ML20133Q305
| ML20133Q305 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/28/1985 |
| From: | Johnson T CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#485-990 OL, NUDOCS 8511010483 | |
| Download: ML20133Q305 (13) | |
Text
u >: m-
. g
, , s _.m n t e n ,
g tp -; #
0y' UNITED STATES OF AMERICA f OCT3~l?"" " h I l
NUCLEAR REGULATORY COMMISSION J ~ "M a
ll s
1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
\ s.
In the Matter of )
)
GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425 dv
)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
INTERVEN0RS' RESPONSE TO APPLICANTS' FIRST SET OF INTERR0GATORIES AND REQUESTS TO PRODUCE CONCERNING EMERGENCY RESPONSE CONTENTIONS The following is Intervenors' response to the Applicants' "First Set of Interrogatories and Requests for Production of Documents on Emergency Planning Contentions" in the above-docketed proceeding.
A. Specific interrogatories 1(a)-1. Please see the earlier filings cited by Applicants.
1(a )-2. The substance of this conversation included discussion of training of personnel, evacuation procedures and related matters described in the documents previously submitted by Intervenors. No other individuals were present during any part of the conversation. It took place during the early af ternoon. During the discussion, a tornado alert was in effect, so the radio was on throughout to monitor j
that situation.
1 i
1(a )-3. This depends on Applicants' definition of " full-time." Is full-time forty l hours per week, or is it twenty-four hours per day? Intervenors have not 1
independently deterinined if this is a full-time position at this point in time.
l 1(a)-4. Obviously, H the Director is at the emergency number 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days per week, then the difficulties are considerably diminished.
l 1(a )-5. The burden is upon the Applicants to guarantee that the Burke County ENN 1
link is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week.
1 8511010483 851028 PDR ADOCK 05000424 G PDR . ,
- b. b' 3
k 1(a)-6. Please see response to 1(a)-5 above.
1(a)-7. Please see response to 1(a) 6 above.
1(a)-8. Please see response to 1(a)-6 above.
1(a)-9. Sheriff's department personnel could not initiate an emergency response in a timely and efficient fashion. These personnel face role conflict: many will feel i a greater obligation to the welfare and safety of their families and will leave assigned tasks to care for their families. Many will not return to duty until the crisis subsides.
1(a)-10. Please see response to 1(a)-9, above.
1(a)-11. Changes sufficient to assure that timely emergency response is initiated regardless of role conflict must be made.
1(a )- 12. Yes. Changes sufficient to assure that timely emergency response is 4
initiated must be made.
1(a)-13. Please see the response to 1(a)-12, above.
I 2(a)-1. Yes. Intervenors have stated that Applicants have not thus far provided adequate administrative controls over the ENN system. The bases for this is the lack of such controls in Applicants' written plan.
2(a )-2. Intervenors' contention that administrative controls are lacking is based on Applicants' failure to provide such controls. It is Applicants' duty to provide such controls (and describe them in writing) for each ENN terminal.
2(a )-3. Applicants have not provided Intervenors with the existing administrative controls over the use of the terminals, so how can Intervenors provide them to Applicants?
- 2(a)-4. Please see 2(a)-3, above.
l 2(a )-5. Intervenors' contention relates to the inadequate plans at Plant Vogtle, not to the plans in place at other facilities in the United States.
2(a)-6. Yes. Adequate controls must be provided to assure that the ENN system is 2
. - - _ ~ . , __ _
fully available and functioning to assure appropriate emergency response.
2(a)-7. This is essentially the same question as 2(a)-6 above and has the same response. )
2(c)-1. Intervenors object to the use of NOAA tone alert radios for the reasons previously cited. It is the duty of the Applicants to provide adequate measures to l alert the public to emergencies, and the NOAA tone alert radios are inadequate for the reasons cited by Intervenors. To ask Intervenors to " state all types to which you object" is overly broad and not relevant. Intervenors, the NRC and the Board will review Applicants' proposals for alerting the public and will respond appropriately. The burden is on the Applicants to select those measures which are adequate, not on the Intervenors to name (in advance) all measures which are inadequate.
2(c)-2. Please see response to 2(c)-1, above.
i 2(c)-3. Please see response to 2(c)-2, above. Also, it is not the duty of Intervenors to " list all other U.S. nuclear plants" which have any type of alert system; it is the duty of the Applicants to identify and institute an adequate alert
- system.
