ML20100G438
| ML20100G438 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/04/1985 |
| From: | Ferkin Z, Otto T PENNSYLVANIA, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20100G411 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 OL, NUDOCS 8504080250 | |
| Download: ML20100G438 (20) | |
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.d4 I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'65 APR -5 A!0 :08 CFFIC Cr SECEETARY Before the Atomic Safety and Licensing Board 00CKE gSE8V.Cf in the Matter of
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PHILADELPHIA ELECTRIC COMPANY
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Docket Nos.
50-352
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50-353 (Limerick Generating Station,
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Units 1 and 2)
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ANSWER OF THE COMMONWEALTH OF PENNSYLVANIA TO PROPOSED CONTENTIONS OF THE GRATERFORD INMATES WITH REGARD TO THE EVACUATION PLAN I.
INTRODUCTION On April 20, 1984, the Atomic Safety and Licensing Board ordered the Graterford inmates to submit specific contentions within 20 days following the receipt of the evacuation plan for Graterford. On December 13, 1984, counsel for the inmates received a " sanitized" version of the evacuation plan for Graterford. On December 19, 1984, the Graterford inmates moved for full disclosure of the Graterford plan, as well as asking for additional time in which to file their contentions. On January 29,1985, the Board denied the inmates' motion for full disclosure and ordered them to submit their contentions within 20 days.
Counsel for the inmates filed proposed contentions on February 15, 1985.
In response to the January 29, 1985 order of the Board denying any further disclosure, counsel for the inmates filed an appeal with the Atomic Safety and Licensing Appeal Board on February 8,1985. Although the Appeal Board dismissed the appeal of k [D O h 53 9
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the inmates', the Appeal Board also expressed its opinion that the parties should attempt to find a middle ground with regard to the disclosure issue.
In response to the language in the Appeal Board order, this Board held a hearing on February 27, 1985, between the parties to try and find a middle ground. Using the proposed contentions of the inmates as a structure for the hearing, the Board reviewed each contention with all the parties and had counsel for the inmates specify what information would satisfy him.
As a result of that hearing, the Commonwealth of Pennsylvania (hereinafter Commonwealth) filed a Response of the Commonwealth of Pennsylvenia, Department of Corrections to Request for Information Raised at the February 27, 1985 Atomic Safety and Licensing Board Conference. Furthermore, the Commonwealth made available to counsel for the inmates, as well as other interested parties, a substantially less sanitized version of the plan under the aegis of a protective order and affidavits of non-disclosure. On March 22, 1985, another hearing was held with the interested parties present. At the conclusion of that hearing, counsel for the inmates had not withdrawn all of his proposed contentions, and had raised some new
" concerns".1 This is the Answer of the Commonwealth to the remaining contentions and new " concerns". Our answer will use the same format as the proposed contentions of the Graterford inmates, including answers to the new " concerns" where appropriate.
II. GENERAL CONTENTIONS A.
Counsel for the inmates has not withdrawn his proposed contention. The Department of Corrections objects to the language in the proposed contentkon that refers to the staff of the State Correctional Institution at Oraterford since counsel for the inmates only has standing to represent the Graterford inmates pursuant to the 1.
The term " concerns" is used to describe the new matters raised by counsel for the inmates at the March 22, 1985 Hearing. The Board correctly viewed the actions of counsel for the inmates as attempts to amend or add to his original proposed contentions.
The Commonwealth agrees with the Board but addresses the new concerns here to ensure our position is clear.
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^ Atbmic Safety and Licensing Board Order in this case at Philadelphia Electric Company s
(Limerick Generating Station, Units 1 and 2), LBP-83-39, 15 NRC 1423 (1982).
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Furthermore, the Commonwealth objects to the proposed contention because it is not reasonably specific and is unsupported by specific bases.
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B.
Counsel for the inmates has not withdrawn this proposed contention. The Commonwealth objects to this contention since it is again not specific and raises no 1
j litigable issue in itself. It also is overly broad in that it is not limited to representing
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the interests of the inmates.
