ML20031B341
| ML20031B341 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/24/1981 |
| From: | Christy W CHRISTY, W. |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8110010247 | |
| Download: ML20031B341 (5) | |
Text
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NUCLEAR REGULATORY COMMISSION
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'"4 - 'g BEFOI)E THE ATOMIC SAFETY AND LICENSING BOARD 4
In the Matter of
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KANSAS GAS AND ELECTRIC COMPANY, )
Docket No. 50-432 et. al.
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(Wolf Creek Generating Station,
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Unit No.1)
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ANSWER OF WANDA CHRISTY TO NRC STAFF INTERROGATORIES
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AND REQUEST FOR PRODUCTION OF DOCUMENTS g\\'
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,4 The intervenor, Wanda Christy, being first du!y sworn states under h
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as follows:
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The following are my answers to the NRC Stv.ff Interrogatories and /),
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Request for Production of Documents to Wanda Christy; Mary Ellen Salava and Kansans for Sensible Energy (KASE), dated August 14, 1981:
1.
(t.) Our contention is that the local governments (CoMy County, the State of Kansas, and other local units of government required to respond to an emergency at the Wolf Creek plant) do not have a work.
able evacuation plan. To date, none of these units of government has prepared a plan.
Even though a plan has not been prepared, discussions I have had with County Commissioners, representatives of the State of s
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Kansas, arid others IH!cate that plans being contemplated ccmot be implemented because there are not enough people available to fill the positions required for the evacuation plan.
Additionally, there is no evidence that governmental units are providing adequate training to people who might be involved in implementing an evacuation plan. There is no indication that such units of government have the equipment needed to implement such an evacuation plan. None of the units of government required to respond to an accident at the Wolf Creek plant and provide for the evacuation of pople affected thereby has provided for any fund-ing to carry out such an evacuation plan. Until plans are prepared and submitted, there is no evidence that a viable evacuation plan exists.
Until such plans are submitted, I cannot adequately respond to this Inter-rogatory. Hcicever, once the plans are submitted, I will respond as requested.
(b) Until the plans of the local units of government and the state are submitted, I am not able to answer this interrogatory. At this time, we have not decided upon who will be called as a witness. However, as soon as witnesses are decided upon, the NRC Staff will be notified and.
furnished with the information requested in Interrogatories 1(b),1(c),1(d),
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The answers set forth above on pages
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to k are based on the information available to me at this time.
If further information becomes available to me, I reserve the right to supplement or amend these answers and to the extent required to do so will supplement or amend these answers.
8bM day of September,1981.
Signed this d
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Wanda Christy STN)e OF KANSAS, COUNTY )F 6
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On this M
day of
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/b1Au[L 2 4/7 appeared before me and being first duly sworn made and signed the" above answer under oath.
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- ,....._, www r-x-Fr notary eudiic (Seal) 4,
UNITED STAidS OF AMERICA NUCLEAR' REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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KANSAS GAS AND ELECTRIC COMPANY, )
Docket No. 50-482 et. al.
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(Wolf Creek Generating Station,
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Unit No.1)
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CERTIFICATE OF SERVICE I hereby certify that copies of Ai.swer of Wanda Christy to NRC Staff Interrogatories and Request for Production of Documents in the above-cap-tioned proceeding have been served on the following by deposit in the United States mail, first dass, on September 24, 1981.
James P. Gleason, Esq., Chairman Atomic Safety and Licensing 513 Gilmoure Drive Board Panel Silver Spring, MD 20901 U.S. Nuclear Regulatory Commission Washington, D.C.
20535 Dr. George C. Anderson Department of Oceanography Docketing and Service Section University of Washington-Office of the Secretary Seattle, Washington 98195 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. 3. Venn Leeds 10807 Atwell Eric A. Eisen, Esq.
Houston, Texas 77096 Birch, Horton, Bittner & Monroe 1140 Connecticut Avenue, N.W.
Treva 3. Heat., Esq.
Washington, D.C.
20036 Assistant Gerr.1 Counsel P. O. Box 360 Kansans for Sensible Energy Jefferso.? City, Mo.
65102 P. O. Box 3192 Wichita, Kansas 67201 3ay Silberg, Esq.
Shaw, Pittman,Potts & Trowbridge Mary Ellen Salava 1800 M Street, N.W.
Route 1, Box 36 Washington, D.C.
20006 Burlington, Kansas 66839
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r Wanda Christy Myron Karman 515 N. Ist Street Deputy Assistant Chief Hearing Counsel Burlington, Kansas 66839 Office or 'he Executive Legal Director Nuclear Regulatory Commission Atomic Safet > ind Licensing Washington, D.C.
20555 Appeal Boa J U.S. Nuclear Regulatory Commission C. Edward Peterson, Esq.
Washingtcn, D.C.
20555 Assistant General Counsel Kansas Ccrporation Commission Str.te Office Bldg.
Topeka, KS 66612
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