ML20205J032

Intervenor Response to NRC Interrogatories Re Emergency Planning.Certificate of Svc Encl.Related Correspondence

ML20205J032
Person / Time
Site:	Vogtle
Issue date:	01/24/1986
From:	Johnson T JOHNSON, T.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
CON-#186-873 OL, NUDOCS 8601300082
Download: ML20205J032 (5)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION []~ JMl 2 9 , w l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD c$[ ' Q j.%

In the Matter of ) ,

GEORGIA POWER C0., et al. ) Docket Nos. 50-424 and 50- 25'U L

) ..

(Vogtle Electric Generating Plant, )

Units 1 and 2) )

Intervenors' Response to NRC Staff's Interrogatories Relting to Emergency Planning

1. Intervenors have not completed their testimony for hearings on emergency response. A this point, Intervenors have relied on information previously described in response to interrogatories from the Applicants; these documents will be available for staff's inspection and copying at a time convenient if the staff so desires.

2. The information Intervenors have provided in the contentions was provided to Intervenors by the individuals quoted therein. While'Intervenors have not made final selection of witnesses on these contentions and subcontentions, at this point Intervenors intend to present Atlanta psychologist Seymour Shaye as an expert witness on emergency response.

3. a) and b) Intervenors have previously responded to this inquiry in response to Applicants' interrogatory. To summarize, " full-time" preparedness and coordination of a nuclear emergency must be around the clock, and Intervenors have seen nothing to demonstrate that Burke County has obtained 24-hour per day, seven-day per week direction for emergency management. ,

c) The amendments suggested by Staff would have to be examined in their specificity by Intervenors before determining if they would be sufficient to alleviate the concerns. There is considerable concern about role conflict for personnel in the Sheriff's Department.

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. d) Intervenors have not yet prepared testimony on this contention. Such a plan would have to include guarantees that all functions would be properly performed.

e) Again, it depends on the adequacy of the "continous" staffing and/or "the procedures to be followed." Obviously, if Intervenors' concerns are sufficiently addressed, then Intervenors will no longer have those concerns; onversely, until those concerns are adequately addressed, Intervenors will maintain those concerns.

f) This is substantively the same question as (d). Please see response to (d), above. 1 g) Please see intervenors' previous filings and the Board's ruling, b) Please see (d) and (f), above.

4. a) The Applicants' plan lacks adequate specific controls over.the ENN.

l b) Please see Intervenors' previous filing's and the Board's order. l c) Adequate controls must be provided to assure that the dedicated lines are ,

used only for official and necessary uses, and that they are available for such

! usage.

t d) Please see response to (c), above, as well as previous submissions by ,

Intervenors. Intervenors have not yet prepared their testimony on emergency i ' planning.

5. a) Intervenors have not prepared their testimony on this issue. The reasons for Intervenors' ebjection to the tone alert radios have been previously cited and i

include the obvious problem that they can be and are frequently shut off by the intended recipients of the alerts, b) Please see Intervenors' previous filings on this issue, as well as the Board's order.

1 c) Please see Intervenors' previous filings on this issue, as well as the Board's order.

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a d) Please see Intervenors' previous filings on this issue as well as the the Board's order. While Intervenors have not prepared testimony on this issue, sufficient assurance must be provided that those who should evacuate are notified of any emergency situation.

6. a) Intervenors have not yet prepared testimony on this issue. Please see ,e Intervenors' previous filings, as well as the Board's order, for a description of certain concerns about notification of transients. As far as transients are concerned, a warning signal might signiffy a test, a weather alert, a malfunction in the system or something else irrelevant to the presence of a nuclear facility.

b) This 'is essentially the same as (a). Please see the response thereto, c) Please see Intervenors' previous filings and the Board's order.

d) Intervenors have not yet prepared their testimony on this issue.

Generally speaking, information must be sufficient in content and dissemination to notify all transients in the area in the event of an emergency.

e) Please see response to d) above.

7. a) Applicants fail to identify adequately medial facilities capable of treating contaminated individuals. Please see the Board's order and Intervenors previous filings.

b) Please see (a), above.

c) Please see the Board's order and Intervenors' previoJs filings.

d) Medical facilities must be adequately described which are capable of treating radioactively contaminated individuals in the event of an emergency.

8. a) Applicants and Burke County must set out with specificity how proposed facilities will accomodate evacuees, including availability of space at the reception center. This space could easily be overwhelmed if most county refugees sought refuge therein. Please see Intervenors' previous 'fflings and the Board's order related to this issue, b) Please see (a), above, as well as the Board's order and Intervenors' 3

. previous filings, c) Please see (b), above. In summary, sufficient provisions must be made to l

assure availability of reception areas for evacuees in an emergency.

d) Please see the above, Intervenors' previous filings, and the Board's order.

e) Intervenors have not yet prepared testimony on this issue. Please see

Intervenors' previous filings and the Board's order.

9. a) The Vogtle plume EPZ must include the entire area required by the regulations, b) Merel,y " showing" the areas of the plume EPZ would not be adequate.

c) Adequate planning must include all areas of the plume EPZ to meet all regulatory requirements. Please see Intervenors' previous filings. and the Board's order.

The above responses were prepared by Tim Johnson based on information previously made available to him by Seymour Shaye and others as described in previous Intervenor filings on emergency response in this proceeding.

Respectfully submitted this, the 24th day of January,1986.

<_ _ , = '

Tim Johnson 1083 Austin Ave.

4 Atlanta, GA 30307 404-659-5675 for Intervenors 4

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- CERTIFICATE OF SERVICE This is to certify that copies of the foregoing Intervenors' response to the NRC staff's interrogatories relating to emergency response were served by hand or by deposit with the U. S. Iostal Service in the City of Atlanta with first class postage attached to be delivered to the following service list this 24th day of January, 1986.-

~Tini Johnson SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel t

U.S. Nuclear . Regulatory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C.'.20555 Dr. Oscar H. Paris Docketing and Service Section Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Gustave A. Linenberger Bernard M. Bordenick, esq.

l Atomic Safety & Licensing Board Office of the Executive Legal-t U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear- Regulatory Comission i Washingten, D.C. 20555 Atomic Safety & Licensing Board Panel Ruble A. Thomas U.S. Nuclear Regulatory Commission Southern Company Services, Inc.

Washington, D.C. 20555 P. O. ',ox 2625 Birmingham, Alabama 35202 Bruce Churchill, esq.

Shaw, Pittnan, Potts & Trowbridge Bradley Jones, esq.

1800 M Street, N.W. Regional Counsel, U.S. NRC Washington, D.C. 20036 101 Marietta Street, Ste. 3100 Atlanta, Georgia 30303 James Joiner, eso.

Troutman, Sanders, Lockerman nshmore H. Joseph Flynn, esq.

The Candler Building Assistant General Counsel Atlanta, Georgia 30303 Federal Emergency Regulatory Agency 500 C St. S.W.

Steven M. Rochlis Washington, D.C. 20472 Regional Counsel '

Federal Emergency Management Agency Suite 700 1371 Peachtree Street, N.E.

Atlanta, Georgfa 30309

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