ML20132A458
| ML20132A458 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/20/1985 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | JOINT INTERVENORS - VOGTLE |
| References | |
| CON-#385-584 OL, NUDOCS 8509250346 | |
| Download: ML20132A458 (51) | |
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UNITEDiC$TATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of :
GEORGIA POWER COMPANY, et al. : Docket Nos. 50-4240L
- 50 4250L (Vogtle Electric Generating :
Plant, Units 1 and 2) :
APPLICANTS' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS ON EMERGENCY PLANNING CONTENTIONS These interrogatories and these requests for production of documents are directed to Joint Intervenors Campaign for a Prosperous Georgia / Georgians Against Nuclear Energy and pertain to contentions admitted by the Atomic Safety and Licensing Board in'its " Memorandum and Order.(Ruling on Joint Interve-nors' Proposed Contentions on Emergency Planning)" dated August 12, 1985.
Answers or. objections to these interrogatories and re-sponses or objections to the requests for production of docu-ments must be served within the time specified in the Commis-sioner's Rules of Practice. Response times would be controlled by a Board order establishing a discovery schedule, if such an order issues prior _to the time for filing of these responses.
8509250346 850920 PDR O ADOCK 05000424 -
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The interrogatories are filed pursuant to 10 C.F.R. 5 2.740b, which requires that they be answered separately and fully in writing under oath or affirmation. The interrogato-ries are intended to be continuing in nature and, pursuant to 10 C.F.R. $ 2.740(e), the answers must be immediately supple-mented or amended, as appropriate, should Joint Intervenors ob-tain any new or differing information responsive to the inter-rogatories.
The requests for production of documents are filed pur-suant to 10 C.F.R. $ 2.741, which requires that Intervenors produce and furnish copies of, or permit Applicants to inspect and copy, any documents that.are responsive to the requests and that are in the possession, custody, or control of Joint Inter-venors. The requests for production of documents are also con-tinuing in nature, and Joint Intervenors must produce immedi-ately any documents they obtain which are responsive to the requests.
I .. INSTRUCTIONS The following instructions and definitions apply to Appli-cants' interrogatories and requests for production of docu-ments.
When identification of a document is requested, briefly describe the~ document (i.e., letter, memorandum, transcript, book, pamphlet, handwritten notes,-etc.) and state the follow-ing information as-applicable to the particular document:
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document name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.
Also state the portion or portions of the document (whether section(s), chapter (s), or page(s)) upon which you rely. When identification of a person is requested, state' that person's full name, present employer or business affiliation, present address, and present telephone number.
The following terms shall have the meaning indicated below:
- 1. "VEGP" or "Vogtle" means the Vogtle Electric Generating Plant, Units'1 and 2.
- 2. " Joint Intervenors," "Intervenor's," "you," or "your" refers to Georgians Against Nuclear Energy (GANE) or Campaign for a Prosperous Georgia (CPG) and all directors, officers, shareholders, members, employees, agents, consultants, attor-neys, or other representatives of GANE or CPG.
- 3. " Document" means any handwritten, typed, printed, graphic, photographic, mechanically recorded, computer stored, i
filmed, or_other verbal _or. pictorial matter of whatever charac-ter, however produced or reproduced, of any kind and descrip-
, tion. " Document" shall also mean every. copy of a document when I such copy is not an identical duplicate of the original.
" Document" shall be construed broadly, and includes,_but_is not limited to, inter-office and intra-office memoranda, other memoranda, letters and other correspondence, reports, surveys, l
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1 tabulations, charts, books, pamphlets, photographs, maps, bul-letins,, minutes, notes of telephone calls and personal conver-sations, other notes, speeches, articles, transcripts, record-ings, telegrams, telecopies, telex messages, and all other writings or recordings of any kind.
- 4. The "Vogtle Plan" refers to the "Vogtle Electric Generating Plant Unit,1 and Unit 2 Emergency. Plan," Volumes 1 and 2, served on Joint Intervenors on November 30, 1984, in',cluding Revision 1, dated May 1985, served on Joint Interve-nors on May 17, 1985.
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- 5. The " County Plan" refers to the " Burke County Emer-gency Management Agency Radiological Emergency Plan For Nuclear Incidents / Accidents Invo'lving Vogtle Electrical Generating Plant," dated April 1985, served on Joint Intervenors on May 3, 1985.
- 6. The " State Plan" refers to " Annex D, Plant Vogtle, To The Georgia Radiological Emergency Plan," dated April 1985, served on Joint Intervenors on Ma'y 3, 1985, as well as to the
" State of Georgia Radiological Emergency Plan -- Base Plan."
- 7. "Offsite plans" refers to.the " County Plan" and the j " State Plan," as defined above.
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II. INTERROGATORIES In answering each interrogatory, please recite the inter-rogatory before providing the response.
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.m A1 A. Specific Interrogatories Contention EP-1/EP-1(a)/EP-2(b)
(24-hour Staffing of Burke County ENN Link) s EP-1(a)-1. In GANE's April 11, 1984 " Supplement To Peti-
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tion For Leave To Intervene anc Request For Hearing" and in CPG's May 25, 1984 " Amendment To-Supplement To Petition For Leave To Intervene and Request For Hearing," Intervenors iden-tified an April 4, 1984 conversation between Dr. Judy Gordon and Ms. Pam Smith as a basis for your allegation that there is j
" occasionally * *
- difficulty in contacting emergency person-nel in Burke County due to the lack of a full-time emergency planner." Describe all bases for that allegation, including (but not limited to) an identification of the date and time of each unsuccessful attempted contact, and the means used in the attempted contact (i.e. commercial telephone, the Emergency No-tification Net ("ENN"), etc.).
EP-1(a)-2. Describe in detail the April 4, 1984 conversa-I tion between Dr. Judy Gordon and Ms. Pam Smith,' incl'uding (but not limited to) the time of the conversation, a listing of all ,
persons present during any part of the conversation, and a dis-
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cussion of the substance of the conversation.
EP-1(a)-3. State;whether you contend that Director of the Burke County Emergency Management Agency is not a full-time po-sition. If your answer is affirmative, specify the bases for your answer.
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e EP-1(a)-4. State whether you contend that the difficul-ties allegedly encountered in contacting Burke County emergency personnel still exist even though Director of the Burke County Emergency Management Agency is now a full-time position. If your answer is affirmative, specify the bases for your answer.
EP-1(a)-5. State whether you contend that the Burke Coun-ty ENN link will not be staffed on a 24-hour basis. If your "
answer is affirmative, specify the bases for your answer.
EP-1(a)-6. State whether you' contend that Burke County
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fails.to provide for "24-hour per day manning of communications links that initiate emergency respohse actions" in accordance with NUREG-0654 Criterion F.1.a. If your answer is affirma-
- ;7s, specify the bases for your answer.
1 EP-1(a)-7. If your answer to - Interrogatory EP-1(a)-6
. above s aff irmative, identify each respect in which Burke County a llege dly fails to provide for "24-hour per day manning of commur' cat.ons links that initiate emergency response ac-
, tions", ar.1 sp. cify the bases for your answer.
