ML20138A520
| ML20138A520 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/10/1986 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20138A232 | List: |
| References | |
| OL, NUDOCS 8603140305 | |
| Download: ML20138A520 (15) | |
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March 10 1986,4 UNITED STATES OF AMERICA 8
Q NUCLEAR REGULATORY COMMISSION y
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BEFORE THE ATOMIC SAFETY AND LICENSING BOA 0002nnas
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$EN@ $ V In the Matter of )
- 7%ETTT' GEORGIA POWER COMPANY, et al.
) Docket Nos. 50-424' ~ ~ ~ ' ) 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-2/EP-2(h) (PUBE,IC INFORMATION FOR TRANSIENTS) Pursuant to 10 C.F.R. 5 2.749(a), Applicants state in sup-port of " Applicants' Motion for Summary Disposition of Joint Intervenors' Contention EP-2/EP-2(h)" 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(h) concerns the provision of emergency public information for transients within the Vogtle plume exposure pathway Emergency Planning Zone ("EPZ"). 2. A thorough survey of the Vogtle EPZ has been con-ducted to identify all transient populations in the area, and a comprehensive program has been designed to assure that 8603140305 B60310 PDR ADOCK 05000424 G PDR
J transients are provided with information needed for response to a Vogtle emergency..Bryant Affidavit at 11 4, 16; Maunay Affi-davit at 1 4; Awbrey Affidavit at 1 4; Wald Affidavit at 1 4; Twine Affidavit. at 1 3. A. Burke County 3. The transient population in that portion of Burke County which. lies within the EPZ is comprised of non-resident (1) sportsmen, (2) motorists passing through the area, (3) employees working in the area, and (4) individuals making occa-sional brief visits to attend church, the Plant Vogtle Visitors Center, commercial establishments, or for other such reasons. Also included are the staff and students of Girard Elementary School (the only school in the EPZ), although the school will be closed permanently no later than September 1987. Bryant Af-fidavit at 11 3, 5-15. 4. The Burke Ccunty program for dissemination of Vogtle emergency public information to transients has a number of ele-monts. These include the emergency public information bro-chure, information placed in the local telephone directory, stickers cut or near public phones, and large warning signs (for outdoor use) and smaller warning signs (for indoor use) for posting at strategic locations in the EPZ. Each of these will j l j
r ~- provide the basic information needed by a transient to respond effectively to a warning of an emergency at Plant Vogtle. The signs and stickers will also refer the reader to the telephone directory insert, which will include more detailed information. Bryant Affidavit at 11 16-17. 5. At the up-river'and down-river boundaries of the EPZ, warning signs will be posted on both banks of the Savannah River, to provide information to sportsmen. Georgia Power Com-pany will also provide outdoor warning signs to appropriate local officials and landowners, for posting at Mil 10r's Pond and at the boat launches within the Burke County portion of the EPZ. Bryant Affidavit at 1 19; DiLuzio Affidavit at 1 14. 6. Georgia Power Company will provide each hunting club in the EPZ with a supply of the brochures, for distribution to their membership. Bryant Affidavit at 1 19; DiLuzio Affidavit at 1 7. 7. Sportsmen will also be informed by warning notices posted in commercial establishments within the EPZ, where they stop for supplies, gasoline, food, or lodging. The public telephone stickers and the telephone directory insert are addi-tional means of informing sportsmen. Bryant Affidavit at 1 19. 8. Motorists traveling through the area will be informed by the warning notices posted in commercial establishments i
.O (when they stop for gasoline,. food, loc'ging, etc.), and by the information on the public telephone stickers and in the tele-phone directory. Those who do not stop will spend a maximum of 25 minutes in the EPZ. Bryant Affidavit at 1 20. 9. The greatest number of non-resident employees is the Plant Vogtle work force. All Vogtle const uction workers, plant personnel and contractor personnel receive instruction on the methods of personnel notification and required protective actions in the event of a Vogtle emergency. Bryant Affidavit at 1 31; DiLuzio Affidavit at 1 3. 10. Georgia Power Company will provide all commercial es-tablishments within the EPZ -- as well as all timber companies operating in the EPZ -- with a supply of the brochures, for distribution to non-resident employees. Bryant Affidavit at 1 22; DiLuzio Affidavit at 11 5-6. 11. All area farmers are required to register annually with tha Agricultural Stabilization and Conservation Service ("ASCS") of the U.S. Department of Agriculture in Augusta. The ASCS office has agreed to post a warning sign to provide in-formation to area farmers, and to distribute copies of the bro-l chures to farmers using land in the EPZ. Bryant Affidavit at i 1 22; DiLuzio Affidavit at 11 9,