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. C.
Counsel for the Graterford inmates withdrew this proposed contention at the March 22,1985 Hearing at Transcript Pages 20,677-20,678.
i Ill. SPECIFIC BASES FOR CONTENTIONS A.
Transportation 4
At the ~ March 22, 1985 Hearing, Mr. Love was satisfied that there would be i
l a sufficient number of buses, vans, ambulances and drivers available to complete the l
l evacuation. His satisfaction was indicated at the March 22, 1985 Hearing at Transcript i
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Pages 20,678 through 20,681. Therefore, the transportation issue is resolved.
B.
Preparation for Evacuation
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. Manpower i
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At the February 27, 1985 Hearing before the Atomic Safety and l
Licensing Board,. Mr. Love was asked what concerns he had regarding the manpower issue. At that. time, he requested information regarding the call-up procedure and was given that information. Furthermore, Mr. Love requested information regarding whether the system worked. He also requested information regarding the number of offleers in l
the compliment at the State Correctional Institution at Graterford and explained that j
the National Guard was not a necessary part of the evacuation plan, as they were only being used for back-up (see Tr. 20533 through 20537).
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. 4 In the Response of the Department of Corrections to the Request for Information, the Department of Corrections indicated the specifies of the call-up system.
Furthermore, we provided the information that the system was tested as of January, 1985, and the system worked.
We also provided information regarding the number of officers and other employes available to conduct the evacuation.
i At the March 22, 1985 Hearing, counsel for the inmates indicated he j
was satisfied with the amount of manpower (see Tr. 20,681). However, counsel for the 4
inmates then raised new " concerns" regarding the manpower issue.
One concern was 1
j with the use of commercial telephone lines in the call-up system and the second.was j
with regard to the lack of correctional officer union participation in the hearings before i
the board.
With regar'd to the commercial telephone line issue, the Department of
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Corrections objects to what would result in a new contvtion. Counsel for the inmates has not shown any good cause for his failure to include this with his original proposed contentions and to fully litigate this issue would significantly delay the proceedings.
l Counsel for the inmates can protect the interests of his clients with regard to the i
i commercial telephone line issue by expressing his concerns to either the Federal 4
Emergency Management Agency (FEMA) or the Pennsylvania Emergency Management 4
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Agency (PEM A). He has offered no information regarding any possible testimony that 4
would help this board in developing a sound record.
With regard to this issue, the f
counsel for the inmates has not shown how the inmates' interests are any different j
than other individuals with regard to the evacuation and, therefore, the inmates' interests were represented by other intervenors. For all the reasons referred to above, we would -
suggest that this new " concern" should not be admitted due to its lateness in filing.
l The Commonwealth further objects to this concern due to counsel for l
the inmates having. no basis for his contention.
Furthermore, it lacks speelficity
i and, thus, falls to meet the requirements of 10 C.F.R. 6 2.714(b).
We also suggest i
that this is not a litigable issue and should be dismissed for that reason.
The other new " concern" that counsel for the inmates raised was with regard to the participation of the correctional officers at the State Correctional
~1nstitution at Graterford in the evacuation plan.
Again, counsel for the inmates has not offered any reason for the lateness of this contention and has certainly not met the good cause standard in 10 C.F.R. 4 2.714(a). It is clear, even in the sanitized j
version of the evacuation plan filed with this Board on December 13, 1984, that the correctional officers would play a significant part in the evacuation. It is clear that any additional testimony on this issue would broaden the issues and delay this proceeding.
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Therefore, we request that the contention not be admitted due to its lateness.
1 The Commonwealth -also objects to the proposed contention because i
counsel for the inmates has expressed no basis for his contention.
Additionally, it is j
not reasonably specific and, thus, falls the requirement of 10 C.F.R. I 2.714(b). Finally, since the correctional officers are employes of the-Commonwealth of Pennsylvania, Department of Corrections, they are subject to discipline for failure to obey direct j
orders. The Commonwealth of Pennsylvania, Department of Corrections would be the party to provide testimony with regard to the officers participation in the plan.
