ML20137B133

Response to Applicants Second Set of Discovery Re P Smith Difficulty in Contacting Emergency Response Personnel in Burke County.Related Correspondence

ML20137B133
Person / Time
Site:	Vogtle
Issue date:	01/05/1986
From:	Johnson T CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL)
To:	Atomic Safety and Licensing Board Panel
References
CON-#186-723 OL, NUDOCS 8601150114
Download: ML20137B133 (3)

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4 "urs coawmmsoa:;n UNITED STATES OF AMERICA DJur NUCLEAR REGULATORY COMMISSION USO BEFORE THE ATOMIC SAFETY AND LICENSING BOARD *86 g In the Matter of ) .

All:58 GEORGIA POWER CO., et al. Docket Nos. 50- 2 a[i 2[S( O b (Vogtle Electric Generating Plant, )

Units 1 and 2) )

INTERVENORS' RESPONSE TO APPLICANTS' SECOND SET OF DISCOVERY RELATING TO EMERGENCY RESPONSE Interrogatories.

EP-1(a)-14. Intervenors have provided the information they have relating to Pam Smith's difficulty in contacting emergency response personnel in Burke County.

Intervenors do not have the specific date and time and related information for each attempt beyond what has already been provided to the Applicants.

EP-1(a)-15. Intervenors do not have this information beyond what has oreviously been provided to Applicants.

EP-1(a)-16 through EP-1(a)-21. Intervenors have not yet prepared testimony for the-hearings and have not completed their analysis of the dispatch system. Further information will be provided upon completion of this analysis.

EP-2(a)-8 and EP-2(a)-9. Intervenors have not yet prepared their testimoay for the hearings and have not completed their analysis of the controls over the ENN.

Intervenors will provide further information upon completion of such analysis.

EP-2(c)-22. Intervenors have already provided this information in response to Applicants first requests for production of documents relating to emergency response.

EP-2(c)-23. Applicants have stated that the weather around Plant Vogtle is severe.

This includes relatively frequent tornadoes as well as other severe weather. Such I

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_ - s, weather occur's throughout the cuergency response zone, through the aresa to which evacuees are to be taken, and far beyond. Intervenors have not conducted a specific year-by-year survey of the frequency of such occurances in the years requested by Applicants.

EP-2(c)-24. Yes.

EP-2(c)-25. Residents will shut off the radios because not only do they frequently go off without reason, but, among other causes, they can also go off with reason.

Intervenors have provided Applicants with information in their possession relating to some of the experiences at other nuclear facilities.

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EP-4-8 through EP-4-9. Burke County Hospital, Humana Hospital and Oak Ridge Hospital should have sufficient facilities to treat the number of contaminated

. victims of a severe accident at Plant Vogtle.

EP-5-13 and EP-5-14 Intervenors have not yet prepared their testimony and have not completed their analysis of Applicants' responses to Intervenors' discovery requests. When such analysis is completed, Intervenors will further respond to these requests.

EP-7-37. Intervenors cannot identify all such emergency situations, but they might be related to weather, civil disturbances, geologic events or any number of other0 phenomena.

EP-7-38 and EP-7-39. The point of Intervenors' concern is that such events could

. occur and, indeed, any external event causing an accident at either facility is similarly likely to cause an accident at the other facility. Intervenors have not conducted statistical analyses of the likelihood of such occurences, but are concerned that Applicants rely to a too-great extent on personnel which may be occupied with problems relating to Savannah River Plant.

EP-7-40 through EP-7-43. Intervenors' concern is that Applicants have not provided for the contingency that a simultaneous accident may occur at Savannah River Plant SRP). Applicants do not provide specific information as to how the assistarce from 2

.- s.

SRP on which Applicants rely might be affected by a similar accident at that facility.

G-11. These responses were prepared by Tim Johnson, Campaign for a Prosperous Georgia,1083 Austin Ave., Atlanta, GA 30307, relying on information previously provided to the Applicants and on conversations with Atlanta psychologist Seymour Shaye, who will serve as an expert witness for Intervenors on this contention.

G-12. Intervenors have already provided Applicants with the documents relied on herein.

G-13. Intervenors have provided Applicants with all sources of information used in these responses.

G-14. Intervenors do not claim a privelege against production for any documents used.

G-15. Information relating to Seymour Shaye's employer, education and professional background have previously been provided to the Applicants; any further information or clarification will be provided at the deposition of Mr. Shaye on January 6. In regards to his testimony, he has not yet prepared said testimony. When he does so, Applicants will be provided with complete copies.

Documents.

Intervenors have provided Applicants with all documents used in preparation of or described in these responses.

Respectfully submitted this, the 5th day of January, 1986.

f

%W Tim Johnson Executive Director ECPG 1083 Austin Ave.

Atlanta, GA 30307 3