ML20133J672

First Set of Interrogatories & Requests to Produce Re Emergency Planning.Certificate of Svc Encl.Related Correspondence

ML20133J672
Person / Time
Site:	Vogtle
Issue date:	10/15/1985
From:	Johnson T CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY
To:	GEORGIA POWER CO.
References
CON-#485-842 OL, NUDOCS 8510210029
Download: ML20133J672 (6)

Text

. _ . . . - __ --

h2-I t,r,00pnE9W m  ;

UNITED STATES OF AMERICA OgE4E0 ~

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENS:NG BOARD 85 0CT 18 A9 N4 l In the Matter of )  !

I

) grFKT(# SELL M '

GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and l50'-42504 Sb . l

BRANCH

) ,

1 (Vogtle Electric Generating Plant, )

Units 1 and 2) ) '

i i  :

{

4 f

INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS TO PRODUCE

, i RELATING TO EMERGENCY PLANNING i Intervenors Campaign for a 1rosperous Georgia and Georgians Against Nuclear f Energy (hereinafter "Intervenors") hereby serve their First Set of Interrogatories an Requests to Produce Relating to Emergency Planning upon the Applicants in the l i

above-styled proceeding. j v

Each interrogatory shall be answered fully in writing, under oath or }

l affirmation, and include all pertinent informatin known to the Applicants including  !

, I l

its officers, employees, agents, advisors or counsel. Each request to produce i j applies to pertinent documetns which are in the possession, custody or control of,  !

i or are otherwise available to, the Applicants, including its officers, employees, e agents, advisors or counsel. In answering each interrogatory and responding to each t i request, please recite the interrogatory or request preceding each answer or  ;

i  !

response. Also, identify the person providing each answer or response, including [

but not limited to his or her name, address, employer, current position and a

! t

! statement of professional qualifications. [

These interrogatories and requests shall be continuing in nature. Thus,

whenever any information is obtained which renders any previous response incorrect or incomplete or indicates that a response was incorrect or incomplete when made, j l

l the Applicants are hereby requested to supplement their previous response.  !

I 8510210029 851015 l; PDR ADOCK 05000424 G PDR l T)SO6l

The term " document" shall include any writings, drawings, graphs, charts, photographs and other data compilations from which information can be obtained.

Intervenors request that Applicants make available all documents subject to the requests set forth below.

Requests for Documents ,

Intervenors request that Applicants make available to Intervenors any and all documents of-whatsoever description identified in response to Intervenors interrogatories below, including but not limited to:

(1) any written record of any oral communication between or among Applicants, their advisors, consultants, contractors, agents, attorneys, and/or any other persons, including but not limited to the NRC staff, the Intervenors and their advisors, consultants, contractors, agents, attorneys and/or any other persons; and (2) any documents, correspondence, letters, memoranda, diagrams, repors, charts, photographs, or any other writing of whatsoever description, including but not limited to work papers, prior drafts and notes of meetings.

If Applicants maintain that some documents should not be made available, Applicants shall specify the documents and explain why sucn are not being made available. This requirement extends to any such document, described above, in the possession of or available to the Applicants, their advisors, consultants, agents or attorneys.

Interrogatories Intervenors request that Applicants answer separately and fully in writing, under oath or affirmation, by persons having knowledge of the information requested, the following interrogatories.

1. Identify (by name, business address, occupation and employer) a) all individuals 2

r who have knowledge or information responsive to each interrogatory and designate the interrogatory or the part thereof which that individual answered; and b) each person you expect to call as an expert witness in this proceeding sa well as a description of the subject matter on which that person is expected to testify and teh substance of that testimony, the witness's educational and professional background, and the i identity of any previous proceedings in which that person has testified.

2. How will the Applicants assure that me-bars of the public will take an order to evacuate seriously?

3. How will the Applicants deal with role conflict for emergency response personnel (e.g., conflicts between their roles as emerg0ncy response personnel and as family members)?

4. What impacts will occur if only 20% of emergency respcnse personnel show up during an emergency?

5. What measures have the Applicants taken (or will the Applicants take) to identify role conflicts for individuals who might be involved in emergency response?

6. Will backup personnel be available for the various emergency response positions?

Will the backup _ personnel, if any, have backup personnel?

