ML20138A533

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Affidavit of Kp Twine Re Contention EP-4.Savannah River Plant Guide Identifies Plant Medical Bldg & Dwight D Eisenhower Army Medical Ctr as Facilities for Treatment of Transients or Employees.Certificate of Svc Encl
ML20138A533
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 03/06/1986
From: Twine K
EBASCO SERVICES, INC., GEORGIA POWER CO.
To:
Shared Package
ML20138A465 List:
References
OL, NUDOCS 8603140308
Download: ML20138A533 (10)


Text

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March 6, 1986

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UNITED STATES OF AMERICA f p

. NUCLEAR REGULATORY COMMISSION fu('

{ 3 ggg 101gggp- J2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD \ co g fj6cg /C)

% G*hiit.uM llj 4 p In the Matter of ) '.

GEORGIA POWER COMPANY, et al.

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) Docket Nos. 50-424

) 50-425 (Vogtle Electric Generating Plant, )

Units 1 and 2) )

AFFIDAVIT OF KEVIN P. TWINE ON CONTENTION EP-4 COUNTY OF BERGEN )

)

STATE OF NEW JERSEY )

I, Kevin P. Twine, being duly sworn according to law, de-pose and say as follows:

1. My name is Kevin P. Twine. I am employed by Ebasco s Services, Inc. as Manager, Resources Planning. Ebasco has been retained by Georgia Power Company to coordinate offsite emer-gency planning activities for the Vogtle Electric Generating Plant, including coordination with the Savannah River Plant

(*SRP"). I am Project Manager for the Ebasco Vogtle project.

My business address in Atlanta is 145 Technology Park / Atlanta, Norcross, Georgia 30092. A summary of my orofessional quali-fications is attached to this affidavit as Exhibit A.

2. The puroose of this affidavit is to support "Appli-cants' Motion for Summary Disposition of Joint Intervenors'

< Contention EP-4," which concerns the identification of khg314030s 960306 O ADOCM 0500 4

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.. D facilities for the treatment'of contaminated injured individu-als. I have;perrgnal knowledge of the matters set forth herein and belie'Je them to be true and correct.

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3.- .The "Vogtle Electric Generating Plant Resoonsa Guide, CR 402.1" ("SRP Response Guide") identifies the SRP Medical Building-(outside the Vogtle plume Emergency Planning ~ Zone) and the Dwight D. Eisenhower Army Medical Center ("DDEAMC") (at Fort Gordon, South Carolina) as the medical facilities in the vicinity of Plant Vogtle for the treatment of any Savannah River Plant transients or employees who might be contaminated and injured as a result of an accident at Plant Vogtle. See l- SRP Response Guide, S III.E.

4. Due to the extensive nuclear operations at the Savan-nah River Plant site, the SRP onsite Medical Department is pre-pared to treat contaminated, injured employees and/or tran-sients on a 24-hour basis. A special Decontamination and Treatment Unit in the Medical Building facilitates treatment of contaminated, injured persons, and permits major or minor sur-gery cases with radiological complications to be handled on the SRP site if necessary. Physicians, nurses, and emergency medi-

! cal technicians on the Medical Department staff have been trained in the treatment of contaminated patients and work with

the advice and supervision of health physicists from the SRP Health Protection Department. The Medical Department staff has an ongoing, active working relationshio with DDEAMC, which has 9

a radiological emergency department. DDEAMC provides offsite i'

hospital facilities and other support, accepting contaminated 1

i

l patients from SRP and deploying trained medical oersonnel to the SRP site upon request. SRP provides radiological moni-toring and support for handling radiologically contaminated pa-tients. The SRP Response Guide further provides that addition-al radiological medical support can be obtair,ed through the Radiation Emergency Action Center and TrainiM Site (" REACTS ')

located in Oak Ridge, Tennessee. See SRP Response Guide, S III.E. This is a U.S. Department of Energy-operated facility which is a national center for the observation, assessment and treatment of radiation patients, including the contaminated in-jured.

5. The SRP Response Guide thus identifies medical ser-vice facilities capable of treating contaminated, injured Sa- ,

vannah River Plant transients and emoloyees.

