ML20137X114
| ML20137X114 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/03/1986 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20137X102 | List: |
| References | |
| OL, NUDOCS 8603050209 | |
| Download: ML20137X114 (3) | |
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e DOLMETED March 3,UlTW6 UNITED STATES OF AMERICA g N 4 41 :55 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARQ)FFict..
DOCMEinw.:,: virt BRAN 0t 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)
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APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH NO GENUINE ISSUE EXISTS TO BE HEARD REGARDING CONTENTION EP-2/EP-2(a)
(ADMINISTRATIVE CONTROLS OVER ENN USE)
Pursuant to 10 C.F.R.
S 2.749(a), Apolicants state in sup-port of " Applicants' Motion for Summary Disposition of Joint Intervenors' Contention EP-2/EP-2(a)" that no genuine issue ex-ists to be resolved with respect to the following material facts:
1.
As admitted by the Board, Joint Intervenors' Conten-tion EP-2/EP-2(a) concerns the existence of administrative con-trols to assure the ready availability of the Emergency Notifi-cation Network ("ENN") in an emergency for the transmission of official and necessary messages.
2.
The ENN is a dedicated, "hard-wired" telecom-munications syntem exclusively for use in a radiological gmargency.
The ENN system links Plant Vogtle with the princi-pal organizations for emergency resoonse within the Vogtle plume exposure pathway Emergency Planning Zone ("EPZ")
8603050209 B40303 ADOCK 05000gg4 PDR G
specifically, the States of Georgia and South Carolina; Burke County, Georgia; Aiken, Allendale, and Barnwell Counties, in I
South Carolina; and the Savannah River Plant.
DiLuzio Affida-vit at 1 3.
3.
Physical access to the ENN is restricted.
Clack Af-fidavit at 1 4; Bryant Affidavit at 1 3; Gardner Afidavit at 1 4; Mauney Affidavit at 1 4; Awbrey Affidavit at 1 4; Wald Af-fidavit at 1 3; Twine Affidavit at TS 4-5; DiLuzio Affidavit at 16, 4.
All ENN terminals will be subject to administrative controls, to assure the ready availability of the ENN during an emergency for the transmission of official and necessary mes-sages.
Clack Affidavit at 1 5; Bryant Affidavit at 1 4; Gard-ner Affidavit at 1 5; Mauney Affidavit at 1 5; Awbrey Affidavit at 1 5; Wald Affidavit at 1 4; Twine Affidavit at 1 5; DiLuzio Affidavit at 1 7.
5.
Because of the physical characteristics of the ENN system, it cannot be " overloaded" even by ENN users.
Once the
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ENN system is activated, all parties at ENN terminals would au-tomatically hear everything said at any of the other connected terminals, and would physically be able to speak up at any time.
The ENN system is thus designed to assure the constant physical capability to transmit official and necessary mes-sages.
DiLuzio Affidavit at 1 4.
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6.
All ENN terminals will be both physically and admin-istratively controlled.
The physical controls will prevent unauthorized access to the ENN.
The administrative controls will assure its ready availability during an emergency for the
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transmission of official and necessary messages.
Clack Affida-it at Y 6; Bryant Affidavit at 1 5; Gardner Affidavit at 1 6; Mauney Affidavit at 1 6; Awbrey Affidavit at 1 6; Wald Affida-vit at 1 5; Twine Affidavit at 1 5; DiLuzio Affidavit at 1 8.
Respectfully submitted, 1
n ArucMMurchill, 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. Joiner, 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:
March 3, 1986
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