ML20129H864

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Response of Commonwealth of Pa,Dept of Corrections to Requests for Info Raised at ASLB 850227 Conference
ML20129H864
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/15/1985
From: Ferkin Z, Otto T
PENNSYLVANIA, COMMONWEALTH OF
To:
Shared Package
ML20129H806 List:
References
FOIA-85-304 NUDOCS 8507200508
Download: ML20129H864 (19)


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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ~

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Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

RESPONSE OF THE COMMONWEALTH OF PENNSYLVANIA.

DEPARTMENT OF CORRECTIONS TO REQUESTS FOR INFORMATION RAISED AT THE FEBRUARY 27, 1985 ATOMIC SAFETY AND LICENSING BOARD CONFERENCE I. BACKGROUND On February 27, 1985, a conference was held pursuant to the language in the Order of the Atomic Safety and Licensing Appeal Panel denying the appeal filed by?

counsel for the Graterford inmates. At that conference, counsel for the Graterford inmates, and his expert, made representations as to what information they needed so that they would have reasonable assurances that the inmates'. health and. safety.would be protected in the event of an incident at the Limerick Generating Station. Below are the representations of the Department of Corrections in response to those requests for information.

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II. DISCUSSION The discussions at the February 27, 1985 conference followed the order of the proposed contentions that were filed by counsel for the inmates. In order to maintain a semblance of order, the responses in this document will also follow the order of the proposed contentions.

TR ANSPORT ATION The buses used to transport the inmates will come from outside the 10 mile EPZ.

This is because sufficient numbers of buses could not be located inside the 10 mile EPZ. The plan calls for the use of 58 buses. For planning purposes, we have assigned 40 inmates per bus, although the buses have a rated adult capacity of between 46 to

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48 individuals. (These are the same type school buses that have a school children rated capacity of between 66 and 72 school children.) Attached as Exhibit A through C are three representative samples of the assurances given by our bus providers. The exhibits represent assurances for 71 buses. These exhibits represent less than half of the bus providers and give assurances for 13 more buses than are aeeded for the entire plan.:

The number of inmates that can be carried by these 71 buses (at 40 per bus) is 2,840 inmates, which is in excess of the entire inmate population at the institution.

The sources for bus drivers are two-fold. The first source is the bus providers.

They have given us assurances the drivers will be available in the event of an evacuation to drive the buses. In the operation of the plan, we expect to use only a small number of a bus providers total compliment of buses and, therefore, it is reasonable to believe that they could provide us with bus drivers for the buses, even if some of the bus drivers refused to drive. ,

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The second source for bus drivers will be the Department.of Corrections. At the support institutions, we currently have at least 110 employes with a Class II driver's license. According to the Commonivealth of Pennsylvan.la Motor Vehicle Code, a Class II driver's license permits an individt:al to operate a bus on Pennsylvania highways. At the suggestion of some of our bus providers, and to further ensure the competence of the selected bus drivers, we are planning to have them receive further training. We estimate that the training will be completed by the end of 1985.

Regarding inmates scheduled to be transferred in Department of Corrections vans, the Department of Corrections maintains a fleet of .15 vans. If necamary, all of these vans would be available for an evacuation, although the plan calls for the use of -

substantially less than entire fleet. The combined capacity of these vans is 216 inmates.

We are also currently in the process of bidding for a new 32-passenger van. For planning purposes, we believe about five percent of the total inmate population would be moved in these vans. If, for some unexpected reason, insufficient vans were available.

Department of Corrections vehicles (station wagons, cars, etc.) would be . utilized to move these inmates. *-

With regard to the location of ambulance resources, attached as Exhibit D is a written assurance that we could get at least 15 ambulances from our selected provider.

The number of ambulances used for planning purposes is in the range of two to three.

ambulances, although we obviously have substantial excess capacity if further ambulances were needed.

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. e M ANPOWER As a par't of the SCI-Graterford Emergency Plan for any type of emergency, there is a call-up system in place. 'This system is available to notify additional manpower if they were needed during a radiological emergency.

The plan uses management individuals to call the staff. Each individual has less than 10 other persons to call. Furthermore, the callers are of sufficient rank to give 4

orders to the person receiving the call to report to work.

The system was tested as of January,1985. The institution passed the test.

The Department of Corrections maintains a compliment of approximately 700 employes at the State Correctional Institution at Graterford. Approximately 400 of these employes are Correctional Officers. If necessary, many of the remaining 300 employes could be of assistance since they have received basic training in famate custody and control. If, for some reason, further manpower was required, officers from other department resources or the Pennsylvania State Police would be utilized.

