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Category:INTERVENTION PETITIONS
MONTHYEARML20045G9291993-06-30030 June 1993 Intervenor Supplemental Response to Georgia Power Co First Request for Production of Documents & Response to Interrogatory Questions.* Related Correspondence ML20126A5281992-12-0909 December 1992 Amends to Petition to Intervene & Request for Hearing.* Petitioners Request That Contentions 1-4 Be Admitted & Petitioners Be Allowed to Appear as Parties Before Board. W/Certificate of Svc ML20116M1661992-11-0606 November 1992 Georgia Power Co Answer to 921022 Petition of AL Mosbaugh & Mb Hobby to Intervene in License Amend Proceeding.* Requests That Petition Be Denied.W/Certificate of Svc & Notice of Appearance ML20116M2431992-10-22022 October 1992 Petition to Intervene & Request for Hearing of AL Mosbaugh & Mb Hobby.* Petitioners Seek Leave to Intervene Re Util Request to Amend OL to Allow Southern Nuclear Operating Co, Inc to Take Over Const Control.W/Certificate of Svc ML20083B4941991-08-0909 August 1991 Georgians Against Nuclear Energy Amend to Petition for Leave to Intervene.* Suppls 910614 Petition W/Listed Petitions ML20081L4761991-06-14014 June 1991 Georgians Against Nuclear Energy Petition for Leave to Intervene.* Petitions Commission for License to Intervene in Util Request to Change Testing Schedule Requirements on Emergency Diesel Generators at Facilities ML20059L8441990-09-14014 September 1990 Applicant Response to Georgians Against Nuclear Energy Amend to Petition for Leave to Intervene.* Petition Should Be Dismissed Due to Gross Deficiencies in Statement of Standing.W/Certificate of Svc ML20059L8381990-09-14014 September 1990 NRC Staff Response in Oppositon to Georgians Against Nuclear Energy Amended Petition for Leave to Intervene.* Petition Should Be Dismissed Due to Contentions Not Meeting 10CFR2.714(b)(2) & 2.714(d)(2).W/Certificate of Svc ML20059H3721990-09-12012 September 1990 Amend to Petition for Leave to Intervene.* Expresses Appreciation for ASLB Consideration in Scheduling Prehearing Conference & Suppls 900723 Petition by Showing That Intervenor Has Standing to Intervene Through Membership ML20056B1891990-08-13013 August 1990 NRC Staff Response in Opposition to Georgians Against Nuclear Energy Petition for Leave to Intervene.* Petition Does Not Identify Real Injury Which Could Be Incurred by Petitioner & Should Be Denied.W/Certificate of Svc ML20056B2241990-08-0707 August 1990 Util Answer to 900723 Petition of Georgians Against Nuclear Energy for Leave to Intervene in License Amend Proceeding.* Petition Should Be Denied.W/Certificate of Svc & Svc List ML20056A4401990-07-23023 July 1990 Petition for Georgians Against Nuclear Energy to Intervene in Georgia Power Co Request for Amend to Licenses NPF-68 & NPF-81.* Util Should Acquire Temp Switch That Works ML20137B1331986-01-0505 January 1986 Response to Applicants Second Set of Discovery Re P Smith Difficulty in Contacting Emergency Response Personnel in Burke County.Related Correspondence ML20129F8911985-07-15015 July 1985 Response to Joint Intervenors Revised Contention Re Emergency Response.Nrc Objects to Contention on Emergency Planning as Lacking Specificity Except as Limited to Issues of Notifying Public & Availability of Reception Ctrs ML20127K5571985-06-24024 June 1985 Joint Intervenors Revised Contention Re Emergency Response. Proposed Emergency Plan Fails to Provide Reasonable Assurance That Adequate Protective Measures Will Be Taken During Radiological Emergency.Certificate of Svc Encl ML20093L0331984-10-10010 October 1984 Joint Rev to Contention 8 & Amend to Basis for Contention 8 Re QA Program.Certificate of Svc Encl ML20092N2131984-06-28028 June 1984 Response to Campaign for Prosperous Georgia 840613 Second Amend to Suppl to Petition for Leave to Intervene & Request for Hearing.Amend Untimely,But Acceptable.Certificate of Svc Encl ML20092N1341984-06-28028 June 1984 Response Opposing Georgians Against Nuclear Energy (Gane) 840628 Amend to Gane Contention 2.GANE late-filed Amend to Contention 2 Should Be Disallowed & Contention Rejected. Certificate of Svc Encl ML20140C7491984-06-13013 June 1984 Amended Basis for Contention 2 & Rationale Supporting Late Filing Re Environ Impact.Offsite Releases Comparison & Certificate of Svc Encl ML20140C7281984-06-13013 June 1984 Second Amend to Suppl to Petition for Leave to Intervene & Request for Hearing.Contentions CPG-2,CPG-3 & CPG-11 Addressed.Certificate of Svc Encl ML20083L2221984-04-11011 April 1984 Suppl to 840127 Petition for Leave to Intervene & Request for Hearing.Applicant Has Not Adequately or Correctly Addressed Potential Releases of Radionuclides During Normal Transient Conditions.W/Certificate of Svc ML20083M1431984-04-11011 April 1984 Suppl to 840127 Petition for Leave to Intervene & Request for Hearing.Applicant Has Failed to Show That in Event of Accident,Adequate Notification,Communication,Educ,Evacuation & Relocation Can Occur.W/Certificate of Svc ML20080U0021984-02-24024 February 1984 Response Opposing Applicant Answer to Petitions for Leave to Intervene & Requests for Hearing.Request for Hearings to Be Held in Atlanta,Ga Reiterated.Certificate of Svc Encl ML20080J6291984-02-10010 February 1984 Answer to Petitions for Leave to Intervene & Requests for Hearing.Notices of Appearance & Certificate of Svc Encl ML20079N1611984-01-26026 January 1984 Joint Petition of Georgians Against Nuclear Energy for Leave to Intervene & Request for Hearing ML20079P5081984-01-26026 January 1984 Petition of Consumers Util Counsel of Ga for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20079N7511984-01-26026 January 1984 Petition of Campaign for Prosperous Georgia for Leave to Intervene & Request for Hearing in Atlanta,Ga Re Applications for Ols.Affidavits,Notice of Appearance & Certificate of Svc Encl ML20079N1651984-01-26026 January 1984 Request That Hearings Be Held in Atlanta,Ga.Certificate of Svc Encl 1993-06-30
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20045G9291993-06-30030 June 1993 Intervenor Supplemental Response to Georgia Power Co First Request for Production of Documents & Response to Interrogatory Questions.* Related Correspondence ML20126A5281992-12-0909 December 1992 Amends to Petition to Intervene & Request for Hearing.* Petitioners Request That Contentions 1-4 Be Admitted & Petitioners Be Allowed to Appear as Parties Before Board. W/Certificate of Svc ML20116M1661992-11-0606 November 1992 Georgia Power Co Answer to 921022 Petition of AL Mosbaugh & Mb Hobby to Intervene in License Amend Proceeding.* Requests That Petition Be Denied.W/Certificate of Svc & Notice of Appearance ML20116M2431992-10-22022 October 1992 Petition to Intervene & Request for Hearing of AL Mosbaugh & Mb Hobby.* Petitioners Seek Leave to Intervene Re Util Request to Amend OL to Allow Southern Nuclear Operating Co, Inc to Take Over Const Control.W/Certificate of Svc ML20083B4941991-08-0909 August 1991 Georgians Against Nuclear Energy Amend to Petition for Leave to Intervene.* Suppls 910614 Petition W/Listed Petitions ML20081L4761991-06-14014 June 1991 Georgians Against Nuclear Energy Petition for Leave to Intervene.* Petitions Commission for License to Intervene in Util Request to Change Testing Schedule Requirements on Emergency Diesel Generators at Facilities ML20059L8441990-09-14014 September 1990 Applicant Response to Georgians Against Nuclear Energy Amend to Petition for Leave to Intervene.* Petition Should Be Dismissed Due to Gross Deficiencies in Statement of Standing.W/Certificate of Svc ML20059L8381990-09-14014 September 1990 NRC Staff Response in Oppositon to Georgians Against Nuclear Energy Amended Petition for Leave to Intervene.* Petition Should Be Dismissed Due to Contentions Not Meeting 10CFR2.714(b)(2) & 2.714(d)(2).W/Certificate of Svc ML20059H3721990-09-12012 September 1990 Amend to Petition for Leave to Intervene.* Expresses Appreciation for ASLB Consideration in Scheduling Prehearing Conference & Suppls 900723 Petition by Showing That Intervenor Has Standing to Intervene Through Membership ML20056B1891990-08-13013 August 1990 NRC Staff Response in Opposition to Georgians Against Nuclear Energy Petition for Leave to Intervene.* Petition Does Not Identify Real Injury Which Could Be Incurred by Petitioner & Should Be Denied.W/Certificate of Svc ML20056B2241990-08-0707 August 1990 Util Answer to 900723 Petition of Georgians Against Nuclear Energy for Leave to Intervene in License Amend Proceeding.* Petition Should Be Denied.W/Certificate of Svc & Svc List ML20056A4401990-07-23023 July 1990 Petition for Georgians Against Nuclear Energy to Intervene in Georgia Power Co Request for Amend to Licenses NPF-68 & NPF-81.