1 2.-
Security Equipment J
Counsel for the inmates was satisfied with the provision of security equipment for the evacuation. This is indicated on Transcript Page 20,681 of the March 22, 1985 Hearing.
3.
Communications Equipment
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Counsel for the inmates was satisfied with the provision of l
communications equipment. This is indicated on Transcript Pages 20,681-2 of the March I
22,1985 ' Hearing.
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. l 4.
Radiological Equipment Counsel for the inmates was satisfied with the provision being made for radiological equipment. This satisfaction is indicated on Transcript Page 20,682 of the March 22, 1985 Hearing.
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C.
Notification to the Public Counsel for the inmates was satisfied with the notification system in place.
This satisfaction is indicated on Transcript Page 20,682 of the March 22, 1985 Hearing.
i D.
Medical Services l
l The Commonwealth would object to the proposed contention on this subject since it refers to individuals contaminated by radiation and not solely to inmates (see t
Inmates' Proposed Contention at Page 8).
Counsel for the inmates only has standing to raise issues on behalf of the inmates, and, therefore, the contention, if admitted, must be limited to medical services for the inmates.
At the February 27, 1985 Hearing, counsel for the inmates was requested to specify what information he required on this issue. The relevant responses by counsel for the inmates were "...we just think there should be some mention of what medical services could be provided if someone were seriously contaminated", Tr. at 20,555.
Furthermore, beginning on Tr. Page 20,557 and continuing onto Tr. Page 20,558, the 4
following exchange took place:
Mr. Otto: I think we could offer this at this point:
At our support correctional. institutions, we obviously have contracts - I don't know if it's obvious or not. We have contracts with local hospitals to take care of our inmates when they have serious medical needs, because we really don't run our own hospitals inside of our institutions. And I see~ no reason why those l
hospitals couldn't be used for decontamination.
Judge Hoyt:
If, in fact, those institutions, those medical institutions would l
l have that capability, Mr. Otto, that's the kicker.
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Judge Cole:
Don't we have evidence in our record that indicates that certified hospitals, by virtue of their certification, are qualified to handle contaminated inmate personnel?
Ms. Ferkin:
There is some testimony, and I believe it was addressed in one of the initial decisions, that that was a finding by the Brenner Board.
Judge Hoyt:
I think we had better revise that particular piece of information also, and be certain that we have it.
Now that, Mr. Love, would appear to me that what you're after, and what the D.C. Circuit opinion seems to indicate we need to have.
Mr. Love: Certainly; just an assurance that there is provision for radiological, not just any kind of - Because I assume it's a whole different type of medication (sic).
During further testimony on the medical service issue, the following exchange took place at Tr. Pages 20,561 through 20,562:
Ms. Ferkin:
I think what Judge Cole is referring to - and correct me if I'm wrong -is the Joint Committee on Hospital Accreditation, am I correct?
Judge Cole:
Yes.
Ms. Ferkin:
There is also a certification procedure for hospitals by the Pennsylvania Department of Health which, frankly, I am completely unversed with. I'm not sure how that fits in with what Judge Cole is referring to, but I do recall very clearly the findings that Judge Cole is referring to.
Judge Cole:
And I believe it's a national accreditation.
Judge Hoyt:
Anything else, Mr. Love, ' that you need on the medical services?
Mr. Love: Nothing, just so it's something from the Bureau. Because i don't agree with Mr. Rader that the assurances for the public are sufficient for the inmates, because the inmates are in the custody of the Bureau, and l
1 i anyone that wants to treat the inmates would have to go through the Bureau l-first.
So, I think something has to come forth from the Bureau, j
Pursuant to that-testimony, the Commonwealth had executed, by each of the l
hospitals for the Department of Corrections support institutions, an addendum to the hospitals statement of understanding with the institution. That addendum indicated that the hospital complied with the provisions of the Joint Commission on the Accreditation i.
of Hospitals, Standard 5, which deals with the treatment of radioactively contaminated wounded.