As a last resort, the Pennsylvania National Guard could be used. Thus, the reference by counsel for the inmates in his proposed contentions to the necessity for a battalion of the' National Guard to be used in the Graterford evacuation is incorrect. To evacuate the State Correctional Institution at Graterford, the Pennsylvania National Guard is the source to be used only after the Department's own resources and the Pennsylvania. State  ;

Police resources are exhausted.

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SECURITY EQUIPMENT Although the numbers and types of security equipment to be used in the Graterford l

evacuation is of such a sensitive matter that the Department of Corrections is not disclosing that information, we will disclose that we are expecting delivery of the

  • required equipment within 90 days. _

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CO51MUNICATIONS EQUIPMENT As part 'of 'its ongoing operation, the Department of Corrections has substantial radio resources with base units, mobile units (in cars and other vehicles) and hand-held units. To supplement this existing capacity, we have received 68 additional hand-held units. These units were in Harrisburg as of March 8,1985, and are awaiting distribution.

These radios are tN same type radios we use in our daily operation, so we can attest to their quality. Little, if any, formal training will be required since we will be authorized to use them on a daily basis (see letter from Vincent S. Boyer, Sr. Vice President, Nuclear Power, Philadelphia Electric , Company, attached hereto as Exhibit E).

R ADIOLOGICAL EQUIPMENT According to PEMA Representative, Ralph Hippert, the CD V-750 and the' CD V-700 are currently in stock. The DCA-622's are due to start coming in about March 10,1985. The K1 is due April 1,1985. We are waiting until the DCA-622's and the K1 are in stock to distribute these materials all at once. The TLD's are in the bidding process. Once they are received, they will be distributed as well.

According to Mr. Hippert, if an incident would occur before the delivery of these items, there are sufficient stock' piles of this equipment available in the, Three-Mile Island EPZ counties to cover the evacuation of the Limerick EPZ including the inmates at Graterford. .

MEDICAL SERVICES i

As a part of its ongoing operation, the Department of Corrections has agreements '

with local hospitals to give health care to our inmates. Attached as Exhibit F is a copy of an addendum to these agreements we have had our hospitals execute to evidence ~

their ability to take care of inmates injured by radioactivity. Also attached as Exhibit G is the JCAH Standard to which the addendum refers.

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  • MO ITORING t

The Departnient of Corrections will use the same standards for the inmates as are being used for the general public with regard to sheltering, evacuation and the general operation of this plan, with one exception. In the event that. sheltering is i ordered for the entire EPZ during the summer, and the temperatures and humidity are such that the institution would become uncomfortable, a DOE plume-monitoring team e

i will be requested by the State Correctional Institution at Graterford. This will allow us to keep the windows open if only background levels of radiation are detectable. If the team indicates that a radioactive plume is coming, the information will be relayed to PEMA. PEMA will consult with the BRP and PEMA will issue instructions for the institution to follow, and these will be the official actions which the institution will implement. In the interim period between the time the DOE indicates that a plume is heading towards the State Correctional Institution at Graterford and the State

!~ Correctional Institution at Graterford receives word from PEMA . the Superintendent

will take interim actions as per his best judgment. This information is contained in

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l the plan on Page E-1, D-1 and E-1 (9). "

a It should be emphasized that this action is the only action that is different than the actions taken by the general public, and this only happens in the situation where the temperatures and humidity are such that the institution would become uncomfortable.

SIMULATED EVACUATION PLAN EXERCISE .

A " tabletop" exercise of the plan was conducted on March 7,1985. FEMA, PEMA and DOC were in attendance. Upon receipt of the FEMA report, the DOC will provide

! information as to whether the plan was found by FEMA to be adequate.

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TR'AINING 4 s 4

The training for the decision-makers in the plan is completed. These are the people that have the respons'ibility to control the actions of their staff at Graterford

and the other support institutions and relocation centers. These individuals are fully j aware of the components and operation of the plan. The training they received was
tested during the tabletop exer.cise. During that exercise, the decision-making and

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j communication parts of the plan were tested. These are the people who will be giving i

orders to the staff regarding care, custody and control of the inmates and receiving information from the Department of Corrections Central Office regarding actions to be 4

taken at their institutions.

j To provide training for our decontamination monitoring teams, we are utilizing a train-the-trainers approach. By using this approach, certain individuals are being j qualified to go back to their support institutions and train the decontamination monitoring 1

teams. The training for the trainers is completed and was conducted by PEMA. As soon as the additional radiological equipment is received by the Department of 1

Corrections, the trainers can give training as to the actual use of the equipment. We l estimate that the training process will be completed three months following the receipt

of the equipment by the Department of Corrections.

