ML20214P065

Petition for Review of Aslab 860828 Order,Including Adequacy of Manpower Mobilization Component of Radiological Emergency Response Plans for Facility.Certificate of Svc Encl

ML20214P065
Person / Time
Site:	Limerick
Issue date:	09/16/1986
From:	Love A GRATERFORD INMATES, LOVE, A.R.
To:	NRC COMMISSION (OCM)
References
CON-#386-708 ALAB-845, NUDOCS 8609170248
Download: ML20214P065 (14)

Text

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V-1bV i UNITED STATES OF AMERICA DOCHETED USNRC NUCLEAR REGJLA'IORI COMISSIOi

'86 SEP 16 Noc 2 CO M ISSICNERS:

Lando W. Zech, Jr., Chairman QFyl' ' e ; -

l Thomas M. Roberts "

! James K. Asselstine j Frederick M. Bernthal I

I Kenneth M. Carr

.In the Matter'of  :

PHILADELPHIA ELECTRIC COMPANY  :

U(Limerick Generating System, Units 1 and 2)  : NOS. 50-352 and 50-353

]l i

!i PETITION EOR REVIEW fI. INTRODUCTION - Decision Upon Which Review is Sought 1

o The Inmates of the State Correctional Institute at Graterford, d

Pennsylvania, through their attorney, Angus R. Love, hereby petition the Nuclear 1

Regulatory Comission for review of the Atomic Safety and Licensing- Appeal Board

Order of August 28, 1986 docketed as ALAB-845, pursuart to 10 C.F.R. 2.786.

The Inmates note that they have withdrawn one issue which was previously litigated before both the Atomic Safety and Licensing Board and the Atomic Safety and Licensing App =al Board, that issue being the contention involving medical services. (See ALAB-845 pp.18-21.) The Inmates note also that this ll

" appeal does not cover the issue which was remanded to the Atomic Safety and lI

[ Licensing Board involving the adequacy of the manpower mobilization component of i!

the Radiological Emergency Response Plans for the Limerick Generating Station.

,[(See Manpower Mobilization ALAB-845 pp. 4-15.)

i The Inmates seek review of two contentions and three proposed but rejected I

' contentions. On their behalf, the Inmates presented testimony from Major John

[! Case, Field Director of the Pennsylvania Prison Society, and Robert Morris 8609170248 e60916 PDR ADOCK 05000352

. pf 63

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N dtrafficcontrolexpert, in support of the above-mentioned contentions. The

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Inmates contend that both the Atomic Safety and Licensing Board and the decision

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' of the Atomic Safety and Licensing Appeal Board failed to give proper weight to the evidence presented by the Inmates' experts and have failed to properly weigh the evidence in light of the unique nature of the fact pattern presented by the Inmates. The Inmates further note that this question presents a novel

' issue for the Nuclear Regulatory Commission as never before has a maximum i

security prison been located within the ten-mile emergency planning zone d

, surrounding a nuclear power plant. In light of the potential for danger to the

'l jinmates and public, the Inmates continue to press for a sound and workable d

, evacuation plan in the event of an accident at the Limerick facility. 'Ihe -

1 (Inmates rely upon the testimony of the aforementioned experts, previous

.i Jdecisions by both this Commission and the United States Court of Appeals, the

Emergency Planning Standards of 10 C.F.R. 50.47, and the guidelines presented by i

NUREG 0654.

II. ARGUMENT t

j A. ADMITrED CONTENTIONS

1. Bus driver training. Although much has been said with respect

! to this issue in many decisions of both the Atomic Safety and Licensing Board ano the Atomic Safety and Licensing Appeal Board, the Inmates remain convinced that both of these tribunals have failed to grasp the meaning of this M

This' issue involves .the use of civilian personnel who will be

[ contention.

