ML20112B147

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Response to State of PA Dept of Corrections Requests for Info Raised at 850227 ASLB Conference Re Graterford Inmates Health & Safety in Event of Incident at Facility.Certificate of Svc Encl.Related Correspondence
ML20112B147
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/18/1985
From: Ferkin Z, Otto T
PENNSYLVANIA, COMMONWEALTH OF
To:
References
CON-#185-090, CON-#185-90 OL, NUDOCS 8503190040
Download: ML20112B147 (19)


Text

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yTED P CORRESPONN DSCniTED USVC UNITED STATES OF AMERICA E MAR 18 A1056 NUCLEAR REGULATORY COMMISSION 0FFICE U SEC?iTlaw 00CKETiN3 4 SEFV'Cf Before the Atomic Safety and Licensing Board WH In the Matter of )

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Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 jb (Limerick Generating Station, )

Units 1 and 2) )

RESPONSE OF THE COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CORRECTIONS TO REQUESTS FOR INFORMATION RAISED AT THE FEBRUARY 27, 1985 ATOMIC SAFETY AND LICENSING BOARD CONFERENCE

1. BACKGROUND On February 27, 1985, a conference was held pursuant to the language in the Order of the Atomic Safety and Licensing Appeal Panel denying the appeal filed by counsel for the Graterford inmates. At that conference, counsel for the Graterford inmates, and his expert, made representations as to what information they needed so that they would have reasonable assurances that the inmates' health and safety would be protected in the event of an incident at the Limerick Generating Station. Below are the representations of the Department of Corrections in response to those requests for information.

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11. DISCUSSION The discussions at the February 27, 1985 conference followed the order of the proposed contentions that were filed by counsel for the inmates. In order to maintain a semblance of order, the responses in this document will also follow the order of the proposed contentions.

TR A NSPORT ATIO N The buses used to transport the inmates will come from outside the 10 mile EPZ.

This is because suffielent numbers of buses could not be located inside the 10 mile EPZ. The plan calls for the use of 58 buses. For planning purposes, we have assigned 40 inmates per bus, although the buses have a rated adult capacity of between 46 to 48 individuals. (These are the same type school buses that have a school children rated capacity of between 66 and 72 school children.) Attached as Exhibit A through C are three representative samples of the assurances given by our bus providers. The exhibits represent assurances for 71 buses. These exhibits represent less than half of the bus providers and give assurances for 13 more buses than are needed for the entire plan.

The number of inmates that can be carried by these 71 buses (at 40 per bus) is 2,840 inmates, which is in excess of the entire inmate population at the institution.

The sources for bus drivers are two-fold. The first source is the bus providers.

They have given us assurances the drivers will be available in the event of an evacuation to drive the buses. In the operation of the plan, we expect to use only a small number of a bus providers total compliment of buses and, therefore, it is reasonable to believe i that they could provide us with bus drivers for the buses, even if some of the bus drivers refused to drive.

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The second source for bus drivers will be the Department of Corrections. At the support institutions, we currently have at least 110 employes with a Class II driver's license. According to the Commonwealth of Pennsylvania Motor Vehicle Code, a Class II driver's license permits an individual to operate a bus on Pennsylvania highways. At the suggestion of some of our bus providers, and to further ensure the competence of the selected bus drivers, we are planning to have them receive further training. We estimate that the training will be completed by the end of 1985.

Regarding inmates scheduled to be transferred in Department of Corrections vans, the Department of Corrections maintains a fleet of 15 vans. If necessary, all of these vans would be available for an evacuation, although the plan calls for the use of substantially less than entire fleet. The combined capacity of these vans is 216 inmates.

We are also currently in the process of bidding for a new 32-passenger van. For planning purposes, we believe about five percent of the total inmate population would be moved in these vans. If, for some unexpected reason, insufficient vans were available, Department of Corrections vehicles (station wagons, cars, etc.) would be utilized to move these inmates.

With regard to the location of ambulance resources, attached as Exhibit D is a written assurance that we coald get at least 15 ambulances from our selected provider.

