ML20084L632

Response to Applicant Failure to Put EPZ Map Into Offsite Emergency Plan.Local Emergency Response Needs & Capabilities,Topography & Meteorology Not Appropriately Considered.Certificate of Svc Encl

ML20084L632
Person / Time
Site:	Harris
Issue date:	05/10/1984
From:	Eddleman W, Eddlwman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8405140559
Download: ML20084L632 (4)

Text

14 6 UNITED STATES OF AMERICA May 10,1981; NUCLEAR REGULATOBY COMMISSION gNC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '84 NAY 14 A10:1 Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman [o$.[rMg

. Y$$di;c, BRANCH In the Matter of CABOLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, Unit 1) ASLBP No. 82-k66-01

) OL Wells Eddleman's Response to Harris FPZ Map Applicants (and the State of NC and other emergency planners) failed to put a map of the Harris EPZ into the offsite emergency plan (PlankppendixIjustsaysthemapwillbeaddedlater).

i Applicants did put a map into their site emergency plan,

! (amendment 2?) which they claim is the man for the offsite emergency l

planning zones. Why they screwed things un like this is beyond me, since if the map was so well known as Annlicants' lawyers claim, they should be able to find a copy and get it into the offsite emergency plan, which is the thing it is relevant to. NUREG-065h II.J.10 requires such plans to" include mans showing evacuation routes, evacuation areas .!

" Neither the State nor Applicants did this, (p.61, item II.J.10.a).

i Nevertheless, the Board orally orderedintervenorstorespondto i the map as soon as possible. So here goes: l 250. The map fails to connly with NUREG-0654. II.J.10.a because it does not show the relocation areas, relocation centers or shelter areas. l The man is also, in the size producted, virtually illegible, violating .

ri i the cisterion for " showing" the information.

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251. The man fails to comoly with NURM-0654.II.J.10.b because it does not show the population distribution around the facility nor does it show the popuklation by evacuation areas.

A separate listing in sec6or format (as is in the HMH study if not in the plan) does not meet this requirement: 0654 says " licensees '

shall also present the information in a shelter format). I reiterate my. objection that the information must be ja the plan. NUMEG-0654 is clear on this point (p.61, item II.J.10 says the organization's plann ... shall include" the items listed in a, b, etc below).

252. The setup of zone C on the map includes a peninsula junstting into an area much closer to the plant; the setup of zone B includes a salient including part of the exclusion area of the plant. 1 Both the zmone C peninsula (west of what anpear to be the P lane NC highway #751) and the salient of zone B ("the tongue" along white ,

oak creek) should be included in zone A to assure trotection of any ,

persons in those areas in an accident. No rationale for the exclusion of these areas is given, nor wous1d one make sense, since both are equally as close to the plant as much of zone A. Why a part inside the exclusion area is left out of Zone A is just unfathomable to me. ,

l NUREG-0654 II.J.10.m requires basis for choice of protective action, and that requires a basis for distinguishing these areas fron Zone A unless they are included in Zone A, since Anoropriate protective action in the plan is deternined by zones (or anpears to be: HMM study part 7: this is not "in the plan" as -0654 II.J.10 requires). ,

253. Evacuation routes from zones E,F and G are toward-Raleigh and in the path of prevailing winds. Such winds, or a wind shift during evacuation, could imneril the evacuees and violate 10 CFR 50.47(a)(1)'s requiremment that anpropriate nrotective action will be carried out. In addition, the turn sharply north onto NC55 (a 2 lane miles to J5 Sad) putspond the evacuees side the to EDZ boundary for 3 1 nson's (see azonebaa G) effgsc6 @ fhas uJ fre%Ig vo wJj,

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1' 3 254 No rationale is given for excluding varioud areas within the 10-m11e radius of Harris from the EPZ. It appears that roads either near the inside or near the outside of the 10-mile radius were somewhat arbitrarily chosen to keep the EPZ boundary partly inside 10 miles and partly outside 10 miles. But this obviously denies nrotection to those within 10 miles of the plant but not included in the EPZ. Absent some statement of local conditions that make such exclusion appropriate, this violates 10 CFR$0.47(c)(P).

Local emergency resnonse needs and capabilities, topography, meteorolocy and so on do not appear to have been annropriately considered in setting the boundary of the EPKZ. Indeed, the plan gives no indications these factors were considered at all, bNf O'b N CCffRt%/ OA) Of k (OCb I 2 3 ^) 00 & NCW.^) COW { 5 '

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UNITED STATES OF AMERICA

! NUCLEAR REGULATORY COMMISSION I

Docket 50-h00 In the matter of Ct.ROLIKA POWER k LIGHT CO. 1' Et al. J) 0.L.

l Shearon Harris Nuclear Power Plant, Unit l

I CERTIFICATEOF SERVICE I hereby certify that copies of Wells Edd_ leman's Restense on

! Emergency Planning Contentions  ! Lt)[ k 6 <

ale 'tv NCNVl_C E @ /LP h

l HAVE been served this 10** day of May 198 1 , by deposit in the US W il, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are rurked with Express Mail

! an asterisk, for whom service was accomplished by

• • Oral extension til lith was geanted by Judge Kelley 5-10 ir naecessars j g)45 rn t< k A + Sp MNied 3- t ( + '7s E l

Judges James Kelley, Glenn Bright and Jae.as Carpenter (1 copy each)

Atomic Safety and Ticensirg Board US Nuclear Regulatory Comission Washington DC 20555 l George F. Trowbridge (attorney for Applicants)

Shaw, Pittnan, Potts & Trowbridge R.uthanne G. Miller 1600 M St. NW ASLB Panel WashinEton, DC 20036 USNRC Washington DC 2C55 5 Office of the Executive Legal Director Phv111s Lotchin, Ph.D.

Attn Docke ts 50-400/k010.L. lob Bridle Run USNRC Chanel Hill

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NC 2751h Washington DC 20555 Dan Read Docketing and Service Section (3x) CEA!ET/TLP Attn Docke ts 50-h00/h01 o.L. .

Waleigh,$707 NC Waveross l

Office of the Secretary 27606 l

USNRC Dr. Linda W. Little Washington DC 20555 Governor's Waste Mst. Bd.

513 Albenarle B1dg.

J hn Runkle -

325 N. Salisbutv St.

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Granville Rd <

Chapel Hill Ne 2751L Bradley W. Jones Robert Gruber USNRC Region II

'Travi s Payne Exec. Director 101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 30303 Bkx 12607 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D. Certified by .8t h 729 Hunter St.

Apex NC 27502