* Util Should Acquire Temp Switch That Works ML20137B1331986-01-0505 January 1986 Response to Applicants Second Set of Discovery Re P Smith Difficulty in Contacting Emergency Response Personnel in Burke County.Related Correspondence ML20129F8911985-07-15015 July 1985 Response to Joint Intervenors Revised Contention Re Emergency Response.Nrc Objects to Contention on Emergency Planning as Lacking Specificity Except as Limited to Issues of Notifying Public & Availability of Reception Ctrs ML20127K5571985-06-24024 June 1985 Joint Intervenors Revised Contention Re Emergency Response. Proposed Emergency Plan Fails to Provide Reasonable Assurance That Adequate Protective Measures Will Be Taken During Radiological Emergency.Certificate of Svc Encl ML20093L0331984-10-10010 October 1984 Joint Rev to Contention 8 & Amend to Basis for Contention 8 Re QA Program.Certificate of Svc Encl ML20092N2131984-06-28028 June 1984 Response to Campaign for Prosperous Georgia 840613 Second Amend to Suppl to Petition for Leave to Intervene & Request for Hearing.Amend Untimely,But Acceptable.Certificate of Svc Encl ML20092N1341984-06-28028 June 1984 Response Opposing Georgians Against Nuclear Energy (Gane) 840628 Amend to Gane Contention 2.GANE late-filed Amend to Contention 2 Should Be Disallowed & Contention Rejected. Certificate of Svc Encl ML20140C7491984-06-13013 June 1984 Amended Basis for Contention 2 & Rationale Supporting Late Filing Re Environ Impact.Offsite Releases Comparison & Certificate of Svc Encl ML20140C7281984-06-13013 June 1984 Second Amend to Suppl to Petition for Leave to Intervene & Request for Hearing.Contentions CPG-2,CPG-3 & CPG-11 Addressed.Certificate of Svc Encl ML20083L2221984-04-11011 April 1984 Suppl to 840127 Petition for Leave to Intervene & Request for Hearing.Applicant Has Not Adequately or Correctly Addressed Potential Releases of Radionuclides During Normal Transient Conditions.W/Certificate of Svc ML20083M1431984-04-11011 April 1984 Suppl to 840127 Petition for Leave to Intervene & Request for Hearing.Applicant Has Failed to Show That in Event of Accident,Adequate Notification,Communication,Educ,Evacuation & Relocation Can Occur.W/Certificate of Svc ML20080U0021984-02-24024 February 1984 Response Opposing Applicant Answer to Petitions for Leave to Intervene & Requests for Hearing.Request for Hearings to Be Held in Atlanta,Ga Reiterated.Certificate of Svc Encl ML20080J6291984-02-10010 February 1984 Answer to Petitions for Leave to Intervene & Requests for Hearing.Notices of Appearance & Certificate of Svc Encl ML20079N1611984-01-26026 January 1984 Joint Petition of Georgians Against Nuclear Energy for Leave to Intervene & Request for Hearing ML20079P5081984-01-26026 January 1984 Petition of Consumers Util Counsel of Ga for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20079N7511984-01-26026 January 1984 Petition of Campaign for Prosperous Georgia for Leave to Intervene & Request for Hearing in Atlanta,Ga Re Applications for Ols.Affidavits,Notice of Appearance & Certificate of Svc Encl ML20079N1651984-01-26026 January 1984 Request That Hearings Be Held in Atlanta,Ga.Certificate of Svc Encl 1993-06-30
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196J3291999-06-28028 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Industry Codes & Standards ML20206M7291999-04-30030 April 1999 Comment Supporting Draft RG DG-1083, Content of UFSAR IAW 10CFR50.71(e). Licensee of Listed Plants in Total Agreement with Comments Provided to NRC by NEI HL-5717, Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC1998-12-18018 December 1998 Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC HL-5715, Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments1998-12-14014 December 1998 Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments HL-5702, Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols1998-10-23023 October 1998 Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols HL-5695, Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers1998-10-13013 October 1998 Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers HL-5690, Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC1998-10-0505 October 1998 Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC HL-5983, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed1998-09-21021 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed ML20153B2391998-09-15015 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Ki as Protective Action During