ML20129H824

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Motion for Order Requiring Full Disclosure by PEMA of Evacuation Plan for State Correctional Institute at Graterford
ML20129H824
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 12/20/1984
From: Love A
GRATERFORD INMATES, MONTGOMERY COUNTY, PA
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20129H806 List:
References
FOIA-85-304 NUDOCS 8507200465
Download: ML20129H824 (3)
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~7DNITsD~ETXTES OF nHERICX NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of  :

PHILADELPHIA ELECTRIC COMPANY  :

(Limerick Generating Station,  : DOCKET NOS. 50-352 Units 1 and 2)  : 50-353 MOTION FOR ORDER REQUIRING FULL DISCLOSURE BY PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY OF THE EVACUATION PLAN FOR STATE CORRECTIONAL INSTITUTE AT GRATERFORD AND NOW, comes the inmates of the Stage Correctional In-stitute at Graterford, through their attorney,'kngus R. Love, who respectfully request the Licensing Board to permit full disclosure of the evacuation plan for the Stat 5'~ Correctional Institute at Graterford under appropriate circumstances for the following reasons:

1. On September 18, 1981, the National Lawyers Guild, through their attorney, Don Bronstein, filed a Petition to Inter-vene in the above-captioned matter on behalf of inmates at the State Correctional Institute at Graterford.
2. In response to a Board Order of October 14, 1981, the National Lawyers Guild filed a supplmental Memorandum.

3.

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On November l6, 1981, the Nuclear Regulatory Com-mission staff issued a response to said Motions indicating that the Nuclear Regulatory Commission staff believes the inmates do 8507200465 PDR FOIA ADEL85-304 850517 PDR FUk%90h

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  • a have standing to intervene.
4. On July 22, 1983, Angus R. Love, Esquire, agreed to assume representation of the' inmates and Don Bronstein formally withdrew from this matter. .
5. On April 20, 1984, in a Special Prehearing order, the Board granted the inmates twenty (20) days to submit their contentions upon receipt of the evacuation plan for S.C.I.G.
6. On December 14, 1984, counsel for the inmates re-ceived an unclassified copy of the Pennsylvania Bureau of Corrections Radiological Emergency Response Pla'n (copy attached I ,

as Exhibit "A").

7. Upon review of said document, it became obvious that major portions of said plan have been removed. The remain-ing portions made little or no sense, giving counsel an inadequate basis from which to form contentions pursuant to the Board's Order of April 20, 1984.
8. Censorship of the plan was so broad that even information in the public domain has been with. held (see page E-1-7; capacity of infirmary at S.C.I.G.).
9. Information in said plan is irreconcilable with information given in Applicant's initial evacuation plan filed March 17,1981 App. H s4.1 (attached as Exhibit "B") .
10. Pennsylvania Emergency Management Agency and the Governor's Energy Council have joined in a request to withhold confidential portions of said plan from the public citing 10 C.F.R. 2.790(d) as authority.
11. Inmates at S.C.I.G. object to the withholding of confidential information, and request the Board to issue a protective Order allowing counsel and any recognized experts to review the entire plan under appropriate circumstances.
12. Inmates also request that the twenty day time period allowed for the filing of their contentions not begin until full disclosure of the plan is permitted under the appro-priate circumstances.

Respectfully subr:iitted, f',\,,; ;z g:y}\ f. fT .I%- s. , .

AliGUS R. LOVE, ESQUIRE'*

Montgomery County Legal Aid e

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