ML20031B343
| ML20031B343 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/24/1981 |
| From: | Christy W CHRISTY, W. |
| To: | KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8110010252 | |
| Download: ML20031B343 (13) | |
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING SOAilD In the Matter of
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Docket No. 5 @2 y { g[ fi') '/}
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(Wolf Creek Generating Station,
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comum ANSWER OF INTERVENOR CHRISTY TO APPLICANTS V/
g FIRST SET OF INTERROGATORIES The Intervenor, Wanda Christy, being first duly sworn states under oath as follows:
The following are my answers to the Emergency Planning Contention Inter-rogatories, Nos. EP-1 to EP-18; the Emergency Planning and Financial Qualifications Contentions; and the General Interrogatories of the Applicants, Nos.1-4; each dated August 19, 1981:
EMERGENCY PLANNING CONTENTION 9 o3 5
S EP-1.
The radiological emergency response plan of the applicants J///
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as it relates to evacuation is not workable.
To the best of my knowledge, the evacuation plan of Coffey County, the state of Kansas, and any other local unit of government which would need to respond to an emerger.cy at t'a Wolf Creek Plant has not been prepared.
EP-2. There must be enough people available to implement the plan.
This depends upon the goals of the plan.
An adequate level of staffing depends upon the number of people to be warned, the number of people needed to coordinate with the applicants' onsite and offsite plans, the means of evacuation selected, the number needed to operate monitoring and decontamination equipment, the numh-r of people to be evacuated, the age of the people to be evacuated, the location of the people to be evacuated, the background a.d training of the people who will implement the plan, the amount of evacuation equipment available, the methods selected to warn people, the means selected to transport people to safe areas, the number of injured people, the distance and place people are to be moved to, the duretion period ci the evacuaticn, the health of the people to be moved, weather, the type of accident, and the availability of people assigned to the various evacuation plan tasks, and the training of the people who will implement the plan.
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EP-3. Coffey County, the state of Kansas, and any otner governmental unit responsible for participating in the evacuation plan.
EP-4. The plan of the state of Kansas, Coffey County, and other local governmental units have not been submitted. Tnerefore, it is not possible to answer this interrogatory because the functions assigned to each unit of government are not specified. When the plans are submitted, I will review them and respond to this interrogatory.
EF-5. Due to the fact that the plans of the local units of government and the state Save not been submitted, it is not possible to answer this interrogatory.
EP-6. To determine whether personnel of governmental bodies are ade-quately trained it is necessary to consider the following: the background and experience of each person who will have a re-sponsibility to carry out part of the evacuation plan; the amount of and content of instruction received by personnel about traffic control, ev&cuation plan equipment operation, and the nature and scope of the evacuation plan and proceduri.s; the number, type, and critiques for exercises and drills conducted; the qualification; of instructors; the actual experience and work with duties similar to that which a person will be responsible foi... the evacuation plan; instruction about radiological emergencies; instruction about and knowledge of the Wolf Creek Nuclear Generating Plant and the -
applicants' plans in the event of an accident; and detailed instruc-tion about the specifics of all aspects of t evacuation plan. It is also important that each person participat.ng in the plan be able w express his duties and how they relate to the overall plan.
EP-7. Due to tha fact that the local units of government and the state of Kansas have not submitted plans, it is not possible to answer this inter ogatory.
The ttictions have not been assigned.
EP-8. Due to the fact that the local units of government and t e state of Kansas have not submitted plans, it is not possible to answer this interrogatory. I do net know what functions have been assigned to each governmental unit.
EP-9. Until the details of the plans are known. It is not possible to precisely answer this interrogatory.
However, the personnel involved in the plan should receive training in at least the follow-in areas: first aid treatment, decontamination techniques, traf-fic control, use of monitoring equipment, evacuation plan details, drills and exercises which regularly simulate a radio!og-ical accident at the plant, use of safc;y equipment, instruction about the location of evacuation plan equipment: and technigi=s to be used in warning the public li. the event c.i an accident. k
EP-10. The followir>g are factors which are, among others, to be applied to determine if the governmental bodies are equipped to imple-ment the plan: weather conditions, the number and types of ichicles available to evacuate people, the method used to warn people of an accident and the type of equipment and means that will be used to make such warnings, the communications systems needed to conduct the plan, the number of warning sirens avail-able, the type and amount of monitoring equipment available, the type and amount of protective equipment available, and the speed with which people are to be evacuated.