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RECOVERY AND RE-ENTRY l

j The recovery and re-entry will essentially be a reverse of the evacuation. Re-1 t

entry will only be initiated when the Department of Corrections is advised by PEMA

! that it is safe to return.

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SHELTERING t

. The Department of Corrections will rely on the determination by PEMA requiring s

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sheltering. If PEM A suggests sheltering, we will shelter with the limitation more fully explained under monitoring in this response. The E-1-10 (8) referral to " institutional climate" does not refer to any sheltering decision but only to one of the elements of a report the Department of Correction will provide to PEMA regarding the progress of e

an evacuation.

GENERAL CONCEPT OF EVACUATION The counsel for inmates has been afforded the opportunity to review a substantially less sanitized version of the plan than he had viewed at the time of filing the proposed contentions. The plan that he has seen under protective order and an affidavit of non-disclosure is complete with the exceptions of the destinations, routes, specific numbers of manpower and inmates, restraints, and radio frequencies. This information was deleted due to the security concerns of the Department of Corrections. The information, in our opinion, could also be classified as the " gory details" which are not subject to

disclosure. With the information that has been provided to the counsel for the inmates, as well as his expert, we believe that they will agree there is a reasonable assurance that the evacuation would provide for the safety and security of the inmates.du_ ring the evacuation.

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CONCLUSION i '

The above information represents what the Department of Corrections understood Counsel for the inmates need' ed to complete his review and for the consideration of the Atomic Safety and Licensing Board..

Respectfully submitted, l (cit ,.

eodore G. Otto, III' '

Assistant Counsel Department of Corrections *

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/ssistant Counsel Governor's Energy Council'

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Dear Superintendent TM NT.'

This letterCorrections.

Depcrtment-of confirms previous verba2 assurances made by this company sc. the k'e understand you need this 2ctter as proof of these assurcnces for of buses for crergency use. the  ::uclear Regulatory Connissien, showins. that you have located se the interest this company hasThis letter is not a contrag but serves as a statene expressed in providing buses to the maximum extent pessible there is an for incident use during at an emergency including the evacuation of SCI Graterford if the Limmerick Generating Station.

To permit evacuation, the Department of Corrections to cdequate3y plan for the possible the compnny can give reasonable assurances that ti.e3 can provide at le 30 twobuseshours. with a capacity of 72 schob1 children or 48 adults per bus within

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This letter confirms previous verbal by this company to the Department of Corrections.assurcnces k' e understand cade you need this letter as p r o of o f these assurances for the Nuclear Re gul a t ory , Commission, showing that you have located ~'s sources of buse s for emergency use. This letter is not a contract but serves as a statement of the interest this company has expressed in providing buses to the ca'ximum extent for use during an emergency including possible the evacuation of SCI Graterford Station. if there is an incident at the Limmerick Generating

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To permit the Department of Corrections to adequately plan for the possible evacuation, the company can give reasonable assurances that they can provide at least 20 school and 10 buses charter buses with a capacity of Ab per bus withir 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Sincerely!;

Vice President y 24 Hour l'h o n e

Contact:

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2 State Correctional Institution 'I-Deer Superintendent This letter confir=s previous verbal assurances made by this ce=pany to the Dep'Ert=ent of Corrections. We understand you need this letter as probf of these assurances for the Nuclear Regulatory Co--ission, shoving that you have located sources of buses for.

e=ergency use. Tnis letter is not a contract but serves as a

  • stata=ent of the interest tils co=pany has expressed in providing buses to the cas:i=u= extent possible for use during an emergency including the evacuation of SCI Graterford if there is an incident at the Li =erich Generating Statinn.

To permit the Department of Corrections to adequately plan for the possible evacuation, the co=pany can give reasonable assurances that they can provide at least M buses with a capacity of 66-72 per bus within 1-3 hours.

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March 5, 1995 Superintendent S'= + = N-action Instituuca, Dear Superintendent This letter cchfims previous verbal assurances nade by this agency to the Department of Corrections. We understand you need this letter as proof of these assurances for the Nuclear Regulato:7 Cv. .dssion, showing that you have located sources.of ambulances for emergency use. This let-ter is not a contract but serves as a statement of the interest this agency has epressed in providing ambulances to the ra:r.imum extent possi-ble for use during an emergency ' including' the evacuatien of SCI Graterford if there is an incident at the L1:=nerick Generating Station.