2(c)-4. Intervenors object to this question as being overly broad, irrelevant and
]
not susceptible to a reasonable response. It is not the duty of the Intervenors to i
! " Identify specifically each type of tone alert radio which is commercially available in the United States."
2(c)-5. See response to 2(c)-4, above.
2(c)-6. Intervenors object to this question as being overly broad, irrelevant and not susceptible to a reasonable response. It is not the duty of the Intervenors tc 1
" 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."
l 2(c)-7. See response to 2(c)-6, above.
- 2(c)-8. See response to 2(c)-7, above.
i l 3 I
!l
k .
2(c)-9. See response to 2(c)-6, above.
2(c)-10. This is based on experience with tone alert radios at other nuclear facilities and in other applications.
{
2(c)-11. Yes. Please see response to 2(c)-10, above.
2(c)-12. Intervenors have not stated that NOAA tone alert radios are more likely
) than others to sound at times other than when the/ are intentionally sounded (testing, storm watches and warnings, etc.), althot.gh these circumstances frequently occur, particularly in an area with weather as often severe as the area around Plant Vogtle.
2(c)-13. Intervenors do not currently have this data accessible; Applicants should 1
l have this data.
2(c)- 14. Intervenors object to this question as being overly broad, irrelevant and i
l not susceptible to a reasonable response. It is not the duty of the Intervenors to
- analyze tone alert radios not in use by the Applicants. Intervenors' objection is to Applicants' tone alert radios.
2(c)-15. It is not the Intervenors' duty to review if "it is acceptable to use NOAA J
j tone alert radios in other plume EPZs around the country," as requested by the c Applicants. Intervenors have done no such analysis for other facilities.
2(c)-16. Intervenors object to this question as being overly broad, irrelevant and f not susceptible to a reasonable response. It is not the duty of the Intervenors to analyze " conditions in the plume EPZs of the other nuclear plants" as requested by
} Applicants.
2(c)-17. Intervenors object to this question as being overly broad, irrelevant and not susceptible to a reasonable response. It is not the duty of the Intervenors to I review "the plume EPZs of other U.S. nuclear plants" as requested by Applicants.
2(c)-18. Intervenors' contention is not whether the alert / notification system can be deliberately disabled, but whether it is likely to be and whether adequate -
j-
! 4
notification will be obtained during an emergency.
2(c)-19. See response to 2(c)-18, above.
2(c)-20. Yes. Changes must be made sufficient to assure that adequate notification of the public is made to assure appropriate response in the event of an emergency at Plant Vogtle.
2(c)-21. Yes. This is essentially the same question as that asked in 2(c)-20 above and has the same response.
2(h)-1. Applicants have made no adequate provision for assuring that transients understand the implications of a warning signal which, as far as the transients are concerned, might signify a test, a weather alert, a malfunction in the system or something else irrelevant to the presence of a nuclear facility.
2(h)-2. It is the duty of the Applicants, not the Intervenors, to identify transient populations and provide assurances that they will be adequately notified of an emergency. Applicants have not made such assurance, as Intervenors have previously pointed out. See Intervenors' basis for their proposed emergency response contention.
2(h)-3. See 2(h)-2, above.
2(h)-4. See 2(h)-3, above.
2(h)-5. It is the duty of the Applicants to provide adequate measures for notifying and informing all affected populations, including transients. Measures which might be used include (but are not limited to) billboards, notification by all telephones, posters, warning signs posted (on the river, in restaurants, in gasoline stations and in other areas), frequent radio and television announcements, literature to all hotel / motel visitors and other measures.
2(h)-6. Intervenors object to this question as being overly broad, irrelevant and not susceptible to a reasonable response. It is not the duty of the Intervenors to
" list all U.S. nuclear plants which have public information programs" using particular notification systems, as requested by Applicants.
5
I l
l 2(h)-7. Please see response to 2(h)-5, above.
2(h)-8. Yes, changes must be made to assure adequate notification of all populations in the event of an emergency at Plant Vogtle.
2(h)-9. This is essentially the same as 2(h)-8 above and has the same response.
