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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20151L3671997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Orders That SA Blacklock Prohibited from Engaging in Activities Licensed by NRC for 5 Yrs from Date of Order ML20151L5181997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately) Re SL Nevin Deliberately Falsifying Records of RECW Sample Documentation on 960207 ML20203H6891997-06-0202 June 1997 Transcript of 970602 Enforcement Conference in King of Prussia,Pa ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20045D8121993-06-14014 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54 Re FSAR Update Submittals. ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20062C6561990-10-22022 October 1990 Affidavit Requesting Withholding of Summary Rept on Evaluation of Recirculation Nozzle to Safe End Weld Indication & Proposed Disposition to Permit Unit 1 Cycle 4 Operation, from Public Disclosure,Per 10CFR2.790 ML20246J4521989-08-30030 August 1989 Memorandum & Order (Terminating Proceeding).* Terminates Proceeding Per Settlement Agreement Between Limerick Ecology Action,Inc & Licensee.W/Certificate of Svc.Served on 890831 ML20246F1471989-08-25025 August 1989 Settlement Agreement.* Certificate of Svc Encl ML20246F1011989-08-25025 August 1989 Joint Motion for Termination of Proceedings.* Board Moved to Accept Encl Settlement Agreement,Dismiss Limerick Ecology Action,Inc (Lea) Contention W/Prejudice,Dismiss Lea as Party to Proceeding & Terminate Proceeding ML20246F0121989-08-25025 August 1989 Memorandum & Order CLI-89-17.* Staff Authorizes Issuance of Full Power License to Licensee to Operate Unit 2 After Requisite Safety Findings Under 10CFR50.57 Completed. W/Certificate of Svc ML20246E3431989-08-22022 August 1989 Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc ML20246C0271989-08-18018 August 1989 Notice of Appointment of Adjudicatory Employee.* Informs That D Nash Appointed as Commission Adjudicatory Employee to Advise Commission on Issues in Proceeding.W/Certificate of Svc.Served on 890818 ML20246B7721989-08-17017 August 1989 Correction of Memorandum & Order of 890815.* Advises That Refs to 49CFR2.730(c) on Page 1 & 49CFR2.710 & 49CFR2.711 on Page 2 Should Be Corrected to Read as 10CFR2.730(c),2.710 & 2.711,respectively.W/Certificate of Svc.Served on 890818 ML20246D7411989-08-17017 August 1989 Transcript of 890817 Meeting in Rockville,Md Re Discussion of Full Power OL for Facility.Pp 1-58.Supporting Documentation Encl ML20246B7571989-08-16016 August 1989 Order Responding to Limerick Ecology Action Motion for Reconsideration.* Denies Motion to Reconsider,Stay,Suspend or Revoke 890707 Order on Basis That Order Appropriate.W/ Certificate of Svc.Served on 890816.Re-served on 890818 ML20246B7751989-08-16016 August 1989 Memorandum & Order.* Denies Rl Anthony 890623 Request for Hearing for Intervention in Remand Proceeding & for Stay of Low Power Authorization.W/Certificate of Svc.Served on 890816 ML20246B7931989-08-15015 August 1989 Memorandum & Order (Request for Expedited Answer).* Denies Licensee 890811 Request for Expedited Answer from NRC & Limerick Ecology Action on Basis That Request Lacks Good Cause.W/Certificate of Svc.Served on 890816 ML20245H8061989-08-14014 August 1989 Supplemental Response of Intervenor Limerick Ecology Action, Inc to Memorandum & Order of Commission & to Memorandum & Order of 890807.* Requests Further Extension of Time in Which to Reply.Certificate of Svc Encl ML20245H8491989-08-14014 August 1989 Notice of Change of Address.* Advises of Council Change of Address for Svc of Documents ML20245H5991989-08-11011 August 1989 Memorandum & Order (Terminating Proceeding).* Dismisses Graterford Inmates Contention Re Adequacy of Training for Drivers Responsible for Evacuating Graterford & Terminates Proceeding.Certificate of Svc Encl.Served on 890814 ML20245H7341989-08-10010 August 1989 Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing & Request for Expedited Answer to This Motion.* Divergence in Positions of Respective Parties Emphasizes Need to Conclude Proceeding.W/Certificate of Svc ML20245F7511989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to NRC Staff Response to Commission Questions.* Commission Should Rely on Licensee Cost Analysis in Response to Question 5 & Rc Williams Affidavit.W/Certificate of Svc ML20245F7341989-08-0909 August 1989 NRC Staff Response to Commission Memorandum & Order of 890807.