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To pe.m.it the Department of Ccerections to ade:;uately plan for the pessible evacuation, the agency can give reasonable assurances that they can provice at least 15 ambulances with a capacity of 2 per ambulance within one hour. ~

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, P.0, BOX B099 PHILADELPHI A. PA.19101 Op..r. tior.:. Divisioti g.. , , o g. t m 82 * #DOO

. v.c. n i ot.n 12cvember 6, 1984 I:r . L. P. Benning, Chief i Security / Safety Pennsy2vania Eureau of Correction ~

P. O. Box 59F Camp Hill, PA 37011

Dear Mr. Denning:

In October at a meeting I attended with you and your asso-ciates at the Pennsylvania Bureau of Correction as well as with John Patten and Ralph Hippert of.PE!!A, you proposed the training program and list of equipment developed by the Bureau of Correction for the radiological emergency response plan of the Graterford Prison. Since that date, we have had discussions with you relative tc. various aspects of your requested program.

With regard to the' training plans , we understand that PE!!A will either conduct or review the program to assure that the train-ing material is adequate for the intended purpose. Philadelphia Electric Company agrees to reimburse the Bureau of Correction for incremental costs associated with the training program beyon6..that provided by the State of Pennsylvania under Act 147, the Pennsyl-vania Radiation Protection Act. We expect that training will be accomplished as part of the normal work week in so f ar as possible.

Invoices for the incremental training costs may be directed to my attention. ,

ne have reviewed the equipment listed in the Pennsylvania Eureau of Correction equipment cost projection and find the quantity and type of equipment listed to be reasonable for the purposes intended. We plan on initiating the purchase orders for hardware and having it delivered to your attention.

Items 6, 7 and 8 of the equipment list covers the furnishing of radios and associated equipment. We intend to purchase and furnish this equipment to you, but as I discussed with you on the phone, we are formulating a proposal which, while making the equip-ment available to you when needed, will enable it to be utilized rather than gathering dust in a storage cabinet. .

We are pleased to work with you in the finalization of the emergency planning needs for the Graterford Prison.

Sincerely, c c.: ilohn Petten fe18 i 9 EXHIBIT "E" '

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[ ear Superintendent $l3%Ql9ur.

This is to certify ths Hospital coq. lies with the provisient of the Joint Gommitrion on the Accreditation of Hospitals Standard !V, Emergency Services dealing with the treatment of radioactively cor.taminated wounded.

Sincerely.

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EXHIBIT "F" i

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2l! ALCREh!T ATIOh M AM:A1. I Oh IlOSP11 A1.5, 3 9ll1 Orieraation Program A planned, formal training program shall be re-(

INTrnr arTATion

, quired for all registered and licensed nurses, and for specified professional perp.onnel who provide patient care in the emergency department / service.

When there is no in. house capability of providing this training, a qualified s outside source. of instruction shall be substituted. The program shall be acceptahlc to the physician dircetor of the emergency depanment/ service, or to the committee of the medical staff when there is no director, and to the director of the nursing department / service. The orientation program shall be of sufficient duration and substance to cover all patient care responsibilities to related to each individual's level of participation in the emergency depaft-menthervice. The program shall include training in:

  • recoEnition, interpretation, a,)d recording of patients' signs and symp-toms, particularly those that require notification of a physician;
  • initiation of cardiopulmonary resuscitation and other related life-Is support procedures; I@
  • parenteral administration of electrolytes, fluids, blood, and blood com-i ponents; h
  • wound care and management of sepsis;
  • initial burn care;

/,h6 / 4 :o e initial management of injuries to the extremities and central nervous

. system; hg g;

  • effective.and saf e use of electrical and electroniclife support and other equipment used in the emergency department / service; JJl
  • prevention of contamination and cross infection; and

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  • recognition of, and attention to, the psychological and social needs of J g, patients and their families.

h hiV', Continuing Education Program All emergency department / service person-

[' q6 h3 nel shall participate in relevant in. service education programs The director or his qualified designees shall contribute to the in-service education of emergency department / service personnel. In. service education shall include T-l[/T b { . 30 the safety and infection control requirements described in this Afonual. Car-diopulmonary resuscitation training shall be conducted as often as necessary for all physicians, nurses, and specified professional personnel who work in l the emergency care area.

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} gency department / service continuing education programs outside the bo' spi- l l tal, as needed. Education programs for emergency department / service person-nel shall be based at least in part on the results of the review and evaluation 40 of the quality and appropriateness of emergency care. The extent of par.

ticipation shall be documented and shall be realistically related to the sine of the staff and to the scope and complexity of the emergency care services provided. ,,

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' Standard V Emergency patient care shall be guided by written Policles.an 3y:.sw. ,n.

eedures.  : , .] - .