The number of ambulances used for planning purposes is in the range of two to three ambulances, although we obviously have substantial excess capacity if further ambulances were needed.

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M ANPO WER l j As a part of the SCI-Graterford Emergency Plan for any type of emergency, there [

is a call-up system in place. This system is available to notify additional manpower if

they were needed during a radiological emergency.  !

] The plan uses management individuals to call the staff. Each individual has less than 10 other persons to call. Furthermore, the callers are of sufficient rank to give orders to the person receiving the call to report to work.

The system was tested as of January,1985. The institution passed the test.

The Department of Corrections maintains a compliment of approximately 700 l

! employes at the State Correctional Institution at Graterford. Approximately 400 of  !

l these employes are Correctional Officers. If necessary, many of the remaining 300 '

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} employes could be of assistance since they have received basic training in inmate custody [

t and control. If, for some reason, further manpower was required, officers from other [

j department resources or the Pennsylvania State Police would be utilized. As a last i resort, the Pennsylvania National Guard could be used. Thus, the reference by counsel '

1 for the inmates in his proposed contentions to the necessity for a battalion of the L f

National Guard to be used in the Graterford evacuation is incorrect. To evacuate the l

! r l State Correctional Institution at Graterford, the Pennsylvania National Guard is the  :

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{ source to be used only after the Department's own resources and the Pennsylvania State  !

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Police resources are exhausted.

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SECURITY EQUIPMENT I

Although the numbers and types of security equipment to be used in the Graterford evacuation is of such a sensitive matter that the Department of Corrections is not l disclosing that information, we will disclose that we are expecting delivery of the required equipment within 90 days.

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COMMUNICATIONS EQUIPMENT As part of its ongoing operation, the Department of Corrections has substantial radio resources with base units, mobile units (in cars and other vehicles) and hand-held units. To supplement this existing capacity, we have received 68 additional hand-held units. These units were in liarrisburg as of March 8,1985, and are awaiting distribution.

These radios are the same type radios we use in our daily operation, so we can attest to their quality. Little, if any, formal training will be required since we will be authorized to use them on a daily basis (see letter from Vincent S. Boyer, Sr. Vice President, Nuclear Power, Philadelphia Electric Company, attached hereto as Exhibit E).

RADIOLOGICAL EQUIPMENT According to PEMA Representative, Ralph liippert, the CD V-750 and the CD V-700 are currently in stock. The DCA-622's are due to start coming in about March 10,1985. The K1 is due April 1,1985. We are waiting until the DCA-622's and the KI are in stock to distribute these materials all at once. The TLD's are in the bidding process. Once they are received, they will be distributed as well.

According to Mr. Hippert, if an incident would occur before the delivery of these items, there are sufficient stock piles of this equipment available in the Three-Mile Island EPZ counties to cover the evacuation of the Limerick EPZ including the inmates at Graterford.

MEDICAL SERVICES As a part of its ongoing operation, the Department of Corrections has agreements with local hospitals to give health care to our inmates. Attached as Exhibit F is a copy of an addendum to these agreements we have had our hospitals execute to evidence their ability to take care of inmates injured by radioactivity. Also attached as Exhibit G is the JCAll Standard to which the addendum refers.

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o MONITORING The Department of Cctreetions will use the same standards for the inmates as are being used for the general public with regard to sheltering, evacuation and the general operation of this plan, with one exception. In the event that sheltering is ordered for the entire EPZ during the summer, and the temperatures and humidity are such that the institution would become uncomfortable, a DOE plume-monitoring team will be requested by the State Correctional Institution at Graterford. This will allow us to keep the windows open if only background levels of radiation are detectable. If the team indicates that a radioactive plume is coming, the information will be relayed to PEMA. PEMA will consult with the BRP and PEMA will issue instructions for the institution to follow, and these will be the offielal actions which the institution will l implement. In the interim period between the time the DOE indicates that a plume is heading towards the State Correctional Institution at Graterford and the State Correctional Institution at Graterford receives word from PEMA, the Superintendent will take interim actions as per his best judgment. This information is contained in the plan on Page E-1, D-1 and E-1 (9).