EP-1(a) 8. If your answer to Interrogatory EP-1(a)-6 i
above is afficma';.ive, describe all changes you believe must be made to the'Coint, Plan and all other actions you believe must be taken to pro'i@ for "24-hour per day manning of communica-tions links taat -
Atiate emergency response actions." Specify the bases for your a swer.
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e EP-1(a)-9. State whether you contend that the procedure to be followed-by the Sheriff's Department upon notification of an emergency at Vogtle could not initiate an emergency response infa timely and efficient fashion. If your answer is affirma-1 tive, specify the-bases for your answer.
EP-1(a)-10. If your answer to Interrogatory EP-1(a)-9 above is affirmative, identify each respect'in which the proce-dure-to be followed by the Sheriff's Department is allegedly l inadequate to initiate timely emergency response, and specify I
the bases for your answer.
EP-1(a)-11. If your answer to Interrogatory EP-1(a)-9 j above is affirmative, describe all changes you believe must be made to the County Plan and all other actions you believe must j be taken to. assure.that the procedure to be followed by the i-l Sheriff's Department is adequate to initiate timely emergency response. Specify the bases for your answer.
EP-1(a)-12. State whether you contend that changes must be j made in the County Plan to meet the concern expressed in i
i EP-1/EP-1(a)/EP-2(b) as admitted by the Board (i.e., 24-hour staffing'of-the Burke County ENN link). If your answer is
- affirmative, describe any and all such changes, and describe in i .
4 detail the factual and regulatory bases for your belief that such changes must be made, i
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s EP-1(a)-13. State whether you contend that actions must be taken and changes must.be made (other than those identified in the answer to Interrogatory EP-1(a)-12 above) to meet the con-tern expressed in EP-1/EP-1(a)/EP-2(b) as admitted by the Board (i.e., 24-hour staffing of_the Burke County ENN link). If your answer is affirmative, describe any and all such changes and actions, and describe in detail the factual and regulatory bases for your belief that such actions must be taken and such changes made.
Contention EP-2/EP-2(a)
(Administrative Controls Over ENN Use)
EP-2(a)-1. State whether you contend that there are inad-equate administrative controls over the ENN system to restrict use of the system to the transmission of official and necessary messages. If your answer is affirmative, specify the bases for your answer.
EP-2(a)-2. If your answer to Interrogatory EP-2(a)-1 above is affirmative, identify specifically (by location) all ENN terminals for which you contend there are insufficient ad-ministrative controls. Specify the bases for your answer.
EP-2(a)-3. For each ENN terminal specified in your answer
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to Interrogatory EP-2(a)-2 above, describe the existing admin-istrative controls over the use.of that terminal. Specify the bases for your answer.
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- ' EP-2(a)-4. For each ENN terminal specified in your answer to Interrogatory EP-2(a)-2 above, describe the administrative controls which you-believe should be in place for that termi-nal, but which are not now in place. Specify the bases for your answer.
EP-2(a)-5. For each individual administrative control identified.in your answer to Interrogatory EP-2(a)-4 above, list by jurisdiction all emergency response organizations with-in the plume EPZs of other nuclear plants in the U.S. which have implemented that specific administrative control over their dedicated emergency telecommunications systems. Specify the bases for your answer.
EP-2(a)-6. State whether you contend that changes must be made in the Vogtle Plan and/or the offsite plans to meet the i
concern expressed in EP-2/EP-2(a) as admitted by the Board (i.e., administrative controls over ENN use). If your answer is affirmative, describe any and all such changes, and describe in detail the factual and regulatory bases for your belief that such changes must be made.
EP-2(a)-7. State whether you contend that actions must be taken and changes must be made (other than those identified in the answer to Interrogatory EP-2(a)-6 above) to meet the con--
j cern expressed in EP-2/EP-2(a) as admitted by the Board (i.e.,
administrative controls over ENN use). If your answer is
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affirmative, describe any and all such changes and act' ions, and describe in detail the factual and regulatory bases for your belief that such actions must be taken and such changes made.
Contention EP-2/EP-2(c)
(Use of NOAA Tone Alert Radios)
EP-2(c)-1. State whether you object only to the use of NOAA tone alert radios, or also to the use of other types of-tone alert radios. If you object to tone alert radios other than NOAA radios, state all types to which you object, and explain in detail the reasons for your objections.
EP-2(c)-2. State whether you contend that some tone alert radio system other than the NOAA' system should be used in the
. Vogtle plume EPZ. If your answer is affirmative, specify the bases for your answer.
EP-2(c)-3. If your answer to Interrogatory EP-2(c)-2 above is affirmative, identify specifically the tone alert radio system you propose for use in the Vogtle plume EPZ, de-scribe its advantages over the NOAA system,.and list all other U.S. nuclear plants which have the type of tone alert radio you propose in use within their plume EPZs.
EP-2(c)-4. Identify specifically each type of tone alert radio which is commercially available in the United States.
Specify the bases for your answer.
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EP-2(c)-5. Describe in detail each type of tone alert radio listed in your answer to Interrogatory EP-2(c)-4 above, specifically identifying the differences between the various types. Specify the bases for your answer.
EP-2(c)-6. Identify all U.S. nuclear plants which have public alert / notification systems which are comprised (entirely or in part) of any type of tone alert radio. Specify the bases for your answer. .
t EP-2(c)-7. Of the nuclear plants listed in your answer to Interrogatory EP-2(c)-6, identify those plants which have sys-tems which do not use NOAA tone alert radios. Specify the
- bases for your answer.
EP-2(c)-8. Identify specifically the type of tone alert radios in use at each of the nuclear plants listed in your answer to Interrogatory EP-2(c)-7 above. Specify the bases for your answer to Interrogatory EP-2(c)-8.
EP-2(c)-9. Of the nuclear plants listed in'your answer to Interrogatory EP-2(c)-6, identify those plants which have sys-i tems which do use NOAA tone alert radios. Specify the bases for your answer.
EP-2(c)-10. State the bases for the allegation that tone alert radios "are often shut off permanently by residents who become aggravated by [the] tendency to go off frequently without reason."
EP-2(c)-ll. State whether you contend that tone alert ra-dios frequently sound truly "without reason" -- that is, at times other than during periodic tone alert system testing, se-vere storm watches and warnings, and marine interest watches and warnings, or other emergency. Specify the bases for your answer.
EP-2(c)-12. State whether you contend that NOAA tone alert radios are more likely than other types of tone alert ra-dios to sound truly "without reason" -- that is, at times other than during periodic tone alert system testing, severe storm watches and warnings, and marine interest watches and warnings, or other emergency. Specify the bases for your answer.
EP-2(c)-13. State how often NOAA tone alert radios sound truly "without reason" -- that is, at times other than during periodic tone alert system testing, severe storm watches and warnings, and marine interest watches and warnings, or other emergency. Specify the bases for your answer.
EP-2(c)-14. State how often other tone alert radios (those which are not NOAA radios) sound truly "without. reason"
-- that is, at times other than during periodic tone alert sys-tem testing, severe storm watches and warnings, and marine interest watches ~ and warnings, or other emergency. Specify the bases for your answer.
