ML20133F544

Emergency Planning Interrogatories.Certificate of Svc Encl. Related Correspondence

ML20133F544
Person / Time
Site:	Vogtle
Issue date:	10/07/1985
From:	Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	JOINT INTERVENORS - VOGTLE
References
CON-#485-720 OL, NUDOCS 8510110087
Download: ML20133F544 (13)

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DOCKETED October 7, 1985 usMc

'85 00T -9 P2 57 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g>g,c : 3.g .,

uw. , y n, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

GEORGIA POWER COMPANY ) Docket Nos. 50-424 et al. ) 50-425

) (0L)

(Vogtle Electric Generating Plant, )

Units 1 and 2) )

NRC STAFF'S EMEPGENCY PLANNING INTERROGATORIES TO JOINT INTERVFNORS CAMPAIGN FOR A PROSPEROUS GEORGIA (CPG) AND GEORGIANS AGAINST NUCLEAR ENERGY (GANE)

Pursuant to 10 CFR @ 2.740, 2.74db and 2.741, the NRC Staff propounds the following Interrogatories to Joint Intervenors CPG and GANE (hereafter " Joint Intervenors").

INSTRUCTIONS

1. Each Interrogatory set forth below shall be answered separately and fully in writing under oath or affirmation, and shall include all pertinent information available to Joint Intervenors, their respective officers, directors, members, employees, advisors, or consultants.

2. State the name, address, occupation and employer of the person or persons answering each Interrogatory and identify the portions of each Interrogatory such person has answered.

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3. As used herein the tenn " Documents" shall be construed to mean all writings and/or records of every type in the possession, control or custody of Joint Intervenors their respective directors, officers, attorneys, ' employees or agents, including, but not limited to, memoranda, correspondence, reports, surveys, evaluations, charts, books, minutes, notes, agenda, diaries, logs, transcripts, microfilm, accounting statements, telephone and telegraphic communications, speeches, and all other records, written, electrical, mechanical or otherwise. " Documents" shall also be construed to mean copies of documents even though the originals thereof are not in the possession, custody or control of Joint Intervenors, their respective members or i consultants.

4. For all references to documents requested in these Interrogatories, identify such documents by author, title, date of publication and publisher if the reference is published; and if it is

- not published, identify the document by the author, title, and the date

? it was written.

5. As to any Interrogatory, section or subsection of the following Interrogatories that Joint Intervenors refuse to answer or to which Joint Intervenors object, for any reason, separately state the grounds for any such refusal. Where a complete answer to a particular Interrogatory, section or subsection of said Interrogatory is not possible, such Interrogatory, section or subsection of said Interrogatory should be answered to the extent possible and a statement made indicating the reason or reasons for the partial or incomplete answer.-

6. Identify by author, title and date any documents used as the basis for the answer to each Interrogatory.

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7. If the answer to any Interrogatory is based upon a calculation., describe (a) the calculation, (b) identify any documents setting forth such calculation, (c) identify the person who perfonned each calculation, (d) when it was performed, (e) each parameter used in such calculation, each valve assigned to the parameters, and the source of your data, (f) the results of each calculation, and (g) how each calculation provides a basis for the answers.

8. If-the answer to any Interrogatory is based upon conversa-tions, consultations, correspondence or any other type of communica-tions with one or more individuals, (a) identify each such individual by name and address, (b) state the educational and professional back-ground of each such individual, (c) describe the information received from such individual and its relation to your direct answer, and (d) identify each writing or record related to each such conversation, consultation, correspondence or other communications with such individual.

9. As used in these interrogatories, the word you or your shall mean Joint Intervenors or any agent or employee of Joint Intervenors.

10. As used in these interrogatories, the phrase NRC Staff or Staff includes the Federal Emergency Management Agency (FEMA).

11. The contentions and subcontentions referred to in these Interrogatories were admitted in the Atomic Safety and Licensing Board's "MemorandumandOrder(RulingonJointIntervenor'ProposedContentions on Emergency Planning)" which is dated August 12, 1985.

. INTERR0GATORIES INTERR0GATORY 1 Identify all documentary or other material that you intend to rely on during this proceeding to support Joint Intervenors' contentions and subcontentions EP-1 and EP-1(a), EP-2 and EP-2(a), (b), (c), and (h),

EP-4, EP-5, EP-6, EP-7, or which you may offer as exhibits on these contentions and subcontentions or refer to in preparation for or during your cross-examination of NRC Staff or Applicant witnesses. Provide, if available, copies of any documents you intend to rely on.

INTERROGATORY 2 a) Identify each person you rely on to substantiate in whole or in part the Joint Intervenors' contentions and subcontentions set out in Interrogatory 1 above, b) Provide the address and educational and professional qualifications of all persons named in your response to 2a above.

c) Identify which of the above persons or any other persons you may call as witnesses at a hearing on the contentions set out in Interrogatory 1 above, and identify which portions of each contention or l subcontention set out in Interrogatory 1 above that each such person will l support.