* Advises That NRC Will Provide Comments on Limerick Ecology Action 890814 Filing Prior to Commission Meeting Scheduled for 890817.W/Certificate of Svc ML20245F7161989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Environ Benefits for Operating Unit 2 Outweigh Small Risk of Severe Accident ML20245F7291989-08-0808 August 1989 Affidavit.* Discusses Costs Incurred While Plant Inoperable. Allowance for Funds Used During Const,Security,Maint & Operational Costs Considered Proper for Calculating Costs for Delay ML20248D9241989-08-0707 August 1989 Memorandum & Order.* Extends Limerick Ecology Action Response Deadline to 890814 to Respond to Five Questions Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890807 ML20248D7871989-08-0303 August 1989 Correction for NRC Staff Response to Commission Questions.* Forwards Corrected Page 5 to NRC Response to Questions Filed on 890802,deleting Phrase by Nearly Factor 2.5 in Next to Last Line.W/Certificate of Svc ML20248D5391989-08-0202 August 1989 Affidavit of MT Masnik.* Advises That Author Prepared Response to Question 3 ML20248D7111989-08-0202 August 1989 Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Commission Order Fails to Provide Intervenor Adequate Time for Response & Should Therefore Be Revoked.W/Certificate of Svc ML20248D5671989-08-0202 August 1989 Affidavit of SE Feld.* Advises That Author Prepared Response to Question 5.W/Certificate of Svc ML20248D4971989-08-0202 August 1989 Joint Affidavit of Gy Suh & CS Hinson.* Advises That Authors Prepared Responses to Questions 1 & 4 ML20248D6451989-08-0202 August 1989 Affidavit.* Advises That Author Read Responses to Request for Comments by NRC & Knows Contents.W/Certificate of Svc ML20248D4721989-08-0202 August 1989 NRC Staff Response to Commission Questions.* Provides Info for Use in Commission Effectiveness Review of Plant Full Power Operation,Per Commission 890726 Memorandum & Order. Supporting Affidavits Encl ML20248D5981989-08-0202 August 1989 Response by Licensee Philadelphia Electric Co to Commission Request for Comments by Memorandum & Order Dtd 890726.* Licensee Requests Commission Issue Full Power OL for Unit 2 Conditioned Upon Outcome of Pending Litigation ML20248D5311989-08-0202 August 1989 Affidavit of Rj Barrett.* Advises That Author Prepared Response to Question 2 ML20245J1321989-07-27027 July 1989 Transcript of 890727 Meeting in Rockville,Md Re Facility Severe Accident Mitigation Issues.Pp 1-130.Supporting Info Encl ML20247N3261989-07-26026 July 1989 Transcript of 890726 Affirmation/Discussion & Vote in Rockville,Md on SECY-89-220 Re Order Requesting Info from Parties for Immediate Effectiveness Review of Full Power Authorization for Limerick Unit 2.Pp 1-4 ML20248D7331989-07-24024 July 1989 Second Rept of Parties & Request for Dismissal of Graterford Inmates Contention & Termination of Proceeding.* Requests Board to Enter Order to Terminate Proceeding Based on Parties Agreeing to Dismissal of Remaining Contention ML20247Q4621989-07-23023 July 1989 Response of Intervenor Rl Anthony to Answer of Philadelphia Electric Co (PECO) to Request for Hearing on PECO Application for Low Power Operation of Unit 2 & Stay of Any Operation in Keeping W/Us Circuit Court Remand Of....* ML20247B7261989-07-20020 July 1989 Notice of Appointment of Adjudicatory Employee.* Advises That H Vandermole Appointed to Advise Commission on Issues in Proceeding Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890720 ML20247B3821989-07-18018 July 1989 Memorandum & Order.* Orders That Severe Accident Mitigation Alternatives,Per Nepa,To Be Considered Include Containment Heat Removal,Core Residue Capture & Venting.Certificate of Encl.Served on 890719 ML20247B7641989-07-13013 July 1989 Motion of Intervenor,Limerick Ecology Action Inc,To Reconsider/Stay/Suspend/Revoke Order Authorizing Issuance of Low Power OL for Limerick 2.* Consideration of Accident Mitigation Alternatives Imperative.Certificate of Svc Encl 1997-08-05
[Table view] Category:PLEADINGS
MONTHYEARML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20246F1011989-08-25025 August 1989 Joint Motion for Termination of Proceedings.* Board Moved to Accept Encl Settlement Agreement,Dismiss Limerick Ecology Action,Inc (Lea) Contention W/Prejudice,Dismiss Lea as Party to Proceeding & Terminate Proceeding ML20246E3431989-08-22022 August 1989 Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc ML20245H8061989-08-14014 August 1989 Supplemental Response of Intervenor Limerick Ecology Action, Inc to Memorandum & Order of Commission & to Memorandum & Order of 890807.* Requests Further Extension of Time in Which to Reply.Certificate of Svc Encl ML20245H7341989-08-10010 August 1989 Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing & Request for Expedited Answer to This Motion.