ML20031B350
| ML20031B350 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/24/1981 |
| From: | Salava M SALAVA, M.E., INTERVENOR |
| To: | KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8110010264 | |
| Download: ML20031B350 (13) | |
Text
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UNITED STATES OF AMERICA
\\oa ti NUCLEAR REGULATORY COMMISSION N
g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Mattrr of
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Docket No. 50-
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ANSWER OF INTERVENOR SALAVA TO APPLICANTS,
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FIRST SET OF INTERROGATORIES
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_ S' The Intervenor, cry EJten Sa!ava, being first duly sworn states under o'atli' as iollows:
The following are my answers to the Emergency Planning Contention Inter-rogatories, Nos. EP-1 to EP-18; de Emergency Planning and Financial Qualifications Contentions; and the General Interrogatories of the Applicants, Nos.1-4; each dated August 19, 1981:
EMERGENCY PLANNING CONTENTION EP-1. The radiological emergency response plan of the applicants as it relates to evacuation is not workable. To the bet of my knowledge, the evacuation plan of Coffey v603 Coun cy,
the state of Kansas, and any other local y j unit of government which would need to respond to an j
emergency at the Wolf. s eek Plant has not been prepared.
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EP-2. There must be enough people available to implen ent the plan.
This depends uf an 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 number of people to be evacuated, the age of the people to be evacuated, the location of the people to be evacuated, the background and 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 duration period of the evacuation, the health of the people to be moved, weather, the type of accident, and the availability of people assigned to the various evacuation plan usks, and the training of tae people who will implement the plan.
EP-3. Coffey County, the state of Kansas, and any other governmental unit responsible for participatint in the evacuation plan.
EP-4.
The plan of the state of Kansas, Coffey County, and other local governmental units have not been submitted. Therefore, it is not possible to answer tnis 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.
EP-5.
Due to the fact that the plans of the local units of government and the state have not been submitted, it is not possible to ant. er this interrogatory.
EP-6. To determine whether personnet 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, evacuation plan equipment operation, and the nature and scope of the evacuation plan and procedures; the number, type, and critiques for exercises and drills conducted; the qualifications of instructors; the actual experience and work with duties similar to that which a persen will be responsible for in 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 the evacuation plan, it is also important that ch person partic.pating in the plan be able to express his duties and how they relate to the overall plan..
EP-7. Due to the fact that the local units of government and the state of Kansas have not sinmitted plans, it is not possible to answer this interrogatory.
The functions have not been assigned.
EP-8. Doe to the fact that the local units of government and the state of Kansas have not submitted plans, it is not possible to answer this interrogatory. I do not 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 whic, regularly simulate a radiolog-ical accident at the plant, use of safety equipment, instruction about the location of evacuation plan equipment, and techniques to be used in warning the public in the event of an accident.
EP-10. The following 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 vehicles available to evacuate people, the method used to warn 1.
people of an accident and the type of equipment and means that will be used to i..ake such warnings, the communications systems needed to conduct the plan, the number of warning sitens 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-il. Coffey County, state of Kansas, and 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 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 l
tasks in the evacuation plan to these units of government.
l The type of equipment required depends upon the plan and what the sarious units of government will be asked to do under the plan.
When the plan is submitted, it will be possible to d scribe the equip-ment needed and state why it is needed.
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EP-13. Criteria to be used to determine whether governmental bodies are sufficiently funded include the following: present tax levies, the size and nature of the property tax base, the availability l
of other types of tax revenues, the number of people in the l
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taxing unit and their age and income, general taxpayer resistance or acceptance of a tax increase, other needs for funds of the unit of government, and the e-asent level of funding provided for the plan.
EP-14. Coffey County, the state of Kansas, and any other local units of gover. nent tint will be required to respond to an accident at the piant.
EP-15. The amount of additional funds cannot be determined until the plans are submitted by the state and the local units of govern-ment. Only then will I know the number of people, the amount and type of equipment, the amount of training required, and the responsibilities of each unit of government under the plari.
EP-16. For the reasons set forth in my answer to EP-15, it is not possible to respond to this interrogatory, however, in general the funds would be used to make up for deficiencies in training, equipment, personnel, warning systems, and other needs created by the plan.
