ML20154D551

Affidavit of Cl Stovall,Supporting Applicant 860210 Motion for Summary Disposition of Contention EP-7 Re Emergency Planning in State of Sc.Certificate of Svc Encl

ML20154D551
Person / Time
Site:	Vogtle
Issue date:	02/27/1986
From:	Stovall C Federal Emergency Management Agency, GEORGIA POWER CO.
To:
Shared Package
ML20154D547	List: ML20154D546 ML20154D551
References
OL, NUDOCS 8603060247
Download: ML20154D551 (6)

Text

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UNITED STATES OF AMERICA Og ED NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEMSING BOARD W MR -5 R2:03 In the Matter of ) Orricc c. :r L, GEORGIA POWER COMPANY et al. ) Docket No. 50-424 OGug k r, ,

(Vogtle Electric Generating ) 50-425 Plant, Units 1 and 2) )

AFFIDAVIT OF FEMA EMERGENCY MANAGEMENT PROGRAM SPECIALIST CHERYL L. STOVALL IN SUPPORT OF AP-PLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF EP-7 (EMERGENCY PLANNING IN SOUTH CAROLINA)

County of Fulton )

)

State of Georgia )

Cheryl L. Stovall, being duly sworn, deposes and says:

1. My present position is Emergency Management Program Specialist for the Federal Emergency Management Agency. Included among my re-sponsibilities is the radiological emergency planning liaison func-tion between FEMA Region IV and the States of, Georgia, Alabama, Florida and Tennessee. In this position, I am responsible for the review of radiological plans and preparedness for these States and for the local governments within these States.

I have held this position since December 1981. I have been em-ployed by FEMA since June 1980. A current statement of my profes-sional qualifications is attached hereto. My business address is 1371 Peachtree Street, N. E., Suite 706, Atlanta, Georgia 30309. I have personal knowledge of the matters discussed herein and believe them to be true and correct.

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2. I make this affidavit in response to contention EP-7.

EP-7 contends:

Applicants claim that the Department of Energy. (Savannah River Plant Operations Office, Aiken, South Carolina) will provide radiological assistance (advise and emer-gency action essential for the control of immediate hazards to health and safety) in the event of an emergency at Vogtle. It fails to address the possibility that an emergency situation (for example, an earth-quake) which threatens the safe operation of Vogtle might also endanger operations at Savannah River Plant. In this event, not only would Department of Energy Offices be prevented from providing aid to Vogtle, other federal, state and local assistance resources would be divided between the two sites. Ap-plicants do not address the impacts of simul-taneous evacuation from both plants, or over-load of medical facilities and emergency vehicles in the event of injury to persons by the operation of both plants. Nor do AD-plicants adequately discuss coordination of activities of Georgia and South Carolina's agencies.

I have also reviewed the Board's Memorandum and Order of October 1, 1985 (Ruling on Applicants' Motion of September 5, 1985 for Reconsideration and Clarification) in which the Board states:

We find that the litigible issue extant in EP-7 is Applicants' alleged failure to pro-vide an emergency response plan for the VEGP which encompasses that part of the plume EPZ within South Carolina.

3. In addition, I have reviewed the following documents in pre-paration for this affidavit a) Applicants' Motion for Summary Disposition of Joint In-tervenors' Contention EP-7 (Emergency Planning in South Carolina).

4 b) Applicants' Statement of Material Facts As To Which No Genuine Issue Exists To Be Heard Regarding Contention EP-7.

- ~ (Emergency Planning in South Carolina).

c) Affidavit of Jean M. Diluzio on Contention EP-7.