* Divergence in Positions of Respective Parties Emphasizes Need to Conclude Proceeding.W/Certificate of Svc ML20245F7511989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to NRC Staff Response to Commission Questions.* Commission Should Rely on Licensee Cost Analysis in Response to Question 5 & Rc Williams Affidavit.W/Certificate of Svc ML20245F7161989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Environ Benefits for Operating Unit 2 Outweigh Small Risk of Severe Accident ML20248D5981989-08-0202 August 1989 Response by Licensee Philadelphia Electric Co to Commission Request for Comments by Memorandum & Order Dtd 890726.* Licensee Requests Commission Issue Full Power OL for Unit 2 Conditioned Upon Outcome of Pending Litigation ML20248D7111989-08-0202 August 1989 Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Commission Order Fails to Provide Intervenor Adequate Time for Response & Should Therefore Be Revoked.W/Certificate of Svc ML20247Q4621989-07-23023 July 1989 Response of Intervenor Rl Anthony to Answer of Philadelphia Electric Co (PECO) to Request for Hearing on PECO Application for Low Power Operation of Unit 2 & Stay of Any Operation in Keeping W/Us Circuit Court Remand Of....* ML20247B7641989-07-13013 July 1989 Motion of Intervenor,Limerick Ecology Action Inc,To Reconsider/Stay/Suspend/Revoke Order Authorizing Issuance of Low Power OL for Limerick 2.* Consideration of Accident Mitigation Alternatives Imperative.Certificate of Svc Encl ML20246P4951989-07-0303 July 1989 Licensee Memorandum Re Proposed Design Mitigation Alternatives for Which Agreement Among Parties Could Not Be Reached.* Only Specific Alternatives Being Considered by Licensee & Should Be Given Attention.W/Certificate of Svc ML20246P3321989-07-0303 July 1989 NRC Staff Memorandum Supporting Staff Position Re Alternatives to Be Litigated.* Board Should Reject Limerick Ecology Action Suggested Items for Litigation Considered Outside of Scope of Remand.W/Certificate of Svc ML20246N9971989-06-30030 June 1989 Memorandum of Limerick Ecology Action,Inc,Per Prehearing Conference Order of ASLB of 890609.* Proposed Alternatives for Severe Accident Mitigation within Scope of Proceeding on Remand.Certificate of Svc Encl ML20245D2691989-06-21021 June 1989 Applicant Reply Memorandum in Support of Motion for Clarification Or,Alternatively,For Exemption.* Commission Should Determine That NRC Fully Authorized to Issue OL for Facility & Be Directed,Per 10CFR51.6.W/Certificate of Svc ML20245A5981989-06-15015 June 1989 Opposition of Limerick Ecology Action,Inc to Applicant Motion for Clarification of Commission Delegation of Authority & for Issuance of Ol,Or Alternatively,For Exemption from Procedural....* W/Certificate of Svc ML20245A5811989-06-15015 June 1989 Opposition of Commonwealth of PA to Motion of Philadelphia Electric Co for Clarification of Commission Delegation of Authority & for Issuance of OL & Opposition to Motion for Exemption.* W/Certificate of Svc ML20248B7471989-06-0505 June 1989 Applicant Motion for Clarification of Commission Delegation of Authority & for Issuance of Ol,Or,Alternatively,For Exemption from Procedural Requirement That License for Limerick Unit 2 Cannot Issue Until Contention Remanded....* ML20151T6901988-04-25025 April 1988 Response of Intervenor Rl Anthony to PECO 880331 Response & NRC Staff 880404.* Denial of Applicant Motion for Summary Disposition & Application for License Amend Urged ML20150F8721988-03-31031 March 1988 Licensee Response to Order of 880317 Requesting Clarifying Info.* Clarifying Info Needed to Decide Parties Submissions on Licensee Motion for Summary Disposition ML20149K9821988-02-18018 February 1988 Response of NRC Staff in Support of Licensee Motion for Summary Disposition.* NRC Agrees W/Licensee Motion Because No Genuine Issue of Matl Fact Exists to Be Litigated. Consolidated Contention & Proceeding Should Be Dismissed ML20196D6751988-02-0909 February 1988 Response in Opposition to Licensee Request for Summary of Disposition of Air & Water Pollution Patrol Opposition to Licensee Application for Amend to License NPF-39 & Exemption to App J of 871218. * ML20235A8101988-01-0606 January 1988 Licensee Opposition to Intervenor Rl Anthony Request for Extension of Time for Discovery.* Intervenor Request Should Be Denied as Intervenor Had Adequate Opportunity to Review Responses & Pursue Addl Discovery.W/Certificate of Svc ML20235A8041988-01-0505 January 1988 Air & Water Pollution Patrol (Romano) Reaction to Licensee time-defaulted Response for Production of Documents as Ordered by NRC Administrative judges,871120.