EP-2(c)-15. State whether you contend that it is accept-Male to use NOAA tone alert radios in other plume EPZs around' the country, but.not in the Vogtle plume EPZ. Specify the
] bases for'your answer.
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EP-2(c)-16. Explain in detail how.-- if at all ---condi-tions in the Vogtle plume EPZ differ from conditions in.the plume EPZs of the other nuclear plants which have public alert / notification systems using NOAA tone alert radios.
Specify the bases for your answer.
EP-2(c)-17. State whether you contend that the area en-
. compassed by the Vogtle plume EPZ experiences more_ severe storm j watches and warnings and marine interest watches and warnings i than are experienced in'the plume EPZs of other U.S. nuclear
. plants where NOAA tone alert radios are in use. If your answer is affirmative, specify the bases for your answer.
EP-2(c)-18. State whether you contend that the l alert / notification syst'em for the public within the plume EPZ
, of a nuclear plant is required to be designed so'that it cannot
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! be deliberately disabled by the members of the public for whose I
benefit it has been installed. Specify the bases for your i answer.
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-system for the public within the: plume EPZ of a nuclear plant must be designed so that it cannot be disabled by the members-l l
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of the public for whose benefit it has been installed, identify with specificity all NRC and FEMA rules, regulations, regula-tory guidance and other authority which require or provide for such a design.
EP-2(c)-20. State whether you contend that changes must be made in the Vogtle Plan and/or.the offsite plans to meet the concern expressed in EP-2/EP-2(c) as admitted by the Board 4
(i.e., the use of NOAA tone alert radios vs. some other type of tone alert radios). If your answer is affirmative, describe
, any and all such changes, and describe ~in detail the factual and regulatory bases for your belief that such changes must be made.
EP-2(c)-21. State whether you contend that actions must be taken and changes must be made (other than those identified in the answer to Interrogatory EP-2(c)-20 above) to meet the concern expressed in EP-2/EP-2(c) as admitted by the Board (i.e., the use of NOAA tone alert radios vs. some other type of tone alert radios). If your answer is affirmative, describe any and all such changes and actions, and describe in detail the factual and regulatory bases for yo'ur belief that such ac-tions must be taken and such changes made.
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Contention EP-2/EP-2(h)
(Public Information For Transients)
EP-2(h)-1. State all bases for your allegation that there is "no assurance that transients who are unfamiliar with the area will understand the implications of a warning signal."
EP-2(h)-2. Identify with specificity each transient popu-lation (if any) within the Vogtle plume EPZ -- other than the transient population on, and along the banks of, the Savannah River -- which you cont'end might not understand the meaning of a warning signal. Specify the bases for your answer.
EP-2(h)-3. For each population identified in your answer to Interrogatory EP-2(h)-2 above, specify the postulated loca-tion of that population at the time a warning signal is sounded. Specify the bases for your answer.
EP-2(h)-4. For each location identified in your answer to Interrogatory EP-2(h)-3 above, specify the size of the peak ,
population that could be at that location at the time a warning signal is sounded. Specify the bases for your answer.
EP-2(h)-5. For each population identified in your answer to Interrogatory EP-2(h)-2 above, specify the pre-emergency public information means (e.g., billboard, etc.) you propose to advise that population of the meaning of a warning signal.
Specify the bases for your answer.
EP-2(h)-6. For each of the specific pre-emergency public information means identified in your. answer to Interrogatory EP-2(h)-5 above, list all U.S. nuclear plants which have public information= programs using that means to educate transients about the meaning of a warning' signal. Specify the bases for your answer.
EP-2(h)-7. For each of the specific pre-emergency public information means identified in your answer to Interrogatory EP-2(h)-5 above, specify precisely each individual. location where you propose to place that means (including, but not lim-ited'to, the name and street address of the establishment, where it would be located within the establishment, etc.).
Specify the bases for your answer.
EP-2(h)-8. State whether you cor.;end that changes must be made in the Vogtle Plan and/or the offsite plans to meet the concern expressed in EP-2/EP-2(h) as admitted by the Board (public information for transients). If your answer is affir-mative, describeanyandallsucE"E555'ges, and describe in de-tail the factual and regulatory bases for your belief that such changes must be made.
EP-2(h)-9. State whether you contend that actions must be taken and changes must be made (other than those identified in the answer to Interrogatory EP-2(h)-8 above) to meet the con-cern expressed in EP-2/EP-2(h) as admitted by the Board (public information for transients). If your answer is affirmative, describe any and all such changes and actions, and describe in detail the factual and regulatory bases for your belief that such actions must be taken and such changes made.
Contention EP-4 (Identification of Existing Hospitals For Treatment of Contaminated Injured Individuals)
EP-4-1. State whether you contend that "the plans do not adequately identify medical service facilities capable of treating contaminated injured individuals." If your answer is affirmative, describe all such alleged deficiencies, and specify the bases for your answer.
EP-4-2. State whether you contend that Burke County Hos-pital (Waynesboro, Georgia) lacks the capability to treat con-taminated injured individuals. If your answer is affirmative, specify the bases for your answer.
EP-4-3. State whether you contend that'Humana Hospital (Augusta, Georgia) lacks the capab.lity to treat contaminated injured individuals. If your ansser is affirmative, specify
-the bases for your answer.
EP-4-4. State whether you contend that Osk Ridge Hospital of the Methodis't Church (Oak Ridge, Tennessee) lacks the capa-bility to treat contaminated injured individuals. If your answer is affirmative, specify the bases for your answer.
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EP-4-5. State whether you contend that other local and regional medical facilities exist (other than those identified in Interrogatories EP-4-1, EP-4-2, and EP-4-3) that have the capability to treat contaminated injured individuals. If your answer is affirmative, list the name and location of each such facility, and the bases for your assertion that it has the ca-pability to treat contaminated injured individuals.
EP-4-6. State whether you contend that changes must be made in the offsite plans to meet the concern expressed in EP-4 as admitted by the Board (identification of existing hospitals for treatment of contaminated injured individuals). If your answer is affirmative, describe any and all such changes, and describe in detail the factual and regulatory bases for your belief that such changes must be made.
EP-4-7. State whether you contend that actions must be taken and changes must be made (other than those' identified in the answer to Interrogatory EP-4-5 above) to meet the concern expressed in EP-6 as admitted by the Board (identification of' existing hospitals for treatment of contaminated injured indi-viduals). If your answer is affirmative, describe any and all such changes and actions, and describe in detail the factual and regulatory bases for your belief that such actions must be taken and such changes made.
- A 3 - +- -* -- -++--e- A -A__-e Contention EP-5 (Reception Center Capacity)
EP-5-1. State whether you contend that the offsite plans fail to " assure that a'dequate emergency facilities, namely re-ception centers, will be readily available for use in the event of a radiological emergency at VEGP." If your answer is affir-mative, specify the bases for your answer.-
EP-5-2. State whether you contend that Burke County Com-prehensive High School students must be dismissed in order to accommodate evacuees. Specify the bases for your answer.