!I fl assigned to driving the buses used to evacuate the Inmates of the State

[ Correctional Institute at Graterford. In order to conduct a successful 1

evacuation, these civilians must be relied upon. Due to their participation, l the Inmates have requested some assurance that these individuals can be counted 4

[upontoparticipateinanevacuationintheeventofanaccidentattheLimerick i'

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Generating Station. Unfortunately, the issue degenerated into a discussion of 4

(semantics regarding whether or not these individuals will be offered training prior to any participation in such an evacuation. The Inmates initial linsistence upon such training was based upon their belief that training could d:better prepare said individuals for their eventual role in the utilization of the Emergency Radiological Response Plan for the State Correctional Institute at Graterford. Both the Atomic Safety and Licensing Board and the Atomic Safety 3

[and Licensing Appeal Board failed to grasp the larger argument as to the a

reliability of using civilian personnel in an endeavor as potentially dangerous lasthis. Eventually the issue was narrowed, despite objections from Inmates, to y -.

whether or not- said training would occur. The issue was then further narrowed q

[as to whether or not said training would be offered. (See ALAB-845 p. 29.) The d

WInmates contend that the use of such personnel.is unwise in light of'the il 5 serious nature of the taek involved. They point to the testimony presented by 1

Major John Case in support of their belief that as things now stand, civilians are unreliable for the tasks contemplated by the Graterford Emergency Response l Plan. (See Inmates Brief at 21-25, as presented to the Atomic Safety and

, Licensing Appeal Board prior to their recent decision of ALAB-845. ) It is the Inmates' position that training is_ only a necessary prerequisite and does not jnecessarilyguaranteeparticipationofsaiddrivers. The position of the Atomic fSafety and Licensing Appeal Board appears to be very narrowly construed to indicate that merely an offer of training will be sufficient to guarantee the reliability of the use of civilian personnel in the evacuation.

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! With respect to the record made in this proceeding, the Inmates point out

,[that the only action taken by any agency with respect to this issue is a letter N

'sent out to six bus companies located up to 190 miles away from the State 7

I a

N Correctional Institute at Graterford, Pennsylvania, on April 4,1985, offering i

jradiological training to civilian personnel employed by said bus companies.

(See TR. 20,863.) The Inmates further point out that not even this minimal effort has been met by any responses from the respective bus companies. (See TR. 20,863 and 20,878.) The Inmates presented Major Case's testimony which t

stated that there is no information available which indicates that said bus i

3d rivers will cooperate. (See 'IR. 20,951.) Case further suggested the need for i

jfinancial incentives to encourage civilian bus driver participation. (See TR.

i

20,951, 20,938 and.20,939.) The issue was further down-played by PEMA witnesses 0

[that suggested that motivation of civilian personnel to be utilized in this i

revacuation was irrelevant to the task at hand. (See TR. 21,001.) FEMA '

d Iwitnesses also indicated a cynical view of the issue when they stated that they b

'are not concerned with whether or not the offer will ever be accepted. (See TR.

1

[,21,017. ) PEMA rejected the possibility of utilizing financial incentives to encourage participation of said drivers. (See TR. 20,863-20,864.) Mr. Taylor, jtestifying on behalf of PEMA, further indicated a failure to grasp the seriousness of this issue when he stated that it makes no difference as far as

'he was concerned, who the bus drivers would be transporting. (See TR. 20,860.)

The Inmates' understanding of this issue is based upon a flow chart which was explained by Superintendent Charles Zimerman during his testimony regarding the estimated time of evacuation during hearings held on July 15, 1985. (See ii LTR. 20,761 which introduces into evidence an eight-page statement accompanied by

[a flow chart which provides details of the contemplated evacuation plan for li

. ,Graterford. ) The flow chart indicates that 58 buses will be used in order to 1

a l-

' transport the inmates from the State Correctional facility to ra undisclosed alocation. A letter from Theodore G. Otto, III, counsel for the Pennsylvania

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, Department of Corrections to Angus Love, dated June 27, 1985, which accompanied l the flow chart, provides further information with regard to this issue. Said y

a letter was attached to Major Case's deposition as Applicant's Exhibit No. 3 and

~is referred to in the record at TR. 20,797. This letter states that the " buses

[will be coming from within a 190 mile distance from the State Correctional HInstitute at Graterford." Thus, the Inmates' understanding of this issue is d

that the civilian personnel to be utilized during the evacuation will be obtained from private bus companies located approximately 190 miles away from 1

!;the institution. The Inmates contend that the use of such personnel, traveling F

from such a far distance into an area where a nuclear accident is in progress in

[! order to transport inmates from a maximum security penal facility requires -

additional assurances to guarantee participation. Thus, they raised the issue iregarding the necessity for training in order to better prepare these

(/ individuals for the task at hand.