* Requests That Util Be Reprimanded for Defaulting on 871120 Order ML20238D1601987-12-20020 December 1987 Intervenor Rl Anthony Request for Extension of Time for Discovery.* Extension Requested Due to Listed Obstacles Which Have Prevented Study of Matl Provided & Matl Missing ML20236T1781987-11-23023 November 1987 Licensee Memorandum in Support of Motion for Summary Disposition,Preliminary Statement.* Proposed Amend Does Not Downgrade Reporting Requirements for Iodine Spikes. Consolidated Contention & Proceeding Should Be Dismissed ML20236T1611987-11-23023 November 1987 Licensee Motion for Summary Disposition.* Forwards Util Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard,Memorandum in Support of Motion for Summary Disposition & J Doering & Js Wiley Affidavits ML20236P8241987-11-12012 November 1987 Air & Water Pollution Patrol (Awpp) (Romano) Objection to Licensee Objection to Intervenor Awpp Request for Opportunity to File for Discovery & Motion for Protective Order.* Failure to Monitor Proceeding Inadvertent ML20236P8971987-11-10010 November 1987 Intervenor Rl Anthony Objection to Philadelphia Electric Co Objection to Anthony Discovery & Request for Protective Order Dtd 871030.* Only Essential Matl for Appeal of Granting License Amend Requested ML20236N8971987-11-0909 November 1987 Response of NRC Staff to Rl Anthony Discovery Requests & Licensee Objections Thereto.* ASLB Should Deny Request,But Protective Order Not Opposed.Certificate of Svc Encl.Related Correspondence ML20236N8351987-11-0909 November 1987 Response of NRC Staff to Air & Water Pollution Patrol Motion of 871027 Concerning Summary Disposition & Discovery & Licensees Objections Thereto.* Motion Should Be Denied. Certificate of Svc Encl ML20236L7471987-11-0202 November 1987 Licensee Objection to Intervenor Air & Water Pollution Patrol Request for Opportunity to File for Discovery & Motion for Protective Order.* Certificate of Svc Encl ML20236H3911987-10-30030 October 1987 Licensee Objection to Intervenor Anthony Request for Discovery & Motion for Protective Order.* Certificate of Svc Encl ML20236H4091987-10-27027 October 1987 Memorandum & Order (Memorializing Special Prehearing Conference;Ruling on Contentions).* Motion for Board to Summarily Dispose Util Request Instant Amend & for Exercise to Discovery ML20236H3401987-10-25025 October 1987 Intervenor Rl Anthony Response to 871009 Memorandum & Order.* Author Has No Further Requests for Info in Addition to Items Recorded in .Util Should Provide Listed Records ML20236R7731987-08-26026 August 1987 Suppl to Petitioner Response of 870702 to Board Notice of Hearing & Order of 870729.* Petitioner Lists Contentions Opposing Granting of License Amend to Tech Specs for Plant Re Matter of Radioactive Iodine Spikes ML20237G9731987-08-21021 August 1987 Air & Water Pollution Patrol Suppl to Opposition to Radioactive Iodine Amend for License NPF-39.* Concerns Expressed Re Unusual Sensitivity of Thyroid to Iodine. Licensee Does Not Merit Amend,Based on Util Past Conduct ML20235M1751987-07-13013 July 1987 Staff Reply to Licensee Answers to Petitioner Requests for Hearing & Motions to Intervene (Licensee Second Argument).* Air & Water Pollution Patrol & R Anthony Failed to Meet Stds for Intervention in Amend Proceedings.Aslb Denies Petition ML20235G5851987-07-0505 July 1987 Awpp (Romano) Answers Licensee Argument II as Per Order of 870522 Re Representational Standing.* Urges Licensee to Show Cause Why Cable Pulling Necessitates Greater Air Leakage from Reactor Openings ML20235J0491987-07-0202 July 1987 Response by Intervenor Rl Anthony to Board Order of 870622.* Licensee Opposed to License Amend & Request Hearing to Form Basis for Board to Deny Request.Reduction of Control Over Iodine Spikes & Levels Is Threat to Health of Public ML20215J7661987-06-16016 June 1987 NRC Staff Response to Licensee Answer in Opposition to Request for Hearing & Leave to Intervene by Air & Water Pollution Patrol.* Board Should Reject Licensee First Argument & Anthony Request for Hearing.W/Certificate of Svc ML20216D3641987-06-16016 June 1987 NRC Staff Response to Licensee Answer in Opposition to Request for Hearing & Leave to Intervene by Air & Water Pollution Patrol.* ASLB Should Reject Licensee First Argument & Anthony Request for Hearing.W/Certificate of Svc ML20215D9491987-06-0808 June 1987 Intervenor Rl Anthony Response to ASLB Order of 870522.* Licensee Position Mistaken Both in Relation to Correctness of Petition to Intervene & as to Intent of Citizen Participation Specified in NEPA & Aea.Served on 870616 ML20214W5531987-06-0202 June 1987 Response Opposing Util Request for Legal Loopholes to Prevent Groups w/long-term Commitment to Insure Licensee Does Better Job Abiding Rules Re Public Safety ML20214G6271987-05-19019 May 1987 Commonwealth of PA Opposition to Graterford Inmates Petition for Review of ALAB-863.