EP-5-3. Specify the number of students enrolled in Burke County Comprehensive High School, and the enrollment capacity.
Specify the bases for your answer.
EP-5-4. Specify the number of evacuees that you contend must be accommodated in the Reception Center. Specify the bases for your answer.
EP-5-5. List individually each of the common areas (e.g.,
gym, auditorium, library, study hall, cafeteria, hallways, etc.) of Burke County Comprehensive High School'and, for each individual common area, specify the-number of evacuees that j could be accommodated in that area without dismissal of the students at that school. Specify the bases for your answer.
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,, EP-5-6. Specify the number of evacuees that could be accommodated in Burke County Comprehensive High School if the students at that school are dismissed. Specify the bases for your answer.
EP-5-7. State whether you dispute that the old high school on Park Avenue and the Elementary School on Academy Ave-nue (both in Waynesboro) have been designated as backup facili-ties to Burke County Comprehensive High School, for use in an evacuation as necessary. If your answer is affirmative, specify the bases for your answer.
EP-5-8. Specify the number of evacuees that could be accommodated in the old high school on Park Avenue in Waynesboro. Specify the bases for your answer.
EP-5-9. List individually each of the common areas (e.g.,
gym, auditorium, library, cafeteria, hallways, etc.) of the El-ementary School on Academy Avenue in Waynesboro and, for each individual common area, specify the number of evacuees that could be accommodated in that area without dismissal of the students.at that school. Specify the bases for your answer.
EP-5-lO. Specify the number of evacuees that could be accommodated in the Elementary School on Academy Avenue in Waynesboro if the students at that school are dismissed.
Specify the bases for your answer.
EP-5-11. State whether you contend that changes must be made in the County Plan to meet the concern expressed in EP-5 as admitted by the Board (Reception Center capacity). If your answer is affirmative, describe any and all such changes, and describe in detail the factual and regulatory bases for your belief that such~ changes must be made.
EP-5-12. State whether you contend that actions must be taken and changes must be made (other than those identified in the answer to Interrogatory EP-5-11 above) to meet the concern expressed in EP-5 as admitted by the Board (Reception Center capacity). If your answer is affirmative, describe any and all such changes and actions, and describe in detail the factual and regulatory bases for your belief that such actions must be taken and such changes made.
Contention EP-6 (Content of Public Information Brochure, Phone Directory Ad, and Transient Warning Notices)
EP-6-1. Identify all emergency public information bro-chures (in use in the plume EPZs of other U.S. nuclear plants) which you deem adequate.
EP-6-2. State specifically each change you propose to the content of the Vogtle emergency public information bro-chure, indicating in each instance the exact language you pro-pose to add or delete and the-precise location where the lan-guage should be inserted or deleted.
EP-6-3. For each individual proposed change identified in your answer to Interrogatory EP-6-1 above, explain why the change is needed and state all bases for the proposed change.
EP-6-4. For each individual proposed change identified in your answer to Interrogatory EP-6-1 above, specify the reg-ulation or other authority which you contend necessitates the change, and explain in detail why the change is necessary to comply with the cited regulation or other authority.
EP-6-5. For each individual proposed addition to the brochure identified in your answer to Interrogatory EP-6-1 above, list all U.S. nuclear plants which have emergency public information brochures that include such language.
EP-6-6. Identify all emergency public.information phone directory ads (in use in the plume EPZs of other U.S. nuclear plants) which you deem adequate.
EP-6-7. State specifically each change you propose to the content of the Vogtle emergency public information phone directory ad, indicating in each instance the exact language you propose to add or delete and the precise location where the language should be inserted or deleted.
EP-6-8. For each individual proposed change identified in your answer to Interrogatory EP-6-7 above, explain why the change is needed and state all bases for the proposed change.
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EP-6-9. For each individual proposed change identified in your answer to Interrogatory EP-6-7 above, specify the reg-ulation or other authority.which you contend necessitates the change, and explain in detail why the change is necessary to comply with the cited regulation or other authority.
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EP-6-lO. For each individual proposed addition-to the .
phona -li. etory ad identified in your answer to Interrogatory I EP-6-7 above, list all U.S. nuclear plants which have emergency i
public information phone directory ads that include such lan-guage.
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signs, etc. (in use in the plume EPZs of other U.S. nuclear plants) which you deem adequate.
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)j EP-6-12. State specifically each change you propose to-j the content of the transient warning notices for the Vogtle EPZ, indicating in each instance the exact language you propose 4
to add or delete and the precise location where the language i
should be inserted or deleted.
EP-6-13. For each individual proposed change identified in your answer to Interrogatory EP-6-12 above, explain why.the change is needed and state all bases for the proposed change.
i EP-6-14. For each individual proposed change identified i in your answer to Interrogatory EP-6-12 above, specify the i
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'I regulation or other authority which you contend necessitates the change, and' explain in detail why the change is necessary to comply with.the cited regulation or other authority.
i .EP-6-15. For.each individual proposed addition to the i
i transient warning notices identified in your answer to Inter-L rogatory EP-6-12 above, list all U.S. nuclear plants which have
- transient warning notices that include such language.
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EP-6-16. ' State the name, present or last known address, and present or last known employer of each person with whom you i
have consulted or conferred concerning (in general) emergency public information brochures, emergency public information phone directory ads, and/or transient warning notices, posters, A
E signs, etc., and/or (specifically) the content of the brochure, i
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- phone directory ad, and transient warning notices for use in
, the Vogtle plume EPZ. Describe in detail any information pro-l vided by each such person, and specify the date and time of ,
each such consultation, conference or other contact.
EP-6-17. State whether you contend that changes must be
! made in the Vogtle Plan and/or the offsite plans to meet the l
concern expressed in EP-6 as admitted by the Board (content of public information brochure, phone directory ad, and transient
, warning notices). If your answer is affirmative, describe any 1
, and all such changes, and describe in detail the factual and j
regulatory bases for.your belief that such changes must be made.
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EP-6-18. State whether you contend that actions must be taken and changes must be made (other than those specifically identified in the answers to Interrogatories EP-6-2, EP-6-7, EP-6-12 and EP-6-17 above) to meet the concern expressed in EP-6 as admitted by the Board (content of public. information brochure, phone directory ad, and transient warning notices).
If your answer is affirmative, describe any and all such changes and actions, and describe in detail the factual and regulatory bases for your belief that such actions must be taken'and such changes made.
Contention EP-7 (Simultaneous Emergencies at Vogtle and Savannah River Plant)
EP-7-1. Identify specifically each type of " emergency situation" which you contend would " threaten the safe operation of Vogtle [and] might also endanger operations at the Savannah River Plant." Describe in detail the bases for your answer.
EP-7-2. For each individual type of " emergency situa-tion" identified in your answer to Interrogatory EP-7-1 above, state the probability of occurrence of that event at Vogtle.
Describe in detail the bases for your answer.
EP-7-3. For each individual type of " emergency situa-tion" identified in your answer to Interrogatory EP-7-1 above, state the probability of occurrence of that event at the Savan-nah River Plant. Describe in detail the bases for your answer.