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e -- 12. Non-resident employees also will be informed by the warning notices posted in commercial establishments within the EPZ, the public telephone stickers, and the telephone directory insert. Bryant Affidavit at 1 22. 13. Georgia Power Company will provide the motel with a supply of brochures for distribution to guests. Bryant Affida-vit at 1 16; DiLuzio Affidavit at 1 5. 14. Georgia Power Company is providing the pastors of all churches in the Burke County portion of the EPZ with supplies of the brochures, for distribution to the church congregations. The churches will also be provided with indoor warning notices, for posting on church premises. Bryant Affidavit at 1 23; DiLuzio Affidavit at 11 12, 16. 15. At the Vogtle Visitors Center, warning signs will be posted and brochures will be available to all visitors. Bryant Affidavit at 1 24; DiLuzio Affidavit at 1 4. 16. Both church-goers and Vogtle visitors, as well as any other occasional visitors in the area such as those patronizing commercial establishments, will also be informed by means of the warning information posted in commercial establishments (such as the motel) and at public telephones, and the in-formation in the local telephone directory. Bryant Affidavit at 1 25. O. 17. Prior to fuel load, and annually thereafter (until the school closes), Georgia Power Company will provide Girard Elementary School with a supply of brochures, for distribution to school staff and parents of students attending school. Bryant Affidavit at 1 26; DiLuzio Affidavit at 1 8. 18. Thus, adequate measures are being taken to provide emergency public information to transients in t at portion of Burke County which lies within the Vogtle EPZ. Bryant Affida-vit at 1 27. B. Aiken County 19. The portion of Aiken County that lies within the EPZ r.onsists of part of the Savannah River Plant and part of the Cowden Plantation. Cowden Plantation is privately owned and is used principally for hunting and occasionally for fishing. Ac-cess to the plantation is restricted, and hunting and fishing are limited to defined areas and to individuals who have the express permission of the plantation owner. There are no phone booths, hotels, motels, gas stations or other such commercial establishments in the Aiken County portion of the EPZ. The transient population at Cowden Plantation is therefore limited to sportsmen and employees of the plantation, as well as any Seaboard Coast Line crew operating in the area. Mauney Affidavit at 1 3. t :- 20. Georgia Power Company will provide Cowden Plantation management with a supply of the Vogtle emergency public in-formation brochure, for distribution to all employees and sportsmen at the plantation. Mauney Affidavit at 1 5; DiLuzio Affidavit at 1 11. 21. Georgia Power Company will provide Seaboard Coast Line railroad with a supply of the brochures, for distribution to all railroad employees who work within the EPZ. Mauney Af-fidavit at 1 6; DiLuzio Affidavit at 1 13. 22. The local telephone directory will include emergency public information such as means of notification, actions to be taken if a warning is received, and appropriate EBS stations for the area. Mauney Affidavit at 1 7. 23. Thus, adequate measures are being taken to provide emergency public information to transients in that portion of Aiken County which lies within the Vogtle EPZ. Mauney Affida-vit at 1 7. I.
r-C. Allendale County 24. The' portion of Allendale County that lies within the EPZ. consists.of approximately one and one half square miles of the Creek. Plantation. The Creek Plantation is a ~ privately-owned breeding farm for quarter horses, which extends into neighboring Barnwell' County. There is a section of Seaboard Coast Line railroad. track within the Allendale County portion of the EPZr and a short segment (less than one-half mile) of South Carolina Route 125 bounds the EPZ on the north. There are no phone booths, hotels, motels, gas stations or-other such commercial establishments in the Allendale County portion of the EPZ. The transient population in this part of the EPZ is therefore limited to Creek Plantation employees and visitors, motorists on Route 125, and any Seaboard Coast Line crew operating in the area. Awbrey Affidavit at 1 3. 25. Georgia Power Company is providing Creek Flantation management with a supply of the Vogtle emergency public in-formation brochure, for distribution to all employees and visi-tors to the plantation. Awbrey Affidavit at 1 5; DiLuzio Affi-davit at 1 10. 26. Any motorists on the short segment of Route 125 with- .. ? in the Allendale County portion of the EPZ either are visitors .c l b
to the Creek Plantation or are simply passing through this part of the EPZ. Any motorists who do not stop at the Creek Planta-tion will spend less than two minutes within the Allendale County portion of the EPZ. Awbrey Affidavit at 1 6. 27. Georgia Power Company will provide Seaboard Coast Line railroad with a supply of the emergency public information brochures, for distribution to all railroad employees who work within the EPZ. Awbrey Affidavit at 1 7; DiLuzio Affidavit at 1 13. 28. The local telephone directory will include emergency public information such as means of notificat ion, actions to be taken if a warning is received, and appropriate EBS stations for the area. Awbrey Affidavit at 1 8. 29. Thus, adequate measures are being taken to provide emergency public information to transients in that portion of Allendale County which lies within the Vogtle EPZ. Awbrey Af-fidavit at 1 8. i J
I. D. Barnwell County 30. The portion of Barnwell County that lies within the EPZ consists of part of the Savannah River Plant and approxi-mately one and one half additional square miles. The Creek Plantation accounts for most of the portion of the EPZ for which Barnwell County is responsible. Also included within the Barnwell County portion of the EPZ are St. Mary's Baptist Church, Steel Creek Landing (a boat launch), and a section of track of Seaboard Coast Line railroad. A short segment (less than one-half mile) of South Carolina Route 125 partially bounds the EPZ on the north. There are no phone booths, ho-tels, motels, gas stations or other such commercial establish-ments in the Barnwell County portion of the EPZ. The transient population in this part of the EPZ is therefore limited to Creek Plantation employees and visitors, motorists on Route 125, sportsmen using Steel Creek Landing, the church congrega-tion, and any Seaboard Coast Line crew operating in the area. Wald Affidavit at 1 3. 31. Georgia Power Company is providing Creek Plantation management with a supply of the Vogtle emergency public in-formation brochure, for distribution to all employees and visi-tors to the plantation. Wald Affidavit at 1 5; DiLuzio Affidavit at 1 10. i
