ML20137P087
| ML20137P087 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/31/1986 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20137P050 | List: |
| References | |
| OL, NUDOCS 8602040332 | |
| Download: ML20137P087 (4) | |
Text
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Janua A31, 1986 cy n
UNITED STATES OF AMERICA
't FEB ~ 3 g, NUCLEAR REGULATORY COMMISSION
', (s/h BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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-hp sN'~lW In the Matter of
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GEORGIA POWER COMPANY, et al.
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Docket Nos. 50-424
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50-425 (Vogtle Electric Generating Plant, )
Units 1 and 2)
)
APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH NO GENUINE ISSUE EXISTS TO BE HEARD REGARDING CONTENTION EP-1/EP-1(a)/EP-2(b)
(24-HOUR STAFFING OF BURKE COUNTY ENN LINK)
Pursuant to 10 C.F.R.
$ 2.749(a), Applicants state in sup-port of " Applicants' Motion for Summary Disposition of Joint Intervenors' Contention EP-1/EP-1(a)/EP-2(b)" that no genuine issue exists to be resolved with respect to the following mate-rial facts:
1.
As admitted by the Board, Joint Intervenors' Conten-tion EP-1/EP-1(a)/EP-2(b) concerns the 24-hour staffing of the Burke County Emergency Notification Network ("ENN") link.
2.
The " Burke County Emergency Management Agency Ra-diological Emergency Plan for Nuclear Incidents / Accidents Involving Vogtle Electric Generating Plant" identifies four means -- one primary and three back-up means -- by which Burke County could be notified of an emergency at Plant Vogtle.
"Af-fidavit of Richard L.
Bryant on contention FP-1/EP-1(a)/EP-2(b)" ("Bryant Affidavit") et 13.
0602040332 060131 ADOCK 0500pg 4 PDR 0
s 3.
The ENN -- a dedicated telephone network linking offsite emergency response officials with Plant Vogtle -- will be the primary means for notification to Burke County of an emergency at Plant Vogtle.
Bryant Affidavit at 14.
4.
As first back-up to the ENN, Burke County could be notified via com.aercial phone lines using a specific "24-hour" emergency number at the Burke County Emergency Operations Cen-ter ("EOC").
Bryant Affidavit at 14.
5.
The second back-up to the ENN will be the Burke Coun-ty EMA radio network.
Bryant Affidavit at 14.
6.
A receiver for each of these three means of notifica-tion -- the ENN, the EOC emergency number, and the Burke County EMA radio network -- will be located on the central dis-patcher's console in the new Burke County EOC.
Bryant Affida-vit at 15.
7.
Burke County will staff the central dispatcher's po-sition on a 24-hour-per-day basis.
Therefore, the ENN, the EOC emergency number, and the Burke County EMA radio network all will be staffed on a 24-hour-per-day basis, and the use of any of them would place Plant Vogtle in direct contact with the Burke County EOC.
Bryant Affidavit at H5.
8.
The third back-up to the ENN is via commercial phone lines to a specific "24-hour" emergency number for the Sher-iff's Department.
That phone is located on the Sheriff's Dis-patcher's console, which is staffed on a 24-hour-per-day basis.
l l L
L Pursuant to procedure, the Sheriff's Dispatcher would then advise the central dispatcher (in the EOC) of the notification from Plant Vogtle.
Bryant Affidavit at 16.
9.
Upon notification of an emergency at Plant Vogtle 4
(via any of the four identified means), the central dispatcher would contact the EMA Director (a full-time position) or a des-ignated alternate pursuant to a specific predetermined line of succession.
The line of succession was specifically developed to assure the 24-hour-per-day availability of an official with the authority to respond to an emergency at Plant Vogtle.
Each individual in the line of succession has the authority to ini-tiate an emergency response by Burke County.
Bryant Affidavit at 111,7, Exhibit A.
i 10.
The Burke County ENN link and the three back-up means for notification to Burke County of a Vogtie emergency thus all will be staffed on a 24-hour-per-day basis, and the procedure for initiation of Burke County emergency response will be the same regardless of the means used to notify Burke County of the emergency.
Bryant Affidavit at H8.
Respectfully submitted,
~
>J Bruce W. Churchill, P.C.
Delissa A. Ridgway David R.
Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 James E.
- Joinor, P.C.
Charles W. Whitney Kevin C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN
& ASHMORE 1400 Candler Building Atlanta, Georgia 30043 (404) 658-8000 Counsel for Applicants Dated:
January 31, 1986