Severe Reactor Accidents. Endorses NEI Comments HL-5682, Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute1998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds HL-5586, Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps1998-03-0404 March 1998 Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps HL-5582, Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events1998-02-27027 February 1998 Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events HL-5564, Comment on Draft NUREG 1555, Updated Environ Standard Review Plan1998-01-30030 January 1998 Comment on Draft NUREG 1555, Updated Environ Standard Review Plan HL-5554, Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public1998-01-15015 January 1998 Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public HL-5546, Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements1997-12-31031 December 1997 Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements HL-5529, Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard1997-12-0101 December 1997 Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard ML20199J0031997-11-24024 November 1997 Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060 HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions1997-07-0707 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions ML20148N0741997-06-19019 June 1997 Comment on Proposed Suppl to Bulletin 96-001 Re Control Rod Insertion Problems.Util in Complete Agreement That Incomplete Rcca Insertion Not Acceptable HL-5407, Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ1997-05-27027 May 1997 Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ ML20137C2581997-03-18018 March 1997 Summary of Director'S Decision Under 10CFR2.206 of Mb Hobby & AL Mosbaugh, ML20137C4261997-03-18018 March 1997 Director'S Decision Under 10CFR2.206 Re Petition Re Allegation of Illegal Transfer of OLs to Southern Nuclear Operating Co.Petitions Filed by Mb Hobby & AL Mosbaugh Denied HL-5268, Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols1996-11-27027 November 1996 Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols ML20133H1131996-11-25025 November 1996 Petition for Enforcement,Per 10CFR2.206,to Revoke Northeast Utils Operating Licenses for CT Nuclear Power Stations Due to Chronic,Systemic Mismanagement Resulting in Significant Violations of NRC Safety Regulations ML20129J5481996-10-30030 October 1996 Order.* Extends Time within Which Commission May Take Sua Sponte Review of Memorandum & Order LBP-96-16 to 961129. W/Certificate of Svc.Served on 961030 ML20129K4291996-10-0202 October 1996 Comment Supporting Proposed Rule 10CFR25 & 95, Access to & Protection of Classified Info HL-5247, Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations1996-10-0101 October 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20128K2791996-09-30030 September 1996 Order.* Time within Which Commission May Take Sua Sponte Review of Memo & Order LBP-96-16 Extended Until 961030. W/Certificate of Svc.Served on 960930 ML20116J8921996-08-0202 August 1996 Withdrawal of AL Mosbaugh.* AL Mosbaugh Voluntarily Withdraws Intervention,Opposition & Contention in Proceedings.W/Certificate of Svc & Svc List ML20116J8551996-08-0202 August 1996 Joint Notice of Termination.* AL Mosbaugh Voluntarily Withdrew Intervention,Opposition & Contentions in Proceeding.W/Certificate of Svc & Svc List ML20116J8431996-08-0202 August 1996 Intervenor Response to Georgia Power Motion for Reconsideration.* Intervenor Supports Motion for Reconsideration.W/Certificate of Svc & Svc List ML20116N5881996-07-31031 July 1996 Comment Re Proposed Rule 10CFR26, Mods to Fitness-For-Duty Program Requirements. Supports NEI Comments ML20116A4931996-07-15015 July 1996 Georgia Power Company Motion for Reconsideration of 960628 Memorandum & Order Or,In Alternative,For Certification.* Gpc Requests That Board Not Require Submittal or Approval of Settlement Between Gpc & Mosbaugh.W/Certificate of Svc ML20115H2671996-07-0808 July 1996 Comment Supporting Final Rule 10CFR51, Environ Review of Renewal of Nuclear Power Plant Operating Licenses HL-5195, Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20114E6491996-06-20020 June 1996 Joint Motion to Defer Issuance of Initial Decision.