Furthermore, the Commonwealth attached to our response to the request for t
information the Joint. Commission on the Accreditation of Hospitals Standard No. 5, 1
whleh indicated the requirements of that standard.~
At the March 22, 1985 Hearing, counsel for the inmates was not satisfied 1
with what he had originally indicated would be satisfactory and expressed new " concerns".
l His concerns were expressed on Pages 20,665 through 20,671 of the Transcript and 4
i centered around his belief that the JCAH Accreditation was not sufficient to give him a reasonable assurance that adequate medical services were available for the inmates.
The Commonwealth objects to the new "concernN of counsel for the inmates.
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He has not established good cause as to why this late-filed contention is so late. He 4
has also not shown that there are not other means to protect the interests of the inmates with regard to this issue.
Furthermore, this Board has heard substantial testimony with rega d to the sufficiency of medical services for the general public and
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what the standards for the medical care should be. Thus, the inmates' interksts as to J
the standards to be used to measure the hospitals have already been represented by I
existing parties. Any additional testimony on this issue would be cumulative and would certainly delay the proceedings.
For the above reasons, we request that this new
" concern" not be admitted since it was late-tiled.
. The Commonwealth would also argue that this issue has already been litigated in this proceeding. This Board has clearly held in its second partial initial decision that the accreditation by the Joint Committee on Hospital Accreditation indicates that these hospitals have plans for treating contaminated, injured patients. See Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2) LBP-84-31, 20 NRC 446 (1984). The decision by this Board is not affected by the recent District Court opinion in the case of Guard v. NRC, since the Guard opinion only held that a mere list of hospitals for the radiation exposed public was insufficient. In the case presently before the Board, the Department of Corrections has existing agreements with our support institution hospitals, all of which are JCAll accredited.
E.
Monitoring Counsel for the inmates was satisfied with the information provided regarding monitoring. This satisfaction is indicated on Transcript Page 20,683 of the March 22, 1985 Hearing.
F.
Simulated Evacuation Plan Exercise Counsel for the inmates indicated that he would be satisfied with regard to this proposed contention upon receipt and review of the FEMA evaluation of the Table Top Exercise conducted by FEMA, PEMA and the Department of Corrections on March 7,1985 with the reservation that the FEMA Report would indicate that "[the exercise]
is fine, then that would end my concern". Tr. 20,684. Attached as Exhibit A is the FEMA Report on the March 7,1985 Table Top Exercise which states "the Graterford authorities adequately demonstrated an understanding of the emergency [ response procedures and the ability to adequately implement them...".
G.
Training The concerns of the counsel for the inmates were satisfied.
To satisfy counsel for the inmates, PEMA agreed to offer emergency response training to civilian u
,, ar,
,,s
. bus drivers. Counsel for the inmates recognized that we could not force the people to attend this training, but stated he would be satisfied if PEMA sent a letter to the bus providers offering the training. This satisfaction was indicated on Transcript Pages 20,684 through 20,691 of the March 22, 1985 llearing. A copy of the letter that was sent by PEMA is attached hereto as Exhibit B.
11.
Recovery and Reentry Counsel for the inmates was satisfied with the information provided on the recovery ar$d reentry procedures. This is indicated on Transcript Page 20,691 of the March 22,1985 Hearing.
I.
Sheltering 4
Counsel for the inmates was satisfied with the information provided regarding sheltering in the plan. This is indicated on Transcript Page 20,691 of the March 22, 1985 Hearing.
J.
General Concept of Evacuation The Commonwealth objects to this contention since it is lacking in specificity or bases. It appears to be a " catch-all" contention which raises no litigable issues.
At the March 22, 1985 Hearing, Mr. Love raised new " concerns" under this heading (See Tr. 20,693 through 20.694).
The one concern was with regard to the estimated time of evacuation and the second was with regard to the possible panic at the institution during evacuation.
