ML20080F899

Forwards Joint Stipulation on Waverly Contention.Stipulation Obviates 840208 Filing of Written Direct Testimony. Certificate of Svc Encl

ML20080F899
Person / Time
Site:	Wolf Creek
Issue date:	02/08/1984
From:	Silberg J KANSAS GAS & ELECTRIC CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Anderson G, Paxton H, Wolfe S Atomic Safety and Licensing Board Panel
References
NUDOCS 8402130179
Download: ML20080F899 (3)

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i sw m SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNCPSMip OF PROFESSloNAL CORPORATsoNS 1800 M STRE ET. N. W. '84 FI310 All:06 WASHINGTON D. C. f 7036 TELtcopiCR erosi saa-ioes s saa-sies February 8, 1984 '[,,{j; 2 [/,

So-2693 MAWLAW SHI CABLEU5NAWLA'w" TELCPMoNC JAY E. SILBERG, P C. i202 eaa-toe 3 Sheldon J. Wolfe, Esquire .

Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. George C. Anderson Department of Oceanography University of Washington Seattle, Washington 98195 Dr. Hugh C. Paxton 1229 - 41st Street Los_ Alamos, New Mexico 87544

Re: In the Matter of Kansas Gas and Electric Company, et al. (Wolf Creek Generating Station, Uiiit No. 1) Docket No. STN 50-482 Gentlemen:

Enclosed is the Joint Stipulation on Waverly Contention executed by counsel for Intervenors', Applicants, MRC Staff and FEMA.

As indicated during the February 3 conference call, the Joint Stipulation obviates the February 8 filing of any written direct testimony called for by the Licensing Board's January 5, 1984 Memorandum and Order (Granting Intervenors' Motion to Add Contention and Witnesses).

Ve truly yo ,

! y V Af Enclosure cc: . Service List hA 6ne '

. ILBERC for Applicants

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JES:db 8402130179 840200 PDR ADOCK 05000482 O PDR .

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY CDMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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KANSAS GAS AND ELECTRIC COMPANY, j e al . ) Docket No. STN 50-482

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(Wolf Creek Generating Station, )

Unit No. 1) )

l SERVICE LIST l

l Sholdon J. Wolfe Atomic Safety and Licensing Chairman Appeal Board Atcmic Safety and Licensing U.S. Nuclear Regulatory Commission '

Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Wnchington, D.C. 20555 Docketing and Service Section Office of the Secretary -

.r. George C. Anderson U.S. Nuclear Regulatory Commission Department of Oceanography Washington, D.C. 20555 University of Washington SOcttle, Washington 98195 Kent M. Ragsdale l General Counsel Dr. Hugh C. Paxton Missouri Public Service Commission 1229 - 41st Street Post Office Box 360 Loo Alamos, New Mexico 87544 Jefferson City, Missouri 65102 Myron Karman, Esquire A. Scott Cauger, Esquire Deputy Assistant Chief Assistant General Counsel R0aring Counsel Missouri Public Service Commission '

Office of the Executive Post Office Box 360 Legal Director Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission Wnchington, D.C. 20555 Eric A. Eisen, Esquire Birch, Horton, Bittner & Monroe Atcmic Safety and Licensing Board 1140 Connecticut Avenue, N.W.

U.S. Nuclear Regulatory Consnission Washington, D.C. 20036 Wachington, D.C. 20555 i C. Edward Peterson, Esquire l Alan S. Rosenthal, Esquire Assistant General Counsel l Atcmic Safety and Licensing Kansas Corporation Commission i

Appeal Board State Office Building - 4th Floor S. Nuclear Regulatory Commission Topeka, Kansas 66612 Washington, D.C. 20555 l

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Service List Page No Dr. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Ccentission Washington, D.C. 20555 Brian P. Cassidy, Esquire Federal Emergency Management Agency Region I ,

J. W. McCormack POCH Boston, Massachusetts 02109 John M. Simpson, Esquire 4350 Johnson Drive, Suite 120 Shawnee Mission, Kansas 66205 Thomas S. Moore, Es; mire Atomic Se'ety and Licensing Appeal doard U.S. Nuclear Regulatory Commission Washington, D.C. 20555 t