r 32. Georgia Power Company will also provide outdoor warn-ing signs-for posting near Steel Creek Landing, to provide emergency public information to sportsmen in the area. Wald Affidavit at 1 6; DiLuzio Affidavit at 1 14, 33. Georgia Power Company will provide the pastor of St. Mary's Baptist Church with a supply of the emergency public in-formation brochures, for distribution to the congregation of the church. The church will also be provided with an indoor warning notice, for posting on church premises. Wald Affidavit at 1 7; DiLuzio Affidavit at 11 12, 16. 34. Any motorists on the short segment of Route 125 with-in the Barnwell County portion of the EPZ either are visitors to the Creek Plantation, Steel Creek Landing, or the church, or are simply passing through this part of the EPZ. Any motorists who do not stop at the plantation, the landing, or the church spend less than two minutes within the Barnwell County portion of the EPZ. Wald Affidavit at 1 8. 35. Georgia Power Company will provide Seaboard Coast Line railroad with a supply of the emergency public information brochures, for distribution to all railroad employees who work within the EPZ. Wald Affidavit at 1 9; DiLuzio Affidavit at 1 13. f; s 36. Thus, adequate measures are being taken to provide emergency public information to. transients in that portion of Barnwell County which lies within the Vogtle EPZ. Wald Affida-vit at 1 9. E. Savannah River Plant 37. By definition, all persons in Savannah River Plant ("SRP")-controlled areas of the Plant Vogtle EPZ are considered t to be transients. These transients fall-into seven categories: (1) Personnel, working in fixed SRP facilities; (2) Department of Energy (" DOE") or contractor personnel working outdoors within the Plant Vogtle EPZ; (3) Forest Service presonnel and contractors working within the Plant Vogtle EPZ; (4) Hunters onsite during deer-hunting. season; (5) Hunters in the Crack-erneck Section of the Sumter National Forest (National Forest land secured by the SRP); (6) Motorists transiting the SRP site on Route 125; and (7) Railroad personnel passing through the SRP site. Twine Affidavit at 1 3.
- 38.. All personnel working in fixed SRP facilities receive employee training, which includes instruction in emergency sig-nals/ announcements, rally points, and evacuation routes.
The initial. training is reinforced by protective action exercises conducted several times a year. Twine Affidavit at 1 4.. L
(' 39. DOE and DOE-contractor personnel working out-of-doors and away from fixed facilities in the EPZ receive, at a mini-mum, an orientation program outlining warning procedures and required responses to notification of an emergency. Twine Af-fidavit at 1 4. 40. Signs, flyers, and printed instructions (e.g., emer-gency procedures summarized on the back page of all SRP tele-phone books) are also used to continually remind all employees of emergency procedures. Twine Affidavit at 1 4. 41. U.S. Forest Lervice persennel and timber contractors working within the SRP portion of the Plant Vogtle EPZ receive an orientation including information on means of emergency no-l tification, emergency conditions, and protective actions prior l to their entry to the work site. Twine Affidavit at 1 5. 42. HunterP using lands on the SRP portion of the EPZ are informed of emergency notification and evacuation procedures each day prior to the hunt by the SRP Hunt Coordinator. Access for hunters to the Crackerneck Section of the Sumter National j Forest is also controlled by SRP, and is limited to those with l a special permit. Access is restricted to specific hours, and all hunters must sign in and out on a log sheet maintained by i Security Contractor personnel at the only entrance to the prop-erty. Each person entering the area receives an orientation 1 . l I
r card describing notification procedures and protective actions in case of a radiological emergency. Twine Affidavit at 1 6. 43. Motorists traveling on Route 125, which traverses the EPZ, must stop'at security barricades operated continuously by SRP. Upon notification of an emergency at Plant Vogtle, SRP would be closed to civilian traffic and any motorists then on Route 125 within the SRP boundaries would be intercepted by mo-bile patrols. The stringent controls of SRP staff over the movement of motorists on Route 125, and their ability to pro-vide immediate personal notification and individual instruc-tions to those motorists in the event of an emergency, obviate the need for specific pre-emergency public information measures directed at the motorists. Twine Affidavit at 1 7. 44. Georgia Power Company is providing a supply of the Vogtle emergency public information brochure to the Seaboard Coast Line railroad, for distribution to all railroad employees who work within the EPZ. Twine Affidavit at 1 8; DiLuzio Affi-davit at 1 13. 45. Thus, adequate measures are being taken to assure that all transients on the SRP site will take appropriate I -
( actions in the event of an emergency at Plant Vogtle. Twine Affidavit at 1 9. Respectfully submitted, Bthce"W.7hurchill, 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 10, 1986 15- -.-..--__,____m .. - ~. - -,,}}