The Commonwealth objects to the " concerns" of counsel for the inmates new concern with regard to the ETE. At the time he filed his original proposed contentions, he was very much aware that it would take six to ten hours to evacuate the institution.
(See Inmates' Proposed Contentions, Page 5.)
At the February 27, 1985 Hearing, he was given an opportunity to raise any concerns he had with regard to the six to ten hour evacuation estimate. Therefore, it is patently obvious that counsel for the inmates has not shown good cause for this late-filed contention.
To pursue this issue any
. further would certainly broaden the issues and delay the proceeding.
Therefore, we ask that the Board not admit this proposed contention.
The Commonwealth also objects to the admission of this contention since it is not reasonably specif sc and has no basis. NUREG-0654 does not specify a minimum or maximum evacuation time.
Furthermore, counsel for the inmates own expert, Mr.
Case, indicated that he had no problem with the ETE (See Tr. 20,665). Therefore, the Commonwealth submits that this is not a litigable issue.
Counsel for the inmates'second new " concern" under this heading is a concern that an evacuation would cause a panic. This concern was raised at the March 22, 1985 Hearing.
The Commonwealth requests that this proposed contention not be admitted since it is late-filed, and counsel for the inmates has not shown good cause for the late filing nor has he shown any of the other requirements for permitting late-filed contentions in 10 C.F.R. 0 2.714(a).
The Commonwealth objects to this contention since it. is not ' reasonably specific and lacks a basis.
Counsel for the inmates' alleged basis for this proposed contention is Louisiana Power and Light Company (Waterford Steam Electric Station, Unit 3), LBP-82-10016 NRC 1550 (1982). From Page 1562 of that case, he stated "the Board recognized that excessive anxiety on the part of the public could result in an overreaction and possible disruption of the plans for protective action. It would most likely take the form of spontaneous evacuation". The Board in the Louisiana Power case also held later on in that same subheading that "we conclude that public overreaction to.a nuclear accident is likely to be minimized provided the guidance in NUREG-0654 is followed, and we conclude that no additional measure need be taken to cope with the ~ public safety.
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. IV.
CONCLUSIO N i
For the reasons discussed above, the Commonwealth respectfully submits that the Graterford inmates have failed to raise an admissable contention and that, therefore, we request tnat they be dismissed from this proceeding.
Respectfully submitted, chl 7-2, g{ b ' Rho,br fil
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,f 'fEORI G. FERKIN
[/ Assistant Counsel Governor's Energy Council
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, flEODORE G. OTTO,111 Assistant Counsel Department of Corrections i
Dated: April 4,1985 2.
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1
- 7.4 T f 7 UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION in the Matter of
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0FF:CE OF SECEEI'3 EN~
000KEIyM'C PHILADELPHIA ELECTRIC COMPANY
)
Docket Nos.
50-352
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50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Answer of the Commonwealth of Pennsylvania to Proposed Contentions of the Graterford inmates with Regard to the Evacuation Plan" in the captioned matter have been served upon the following by deposit in the United States Mail this 4th day of April,1985, except as indicated:
Helen F. Hoyt, Esq.
Donald Hassell, Esq.
Chairperson Counsel for NRC Staff Atomic Safety and Licensing Office of the Executive Board Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Richard F. Cole Zori G. Ferkin, Esq.
Atomic Safety and Licensing Assistant Counsel Board Commonwealth of Pennsylvania U.S. Nuclear Regulatory Governor's Energy Council Commission P. O. Box 8010 Washington, D.C.
20555 300 North Second Street lith Floor Dr. Jerry Harbour Harrisburg, PA 17101 Atomic Safety and Licensing Board Angus Love, Esq.
U.S. Nuclear Regulatory 107 East Main Street Commission Norristown, PA 19401 Washington, D.C.
20555 l
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O Docketing Service Mark J. Wetterhahn, Esq.
Section Conner & Wetterhahn, P.C.
U.S. Nuclear Regulatory 1747 Pennsylvania Avenue, N.W.
Commission Washington, D.C.