4- 1. Yes, Applicants fail to identify adequately identify medical facilities capable of treating contaminated individuals. Please see Intervenors proposed contention and the Board's order describing such deficiencies.
I 4-2. Yes. Burke County Hospital does not have adequate facilities to treat contaminated individuals in the event of a major accident.
4-3. Yes. Humana Hospital lacks the capability to treat contaminated individuals in the event of a major accident.
4-4. Yes. Oak Ridge Hospital lacks the capability to treat contaminated individuals in the event of a major accident.
4-5. It is the obligation of the Applicants to describe all medical facilities, not the Intervenors.
4-6. Yes, sufficient changes must be made to assure identification of facilities
! for treatment of contaminated individuals.
4-7. This is essentially the same question as 4-6 above and has the same response.
t 5- 1. Yes. See the basis for Intervenors' proposed contention and the Licensing Board's order thereon.
5-2. Yes. Applicants must describe with specificity how proposed facilities will accomodate evacuees, including availability of space in the reception center. Given I
that this is the only evacuation center for the county, this space could easily be I overwnelmed if most sought refuge therein.
5-3. It is the duty of the Applicants to provide the requested information, not the j
Intervenors. Without such information, Applicants' plan is inadequate.
5-4. It is the duty of the Applicants to provide this information, without which t
1
. . - ~ _ , . . . ,_- . . _ - , , - - - - . . . . . _ . . . - , . . . , _ . - . _ _ . , , . - . , , _ - - - - - . _ _ - - . , _ - - - - - _
4 n
Applicants' plan is obviously inadequate.
5-5. It is the Applicants' duty to provide this information in order to have an adequate plan.
5-6. It is the Applicants' duty to provide this information to have an adequate plan.
5-7. Please see Intervenors' proposed contention.
5-8. It is the Applicants' duty to provide this information in its plan.
i' 5-9. This information should be provided by the Applicants, not the Intervenors.
5-10. This information should be provided by the Applicants, not the Intervenors.
4 5-11. Yes, sufficient changes must be made to assure an adequate reception center i
in the event of an emergency.
5-12. Yes; this is essentially the same as 5-11 above and has the same response.
6- 1. Intervenors object to this question as being overly broad, irrelevant and not susceptible to a reasonable response. It is not the duty of the Intervenors to
" identify all emergency public information brochures in use in the plume EPZs of other U.S. nuclear plants" as requested by Applicants.
6-2. Intervenors have not yet prepared their testimony for hearings on this contention and have not as yet formulated proposed language for a brochure.
6-3. Intervenors assume Applicants mean 6-2, not 6-1; please see response to 6-2, above.
! 6-4. Intervenors assume Applicants mean 6-2, not 6-1; please see response to 6-2 above.
l t
6-5. Intervenors assume Applicants mean 6-2; see response to 6-2 above.
l 6-6. Intervenors object to this question as being overly broad, irrelevant and not susceptible to a reasonable response. It is not the duty of the Intervenors to l
" Identify all emergency public information phone directory ads in use in the plume EPZs of other U.S. nuclear plants" as requested by Applicants.
6-7. It is absolutely essential that all advertisements and other information 7
-.._._.-m __ .- _.,. _ _ . - ___._.___-.,,._7m,__ , . _ _ . - . , _ _ _ ,_,,, _, , . , _ . . , , , , , . , , ._.-..,,._.._,.._m,,._., _
explain to the potential evacuees why an emergency evacuation might be necessary and what might happen to them should they not evacuate when so directed following a serious accident.
6-8. If evacuees are not informed as to the need to and reasons for evacuating, they might not evacuate.
6-9. Please see Intervenors' previously submitted documents and the Board's order concerning emergency response contentions.
6-10. It is not the Intervenors' burden to " list all U.S. nuclear plants" which provide particular information. It is the Applicants' outy to assure that the best possible information is provided to the public to assure a prompt and effective evacuation.
6-11. It is not the Intervenors' burden to identify "all transient warning notices, posters, signs etc. in use in the plume EPZs of other U.S. nuclear plants" containing certain information. It is the duty of the Applicants to assure that the best possible information is provided to transients in the Vogtle area to assure safe evacuation in the event of an emergency.
6-12. Merely referring transients to the Yellow Pages is inadequate. Sufficient information should be provided on the notice. Also, transients (and others) must be informed as to the reasons an evacuation might be required and the potential consequences should the individual fail to evacuate following an accident.
