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Category:AFFIDAVITS
MONTHYEARML20094J9201995-11-0101 November 1995 Affidavit of Ck Mccoy to Correct Info Contained in Intervenor Exhibit II-97,which Consists of Portions of Deposition in a Mosbaugh Complaint Against Gap ML20092M6721995-09-28028 September 1995 Affidavit.* Affidavit of Gr Frederick Re Recollection of Recommendation Made to Keep Special Record of Diesel Testing Activities ML20092M6771995-09-28028 September 1995 Affidavit.* Affidavit of H Handfinger Re Review of Documents & Amount of Involvement of Quality Control Organization. W/Certificate of Svc ML20092H6621995-09-20020 September 1995 Affidavit.* Affidavit of MD Duncan Re Testimony on 950609, Concerning Alnor Test Instrument ML20092H7211995-09-19019 September 1995 Affidavit of J Lamberski.* Discusses Violations of NRC Regulations at Plant,Filed by a Mosbaugh W/Nrc.W/Certificate of Svc & Svc List ML20092H7891995-09-13013 September 1995 Affidavit.* Affidavit of Kc Stokes Certifying That Statements & Opinions in Such Response True & Correct to Best of Personal Knowledge & Belief.W/Certificate of Svc ML20087C0621995-07-31031 July 1995 Affidavit.* Affidavit of D Huyck Providing Info Re Entrances & Exits for Secured Areas of Plant by E Dixon ML20085M1601995-06-23023 June 1995 Affadavit.* Affidavit of J Aufdenkampe Re Info Re Reporting of Safety Sys Performance Indicator Data ML20083L5161995-05-12012 May 1995 Affidavit of Kr Holmes Discussing Evaluation of Test Plan for 1A Diesel Following 900320 Site Area Emergency,In Order to Determine Root Cause of 900320 Diesel Failure ML20083L5801995-05-11011 May 1995 Affidavit of G Bockhold,Describing Decision Making Involved W/Util Determination as of 900409,that Plant Diesels Operable & Capable of Performing Intended Safety Functions ML20080S9301995-03-0303 March 1995 Affidavit of Ck Mccoy Re Events Surrounding Util Statements to NRC in Respecting Plant DG Instrument Air Quality ML20080E1021994-12-27027 December 1994 Affidavit of Lk Stevens Re Review of Public Affairs Dept Files,Including Articles,Speeches & Press Releases Re Formation of Sonopco Project or Southern Nuclear Operating Co ML20080E0951994-12-23023 December 1994 Affidavit of LB Long Re Formation of Sonopco Project or Southern Nuclear Operating Co Concerning Files in Possession of Employee While Under Util Employ ML20080E1011994-12-22022 December 1994 Affidavit of T Wright Re Review of Util Publication Entitled This Week for Documents Dealing W/Sonopco Project or Southern Nuclear Operating Co from 880101-901231 ML20076K1431994-10-13013 October 1994 Affidavit of MD Kohn.* Affidavit Stating That Author Has first-hand Knowledge Re Factual Assertions That Represent Substance of Corresponding Statements Made by Deponent in Author Presence ML20024J3051994-10-0303 October 1994 Affidavit of Fr Allenspach & Ds Hood Re Util Motion for Summary Disposition of Alleged Illegal Transfer.* Informs That No Error Found in Factual Assertions of Util. W/Certificate of Svc ML20070A8961994-06-22022 June 1994 Affidavit of John O Meier.* Certifies That Listed Statements True & Correct to Best of Personal Knowledge & Belief. W/Certificate of Svc ML20029D9421994-05-0606 May 1994 Affidavit of Mj Wilmoth.* Affidavit Re 940412 Conversation W/M Kohn Re Close Call When Red Sports Car at Corner of Ofc Building of Troutman Sanders,Nearly Missed Running Him Down ML20059L9891993-11-0808 November 1993 Affidavit of Wg Hairston Re Reputation of Util & Mgt Continuing to Be Adversely Affected by Stigma Associated W/Wilful Wrongdoing.W/Certificate of Svc ML20059E9071993-10-27027 October 1993 Affidavit of RA Fortuna.* Requests That Investigation Matls Collected During Ongoing Investigation Be Withheld from Disclosure at Least Until 940218 to Allow More Time for Completion of Review.W/Certificate of Svc ML20059E8981993-10-27027 October 1993 Affidavit of J Lieberman.* Requests That Investigatory Matls Collected During Ongoing Investigation Be Withheld from Disclosure at Least Until After 940218 ML20056G5231993-08-25025 August 1993 Affidavit of J Lieberman.* Provides Info Re Status of Ofc of Enforcement Activities Re Alleged Violations of NRC Requirements by Util to Support NRC Request That Board Defer Decision on Util Motion.W/Certificate of Svc ML20056G5221993-08-24024 August 1993 Affidavit of Bb Hayes.* Provides Info Re Status of Ofc of Investigations Activities Re Investigation of Alleged Misconduct by Util Re Reporting of Diesel Generator Reliability ML20045G9721993-07-0101 July 1993 Affidavit.* Affidavit of AL Mosbaugh Re Statements & Opinions Set Out in Intervenor Response to Licensee First Set of Interrogatories.W/Certificate of Svc ML20045G9341993-06-30030 June 1993 Affidavit.