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Kevih P. Twine Sworn to aro nubsc before me this /'/ yibed day of February, 1986.

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Notary Pubfic/ ROSEMARY SCRIMENTI

/ NOTARY PUJUC OF (Ol/ .muy MY C0*G.:2.*6 fu tr n a gj My Commission Expires:

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Exhibit A 2/86 Page 1 cf 4 i

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KEVIN P TWINE Manager - Resources Planning

SUMMARY

OF EXPERIENCE (Since'19o7)

Total Experience - Eightecn years experience including supervision and direction of numerous projects involving demographic, land use, traffic / transportation and socioeconomic impact and environmentel assessment analyses.

Professional Affiliations - American Society of Photogrammetry Education - MKP, University of North Carolina, 1967 - Regional Planning BA, Wesleyan University, 1965 - History REPRESENTATIVE ENVIROSPHERE PROJECT EXPERIENCE'(Since 1974)

Manager - Resources Planning Responsibilities 1:clude management of Envirosphere Staff involved in

. land use, traffic / transportation, socioeconomic, aesthetic, and ,

archaeological disciplines; direction of research in these fields; .

management of projects relating to resources planning; management of Envirctphere's Land Resources Analysis System (LRAS) for satellite imagery analysis and computerized geographic studies; expert testimony .

before regulatory bodies.

Projects include:

Ceorgia Power Co. Vogtle Electric Generativg Plant. Project manager for -

offsite emergency preparedness planning progran. Responsibilities 2

included coctract management; management of subcontractors; and l annagement of tasks in plan and procedure preparation, alert and notification system, corporate and communications planning, exercise preparation, and preparation of documents for ASLB hearings. Areas for 4 which plans were carried out included three counties in South Carolina, USDOE Savannah River Plant, and Burke County, Georgia.

i Carolina Power & Light Co. Shearon Harris Nuclear Power Planc. Served as technical project manager for licensing support concerning off-site emergency and evacuation pisaning. Work involved extedsive contacts with local <nd state government officials, utility officials, and legal counsel, as well as demographic analyses and planning for shelter and evacuation.

Holyoke Energy Recovery Company; Environmental Impact Report for Waste-to-Energy Facility in Holyoke, MA. Conducted analysis of the

impact of increased truck traffic on urban roadway system; study included 4

traffic counts, volume / capacity ratio calculations, optimization of truck routes, and mitigation recommendations.

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Page 2 of.4

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KEVIN P TWINE REPRESENTATIVE ENVIROSPHERE PROJECT EXPERIENCE (Continued)

TRC Environmental Consultants, Inc; Data Base for Air Quality Materials Damage Study. Gathered Jand use, demographic, and air quality data and incorporated it into a computerized data base for use ,in an air quality sacerials damage study. Data base was organized in two' formats: 9,000

.1-ka square grid cells; and 1200 census tracts. Study area was Southern California Air Fasin (Los Angeles area).

Kansas Gas and E.'Actric Company (KG&E); Wolf Creek Nuclear Generating Stacion.- Directed a 3 person field team in a four month comprehensive offsite emergency and evacuation planning effort for Coffey County, Kansas (location of Wolf Creek Nuclear Plant) ,and the State of Kansas.

Functioned as part of KG&E staff. Prepared witnesses and developed testimony for hearings. Reviewed, revised and prepared Interfaced offsite closely with emergency county and plans and implementing procedures.

- state officials.

Louisiana Power & Light Company; Waterford 3 Nuclear Generating Station.

Directed the preparation of Evacuation Time Estimate, 1980 and 1982; -

testified in defense of findings at hearings of Atomic Safety and '

Licensing Board, May,1982; directed preparation of detailed analysis of large evacuation which ecok place in Weterford 3 vicinity as a result of an industrial accident on December 11, 1982.

Consulidated Edison Company of New York; Site Selection Study for Coal Burning Waste. Disposal Facility. Directed preparation of demographic, land use, and aesthetic elements of site selection study; performed analysis of satellite imagery on LRAS for input to site selection procedure.

Pennsylvania Power & Light Company; Pumped Storage Site Selection Study.

Directed land use, socioeconomic, aesthetic and archaeological studies and was responsible for assisting a Public Advisory Committee (PAC) in reaching a decision.

