ML20080B452
| ML20080B452 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/30/1984 |
| From: | Christy W, Salava M CHRISTY, W., SALAVA, M.E., INTERVENOR |
| To: | KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8402070147 | |
| Download: ML20080B452 (13) | |
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00tKETED USNRC 84 8 -6 N0 :28 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION rrn:T cr gry og
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Before the Atomic Safety and Licensing Board'"
In the Matter of
)
)
KANSAS GAS AND ELECTRIC COMPANY, et al. )
Docket No. STN 50-482
)
(Wolf Creek Generating Station,
)
Unit No. 1)
)
4 Intervenors' Answers to Applicants' Interrogatories and Request for Production of Documents to Intervenors Wanda Christy and Mary Ellen Salava (EPZ Contention).
Wanda Christy and Mary Ellen Salava, the intervenors, being first duly sworn state under oath as follows:
The following are our joint answers to Applicants' Interrogatories and Request for Production of Documents to Intervenors Wanda Christy and Mary Ellen Salava (EPZ Contention), dated January 11, 1984:
Interrogatory 1.
At this time the intervenors do not intend to call any witnesses.
Interrogatory 2.
These documents are listed in our answers a
to interrogatory 7 (a).
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_ Interrogatory 3.
These documents are listed in our answers to interrogatory 7(a).
Interrogatory 4.
(a).
Some of the children who attend the schools in Waverly live in the 10 mile EPZ.
Their parents will evacuate, and if school is in session, they will have to pick up their children at school or go without them.
That would not be the case if the Waverly schools are in the EPZ.
If the children are not in the EPZ, what would be done with them? There is testimony in the proceedings that the students at Waverly would first be bused home when the EPZ was warned.
That could put some of them in the EPZ and without transportation, or the parents would have to wait for them.
The parents could assume that because they are in the EPZ and are evacuating that the children will also be evacuated.
To resolve these kinds of problems it is best to put Waverly and the schools in it in the EPZ.
That way people will be educated about what to do in the event of an emergency, and evacuation of the children and parents will be assured.
(b).
Waverly is 11.4 miles north-northeast of the Wolf Creek Plant.
During the months of April to December the prevailing winds are from the south.
Even during the balance of the year there are frequent winds from the south.
Therefore, in the event of an accident Waverly is very likely to be in the path of the 2
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O radi active plume, and its citizens will have a high possibility of being contaminated if they are not removed.
(c).
The proposed EPZ comes right to the edge of Waverly.
If it is important to evacuate a few people who are on one side of a road, then the substantially greater number of people in Waverly should be entitled to the same protection that being part of the evacuation plan provides.
Also, because of this proximity to the EPZ people in Waverly might become confused and expect assistance when there would be none forthcoming.
(d).
Because they are so close to the EPZ, people in Waverly may evacuate any way.
If they do this, it would be best for them to be educated about the plan so they can respond in a way that is consistent with what the people in the EPZ will be doing.
Also if they are in the plan, they will receive the educational material and will be directed to the proper host county for radiation checks and shelter.
(e).
Only 700 people live in Waverly.
Those people plus the 270 in the Waverly schools will not i
add an unmanageable number of people to the plan.
Few
. additional resources will be required.
Enough school buses l
may be available.
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(f).
The buses of the Waverly schools will be used in the evacuation of people in the EPZ, and some people in Waverly will probably be emergency workers under the Coffey County plan.
If so, the people of Waverly may not be able to evacuate themselves and their neighbors.
If they are to provide resources for the evacuation of the EPZ they must not do so if it could create problems for their families and friends.
Interrogatory 5. (a).
(1).
If Waverly is in the EPZ, warnings will be provided.
At the present time there are no warning devices in the town that relate to the evacuation of the EPZ.
'(2).
Since they are not in the EPZ, the people of Waverly do not receive educational materials about what to do in the event of an emergency.
(3).
The people and schools will need transporation.
People without transportation will not be assured of transportation to evacuate unless they are included in the EPZ transportation plan.
(4).