Here shall be written policies and procedures specifying the scope d INTERPRETATt0N conduct of patient care to be rendered in the emergency department / service, i Such policies and procedures must be approved by the =whl ata{aiid ,

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. Emersency Services hospital administration, and shall be reviewed at least annually, revised as 3, necessary, dated to indicate the time of the last review, and enforced. The W policies and procedures in Level I, Level II, and Level Ill emergency de.

, partments/ services and, as appropriate, in Level IV emergency departments /

services, shall relate to at least the following: s

  • Location, storage, and procurement of medications, blood, supplies, and equipment at all times.

. Provision of care to an unemancipated minor not accompanied by parent or guardian, or to an unaccompanied unconscious patient.

  • Circumstances under which the patient's personal physician is to be to notified or given reports.
  • Conndentiality of patient information and the safeguarding of records.

. Release of authorized information and materials to police or health authorities.

. Transfer and discharge of patients. is

. . The emergency medical record, including any consent for treatment.

. Infection control measures, including procedures designed to eliminate the possibility of contamination and cross infection.

- . Procedures to be followed in the event of equipment failure.

. Pertinent safety practices. 20

  • Control of traffic, including visitors.

. Dispensing of medications in accordance with the requirements of the Pharmaceutical Services section of this Manual

. The handling and safekeeping of patients' valuables.

. The role of the emergency department / service in the hospital disaster :s

. plans.

!$ . Specification of the scope of treatment allowed, including the general and specific procedures that may not be performed by medical staff members in the emergency department service, and the use of anes.

i thesia. so.,.

. Who, other than physicians, may perform special procedures, under what circumstances, and under what degree of supervision. Such pro.

cedures include, but are not limited to, cardiopulmonary resuscitation, including cardiac defibrillation; endotracheal intubation; tracheostomy or cricothyrectomy; respiratory care, including assisted ventilation and 35 humidification; the administration of parenteral antiarrhythmic and other specified medications; and the obtaining of arterial and venous-blood samples and other laboratory specimens.

. The use of standing orders.

. The property exchange system, when necessitated by the transportation 40 and transfer of patients.

. Circumstances that require the patient to return to the emergency de.

partment/ service for treatment.

. The emergency management of individuals who have actual or sus.

pected exposure to radiation or who are radioactively contaminated. 4s

? Such action may include radioactivity monitoring and measurement; I

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designation and any required preparation of space for evaluation of 1 the patient, including, as required, discontinuation of the air circula. l s tion system to prevent the spread of contamination; decontamination l f ;,[* ' .

of the patient t.1 rough an appropriate cleansing mechanism; and con. So tainment, labeling, and disposition of contaminated usaterials. The i

7 Individual responsible for radiation safety should be notified.

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. UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION in the Matter of )

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PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353 (Limerick Generating Stations, )

Units 1 and 2) ) ,

CERTIFICATE OF SERVICE I hereby certify that copies of " Response of the Commonwealth of Pennsylvania, Department of Corrections to Requests for Information Raised at the February 27, 1985 Atomic Safety and Licensing Board Conference" in the captioned matter have been served upon the following by deposit in the United States Mail this 15th day of March, 1985: - ,

Helen F. Hoyt, Esq.. Donald Hassell. Esq.

Chairperson Counsel for NRC Staff Atomic Safety and Licensing Office of the Executive Board Legal Director U.S. Nuclear Regulatory U.S. Nuclear. Regulatory Commission Commission -

Washington, D.C. 20555 ' Washington, D.C. 20555 Dr. Richard F. Cole

  • Zori G. Ferkin, Esq.

Atomic Safety and Licensing Assistant Counsel Board Commonwealth of Pennsylvania U.S. Nuclear Regulatory Governor's Energy Council Commission P. O. Box 8010 -A Washington, D.C. 20555 300 North Second Street lith Floor Dr. Jerry Harbour Harrisburg, PA 17101 Atomic Safety and Licensing '

Board Angus Love, Esq.

U.S. Nuclear Regulatory 107 East Main Street Commission Norristown, PA 19401 Washington, D.C. 20555

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Docketing and Service John L. Patten, Director Section . Pennsylvania Emergency U.S. Nuclear Regulatory

  • Management Agency Commission Room B-151 Washington, D.C. 20555 . Transportation and Safety Building Harrisburg, PA 17120 e

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. MONTGOMERY COUNTY L.EGAL AID SERVICE , , , , , , , , , , , , , , , , , , ,

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