New York State Electric 4 Gas Corp.; Somerset Station Unit No.1 Licensing. Directed aesthetic impact studies; estimates of construction worker mobilisation; landscape architecture; recreational multiple use plan.

Public Power Corporation of Greece; First Fuclear Power Station. Site selection studies in southern two-thirds of Greece, including development and analysis of criteria concerning demographic, land use, socioeconomic and aesthetic factors.

Florida Power & Light Company; St. Lucie Unit 2 Nuclear Generating Station. Directed the preparation of demographic, land use, cultural and aesthetic analyses for the environmental report and safety analysis; testified at ACRS hearings, Oct. 1981.

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dage 3 of 4

- KEV 1N P TWINE REPLESENTATIVE ENVIROSPHERE PROJECT EXPERIENCE (Continued)

Louisiana Power & Light company; Waterford Unit 3 Nuclear Generating Station. Directed the preparation of a survey of cons:ruction and operational work forces to determine socioeconomic impacts; performed land use and demographic studies for environmental report and safety analysis.

Directed the gathering and presentation of detailed agricultural information within 50 miles of the St. Lucie 2 and Waterford 3 Nuclear Power Stations.

Directed land use and socioeconomic studies for four synthetic fuels -

plants in central and south-cancral areas of U.S.

Analyzed land use and industrial development implications of a major coal conversion project in New York metropolitan area.

Served as project manager for a review of decontamination and decommissioning methods for radioactive facilities at Oak Ridge National Laboratories; was project manager of an environmental report ar d ,

engineering plan for removal of radioactive wastes from the site of the ,

former Kellex laboratory in Jersey City, NJ.

Regional Planner (4 years)

Areas of responsibility included demographic modeling and projections; use of remote sensing techniques land use surveys and analyses; regional economic analysis; socioeccnomic impact assessments for large projects; land use surveyc and analyses; public services assessment; and community planning.

Projects included:

Developed demographic models for projecting population by annular sector within five and fifty miles of the Waterford Unit 3 Nuclear Generating Station for Louisiana Power & Light Company.

Developed mathematical models to project construction wo-ker influxes and

' location patterns at major energy projects, enabling the assessment of socioeconomic impacts on a town-by-town basis, for the Lake Erie Generating Station, Dunkirk, New York; Niagara Mohawk Power Corporation.

Dafended these codels at New York Public Service Commission hearings, November 1976 - March 1977.

Directed land use and socio-economic analyses for site-selection studies for large coal-fired generating facilities in British Columbia, Canada, and Washington State.

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Page 4 of 4

' KEVIN P TWINE REPRESENTATIVE ENVIROSPHERE PROJECT EXPERIENCE (Continued) ,

Ditected' the preparation of land use and socio-economic assessments for the Philippine Nuclear Power Plant Unic No.1. Philippine National Power Corporation. Prepared the land use and socio-economic elements of the environmental report for the Killen Steam Electric Station, Adams County, Ohio, for the Dayton Power and Light Company.

PRIOR EXPERIENCE (8 years)

- The Fantus Company-Consultant (1 year)

- Florida Land Company-Land Planne* (2 years)

' - Planning: Department, City of Portland, Maine-Consunity Development Coordinator (3 years)

- Gassner, Nathan, Browne - Architects / Planners; '

' Project Manager (1 year) l

- Memphis and Shelby County Planning Commission; Associate Planner (1 year)

PUBLICATIONS AND PAPERS i

Twine, K P 1983. The Use of Landsat as a Cost-Effective Data Resource:

Land Cover Analysis of Multiple Sites (a Case Study). National Conference on Energy Resource Management, San Francisco, CA, August.

Twine, K ? 1982. Usina Satellite Isaaery and Geoaraphic Information Systems. Presented at Seminar on Environmental Impact Assessment: Its Importance, Methods, and Applications, Santo Domingo, Dominican Republic, s

October.

l l Twine, K P 1982. Impact Assessment Methods:- Sociocultural Studies.