It should be emphasized that this action is the only action that is different than the actions taken by the general public, and this only happens in the situation where the temperatures and humidity are such that the institution would become uncomfortable.

SIMULATED EVACU ATION PLAN EXERCISE A " tabletop" exercise of the plan was conducted on March 7,1985. FEMA, PEMA and DOC were in attendance. Upon receipt of the FEM A report, the DOC will provide information as to whether the plan was found by FEM A to be adequate.

o T R'AINING The training for the decision-makers in the plan is completed. These are the people that have the responsibility to control the actions of their staff at Graterford and the other support institutions and relocation centers. These individuals are fully aware of the components and operation of the plan. The training they received was tested during the tabletop exercise. During that exercise, the decision-making and communication parts of the plan were tested. These are the people who will be giving orders to the staff regarding care, custody and control of the inmates and receiving information from the Department of Corrections Central Office regarding actions to be taken at their institutions.

To provide training for our decontamination monitoring teams, we are utilizing a train-the-trainers approach. By using this approach, certain individuals are being qualified to go back to their support institutions and train the decontamination monitoring teams. The training for the trainers is completed and was conducted by PEMA. As soon as the additional radiological equipment is received by the Department of Corrections, the trainers can give training as to the actual use of the equipment. We estimate that the training process will be completed three months following the receipt of the equipment by the Department of Corrections.

RECOVERY AND RE-ENTRY The recovery and re-entry will essentially be a reverse of the evacuation. R e-entry will only be initiated when the Department of Corrections is advised by PEM A that it is safe to return.

e::S SilELT Ell 1NG The Department of Corrections will rely on the determination by PEMA requiring sheltering. If PEM A suggests sheltering, we will shelter with the limitation more fully explained under monitoring in this response. The E-1-10 (8) referral to " institutional.

climate" does not refer to any sheltering decision but only to one of the elements of a report the Department of Correction will provide to PEM A regarding the progress of an evacuation.

GENER AL CONCEPT OF EVACUATION The counsel for inmates has been afforded the opportunity to review a substantially less sanitized version of the plan than he had viewed at the time of filing the proposed contentions. The plan that he has seen under protective order and an affidavit of non-disclosure is complete with the exceptions of the destinations, routes, specific numbers of manpower and inmates, restraints, and radio frequencies. This information was deleted due to the security concerns of the Department of Corrections. The information, in our opinion, could also be classified as the " gory detalb" which are not subject to disclosure. With the information that has been provided to the counsel for the inmates, as well as his expert, we believe that they will agree there is a reasonable assurance that the evacuation would provide for the safety and security of the inmates during the evacuation.

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  • l' CONCLUSION j The above information represents what the Department of Corrections understood l Counsel for the inmates needed to complete his review and for the consideration of the Atomic Safety and Licensing Board.

Respectfully submitted,

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/J fieodore G. Otto,111~

Assistant Counsel Department of Corrections

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_N WV Zori G. Ferkin ,f

/f y/6ssistant Counsel /

Governor's Energy Council i

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L's tmd c t s t t.nd yc u r.m d thir 1 ( t t t r ti r proof of thert cirurancor ior tlu ::u(Itat Ferulstorv Cor.ieeion. tLovinr tl.at you havt 3ocatcd of Iuscr. for erc1f(nc) urc. Th i r. I t t t e r i s tr t a c orit r ac t but rervee as ti rtett ti e interett t hi!. corpany hnt expr(fr.cd in riovi in;. t use s, to the erxfr.u crt(nt

r t r ib1( for ut>e during on cr.orr(ncy includirr th< ( vt. c u t> t i e n c. f T C) Crct<rford th(te at t.n intident at the 1.it.~eric h Gonc re t in; Etoticn.