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EP-7-4. For each individual type of " emergency situa- '
tion" identified in your-answer to Interrogatory EP-7-1 above, state the probability of occurrence of that event at both Vogtle and the Savannah River Plant. Describe in detail the bases for your answer. '
EP-7-5. For each individual type of " emergency situa-tion" identified in your answer to Interrogatory EP-7-1 above, state whether Vogtle is designed to withstand such an event.
Describe in detail the bases for your answer.
EP-7-6. For each individual type of " emergency situa-tion" identified in your answer to Interrogatory EP-7-1 above, state whether the Savannah River Plant is designed to withstand such an event. Describe in detail the bases for your answer.
EP-7-7. For each individual type of " emergency situa-tion" identified in your answer to Interrogatory EP-7-1 a'bove, state the probability of such an event causing a radiological accident at Vogtle, and identify all bases for your belief that such an event could cause a radiological accident at Vogtle.
EP-7-8. For each individual type of " emergency situa-i tion" identified in your answer to Interrogatory EP-7-1 above, state the probability of such an event causing a radiological accident at the Savannah River Plant, and identify all bases for your belief that such an event could cause a radiological accident at the Savannah River Plant.
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l EP-7-9. State all bases for your allegation that, in the I
event of emergencies at both.Vogtle and the Savannah River 1
Plant, " Department of Energy offices [would] be prevented from.
I providing aid to Vogtle."
i EP-7-10. Identify (inclu' ding, but not limited to, specif-1 ;
ic references to the emergency plans) each type of assistance 4
that the Vogtle Plan and/or the offsite plans indicate will be provided by the Department of Energy (" DOE") and/or the Savan-nah River Plant ("SRP") that DOE and/or SRP would be unable to j provide in the event of simultaneous emergencies at Vogtle and i
SRP. Describe in detail the bases for your answer.
i j EP-7-11. For.each individual type of assistance identi-fied in your answer to Interrogatory EP-7-10 above, explain why i the Department of Energy and/or the Savannah River Plant would j be unable to provide that assistance in the event of simulta-l l neous emergencies at Vogtle and the Savannah River Plant. De--
scribe in detail the bases for your answer. !
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{ EP-7-12. For each individual type of assistance identi-4 L
fied in your answer to Interrogatory EP-7-10 above, explain why ;
j some Department of Energy office other than the Savannah River 1 i Plant, or some other state or federal agency or other organiza-P tion, could not provide that assistance. Describe in detail t
- the bases for your answer.
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EP-7-13. State all bases for your allegation that, in the event of simultaneous emergencies at Vogtle and the Savannah River Plant, "other federal, state and local assistance re-sources would be divided between the two sites."
EP-7-14. Identify specifically each federal, state and local agency or organization whose resources allegedly "would 4
be divided betweer. the two sites" in the event of simultaneous emergencies at Vogtle and the Savannah River Plant. Describe in detail the bases for your answer.
EP-7-15. For each individual agency or organization iden-tified in your answer to Interrogatory EP-7-14 above, specify (including, but not limited to, specific references to the i
emergency plans) each type of assistance that the agency is
, relied upon to provide in the event of an emergency at Vogtle.
Describe in detail the bases for your answer.
For each individual agency or organization iden-tified in your answer to Interrogatory EP-7-14 above, specify (including, but not limited to, specific references to any ap-plicable emergency plans) each type of assistance that the agency is relied upon to provide in the event of an emergency at the Savannah River Plant. Describe in detail the bases for your answer.
EP-7-17. For each individual agency or organization iden-tified in your answer to Interrogatory EP-7-14 above, explain
t 4 specifically why that agency or organization could not provide i
the necessary assistance for-both sites in the event of simul-i taneous emergencies. Describe in detail the bases for your as- l
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- sistance. '
I I 2 r EP-7-18. For each individual agency or organization iden-i tified in your answer to Interrogatory EP-7-14 above, i j identify -- with specific reference to each type of assistance identified in your answer to Interrogatories EP-7-15 and
- EP-7-16 above -- the additional resources needed by that agency 4
to provide that type of assistance in the event of ~ simultaneous ,
l emergencies at Vogtle and the Savannah River Plant. Describe ;
i
]. in detail the bases for your answer.
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! EP-7-19. Identify the additional " impacts" of evacuation l 4 ,
I in the event of simultaneous emergencies at Vogtle and the Sa-1 j vannah River Plant that would not occur if only one of the two i j facilities had an emergency necessitating evacuation. Describe s t in detail the bases for your answer.
I f EP-7-20. For each individual " impact" identified in your f 4
{ answer to Interrogatory EP-7-19 above, explain fully all ways
! in which the emergency plans should give consideration to that j " impact." Describe in detail the bases for your answer.
I 1 EP-7-21. State all bases for your allegation that there i '
would be an " overload of medical facilities" in the event of simultaneous emergencies at Vogtle and the Savannah River f
- l. Plant. '
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EP-7-22. Identify specifically each medical facility which allegedly would be overloaded in the event of the simul-taneous emergencies at Vogtle and the Savannah River Plant that you hypothesize. Describe in detail the bases for your answer.
1 EP-7-23. For each individual medicel facility identified i
in your answer to Interrogatory EP-7-22 above, specify (includ-ing, but not limited to, specific references to the emergency plans) the type of assistance that the medical facility is relied upon to provide in the event of an emergency at Vogtle.
Describe in detail the bases for your answer.
EP-7-24. For each individual medical facility identified !
- in your answer to Interrogatory EP-7-22 above, specify (includ-
) ing, but not limited to, specific references to any applicable j emergency plans) the type of assistance that the medical i
facility is relied upon to provide in the event of an emergency l
at the Savannah River Plant. Describe in d1 tail the bases for your answer.
f EP-7-25. For each individual "emergene: situation" iden-tified in your answer to EP-7-1, identify specifically the ad-
- ditional medical facilities allegedly needed for adequate re-sponse to simultaneous emergencies at Vogtle and the Savannah River Plant. Describe in detail the bases for your answer.
EP-7-26. State all bases for your allegation that there would be an " overload" of emergency vehicles in the event of l
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simultaneous emergencies at Vogtle and the Savannah River Plant.
EP-7-27. Identify specifically each source of emergency vehicles which allegedly would be overloaded in the event of the simultaneous emergencies at Vogtle and the Savannah River i
Plant that you hypothesize. Describe in detail the bases for your answer.
EP-7-28. For each individual source of emergency vehicles identified in your answer to Interrogatory EP-7-27 above,
- specify (including, but not limited to, specific references to the emergency plans) the type and function of the vehicles that i the source is relied upon to provide in the event of an emer-gency at Vogtle. Describe in detail the bases for your answer.
f
- EP-7-29. For each individual source of emergency vehicles identified in your ant,wer to Interrogatory EP-7-27 above, i specify (including, but not limited to, specific references to i I
any applicable emergency plans) the type and function of the l vehicles that the source is relied upon to provide in the event of an emergency at the Savannah River Plant. Describe in de-tail the bases for your answer.