INTERROGATORY 3 a) With respect to Contention EP-1 and subcontention EP-1(a), do you assert that Burke County, Georgia, does not have a full time Emergency Management Agency Director?

b) If your answer to Interrogatory 3(a) is in the affirmative, please state the basis for this assertion.

c) Would the matters delineated by the Board order of August 12, 1985, for consideration under subcontention EP-1(a) be resolved if the Burke Coun y, Georgia emergency response plan were amended to specify (1) the responsibilities of the Burke County Sheriff's Department in the event that the County director of emergency planning or the Burke County Operating Center (E0C) could not be contacted via the Emergency Notification Net (ENN) and (2) the manner in which those responsibilities were to be exercised?

d) If your answer to the above question is in the negative, specify each other matter that must be included in the Burke County emergency plan to resolve contention EP-1(a), and the reason why it is necessary that each of these matters be included in the plan.

e) In the event that Applicants can demonstrate either that the E0C is staffed continuously or, in the alternative, that the procedures to be followed by the Burke County Sheriff's Department can initiate an emergency response in a timely and efficient fashion, would the matters delineated by the Board for consideration under subcontention EP-1(a) be resolved?

f) Set out the specific provisions which intervenors maintain must be contained in the Vogtle or Burke County emergency response plan to obviate the matters delineated by the Board Order of August 12, 1985, for consideration under subcontention EP-1(a), and why each of those provisions is necessary.

g) Set out the specific provisions of law and regulation which intervenors maintain the Vogtle or Burke County emergency response plan does not meet in regard to the matters the Board delineated for

consideration under subcontention EP-1(a), the specific manner in which the plan fails to meet those provisions of law and regulation, and why each of'those provisions is necessary.

h) Set out the specific provisions which intervenors maintain must be contained in the Vogtle emergency response plan in regard to the matters the Board delineated for consideration under subcontention 1

EP-1(a) to have the plan meet the requirements of law and regulation, and why each of those provisions is necessary.

INTERROGATORY 4 Subcontention EP-2(a) as admitted by the Licensing Board raises the

! issue of whether there are adequate administrative controls in place over the use of the ENN so as to restrict the use of dedicated lines to the transmission of official and necessary messages in the event of a radiological emergency at Vogtle, a) Set out each respect, if any, in which intervenors maintain the present administrative controls of the ENN set out in the Vogtle emergency response plan are inadequate, and why they are inadequate.

b) Set out the specific provisions of law and regulation intervenors maintain the Vogtle emergency response plan does not meet in regard to the matters the Board delineated for consideration under subcontention EP-2(a), and the manner in which the plan fails to meet those provisions of law and regulation, c) Set out.the specific provisions which intervenors maintain must be contained in the Vogtle emergency response plan to obviate each of the

i matters delineated by the Board for consideration under subcontention EP-2(a), and why each of these provisions is necessary, d)' et out the specific provisions which intervenors maintain must be contained in the Vogtle emergency response plan in regard to the matters delineated by the Board for consideration under subcontention EP-2(a) to have the plan meet the requirements of law and regulation, and why each of these provision is necessary.

1 INTERROGATORY 5 Subcontention EP-2(c) challenges the proposed use of NOAA tone alert radio receivers installed in each household in the EPZ as a means of notification.

a) Set out each respect in which intervenors maintain the NOAA tone alert radio receiver system is inadequate, and the bases for each such conclusion.

b) Set out each respect in which intervenors maintain the Vogtle emergency response plan is inadequate in regard to matters the Board delineated for consideration under subcontention EP-2(c), and the bases for such conclusions.

c) Set out each provision of law and regulation which intervenors maintain the Vogtle emergency response plan does not meet in regard to the matters the Board delineated for consideration under subcontention

't EP-2(c), and the specific manner in which the plan fails to meet those provisions of law and regulation.

d) Separately set out and describe all features that intervenors maintain a tone alert radio system or other alerting system must have to:

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(i) be adequate; (ii) obviate all matters delineated by the Board for considerati.on under subcontention EP-2(a); (iii) meet the requirements of law and regulation.

INTERROGATORY 6 SubcontentionEP-2(h)concernsnotificationoftransientswithinthe EPZ.

a) Set out each respect in which intervenors maintain the Vogtle emergency response plan is inadequate in regard to the notification of transients in the EPZ, and the bases for each such conclusion.

b) Set out each respect in which intervenors maintain the Vogtle emergency response plan is inadequate in regard to matters alleged in the

! matters the Board has set for consideration under subcontention EP-2(h),

and the bases for each such conclusion.

c) Set out each provision of law or regulation intervenors

maintain the Vogtle emergency response plan or the Burke County plan does not meet in regard to matters the Board has delineated for consideration i under subcontention EP-2(h), and the specific manner in which either of those plans fails to meet those provisions of law or regulation, d) Separately set out and describe each method of notification of transients which intervenors maintain must be set out in plans to

(i)be adequate; (ii) obviate the matters the Board has delineated for a

consideration under subcontention EP-2(h); (iii) meet the requirements of law and regulation.

e) List each other sign or other notification of transients that must be made to allow the Vogtle emergency response plan to be adequate.