20006 Washington, D.C.
20555 Robert M. Rader, Esq.
John L. Patten, Director Conner & Wetterhahn, P.C.
Pennsylvania Emergency 1747 Pennsylvania Avenue, N.W.
Management Agency Washington, D.C.
20006 Room B-151 Transportation and Safety Building Harrisburg, PA 17120 Troy B. Conner, Jr.
Conner & Wetterhahn, P.C.
1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006
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b' / 04'sMJ f/ /k, heodore G. Otto,111 Assistant Counsel Federal Express Hand Delivery a
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f W W:ahingc.n, D.C. 204 72
'..i, WR 2 7 S=.5 P.DCFRO.M IDF.:
Dferd L. Jcrdan Director, Divisien of D ergency Irtparefness e.nd Engine 2rirq Fe spcr.se Office of Inspcetion and Enfcrcc cnt U.S. NJelear Te ulatory Cc;:-dssion FPCF.:
Assistant Assxiste Director of fice cf Hatral and 'Achnological F.acards Progra s Fcn2 dial D:ercise at Graterford State Corrertionh1 EECI:
Institution in SJppert cf the Lincrich Cenerating Station Co March 7,1985, a reedial exercise ws.s cend.::ted at the Stete Ccrre tional Institution, Graterford, to dc.mnstrate that a p:rtion cf one cf t.he Catecery A deficiencies cited at the July 25,19E4, Linerick Of fsite Radiclogical L ergency Preparedness Exercise has been ccrrec.ed.
W.s rep;rt en the July 25, 1954, exercise was for.arded to you en Septe:ber 25,19E4.
2.e reisdial exercise was cendacted to nere fully exercise the cergency res;onse procedres at the State Cerrecticcal Institution, Graterford, including simulated cracaation of irrates.
Ihring the exercise the Graterford authcrities ade:;uately decenstrated an understandin;; cf the mergency response pro:ed=cs and the ability to ade7a.ately irpienent then, therefore, this p:rtion of Category A deficiency nu-ber 2,has been ccrrected.
As additional Categcry A and B deficiencies e.re corrected, wa will notify you.
If you have any qaestions, please contact Robert S.
257-0200.
j Wilkerson, Cnief, Technological F.acards Division, at AttachTent As Stated
" EXHIBIT A" 1
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re lecction. ; The bepartyc=t o Corrections inr. r.neted Gra tarf ort to insui KI l
s.td decimetry to e tdf pt.rsennel. Vhts ra?syitt t he inferzetiot, t e.
i creterf ord ths : tern Kil., tr.the.r then* r.1 kr.r utils s ed causing s eme initial confutten.. A lock-/orn cf the itis:ctes: occurred at 1310 end, upen siir. ct.c.n 8
of the Ikveroor, rTacur. tion con caced as cr.110t is,r ic :he s;raterford Inp.
w. rb !tt 2 : : 33 : ron med rc CTW.E.
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Tre k cric ur: t uri ert 'it.e tLtstirt.t t:4 rvicted a rrter:.t>g f er that ht s c i 5, c.uri ty.vn.r,: trif ere nd etbet.t quiparat,
utetaatry r.c httinc it site t t o crettriced. Irrt rc:te:.z it-cre w dc t to Leuse erriving ir.xx tos.. Avef ers t re tt i citel f res cbc. kritc rt it.stitutict.t:, to Cre ttricrd : s 4:ppretinttaly 2 2/2 h::urs a :.