EP-7-30. For each individual " emergency situation" iden-
! , tified in your answer to Interrogatory EP-7-1, identify specif-1 ically the additional emergency vehicles allegedly needed for adequate re9ponse to simultaneous emergencies at Vogtle and the
Savannah River Plant. Describe in detail the bases for your answer.
EP-7-31. State whether you contend that there would be inadequate " coordination of activities of Georgia and South Carolina's agencies" in the event of simultaneous emergencies at Vogtle and the Savannah River Plant. Describe in detail the bases for your answer.
EP-7-32. Identify specifically the Georgia agencies and the South Carolina agencies whose activities allegedly would be inadequately coordinated in the event of simultaneous emergencies at Vogtle and the Savannah River Plant. Describe in detail the bases for your answer.
EP-7-33. For each individual agency identified in your answer to Interrogatory EP-7-32, specify (including, but not limited to, specific references to the emergency plans) the ac-tivities of that agency that allegedly would be inadequately coordinated in the event of simultaneous emergencies at Vogtle and the Savannah River Plant. Describe in detail the bases for your answer.
EP-7-34. For each alleged example of potential inadequate coordination of Georgia and South Carolina agencies in the event of simultaneous emergencies at Vogtle and the Savannah River Plant, explain fully and specifically all ways in which the emergency plans should be changed to assure adequate coordination. Describe in detail the bases.for your answer.
i EP-7-35. Stete whether you contend that changes must be made in the Vogtle flan and/or the offsite plans (other than those specifically identified in your answers to Interrogato-ries EP-7-20 and EP-7-34) to meet the concern expressed in EP-7 as admitted by the Board (simultaneous emergencies at-Vogtle and the Savannah River Plant). If your answer is affirmative, describe any and all such changes, and describe in detail the factual and regulatory bases for your belief that such changes must be made.
EP-7-36. State whether you contend that actions must be taken and changes must be made (other than those specifically identified in the answers to Interrogatories EP-7-18, EP-7-20, j EP-7-25, EP-7-30, EP-7-34, and EP-7-35) to meet the concern ex-4 pressed in EP-7 as admitted by the Board (simultaneous
- emergencies at Vogtle and the Savannah River Plant). If your J
answer is affirmative, describe any and all such changes and actions, and describe in detail the factual and regulatory bases for your belief that such actions must be taken and such
- char.ges cade. '
B. General Interrogatories i
G-1. State the name, present or last known address, and present or last known employer of each person who prepared, i
assisted in preparing, or provided information relating to your i
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admitted emergency planning contentions or the bases for those contentions. Describe each such person's role and any informa-tion provided.
t G-2. State the name, present or last known address, and present or last known employer of each person with whom you have communicated regarding your admitted emergency planning contentions. Identify the date and describe the substance of each such communication.
! G-3(a). State the name, present or last known address, and present or last known employer of each person known to you to have knowledge of the facts alleged, and upon which you i
relied ir. formulating allegations, in each of your contentions which are the subject of this set of interrogatories.
l (b). Identify those facts concerning which each such i
person has knowledge.
(c). State the specific allegation in each contention which you contend such facts support.
G-4(a). State the name, present or last known address, and present or last known employer of each person who provided information used in preparing your response to each interroga-tory herein.
(b). Identify all such information which was provided by each person and the specific interrogatory response in which such information is contained.
t
G-5(a). State the name, address, title, employer and ed-ucational and professional qualifications of each person you intend to call as a witness or expert witness relating to each contention which is the subject of this set of interrogatories.
(b). Identify the contention (s) regarding which each such person is expected to testify.
(c). State the subject matter as to which each such person is expected to testify.
(d). State the substance.of the facts and opinions as to which each such expert witness is expected to testify, including a summary of the grounds for each opinion.
I G-6(a). Identify all documents in your possession, cus-tody or control, including all relevant page citations, per-taining to the subject matter of, and upon which you relied or to which you referred in formulating allegations in, each con-tention which is the subject of this set of interrogatories.
(b). Identify the contention (s) to which each such document relates.
(c). State the specific allegation in each contention which you contend each document refers to or supports.
G-7(a). Identify all documents in your possession, cus-tody or control (including all relevant page citations) which you used or referred to in answering each interrogatory herein.
(b). Identify the specific interrogatory response (s) to which each such document relates.
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G-8(a). Identify any other source of information, not previously identified in response to Interrogatory G-4 or G-7, which was used or referred to in answering the interrogatories set forth herein.
(b). Identify the specific interrogatory response (s) to which each such source of information relates.
G-9(a). Identify all documents which you intend to offer as exhibits during this proceeding to support the contentions which are the subject of this set of interrogatories or which you intend'to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff and/or the Federal Emergency Management Agency (" FEMA") Staff on each contention which is the subject of this set of interrogatories.
(b). Identify the contention (s) to which each docu-ment relates and the particular page citations applicable to each contention.
G-10. Identify each document requested by " Applicants' First Set of Interrogatories and Requests for Production of Documents On Emergency Planning Contentions" for which Interve-j nors claim a privilege against procuction. Include in the l identification all addressees or recipients of the original or i
a copy of the document, a brief description of its subject mat--
ter, and the nature of the privilege claimed.
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1-III. REQUEST FOR PRODUCTION OF DOCUMENTS i
Applicants request that Intervenors respond in writing to i
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the following request for, production of documents and produce $
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or make available for inspection and copying at a designated location each of the documents requested below that is in the possession, custody, or control of Intervenors. A document shall be deemed to be within the " control" of the Intervenors if Intervenors or their attorneys have ownership, possession or custody of the document or a copy thereof, or have the right to j secure the document or copy from any person, organization, or
~
, public or private entity having physical possession thereof.
1 A. Specific Document Requests T
I Contention EP-1/EP-1(a)/EP-2(b)
(24-hour Staffing of Burke County ENN Link) '
EP-1(a)-1. All documents that refer to, relate.to, or
! contain information about any difficulty encountered by anyone f i
in contacting emergency personnel in Burke. County, including --
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! but not limited to -- the Director of the Burke County Emergen-1 cy Management Agency.
EP-1(a)-2. All documents that refer to, relate to,
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record, or contain information about an April 4, 1984 conversa-i i tion between Dr. Judy Gordon and Ms. Pam Smith.
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F EP-1(a)-3. All documents that refer to, relate to, or j contain information about the hours during which the Burke
- County EOC is staffed.
] EP-1(a)-4. All documents that refer to, relate to, or contain information about the hours during which the Burke County ENN link is staffed.
1 EP-1(a)-5. All documents that refer to, relate to, or
{ contain information about the extent to which Burke County pro-j vides for "24-hour per day manning of communications links that initiate emergency response actions" in accordance with
- NUREG-0654 Criterion F.1.a.
ir j EP-1(a)-6. All documents that refer to, relate to, or
} contain information about the adequacy of the procedure to be I followed by the Sheriff's Department to initiate an' emergency i
f response in a timely and efficient fashion.