EP-II. Coffey County, state of Kansas, rend all other local units of govern-ment are insufficiently equipped to implement an evacuation.
It is difficult to adequately respond to this interrogatory until a plan is developed.
Because, only at that time, will I be,
y able to indicate which unit of government lacks certain equipment.
EP-12. It is not possible to answer this interrogatory until the plans of the local units of government and the state of Kansas assign various '
i tasks in the evacuat!on plan to these units of government.
The type nf equipment required depends upon the plan and what the various units of government will be asked to do uryder the plan.
When the plan is submitted, it will be possible to describe the equip-
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ment needed and state why it is needed.
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EP-13. Criteria to be used to determine whether governmental boaies are sufficiently funded include the followbg: present tax levies, the size and nature of tha property tax base, the availability of ciher types of tax revenues, the number of people li, the taxing unit and their age, and income, general taxpayer resistance or acmptance of a tax increase, other needs for funds of the unit af government, and the present level 3f funding provided for the plan.
2-a EP-14. Coffey-County, ' he. state of Ka isas,cand any other local units t
- of ' government that will> be required to respond to rei accident
'at the plant.
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EP-15. The.a' mount ~of additio'nal furids cannot.,be determi'ned until the
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plansJare submitted;.by.the state and 'the. local' units.of govern.
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. ment..Only. theri,will I know the number of people, the amount j
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and, tyh of equipment, the amoiirit of training reiuired', And the-l
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EP-16. For the reasons set forth 'in m. answer to ' EP'.15, it is not g-c
. popiblei.to,'.. respond to.' h'is. interrogatory, howeveI,'7in general t
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'the. funds twould 'be used'io,make up for. deficiencies.in.Ptraining, l
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7 Ng equipment, pers6nnel,.: warning' systems, and ?other. needs created
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I Ef'-17. There is too much reliance on utility company personnel.
There are no special in home warning devices to warn peop!s. Not enough consideration has been given to adverse weather conditions.
EP-18. Please see my answers to General Interrogatories Nos. 8 - 4, for my answer to EP-18.
EMFAGENCY PLANNING AND FINANCIAL QUALIFICATIONS CONTENTIONS Until the plans of the local units of government and the state are sub-mitted, 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 applicants will be notified and furnished with the information requested in Items a - e, of this inter-rogatory.
GENER AL INTERROGATORIES i
i 1.
The answers to Emergency Planning Contention Interrcgatories EP-1 to EP-17 are 'to some extent based on the follnwing documents: Coffey County Co'ntingency Plan for Wolf Creek Generating Station, August 1979; Evacuation Plans - the -Achilles' Heel of the Nuclear Industry, by Ron l-Lanoue; and Criteria for Preparation and Evaluation of Radiological Emer-t.
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i gency Respotu lans and Preparedness in Support of Nuclear i ower Plants, NUREG-0654.
Additionally, the answers in Interrogatories EP-13 to EP-17 are to soine extent based on the letter from the Pennsylvania Emergency Management Agency, dated March 5,1981, to Jonn G. Reed, C :ector, Callaway County Emergency Management Agency. The respective answers are based on my analysis of all the information in the respective documents.
Such information provides the basis to determine what is needed in an evac-uation to insure that th: goals of the plan will be met, what is required in a plan, and provides the basis to compare the Wolf Creek plan against a standard. There may be other documents which have been the basis for my answers to the Interruptories. As thee are discovered and recalled, I w 11 furnish information about them as an amendment or supplement to my answer to this General Interrogatory I.
2.
The answers to In+errogatories EP-1 to EP-17 are to some extent based upon my work as acting Coffey County Erner gency Preparedness Coor-dinator in preparing the C.wifey County Contingency Plan for Wolf Creek Generatint Station, August 0 79.
Mary Eilen Saiava and I performed the study and developed the pirn.
This was done during the years 1978 to 1979. A copy of the plan is furnished as requested in the applicants' request for production of documents, dated August 19, 1981.
As a consequence of developing the plan, I am able to determine what is required in order to develop and imple-ment a successful evacuation plan for the Wolf Creek plant. -. _.