'l o O c t r.1 t tbe b<portrent o f Cor r ec t f or r. t o i.dt r,un t < 1 y y } t,n ie r 11. < p o r t. i t I t rvm ut t j or.. t ht (c rnny con rtve teoronnb]( t. r.u r a n u t thot tla: can ptovidt s. t 3 l u t.f r- vi t h ti (t.ratity of 72 Febobl.(f.13drin or t.F t.dulta por tut eithin tce hour s .

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EXHIBIT "A" t

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PLANNCD C H A R"It M S AND LUXURY T O L .' R G 114 U .D ./s. ." N t t D A N r.

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'lhir itttcr r o n i i r n r. previous v(rbt.1 a s r u r t. n c t s t. .

b this c o r. p t. n y to the D e p a r t rn e n t of Corrtctient. b' t underst.

you n a c- d this l e. t t e r as pr oof o f thtet assurancts for the hucl<

h( rulatory r, o r.r. i t. s i o n , r.hoving that you have located s. o u r of bute- foi e n e r r,e n c y ute. Thir. letter it not a contrc but s t r v e r, a r, a s t a t e rn a n t of the intofort this company e x p r e r s. e d in providinr, buses to the tr. a >. i rn u m < >. t e n t posti for ute durint an entrrency including the evacuation of Crattriord if t h e r c- is t. n incident at the L i r rn e r i c k Generat btation.

10 p e r r, i t the De partment of Corrections to adequat plan for the por.sible e v t. c u a t i o n , ths company can r i v t- r e a r,o n a a s.t. u r a n c e s that they can provide at I t n r. t 20 r,chool bu and 10 chartar buros with a capacity of 4t per bus wit

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EXHIBIT "B"

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Superintendent:

State Correctional Institution Dear Superintendent

'Jhis It.ttcr confirms previous verbal assurances cado by this company to the Department of Corrections. k'e understand you need this letter as probf of these assurances for the 1;uclear Regulatory Co :ission, shoving that you have located sources of buses for etergency use. This Ictter is not a contreet but serves as a statetent of the interest this company has exprecced in providing buses to the maximum extent possible for use during an energency including the evacuation of SCI Graterford if tht:re is an incident at the Litecrich Generating Station.

To percit the Departcent of Corrections to adequately plan for the possible evacuation, the co:pany can rive reasonabic assurances that they can provide at least M buses with a capacity of _66-72 per bus within 3-3 hours.

Your Bus Service Contact l'erson 24 liour phonc ); umber EXHIBIT "C"

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EXHIBIT "D" l 1

, l g .,,, .....uto PHILADELPHI A ELECT RIC COM PA TY i r3olMARKET 51hErl . . ,,j . ; ,j P.O. DOX B699 PHIL ADELPHI A. PA.191ol Op I.1107.!, DWMDt v . , g o g i ,, mu eu e t oc-s o. 4 et e one sit >t h1 11 oven.ber 6, 1984 1:r . L. P. Denning, Chief Security /Saiety Pcnnry3vanie Eureau of Correction P. O. Lox $90 Carnp 11111, PA 37011 Dear Mr. Denningt In October at a meeting I attended with you and your asso-cintes at the Pennsylvania Lureau of Correction as well as with John Patten and Ralph liippert of PD%, you proposed the training program and list of equipment developed by the Bureau of Correctic for the radiological emergency response plan of the Gratcrford Prison. Since that date, we have had discussions with you relatiN tc. Various aspects of your requested program.

With regard to the training plans, we understand that Perm will either conduct or review the program to assure that the trair ing material is adequate for the intended purpose. Philadelphia Electric Company agrees to reimburse the Dureau of Correction for incremental costs associated with the training program beyond thai provided by the State of Pennsylvania under Act 147, the Pennsyl-vania Radiation Protection Act. We expect that training will be accompliched as part of the normal work wook in so far as possib1<

Invoices for the incremental training costs may be directed to my cttention. .

Uc have reviewed the equipment listed in the Pennsylvania Eureau of correction equipment cost projection and find the quantity and type of equipment listed to be reasonable for the purposes intended. We plan on initiating the purchase orders for hardware and having it delivered to your attention.