o The Inmates' initial filing with respect to proposed contentions was dated i

February 15, 1985 and contained three general contentions along with ten b

,[specificbasesforthegeneralcontentions. The first specific basis, subtitled i

Section A, was entitled " Transportation". It read, "There is no reasonable

assurance that PEMA has made arrangements to provide the sufficient number of

. buses, vans, ambulances and drivers for said vehicles, necessary to implement an evacuation from SCIG." After considerable procedural manuevering, a second list i

of contentions was filed by Graterford Inmates entitled, " Proposed Revised Contentions of the Graterford Inmates With Regard to the Radiological Emergency Response Plan", which was dated May 13, 1985. The Inmates note that they now had the benefit of additional information with regard to the specifics of the qGraterford Emergency Radiological Response Plan, and thus were able to further I

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jrefine the initial contentions. There was now one general contention followed 4

!by eight specific bases for that contention. The third basis for the general contention labeled Subsection C, was entitled, " Training". (See p. 6.) It was further explained as follows: "There is no reasonable assurance that f

Lemergency response training will be offered to civilian personnel who will be jinvolved in the emergency response plans such as civilian bus drivers, rescue squads, and other such personnel." The Inmates contend that the entire f focus of this issue has been narrowed down to whether or not the Pennsylvania

t Emergency Management Agency will offer training to the civilian personnel.

jThe Inmates contend that this misses the point of the proposed contention.

d -

The Inmates are attempting to ensure that u workable evacuation plan gis in place. In order to execute such a plan, civilian bus drivers must lbe relied upon due to the intregal nature of their role. Training

does address some'of the Inmates' concerns regarding their participation, however, the decision to further refine this contention to a mere offer of training manages to evade the essence of the Inmates' contention; that essence being that these individuals must be reliable components of the plan.

Therefore, the Inmates recpectfully request this Comission to review the record of this contention in its entirety and to provide additional assurances that such civilian personnel can be counted upon in the event of a nuclear accident dat the Limerick Generating Station.

l 2. Estimated time of evacuation. Inmates contend that the Appeal

Board's affirmation of the litigated contention involving the estimated time of l 0

! evacuation is in error. In Support of this argument, they cite Superintendent N

Zimerman's testimony regarding his copulation of the ETE, the testimony of d

l Major Case and Robert Morris in support of the Inmates' contention that the ETE

! i b

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, laspresentedfailstoincludeproblemscausedbyanemerg:ncysituation,andth:

blackofcoordinationbetweenthevariouspersonswhoassistedindeterminingthe ETE as presented through testimony of Superintendent Zimerman. The record

' amply supports the Inmates' position that the ETE could just as easily be 12 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. (See Case Deposition, p. 54.)

I;; Despite the Appeal Board's attempt to reconcile the three different ETEs 5 presented during the course of these proceedings, the Inmates continue to insist that the coordination' between the various parties has been overstated. In il

! support of this contention, the Inmates point to Superintendent Zimmerman's 4

[ testimony that he was not involved in compiling the Jeffes ETEs. .(See TR.

20,769.) We note that the Appeal Board relied upon assertions made by ,

[ Superintendent Zimerman that an addendum would be added to the Inmate Handbook d

[which could improve overall efficiency. (See TR. 20,948.)' The Inmates note N

lthat as of the date of submission of this Petition for Review, no such addendum il

(: has been added to the Handbook. The Inmates further contend that no such haddendum will ever be submitted as the proceedings was merely a paper chase

necessary to satisfy procedural and public relations concerns of the Applicant.

d As the Inmates' expert witness, John Case, relied upon such a proposal which has

'not in fact occurred, his testimony regarding such an addendum should be

., disregarded until it is in fact in existence. (See TR. 20,948.)

1 With respect to the Appeal Board's suggestion that the Inmates have ignored I

i the testimony of Edward Lieberman and their suggestion that Robert Morris' l  !

testimony lacks sufficient expertise to be given the proper weight, the Inmates l

!contendthatareviewofthetranscript indicates otherwise. The Inmates I

dcontend that Mr. Lieberman's testimony was virtually inccmprehensible and thus U (See TR. 20,957-20,973.).

i iwas ignored for good reason in their Brief.

