ML20092P776
| ML20092P776 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/25/1984 |
| From: | LIMERICK ECOLOGY ACTION, INC. |
| To: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8407090362 | |
| Download: ML20092P776 (13) | |
Text
D TiELATED CCRRESPONDENCE
$f,','.539 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- d4,fg g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD __,
In the Matter of Docket Nos. 50-352 PHILADELPHIA ELECTRIC COMPANY 50-353 (Limerick Generating Station, Units 1 and 2)
LIMERICK ECOLOGY ACTION'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE PHILADELPHIA ELECTRIC COMPANY ON LEA'S ADMITTED "OFF-SITE" EMERCENCY PLANNING CONTENTIONS Pursuant to the Rules of Practice and Procedure of the Nuclear Regulatory Commission (NRC), 10 C.F.R. 8 2.740(b), and the Orders of the Atomic Safety and Licensing Board in this proceeding, Limerick Ecology Action hereby propounds the follow-
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ing interrogatories to the Philadelphia Electric Company to be answered fully in writing, under oath, in accordance with the definitions and instructions set forth below. Additionally, pur-suant to 10 C.F.R. 8 2.741, Limerick Ecology Action requests that Philadelphia Electric Company (FECO) produce copies of those documents designated by it in its respective answers below.
Definitions and Instructions l
1.
For each interrogatory, please state the full name, work address, and title or position of each person providing information for the answer to the interrogatory.
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2.
The following definitions shall apply:
a.
"PEC0" shall refer to the Philadelnhia Electric Co ra p a ny, or any official, officer, member, employee, or consultant thereof, including Energy Consultants, Inc.
b.
" Document" shall mean any written, printed, typed or other graphic matter of any kind or
- nature, computer tapes or other electronically stored or generated material, and all mechanical and electronic sound recordings or transcripts thereof, in the possession, custody, or control of f
g PECO, or its o f f i c i r. l s, employees, or consultants; f
b it shall also mean all copies or drafts.of g
documents by whatsoever means made.
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c.
"Date" shall mean the exact day, month and A
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year.,.if ascertainable,
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or, if not ascertainable,
$p the best appr.oximation (including the event's E
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relationship to other events in the relevant EE c.ontext of the interrogatory).
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d.
"NRC" or " Commission" shall mean either the ifI iEd Atomic Energy Commission or the Nuclear Regulatory 5 11[
Commission,- as appropriate, including its regu-l latory staff and adjudicatory boards, as indicated
.g by the context of the interrogatory.
FE g@
e.
"Specify",
when referring to a
sa proceeding before the Nuclear Regulatory Commission, means Es5.'
that the answer shall set forth the proceeding, h
inB applicant, docket number, relevant date, and any liiiff SiiF Ei rW IIlhi
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3-other descriptive information appropriate to the request.
f.
"Specify" or " identify", when referring to an individ'ual, corporation, or other entity, means that the answer shall set forth the name, present or last known work address, and, if a corporation or other entity, its principal place of business or, if an individual, his or her title or titics and employer.
Once an individual corporation or other entity has been thus identified in answer to an interrogatory, it shall be sufficient thereaf-ter when identifying that individual, corporation or other entity to state merely his, her or its name.
3.
These: : interrogatories e
request. all. knowledge and
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information in PECO's.
possession and/or knowledge, and-N information in the possession of PECO officials, officers, agents, representatives, consultants, and unless privileged attorneys.
=g 4.
In each instance in w ch an interrogatory re-quests a statement of PECO's assertion, contention, view or N
ww opinion,-the answer shall also contain a full discussion of EE 3
the factual basis for the assertion or opinion D
EE Interrogatories 3
'55?
WITH REGARD TO LEA ~14:
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(AND LEA-12)
Please~ discuss " training" provided for school h
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personnel.
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gig lias all school training been completed? If not, please provide gl.x ww a schedule indicating,when outstanding n;-
training is to be completed.
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4 Please clarify the role played in such " training" by representatives from PEMA, ECI, and the County Offices of Emergency Preparedness.
2.
Does PECO or ECI have any information or knowledge about whether or not such training covers roles and responsibilities assigned to school personnel during a radiological (uergency, especially in regards to sheltering and/or multiple trip evacuation scenarios?
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3.
Would adequate supplies of K1, dosimetry, and communications equipment be available during a sheltering and/or a multiple trip scenario?