Items 6, 7 and 8 of the equipment list covers the furnishing of radios and associated equipment. We intend to purchase and furnish this equipment to you, but as I discussed with you on tho phonc, we are formulating a proposal which, while making the equi ment available to you when needed, will enabic it to be utilized rather than gathering dust in a storage cabinet.

We are pleased to work with you in the finalization of the emergency planning needs for the Graterford Prison.

Cinecroly, cci .lohn Potten f fe n i WH I

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best S uf.c r ir; te ndt n t Thit 2t to ccrtify that Hott2tl] ccri1its v2th the p?cviticnr of the Join t Lom .2tt a c?> cn the Accredita tic:n of liotpitalt Standard tV, Et,e rgency Services dcalit:g with the Ltca tt.er;t ci rad 20act Avc1y contaminated wounded.

!incerely, Ad?.2 ni t t r u tu i 1

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2f; At cht n!! ATloh M 4M Al loh no5cil Al.5, toOI INTL;n!'nifl ATloN Urirraharion Program A planned, formal training program thall be re-quired for all registried and licen>cd nur>cs, and for specifed professio"al 8 pes >onnel who provide patient care in the emergency department / service.

When these is no in house capability of providing tliis training, a qualired s outside source of instruction shall lie substituted. The program shall be acceptable to the physician director of the emergency department /ecrvice, or to the committee of the inedical stafl when there is no director, and to the direcim of the nursing department 4enice. The orientation program shall be of tufheient duration and substance to coser all patient care retponsibilities io related to each individual's level of participation in the emergency depart-ineniJ,crvice. The program thall include training in:

. recognition, interpretation, nd recording of patient ' sign and Symp-toms, particularly those that require notification of a physician:

. initiation of cardiopulmonary resuscitation and other related life-( n support procedures; lp , . parenteral administration of electrolytes, fluid =, blood, and blood com.

ponents; h @j e

. wound care and management of eepsis;

. initial burn care;

[7 ft,tNO-l/ :o e initial management of injuries to the extrernities and central nervous system; eficctive and safe use of electrical and electronic life support and other g$g / .

equipment used in the emergency department / service;

% -h 25 prevention of contamination and cross infection; and terornition of, and attention to, the psychological and social needs of patients and their families.

0,, h1 hTD Continuing Education Prorram All emergency department / service prson.

ghg, h p,, nel shall panicipate in relevant in service education programs. The director or hi. qualified designees shall contribute to the in senice education of l

so emergency department / service personnel. In. service education shall include the safe ty and infection control requirements described in this Manual. Car.

d/f fdh V diopulmonary resuscitation training shall be conducted as often as necessary for all physicians, nurses, and specified professionel personnel who work in the emergency care area.

- 0Ly? >s Thehe viiiaami#isiraiie#stnii s reihaither e ener'"#itie 'er l physicians, nurses, and, as required, other personnel to participate in emer.

I gency departmenthervice continuing education programs outside the hospi.

  • tal, a, needed. Llucation programs for emergency departmenthervice person.

nel shall be based at least in part on the result, of the review and evaluation 3

/, g > 40 of the quality and appropriatene.s of ernergency care. The extent of par.

^ d ticipation thall be documented and shall be realistically relatal to the alte l of the stafi and to the ecope and complexity of the emergency care services 3

3 prosided.

' Standard Y 1:inergency patient care ebull be Fulded 1 y written poUcles and '3A redures, ,

tuitnt'ntT ATios %ere shall lie written policies and procedures specifying the scope and conduct of patient care to be rendered in the emergency department /serdo Such policies and procedures must be approved by the medical staff g ,

and EXH!llli "G" 1

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a Em:ry;ney Smic hospital administration, and shall be reviewed at least annually, revised as g necessary, dated to indicate the time of the last review, and enforced. The policies and procedures in Level 1, Level 11, and Level 111 emergency de.