- l INTERROGATORY 7 Contention EP-4 deals with the identification in the Vogtle emergency response plan of medical service facilities capable of treating radiologically contaminated injured individuals.

a) Set out each respect in which intervenors maintain the Vogtle emergency response plan is inadequate in regard to the identification of medical facilities capable of treating radiologically contaminated injured individuals, and the bases for each such conclusion, b) Set out each respect in which the Vogtle emergency response I plan is inadequate in regard to the matters the Board delineated for J

consideration under contention EP-4, and the bases for each such i' conclusion, c) Set out each provision of law or regulation which intervenors maintain the Vogtle emergency plan does not meet in regard to matters the Board delineated for consideration under contention EP-4, and the specific manner in which the plan fails to meet those provision of law and regulation.

d) Separately set out and describe all matters dealing with the identification of medical service facilities capable of treating radiologically contaminated injiired individuals which intervenors 4

maintain the Vogtle emergency response plan must contain to: (i)be adequate; (ii) obviate all matters the Board delineated for consideration under contention EP-4; (iii) meet the requirements of law and regulation.

, INTERR0GATORY 8 Contention EP-5 deals with the availability of reception centers for evacuees in the event of a radiological emergency at Vogtle.

a) Set out each respect in which intervenors maintain that either the Vogtle emergency response plan or the Burke County plan is inadequate in regard to their treatment of reception centers or actions to assure the availability of those centers, and the bases for each such conclusion.

b) Set out each respect in which intervenors maintain the plans are inadequate in regard to matters the Board has delineated for consideration under contention EP-5, and the bases for each such conclusion.

c) Set out the specific details or provisions that intervenors maintain must be included in either of the plans to obviate the matters the Board l'as delineated for consideration under contention EP-5, and the i

bases for intervenors' conclusion that each of those details or provisions is necessary, d) Set out each provision of law or regulation intervenors maintain either of the plans do not meet in regard to the matters the Board delineated for consideration under contention EP-5, and the specific manner in which the plan fails to meet those provisions of law i

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or regulation, e) Separately set out and describe the matters that either of the plans must contain in regard to the availability of reception centers for evacuees for the plans to: (i) be adequate; (ii) obviate the matter the Board delineated for consideration under contention EP-5; (iii) meet the requirements of law and regulation.

. INTERROGATORY 9 Contention 7 deals with those portions of the EPZ in South Carolina.

a) escribe the area in South Carolina that should be included within the Vogtle plume EPZ.

b) In the event Applicants or the State of South Carolina amended the emergency response plan for Vogtle to show the area intervenors believe should be included within the plume EPZ in South Carolina, would such an amendment resolve the matters delineated by the Board for hearing under contention 7.

c) If the answer to (b) is in the negative (1) set out intervenors' reasons in full, and (ii) specifically detail all other information which needs to be set out in the Vogtle emergency response plan in regard to those portions of the EPZ in South Carolina.

Respectfully submitted,

/d Bernard M. Bordenick Counsel for NRC Staff Dated et Bethesda, Maryland ,

this 7/T day of October,1985 1

i i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

GEORGIA POWER COMPANY, ) Docket Nos. 50-424 et al.

) 50-425 (0L)

(Vogtle Electric Generating Plant, Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S EMERGENCY PLANNING INTERROGA-TORIES TO JOINT INTERVEN0RS CAMPAIGN FOR A PROSPEROUS GEORGIA (CPG) AND GEORGIANS AGAINST NUCLEAR ENERGY (GANE) in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 7th day of October,1985.

Morton B. Margulies, Esq., Chairman

• Mr. Gustave A. Linenberger, Jr.*

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.-C. 20555 Dr. Oscar H. Paris

• Bradley Jones, Esq.

Administrative Judge Region 1 Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington, D.C. 20555 Atlanta, GA 30303 Bruce W. Churchill, Esq. Douglas C. Teper David R. Lewis, Esq. 1253 Lenox Circle Shaw, Pittman, Potts & Trowbridge Atlanta, GA 30306 1800 M Street, N.W.

Washington, D.C. 20036,

- 2-Atomic Safety and Licensing Laurie Fowler, Esq.

Board Panel

• 218 Flora Ave. NE U.S. Nuclear Regulatory Commission Atlanta, GA 30307 Washington, D.C. 20555 Docketing and Service Section* Atomic Safety and Licensing Office of the Secretary Appeal Board Panel

• U.S. Nuclear Regulartory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 James E. Joiner, Esq. Ruble A. Thomas Troutman, Sanders, Lockerman, Southern Company Services, Inc. ,

& Ashmore P.O. Box 2625 i

127 Peachtree Street, N.E. Birmingham, AL 35202 4

Candler Building, Suite 1400 Atlanta, GA 30043 Tim Johnson '

Executive Director Campaign for a Prosperous Georgia 175 Trinity Avenue, S.W.

Atlanta, GA 30303

/

Bernard M. Bordenick Counsel for NRC Staff i

I I

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