* Requests That ASLB Defer Issuance of Decision in Proceeding Until 960920,in Order to Allow Gpc & Mosbaugh to Reach Settlement Agreement.W/Certificate of Svc IA-95-211, Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-391996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 ML20129H7151996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 HL-5103, Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use1996-02-0606 February 1996 Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use ML20096A4911995-12-22022 December 1995 Georgia Power Co Reply to Intervenor & NRC Staff Proposed Findings of Facts & Conclusions of Law.* W/Certificate of Svc ML20095D9821995-12-12012 December 1995 Georgia Power Co Motion to Correct Record of Exhibits of Diesel Generator Reporting Issues Allegation Hearing.* W/Certificate of Svc ML20095D9771995-12-0808 December 1995 Comment on Proposed Generic Ltr Boraflex Degradation in Spent Fuel Pool Starage Racks. Request for Licensees to Demonstrate Subcriticality Margin in Unborated Water,Seems Inconsistent W/Stated Benefit of Borated Water ML20094S2751995-11-30030 November 1995 Intervenor Final Statement of Fact & Conclusions of Law.* Board Finds That Util & Applicant Failed to Meet Burden of Proof Re Ultimate Issue of Character,Competence & Integrity. W/Svc List ML20094S2411995-11-22022 November 1995 Georgia Power Co Response to Intervenors Motion for Continuance.* Intervenor Motion Unjustified & Prejudicial & Should Be Denied.W/Certificate of Svc & Svc List ML20094S2931995-11-21021 November 1995 Intervenor Motion for Continuance for Good Cause.* Requests Deadline for Filing Post Hearing Brief Be Extended Until 951130.W/Certificate of Svc & Svc List ML20094K1161995-11-0909 November 1995 Intervenor Motion to Admit Supplementary Exhibits.* Moves That Naslp Admit Encl Documents Into Evidence for Listed Reasons.W/Certificate of Svc & Svc List ML20094J9301995-11-0606 November 1995 Georgia Power Company Motion to Correct Record of Diesel Generator Reporting Issues Allegation Hearing.* Moves Licensing Board to Order That Corrections Be Made to Transcript.W/Certificate of Svc & Svc List ML20094J9281995-11-0606 November 1995 Gap Proposed Findings of Fact & Conclusions of Law on Diesel Generator Reporting Issues.* Findings of Fact & Conclusion Accepted.W/Certificate of Svc ML20094J9201995-11-0101 November 1995 Affidavit of Ck Mccoy to Correct Info Contained in Intervenor Exhibit II-97,which Consists of Portions of Deposition in a Mosbaugh Complaint Against Gap 1999-06-28
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DSCHETED USNRC In the Matter of
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GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425'85 J'JN 26 A10:14
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(Vogtle Electric Generating Plant, ) CFFICE OF SECiETC Units 1 and 2) ) 00CMETING A SERVIU BRANCH JOINT INTERVENORS' REVISED CONTENTION RELATING TO EMERGENCY RESPONSE In April,1984, Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy separately filed a contention objecting to the inadequacy of the Applicants' proposed emergency response for Plant Vogtle. The Applicants subsequently withdrew the plan and the Licensing Board ruled that Intervenors could file a new contention relating to emergency response thirty days from the date final plans were submitted for Burke and Richmond Counties. Since that time, at the i
request of the Board, Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy have joined interventions and are hereinafter referred to as i "Intervenors." i In May,1985, Applicants filed a Preliminary Draft emergency response plan for Burke County. No mention was made of when a final plan would be ready, and no j mention was made of a plan for Richmond County. At the end of May, 1985, counsel for the Applicants mailed a letter to counsel for the Intervenors stating that the Richmond County plan had been filed earlie: in May; again, no mention was made of when a final plan would be completed and no mention was made of a plan for Richmond County.
On Friday, June 21, 1985, counsel for Applicants informed a representative of
- i Intervenors by telephone that there would be no plan for Richmond County and that the " Preliminary Draft" plan for Burke County was in fact the final plan. Counsel 4
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for the Applicants said he was at a loss to explain why the Board had stated that a plan for Richmond County would be submitted. He further stated that no further plans would be submitted.