There needs to be training for the administrators, teachers, and students in the Waverly schools so they will know how to respond in the event of an 4
t emergency.
If they are in the EPZ this would be given to them under a recommendation by FEMA.
( 5 ) ~.
The poeple of Waverly would need the services that will be provided at the host counties -
radiation monitoring, decontamination.-and shelter.
This could be assured to-them if they are part of the EPZ.
Interrogatory 5 (b).
If these needs are not met, and if the response capabilities are not provided, the health and safety of residents and school children in Waverly will be threatened.and not adequately provided for.
Unless the needs are addressed in advance, there is no assurance the residents of Waverly and its school children will be warned, evacuated, and sheltered in the event of an emergency.
Interrogatory 6 (a).
(1).
Demography. There are 700 residents in Waverly and 270 students.
There will be people without transportation - handicapped and those who temporarily do not have transportation.
Some people will need special warnings because they can not hear a siren or i.
tone alert.
There will be school children who live in the EPZ and attend Waverly schools.
Some families may have emergency workers who are part of the county emergency organization.
Pregnant women and young children might need special transporation if they are evacuated early.
The people specified will need special warnings, a general 7
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warning, special transportation, education, and/or shelter in the host counties. This favors putting Waverly and its schools in the EPZ.-
(2).- Topography.
The town is not in siren range of the sirens in the EPZ and its residences and businesses do not have tone alerts.
Adequate warnings will need to be provided to the residents and schools.
This favors putting Waverly and its schools in the EPZ.
(3).
Land Characteristics.
The city of Waverly is only 11.4 miles north-northeast of the Wolf Creek Plant.
Prevailing winds could carry radiation to the town in a little over one hour after a release began.
Because people could receive harmful doses of radiation in a little over_an hour after a release began, the people must be rapidly evacuated.
This favors putting Waverly and its schools in the EPZ.
(4).
Access Routes.
Access routes do not affect the local response needs and capabilities except to the extent that adequate evacuation routes must be provided for and kept open.
Access routes are needed so people will know how to evacuate in the most desirable manner; so they will get to the most desirable host county center; and to insure that the routes are available in the 6
event of snow, ice, or other adverse weather conditions.
This. favors putting WaverlP and its schools in the EPZ.
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4-(5).
Jurisdictional Boundaries.
Parts of the school district are in the EPZ and part are out of it.
For-fthe reasons specifed in paragraph (a) of the answer to Interrogatory 4 above, this favors putting Waverly and its schools in the EPZ.
Interrogatory 7 (a).
The following are documents relied upon.
The references after a page number in the answers to Interrogatory 7 (a) and 7(b) are to interrogatory answers set s
forth above.
For example, "I4 (c) " refers to our answer to Interrogatory 4,. subparagraph (c).
Coffey County Emergency Plan, September 1983 Revision.
P.
0-5, 14 (c) ;
P.
3-4, I5 (a) (1), 16 (a) (2) ;
P.
H-11, I5 (a) (1), 16 (a) (2) ; P.
K-12, I4 (e).
Coffey County Emergency Plan, 1981 Version, November 1982 Revision.
P.
0-3, I4 (e), I6 (a) (1) ;
P.
3-44, I4 (e),
L 16 (a) (1).
t NUREG 0654, P.
17, I6 (a) (3).
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Applicants' prefiled testimony, Norman Bowers.
P.72, i
. I4 (f) ;
P.
89, I4 (f).
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Applicants' profiled testimony, Carol Wilcox. P.
89, l
I4 (f).
Wyle Laboratories Report 82-36.
P.
2-5, I4 (b),
I6 (a) (3) ; P.
2-8, I4 (b).
FEMA profiled testimony, P.
61, I5 (a) (4).
Interrogatory 7 (b).
Norman Bowers, Coffey County Engineer.
I4 (a), I4(b), I4 (f).
Carol Wilcox, Coffey County Emergency Preparedness Coordinator.
I4 (a), I4 (b), 14 (e), I4 (f),
l 15 (a) (1), 15 (a) ( 2), I6 (a) (2), 16 (a) (5).