partments/ services and, as appropriate, in Level IV emergency departments /

services, shall relate to at least the following: 5

  • Location, storage, and procurement of medications, blood, supplies, and equipment at all times.
  • Provision of care to an unemancipated minor r.at accompanied by parent or guardian, or to an unaccompanied unconscious patient.
  • Circumstances under which the patient's personal physician is to bc to notified or given reports.
  • Confidentiality of patient information and the safeguarding of records.
  • Helease of authorized information and materials to police or health authorities.
  • Transfer and discharge of patients. is

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  • The emergency medical record, including any consent for treatment.
  • Infection control measures, including piocedures designed to eliminate the possibility of contamination and cross infection.
  • Procedures to be followed in the event of equipment failure.
  • Peninent safety practices. :o
  • Control of traflic, including visitors.
  • Dispensing of medications in accordance with the requirements of the Pharmaceutical Services section of this Manual.
  • The handling and safekeeping of patients' valuables.
  • The role of the emergency depaitment/ service in the hospital disaster :s plans.

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  • Specification of the scope of treatment allowed, including the general and specific procedures that may not he performed by medical staff rnembers in the emergency department service, and the use of anes.

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  • Who, other than physicians, may perform special procedures, under what circumstances, and under what degree of supervision. Such pro.

cedures include, but are not limited to, cardiopulmonary resuscitation, including cardiac defibrillation; endotracheal intubation; tracheostomy or cricothyreotomy; respiratory care, including assisted ventilation and 35 humidification; the administration of parenteral antiarrhythmic and other specified medications; and the obtaining of arterial and venous blood samples and other laboratory snecimens.

  • The use of standing orders.
  • The property exchange system, when necessitated by the transportation 40 and transfer of patients.
  • Circumstaneen that require the patient to return to the emergency de.

partment/ service for treatment.

  • The emergency management of individuals who have actual or sus.

pected exposure to radiation or who are radioactively contaminated. 4s t

' Such action may include radioactivity monitoring and measurement; I designation and any required preparation of space for evaluation of the patient, including, as required, discontinuation of the air circula.

j i, tion system to prevent the spread of contamination; decontamination So f ,d ' of the patient tirough an appropriate cleansing mechanism; and con.

tainment, labeling, and disposition of contaminated materials. 'Ihe t

h Individual responsible for radiation safety should be i otified.

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! UNITED STATES OF AMERICA j

i NUCLEAR REGULATORY COMMISSION W MR 18 4057 i

in the Matter of )

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h S.Ifhs BFANCH

[N l PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352 i ) 50-353

! (Limerick Generating Stations, )

, Units 1 and 2) )

CERTIFICATE OF SERVICE i

f I hereby certify that copies of " Response of the Commonwealth of Pennsylvania,

Department of Corrections to Requests for Information Raised at the February 27, 1985 Atomic Safety and Licensing Board Conference" in the captioned matter have been

! served upon the following by deposit in the United States Mall this 15th day of March,

! 1985:

)

i Helen F. Hoyt, Esq. Donald Hassell, Esq.

Chairperson Counsel for NRC Staff Atomic Safety and Lleensing Office of the Executive Board Legal Director i U.S. Nuclear Regulatory U.S. Nuclear Regulatory
< Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 I

Dr. Richard F. Cole

  • Zori G. Ferkin, Esq.

, Atomic Safety and Lleensing Assistant Counsel i Board Commonwealth of Pennsylvania

! U.S. Nuclear Regulatory Governor's Energy Council Commission P. O. Box 8010 j Washington, D.C. 20555 300 North Second Street

! lith Floor l

Dr. Jerry Harbour Harrisburg, PA 17101 4

Atomic Safety and Licensing Board Angus Love, Esq.

U.S. Nuclear Regulatory 107 East Main Street Commission Norristown, PA 19401 Washington, D.C. 20555 i

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Docketing and Service John L. Patten, Director Section Pennsylvania Emergency U.S. Nuclear Regulatory Management Agency Commission Room B-151 Washington, D.C. 20555 Transportation and Safety Building liarrisburg, PA 17120 (N

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Sherree L. Sturgis ' g' Chief! Counsel '

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