* Affidavit of AL Mosbaugh Re Statements & Opinions Set Out in Intervernor Supplemental Responses to Util First Set of Interrogatories.W/Certificate of Svc ML20045D2351993-06-0909 June 1993 Affidavit of MD Kohn in Support of AL Mosbaugh ML20045D2411993-06-0808 June 1993 Affidavit of AL Mosbaugh.W/Certificate of Svc ML20083B6691991-09-0606 September 1991 Affidavit of G Carroll Re Georgians Against Nuclear Energy Interest Re Appropriate Testing Schedule for Facility Being Inadvertently Omitted from 910809 Amend to Petition for Leave to Intervene.W/Svc List ML20076N1231991-03-18018 March 1991 Affidavit of Jd Lisenby in Support of Applicant Response to Board 910122 Memorandum & Order ML20076N1461991-03-15015 March 1991 Affidavit of Kc Stokes in Support of Applicant Response to Board 910122 Memorandum & Order ML20076N1501991-03-11011 March 1991 Affidavit of C Meyer in Support of Applicant Response to Board 910122 Memorandum & Order ML20076N1121991-03-0707 March 1991 Affidavit of Wf Kitchens in Support of Applicant Response to Board 910122 Memorandum & Order ML20076N1321991-03-0707 March 1991 Affidavit of L Ward in Support of Applicant Response to Board 910122 Memorandum & Order ML20062F7231990-11-14014 November 1990 Affidavit of L Ward in Support of Applicant Supplemental Statement Re Matters Raised by Board.* W/Supporting Info & Certificate of Svc ML20059M0211990-09-18018 September 1990 Affidavit of DB Matthews in Support of NRC Staff Response in Opposition to Georgians Against Nuclear Energy Amended Petition for Leave to Intervene ML20214W2381986-12-0303 December 1986 Affidavit of Sj Cereghino,Wv Cesarski & G Bockhold Re Statements in Hm Deutsch 861126 Affidavit.Certificate of Svc Encl.Related Correspondence ML20214W1791986-12-0202 December 1986 Affidavit of Sj Cereghino & Wv Cesarski Re Temp Margins in Environ Qualification by Thermal Lag Analysis of Asco Valve Models NP-8616,NP-8320 & NP-8321.Related Correspondence ML20214P4331986-11-26026 November 1986 Affidavit of Hm Deutsch in Response to ASLB Reopening Matter Re Safety & Qualifications of Asco Valves. Certificate of Svc Encl.Related Correspondence ML20214P3951986-11-25025 November 1986 Affidavit of a Masciantonio in Response to Sj Cereghino & Wa Cesarski 861028 Affidavit & Board 861106 Memorandum & Order Reopening Record of OL Proceeding on Contention 10.5 Re Asco Solenoid Valves.Certificate of Svc Encl ML20214A5961986-11-14014 November 1986 Affidavit of RM Bellamy Re New Allegations Raised by Georgians Against Nuclear Energy.Notice of Appearance & Certificate of Svc Encl ML20211H4531986-10-28028 October 1986 Affidavit of Sj Cereghino & Wv Cesarski Confirming That Asco Solenoid Valves Used in Facility Environmentally Qualified W/Sufficient Margin & Will Function Under Normal & Accident Conditions.Certificate of Svc & Svc List Encl ML20214L6101986-09-0404 September 1986 Supplemental Affidavit of Kp Twine Re Contention EP-5. Savannah River Plant Emergency Plan Will Be Amended to Include Info Re Location of Reception Ctrs & Ctr Capacities ML20211N6521986-06-27027 June 1986 Supplemental Affidavit of Cl Stovall Supporting Proposed Changes to Emergency Plans for State of Ga & Burke County Re Medical Treatment of Contaminated Injured Individuals & 24 H Manning of Communication Links.Related Correspondence ML20206D8321986-06-16016 June 1986 Affidavit of Kp Twine in Support of Applicant Motion for Summary of Disposition of Joint Intervenors Contention EP-5 Re Capacity of Schools Receiving Evacuees from Emergency Planning Zone ML20198A0161986-05-13013 May 1986 Supplemental Affidavit of Cl Stovall in Response to Applicant Motion for Summary Disposition of Contention EP-5 Re Reception Ctr Capacity.Adequate Emergency Facilities Will Be Readily Available.Certificate of Svc Encl ML20155G7681986-04-22022 April 1986 Affidavit of Cl Stovall Supporting Applicant Motion for Reconsideration of Denial of Summary Disposition of Intervenor Contention EP-2/EP-2(c) Re Use of NOAA Tone Alert Radios.Certificate of Svc Encl ML20203D5771986-04-16016 April 1986 Supplemental Affidavit of Dn Keast on Contention EP-2/EP-2(C) Re Use of NOAA Tone Alert Radios for Public Alerting.Certificate of Svc Encl ML20203B7311986-04-15015 April 1986 Affidavit of Cl Stovall Supporting Applicants 860310 Motion for Summary Disposition of Contention EP-2/EP-2(h) Re Public Info for Transients ML20203B6151986-04-11011 April 1986 Affidavit of Cl Stovall in Response to Applicant 860310 Motion for Summary Disposition of Contention EP-5 Re Reception Ctr Capacity.Certificate of Svc Encl ML20203B4061986-04-0909 April 1986 Affidavit of Cl Stovall in Support of Applicant 860306 Motion for Summary Disposition of Contention EP-4 Re Identification of Existing Hosps for Treatment of Contaminated Injured Individuals.Certificate of Svc Encl 1995-09-28
