ML20245L419

Graterford Inmates First Set of Interrogatories for Commonwealth of PA Dept of Corrections & Production of Documents Request.* Certificate of Svc Encl.Related Correspondence

ML20245L419
Person / Time
Site:	Limerick
Issue date:	05/04/1989
From:	Love A GRATERFORD INMATES, LOVE, A.R.
To:	PENNSYLVANIA, COMMONWEALTH OF
References
CON-#289-8565 89-587-03-OL, 89-587-3-OL, OL, NUDOCS 8905080031
Download: ML20245L419 (7)

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((fBIED,gE8gsyg!!D&N3 COLMETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'89 MAY -4 P2 :03 ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES

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l Morton B. Margulies, Chairman

$3 Jerry Harbour Jerry R. Kline In the Matter of Docket Nos. 50-352-OL 50-353-OL PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, ASLBP No. 89-587-03-OL-R Units 1 and 2)

GRATERFORD INMATES' FIRST SET OF INTERROGATORIES FOR THE PENNSYLVANIA DEPARTMENT OF CORRECTIONS and PRODUCTION OF DOCUMENTS REQUEST The Graterford Inmates, through their attorney, Angus R. Love, hereby request the Pennsylvania Department of Corrections to answer the following Interrogatories, pursuant to 10 C.F.R. 2.740(b) with-in thirty (30) days from service thereof.

These Interrogatories shall_be deemed continuing so as to require supplemental answers if I

affiant, or anyone on their behalf, obtains further information be--

tween the time the answers are served and the time of trial.

1.

What role will the Pennsylvania Department of Corrections have in providing bus and ambulance drivers to be used in the Radiological Emergency Response Plan for the State Correctional 8905080031 890504 PDR ADDCK 05000352 O

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Institute at Graterford?

i 2.

Are correctional officers going to be called upon to drive the buses and ambulances in the event that civilian personnel are unavailable for thefr assigned tasks in the Radiological Emergency Response Plan for the State Correctional Institute at Graterford?

3.

.How many correctional officers employed by the Department.

of-Corrections have Class 2 driver's licenses?

4.

Please identify.the location of employment for each such

driver, i.e. which correctional institute are they assigned to?

5.

What training has been given to the employees holding Class 2 driver's license regarding their possible involvement in the Radiological Emergency Response Plan for the State Correctional Institute at Graterford?

6.

Please provide the content of any training given to such l

individuals.

Did the training include an overview of radiological principles, training in the use of dostmatry equipment, and emergency.. = _ _ _ _.- _ _ _ - - _ _ _ _ - _ - _ -.

I management principles?

l 7.

Please provide the dates, places and length of each training.

8.

Please provide attendance records for each such training session.

9.

Please provide the names and professional affiliations of i'

all trainers at each session.

i 10.

Please provide results of any tests given during each training session for each participant.

11.

Have the employees holding Class 2 driver!s licenses received retraining since the initial session?

If so, where, when, and by whom were these refresher courses given?

12.

What provisions have been made to handle the additional capacity of inmates at the State Correctional Institute at

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Graterford.since the initial development'of.the Radiological 1

. Emergency Response-Plan?

13.

Please provide the names and addresses of each bus company to be utilized in the Radiological Emergency Response Plan, and i

the number of buses each company will provide.

14.

Please provide the names and addresses of each ambulance company, including the number of ambulances available, that will be used in the Radiological Emergency Response Plan for Graterford.

PRODUCTION OF DOCUMENTS REQUEST 1

1.

Please produce any and all documentation regarding the course content at the training and refresher training sessions for employees with Class 2 driver's licenses who will be utilized in the Radiological Emergency Response Plan for Graterford in the event that civilian personnel are unavailable, i

2.

Please provide attendance records of all training and retraining sessions for the above-mentioned personnel.

3.

'Please provide test results for training in dosimatry equipment during the training and retraining sessions for all above-mentioned personnel.

4 Please provide all letters of agreement from bus companies who will be utilized in the Radiological Emergency Response Plan for Graterford.

5.

Please provide letters of agreement for all ambulance companies ~to be utilized in the Radiological Emergency Response Plan for Graterford.

6.

Please provide any correspondence regarding the scheduling of training for correctional officers with Class 2 driver's licenses who may be used in the Radiological-Emergency Response Plan for Craterford.

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MONTGOME COUN E AL AID 107 EAST FAIN STREET NORRIST W, PA 19401 (215) 2

-5400 ATTY I.D. #22392

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES OFR.

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Morton B. Margulies, chairman 00CKE.-71Q.q

' Jerry Harbour

~

Jerry R. Kline l

In the Matter of Docket Nos. 50-352-OL 50-353-OL PHILADELPHIA ELECTRIC COMPANY

.e (Limerick Generating Station, Units 1 and 2)

ASLBP No. 89-58 7-03-OL-R CERTIFICA,TE OF SERVICE I, Angus R. Love, Esquire, attorney for the Inmates at the State Correctional Institute at Graterford, hereby certify that l.

a tree and correct copy of the GRATEFORD INMATES' FIRST SET OF l

INTERROG/. TORIES FOR THE PENNSYLVANIA DEPARTMENT OF CORRECTIONS and THE PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY and PRODUCTION GF DOCUMENTS REQUEST, was sent, via first class mail, postage

1. p' prepaid to the Service List below, and the original and two copies to the Docket & Service Station, on May 1,1989.

Administrative Judge Joseph Rutberg, Esquire Chairman, & rtonH. Margulies Office of the General Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Conmission Washington, D.C. 20555 Washington, D.C. 20555

)

Charles W. Elliott, Esquire

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Docket & Service Station 325 N. 10th Street i

U.S. Nuclear Regulatory Comission Easton, PA. 18042 Washington, D.C. 20555 9

Troy B. Conner, Jr., Esquire Theodore G. Otto, III, Esquire Conner & Wetterhahn, P.C.

Chief Counsel 1747 Pennsylvania Avenue, N.W.

Pennsylvania Department of Corrections Washington, D.C. 20006 P.O. Box 598 Camp Hill, PA 17011 3

Michael B. Hirsch, Esquire Federal Emergency Management Agency John L. Patten, Director 500 C Street, S.W.

Pennsylvania Emergency Management Washington, D.C. 20472 Agency Transportation & Safety Building RA B-151 Harrisburg, PA 17120 h$h

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A!LUd R. LOVE, /ESQU1KDs y

&ntgomery nty legal Aid 107 East Street Norristown 19401 (215) 275-Atty I.D. #22392 l

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