Jack W.
Swing, Wyle Laboratories, L
' Arlington, Virginia.
I4(b), I6 (a) (2), I6 (a) (3).
l Interrogatory 7 (c).
At this time we do not intend to call any-witnesses, l
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. Interrogatory 8.
No person provided information to be used i
in preparing these answers.
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l Interrogatory 9.
Not applicable, r
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Interrogatory 10.
No person other than ourselves searched for documents in order to respond to requests for identification of documents.
Interrogatory 11.
Not applicable.
Interrogatory 12.
At this time we do not know of any such written or recorded statement.
Request For Production Of Documents.
The applicants have each of the documents in their possession.
9 m
2.e answers set fort h above on pag : o 1 to 9 are based on the infer: ration available to te at this time. If further inforation Vcorer nysilaala to re, I reserve tht richt to supplt. ment or arend these ans<.ers tnd to the extent required to do so will suppl >;:ent or atend these m sw ers. Sirned this M g dsy of Jenuary, 1921,.
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(hrry Ellen Salava e
STATE OF KANSAS, COUNTY OF JO!INSON:
On this h k day of January, 1984, Wanda Christy and Mary Ellen Salava appeared before me and being first duly sworn made and signed the above answer under oath.
DE80RAHJ.THON l
WMM o kitA
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Notary Public 6 10
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
KANSAS GAS AND ELECTRIC COMPANY, et al.
)
Docket No. STN 50-482
)
(Wolf Creek Generating Station,
).
Unit No. 1)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Intervenors' Answers to Applicants' Interrogatories and Request for Production of Documents to Intervenors Wanda Christy and Mary _ Ellen Salava (EPZ Contention)" was served by deposit in the United States Mail, first class, postage prepaid, this 30th day i
of January, 1984, to all those on the attached Service List.
A hn M. Simpson 4
DATED:
January 30, 1984 I
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
KANSAS GAS AFD ELECTRIC COMPANY, et al.)
Docket No. STN 50-482
)
(Wolf Creek Generating Station,
)
Unit No. 1)
)
SERVICE LIST Sheldon J. Wolfe, Chairman.
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. George C. Anderson Docketing and Service Section Department of Oceanography Office of the Secretary University of Washington U.S.
Nuclear Regulatory Commission Seattle, Washington 98195 Washington, DC 20555
-C.
Edward Peterson, Esquire Kent M. Ragsdale Assistant General Counsel General Counsel Kansas Corporation Commission Missouri Public Service Commission State Office Building - 4th Floor P.O. Box 360 Topeka, Kansas 66612 Jefferson City, Missouri 65102 Dr. Hugh C.
Paxton Atomic Safety and Licensing Board 1229 - 41st Street U.S. Nuclear Regulatory Commission Los Alamos, New Mexico 87544 Washington, DC 20555 1
Myron Karman, Esquire A.
Scott Cauger, Esquire Deputy Assistant Chief Assistant General Counsel Hearing Counsel Missouri Public Service Commission Office of the Executive P.O.
Box 360 Legal Director Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission Washington, DC 20555 Eric A. Eisen, Esquire Jay E.
Silberg Birch, Horton, Bittner & Monroe Shaw, Pittman, Potts & Trowbridge 1140 Connecticut Avenue, N.W.
1800 M Street, N.W.
Washington, DC 20036 Washington, DC 20006 c
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Service-List Page-2 Alan S..Rosenthal, Esquire Dr.EJohn H.
Buck Atomic Safety-and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Brian P. Cassidy, Esquire Thomas S. Moore, Esquire Federal Emergency Management Agency Atomic Safety and Licensing Region I Appeal Board J. W. McCormack POCH U.S. Nuclear Regulatory Commission Boston, Massachusetts 02109 Washington, DC 20555 Mary M. Stephens, Director A. Rodman Johnson Nuclear _ Awareness Network, Inc.
820 Quincy, Suite 418 1347 1/2 Massachusettes Topeka, KS 66612 Lawrence, KS 66044 l
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