ML20198A007
| ML20198A007 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/16/1986 |
| From: | Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20198A014 | List: |
| References | |
| CON-#286-194 OL, NUDOCS 8605200300 | |
| Download: ML20198A007 (5) | |
Text
ce UNITED STATES OF AMERICA O6A NUCLEAR REGULATORY COMMISSION
'l c
/%%_.
BEPORE THE ATOMIC SAFETY AND LICENSING BOARD W
In tbc Matter of
)
)
GEORGIA POWER COMPANY
)
Docket Nos. 50-424 et al.
)
50-425
)
(OL)
(Vogtle Electric Generating Plant,
)
Units I and 2)
)
NRC STAFF SUPPLEMENTAL RESPONSE TO
" APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF JOINT INTERVENORS CONTENTION EP-5 (RECEPTION CENTER CAPACITY)"
I.
Introduction On March 10, 1986, Applicants filed a Motion for Summary Disposition of Joint Intervenors' Contention EP-5.
This contention as admitted by the Licensing Board asserts that:
The offsite emergency response plans for
[Vogtle] do not meet the requirement of 10 C.F.R. 50.47(b)(8) because the plans do not reasonably assure that adequate emergency-facilities, namely reception centers, will be readily available for use in the event of a radiological emergency at (Vogtle).
" Memorandum and Order (Ruling on Joint Intervenors' Proposed N
Contentions on Emergency Planning)" dated August 12, 1985 at 29.
1/
The Contention as originally proposed by Intervenors and the Board's comments in admitting the Contention set out above appears at pp. 2-3 of Applicants' Motion.
The gravamen of Contention EP-5 (FOOTNOTE CONTINUED ON NEXT PAGE) g09 D
- 2,-
By Order dated April 25, 1986, the Board granted the NRC staff (Staff) request that consideration of Applicants' Motion be deferred, and that the Staff be provided a further opportunity to reply to the motion after an cmergency planning exercise is held and evaluated by the Federal Emergency luanagement Agency (FEMA). -
II.
Supplemental Response To Applicants' Motion 3,/
The Staff on April 15, 1986, asked that consideration of Applicants' Motion for Summary Disposition of Contention EP-5, dealing with the adequacy of emergency reception centers, be deferred for the reasons set out in an Affidavit of Cheryl L. Stovall, the FEMA Emergency Management Program Specialist charged with reviewing emergency response planning (FOOTNOTE CONTINUED FROT.1 PREVIOUS PAGE) is the availability of the schools identified as reception centers to accommodate evacuees from the plume exposure pathway Emergency Planning Zone (EPZ).
In particular noting the lack of emergency plan provisions for the release of students from the schools to be used as reception centers, the Board questioned whether "the reception centers are of sufficient capacity that pupils need nct be dismissed and both they and the evacuees will be accommodated at the same time."
August 12, 1985 Order, at 28.
-2/
See "NRC Staff Fesponse Requesting a Deferral of and Permission to FIIe an Additional Response to ' Applicants' Motion for Summary Disposition of Joint Intervenors' Contention EP-5 (Reception Center Capacity)" (Request) dated April 15, 1986.
3/
The Staff at page 2 of its April 15, 1986, Request set forth the
" Legal Standards Governing Summary Disposition" and the
" Background" events leading to Applicants' motion for summary disposition.
for the State of Georgia which was submitted with the Staff's April 15, 1986 Request.
As notid' by the Staff at that time, pursuant to 10 C.F.R. 9 50.47(a)(2), the NRC bases its findings on the adequacy of State and loccl emergency response plans on a review of FEl'1A findings on the adequacy of those plans and whether there is reasonable assurance that they can be implemented.
As further noted by the Staff, although the plans submitted in this proceeding appeared to establish that relocation centers are available to register and monitor evacuees and appeared to adequately meet the requirements of NUREG 0654, O FEMA believed that a field verification of the relocation centers was necessary to fully determine the adequacy of the relocation facilities.
Stovall Affidavit at T 4.
This field verification was conducted during a licensing exercise test of the Vogtle plan held on April 30 and May 1,1986.
g.
Thus, FEMA is now able to pass on the adequacy of the relocation centers.
The results of the FEMA field verification are set out in the attached Supplemental Affidavit of Cheryl L.
Stovall.
On the basis of this Supplemental Affidavit and for the reasons set out below, the Staff now supports Applicants Motion for Summary Disposition of Contention EP-5.
Ms. Stovall's Supplemental Affidavit states that on April 30 and May 1 she visited reception centers / shelters in Georgia and South Carolina.
She proceeded under a scenario where all Vogtle construction workers at Unit 2 were still on-site as potential evacuecs and had to
~4/
The NUREG standard involving the means to register and monitor evacuees is set out at i 2 of Ms. Stovall's (original) Affidavit.
be accommodated in addition to the other EPZ evacuees, in the event of a radiological emergency at Vogtle Unit 1.
Stovall Supplemental Affidavit at ff-4 and 5.
She then describes the recent inspection she
~
made at the following schools in Georgia and South Carolina which premise her factual findings that space and facilities are adequate to accommodate evacuees:
Georgia Burke County Comprehensive liigh School $
Blakeney Elementary and Junior Iligh Schools Waynesboro Ifigh School Waynesboro Elementary School Couth Carolina 1
-Allendale Elementary School Fairfax Primary School South Aiken liigh School Kennedy Elementary School On this basis Ms. Stovall concludes "that adequate emergency facilities, namely reception centers will be readily available for use and able to accommodate evacuecs in the event of a radiological emergency at Plant Vogtle".
Id. at f 5. $
l
-5/
Although the term " shelter" is used in the South Carolina plans, the generic term " reception center" is used in Applicants' motion and by Ms. Stovall to describe both the Georgia and South Carolina facilities used to register (and, if necessary monitor and decontaminate) evacuees in the event _ of a radiological emergency at Vogtle. Stovall Supplemental Affidavit at fn,1.
6/
This school is presently under construction and is expected to be completed by early 1987.
Stovall Supplemental Affidavit, at 5 4.
-7/
The projected number of evacuees within the State of South Carolina is 250.
8/
FEMA also finds that while it is conceivable that students could be accommodated in the classrooms while evacuces are being processed, it is unrealistic to assume that normal school activities would (FOOTNOTE CONTINUED ON NEXT PAGE)
IV.
Conclusion For the reasons presented above, and in the attached Supplemental Affidavit of"Cheryl L.
Stovall, the Staff submits that Intervenors have raised no material issue of fact as regards Contention EP-5. S The Staff therefore submits that Applicants' Motion for Summary Disposition of this contention should be granted.
Respectfully submitted, rlc~7&st}
f% %
- dft, Bernard M. Bordenick Counsel for NRC Staff Dated at Bethesda, Maryland this /6 day of May,1986 (FOOTNOTE CONTINUED FROM PREVIOUS PAGE) continue without disruption of school activities in the event of a
' large scale evacuation.
However, Applicants have shown, through the Director of the Burke County Emergency Management Agency, that Burke County school officials could dismiss students who were not residents of evacuated areas. Bryant Affidavit at i 15.
-9/
Staff has reviewed " Applicants Statement of Material Facts as to which no Genuine Issue Exists to be Heard [etc]" and agrees with the Statement in question.
With respect to Statements numbered 4-15, involving reception centers in Burke County, Georgia, FEMA has assumed a " worst case" scenario, i.e., the maximum number of evacuees expected at reception centers including Vogtle 2 construc-tion workers.
Thus, while the Staff does not disagree with any of the Statements in question, they are largely irrelevant to FEMA's
" worst case" analysis.
,