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1 UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION REFORE THE ATOMIC SAFETY AND L'ICENSING 30AR3 In tlc Matter of ) '

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KANSAS GA3 AND ELECTRIC COMPANY, cJ,al. ) Occket No. STN 50-482

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(Wolf Creek Generating Station, ) i Unit No. 1) )

JOINT STIPULATION ON WAVERLY CONTENTION On January 5, 1984, the Atomic Safety and Licensing Board admitted a' late-filed contention of Intervanors Christy and Salava concerning the inclusion of the Town of Waverly and the Waverly schools in the plume exposure pathway emergency plann* ng -

zone ("EPZ"). As a rpeult of discussions 'between Applicants ,

and :ntervenors, the parties have reached the following agreer.ent:

1. The plume axposure pathway EPZ as described in the September 1983 revision of the Coffey County Contingency Plan

, for Incidents Involving Come.arcial Nuclear Power (the " existing '

plume exposure pathway EPZ") will be ' expanded 'to include the Town of Waverly and the Unified school District No. 243, schools located in Waverly. Such expansion will be shown in the Coffey County Contingency Plant '

2. Intervenors withdraw the contention admitted by the Licensing Board's January 5, 1984 Memorandum and order and agree that their remaining contentions are not to be interpreted to raise, and that Intervonors will not challenge, the availability or adequacy of resources and personnel to provide for emergency response activities (including all activities identified in Intervenors' rs=aining contentions) with respect to Waverly;

3. Intervenois do not withdraw any of the remaining con-tantions as, they apply to the existing plume exposure pathway EPZ ,

4. Intervanors may continue to contest tmergency response I

activities with respect to the eMisting plume exposure pathway EPZ, provided that Intervenors' remaining contentions are not to be interpreted to raise, and Intervenors will not challenge, the

.. - effect that including Waverly in the plume exposure pathway EPZ -

will have on those activites; ,

S. Commercial grade tone alert' radios will be furnished to the Unified School District No. 243 schools locate'd in Waverly;

6. The Coffey County Contingency Plan will'be invised to provide that students at ths Ur.ified School District No. 24.'

schools located in Waverly will be evacuated to a host county registration center designated in the Plans

7. An outdoor warning siren for Waverly will be installed as described in Wyle Research Report WR 82-36 (June 1983) . This will be provided in the Coffey County Contingency Plan;

8. Public information materials (i.e. , brochures and

! telephone books) will be furnished to Waverly households in the isame manner as for households within the existing plume exposure 1

pathway EPZ; l

9. Evacuation route (s) for Waverly will be established in the Coffey County Contingency Plan in .the same manner os for the existing plume exposure pathway EPZi .

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10. A list of those individuals in Waverly needing special notification will be established and maintained in the same manner

, as for the existing plume exposure pathway, and these indivi- '

duals will receive special notification within the same 45 minute period provided for such individuals within the existing plume exposure pathway EP3. The Coffey County Contingen'y c Plan will identify by title the person responsible for performin'g such notification .

11. Applicants will reevaluate the evacuation time estimate for special populations to include special populations

! within Waverly. If the estimate indicates that evacuation of l special populations within Waverly would taks more than 2.5

( hours, the estimated evacuation time for special populations set forth in the Coffey County Contingency Plan will be revised accordingly;

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i 12. The Coffey County Contingency Plan will be revised to provide for special transportation tn those individuals in Waverly who require its and i

13. The Coffey County Contingency Plan will be revised to provide the evacuation confirmation time parameters for Waverly consistent *fith the 10.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> time shown for the e,xisting. plume 1

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exposure pathway EPZ. (The evacuat' ion confirmation time i

parameters represent a technique to estimate' overall confirmation times, rather than a planned allocation of resources, and there-fore ~ the estimated confirmation times for specific locations within the plume expcsure pathway EPZ do not necessarily reflect the time within which confirmation will be completed for those 1

• specific locations.) .

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E Silberg I counsel for .Intervenors C s 1 for plica (nts

, Christy and Salava D e V3 Dated 26. 3; / 9 /4. *

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, V hwz Brian Castidy Myron . Karmin Counsel for FEMA Coun 1 for )IRQ Staff, Dated 4M- CA- 3 Dat 2 /4/ 9 ft

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