[ Contention EP-2/EP-2(a) i
! Administrative Controls Over ENN Use i
i j EP-2(a)-1. All documents that refer to, relate to, or i
j contain information about existing administrative controls over ENN use.
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EP-2(a)-2. All documents that refer to, relate to, or contain information about any asserted.need for additional ad-1 ministrative controls over ENN use.
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EP-2(a)-3. All documents that refer.to, relate to, or contain information about any additional administrative con-trols over ENN us'e that you assert should be imposed.
EP-2(a)-4. All documents that refer to, relate to, or contain information about administrative controls over the ded-
- icated emergency telecommunications systems (such as ENN) in use by emergency response organizations within the plume EPZs i
l of other. nuclear plants in the U.S.
l Contention EP-2/EP-2(c)
(Use of NOAA Tone Alert Radios)
EP-2(c)-1. All documents that refer to, relate to, or
- contain information about the types of tone alerts that'are commercially available in the United States.
1 EP-2(c)-2. All documents that refer to, relate to, or contain information about the types of tone alerts.in use in i the plume EPZs of U.S. nuclear plants other than Vogtle.
4 EP-2(c)-3. All documents that refer to, relate to, or contain information about the advantages and/or disadvantages
, .of one type of tone alert radio over another.
EP-2(c)-4. All documents that refer to, relate to, or i
!' contain information about how often tone alert radios sound.
- EP-2(c)-5. All documents that. refer to, relate to, or
. contain information about tone alert radios being " shut off f 1
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,.m.-, .- .n, -s .,wn-,.,.,--a- - ,
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permanently by residents who become aggravated by (the] tenden-cy to go off frequently."
EP-2(c)-6. All documents that refer to,. relate to, or contain information about the alleged tendency of tone alert radios to go off "without reason."
EP-2(c)-7. All documents that refer to, relate to, or contain information about the frequency of severe storm watches and warnings and marine interest watches and warnings in the Vogtle plume EPZ and in the plume EPZs of other U.S. nuclear plants where NOAA tone alert radios are in use.
Contention EP-2/EP-2(h)
(Public Information for Transients)
EP-2(h)-1. All documents that refer to, relate to, or contain information about the alleged inability of transients to understand the implications of a warning signal.
EP-2(h)-2. All documents that refer to, relate to, or contain information about the locations of transients within the Vogtle plume EPZ.
.i EP-2(h)-3. All documents that refer to, relate to, or contain information about the number of transients within the Vogtle plume EPZ.
EP-2(h)-4. All documents that refer to, relate to, or
! contain information about the reasons for the presence of i
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- s transients within the Vogtle plume EPZ (e.g., driving through the area, visiting in the area, employed in.the area, etc.).
i' EP-2(h)-5. All documents that refer to, relate to, or i
contain information about the means of pre-emergency public i information/ education used in the plume EPZs of other nuclear plants to educate transients about the meaning of a warning signal, i.
EP-2(h)-6. All documents that refer to, relate to, or j contain information about your proposals for pre-emergency edu-
) cation of transients about the meaning of a warning signal.
i Contention EP-4 (Identification of Existing Hospitals-For t i
Treatment of Contaminated Injured Individuals) 4
- EP-4-1. All documents that refer to, relate to, describe, i
or otherwise contain information about, what facilities and I '
equipment are necessary for the treatment of contaminated in-1
- jured individuals.
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! EP-4-2. All documents that refer to, relate to, or con-i tain information about the capability 'of Burke County Hospital l
l- (Waynesboro, Georgia) to treat contaminated injured individ-i i uals.
i l EP'-4-3. All documents that refer to, relate to, or con- .
l tain information about the capability of-Humana-Hospital t (Augusta, Georgia) to treat contaminated injured individuals.
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EP-4-4. All documents that refer to, relate to, or con-tain information about the capability of Oak Ridge Hospital of the Methodist Church (Oak Ridge, Tennessee) to treat contami-nated injured individuals.
EP-4-5. All documents that refer to, relate to, or con-tain information about the capabilities of local and regional medical facilities -- other than Burke County Hospital, Humana Hosptal, and Oak Ridge Hospital of'the Methodist Church -- to treat contaminated injured individuals.
Contention EP-5 (Reception Center Capacity)
EP-5-1. All documents that. refer to, relate to, or con-tain information about the ready availability of Burke County Cemprehensive High School, the old high school on Park Avenue in Waynesboro, and the Elementary School on Academy Avenue in Waynesboro for use as reception centers in the event of an emergency.
.EP-5-2. All documents that refer to, relate to, or cen-tain information about the number of students enrolled at Burke County Comprehensive High School and/or'the enrollment capacity of that school.
EP-5-3. All documents that refer to, relate to, or con-tain information about the number of evacuees that the Recep-tion Center for Burke County must accommodate.
e
EP-5-4. All documents that refer to, relate to, or con-tain information about the number'of evacuees that could be accommodated in the common areas of Burke County Comprehensive High School without dismissal of the students at that school.
EP-5-5. All documents'that refer to, relate to, or con-tain information about the number of evacuees that could be accommodated in Burke County Comprehensive High Scho'ol if the students at that school are not dismissed.
EP-5-6. All documents that refer to,, relate to, or con-tain information about the number of evacuees that could be accommodated in the old high school on Park Avenue in Waynesboro.
EP-5-7. All documents that refer to, relate to, or con-tain information about the number of evacuees that could be.
accommodated in the common areas of the Elementary School on Academy Avenue in Waynesboro without dismissal of the students at that school.
EP-5-8. All documents that refer to, relate to, or con-tain information about the number of evacuees that could be accommodated in the common areas of the Elementary School on Academy Avenue in Waynesboro if the students at that school are dismissed.
Contention EP-6 (Content of Public Information Brochure, Phone Directory Ad, and Transient Warning Notices)
EP-6,-1. All documents supporting the changes you propose to the Vogtle emergency public information brochure in your answer to Interrogatory EP-6-1.
EP-6-2. All documents supporting the changes you propose to the-Vogtle emergency public information phone directory ad in your answer to Interrogatory EP-6-5.
EP-6-3. All documents supporting the changes you propose to the transient warning notices for the Vogtle EPZ in your answer to Interrogatory EP-6-9.
EP-6-4. All documents supporting the changes you propose to the Vogtle Plan and/or the offsite plans in your answer to Interrogatory EP-6-13.
EP-6-5. All documents supporting the actions and changes you propose in your answer to Interrogtory EP-6-14.
Contention EP-7 (Simultaneous Emergencies at Vogtle and Savannah River Plant)
EP-7-1. All documents that refer to, relate to, or con-tain information about the identificatio'n of " emergency situa-tions" which you contend would " threaten ( ) the safe operation of Vogtle [and] might also endanger operations at the Savannah River Plant."
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EP-7-2. All documents-that refer to, relate to, or con-l tain information about the probability of occurrence of "emer-gency situations" at Vogtle. 1 L
{ EP-7-3. All documents that refer to, relate to, or con-1 tain information about the probability of occurrence of "emer-gency' situations" at the Savannah. River Plant.
