ML20062M623

Motion to Reopen Record on Emergency Contention.Request Timely Since Concerns Have Developed Since Close of Record & Are Significant Safety Issues.Certificate of Svc Encl

ML20062M623
Person / Time
Site:	Summer
Issue date:	12/08/1981
From:	Bursey B BURSEY, B.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8112170364
Download: ML20062M623 (3)

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NUCLEAR REGULATORY COMMISSION s

ATOMIC SAFETY AND LICENSING BOAR 9

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dSp In the Matter of: Ne[

SOUTH' CAROLINA ELECTRIC & GAS )

C0,MPANY, et al.

Docket No. 50-395 OL *t' 4 P4:28 Virgil C. Summer Nuclear Station, -) .. >

Unit 1 . )

ld 9; DEC1619816 e INTERVENOR'S MOTION TO REOPEN THE RECORD ON EMERGENCY CONTENTION ' 5 "w"

, J Pursuant to the close of the Atomic Safety and Licensing B emergency considerations, the Intervenor gained significant information that directly affects ' het implementation of emergency plans.

This information, made available to the Intervenor by Richland County .

sheriff Frank Powell, need become a part of the record, as it directly contradicts testimony by Applicant's witness Ken Beale (Tr 4511/15). The Applicant relies (Tr. 4674) upon Mr. Beale's testimony to support their assertion for a timely evacuation in the event of a power outage affecting emergency sirens and utilizing sheriff's deputies as backup notification. -

Si1e the close of the record on the emergency contention, the Applicant has begun testing sirens. I moved, unsuccessfully, that the record be left open until a conclusively safe testing of the sirens (Tr. 4675). The Applicant's methodology for testing the sirens is surprisingly inadequate. They are to be manually switched on, one at a time. There are no plans for an actual test of the collective acti-vation from the V.C. Summer plant, nor is the public being advised to listen to see if they can hear them.

In fact, the sirens closest to my house were tested last week, and it was only after my sister brought them to my attention - and I went outside my house - that I could hear the sirens which had been going off all morn-ing. The piecemeal, manual testing of the siren system should -compel this board to reopen hearings on this issue. The Applicant should be instructed to test entire "

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, portions of the system, as would be necessary in an actual emergency. The public should be advised and involved, in order to aprise the sirens' effectiveness.

8112170364 811201 PDR ADOCK 05000395 0 PDR N0$

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,. The'. record should be reopened at the conclusion of the testing. This could coincide with the' scheduled hearings'on seismic issues set for January 11, 1982.

Precedents favor the reopening fo the hearing upon the favorable consideration I

of three issues: I believe (1) this request is timely since these concerns have developed since the close of the record; (2) these concerns are significant s.afety issues, (3) different.results may be reached upon con >ideration of these newly proffered material (ALAB-598, ALAB-462, 7NRC-320, 338 (:978), ALAB-138, 6AEC-520, 523 (1973).

'Should this motion be granted, I will be submitting prefiled testimony from Sheriff Frank Powell.

Respectfully submitted, ww, '

i Brett Bursey Intervenor 1

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4 D C',f' E T ED iwt' UNITED STATES OF AMERICA  !

NUCLEAR REGULATORY COMMISSION

'81 DEC 14 P4:28 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  %

. . : .? SE?SETARY

C;n.orG & SERVICE EHA!4CH In the Matter oft )

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SOUTH CAROLINA ELE ('TRIC & )

GAE COMPANY and )

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SOUTH CARCLINA PUBLIC ) Docket No.59-395 OL SERVICE AUTHORITY )

)

(Virgil C. Summer Nuclear )

Station) )

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CERTIFICATE OF SERVICE 1 hereby certify that copies of "Intervenor's Motion to Reopen the Record on Emergency Contention" were served upon the following persons by deposit in the United States mail, first class postage, this 8th day of Decembee, 1981:

Herbert Grossman, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Panel Licensir.g Board U. S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 George Fischer, Esq.

Dr. Frank F. Hooper Vice President & Group School of Natural Resources Executive - Legal Affairs University of Michigan S. C. Electric & Gas Ccmpany Ann Arbor, Michigan 48109 Post Office Box 764 Columbia, S. C. 29202 Mr. Gustave A. Linenberger Member, Atomic Safety and Steven C. Goldberg, Esq.

Licensing Board Panel 'ffice of the Executive U. S. Nuclear Regulatory Legal Director Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Appeal Board Panel Mr. Chase R. Stepher.s U. S. Nuclear Regulatory Docketing and Service Section ce e Secretary W n D. C. 20555 U.S. Nuclear Regulatory Connission Washington, D.C. 20555 Richard P. Wilson, Esq.

Assistant Attorney General J.B. Knctts, Jr. , Esq.

South Can>1ina Attorney General's Debevoise & Liberman Office 1200 17th Street N.W.

j P.O. Box 11549 Washington, D.C. 20036

' Columbia, S.C. 29211 Larry Mahan Dr. John Ruoff i l

South Carolina Electric & Gas Company f P.O. Box 764 Columbia, S.C.

( 29218 .

g w w +- y-Ett Bursey. Intervenor j

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