3.
The answers to Interrogatories EP-I to EP-17 are based upon research that I have done since about 19 73.
The research included studies of the documents set forth in the answer to General Interrogatory 1.
I cannot t
describe each document that I have studied; however, I have reviewed numerous newspaper and magazine articles and many phamplets.
The research has made it possible for me to analyze evacuation plans and to determine if a plan such as the one to be developed for the Wolf Creek Generating Station will be successful. If subsequent to filing this answer, I recall or discover any documents relating to such research, I will amend and supplement my answer to this general Interrogatory 3 and produce the documents to the applicants.
4.
The answers to Interrogatories EP-1 to EP-17 are to some extent based upon conversations and communications with the following indivi-duals: Leon Mannell, State Radiologist for the State of Kansas; Ed Johns, Coffey County Local Coordinator; Earl Freeman, Ceffe, County Shen if; la Ellis, Nursing Home Administrator, Burlington, Kansas; Alfred Mann, Burlington, Kansas, Fire Chief; Bill Griffith, Hospital Administrator, Coffey County, Kansas; Max McDowell, Elmdale, Kansas; Harold Sharff, Superintendent of School District 244; Raymu.d Schofield, Superintendent of School District 243; Ted Vannccker, Superintendent of School District 243 and others described in my notes which are as follows:
(a) Meetings with State Planners - dated June 18, 1979.
(b) Minutes of Meeting Monday evening, January 21, 1980 with Firefighters of Coffey County, (c) Minutes of Meeting to discuss various aspects of a Contin- --.-.
gency Plan for Wolf Creek Generating Station, Monday, Fe!'ruary 4, !980, 10:00 a.m., Coffey County Courthouse, Room 8.
I am not familiar with the educational and nrofessional background of these individuals nor do I know more about their occupation than listed above. At this time, I am not able to recall the exact naturc of each communication with these individuals and when it occered.
However, my disce"lons with these individuals have prcvided me with information about the ability of Coffey County, the State rJ Kansas, and other local units of government to re-spond to a radiological emergency at the Wolf Creek Generating Station.
The. conversations have also pmvided me with a basis to evaluate proposed i
emergency and evacuation plans.
At this time I do not recall having any other letters, memorandums, tapes, notes, er other records related to these conversations. If af ter filing the answer to this General Interrogatory 4 I scall the nar:es of other individuals with whom I have had conversations or correspondence that relate to this Interrogatory or the Interrogatories EP-1 to EP-17, I will amenc' 'r supplement this answer by providing such information. >
The answers set forth above on pages _/_ to /C are based on the information available to me at this time.
If further information becomes available to me, I rese-ve the right to supplement or amend these answers and to the extent required to do so will supplement or amend these answers.
Signed this OM/b day of aeptember,1981.
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f Wanch Christy
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STATE OF KANSAS, COUNTY OF
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,b7 On this day of
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, 1981, j
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[#M l ( s Iif appeared before me and being first duly
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sworn made and signed the above answer under oath.
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/lM be u /h < n e,
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(Seal)
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UNITED STATES OF AMERICA NUCL EAR 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 Generatin-
. tion,
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Unit No.1)
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CERTIFICATE OF SERVICE I hereby certify that copies of Answers of Intervenor Chrittu to Applicants' First Set of Interrogatories in the above-captioned proceec!ng have been served on the following by deposit in the United States mail, first class, 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 flashing.on, D. ;.. 20555 Dr. George C. Anderson Department of Oceanography Docketing and Service Section University of Washington OIfice 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 A renue, N.W.
Treva 3. Hearne, Esq.
Washington, D.C.
200 5 Assistant General Counsel
~e. O. Box 360 Kansans for Sensible Energy Wiferson 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 56 Washington, D.C.
20006 Bc.rlington, Kansas 66839
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4 Wanda Christy Myron Karman
$15 'J.1st Street Deputy Assistaat Chief Hearing Counsel Burlington, Kansas 66839 Office of the Executive Legal Director Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board U.S. Nuclear Regulatory Commission C. Edward Peterson, Esq.
j Washington, D.C.
20555 Assistant General Counsel Kansas Corporation Commission j
State Office Bldg.
t Topeka, KS 66612 b.
9dhn M. Simpson ~
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