Presented at Seminar on Environmental Impact Assessment. Its Importance, Methods, and Applications, Santo Domingo, Dominican Republic, October.

l I Twine. K P, and P H Astor 1979. .Geoaraphic Information Systems In i

Riaht-Of-Way Manasement: The Status And Uses Of Current Computer Technoloay. Presented at the Second Symposium on Environmental Concerns in Rights-of-Way Management, Ann Arbor, Michigan, October.

i Twine, K P 1978. How to pick your plant site. Parts I and II, discussing models for projecting socioeconomic impacts of construction workers at a large electric generating facility, in "The Management Report," Electrical World, August and September.

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UNITED STATES OF AMERICA - ! ._

NUCLEAR REGULATORY COMMISSION  ! gg 10 gg67" {t ;2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

'&r.dkW GEORGIA POWER COMPANY, et al. ) Docket Nos. 50-424

) 50-425 (Vogtle Electric Generating Plant, )

Units 1 and 2) )

l CERTIFICATE OF SERVICE

} I hereby certify that copies of (1) " Applicants' Motion For Summary Disposition i

Of Joint Intervenors' Contention EP-4 (Identification of Existing Hospitals For Treatment of Contaminated Injured Individuals)";

(2) " Applicants' Statement Of Material Facts As To Which No Genuine Issue Exists To Be Heard l Regarding Contention EP-4 (Identification of i Existing Hospitals For Treatment of Contami-l nated Injured Individuals)";

I (3) " Affidavit of Jean N. DiLuzio on Contention EP-4";

(4) " Affidavit of Richard L. Bryant on Contention EP-4";

(5) " Affidavit of Billy J. Clack on

! Contention EP-4";

i (6) " Affidavit of Bobby R. Mauney on Contention EP-4";

(7) " Affidavit of Harold W. Awbrey on Contention EP-4";

(8) " Affidavit of Herman E. Wald on Contention EP-4";

(9) " Affidavit of Anthony Wynn on Contention EP-4"; and L._.

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(10)'" Affidavit of Kevin P. Twine on Contention EP-4";

were served this 6th day of March, 1986, by deposit in the U.S.

mail, first class, postage prepaid, upon the parties listed on the attached Service List, except that those whose names are marked by asterisk were served by hand delivery this 6th day of March, 1986.

YE 'M'h "Dblissa R: Ridcfhay (

Dated: March 6, 1986 I

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, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i Before The Atomic Safety And Licensing Boar.

I In the Matter of )

)

GEORGIA POWER COMPANY, et al. -

) Docket Nos. 50-424 F ) 50-425

(Vogtle Electric Generating Plant, )

Units 1 and 2) )

I i SERVICE LIST i *Morton B. Margulies, Chairman

  • Douglas C. Teper
Atomic Safety and Licensing Board 1253 Lenox circle
U.S. Nuclear Regulatory Commission Atlanta, GA 30306 3

Washington, D.C. 20555 ,

J

  • Tim Johnson ,

]

  • Mr. Gustave A. Linenberger, Jr. Campaign for a Prosperous

! Atomic Safety and Licensing Board Georgia

! U.S. Nuclear Regulatory Commission 1083 Austin Ave. NE j Washington, D.C. 20555 Atlanta, GA 30307

*Dr. Oscar H. Paria Docketing and Service Section
Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission ,

, Washington, D.C. 20555

  • Bernard M. Bordenick, Esq.

, Office of Executive Legal Director Bradley Jones, Esquire D.S. Nuclear Regulatory Commission Regional Counsel Washington, D.C. 20555 U.S. Nuclear degulatory Commission Atcaic Safety and Licensing Suite 3100

, Board Panel 101 Marietta Street l U.S. Nuclear Regulatory Commission Atlanta, GA 30303

, Washington, D.C. 20555

  • j *H. Joseph Flynn, Esquire j Atomic Safety and Licensing Assistant General Counsel Appeal Board Panel Federal Emergency Management l U.S. Nuclear Regulatory Commission Agency

. Washington, D.C. 20555 500 C Street, S.W.

3~

Washington, D.C. 20472 j

  • Steven M. Rochlis Regional Counsel l Federal Emergency Management

. Agency l 1371 Peachtree Street, N.E. #700 l Atlanta, Georgia 30309 i l l

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