How and when would these be distributed?
4 Does PECO plan to present any witnesses regarding the L
willingness of teachers and school staff to perform their assigned roles in sheltering,< evacuation or' multiple trip evacuation 3
scenarios? Does PECO have any.information regarding the willingness of school staff;to remain with school-children while:at a-host-school or mass care center?-
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Ilow have teachers been informed of their responsibilities at school in the event of a radiological emergency? Provide the results of any surveys that PECO or EC1 has knowledge of' that indi-I!;
cate the number of school staff willing to participate and remain on
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duty in the event of a radiological-emergency: What arrangements-have Ef g;.,
been made for the families of teachers who are willing to remain on Itr$
duty.during a radiological emergency? If such arrangements have not '
been made, wha t rassurance51s th ere that teachers will remain on duty rather than leave to pick up their own children or family members?
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6.
Provide a list of teachers and school staff willing to remain
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- r ohtdutyfwith children in the event es of a radiological emergency.
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Provide a description of the information provided to these teachers cao.L fi:e
5 at the time the commitment was made to remain on duty during a radio-logical emergency.
7 What procedure is used if a teacher changes his/her mind about volunteering, or for some reason decides to leave the arca?
(and no longer work at the same school) Who do they notify if they longer want to be considered a no volunteer? Is the teacher or school staff memb'er cxpected'to find a replacement volunteer or does that slot remain open?
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8.
Describe the nature of the contact with the teacher / staff person
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when asked to volunteer and the 'date of commitment. Did they hive to H
give an answer"on the spot"?
y 11 9.
What is the staff / student ratio considered to be adequate to E
- 9 remain with children in the event of a radiological F
emergency. Picase 1
differentiate between a sheltering and evacuation a:
scenario.
i; 10.
Are teachers who are being asked--to stay.zbehind with the children- ':.:
.2 being offered overtime pay, and if not, was this information provided
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to them at the time that they volunteered to participate?
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11.
Provide a list of the responsibilities the teachers / staff who
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en remain with the children take on if they volunteer. Are these same si ix volunteers trained and expected.tc fl shelter children? What information is
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being used to train staff / teachers hbout what to do in a sheltering ys situation.
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12.
How will school. districts determine which buildings si5 are suitable
-S mm for use sheltering students during a radiological nr emergency?
=t 13.
Discuss PECO or ECI's response to the concerns raised by Upper A.-
Parkiomen School District about whether or not " training" was adequate.
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6 WITH REGARD TO LEA-27:
14 Please provide any information cvailable to PECO cr ECI about the status of emergency response picnning for Spring Mountain House, Camp Hill Village Schoci (West Vincent Twp.), and Camp Hill Special School (East Nantmeal Twp.). Are these facilities included in their respective municipal plans or are separate plans being developed for them? Please provide any information available about arrangements for:
(a) training of personnel (b) transportation assistance in the event cn evacuation is called for I
(c) suitability of these facilities for sheltering, including the length of time under various possible scencrict that sheltering r
would provide adequate protective action (d) arrangements'for communications with these facilitics during a radiological emergency (especially with the county and/or the municipality involved) j
.4.
With regard to (b) above, please describe
..a thenumberofvehiclesnecessary,]
where they will be dispatched from, how long it will take these vehicles 5
to arrive at their designation, and who will provide drivers for these
- s vchicles.
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15.
What are the reception centers and mass care center arrangements
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that have been made for these facilities? If none have been completed, I
who is esponsible for seeing that these arrangements are completed?
5 16.
What is the resident population that is being planned for at the M"
facilities discussed in LEA-27? Provide any information about special h[
transportation needs for the handicapped or those requiring ambulance e:
assistance. If ambulances are involved, where will they be coming from?
Who is responsible for assigning and dispatching ambulances for these la
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facilities? Have letters of agreement been completed? If not, why not?
$h WITH REGARD TO LEA.28:
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17.
How many vehicles are available for use by the Pa. National
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Guard for providing fuel supplies and towing services in the Limerick s
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Plume EP;? Picase provide a descriction of the type of vehicles Fi'
7 available for use by the National Guard, their approximate location,
'where they will be dispatched from, and any other information available te PECO or ECI.Have letters of agreement been provided for the use of these vehicles? Arc letters of agreement necessary for the use of these vehicles? If not, why not. If yes (and they have not been completed) when will these letters of agreement be co=pleted?
