ML20138A599
| ML20138A599 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/10/1986 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20138A591 | List: |
| References | |
| OL, NUDOCS 8603140327 | |
| Download: ML20138A599 (10) | |
Text
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UNITED STATES OF AMERICA O
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I BEFORE THE ATOMIC SAFETY AND LICENSING BO DOQCDNa g g$k{TQic;t V
In the' Matter of
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GEORGIA POWER COMPANY, et al.
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Docket Nos. 50-424
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50-425 (Vogtle Electric Generating Plant, )
Units 1 and 2)
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APPLICANTS' STATEMENT OF MATERIAL FACTS AS.TO WHICH NO GENUINE ISSUE EXIST 3 TO BE HEARD REGARDING CONTENTION EP-5 (RECEPTION CENTER CAPACITY)
Pursuant to 10 C.F.R.
$ 2.749(a), Applicants state in sup-port of " Applicants' Motion for Summary Disposition of Joint Intervenors' Contention EP-5" that no genuine issue exists to be resolved with respect to the following material facts:
1.
As admitted by the Board, Joint Intervenors' Conten-tion EP-5 concerns the capacity of the reception centers for evacuees from the Vogtle plume exposure pathway Emergency Plan-ning Zone ("EPZ").
2.
In an actual evacuation, not all evacuees would ar-rive at reception centers at the same time.
Rather, arrivals at reception centers would be staggered, so that many who ar-rive early in the evacuation would be processed and then per-mitted to leave the reception centers (for motels or homes of friends or family outside the EPZ) before the later evacuees arrive.
Nevartheless, for purposes of identifying reception 9603140327 960310 PDR ADOCK 05000424 O
PDR 1
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1 center capacity,Lthe-four counties in the EPZ have conserva-
.tively assumed that.all EPZ evacuees.would arrive simulta-neously, and have planned accordingly.
Bryant Affidavit'at 1 6; Maunay Affidavit at 1 3; Awbrey Affidavit at 1 3.
Burke County 3.
Burke County has designated four Waynesboro schools as reception car.ters:
the Burke County Comprehensive E4.gh School (which would be'available for use as a reception center by December 1986 and will be open to students no later than SeptemberL1987); the "old" Waynesboro High School; Waynesboro Elementary School; and the Blakeney Elementary and Junior High Schools.
Bryant Affidavit at 1 3.
4.
In assessing the capability of these reception cen--
ters to accommodate evacuees from the Vogtle EPZ, Burke County examined three scenarios:
Scenario A:
The Burke County Comprehensive High School is available for evacuee recep-tion, but is not open-for students (maximum time period of this scenario is December, i
1986 to September, 1987).
Scenario B:
The Burke County Comprehensive High School is.in use as a school, with
' students present, j
Scenario C:
The same as Scenario B, except that construction has been completed at Vogtle Unit 2.
In each scenario, it was assumed that school was in session.
Bryant Affidavit at 1 5.
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5.
All Burke County analyser assume a need for Burke County to process the entire Vogtle work force at Burke County reception centers.
This is a very conservative assumption, since plant personnel will generally be processed onsite, and then released to go to their homes.
Therefore, in most Jemergencies -- where an eva'cuation occurs prior to the release of radiation offsite -- only those plant personnel who reside I
within the EPZ.would actually report to reception centers.
Bryant Affidavit at 1 7 n.1.
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l Scenario A l
6.
In Scenario A, the Burke County Comprehensive High School (not yet open to students) will accommodate 5,980 evacuees'for processing.
All students at the remaining schools can be accommodated in the classrooms of their schools, leaving the common areas immediately available to receive 2,850 evacuees.
Thus, the reception centers provide a combined ca-7 pacity for 8,830 evacuees in Scenario A.
Bryant Affidavit at 4
1 8.
7.
Under Scenario A, there would be a total maximum of approximately 7,195 evacuees from the Burke County portion of l
the EPZ.
Therefore,.there is sufficient capacity at Burke County reception centers under Scenario A -- even with students present, and even assuming that all evacuees arrive at recep-tion centers simultaneously.
Bryant Affidavit at 11 9-10.
Scenario B 8.
In Scenario B, all Burke County Comprehensive High School students can be accommodated in the classrooms of the school, leaving the common areas immediately available to re-ceive 4,675 evacuees.
The remaining schools can accommodate 2,850 evacuees in cominon areas, with students present.
- Thus, the reception centers provide a combined capacity for 7,525 evccuees in Scenario B.
Bryant Affidavit at 1 11.
9.
Under Scenario B, there would be a total maximum of aproximately 6,995 evacuees from the Burke County portion of the EPZ.
Therefore, there is sufficient capacity at Burke County reception centers under Scenario B -- even with students present, and even assuming that all evacuees arrive at recep-tion centers simultaneously.
Bryant Affidavit at 11 12-13.
Scenario C 10.
Scenario C would be the same as Scenario B, except that only operating staff would be present at Plant Vogtle.
This staff would number approximately 700, which is substan-tially less that the estimated 4,940 plant workers who might require reception if an emergency were to occur before con-struction of Unit 2 is completed.
Therefore, in Scenario C, the maximum number of evacuees to be processed at reception centers would drop dramatically, while the available capacity.
would remain the same as for Scenario B.
Bryant Affidavit at 1 14.
11.
The above analyses demonstrate conclusively that the schools identified as reception centers by Burke County have sufficient capacity to accommodate the maximum number of EPZ evacuees -- even with students present at the schools, and even assuming that all evacuees arrive at reception centers sinulta-neously.. Bryant Affidavit at 1 15.
12.