6-13. Yellow Pages might not be available to transients. Lack of adequate knowledge 'of the reasons for needing to evacuate and the potential consequences of not evacuating could result in failure by many to evacuate.
6-14. Please see Intervenors' earlier filings and the Board's order relating to emergency response for regulatory requirements.
6-15. Intervenors object to this question as being overly broad, irrelevant and not susceptible to a reasonable response. It is not the duty of the Intervenors to 8
" list all U.S. nuclear plants which have transient warning notices that include" certain language.
6-16. Please see responses to G-1 through G-4 below.
6-17. Yes. Adequate changes must be made to assure that the public understands the meaning of an emergency, the gravity of such a situation, the necessity for action and the appropriate response to be taken.
6-18. This is essentially the same question as 6-17 and has the same response.
7- 1. There are many emergency situations which might affect both Plant Vogtle and It is the duty of Applicants the Savannah River Plant (weather-related and others).
to foresee potential emergency situations that might affect both facilities and to assure that adequate emergency response can be made at Plant Vogtle in such an emergency.
7-2. See 7-1 above.
7-3. See 7-1 above.
7-4. See 7-1 above.
7-5. See 7-1 above. Also, the purpose of an emergency response plan is to provide a response when the facility fails to meet its intended design bases and suffers an emergency situation despite being designed against it.
7-6. See 7-5 above.
7-7. See 7-5 above.
7-8. See 7-5 above.
7-9. The Department of Energy would be required to respond to the emergency at its own facility. doe would doubtless give far greater attention to the emergency at SRP not only because it is doe's own facility, but also because of SRP's mission in national security.
7-10. It is the duty of the Applicants to demonstrate that all such aid will be provided in the event of emergencies at both facilities.
l 7-11. It is the duty of Applicants to provide the means by which this assistance 9
will be provided, a duty Applicants have failed to meet.
7-12. Please see response to 7-10, above.
7-13. It is obvious that in the event of simultaneous emergencies at SRP and Plant Vogtle, resources responding to the emergencies would be divided between the two.
l 7-14. It is the duty of the Applicants to demonstrate that adequate response will be provided for emergencies at Plant Vogtle simultaneous to emergencies at SRP.
7-15. Please see response to 7-14 above.
7-16. Please see response to 7-14, above.
7-17. Please see response to 7-14, above.
! 7-18. Please see response to 7-14, above.
7-19. Please see response to 7-14, above.
l 7-20. Please see response to 7-19, above.
7-21. Please see response to 7-14, above.
7-22. Please see response to 7-14, above.
I 7-23. Please see response to 7-22, above.
7-24. Please see response to 7-22, above.
4 7-25. Please see response to 7-1, above.
I i
7-26. It is the duty of the Applicants to assure the availability of emergency vehicles in all reasonably foreseeable emergency situations, including simultaneous l emergencies at SRP and Plant Vogtle.
i 7-27. Please see response to 7-26, above.
! 7-28. Please see response to 7-27, above.
7-29. Please see response to 7-27, above.
I i 7-30. Please see response to 7-1, above.
1 7-31. Yes. Applicants have made insufficient provision for dealing with simultaneous emergencies at SRP and Plant Vogtle, attempting to get around such provisions by claiming Applicants are not required to make such provisions.
10 y ..__ ,.~.-4-- - m-_ _.___r_---
, - - _ - _ - - - - - .7., __.,m.,,,w_, , . - - - , ,--_.,_--___-,__---,--._._,--_--.----.,.--e,- .
7-32. Please see response to 7-31, abova.
7-33. Please see response to 7-32, above.
7-34 Changes sufficient to assure proper coordination must be made.
7-35. Yes. Changes must be made sufficient to assure that a proper, adequate and coordinated response is made in the event of emergency situations involving Plant Vogtle, including those simultaneous with emergencies at the Savannah River Plant.
7-36. This is essentially the same question as 7-35 and has the same response.