- 18. Please provide the same information about the availability cf vehicles for provision of fuel supplies and towing services that would be applicabl.e for use on non-state roads. (question 17 refers to state roads)
- 19. Provide a list by township or municipality of:
(a) tow trucks that locations of gasoline supplies,are availabla during a radiological emergency (b) including a listing of gas stations that will remain open during a radiological emergency
- 20. llave letters of agreement been completed for the use of tow trucks and provision of gasoline supplies (as discussed in question 19) for (a) state roads t
(b) non-state roads 4
1 If not, which ones are still outstanding? Please provide copics of all completed letters of agreement, y
h'bo is responsible for snow removal 21.
on state reads during a radio-
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y logical emergency? Provide any information that will be u:ed by PECO to EE EE demonstrate that this responsibility has been assigned and will be carri fili out in the event lif5 of a radiological emergency. If state employees are hf involved, does their contract require them to carry out their regular 25 gg work dutics in the event of a radiological 55 emergency? If yes, please be specific. If not, how can it be determined that there will be adequate
$3 personnel to assure that snow removal will not (ff?
impede any evacuation.
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- 22. Provide the same information requested in #21 above as it w.
relates to
,:cyc errangements for snow removal
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on non-state roads. Provide any letters of a=:=
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8 agreements that have been completed to cover arrangements for snow removal. If none are required, please explain why.
23.
When will training be offered to tow truck drivers, gas station attendents, and personnel involved in snow removal during a radiological emergency? If not, why won't it bc? Are these personnel considered emergency workers? Is there any length of time that they would be expected to carry out their assigned duties during a radiological emer-gency? Have th'y been tc1d this? When and by whom? (For example, if a f
e gas station agrees to remain open to provide fuel supplies, how long do l
b they have to remain in the EPZ before they can evacuate?)
j 24.
If a gas station agrees to remain open but for some reason is n
d not abic to do so during a radiological emergency, are there any penalties [
or liabilities to the gas station owner or manager (or the person who E
E made the written or verbal commitment to provide these services during E
a radiological emergency?)
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- 25. For gas stations E
expected to remain open during a rad,iological 1
emergency, provide any information availabic e
0 tamount of gasoline available at each gas station at any given time? How ycb
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ill arrangements be made to insure that gas tanks are kept full at all Lw f3;
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,cs at these stations? Have these stations agreed to keep a certain re-
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e availabic at all times? If yes, what is it (by gas station)?
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'\\ ovide any information availabic to B5 g
po indicate how much gasclin2 is y.]
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s&O o supply an evacuation of the Limerick EP2? Have any studies been a
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,3 surveys of any' kind) rr T *pt 55 t
Cys surance is there that employees at gas stations will remain
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pg a radiological emergency? b'h a t happens if they don't?
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.covide a description of the equipment avellabic for use by the EE ra. National Guard. Please be specific about the number and type of
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9 vehicles available, their location, and any information available to PECO or ECI about the time necessray to dispatch and mobilize this equipment.
29.
How many National Guard members can be mobilized by each of the Bata11 ions assigned to cover the Limerick EPZ? In what length of time?
Provide the basis for all information supplied'.If additional persoanel and/or equipment is needed, where will it come from? How much mobiliza-tion time is involved? Provide information specific to each Batallion that will be involved when answering the above.
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30.
Does PECO intend to provide any expert or factual witnesses 1
on LEA-287 If not previously identified in response to LEA's first set of interrogatories, please identify PCCO's witnesses, and provide answers to questions 1-7 as stated in LEA's First Set of Interrogatories.
31.
Is there a direct telephone line betwec:. PEMA and the National
_r Guard? Provide any information available to PECO or ECI about communi-
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E cations equipment and capabilities of the National Guard.
WITH RECARD TO LEA-26:
d.
32.
_ hat is the basis for assigning fire company personnel to the task g_
W
- ..E of " route alerting"? Have firemen been m
Ei surveyed to determine how many EE are willing to participate during a radiological emergency?
b.
33.
If no survey has been done of the firemen (as discussed above is the basis for determining that there will be sufficient personnel gg available to carry out route alerting during a radiological
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emergency?
Ej 34.
What other responsibilities have been assigned to firemen during
[f2 radiological emergency. Provide a
r.2 specifics by municipality, as well as f~
for firemen coming in to assist from outside the EP2. In the event a municipality finds that it does not have sufficient personnel for
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route alcrting, how will additional assistance be provided? By whom?