Nrf r.r. tit c t r e.it t,- et tlc Lit r t e ts.ct, crcterferd infers.tc tht De e t a:er.t de;:.rtre tt inf 6t r d Ghett tferd thc.t iti.c. 'ct.buir.nce s Le d be t tc "ne Lit t : tL-:f tt e cy; diu;ttchec c:
(pr.rt.1 l-7) which.csce toti et11.fbr cbc dieEcvhve c% this is it sc.rittee.vish the den t.otific.1.t W cf u sevetie= :
tch cf et.btitnets until i
Ynt'trtrcitt een:lt4td ci typre::fritet 2(00 v c of it'.Lettti te supperg :itxcticuticer:st.d the. cf rub. ta d rt2 c:ktion Ce tt,r c:ry "F" T.(ecceer.d c.:(e r. (
- 1..*.Tctrot=c t nihvcivcdi it tsdislerie.t1 etergency zurpent e t utivit it s a5ould beter.c tetcily Izzilier rdthf tht! tcrdnology used durtnti. on siterg enty to aveid: eccfusio.:. s
.s
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J.:.balcnce s clould bd Eirpttchet to Crt.tt: ford ct an et:2.y rtig dent. durinci tht excrcis t ). to avoid Long deitys, pttentis.11y 2 neurs or (ae was Lore. if a.s c yccuction.is cedered.' f D
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or~7ern7 e 1.
T e 6e n e n t e re tr. th t-c.bility to c.lert.t r.c n e d f l i c c wr a on.cl t nd rc t c.:rc r. r dn c. tir ly m r.nc r.-
7.
To Cttent tre tt: the lede quc cy. O f. the dccirionna.ki,e t z cce ss et the ~ De portr.c nt r.nd iihetitution. le vci r.
- 3.
To denc:n trttc: the lade qur.cy. c f cc.w..:nica.tian r yt t.rt:s within the 'De.pertmc nt of 'Corra etic.s e nd 1:ter.y dt tigna,t ad f(c11:. tic z.nd ficit.r s.etivitict'.s :
4.
Oo 6t.::ent t:ttc. thtt interne.1 mr.r e ge end infr rmatit r. flow (collt'c'tde= / tc.nclyciri, and. dis t ert:inc tien) is e f f ect.ive.ind timely.t' 5.
.To dt:isnt trtte the fer.pchility to rtlocate select ce.tegorite o f in:ittt t to suppqrt: inctLtutions, if std.e situetien to dicttter:. :
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.To derie:nstrttes the 'epcrational -hnewledged and : !uppes :
!ron cle.cted cr.tppointed public eff1cie.1r.'reyr.rding. pinn f er,ilictity /,cpcpttient sproce.cc tod deetrient.nking.
.To Ct.~~ent trcte t.hc acpc.bil;itic e ch ~ the De partrr.cnt 7.
c.f corre ctient : cad, the rick ri.nr.titutien to imple.rrent tr..ergency rceporteci plcin't: to :proctet ;the her.lth trd safcty sf reploycers Lnd2 int.Ltcc41 E. I 'S e de===ctrett.the t.biliti*cc cf ths. Dcptrtre.ent of Ccrrectienc / sthc ;rith. inttitutieri and t.hc supl: ort iteilisticr to e ffccdvcly l utilize' exte:nt.1 retrour :ts When ilocal.dtpr.biliitiec (cnd rescurces.htve been exrt ed ed.
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- D 0g4 PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY P.O. BOX 3321 H ARRISBURG, PENNSYLVANI A 17105 3321 THIS LETTER IS ONE SENT TO ALL BUS COMPANIES PROVIDING THE DEPARTMENT OF CORRECTIONS WITH BUSES.
Gentlemen:
Some of your employees may be involved in driving buses carrying inmates from the State Correctional Institution at Graterford in the event of an accident at the nuclear generating plant located in Limerick, Montgomery County. Because of this possibility, these drivers may want to take some training regarding the proper use of dosimetry.
The Pennsylvania Emergency Management Agency (PEMA) hereby offers to you and your employees a 2-hour course explaining the proper use of dosimetry. We are prepared to condue this course at a location and time to be selected by you and your employecs. We ask only that you coordinate this scheduling with us to avoid any cont:1 cts with our regular schedule of activities.
You may write to me at the address listed above, or you may telephone me at 717-783-8150.
With kind regards, I am Sincerely, Donald F. Taylor Director Office of Training and Education DFT:tjl (Tel:
717-783-8150)
" Exhibit B"