EP-17. There is too much reliance on utility company personnel. There are no special in home warning devices to warn pecple. Not enough consideration has ocen given to adverse weather conditions. - - _ - -
4 EP-IS. Please see my answers to General Interrogatories Nos.1 - 4, for my answer to EP-18.
EMERGENCY 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.
GENERAL INTERROGATORIES 1.
The answers to Emergency Planning Contention Interrogatories EP-1 to EP-17 are to some extent based on the following documents: Coffey County Contingency Plan for Wolf Creek Generating Station, August 1979; and Evacuation Plans - the Achilles' Heel of the Nuclear Industry, by Ron i
Lanoue. The respective answers are based on my analysis of all the l
information in the respective documents. Such information provides the basis to determine what is needed in an evacuation to insure that the goals of the plan will be met, what is required in a plan, and l
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 Interrogatories.
As these are discovered and recalled, I will furnish information about them as an amendment or supplement to my answer to this General Interrogatory I.
2.
The answers 9 Interrogatories EP-1 to EP-17 are to some extent based upon my work as acting Coffey County Emergency Preparedness Coor-dinator in preparing the Coffey County Contingency Plan for Wolf Creek Gener-ating Station, August 1979. Mary Ellen Salava and I performed the study and developed the plan. This was done during the years 1978 to 1979. A copy of f ie 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 cetermine what is required in order to develop and imple-ment a success' I 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 describe each document that I have studied; however, I have reviewed numerous l
newspaper and magazine articles and many phamplets. The research has made i
it possible for me to analyze evacuation plans and to determine if a plan f
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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 disc., ver 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 L.diologist for the State of Kansas; Earl Freeman, Coffey County Sherrif; Frank Satrines, Jim Cochran, Paul Barkley, and Owen Turrentine of the State of Kansas Emergency Preparedness Office, Topeka, Kansas; Max McDowell, Elmdale, Kansas; Micheal Almon, City of Lawrence, Kansa;, Emergency Preparedness Office; and Professar l
l Bingham, Emporia State University.
I am not familiar with the educational l
t and professional background of these individuals nor do I know more about 1
their occupation than listed above.
At this time, I am not able to recall the exact nature of each communication with these individuals l
l and when it occured. However, my discussions with these individ-uals have provided me with information about the ability of Coffey County, the State of Kansas, and other lxal units of government to re-sp.zd to a radiological emergency at the Wolf Creek Generating Station.
The conversations have also provided me with a basis to evaluate pioposed emergency and evacuation plans.
At this time I do not recall havi..c any l
other letters, me. >randums, tapes, notes, or other records related to 9
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these conversations. If af ter filing the answer to this General Interrogatory 4 I recall the names 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 amend or supplement this answer by providing such information.
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1 The answers set forth above on pages
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to /0 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 su,'plement or amend these answers.
Signed this c21/ -/k day of September, 1981.
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Maryrklien Salava
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STATE OF KANSAS, COUNTY OF do/ s/ /t./
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On this OY day of V 4 3'r/t Mr>.I, 1981, l
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I sworn made and signed the above answer under oath.
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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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KANSAS GAS ANIfELECTRIC 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 af Answers of Intervenor Salava to Applicants' First Set of Interrogatories in the above-captioned proceeding 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 Washington, D.C.
20555 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 i
l 1140 Connect? cut Avenue, N.W.
Treva 3. Hearne, Esq.
Washington, D.C.
20036 Assistant General Counsel P. O. Box 360 Kansans for Sensible Energy Jefferson City, Mo.
65102 P. O. Box 3192 Wichita, Kansas 67201 Jay Silberg, Esq.
Shaw, Pittman,Potts & Trowbridge Mary Ellen Salava 1800 M Street, N.W.
Route 1, Box 56 Washington, D.C.
20006 Burlington, Kansas 66839 l
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Wanda Christy Myron Karman Si 5 N. Ist Street Deputy Assistant Chief Hearing Counsel Burlington, Kansas 66839 Office of the Executive Legal Director Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20535 Appeal Board U.S. Nuclear Regulatory Commission C. Edward Peterson, Esq.
Washington, D.C.
20555 Assistant General Counsel Kansas Corporation Commission State Office Bldg.
Topeka, KS 66612 0A N. $>s Jef5n M. Simpson
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