* Graterford Inmates Failed to Prove That Aslab Decision Erroneous W/Respect to Important Question of Fact,Policy or Law.W/Certificate of Svc ML20214A9491987-05-18018 May 1987 NRC Staff Answer in Opposition to Petition for Review of Inmates of State Correctional Inst at Graterford.* Inmates Failed to Establish That Issues Raised Re ALAB-863 Warrant Review.Commission Should Deny Review.W/Certificate of Svc ML20210C1011987-05-0404 May 1987 Petition for Review.* Review of Aslab 870417 Decision ALAB-836 Requested to Determine If Reasonable Assurances Given That Sufficient Manpower Will Be Mobilized in Event of Evacuation.Certificate of Svc Encl ML20212K5141987-01-23023 January 1987 Response of NRC Staff in Opposition to Graterford Inmates Appeal of Licensing Board Suppl to Fourth Partial Initial Decision.* Certificate of Svc Encl ML20207P9441987-01-12012 January 1987 Commonwealth of PA Brief in Opposition to Appeal by Graterford Inmates of Suppl to Fourth Partial Initial Decision:Preliminary Statement.* W/Certificate of Svc 1993-10-22
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UNITED STATES OF AMERICA UCrTrico NUCLEAR REGULATORY COMMISSION d'E BEFORE'THE ATOMIC SAFETY AND LICENSIN07 BOARD
~6 MO :30 In the Matter of : Docket N67.'050--35 2c t. _,
J'.50-353V N
PHILADELPHIA ELECTRIC COMPANY '
(Limerick Generating Station,
SUPPLEMENTAL MOTION OF THE INMATES AT SCIG REGARDING FULL DISCLOSURE OF THE EVACUATION PLAN FOR SCIG I. INTRODUCTION
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On December 20, 1984, the inmates at the State Correction-al Institute at Graterford, Pennsylvania, filed a Motion before the Atomic Safety and Licensing Board requesting full disclosure of the evacuation plan for the State Correctional Institute at Graterford, Pennsylvania. On January 2, 1985, che Nuclear Regulatory Commission staff filed an Answer to said Motion. The applicant and the Pennsylvania Emergency Management Association also filed responses.- On January 22, 1985, during a public hear-ing before the Board, Chairman Hoyt requested counsel for the inmates to res' pond to the' N.R.L. staff request on page 5, which states, ". . . the inmates should be required to specify the informa-tion the'y need, based on expert opinion, which is beyond that .
provided in the sanitized' version." The purpose of this supplemental motion is to respond to this question.
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'1 II. Inmates have retained John Case, Field Director of the Penn~sylvania Prison Society as their expert.
Initially, the inmates would'like the record to reficct that they have retained the services of John Case to act as their expert in this matter. Mr. Case is currently the Field Director of the Pennsylvania Prison Society (see Vita attached as Exhibit A).
III. The' inmates' expert, John Case, requests that'all informa-tion contained in the unsanitized version of the evacuation plan is needed in order to ascertain the'vi' ability of'such, i
The inmates' expert, John Case, served twenty-one years in the United States Marine Corps (1942-62). During this period, he obtained a security rating of Top Secret "Q". It is his opinion that all the information contained in the sanitized ver-sion is necessary to determine the viability of the plan. He further indicated that said material is secure in his hands due to his prior security clearances in the Marine Corps and his top secret rating. He also indicated that the unsanitized version contains virtually no useful information, therefore further in-quiries as to the type of information needed are premature.
Accordingly, the inmates request full disclosure of the plan to 1
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their expert and counsel. See Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2, ALAB-592 11'N.R.C. (1980). .'
Respect. fully submitted Wf l .' ) M> L ,
GLS R. 'fDVT SQUi.RE Montgom :rC ty Legal Aid s
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matte of : ' Docket Nos. 50-352 50-353 UHILADELPHIAELECTRICCOMPANY (Limerick Generating Station, Units 1 and 2) :
CERTIFICATE OF SERVICE I, Angus R. Love, attorney for hsntes, .SCIQ, hereby certify thatatrueandaccuratecopyoftheSupplementalMotionoftbe Inmates at SCIG Regarding Full Disclosurs of the Evacuation Plan sfor SCIG, in reference to the above-captioned matter, was mailed on January 28, 1985 via regular first class mail, postage prepaid, to the following list:
Helen F. Hoyt, Chairperson Ms. Phyllis Zitzer, Pres.