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196J3291999-06-28028 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Industry Codes & Standards ML20206M7291999-04-30030 April 1999 Comment Supporting Draft RG DG-1083, Content of UFSAR IAW 10CFR50.71(e). Licensee of Listed Plants in Total Agreement with Comments Provided to NRC by NEI HL-5717, Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC1998-12-18018 December 1998 Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC HL-5715, Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments1998-12-14014 December 1998 Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments HL-5702, Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols1998-10-23023 October 1998 Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols HL-5695, Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers1998-10-13013 October 1998 Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers HL-5690, Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC1998-10-0505 October 1998 Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC HL-5983, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed1998-09-21021 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed ML20153B2391998-09-15015 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Ki as Protective Action During Severe Reactor Accidents. Endorses NEI Comments HL-5682, Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute1998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds HL-5586, Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps1998-03-0404 March 1998 Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps HL-5582, Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events1998-02-27027 February 1998 Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events HL-5564, Comment on Draft NUREG 1555, Updated Environ Standard Review Plan1998-01-30030 January 1998 Comment on Draft NUREG 1555, Updated Environ Standard Review Plan HL-5554, Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public1998-01-15015 January 1998 Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public HL-5546, Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements1997-12-31031 December 1997 Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements HL-5529, Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard1997-12-0101 December 1997 Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard ML20199J0031997-11-24024 November 1997 Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060 HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions1997-07-0707 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions ML20148N0741997-06-19019 June 1997 Comment on Proposed Suppl to Bulletin 96-001 Re Control Rod Insertion Problems.Util in Complete Agreement That Incomplete Rcca Insertion Not Acceptable HL-5407, Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ1997-05-27027 May 1997 Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ ML20137C2581997-03-18018 March 1997 Summary of Director'S Decision Under 10CFR2.206 of Mb Hobby & AL Mosbaugh, ML20137C4261997-03-18018 March 1997 Director'S Decision Under 10CFR2.206 Re Petition Re Allegation of Illegal Transfer of OLs to Southern Nuclear Operating Co.Petitions Filed by Mb Hobby & AL Mosbaugh Denied HL-5268, Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols1996-11-27027 November 1996 Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols ML20133H1131996-11-25025 November 1996 Petition for Enforcement,Per 10CFR2.206,to Revoke Northeast Utils Operating Licenses for CT Nuclear Power Stations Due to Chronic,Systemic Mismanagement Resulting in Significant Violations of NRC Safety Regulations ML20129J5481996-10-30030 October 1996 Order.* Extends Time within Which Commission May Take Sua Sponte Review of Memorandum & Order LBP-96-16 to 961129. W/Certificate of Svc.Served on 961030 ML20129K4291996-10-0202 October 1996 Comment Supporting Proposed Rule 10CFR25 & 95, Access to & Protection of Classified Info HL-5247, Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations1996-10-0101 October 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20128K2791996-09-30030 September 1996 Order.* Time within Which Commission May Take Sua Sponte Review of Memo & Order LBP-96-16 Extended Until 961030. W/Certificate of Svc.Served on 960930 ML20116J8921996-08-0202 August 1996 Withdrawal of AL Mosbaugh.* AL Mosbaugh Voluntarily Withdraws Intervention,Opposition & Contention in Proceedings.W/Certificate of Svc & Svc List ML20116J8551996-08-0202 August 1996 Joint Notice of Termination.* AL Mosbaugh Voluntarily Withdrew Intervention,Opposition & Contentions in Proceeding.W/Certificate of Svc & Svc List ML20116J8431996-08-0202 August 1996 Intervenor Response to Georgia Power Motion for Reconsideration.