ML20245L494

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

ML20245L494
Person / Time
Site:	Limerick
Issue date:	05/04/1989
From:	Love A GRATERFORD INMATES, LOVE, A.R.
To:	PENNSYLVANIA, COMMONWEALTH OF
References
CON-#289-8564 89-587-03-OL, 89-587-3-OL, OL, NUDOCS 8905080057
Download: ML20245L494 (8)

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i' UNITED STATES OF AMERICA NUCIEAR REGUIAIORY COMMISSION 89 MY -4 P2 :04 AICMIC SAFETY AND LICENSING BOARD

,;r r BEFORE ADMINISTRATIVE JUDGES Morton B. Margulies, Chairman Jerry Harbour Jerry R. Kline In the Matter of

Docket Nos. 50-352-OL 50-353-OL PHILADELPHIA ELECTRIC COMPANY

ASLBP No. 89-587-03-OL-R (Limerick Generating Station, Units 1 and 2)

GRATERFORD IlttATES' FIRST SET OF INTERROGATORIES FOR PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY and PRODUCTION OF DOCUMENPS REQUEST The Graterford Inmates, through their attorney, Angus R. Love, hereby request the Pennsylvania Emergency Management Agency to answer the following Interrogatories, pursuant to 10 C.F.R. 2.740(b) within thirty (30) days from service thereof.

These Interrogatories shall be deemed continuing so as to require supplemental answers if affiant, or anyone on their behalf, obtains further information between the time the answers are served and the time of trial.

1.

Is the Pennsylvania Emergency Management Agency responsible for conducting the training of civilian personnel to be utilized in the Radiological Emergency Response Plan for the State Correctional Institute at Graterford with respect to the above-captioned matter?

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2 Please identify all persons in need of radiological engergency response training with regard to the Radiological Emergency Response Plan for SCIG.

3.

Please identify all civilian personnel to be utilized in the plan.

4.-

Please describe the' assigned roles or functions of the civilian personnel to be utilized in the plan.

5.

Please identify all bus and ambulance providers, tcluding name of -

provider, address, and number of buses or ambulances to be provided.

6.

Is Donald Taylor still an employee of.PEMA?

7.

Did Donald Taylor write a letter to six bus companies on April 4,1985 offering dosimatry and decontamination training to potential drivers of said-bus companies?

8.

Did PEMA receive any oral or written responses to said letter of April 4, 1985? _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

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Did Donald Taylor or any other employee of PEMA visit the bus and ambulance companies in order to urge them to take advantage of the offer mentioned in the April 4,1985 letter? If so, on what dates were such visits made, who was contacted, what was the nature of the contact, what is the title of each person contacted, and where was the contact made?

10. What response did the bus and ambulance providers give following the l

PEMA contacts? Was the response oral or in writing? When were.the responses i

received and by whom? Please provide the foregoing information regarding each response that was received.

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On what dates was training provided to the bus and ambulance drivers?

i Where was'the training held, how long did it last, and how many persons attended i

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each session?

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12. What was the nature of the training provided?

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13. Was training provided in dosimatry and thermoluminescent dosimatry?

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14. Did training include a general orientation and overview of radiological principles, emergency management principles, and background information?

15.

Were bus' and ambulance drivers provided self-reading dosimatry equipnent during the training sessions?

16.

Were bus and ambulance drivers tested on the use' of dosimatry equipment? Were such results recorded? If so, what were the results?

17. - What were the names, addresses, and employers of the teachers at each training session?

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18. Was training provided on the governmental response to disasters and the-levels of radiation during an incident at a fixed nuclear facility?

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Was training provided regarding the security precautions that will be taken for the protection of the drivers?

20.

Were the bus and ambulance drivers paid for attendance at the training sessions? If so, how much were they paid ard by whom?

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21. Does PEMA have the responsibility to provide retraining of personnel to be utilized in the evacuation plan? If so, how often is said retraining given?

22.

Please provide the dates and locations of each retraining session, including the number and identity of the trainers and participants.

23.

What provisions are made to train new employees who were hired after the initial training sessions?

PRODUCTION OF DOCUMENTS REQUEST Graterford Inmates hereby request the production of the following documents pursuant to 10 C.F.R. 2.741 within thirty (30) days, l.

Please produce all correspondence received from bus and ambulance providers pursuant to the April 4,1985 letter offering training.

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Please produce all correspondence received from the bus and ambulance providers pursuant to the personal contact follow-up visits to each bus and ambulance provider.

Please produce the name and address of each bus and ambulance provider.

3.

Please produce verification, such as travel reimbursement vouchers, for Donald Taylor's follow-up visits to each bus and ambulance provider.

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Please produce any written announcements of the time and place of the initial training sessions.

5.

Please produce all course materials presented during the initial training sessions.

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Please proudce attendance records for each training session.

7.

Please produce the test results of dosimatry training for each trainee at each session.

8.

Please produce any correspondence announcing the refresher training sessions.

9.

Please produce attendance records of the refresher courses.

10. Please produce any written materials distributed at the refresher training courses.

11.

Please produce the dosimatry training test results at the refresher Courses.

12.

Please produce records regarding compensation provided to trainers at both the initial and refresher training sessions.

13.

Please produce any records regarding financial reimbursements to any trainees at the initial and refresher training sessions.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'89 MY -4 P2 :05 ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES

$;'>~,,[,.y Morton B. Margulies, chairman wan -

Jerry Harbour Jerry R. Kline In the Matter of Docket Nos. 50-352-OL 50-353-OL PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)

ASLBP No. 89-587-03-OL-R CERTIFICATE OF SERVICE

-I, Angus R. Love, Esquire, attorney for the Inmates at the State Correctional Institute at Graterford, hereby certify that a true and correct copy of the GRATEFORD INMATES' FIRST SET OF INTERROGATORIES FOR THE PENNSYLVANIA DEPARTMENT OF CORRECTIONS and THE PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY and PRODUCTION OF DOCUMENTS REQUEST, was sent, via first class mail, postage 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, Ibrton B Margulies Office of the General Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Charles W. Elliott, Esquire Docket & Service Station 325 N. 10th Street U.S. Nuclear Regulatory Commission Easton, PA. 18042 Washington, D.C. 20555

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

Chief Counsel 1

1747 Pennsylvania Avenue, N.W.

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

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