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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
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D March 10, 1986 UNITED STATES OF AMERICA [ c; NUCLEAR REGULATORY COMMISSION (Q\;c BEFORE THE ATOMIC SAFETY AND LICENSING BOARD r C{ I 1 19Wyn B93%e S In the Matter of )
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GEORGIA POWER COMPANY, et; al . ) Docket Nos. 504424 9 s
) 50-425 (Vegtle Electric Generating Plant, )
Units 1 and 2) )
AFFIDAVIT OF KEVIN P. TWINE ON CONTENTION EP-2/EP-2(h)
COUNTY OF BERGEN )
)
STATE OF NEW JERSEY )
! I, Kevin P. Twine, being duly sworn according to law, de-pose and say as follows:
i 1. My name is Kevin P. Twine. I am employed by Ebasco Services, Inc. as Manager, Resources Planning. Ebasco has been retained by Georgia Power Company to coordinate offsite emer-l gency planning activities for the Vogtle Electric Generating Plant, including coordination with the Savannah River Plant j ("SRP"). I am Project Manager for the Ebasco Vogtle Project.
My business addreas in Atlanta is 145 Technology Park / Atlanta, Norcross, Georgia 33092. A summary of my professional qualifi-l cations is attached to this affidavit as Exhibit A.
- 2. The purpose of this affidavit is to support "Appli-cants' Motion for Summary Disposition of Joint Intervenors' l
l N g4
r e
O Contention EP-1/EP-2(h)," which concerns the provision of emer-gency public information for transients within the Vogtle plume exposure pathway Emergency Planning Zone ("EPZ"). I have per-sonal knowledge of the matters set forth herein and believe them to be true and correct.
- 3. By definition, all persons in Savannah River Plant
("SRP")-controlled areas of the Plant Vogtle plume exposure EPZ are considered to be transients. These transients fall into seven categories:
(1) Personnel working in fixed SRP facili-l ties (2) Department of Energy (" DOE") or con-tractor personnel working outdoors within 'he Plant Vogtle EPZ (3) Forest Service personnel and contrac-tors working within the Plant Vogtle EPZ (4) Hunters onsite during deer-hunting season (5) Hunters in the Crackerneck Section of the Sumter National Forest (National Forest land secured by the SRP)
(6) Motorists transiting the SRP site on Route 125 (7) Railroad personnel passing through the SRP site The identification of these transient populations is the result of extensive, detailed consultation with SRP personnel. A com-prehensive program has been designed to assure that these tran-sients are provided with information needed for response to a 1
J l
1 i
Vogtle emergency. This program will be fully implemented prior to fuel load at Vogtle.
- 4. 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 involving all employees at each facility several times a year.
DOE and DOE-contractor personnel working out-of-doors and away from fixed facilities in the EPZ receive, at a minimium, an 1
orientation program outlining warning procedures and required responses to notification of an cmergency. In addition, signs, flyers, and printed instructions (e.g., emergency procedures summarized on the back page of all SRP telephone books) are used to continually remind all employees of emergency proce-l dures.
- 5. U.S. Forest Service personnel and timber contractors working within the SRP portion of the Plant Vogtle EPZ receive an orientation including information on means of emergency no-tification, emergency conditions, and protective actions prior to their entry to the work site.
- 6. Hunters 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 Forest is also controlled by SRP, and is granted only to those 1
9 persons with both a South Carolina Game Management Permit and a special DOE permit. Access is restricted to specific hours, and all hunters must sign in and out on a log sheet maintained by Security Contractor personnel at the only entrance to the property. Each person entering the area recei"es an orienta-tion card describing notification procedures and protective ac-tions in case of a radiological emergency.
- 7. Motorists traveling on Route 125, which traverses the l EPZ, must pass through security barricades operated continuous-l ly by SRP. All vehicles receive passes and are time-checked to verify that they have completed their passage in a normal period of time. Upon notification of an emergency at Plant l
Vogtle, the SRP Emergency ' Operating Center would notify the Se- ,
curity Contractor personnel at the barricades to close SRP to civilian traffic. Motorists on Route 125 within the SRP bound-aries then would be intercepted by mobile patrols and directed away from hazardous areas if necessary. The stringent controls i
of SRP staff over the movement of motorists on Route 125, and their ability to provide personal notification and instructions to those motorists in the event of an emergency, obviate the need for specific pre-emergency public information measures t
directed at the motorists.
l
- 8. The Seaboard Coast Line (a freight railraod) also traverses the SRP portion of the EPZ. Prior to fuel load at Vogtle, and annually thereafter, Georgia Power Company will 1
provide the railroad with a supply of the South Carolina edi-tion of the Vogtle emergency public information brochure,
" Safety Information -- Plans To Help You During Emergencies,"
for distribution to all railroad employees who work within the EPZ.
