate there for work, school,etc.?
- 8. How many commuting vehicles travel through K.of P. daily ?
- 9. What are the peak travel hours ? What are the times and peak # vehicles ?
- 10. What are the peak shopping days and hours for E.of P.? # of vehicles, people ?
- 11. What is the peak # of vehicles and people to be evacuated on max. shopping / work
?
Bay ?
- 12. Since U.M. is partly in th, ;r cile zone will E;.fl. be made for these people
- 13. Will Em.Pl. be made for a-.
the r iden's c." U.V.
?
- 14. Is the Schuylkill Ex;reenway partly closed for repairs ? For how many years,
- 15. What is therecordofblockedtrarficonSch.Exp.? Daily?Howlong?f;?eRiUI.i
- 16. PEMA 6/83 Evac. Map showns nc =vacuation south on the Sch.Exp. Will it be blocked
- 17. Evac. Route south on # 363 is routed to d202 and # 76 onto the TPK.(276) east.
How will this traffic enter the TPE, through the toll oouths?
/pr.,
Will all vehicles pick up cards ?.'lill -/.na-be detours through and around bootht 18.Whynoevacuationeaston#202.?'Wi$1itbeblocked?
- 20. How often are there blockager at Valley Force exit of TPV
? For how long ?
What are
- 21. How often are there commuter blockages on !! 202, # 252 ? daily slow-down hours ?
- 22. Evac. plan from Varey Forge Park on the m p is via#252 and # 202 to w.coshen.
e How will parents of schoo? children in
.:.e Purk i: to'.ified of whereabouts. ?
- 23. Map shows 4222 autos in (4) hours passing a point on # 252. Is this auto total derived from PennDot cverage traffic counts ? ar-these counts based on normal mph rate'rather than the er timated pa.. sing of 4222 utos in (4) hours in evac. ?
- 24. How does the estimate of 9499 autos passing on // 363 in(6) hours contrast with normar rate 9
- 25. Is there an evacuation plan for Valley Force Park ?
- 26. Have Park officials been consulted ? If not,when will they be ? If there is no present evac. pl. for the Park,when will there be one ?
27.Has a U.S. Dept. of Com=erce Nov.'94 report Industrial Impacts of Hypotheti-cal Accidebts at the Limerick Nuclear Reactor " been used in Emer.Pl. ?
- 27. Have indus tehe in K.of P. area been cons".I ted on Ecer.Pl.? Indus tries in 10 milzote I
- 20. How will gasoline / diesel fuel supply be assured for evacuation ?
- 29. Will gas stations on evacuation routes be designated f or evaa. emergency ?
- 30. Eave any shopping calls and centere in K.of P. been consultec re. evac.pl. ?
- 31. If not, when wil:.hef be ?
CERTIFICATE O igi;; K gC r.
g.g., 7 Gs:.h[
I hereby certify that the following in f o rma tion vag4 s egupp P4 :17 upon the following parties by first class mcil. postage prepaid, with Express Mail Service to tnose on the service list beside whose name appears an asterick (*):
...,. -i. : a.;
m
...,R HCH
..a 4 37,_
LDi's First Set of Interroratories on "Off-site" E rn e r g e n c y Planning Contentions to PZMA Transmittal of " missing" page 9'from LEA Findings of Fact and Conclusions of Law on Cnntention I-42
'o) Lawrence Brenner, Chairman (2)
(*yAnn P. Hodaden, Esq.
Administrative Judge U.S. Nuclear Regulatory Office of the Executive Legal Director U.S.
Commission Nuclear Eegulatory Commission Washington, DC 20555 Washington, DC 20555 c) Dr. Richard F. Cole
(<-) Benjamin Vogler, Esq.
Administrative Judge Office of the Executive Legal Director U.S.
U.S. Nuclear Regulatory Nuclear Regulatory Commission Commission Washington, DC 20555 W2shington, DC 20555
(*) Troy B. Conner, Jr., Esq.
Dr. Peter A. Morris Conner and Wetterhahn
- 3) Administrative Jud 1747 Pennsylvania Ave., NW ge U.S. Nuclear Regulatory-Washington, DC 20006 Commission Washington, DC 20555 Philadelphic Electric Company Attn:
Edward G.
Bauer, Jr.
Docksting and Service Section VP anel General Counsel Office of the Secretary 2301 Market St.
Phila., PA 19101 U.S. Nuclear Regulatory Commission Wachington, DC 20555 Thomas Gerusky, Director Bureau of Radiation Protection, DER At mic Safety and 5th fl, Fulton Bank Bldg.
Licensing Board Panci Third and Locust Sts.
U.S. Nuclear Regulatory Harrisburg, PA 17120 Commission Wachington, DC 20555 Spence W.
Perry, Esq.
Associate General Counsel FEMA s
Atomic Safety and Room 840 3
Licensing Appeal Panel h
500 C St.,
SW U.S. Nuclear Regulatory Commission Washington, DC 20472 Wachington, DC 20555 Zori Ferkin, Esq.
Dd Governor's Energy Council P.O. Box 8010 1625 Front St.
Harrisburg, PA 17105 i
k l
r e
Jay M.
Gutierrez, Esq.
Robert Sugarman, Esq.
- ~
U.S. Nuclear Regulatory Commission Sugarman and Denworth Region i Suite 510 631 Park Ave.
North American Building King of Prussia, PA 19406 121 S.
Broad St.
Phila., PA 19107 1'
-D,irector,'PEMA Basement, Transportation David Wersan, Esq.
and Safety Building Assistant Consumer Advocate Harrisburg, PA 17120 Office of the Consumer Advocate i
1425 Strawberry Square
, Esq. / M.g gy., g XId)
Harri.e, burg, Psi 17120' i
Angus: Love, C
10 7 East Main St.
L Norristown, PA 19403 Gregory C.
Minor Robert Anthony Miin Tec t.n i ca l Associates 103:Vernon Lane 1723 FamtItan Ave.
Moylan, PA 19065-San Jose, ca. 95125 Martha W.
Bush, Esq.
Timothy Campbell Kathryn S.
Lewis, Esq.
Solici tor's Of fice Chester County Dept.
of Emerger.cy Services City of Philadelphia 14 East P,iddle S'
eet Municipal' Services Building West Chester, Pa. 19380
[
Phila., PA 19107 r
Steven I!crshey, Esq.
conmunity. Legal Services 521't Chestnut St.
Phila., PA 19139
'Marvin I.
Lewis 6504 Bradford Terrace Phila., PA 19149 Frank Romano 61 Forest Ave.
I Ambler, PA 19002 Joseph H. White,III t
15 Ardmore Ave.
Ardmore, PA 19003
/
3
' June 22, 1984 kgu/n
/_M L!AV.
PRESIDESI MAURCEN MULLIGAN, m
,,e--y.r.,
,,,.7_g
..n...
--m
,_y.-r
--w-
-.---erw-
..y
,,.w--
.y y
7---
--,--,,~