ML20203B462
| ML20203B462 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/15/1986 |
| From: | Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20203B466 | List: |
| References | |
| CON-#286-809 OL, NUDOCS 8604180187 | |
| Download: ML20203B462 (6) | |
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'8g #88 ITNITED STATES OF AB1 ERICA NUCLEAR REGULATORY COP.1P.1ISSION 7g Q.~
] 7S BEFORE TIIE ATO511C SAFETY AND LICENSING ' BOARD -
In the Matter of
)
)
GFORGIA POWER COMPANY
)
Docket Nos. 50-424
--et al.
)
50-425
)
(OL)
(Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
NRC STAFF RESPONSE TO " APPLICANTS' 510 TION FOR SUP1 MARY DISPOSITION OF JOINT INTERVENORS'
, CONTENTION EP-2/EP-2(a) (ADP!!NISTRATIVE CONTROLS OVER ENN USE)"
I.
Introduction On Pfarch 3,1986, Applicants filed a Motion for Summary Disposition of Joint Intervenors' Contention EP-2/EP-2(a).
This contention involves thc question of whether " administrative controls are in place to restrict the use of the dedicated telephone lines to the transmiesion of official and necessary messages. "
" Memorandum and Order (Ruling on Joint Intervenors' Proposed Contentions on Emergency Planning)"
dated August 12,1985 at 12-13.1 For the reasons presented below and in the attached Affidavit of Cheryl L.
Stovall, an Emergency Management 1
Program Specialist in the Federal Emergency Manager 1ent Agency (FEMA),
l the NRC Staff submits that Applicants' Motion should be granted.
-1/
The Contention, as originally proposed by Intervenors and as admitted by the Licensing Board, is set out at pp. 2-4 of Applicants' Motion and at page 2 of the attached Affidavit of Cheryl L. Stovall.
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1 1 II.
Legal Standards Governing Summary Disposition The Staff previously set forth the applicable legal standards governing motions for summary disposition in its July 26,1985 " Response to Applicants' Biotion for Summary Disposition of Contention 10.3 (Cables in Multiconductor Configurations)" (at pp.
1-3).
In order to avoid unnecessary repetition, that discussion is incorporated by reference herein.
III. Applicants' Motion A.
Background
The background events leading to tha filing of Applicants' Motion for Summary Disposition are set forth at pp. 2-5 of Applicants' Pfotion. Staff has reviewed Applicants' description of these events and, in order to avoid unnecessary repetition, agrees with and adopts the " background" statement set out in Applicants' Motion.
B. Basis for Staff's Support of Applicants' Motion for Summary Disposition The Staff supports Applicants' Motion for Summary Disposition for the reasons set out in the attached Affidavit of Cheryl L. Stovall, the FEf!A Emergency Pfanagement Program Specialist charged with reviewing energency response planning in Georgia.
Ms. Stovall's Affidavit sets forth the NUREG-0654 planning standard for evaluating State and local emergency response plans for emergency communications.
Stovall Affidavit at T 2.
This planning standard states that " Provisions [must] exist for prompt communications among principal response organizations to emergency personnel and to the public."
Id.
The emergency communications standard is measured by the following evaluation criteria:
l l
. l'.1.
The communications plans for emergencies shall include organizational titles and alternatives for both ends of the communication links.
Each organization shall establish reliable primary and backup means of communication for licensees, local, and State response organizations.
Such systems should be selected to be compatible with one another.
Each plan shall include:
F.1.a. provision for 24-hour per day notification to and activation of the State / local emergency response network; and at a
minimum,
a telephone link alternate, including 24-hour per day manning of communications links that initiate emergency response actions; F.1.d. provision for communications between the nuclear facility and the licensee's near-site Emergency Operations Facility,
State and local emergency operations centers, and radiological monitoring teams.
1d..
Based on her review of Applicants' motion,
and supporting affidavits, and other documents related to the contention in question, Ms. Stovall is able to conclude that the Georgia 2,/ and South Carolina E State and local plans identify the Emergency Notification Network (ENN) as a primary notification and cou munication link.
Stovall Affidavit at i 4.
Ms. Stovall notes that as stated in the affidavit of Jean M. DiLuzio, at i 3 The ENN is a dedicated, "hard-wired" telecommunica-tions system exclusively for use in a radiological emergency.
The ENN system links Plant Vogtle with the principal organizations responsible for. Amergency response within the Vogtle' plurne exposure' pathway 5
Emergency Planning Zone ("EPZ") -- specifically, the States of Georgia and South Carolina; Burke County, 2_/
State of Georgia Radiological Emergency Plan, Annex D -- Plant Vogtle.
3/
Vogtle Electric Generating Plant Site Specific Radiological Emergency Response Plan Part 7, SCORERP.
. Georgia; Aiken, Allen dale, and Barnwell Counties, in South Carolina; and the Savannah River Plant.
l Thus, she is able to conclude that the emergency communications requirements (F.1.,
F.1.a.,
F.1.d.) are adequately addressed by the State and local plans which include: the ENN system.
Id.
Ms. Stovall also states that she has reviewed the affidavits of State and local emergency planning personnel regarding the security of the ENN system.
In Ms. Stovall's opinion, these affidavits confirm that the locations for the ENN terminals are in facilities that are manned ora a 24-hour basis or locked in storage until activation.
She is also able to state that these affidavits establish that security controls are in place for the ENN system which confirms that physical control of access to the ENN exists.
Stovall Affidavit at 15.
Further, Ms. Stovall states that under the State and local response plans the ENN terminal will be subject to strict administrative controls.
Stovall Affidavit at i 6.
Use of the ENN will be limited to the trans-nission of official and necessary messeges, such as information about the date and time of an incident, the class of emergency, whether a release is taking place, the type of actual or projected release and estimated duration / impact times, estimates of quantity, points and heights of rad'o-active releases, the chemical and physical form of releases, meteorological conditions, actuu'. or projected dose rates and integrated doses, estimates of any surface radioactive contamination, emergency response actions underway, potentially affected populations and a.'ess, any recommended emergency actions (including protective measures), requesta for any needed onsite support by offsite organizations, and the prognosis for the event based on plant information.
Id.
She further avers that the
. i l
administrative controls in the plans "should allow effective transmission of official and necessary messages",
d.
- Finally, Ms. Stovall observes that training requirements are established to prepare appropriate personnel for emergency response actions.
In NUREG-0654, Planning Standard O - Radiological Emergency Response Training, the following evaluation criteria are used to measure trainir.g programs:
0.4.
Each organization shall establish a training program for instructing and qualifying personnel who will implement radiological emergency response plans. The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories:
]
O.4.J. Personnel responsible for transmission of emergency information and instructions.
Stovall Affidavit at i 7.
Ms. Stovall states that the NUREG requirements for training are adequately addressed in State and Local plans for Georgia and South Carolina.
d.
By training personnel responsible for the transmission of emergency information, the administrative procedures are further
]
strengtl.cned and the effectiveness of the procedures is enhanced.
Id.
IV.
Conclusion For the reasons presented above, and in the attached affidavit of Cheryl L.
Stovall, the Staff submits that the Joint Intervenors have 1
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b raised no riaterial issue of fact as regards Contention EP-2/EP-2(a).
The Staff therefore submits that the Motion for Summary Disposition of this contention should be granted.
Respectfully submitted, N
/
Bernard M. Bordenick Counsel for NRC Staff Dated at Bethesda, Maryland this 15th day of April,1986 l
-4/
Staff has reviewed " Applicants' Statement of Material Facts as to Which no Genuine Issue Exists to be Heard [ete]" and agrees with the Statement in question.
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