- 9. Thus, adequate measures are being taken to assure that all transients on the SRP site will respond appropriately in the event of an emergency at Plant Vogtle.
! $YW f &L 6* L '
\ Kevid P. Twine I
i Sworn to and subscribed before me this fe/" day of Feb ry, 1986. '
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My Ccannission expires:
y .bO, / VVO l
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- , , - - , , _ _ _ - _ _ - _ . - - - - - , , - _ . - - - - - . _ _ - _ _ - , . - - _ - - - _ _ _ . - _ _ _ _ _ - - _ _ _ - - - - - . - _ . - - , _ _ ---_______.-___--____--__-__-___.-_______---__---_-_-----__-__----a
a Exhibit A a
2/86 Page 1 of 4 KEVIN P TWINE Manager - Resources Planning
SUMMARY
OF EXPERIENCE (Since 1967)
Total Experience - Eighteen years experience including supervision and direction of numerous projects involving demographic, land use, traffic / transportation and socioeconomic impact and environmental assessment analyses.
Professional Affiliations - Americat Society of Photograssetry Education - MRP, University of North Carolina,1967 - Regional Planning RA, Wesleyan University,1965 - History REPRESENTATIVE ENVIROSPHERE PROJECT EXPER.IENCE (Since 1974)
Manager - Resources Planning Responsibilities include management of Envirosphere Staff involved in land use, traffic / transportation, socioeconomic, aesthetic, and ,
archaeological disciplines; direction of research in these fields; ,
sanagement of projects relating to resources planning; management of Envirosphere's Land Resources Analysis Systes (LRAS) for satellite imagery analysis and computerized geographic studies; expert testimony before regulatory bodies.
Projects include Georgia Power Co. Vogtle Electric Generating Plant. Project manager for offsite emergency preparedness planning progras. Responsibilities included contract management; management of subcontractors; and management of tasks in plan and procedure preparation, alert and notification systes, corporate and consunications planning, exercise preparation, and preparation of documents for ASL3 hearings. Areas for which plans were carried out included three counties in South Carolina, USDOE Savannah River Plant, and Burke County, Georgia.
Carolina Power & Light Co. Shearon Harris Nuclear Power Plant. Served as technical project manager for licensing support concerning off-site emergency and evacuation planning. Work involved excessive contacts with local and state government officials, utility officials, and lessi counsel, as well as demographic analyses and planning for shelter and evacuation.
Holyoke Energy Recovery Company; Environmental Impact Report for i Weste-to-Energy Facility in Holyoke, MA. Conducted analysis of the '
impact of increased truck traffic on urban roadway systes; study included traffic counts, volume / capacity ratio calculations, optimization of truck routes, and sitigation recoseendations.
0021G
a Page 2 of 4 KEVIN P TWINE REPRESLNTATIVE ENVIROSPHERE PROJECT EXPERIENCE (Continued)
TRC Environmental Consultants, Inc; Data Base for Air Quality Materials Damage Study. Gathered land use, demographic, and air quality data and incorporatsd it into a computerized data base for use in an air quality sacerials disage study. Data base was organized in two formats: 9,000
-ka square grid cells; and 1200 census tracts. Study area was Southern California Air Basin (Los Angeles area).
Kansas Gas and Electric Company (KG&E); Wolf Creek Nucitar Generating Station. Directed a 3 person field tecs in a four sonth comprehensive offsite emergency and evacuation planning effort for Coffey County, Kansas (location of Wolf Creek Nuclear Plant) ,and the State of Kansas.
Functioned as pa ,c of KC&E staff. Prepared witnesses and developed testimony for hatrings. Reviewed, revised and prepared offsite energency plans and impleetsting procedures. Interfaced closely with county and state officials.
Louisiana Powat & Light Company; Waterford 3 Nuclear Generating Station.
Directed the preparation of Evacuation Time Estimate, 1980 and 1982; -
testified in .sfense of findings at hearings of Atomic Safety and '
Licensing Boa:J, May,1982; directed preparation of detailed analysis of large evacuation which took place in Waterford 3 vicinity as a result of an industrial accident on December 11, 1982.
Consolidated Ediaon Company of New York; Site Selection Study for Coal Burning Waste Diiposal Facility. Directed preparation of demographic, land use, and aes)hetic elements of site selection study; performed ,
analysis of satell'te laagery on LRAS for input to site selection l procedure. l Pennsylvania Power a Light Company; Pusped Storage Site Selection Study.
Directed land use, socioeconomic, aesthetic and archaeological studies and was responsible for assisting a Public Advisory Consittee (PAC) in reaching a decision.