Intervenors submit this contention relating to emergency response based on Applicants' statement in late June that all emergency. response plans have been filed; the cover of what Intervenors received from Applicants in early May is enclosed, and is clearly stamped " PRELIMINARY DRAFT" in huge lette'rs, letters far larger than the title or anything else in the plan. Further, every page of the plan is stamped DRAFT. There is absolutely no indication anywhere that this is intended by Applicants to represent their final plan.
Only by phone on June 21 did Applicants notify Intervenors that the " final" plan had been submitted. Therefore, Intervenors have until thirty days past that date to file a contention based thereon.
This contention is therefore timely filed in compliance with the order of the Licensing Board.
Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy hereby submit the following contention relating to emergency response, followed by the basis therefore.
Applicants proposed emergency plan fails to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Plant Vogtle, as required by 10 CFR 50.33, 50.47, 50.54 and Appendix E to Part 50.
Applicants fail to show that each principal response organization has the staff to respond and to augment its initial response on a continuous basis, as required by 10 CFR 50.47(b)(1). For example,' Applicants rely upon the Burke County Emergency Management Agency to coordinate emergency planning and operation activities.
Applicants fail to note, however, that Burke County has no full-time emergency manager or office. In addition, in listing the state agency resources available to 2
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respond to an emergency at Plant Vogtle (Table D-1) Applicants fail to include an estimate of the number of personnel available at each agency.
Applicants fail to show that provisions exist for prompt communications among principal response organizations to emergency personnel and the public as required by 10 CFR 50.47(b)(6). For example, the Burke County plan states that the means of communication among local governments and respective department / agency personnel within the Plum Exposure Pathway GPZ are, primarily, dedicated circuits and connercial phone lines, and secondly, radio systems. This plan ignores the probability that both dedicated and commercial phone lines will quickly become overloaded and incapacitated and in the event of a radiological accident at the plant the limited radio bans made available to emergency response vehicles will just as quickly become congested. In addition, the Acting Director of Emergency Management of Richmond County, Pam Smith, states that she occasionally has difficultycontactingemergencypersonnelinBurkeCountyduetothelackofafull-time emergency planner. The plan provides for notification of the public in the Plume Exposure Pathway by use of tone alert radio receivers installed in each household in the EPZ. This provision ignores the fact that these devices are often shut off permanently by residents who become aggravated by its tendency to go off frequently without reason. Applicants cannot ensure that all residents have televisions or radios to turn to for additional information in the event of a radiological accident. Applicants list a number of warning devices that might be implemented such as autos and boats equipped with sirens or loudspeakers, door-to-door contact in remote areas and aircraft equipped with sirens to be used in remote areas; however, there is no assurance that such equipment is available to local governments or that personnel will be available to operate this equipment. An adequate county-wide siren warning system which Smith sees as a top priority in the event of Vogtle operation would require installation of a minimum of 200 sirens for
$5,000 each, totalling $1,000,000. The County has lacked the funds to install such 3
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a system in the past. The plani also fails to address how sirens will operate in the event of a power failure. Additionally, Applicants provide no assurance that
! transients who are unfamiliar with the area will understand the implications of a warning signal in the event they are able to hear it. Also, Applicants fail to provide adequately for notification and evacuation of hearing impaired and other handicapped persons.
l Similarly, Applicants fail to show that they have the capabilities to notify responsible state and local governmental agencies within 15 minutes after declaring an emergency as required by 10 CFR Appendix E(10)(D)(3) because they rely upon the same unreliable means of communication (dedicated and commercial phone lines and radio)asdescribedabove.
Applicants fail to show that adequate emergency facilities and equipment to
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support the emergency response are provided and maintained, as required ty 10 CFR 50.47(b)(8). For example, the Burke County plan shows the county has only four emergency medical response vehicles. The Burke County Hospital, which the Plan says will handle the treatment of both radiation-contaminated and noncontaminated injuries, has a bed capacity of only 52. Such facilities are unlikely to be sufficient to service a large number of injured in the event of a fairly serious radiological accident or of an accident external to the plant which results in injury to the plant, such as an earthquake or a nuclear attack, where non-plant
, related injuries will also be rampant. Furthemore, the Plan does not specify whether the designated Reception Center, the Burke County Comprehensive High School, has developed an adequate plan for early evacuation.