Administrative Judge Ms. Maureen Mulligan Atomic Safety and Licensing Limerick Ecology Action Board Panel 762 Queen Street U.S. Nuclear Regulatory Commission Pottstown, PA 19462 Washington, D.C. 20555 Mr. Edward G. Bauer, Jr.
Dr. Richard F. Cole V.P. and General Counsel Administrative Judge Philadel?hia Electric Co.
Atomic Safety and Licensing 2301 Market Street Philadelphia, P A19101 i Board Panel U.S. Nuclear Regulatory Commission Troy B. Conner, Jr., Esq.
Washington, D.C. 20555 Mark J. Wetterhahn, Esq.
Dr. Jerry Harbour Conner and Wetterhahn Administrative Judge 1747 Pennsylvania Ave., N.W Atomic Safety and Licensing Washington, D.C. 20006 Board Panel Mr. Marvin I. Lewis U.S. Nuclear Regulatory Commission Washington, D.C. 20555 6504 Bradford Terrace Philadelphia, PA 19149 Mr. Frank R. Romano Air and Water Pollution Patrol 61-Forest Avenue Ambler, PA 19002 I
Joseph H. White, III Zori G. Ferkin 15 Ardmore Avenue Governor's Energey Council Ardmore, PA 19003 P.O. box 8010 1625 N. Front Street Martha W. Buxh, Esq. Harrisburg, PA 17105 Kathryn S. Lewis, Esq. "
1500 Municigal Services Bldg. Spence W. Perry, Esq.,
15th and JFI Blvd. Associate General Counsel Philadelphia, PA 19107 Federal Emerg. Managemt Agency Room 840, 500 C. Street, s.W.
Thomas Gerusky, Director Washington, D.C. 20472 Bureau of Radiation Protection De7t. of Environmental Resources Robert J. Sugarman, Esq.
5th Floor, Fulton Bank Bldg. Sugarman, Denworth & Hellegers Third and Locust Streets 16th Fl. Center Plaza Harrisburg, PA 17120 101 N. Broad Street Philadelphia, PA 19107 Director Pennsylvania Emergency James Wiggins Management Agency Sr. Resident Inspector Basement, Transportation & U.S. Nuclear Regulatory Comm.
. Safety Bldg. P.O. Box 47 Harrisburg, PA 17120 Sanatoga, PA 19464 Robert L. Anthony Atomic Safety and Licensing Friends of the Earth of Board Panel the Delaware Valley U.S. Nuclear Regulatory Comm.
103 Vernon Lane, Box 186 Washington, D.C. 20555 Moylan, PA 19065 Atomic Safety and Licensing Charles W. Elliott, Esq. Appeal Board Panel Brose & Poswistilo U.S. Nuclear Regulatory Comm.
325 N. 10th Street Washington, D.C. 20555 Easton, PA 18042 Docketing and Service Section David Wersan Office of the Secretary Consumer Advocate U.S. Nuclear Regulatory Comm.
Office of Attorney General Washington, D.C. 20555 1425 Strawberry Square Harrisburg, PA 17120 Gregory Minor MHB Technical Associates Jay Gutierrez 1723 Hamilton Avenue Regional Counsel San Jose, CA 95126 ar e ue Timothy R.S. Campbell, Director King of Prussia,PA 19406 Department of Emerg. Services 14 East Biddle Street Steven P. Hershey, Esq. West Chester, PA 19380 Community Legal Services, Inc.
5219 Chestnut Street Philadelphia, PA 19139 g AMI < /) //V '~
ANGUS R Montgo ,p0VFFESQl(IRE ary County Legal Aid
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VITA JOHN D. CASE
. WORK EXPERIENCE The Pennsylvania Prison Society, Field Directori
- May 1977 to present Philadelphia, PA 19107 and County December 1962 to
' Warden, Bucks County Prison, Doylestown Frbruary 1977 Dephrtment of Corrections lvania Member, Governor's Justice Commission, Pennsy Corps 1969 to 1978 .
Private to Major, United States MarineInstractor, M January 1942 to 1954 to 1957 Staff Schooli Quantico, VA December 1962 Custody Officer, Naval Prison, 1948 to 1950 Portsmouth, N.H. Marine Corps Dase, 1960 to 1962 CampDrig Officerr LeJeune, N.C.