If still more capacity was desired, school officials would dismiss students who were not esidents of the evacuated r
area-(a process estinated to require a total of approximately 1 1/2 hours), providing capacity for approximately 4,310 addi,-
tional persons.
Bryant Affidavit at 1 15.
13.
The " Burke County Emergency Management Agency Ra-diological Emergency Plan For Nuclear Incidents / Accidents Involving Vogtle Electric Generating Plant" is being amended to list the Blakeney schools as reception centers.
Bryant Affida-vit at 1 16.
14.
The revised plan will specify the capacity of each of the schools identified as reception centers (with and without t
students present), and will state that the schools have suffi-cient capacity (even with students present) to accommodate the maximum number of evacuees frem the Burke County portion of the Vogtle EPZ.
Bryant Affidavit at 1 16.
15.
Thus, Burke County has given adequate consideration to the ready availability of schools for use as reception cen-ters-in the event of a radiological emergency at Vogtle.
Bryant Affidavit at 1 16.
Aiken County 16.
In the event of an emergency at Plant Vogtle during a
-school day, a maximum of approximately 200 persons would be evacuated from that part of the Vogtle EPZ which lies within Aiken County, South Carolina.
Mauney Affidavit at 1 3.
17.
" Annex Q, Part 2, Fixed Nuclear Facility (FNF) Ra-diological Emergency Response Plan (RERP) To The Aiken County Emergency Operations Plan (EOP)" ("Aiken County Plan") desig-nates South Aiken High School and Kennedy Middle School (both 3
Aiken, South Carolina) as the reception centers for evacuees from the Aikan County portion of the EPZ.
Mauney Affidavit at 1 4.
18.
The entire student body of South Aiken High School can be accommodated in the classrooms of the school, leaving the gymnasium area immediately available to accommodate approx-imately 100 evacuees.
Similarly, the entire student body of Kennedy Middle School can be accommodated in the classrooms of that school, leaving area immediately available in the gymnasi-um to accommodate approximately 100 evacuees.
Mauney Affidavit at 1 6. 4
19.
This analysis demonstrates conclusively that the schools identified as reception centers by Aiken County have sufficient capacity to accommodate the maximum number of EPZ evacuees -- even with students present at the schools, and even assuming that all evacuees arrive at shelters simultaneously.
Mauney Affidavit at 1 7.
20.
If still more capacity was desired, school officials would dismiss students (a process estimated to require a total of approximately 30 minutes), providing capacity for appro'xi-i mately 3,800 additional persons.
Mauney Affidavit at 1 7.
21.
The capacity figures for the schools identified as reception centers (with and without students present) are in-cluded in the Aiken County Plan.
Mauney Affidavit at 1 7.
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- 22..Thus, Aiken County has given adequate consideration to the ready availability of schools for use as reception cen-ters in the event of a radiological emergency at Vogtle.
Mauney Affidavit at 1 8.
Allendale and Barnwell Counties 23.
In the event of an emergency at Plant Vogtle during a school day, a maximum of approximately 235 persons would be evacuated from that part of the Vogtle EPZ which lies within Allendale and Barnwell Counties, South Carolina.
Awbrey Affi-davit at 1 3.
1 24.
Because Barnwell County evacuees would evacuate into Allendale County, Allendale and Barnwell County evacuees would use the same reception centers.
Awbrey Affidavit at 1 4.
25.
" Annex Q, Part 2, Fixed Nuclear Facility (FNF) Ra-diological Emergency Response Plan (RERP) To The Allendale County Emergency Operations Plan (EOP)" ("Allendale County Plan") and " Annex Q, Part 2, Fixed Nuclear Facility (FNF) Ra-diological Emergency Response Plan (RERP) To The Barnwell Coun-ty Emergency Operations Plan (EOP)" ("Barnwell County Plan")
designate Allendale Elementary School (in Allendale, South Carolina) and Fairfax Primary School (in Fairfax, South Carolina) as the reception centers for evacuees from the Allendale and Barnwell County portions of the EPZ.
Awbrey Af-fidavit at 1 4.
26.
The entire student body of Allendale Elementary School can be accommodated in the classrooms of the school, leaving the gymnasium area immediately available to accommodate approximately 250 evacuees.
Similarly, the entire student body of Fairfax Primary School can be accommodated in the classrooms of that school, leaving area immediately available in the gym-nasium to accommodate approximately 250 evacuees.
Awbrey Affi-davit at 1 6.
27.
This analysis demonstrates conclusively that the schools identified as reception centers by Allendale and Barnwell Counties have sufficient capacity to accommodate the 4
maximum number of EPZ evacuees -- even with students present at the schools, and even assuming that all evacuees arrive at shelters simultaneously.
Awbrey Affidavit at 1 7.
28.
If still more capacity was desired, school officials would dismiss students (a process estimated to require a total of approximately 30 minutes), providing capacity for approxi-mately 700 additional persons.
Awbrey Affidavit at 1 7.
29.
The capacity figures for the schools identified as reception centers (with and without students ppresent) are in-cluded in the Allendale and Barnwell County Plans.
Awbrey Af-fidavit at 1 7.
30.
Thus, Allendale and Barnwell Counties have given ade-quate consideration to the ready availability of schools for l
e use as reception centers in the event of a radiological emer-gency at Vogtle.
Awbrey Affidavit at 1 8.
Respectfully submitted,
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BRIce WMYdrcliiT1, P.C.
Delissa A. Ridgway David R.
Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 James E. Joiner, P.C.
Charles W. Whitney Kevin C.
Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN
& ASHMORE 1400 Candler Building Atlanta, Georgia 30043 (404) 658-8000 Counsel for Applicants Dated:
March 10, 1986 l i
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