ML20031B352
| ML20031B352 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/24/1981 |
| From: | Salava M SALAVA, M.E., INTERVENOR |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8110010266 | |
| Download: ML20031B352 (5) | |
Text
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JEIATED CORRESPONDENCF
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NUCLEAR REGULATORY COMMISSION Ec..., m.a 9
d BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Cn l D In the Matter of
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KANSAS GAS AND ELECTRIC COMPANY, )
Docket No. 50-482 et. al.
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(Wolf Cicek Generating Station,
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Unit No.1)
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ANSWER OF MARY ELL.EN SALAVA TO NRC STAFF INTERROGATORIES AND RE OUEST FOR PRODUCTION OF DOCUMENTS M
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g The intervenor, Mary Ellen Salava, being first duly sworn states r
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c oath as follows:
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,.3 wssee The following are my answers to the NRC Staff Interrogatories a'rjds.
9 Request for Production o,f Dc> uments to Wanda Christy; Mary Ellen [
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Sdava and Kansans for Sensible Energv (KASE), dated August 14, 1981:
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(a) Our contention is that the local government s (Coffey County, the State of Kansas, and other local units of government required to respuid to an emergency at the Wolf Creek plant) do not have a. work-l able evacuation plan.
To date, none of these units of government has prepared a plan. Even though a plan has not been prepared, discussions l
I have had with County Commissioners, representatives of the State of Kansas, and others indicate that plans being contemplated cannot be g$03 1
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implemented because there are not enough people available to fill the positions required ior 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 cf 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 people affected thereby has provided for any fund-ing to carry out such an evacuation plan.
Until plan 3 are prepared and submitted, there is ne evidence that a viable evacuation plan exists.
Until such plans are submitted, I cannot adequately respond to this Inter-rogat.ery. However, 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),
2 and 3..
The answers set forth above on pages
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to
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If further information becomes available to me, I reserve the right to s, olement-or amend these answers and to the e: dent required to do so will supplement or amend these answers.
Signed this 8M [h day of September,1981.
Y fh/> 5 J Mary 9kilen Salava STATE OF KANSAS, COUNTY OF St4 Aft 0
On this
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sworn made and signed the above answer under oath.
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(Seal)
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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 AND ELECTRIC COMPANY, )
Docket No. 50-432 et. al.
)
)
(Wolf Creek Generating Station,
)
Unit No.1)
)
CERTIFICATE OF SERVICE I hereby ca.ify that copies of Answer of Mary Ellen Salava 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, Mrst 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 Ser'tle, Washington :8195 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. Hea.rne, Esq.
Washingian, D.C.
20036 Assistant ueneral 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 t
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Wanda Christy Myron Karman 515 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.
20555 Appeal Board U.S. Nuclear Regulatory Commission C. Edward Peterson, Esq.
Washington, D.C.
205M Assistant General Counsel Kansas Corporation Commission State Office Bldg.
Topeka, KS 66612 A h,. O,
'fohn~ M. Simpson '
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