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EXPERT WITNESS Nez vs Marila, U.S. District Court of Arizona, June 1970 H70-216 ization Legislative-Executive Task Force on ReorganCom August 13, 1970 of Government ntatives, Committee on the Judiciary, House of Represe
'Nay 29,1971 Washington, D.C. ited Committee on the Judiciary, Senate of the Un June 22, 1972 States, Washington, D.C.
027 9, U.S.
July 1977 Sutton vs Washington, Civil Action H77 ,
Civil Action H78-270, ty U. S.
Jail)
March 1979 Valentin vs Englehadt, District Court for New Jer ,
11, U.S.
Ippolito vs Howell, Civil Action H78-09 Jerscy f
= September 1979 District Court for Cho District of New(Consen (Atlantic County Jail) consoll-Civil Action H77-0765 U.S. Di str cit Morrison vs Brennano lington 1989 dated with Civil Action H78-0628, Court County Jail) Consent Decree.
d f
Laroau Vs Mansone Civil Action'HH 1
Octobor 23, 1980 Connecticut. civil Smith vs Montgomery County and Commissionors, h Castern 28, 1981 action H80-4492, U.S. District Court for t e
.Nanuary lvania
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U EXPERT WITNESS h
Marcho 1980 Davis vs H.G. Evatto Sheriff of Hamilton County y Tennessee, Civil Action M1-79-200, U.S. District Court for the Eastern District of Tennessee y 1980 .
! Tammy Lee, James Earl Moreheado et al vs Bradley County, Tennessee, et als C01'1 Action #1-80-38 in the U.S.
District Court for the Eastern District of Tennessee r Southern Division (Consent Decree)
- Aprilo 1981 f{ Laurie DeMier et al vs Arlington County, Civil e
Action H80-1086-A o U.S. District Court Eastern District of Virginia (Consent Decree)
April 2r 1981
[q [i L Fisher vs Arlington County, et al, Civil Action W H80-1204, U.S. District Court, Eastern District of Virginia
, Augusto 195t1 Pontato, at al vs Richard Froy of Jofforson Countua j7 Civil Action HC75-0031-L(A) C79-0492-L (A) o C79-0570-L (A) ,
U.S. District Courto Western District of Kentucky at Loulsville a
\
O-
. July 3r 1981 Raymond La ttisaw, et al vs Hughes, ot 'al o civil Action H8-78-1718, (Depos1C20n) U.S. District Courte District of Maryland January, ~1982 Early vs District of Columbia, Civil Action H1245178 and Civil Action H739579o' Suporlor Court of District; of Columbia
(~ Januarya 1982 V. -Dianda et al vs Norvella Sheriif of SC. Lucie Countyo Florida r ot. ale Civil AcClan H80-8251-CIV-JCP (80-0016-CIV-MAG-PJK)
U.S. District Court for
-Southern Dist'rict of Florida ForC Pietce Division o
o (Consent Decroe)
=Dscembero 1981 Billy Cuttsinger et al vs Billy Ray Shephards at al e
'of Bullitt Countyr Civil Action HC80-0048-L(A): U.S.
e District Court, Western District of Kentucky at Louisville r (Consent ' Decree) '
l March lo-1982 McElvern - et al vs County of Prince William et al o
- o Civil Action H81-1049'ANs U.S. District Court of Virginiao Alexandria Division
?Nay: 1982.
Gary Hendricks vs Paul Davis ot ale Civil Action :
o
- HHM-80-2038 in the U.S. District Court for the District of Maryland
- Februarge 1984-Wheeler vs Sullivan o et air Civil ' Action H80-177-WRS '
U.S. District Court of the District of Delaware December'7: '1984 Michae' l Wayne Spivey vs Roy Banks, et als Civil Action v ,
DistrictDivision Court for Eastarn District v .. _
9 h: e AQARDS 1968 G. Howland Shaw Award of the National Jail Associa-Y-l tion, Jailer of the Year, prosented at the American l
Correctional Association Convention, San Francisco i t j 1975 Exemplary Project Award for Corrections, presented
.
- by the National Association of Counties 197,6 Ambassador of the Ye'v a o presented by the Bucks County Chamber of Commerce
! 1976- Liberty Bell Award, Ydung Lawyers, Pennsylvania Bar Association i
1977 Citizen of the Decade rpresented by the Bucks County Association for Corrections and Rehabilitation F
i- 1977' Commendation from the Senate of Pennsylvania for nino years of service as a member of the Governor
. PUBLISHED ARTICLES
^ January-February, 1965 Modern Corrections in Old County Jailo American g Journal of Corrections s ..