* Intervenor Supports Motion for Reconsideration.W/Certificate of Svc & Svc List ML20116N5881996-07-31031 July 1996 Comment Re Proposed Rule 10CFR26, Mods to Fitness-For-Duty Program Requirements. Supports NEI Comments ML20116A4931996-07-15015 July 1996 Georgia Power Company Motion for Reconsideration of 960628 Memorandum & Order Or,In Alternative,For Certification.* Gpc Requests That Board Not Require Submittal or Approval of Settlement Between Gpc & Mosbaugh.W/Certificate of Svc ML20115H2671996-07-0808 July 1996 Comment Supporting Final Rule 10CFR51, Environ Review of Renewal of Nuclear Power Plant Operating Licenses HL-5195, Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20114E6491996-06-20020 June 1996 Joint Motion to Defer Issuance of Initial Decision.* Requests That ASLB Defer Issuance of Decision in Proceeding Until 960920,in Order to Allow Gpc & Mosbaugh to Reach Settlement Agreement.W/Certificate of Svc IA-95-211, Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-391996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 ML20129H7151996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 HL-5103, Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use1996-02-0606 February 1996 Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use ML20096A4911995-12-22022 December 1995 Georgia Power Co Reply to Intervenor & NRC Staff Proposed Findings of Facts & Conclusions of Law.* W/Certificate of Svc ML20095D9821995-12-12012 December 1995 Georgia Power Co Motion to Correct Record of Exhibits of Diesel Generator Reporting Issues Allegation Hearing.* W/Certificate of Svc ML20095D9771995-12-0808 December 1995 Comment on Proposed Generic Ltr Boraflex Degradation in Spent Fuel Pool Starage Racks. Request for Licensees to Demonstrate Subcriticality Margin in Unborated Water,Seems Inconsistent W/Stated Benefit of Borated Water ML20094S2751995-11-30030 November 1995 Intervenor Final Statement of Fact & Conclusions of Law.* Board Finds That Util & Applicant Failed to Meet Burden of Proof Re Ultimate Issue of Character,Competence & Integrity. W/Svc List ML20094S2411995-11-22022 November 1995 Georgia Power Co Response to Intervenors Motion for Continuance.* Intervenor Motion Unjustified & Prejudicial & Should Be Denied.W/Certificate of Svc & Svc List ML20094S2931995-11-21021 November 1995 Intervenor Motion for Continuance for Good Cause.* Requests Deadline for Filing Post Hearing Brief Be Extended Until 951130.W/Certificate of Svc & Svc List ML20094K1161995-11-0909 November 1995 Intervenor Motion to Admit Supplementary Exhibits.* Moves That Naslp Admit Encl Documents Into Evidence for Listed Reasons.W/Certificate of Svc & Svc List ML20094J9301995-11-0606 November 1995 Georgia Power Company Motion to Correct Record of Diesel Generator Reporting Issues Allegation Hearing.* Moves Licensing Board to Order That Corrections Be Made to Transcript.W/Certificate of Svc & Svc List ML20094J9281995-11-0606 November 1995 Gap Proposed Findings of Fact & Conclusions of Law on Diesel Generator Reporting Issues.* Findings of Fact & Conclusion Accepted.W/Certificate of Svc ML20094J9201995-11-0101 November 1995 Affidavit of Ck Mccoy to Correct Info Contained in Intervenor Exhibit II-97,which Consists of Portions of Deposition in a Mosbaugh Complaint Against Gap 1999-06-28
[Table view] |
Text
._ ._
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.
~~
) 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
- o' l
.. 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.
+
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.
g ,# ,__;
[' A c n e. e.
Kevih P. Twine Sworn to aro nubsc before me this /'/ yibed day of February, 1986.
)
/
- hLu..as ..k - fillh a'u ; '
Notary Pubfic/ ROSEMARY SCRIMENTI
/ NOTARY PUJUC OF (Ol/ .muy MY C0*G.:2.*6 fu tr n a gj My Commission Expires:
'hp f de, s 'i 'h o
Exhibit A 2/86 Page 1 cf 4 i
' ~
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.
0021G l
i
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Page 2 of.4
~
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.
0021G
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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' 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.
0021G
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, gezwm -
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._.
1 d.
i l'
(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
e e.
l i
, 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
- Atomic Safety and Licensing Board 1253 Lenox circle
- U.S. Nuclear Regulatory Commission Atlanta, GA 30306 3
Washington, D.C. 20555 ,
J
]
- 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
- - ... --