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- 35. What equipment is necessary to have available for " route alerting"?
Be specific by providing resource li: ting by municipality.
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- 36. Provide any information that will be relied upon by PECO to demonstrate the amount of time necessary to carry out route alerting as a notification procedure in the event of siren failure. Be specific as to whether the information refers to coverage of the entire EPZ (such as might occur in the event of a loss of power) or isolated siren failure.
37.
Provide any information to document 1
the extent of communications links to be tested during the July 25 ' test drill'. Provide any written in formation that' PECO has any knowledge of. Discuss the minimum standards that are required for each link to remain useful a
and viable during E
a radiological 3
cmergency with regard to notifications and communi-cations with emergency workers, both within and outside of the Plume e
EPZ for Limerick. If PECO has no evaluation of what it considers the 15
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minimum standards needed to successfully be implemented during a
radiological emergency, explain its basis for making a determination that communications capabilities with emergency workers are adequate.
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- 38. Provide any additional information about i
arrangements for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> EBS coverage to each " Risk" and Support County. Are'1etters of agreement 5
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-E necessary? Have'they been completed? Is yes, please provide copies.
$k WITH REGARD TO LEA-24/F0E-1:
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- 39. Provide any information that will bc relied upon by PECO to
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gg demonstrate the impact of traffic congestion in the following areas:
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EW 3:
(a) Valley Forge National Park and King of Prussia area Eq (b) Marsh Creek State Park gg (c) Route 100 South from Pottstown to Exton Mall
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- 40. If PECO does not anticipate any traffic congestion in these areas, fh please provide all information to be relied upon as a basis for PECO's position. Be specific.
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141.
WITH REGARD TO CONTENTION LEA-24/F0E-1, PLEASE PROVIDE ANSWERS TO ANY OF THE FOLLOWTNG OllESTIONS THAT PECOHAS KNOWLEDGE OF:
)
- 1. A part of Upper Merion Township is within the 10 mile zone. Was 5pper..Merion offered an opportunity to be included in Emergency Planrring for the township ? county?
- 2. If not, why,not ? Will 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.M. 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 K.of P.? # of vehicles, people ?
- 11. What is the peak # cf vehicles and people to be evacuated on max. shopping /vork say 7
- 12. Since U.M. is partly in the 10 mile zone will Em.Pl. be made for these people ?
- 13. Will Em.Pl. be made for all the residents of U.M. ?
- 14. Is the Schuylkill' Expressway partly closed for repairs ? For how many years, 15.WhatistherecordofblockedtrafficonSch.Exp.? Daily?Howlong?#NilNie
?
- 16. PEMA 6/83 Evac. Map showns no evacuation south on the Sch.Exp. Will it be blocked ?
- 17. Evac. Route south on # 363 is routed to r/202 and # 76 onto the TPK.(276) east.
How will this traffic enter the TPK, through the toll booths?
/Pr.,
Will all vehicles pick up cards ? Will there be detours through and around booths
- 18. Why no evacuation east on #202.7 Will it be blocked ?
- 19. Why no evacuation west on PA. TPK (76) ? Will it be blocked ?
- 20. How often are there blockages at Valley Forge exit of TPE ? For how long ?
What are
- 21. How often are there commuter blockages on # 202, # 252 7 daily. slow-down hours ?
- 22. Evac. plan from Valley Forge Park on the m p is vis#252 and # 202 to W.conhen.
e How will parents of schoolchildren in the Park be notified of whereabouts. ?
- 23. Map shows 4222 autos in (4) hours passing a point on # 292. Is this auto total derived from PennDot average traffic counts ? Are these counts based on normal sph rate rather than the estimated passing of 4222 altos in (4) hours in evac. 7 B4. How does 'the ewtimate of -9499 autos passing on # 363 in(6) hotirs contras+I' with norma rate 7
- 25. Is there an revacuation plan for Valley Forge 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 Commerce hov.'84 report " Industrial Impacts of Hypotheti-031 Accidehts at the Limerick Nuclear Reactor " been used in Emer.Pl. ?
- 27. Have industrJes in K.of P. area been consulted on Emer.Pl.1 Industries in Igl9
- 28. How will gasoline / diesel fuel supply be assured for evacuation ?
- 29. Will gas stations on evacuation routes be designated for evac. emergency ?