! i 1965 Citizan Participation in the County Jail, American Correctional Association Proceeding Septemberg 1966 Wo Oporato a Salvago Dusiness--Not a Junk Yardi Foderal Probation Quarterly Decemboro 1966 Citizan Participation An Exporimont in Prison =
Community Relations, Federal -Probation Quartarly
' Marche;1967 "Doing Time" in the Communityr Federal Probation Quarterly
' Spring-Summero 1967 Incentives in a County Prisono Prison Journal i
' January or 1969 j Pennsulvania's County Prisonso a presentation to i
Task Force on Correctionso the Legislature of the; Commonwealth of Pennsylvania
- t. . June,1969 Raintogration of tho Offondor into tho Community
];
l, February ~9, 1971 Does Anybody Realig Care? Presented at New York V University, and published as a chapter in book l Social Disabilities.
i .. .
b-: -June 23, 1971 Testimony, Committee on the Judiciary, United States SI Hous.e of Representatives, Washington e D. C, J January-Febt,uary: 1973 Correctional Volunteers in Bucks County, The American
, Journal of Corrections h
4
-CONSULTANT EXPERIENCE AND STUDIES 3 l ki 1968 to present Cortified Jail Consultant, National Jail Associacion =
f' 4 1968 Jail Study, Dixon County, Sioux City, Nebraska ^
1969 Monroe County, Rochester, New York =d Rockland County, New York 4 1970 Hamilton County, Cinncinnati, Ohio
1971 Jefferson County, Louis,villo, Kentucky 1973 Onondago County, Jamesville, New York A 1974-1975 Burlington County, Mount Holly, New Jersey (consulted in planning cf new minimum security corrections center)
} 1978 Columbia County, Bloomsburg, PA -
t 1978 2 Lancastor County, Lancastora PA 1981-1982
}
Dauphin, Lycoming, Westmoreland, Lackawanna Councias SPECIAL PROJECTS y
1964 Planned and opened Bucks County Rehabilitacion Centor, n minimum security institution, first such institution $
s in any county in thu Unitud Status.
1966 n Assisted in preparation of Chapter 3, Community _--
Detention Facility, of 1966 odition of Manual of -
Correctional Standards, American Correctional ^
l Association. ""
1970-1971 Member ad hoc committee on work rolcase, American '
Correctional Association -
i 1972 Member of team which conducted seven training seminars 5
(three days each) for sheriffs under sponsorship of '"
National Shariffs Association 2 1973 Rember of ad hoc committee of American Correctional Association to cost accrodication procedutos. Incl udod y visits to several institutions to ovaluato all aspects -
for accreditation.
PROFESSIONAL AFFILIATIONS
=
National Jail Association - Was' Director and past President. Now called American Jail Association, sorving as Parliamentarian. -f
=
American Correctional Association - Former Director
_3 e
Pennsylvania Association on Probatione Parole and .
Q Corrections -2 Member, American Correctional Association - Local h Dotontion Committoo ]
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9 1
)'
, ' TRAINIhG
.. . l
- January 1955 .
Instructor Orientation Course, Marine Corps School, \
l '
Quantico, VA Y February,1960 Senior Officers Short Course in Military Justice Januaryr1962 Correctional Administration Course, Class H1, V. Fort Gordon, Georgia L
April to Juner 1962 Correctional Adminis' tration, American University, Washington, D. C. (2 months, full-time)
July, 1962 Course in Jail Management, Federal Jail Inspection Service, Bureau of Prisons, Washington, D. C.
November,^1962 Speed Reading Course, Marine Corps Base, Camp LeJeune, N. C.
}. Mayr'1964 Counseling of Inmates, Public Service Institute of Pennsylvania December, 1964 Clinical Criminology I, Public Service Institute, Department of Public Instructioni Harrisburg, PA t !
Mayo - 19qS Security and Discipline in Prison, Pubilc Service s
Ins ti tu te s
June, 1965 Group and Case Counseling in Correctional Settings, Public Service Institute June,1966 Correctional Counselinge Paychotherapeutic Techniques, f
Public Service Institute January, 1967' Prison Staff Developmente Public Service Institute
' Nays .1967 Modern Approach to Administration of ~Justicei Pennsylvania State University
' Decembero 1967 Advanced Course - Prison Security January, 1968 1
The Executive Workshopo Pennsylvania Adult Correctional -
s Training Instituto Pennsylvania r State University
.Augusto 1968..
Juvenile Behavior and Child Cater Public Service Instituto October 1968 Jail Management Correspondence Course r Jail Manage-o men t . Insti tu to r Bureau of Prisons December,;1968 . Group Counseling Public Service Institute d
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EDUCATION 1940.to'1942~ After high school graduation (valedictorian), I
~
attended Fordham University: Bronx, New York, ,
on a combined athletic (football) and scholastic scholarship (Dean's List) . In 1942, I enlisted ;
in the U.S. Marine Corps. During my Marine Corps l
.' career,' I attended Fordham University and George Washington College p' art-time, but did not complete the work required for a degree.
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