G- 1. Laurie Fowler, attorney at law, 218 Flora Ave., Atlanta, GA 30307, employed by Brian Spears, assisted in preparation of Intervenors' proposed emergency response contention; Tim Johnson, Executive Director, Educational Campaign for a Prosperous Georgia and Campaign for a Prosperous Georgia,1083 Austin Ave., Atlanta, GA 30307, assisted in preparing contention; Nina Bell & Gene Rosalie, Nuclear Information &
Resource Service,1616 P St. NW, Ste.160, Washington, DC 20036, providing materials on emergency response requirements and experiences at other facilities. Dr. Judith Gordon,150 Cypress Dr., N. Augusta, S.C. 29841 Augusta College, as cited. Joan Holt, intervenor at Indian Point, address unknown, information on emergency response planning at that facility.
G-2. See G-1 above. Also, Seymour Shaye,1225 Euclid Ave. #3, Atlanta, GA 30307, assisting in responses to interrogatories and research in preparation for hearings concerning emergency response contentions.
G-3(a). See G-1 and G-2 above.
(b). See G-1 and G-2 above.
(c). See G-1 and G-2 above.
G-4. Seymour Shaye, specific information relating to 1(a)-3,1(a)-4, 1(a)-5, 1(a )-
9, 5-2, 6-12 and 7-9 and general information related to the others. Laurie Fowler, specific information relating to G-1 and general information related to others. Tim Johnson, general information relating to all. Dr. Judith Gordon, information relating to 1(a)-2. Addresses are listed above.
11
G-5(a). Intervenors have not identified their expert witness or witnesses for this l
! contention. Seymour Shaye, listed above, may be called as an expert witness.
Intervenors will notify Applicants when Intervenors identify their expert witness (es).
(b). This has not yet been detennined.
(c). This nas not yet been detennined.
(d). This has not yet been determined.
G-6(a), (b) and (c). These documents will be made available for Applicants' inspection and copying at a date and time to be agreed upon when the Applicants so request.
I I
G-7 (a) and (b). These documents will be made available as described in G-6 above.
G-8 (a) and (b). The sources of information have already been identified.
G-9(a) and (b). Intervenors have not yet prepared their testimony or exhibits for hearings concerning emergency response.
G-10. Intervenors have no desire to withhold any documents or other information relating to the emergency response contention and will make them all available as described above.
Document Requests.
l All documents requested by Applicants will be made available for inspection and j
copying at a convenient time and place when Applicants contact Intervenors to ,
establish such a time and place. I i
i 1
Respectfully submitted this, the 28th day of October,1985 Tim Johnson for Intervenors Campaign for a Prosperous Georgia and i Georgians Against Nuclear Energy 1
! 12 l
l E. . -__ , . _ _ . . . _ , _ . _ _ _ _ _ _ . . _ _ _ _ _ _ _ _
. _- . . . . _ ~ _ _ - - _ - - .._ - _ . . . . - - - _
i
! UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION
! BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of i GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425 i )
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Intervenors' Response to j Applicants' First Set of Interrogatories and Requests to Produce Concerning i Emergency Response Contentions" 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 i delivered to the Secretary of the Commission, the members of the Licensing Board and
- all others listed below, this 28th day of October,1985.
I YM I
Tim Johnson SERVICE LIST 4
! Morton B. Margulies, Chaiman Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel i U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1 Washington, D.C. 20555 Washington, D.C. 20555 9
l Dr. Oscar H. Paris Docketing and Service Section Atomic Safety & Licensing Board Office of the Secretary i U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555
) Mr. Gustave A. Linenberger Bernard M. Bordenick, esq.
l Atomic Safety & Licensing Board Office of the Executive Legal 4 U.S. Nuclear Regulatory Commission Director Washington. 0.C. 20555 U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 i
! Atomic Safety & Licensing Board Panel Ruble A. Thomas
- U.S. Nuclear Regulatory Commission Southern Company Services, Inc.
i Washington, D.C. 20555 P. O. Box 2625 l Bimingham, Alabama 35202 Bruce Churchill, esq.
l Shaw, Pittman, Potts & Trowbridge Bradley Jones, esq.
- 1800 M Street, N.W. Regional Counsel, U.S. NRC l Washington, D.C. 20036 101 Marietta Street, Ste. 3100
, Atlanta, Georgia 30303 James Joiner, esq.
Troutman, Sanders, k.vckerman & Ashmare The Candler Building Atlanta, Georgia 30303 f
- _ - _ - - __ - - - - - - -