- 30. Have any shopping malls and centers in K.of P. been consulted re. evac.pl. ?
- 31. If not, when will they be ?
- f
~.7,E' u n r.w CERTIFICATE OF SERVICE
'84 JLL -3 A10:4.2 I hereby cert'ify that L F ". :....z..
by.first class mail, the following have been served by depjj(:y/'
cy e
postage prepaid, upon the service below this 25th, day of June 1984:
list LEA's Second Set of Interrogatories LEA's Second Set of Interrogatories to Philadelphia Electric Co.
to PE!!A Lawrence Brenner, Chairman (2)
Administrative Judge Ann P. Hodgdon, Esq.
U.S. Nuclear Regulatory Office of the Executive Legal Director Commission U.S. Nuclear Regulatory Commission W3chington, DC 20555 Washington, DC 20555 Dr. Richard F. Cole Benjamin Vogler, Esq.
Administrative Judge Office of the Executive Legal Director U.S. Nuclear Regulatory Nuclear Regulatory Commission U.S.
Commission Washington, DC 20555 W3chington, DC 20555 Troy B. Conner, Jr., Esq.
Dr. Peter A. Morris Conner and Wetterhahn L
Administrative Judge '
1747 Pennsylvania Ave., NW h
U.S. Nuclear Regulatory-Washington, DC 20006 Commission W3shington, DC 20555 Philadelphia Electric Company m
Attn:
Edward G. Bauer, Jr.-
Docksting and Service Section VP and General Counsel Office of the Secretary 2301 Market St.
U.S. Nuclear Regulatory Phila., PA 19101 Ctmmission W3chington, DC 20555 Thomas Gerusky, Director fR Bureau of Radiation Protection, DER IEE Attmic Safety and 5th fl, Fulton Bank Bldg.
$5 Licensing Board Panel Third and Locust Sts.
U.S. Nuclear Regulatory Harrisburg, PA 17120 C;mmission W3Dhington, DC 20555 Spence W. Perry, Esq.
Associate General Counsel E=
Atomic Safety and FEMA HE Licensing Appeal Panel Room 840 MJ.
U.S. Nuclear Regulatory 500 C St., SW H!E Commission Washington, DC 20472 l ll W20hington, DC 20555 2f::
Zori Ferkin, Esq.
1 Governor's Energy Council
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P.O. Box 8010 n;. t 1625 Front St.
15ar llarrisburg, PA 17105 Mft
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t.'IN "
4 Ei I
1 i
Jay M.
Gutierrez, Esq.
Robert Sugarman, Esq.
U.S. Nuclear Regulatory Commission Region 1 Sugarman and Denworth
]
631 Park Ave.
16th Floor k
King of Prussia, PA 19406 191 S. Broad Street E
Phila., Pa. 19107 Director, PEMA l
Basement, Trdnsportation David Wersan, Esq.
l and Safety. Building Assistant Consumer Advocate
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Harrisburg, PA 17120 Office of the Consumer Advocate d
1425 Strawberry Square Angus Love, Esq./M g g7 Ald)
Ha M sburg, PA 17120 C
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107 East Main St.
Norristown, PA.19401
,I n
Gregory C.
Minor Robert. Anthony
[j 103 Vernon Lane MHB Technical Associates 5
Moylan, PA 190'65 17 2 3 Hamil ton-Ave.
5 San Jose, CA. 95125 5
if Martha W.
Bush, Esq.
Kathryn S. Lewis, Esq.
Timothy Campbell :
Solicitor's.O.ffice Chester. County. Dept.
. v.
City of Philadelphia f Emergency Services
- g Municipal Services Building 14 East Biddle Street-
,jj Phila., PA 19107 West Chester, Pa. 19380" -
rg Steven Hershey, Esq.
- rl community Legal Services-q 5219 Chestnut St.
21 Phila., PA'19139
- rl Marvin I.
Lewis 15 m
6504 Uradford Terrace 5
Phila., PA 19149 E2
~ ~ '
%.s Frank Romano F.5 61 Forest Ave.
gg Ambler, PA 19002-
. gu.a ED Joseph H. -. White,III ti.i t=a 15 Ardmore Ave.-
g.g.
m Ardmore, PA 19003 ma 15 5 5
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'E June 25, 1984 ng MAUREEN MULLIGAN, EA V.
PRESIDENT he sij 55F f5f I
.