7. How will the Applicants verify that members of the public have read and understand the plan?

8. What happens to the plan if a significant number of people do not follow the official protection action advisories?

9. What effects (such as shadow phenomenon) would result from over-response of the public?

10. How will the Applicants deal with persons who delay evacuating?

11. Will the Applicants have the authority to force persons to leave?

12. Will the Applicants have police powers?

13. What if people take their pets rather than leaving th m?

14. What if people take their firearms with them during an evacuation? What l 3

,+ -- + - , - - . , - . , - - ~ . - .- y , m,- , - , -

measures have Applicants taken or will Applicants take to deal with this likelihood?

15. What measures will be taken to prevent evacuees from returning (for pets or other reasons)?

16. What measures will be taken to prevent looting during an evacuation? i

17. How will Applicants deal with emergency response if another public disaster occurs simultaneously with the plant accident?

18. How will Applicants deal with members of the press during an emergency?

19. How will Applicants deal with " tourists" (people who want to "see" a disaster) during an emergency?

I

20. How will Applicants assure that gear to be used by emergency response personnel is adequate and well maintained? What will be the frequency of checking the equipment?

21. What measures will be taken to assure that all personnel (primary and secondary) are properly trained to use the equipment?

22. Will the emergency personnel have beepers at all times to assure that they are available should an emergency occur?

23. Will emergency personnel have access to dedicated lines from their homes for emergency use?

24. What measures will Applicants take to assure that the Burke County EOC maintains 24-hour per day staffing?

25. What procedures will be followed by the sheriff's department in the event of an i emergency at Plant Vogtle?'

26. Who will have access to the ENN?

27. How will reliability of the ENN be assured? How will such reliability be I

maintained?

28. How will access to the ENN be restricted?

29. Since the ENN is "hard-wired," what measures will asure adequate notification 4

if the ENN fails (due to line failure or any other reason)?

30. How will Applicants assure that tone alert radios used to notify area residents are not shut off by those residents?

31. How will Applicants assure that tone alert radios used to notify area residents of emergencies are functioning reliably and are properly maintained?

32. Please provide copies of any drafts and final signs, decals, notices, brochures, advertisements or other information to be disseminated to members of the public (transient or other).

33. How and where will such notification be provided?

34. What facilities in South Carolina will be used to treat injured and contaminated victims of an accident at Plant Vogtle?

35. What facilities in Georgia will be used to treat the injured and contaminated victims of an accident at Plant Vogtle?

36. How will Applicants assure the availability (including adequate provisions) of adequate evacuation centers in the event of an emergency at Plant Vogtie?

37. When do Applicants p1'an to know and make available the contents of printed brochures, advertisements, warning notices and other information for the public?

38. How would communication, coordination and cooperation among South Carolina and Georgia resources function during an emergency at Plant Vogtie?

39. How will the Department of Energy deal with simultaneous emergencies at Plant Vogtle and the Savannah River Plant?

Respectfully submitted this the 15th day of October,1985, c=72 - - 7 ;,

% &ns

• Tim Johnson for Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy 5

tALAno Coungy UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3,m y-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) *SS CP t o A9 44

)

GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425 (Vogtle Electric Generating Plant, ) 3 MCI l Units 1 and 2) ) l CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Notice of Change of Address" and "Intervenors' First Set of Interrogatories and Requests to Produce Relating to Emergency Planning" were served by hand or by deposit with the U. S. Postal Service in the City of Atlanta with first class postage attached to be delivered to the Secretary of the Commission, the members of the Licensing Board and all others listed below, this 15th day of October,1985.

Tim JoRfison SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Docketing and Service Section Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Gustave A. Linenberger Bernard M. Bordenick, esq.

1 Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Comission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel Ruble A. Thomas U.S. Nuclear Regulatory Comission Southern Company Services, Inc.

Washington, D.C. 20555 P. O. Box 2625 Birmingham, Alabama 35202 Bruce Churchill, esq.

Shaw, Pittman, Potts & Trowbridge Bradley Jones, esq.

1800 M Street, N.W. Regional Counsel, U.S. NRC Washington, D.C. 20036 101 Marietta Street, Ste. 3100 Atlanta, Georgia 30303 James Joiner, esq.

Troutman, Sanders, Potts & Trowbridge The Candler Building Atlanta, Georgi 30303

. .