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1- Initially, the Inmates note that Mr. Lieberman admitted as to having no previous iexperience in evacuating penal institutions. (See TR. 20,957.) The Inmates

, d falso note that he has no previous experience in custody and control of' inmate populations. (See TR. 20,957.) They further note that he failed to cons.ider i-jany possible lane closures, (TR. 20,959), use of the emergency shoulder,.(TR.

l420,960), or meterological conditions of the area (TR. 20,961). The Inmates also

i

[ note that he states that his overall ETE differs from the three previously i j j i;subnitted ETTEs in that he believes that such ~an evacuation can be completed in d

!!1ess than six hours. (See TR. 20,963.) The individual components of his i! '

The Inmates take (Iestimate can be found on page 6 of his proffered testimony.

I

11ssue with the individual breakdowns and the overall ETE estimate of Mr.

$ 4 lLieberman. In particular, they note the travel of buses component states that 4

i

, hsuch a task can be performed within 115 to 245 minutes. The Inmates notes that

!lthe buses will be traveling from at least 190 miles away and for said buses to 1

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farrive at the institution within Mr. Lieberman's time frame, indicates that they

l1 j would be traveling in speeds in excess of 90 miles per hour. The Inmates note L

that the speed limits on Pennsylvania roadways are not permitted to exceed 55

miles per hour, even if the buses had such capabilities. In order to arrive at Mr. Lieberman's 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> estimate for evacuation during fair weather (see p. 8), ,

' he indicates that the boarding of inmates must be completed within 30. minutes, f U(See p. 6 of proffered testimony and TR. 20,969.)' The Inmates find this j . estimate to be totally lacking in substance. To suggest that 2,500 inmates can l l i b;be loaded onto the various buses and vans within a 30 minute time frame is

absurd. For these reasons, the Inmates chose not to rely upon Mr. Lieberman's

[!

? testimony. Instead, they relied upon the testimony of Robert Morris, whose  :

i 1 resume was included as Applicant's Exhibit 6 to his deposition and indicates a

. i l l L  :

4

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• l wealth of experience in the area of traffic control. The Inmates continue to I

insist that his' coments, spoken in easily understood, plain language, should

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fsupport the conclusion that .the estimated time' of evacuation failed to bcontemplate numerous oft recurring problems in such an evacuation. The fact d

Uthat he has never done an evacuation plan for a nuclear power plant or his lack d

of familiarity with NUREG 0654, should not diminish his credentials or his Jtestimony. Thus, the Inmates continue to insist that his testimony regarding d

lthe potential for accidents, panic, meterological conditions, and corridor l! closings should be given its proper weight. (See Morris Deposition, pp. 42-44, 0[60,78-79.) '

I B. REJECTED CCNTENTIONS i 1. Input of correctional officers (AFSCME). The Inmates request

. .l this Honorable Comission to review the Appeal Board's rejection of the Inmates' request for input from the correctional officers union. This proposed revised

$ contention was rejected as a contention and said rejection was affirmed in

!i

,ALAB-845. The Inmates continue to insist that a workable plan depends upon lapproval of the participants in the plan. As the correctional officers are unionized under the banner of the American Federation of State, County and Municipal Employees, it is our position that said group should be allowed input i

linto the ongoing process which is designed to formulate a workable evacuation T

g 1 plan. Despite the Appeal Board's agruments to the contrary, the Inmates respectfully reg'iest this Honorable Commission to allow the input of the

! correctional officers through their union representatives.

h j 2. Simulated Evacuation Plan Exercise. The Appeal Board has (rejected the Inmates' request for additional assurances as to the adequacy of kthe simulated evacuation plan exercise conducted on March 7, 1985. The e

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deficiencias which the Inmntes cited with respect to the simulcted evacuation y

plan, go beyond the ones discussed in ALAB-845. As their brief pointed (out, the exercise failed ' to identify specific personnel at the State Correctional Institute at Graterford who were involved in the drill. It would appear that the majority of the actions occurred in the Camp 11111 office of the 1

0DepartmentofCorrections. This alleged deficiency was not addressed in the

[AppealBoarddecisionofALAB-845._ For these reasons and others previously cited, the Inmates continue to request that this issue be allowed development at the hearing stage.

