ML20138A477
| ML20138A477 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/06/1986 |
| From: | Ridgway D GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20138A465 | List: |
| References | |
| OL, NUDOCS 8603140271 | |
| Download: ML20138A477 (5) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION El ggq ig 0868" y[yh-ifC3 BEFORE THE ATOMIC SAFETY AND LICENSING BOA
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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-4 (IDENTIFICATION OF EXISTING HOSPITALS FOR TREATMENT OF CONTAMINATED INJURED INDIVIDUALS)
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-4" that no genuine issue exists to i
be resolved with respect to the following material facts:
1.
As admitted by the Board, Joint Intervenors' Conten-tion EP-4 concerns the identification of hospitals for the treatment of contaminated injured individuals.
2.
The "Vogtle Electric Ger.erating Plant Unit 1 and Unit 2 Emergency Plan" (Vogtle Plan") identifies Humana Hospital (in Augusta, Georgia) as the primary medical facility to be used by Applicants for treatment of contaminated injured individuals from the Plant Vogtle site, with Burke County Hospital (in Waynesboro, Georgia) as a back-up facility.
" Affidavit of Jean M. DiLuzio on Contention EP-4" ("DiLuzio Affidavit")
at 1 3.
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3.
" Annex D, Plant Vogtle, to The Georgia N5diological Emergency Plan".("Giorgia Plan") identifie's Burke County Hospi-l tal as the primary medical facility in Georgia for treatment of any members of the general public who might be contaminated and injured as a result of an accident at Plant. Vogtle.
" Affidavit of Billy J. Clack on Contention EP-4" (" Clack Affidavit")
l at 1 3.
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4.
The Georgia Plan identifies Humana Hospital as the secondary medical facility in Georgia for the care of offsite victims of an accident at Vogtle.
Clack Affidavit,at 1 4.
5.
The Georgia Plan provides that any victim of a ra-diological accident at Vogtle who requires care that cannot be provided at either Burke County Hospital or Humana Hospital can be treated at Oak Ridge Hospital (in Oak Ridge, Tennessee).
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Clack Affidavit at 1 5.
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6.
The Georgia Plan is being revised to dilete reference l
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to Burke County Hospital and Humana Hospital as facilities for the care of individuals who are injured but not cdptaminated.
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Clack Affidavit at 11 3-4.
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7.
The " Burke County Emergency Management Agehcy Ra-l l
diological Emergency Plan for Nuclear Incidents / Accidents Involving Vogtle Electric Generating Plant" (" Burke County t
Plan") is being amended to be completely consistent with the Georgia Plan.
" Affidavit of Richard L. Bryant on Contention EP-4" ("Bryant Affidavit") at 11 3-5.
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8.~
The "Vogtle Electric Generating Plant Response Guide, SR 402.1" ("SRP. Response Guide") identifies the Savannah River Plant ("SRP") Medical Building and the Dwight D. Eisenhower Army Medical Center (at Fort Gordon, South Carolina) as the medical facilities in the vicinity of Plant Vogtle for the I!
treatment of any SRP transients or employees who might be con-taminated and injured as a result of an accident at Plant Vogtle.
" Affidavit of Kevin P. Twine on Contention EP-4" (Twine Affidavit") at 1 3.
9.
The SRP Response Guide also provides that additional radiological medical support can be obtained through the Radia-tion Emergency Action Center and Training Sito (" REACTS") in Oak Ridge, Tennessee.
Twine Affidavit at 1 4.
10.
The "Vogtle Electric Generating Plant Site Specific Radiological Emergency Response Plan, Part 7, SCORERP"
(" South Carolina Plan"), " Annex Q, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) To The Aiken County Emergency Operations Plan (EOP)" ("Aiken Coun-ty Plan"), " Annex Q, Part 2, Fixed Nuclear Facility (FNF) Ra-diological Emergency Response Plan (RERP) To The Allendale County Emergency Operations Plan (EOP)" ("Allendale County Plan"), and " Annex Q, Part 2, Fixed Nuclear Facility (ENF) Ra-diological Emergency Response Plan (RERP) To The Barnwell Coun-ty Emergency Operations Plan (EOP)" ("Barnwell County Plan")
all consistently identify Aiken Community Hospital (in Aiken, -
t.
4 South Carolina) and Humana Hospital as the medical facilities for the treatment of any other members of the general public in South Carolina who might be. contaminated and injured as a re-sult of an accident at Plant Vogtle.
Affidavit of Anthony J. Wynn on Contention EP-4" ("Wynn Affidavit") at 1 3
" Affidavit of Bobby R. Mauney on Contention EP-4" ("Mauney Af-fidavit") at 1 3; " Affidavit of Harold W. Awbrey on Contention EP-4" ("Awbrey Affidavit") at 1 3; " Affidavit of~ Herman E. Wald t
on Contention EP-4" ("Wald Affidavit") at 1 3.
11.
Due to the extensive nuclear operations at the SRP site, the SRP Medical Building.has a special unit dedicated to the treatmenttof contaminated injured persons; and REACTS is'a U.S. Department of Energy-operated facility which is a national center for the observation, assessment and treatment of radia-tion patients, including the contaminated injured.
Twine Affi-davit at 1 4.
p 12.
Burke County Hospital, Humana Hospital, Oak Ridge Hospital, Aiken Community Hospital and Eisenhower Army Medical 3
Center are all accredited by the Joint Commission for Accred-itation of Hospitals, which requires approved procedures for treatment of contaminated injured individuals.
DiLuzio Affida-vit at 1 4; Clac,k Affidavit at 1 5.
13.
All Vogtle-specific emergency response plans -- both onsite and offsite -- identify medical facilities for the 4
treatment of contaminated injured individuals.
DiLuzio s
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Affidavit at 1 5; Clack Affidavit at 1 6; Bryant Affidavit at 1 6; Wynn Affidavit at 1 4; Mauney Affidavit at 1 4; Awbrey Affidavit at 1 4; Wald Affidavit.at 1 4; Twine Affidavit at 1 5.
Respectfully submitted, hi d k N M ads-Bruch W. Ch'uYchi'll,0 P. C.0 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 6, 1986 l l v
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