4. The plume EPZ for VEGP in South Carolina includes parts of

three counties. Most of the area in South Carolina is within the bounds of the Savannah River Plant, owned by the Department of I

Energy. The remaining area out to the 10-mile radius in Aiken, Allendale, and Barnwell Counties is identified as part of the plume EPZ for VEGP.

l S. The Natural and Technological Hazards Division, Federal Emer-gency Management Agency, Region IV received the following plans on February 7, 1986 from the South Carolina Emergency Management Agency:

a) VEGP Site Specific Radiological Emergency Response Plan - Part 7, South Carolina Operational Radiological Emergency Response Plan (SCORERP).

b) Fixed Nuclear Facility Radiological Emer-gency Response Plan - Annex 0, Part 2, to the Aiken County Emergency Operations Plan.

c) Fixed Nuclear Facility Radiological Emer-gency Response Plan - Annex Q, Part 2, to the Allendale County Emergency Operations Plan.

d) Fixed Muclear Facility Radiological Emer-gency Response Plan - Annex Q, Part 2, to the Barnwell County Emergency Operations Plan.

. In the same Office on February 20, 1986, the following plan l

was received from the Department of Energy, Savannah River Ooera-i I

tions Office:

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Vogtle Electric Generating Plant, Response Guide, SR 402.1, U.S. Department of Eneroy, Savannah River Operations Office.

6. Based on the submission of the plans mentioned in paragraph five of this affidavit and the review of documents identified in paragraphs two and three, I conclude that no material issue of fact remains.

Cl WL L. STOVALL Sworn to and subscribed before me this @ ay of February, 1986.

P

[ (is-Matar? Jublic for State of Georgia Notarv Puen +c. -

.4se My Com:nission Expires: My Commess ; . > cs t . i. ,81 .

-_----_-_-_____--_--._-.__-.__._____._--__---A

r UNITED STATES OF AMERICA COLKEILD NUCLEAR REGULATORY COMMISSION 'J S N9C BEFORE TIIE ATOP"C SAFETY AND LICENSING BOARD '86 NAR -5 R2 :03 0Ffla . . .. ..,e In the Matter of ) 00CKEinio . LLT va

) BRANCH OEORGIA pot,'ER COMPANY, ) Docket Nos 50-42 4

--et al. ) 50-425

) (OL)

(Vogtle Electric Genereting Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF RESPONSF TO ' APPLICANTS' MOTION FOR SUMP!ARY DISPOSITION OF JOINT INTERVENORS' CONTENTION EP-7 (EPIERGENCY PLANNING IN SOUTH CAROLINA)" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deporit in the Nuclear Regulatory Commission's internal mail system, this 3rd day of March,198(i.

Morton B. Margulies, Esq. , Chairman

• Pfr. Gustave A. Linenberger, Jr.*

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Doord Panel Panel U.S. Nuclear Regulatory Connf r.sion U.S. ?!uclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar II. Paris

• Bradley Jones, Esq.

Administrative Judge Region 1 Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington , D.C. 20555 Atlanta, GA 30303 Bruce W. Churchill, Esq. Douglas C. Teper David R. Lewis, Esq. 1253 Lenox Circle Shaw, Pittman, Potts & Trowbridge Atlants, GA 30306 1800 B1 Street, N.W.

Washington, D.C. 20036

2-Atomic Safety and Licensing Board Panel

• U.S. Nuclear Regulatory Commission Washingtoh, D.C. 20555 Docketing and Service Section* Atomic Safety and Licensing Office of the Secretary Appeal Board Panel

• U.S. Nuclear Regulartory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 James E. Joiner, Esq. Ruble A. Thomas Troutman, Sanders, Lockerman, Southern Company Services, Inc.

& Ashmore P.O. Box 2625 127 Peachtree Street, N.E. Dirmingham, AL ' 33202 Candler Dullding, Suite 1400 Atlanta, GA 30043 NRC Resident Inspectors P.O. Box 572 Tin Johnson Waynesboro, GA 30830 Executive Director Campaign for c Prosperous Georgia  !!. Joseph Flynn Esq.

1083 Austin Ave. FE Assistant General Counsel Atlanta, GA 30307 Federal Emergency Planagement Agency 500 C Street, S.W.

Washington, D.C. 30472 Steven M. Rochlis Regional Counsel Federal Emergency Management Agency Suite 700 1371 Peachtree Street, N.E.

Atlanta, Georgia 30300 M #

Bernard it. Bordenick Counsel for NRC Staff

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