3. Panic Factor. In light ' f the o tremendous danger posed by both a nuclear accident and the movement of a maximum security inmate population, the UInmates requested the opportunity to place on the record their concerns 0

-[regarding the potential for panic and disruption during such a contemplated i

evacuation. This case presents a novel fact pattern and thus a case of'first impression for the Nuclear Regulatory Commission. As a prison the size of qGraterford has never before been inclulded within the 10 mile EPZ surrounding i

ha nuclear facility, the Inmates believe that common sense dictates 4

':a thorough analyses of all potential disruptive scenarios during a contemplated evacuation. For these reasons, the Inmates had requested the opportunity to develop the record in light of the many historical incidents ii that had occurred at the facility. The Inmates believe that such a unique I

fact pattern should create a prima facie' case warranting admission.of this contention. The avoidance of this issue throughout the proceedings leads the Inmates to believe once again that the Commission is seeking only a paper review of the plan and not a workable evacuation that will protect the Inmates and d

lpublicalike.

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'h C. Fairness of the Hearing. The Inmates continue to pursue their

! claim thati they have been denied their right to a fair and impartial hearing as

. guaranteed by the Commission's regulations, (see 10 C.F.R. 2.718) and by the i

.Fifth and Fourteenth Amendments of the United States Constitution. These

1 amendments create the requirements of the process due an individual in a

!proceduralsetting. In addition to the arguments previously cited, the Inmates <

4

/ contend that the lack of recognition of in forma pauperis status has further d ~

hampered their ability to receive a fair and impartial hearing before -this o

dtribunal. 'Ihe Inmates note that their lack of ability to apply for such status 0

has significantly impaired their opportunity to present their case to the d

FConunission. The Inmates know of no other courts or agencies which deny this -!

l fundamental concept of our legal system. (See 28 USC Sec.1915 and Pa. R.C.P.

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(240.) The United States Supreme Court has stated, "It is now established j,beyond doubt that prisoners have a constitutional right of access to the

!j .

! courts." Bounds v. Smith, 430 U.S. 817, 821, 97 S.Ct.1491 (1977). It has d

(further held that, " Regulations and practices that unjustifiably obstruct the 11

> availability of professional representation or other aspects of the right of il

[accesstothecourtsareinvalid." Procunier v. Martinez, 416 U.S. 3%, 94 ,

4 S.Ct. 1800 (1974). The source of this right can be found in both the due (process clause of the Fif th and Fourteenth Amendments, and in the First

i

!Amendement of the United States Constitution. Procunier v. Martinez, supra.

I at 419. A review of the legislative history of the Nuclear Regulatory l

Commission provides further support for the Inmates' argument in favor of recognition of in forma pauperis status before the Connission. The Inmates cite r Ilthe legislative history surrounding the 1980 Reorganization Act which can h

(found at 42 U.S.C. 5841. President James Carter's message of March 27, 1980 l

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, j indicated a need to forter safety in c11 of the agency'c activitic:. In his haddress, President Carter suggested the possibility of funding intervenors so

'l that they could upgrade the licensing process and allow the public to have more input in the licensing process. Not only have his pleas for funding fallen on deaf ears, but the Comission continues to be one of the few legislative bodies g in our country that fails to recognize such status. Inherent in our concept of

'i

[ government is the tradition that all parties, regardless of their financial 1

capabilities, are entitled to an equal chance before the courts of our land.

The Inmates note that the costs of transcripts alone are considerable and without such tools, hamper their ability to equally and fully participate in

[!

this litigation. As previously cited in the Inmates Response to the Atomic ,

[ Safety and Licensing Appeal Board Order of June 3,1986 (unpablished), the l'0 Inmates were asked to coment on certain matters which had transpired during the closed conferences in Harrisburg. The Inmates' responce was that they had no hidea what the Board was talking about as they were not able to obtain copies of d

othese transcripts in order to effectively respond. This is but one example of h

f the many ways that the failure to recognize such status has hindered their ability to participate equally with the other parties involved in this litigation. The Inmates respectfully request the Commission to extend its

. discretion to review any and all parts of this Memorandum on behalf of the i

' Inmates of the State Correctional Institute at Graterford.