EP-7-4. All documents that refer to, relate to, or con-tain information about the probability of occurrence of "emer-gency situations" at both Vogtle and the Savannah River Plant.
j EP-7-5. All documents that refer to, relate to, or con-tain information about the extent to-which Vogtle is designed l
, to withstand the "eme'gency r situations" you postulate.
1, j' EP-7-6. All documents that refer to, relate to, or con-i -
j tain information about the extent to which the' Savannah River f1 Plant is designed to withstand the " emergency situations" you postulate.
EP-7-7. All documents that refer to, relate to, or con-i i tain information about the probability that the " emergency sit-
- uations" you postulate will cause a radiological accident at
- Vogtle.
EP-7-8. All documents that refer to, relate to, or con--
tain information about the probability that the " emergency sit-i
. uations" you postulate will cause a radiological accident at the Savannah River Plant.
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1 EP-7-9. All documents that refer to, relate to, or con-tain information about the probability that the " emergency sit-I uations" you postulate will cause radiological accidents at both Vogtle and the Savannah River Plant.
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EP-7-lO. All documents on which you base your belief that an " emergency situation" could cause a radiological accident at i,
Vogtle.
EP-7-11. All documents on which you base your' belief that j an " emergency situation" could cause a radiological accident at I the Savannah River Plant.
i 3 EP-7-12. All documents on which you base your allegation i
that, in the event of an emergency at both Vogtle and the Sa-l vannah River Plant, " Department of Energy offices [would] be prevented from providing aid to Vogtle."
EP-7-13. All documents that refer to, relate to, or con-tain information about the assistance that the Vogtle Plan and/or the offsite plans indicate will be provided by the De-j partment of Energy (" DOE") and/or the Savannah River Plant
! ("SRP") that DOE and/or SRP would be unable to provide in the 1
event of simultaneous emergencies at Vogtle and SRP.
EP-7-14. All documents on which you base your allegation that, in the event of simultaneous emergencies at Vogtle and the Savannah River Plant, "other feder'al, state and local 4
assistance resources would be divided between the two sites."
EP-7-15. All documents that refer to, relate to, or con-tain information about "other federal, state and local assis-tance resources" that you contend would be divided between Vogtle and the Savannah River Plant in the event of simulta-neouc emergencies.
EP-7-16. All documents that refer to, relate to, or con-tain information about additional " assistance resources" alleg-edly needed for adequate reeponse to simultaneous emergencies at Vogtle and the Savannah River Plant.
EP-7-17. All documents that refer to, relate to, or con-tain information about additional " impacts" of evacuation in the event of simultaneous emergencies at Vogtle and the Savan-nah River Plant that would not occur if only one of the two fa-cilities had an emergency necessitating evacuation.
EP-7-18. All documents o'n which you base your allegation that there would be an " overload of medical facilities" in the event of simultaneous emergencies at Vogtle and the Savannah River Plant.
EP-7-19. All documents that refer to, relate to, or con- '
tain information about additional medical facilities allegedly needed for adequate response to simultaneous emergencies at Vogtle and the Savannah River Plant.
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EP-7-20. All documents on which you base your allegation that there would be an " overload" of emergency vehicles in the event of simultaneous emergencies at Vogtle and the Savannah River Plant.
EP-7-21. All documents that refer to, relate to, or con-tain information about additional emergency vehicles allegedly needed for adequate response to simultaneous emergencies at Vogtle and the Savannah River Plant.
EP-7-22. All documents on which you base your allegation that there would be an " inadequate coordination of activities of Georgia and South Carolina's agencies" in the event of si-multaneous emergencies at Vogtle and the Savannah River Plant.
EP-7-23. All documents that refer to, relate to, or con-tain information about actions allegedly needed to assure ade-quate coordination of Georgia and South Carolina agencies in the event of simultaneous emergencies at Vogtle and the Savan-
- nah River Plant.
B. General Document Requests G-1. Applicants request that Intervenors produce or make available for inspection and copying each and every document that Intervenors used or referred to in preparing each of your contentions which are the subject of this set of interrogato-ries.
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G-2. Applicants request that Intervenors produce or make available for inspection and copying each and every document identified or described in the answer to any of the specific or general interrogatories above.
G-3. Applicants request that Intervenors produce or make available for inspection and copying each and every document that Intervenors used or referred to in preparing the response to any of the specific or. general interrogatories above.
Respectfully submitted,
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George F. Trowbridge, P.C.
Bruce W.' Churchill, P.C.
Delissa A. Ridgway David R. Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE James E. Joiner, P.C.
Charles W. Whitney.
Kevin C. Greene 1 Hugh M. Davenport
{' TROUTMAN, SANDERS, LOCKERMAN
& ASHMORE Counsel for Applicants
. Dated: September 20, 1985 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board !
J
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In the Matter of )
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GEORGIA POWER COMPANY, et al. ) Docket Nos. 50-424
) 50-425 1 (Vogtle Electric Generating Plant, ) ,.
1 Units 1 and 2) ) l l
CERTIFICATE OF SERVICE i
I hereby certify that copies of " Applicants' First Set l
Of Interrogatories and Requests For Production Of Documents l- On Emergency Planning Contentions," dated September 20, 1985, were served upon those persons on the attached Service List j by deposit in the United States mail, first class, postage *
! prepaid, this 20th day of September, 1985.
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A s ' '
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ss
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'b .,,
. Bruce W. Churchill, P.C.- ,
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Dated: September 20,-1985 t
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.t UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 1
In the Matter of )
) :
l GEORGIA POWER COMPANY,.et al. - - - -
) Docket Nos. 50-424 1
) 50-425 I
(Vogtle Electric Generating' Plant, )
Units 1 and 2) )
)
SERVICE LIST 4
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Morton B. Margulies, Chairman Douglas C. Teper -
Atomic Safety and Licensing Board 1253 Lenox Circle U.S. Nuclear Regulatory Commission Atlanta, GA 30306
- Washington, D.C. 20555 Laurie Fowler f Mr. Gustave A. Linenberger, Jr. Legal Environmental Assistance Atomic Safety and. Licensing Board Foundation U.S. Nuclear Regulatory Commission 218 Flora Avenue, N.E.
Washington, D.C. 20555 Atlanta, GA 30307 4
Dr. Oscar H. Paris Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous U.S. Nuclear Regulatory Commission Georgia Washington, D.C. 20555 175 Trinity Avenue, S.W.
Atlanta, GA 30303 Bernard M. Bordenick, Esq.
Officelof Executive Legal Director Docketing and Service Section U.S. . Nuclear Regulatory Commission Office of the Secretary.
Washington, D.C. 20555 U.S. Nuclear Regulatory Commission l Atomic Safety and Licensing Washington, D.C. 20555 l Board Panel U S. Nuclear Regulatory Commission Bradley Jones, Esquire Washington, D.C. '20555 Regional Counsel U.S. Nuclear Regulatory l' Atomic Safety and Licensing. Commission Appeal Board Panel Suite 3100 1
U.S. Nuclear Regulatory Commission -101 Marietta Street Washington, D.C. 20555 Atlanta, GA 30303 i
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