New York State Electric & Cas Corp.; Somerset Station Unit No.1 Licensing. Directed testhetic impact studies; estimates of construction worker mobilization; Landscape architecture; recreational multiple use plan. .
Public Power Corporacit'n of Greece; First Nuclear Power Station. Site selection studies in southern two-thirds of Greece, including development and analysis of criterit concerning demographic, land use, socioeconomic and aesthetic factors. ,
l l
Florida Poser & Light Conpany; St. Lucie Unit 2 Nuclear Generating i Station. Directed the ptoparation of demographic, land use, cultural and aesthetic analyses for the environmental report and safety analysis; testified at ACRS hearingst, Oct. 1981.
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KEV 1h P TWINE i
4h REPRESENTATIVE ENVIROSPHERE PROJECT EXPERIENCE (Continued) 9 Louisiana Power & Light Company: Waterford Unit 3 Nuclear Generatingh Station. Directed the preparation of a survey of construction and operational work forces to determine socioeconomic impacts; performed t landuseanddemographicstudiesforenvironmentalreportandsafety\
analysis.
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t~ N
'h Directed the gathering and presentation of detailed agricultural ,
information within 50 miles of the 54.' Lucie 2 and Waterford 3 Nuclear t Power Stations. s , (,,
\,,
g3 Directed land use and socioeconomic studies for four synthetiolfkals" i plants in central and south-central areas of U.S. W (
4 Analysed land use and industrisi development implications of a major' coal conversion project in New York metropolitan area. _
Served as project manager for a review of decontamination and '
decossissioning methods for radioactive facilities at Oak Ridge National Laboratories; was project manager of an environmental report and
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i engineering plan for removal of radioactive wastesefrom the site of the , ,
former Kelles laboratory in Jersey City, NJ. ,
Regional Planner (4 years) ,
Areas of responsibility included demographic modeling and p ojections; use of remote sensing techniques land use surveys and analyses regional ~ '
i I
economic analysis; socioeconomic impact assessments for 1arge projects:
land use surveys and analyses public services assessment; and community planning. y Projects included
, u
) Developed demographic models for projecting populatica uy annular sector i j within five and fifty siles of the Waterford Unit 3 Nu'elear Generating '
i Station for Louisiana Power & Light Company. ,
1 Developed matheastical models to project construction worker influses and location patterns at major ene.sy projects, enabling the assessment of i socioeconomic impacts on a towr.-by-town basis, for the Lake Erie Generating Station, Dunkirk, N w York Niagara Mohawk Power Corporation.
j Defended these models at New York Public Service Consission hearings, November 1976 - March 1977.
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- Directed land use and socio-ecor.oeic analyses ior site-selection studies for large coal-fired generating facilities in British Columbia, Canada, and Washington State. ;
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I Page 4 of 4 KEVIN P T'4INE REPRESENTATIVE ENVIROSPHERE PROJECT EXPERIENCE (Continued)
Directed the preparation of land use and socio-economic assessments for :
the Philippine Nuclear Power Plant Unit No.1. Philippine National Power i Corporation. Prepared the land use and socio-economic elements of the environmental report for the Killen Steam Electric Station, Adams County, !
Chio, for the Dayton Power and Light Company.
PRIOR EXPERIENCE (8 years)
- The Fantus Company-Consultant (1 year)
- Florida Land Company-Land Planner (2 years)
I
- Planning Departtaent, City of Portland, Maine-Community Development Coordinator (3 years) 7
- Gassner, Nathan, Browne - Architects / Planners; Project Manager (1 year) l 1 .
- Memphis and Shelby County Planning Consissions , ;
Associate Planner (1 year) t PUBLICATIONS AND PAPER $_
1 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 P 1982. Usina Satellite Isamery and Geoaraphie Information Systems. Presented at seminar on Environmental Impact Assessment: Its Importance, Methods, and Applications, Santo Domingo, Dominican Republic.
October.
Twine, K P 1982. Isosct Assessment Methods: Sociocultural Studies.
Presented at Seminar on Environmental Ispact Assessment. Its importance, Methods, and Applications, Santo Domingo, Dominican Republic, October.
Twine, K P, and P H Astor 1979. Geoaraphic Information Svatees In Riaht-of-Way Mansmesent The Status And Uses Of Current Computer Technology. Presented at the Second Symposius on Environmental Concerns in Rights-of-Way Management Ann Arbor, Michigan, October.
Twine, K P 1978. How to pick your plant site. Parts I and II, discussing sodels for projecting socioeconomic impacts of construction workers at a large electric generating facility, in "The Management Report," Electrical Worid, August and September.
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