Respectfully sutmitted, 3

b/LAA M GJS R. VE, ESQtfIRE \ "

Attorney cr Inmates, SCIG bbntgcmer - hinty Legal Aid l

107 East Lgin Street Norristown, PA 19401 I'

(215) 275-5400 I

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!' 00tKETED UiNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'86 SEP 16 A10:33 t

f In the Matter of  :

[0C BPMIDi b d i 5-PHILADELPHIA ELECTRIC COMPANY -

l (Limerick Generating Station, j Units 1 and 2)  : Docket Nos. 50-352, 50-353 j

] CERTIFICATE OF SERVICE 9

d, i I, Angus R. Love, Esquire, attorney for the Inmates at I

the State Correctional Institute at Graterford, hereby certify -

that a true and correct copy of Inmates' PETITION FOR REVIEW was sent to the Service List below on September 12, 1986 via 1 first class mail.

Il

.i p Administrative Judge Helen F. Hoyt Robert W. Sugarman, Esquire

/ Atomic Safety & Licensing Board Sugarman, Denworth & Hellegers h U.S. Nuclear Regulatory Commission 16th F1., Center Plaza d Washington, D.C. 20555 101 N. Broad Street Philadelphia, PA 19107 Administrative Judge Jerry Harbour Atomic Safety & Licensing Board Docket & Service Station U.S. Nuclear Regulatory Cmmission U.S. Nuclear Regulatory Conm.

q Washington, D.C. 20555 Washington, D.C. 20555 (3 copies)

, Ann P. Hodgdon, Esquire j Counsel for NRC Staff Mr. Robert L. Anthony jiOfficeoftheExecutiveLegalDirector 103 Vernon Lane, Box 186 i

U.S. Nuclear Regulatory Ccemission bbylan, PA 19065 j Washington, D.C. 20555 I David Wersan, Esq.

g Martha W. Bush, Esquire Asst. Consumer Advocate g Municipal Services Bldg. Office of Consumer Advocate a 15th & JFK Blvd. 1425 Strawberry Square Philadelphia, PA 19107 Harrisburg, PA 17120

,i Atomic Safety & Licensing Atomic Safety & Licensing Board

Appeal Board Panel Panel l U.S. Nuclear Regulatory Conm.

hl U.S. NuclearD.C.

Washington, Regulatory 20555 Conmission Washington, D.C. 20555 i

L Frank Romano Jay M. Gutierrez, Esq.

61 Forest Avenue U.S. Nuclear Regulatory Com.

i Ambler, PA 19002 Region 1 631 Park Avenue .

l Zori G. Ferkin, Esquire King of Prussia, PA 19406 i

Governor's Energy Council P.o. Box 8010 Phyllis Zitzer 1625 N. Front St. Limerick Ecology Action l Harrisburg, PA 17105

. P.O. Box 761 762 Queen St.

l Mr. Thomas Gerusky, Director Pottstown, PA 19464 i Bureau of Radiation Protection Dept. of Environmental Resources Charles W. Elliott, Esq.

Fulton Bank Bldg., 5th F1. Counsel for Limerick Ecology Third & Incust Sts. Action Harrisburg, PA 17120 325 N. 10th Street

. Easton, PA 18042 Spence W. Perry, Esq.

Associate General Counsel Eugene J. Bradley, Esq. .

FEMA Room 840 Counsel for Philadelphia Electric 500 CT St., SW 2301 Market Street Washington,'D.C. 20472 Philadelphia, PA 19101 James Wiggins Edward G. Bauer, Jr.

Sr. Resident Inspector V.P. and General Counsel U.S. Nuclear Regulatory Com. Philadelphia Electric Co.

P.O. Box 47 2301 Market Street Sanatoga, PA 19464 Philadelphia, PA 19101 Timothy R.S. Campbell, Director Steven P. Hershey, Esq.

Dept. of Fmergency Services Comunity Legal Services, Inc.

14 East Biddle Street 5219 Chestnut Street West Chester, PA 19380 Philadelphia, PA 19139 Director Penna. Emergency Management Agency

Basement, Transportation Bldg.

Harrisburg, PA 17120 Arthur E. Gowran U.S. Dept. of Justice Appellate Section Land Division 10th & Penna. Ave. NW Washington, D.C. 20530 Theodore G. Otto, III, Esq. /

, Dept. of Corrections . /MMVE, ESQtrIR4

ArsJs R.

i Office of Chief Counsel P.O. Box 598 Montgomer  ::ounty Legal Aid Camp Hill, PA 17011 counsel o Inmates, SCIG Troy B. Conner, Jr., Esq.

Conner & Wettehahn 1747 Penna. Ave. NW Suite 1050 Washington, D.C. 20006