4 Applicants have not shown, pursuant to 10 CFR Part 50 Appendix E, IV D.2 and 50.47(b)(7) that adequate and credible education and notification procedures will be followed during nomal plant operation and in the event of an accident at Vogtle.
These requirements include " basic emergency planning information," " general
(
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i information as to the nature and effects of radiation," " signs or other measures... helpful if an accident occurs." 10 CFR Appendix E. IV, D.2.
Applicants claim that the Department of Energy (Savannah River Plant Operations Office, Aiken, South Carolina) will provide radiological assistance (advice and emergency action essential for the control of immediate hazards to health and i safety) in the event of an emergency at Vogtle. It fails to address the possibility that an emergency situation (for example, an earthquake) 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. Applicants do not address the impacts of simultaneous evacuation from both plants, or overload of medical facilities and emergency vehicles in the event of injury to persons by the operation of both plants. Nor do Applicants adequately discuss coordination of activities of Georgia and South Carolina's agencies.
The evacuation of the 145,000 citizens of Augusta who live within 26 miles of Plant Vogtle is not addressed in the Emergency Plan though Applicants should be prepared for the displacement of a significant number of the population outside the EPZ due to predictable public response to a limited evacuation. For example, during the accident at Three Mile Island-2, over 30% of the people living within a fifteen mile radius of the plant evacuated though only a precautionary warning to pregnant l women and small children within a five-mile radius of the plant had been issued.
(J. H. Johnson, " Planning for Spontaneous Etacuation During a Radiological l Emergency," Nuclear Safety, Vol. 25, No. 2, March-April 1984) Nor is the likelihood that people will disregard official orders and instructions during a nuclear power d
plant accident. (Ibid.)
- Applicants have failed to plan for a situation where emergency response is 1
hampered by an earthquake and resulting structural damage to roads. The Plan also 5
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1 fails to address the fact that in the event of an earthquake, sheltering is not l l
possible as residents are directed to remain outside houses and other buildings.
l Applicants have also failed to provide a complete list of the orchards and farms within the congestion pathway. y Applicants fail to address the effects on evacuation of the many thousand construction workers at Unit 2 of Plant Vogtle if an accident should occur at Unit 1 t before completion of construction at Unit 2.
In light of the afore-mentioned facts, Applicants have failed to show that in the event of an accident at Plant Vogtle, adequate notification, communication, }
education, evacuation and relocation can take place for permanent, transient and special populations living within the Emergency Planning Zone.
I Respectfully submitted this, the 24th day of June, 1985, !
Tim Johnsdh i Executive Director i Campaign for a Prosperous Georgia i 175 Trinity Ave. SW l Atlanta, GA 30303 l 404-659-5675 for Intervenors Campaign for a Prosperous Georgia ,
and Georgians Against Nuclear Energy 6
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PRELIMIN ARY I
DRAFT .
ANNEX D PLANT YOGTLE TO THE GEORGIA RADIOLOGICAL
'?"dC W W' up EMERGENCY PLAN (Io APRIL 1985 1
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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 00LXETEP In the Matter of ) USNRC
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GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425 g g3 g (Vogtle Electric Generating Plant, )
Units 1 and 2) )
CERTIFICATE OF SERVICE 0FFICEBRANCH OF 00CHETING & SERV p
6 This is to certify that copies of the foregoing emergency response contention I were served by hand or by deposit with the U. S. Postal Service in the City of l Atlanta with first class postage attached to be delivered to the Secretary of the i Comission, the members of the Licensing Board and all others listed below, this l 24th day of June, 1985.
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Tim JoNhson SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 g Dr. Oscar H. Paris Docketing and Service Section Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Gustave A. Linenberger Bernard M. Bordenick, esq.
Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Comission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel Ruble A. Thomas U.S. Nuclear Regulatory Comission Southern Company Services, Inc. l Washington, D.C. 20555 P. O. Box 2625 ,
Birmingham, Alabama 35202 Bruce Churchill, esq.
Shaw, Pittman, 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 l James Joiner, esq. i Troutman, Sanders, Potts & Trowbridge !
The Candler Building Atlanta, Georgia 30303 1
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