ML20092N498
| ML20092N498 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/29/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Federal Emergency Management Agency, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20092N499 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8407030209 | |
| Download: ML20092N498 (12) | |
Text
{{#Wiki_filter:. 00 \\ i 'k [ RELATED CCREE3?CNDENCE y g UNITED STATES OF AMERICA ) . a. g., NUCLEAR REQUIATORY COMMISSION '84 J1. -2 P 3 M 7 BEFORE THE A10MIC SAFETY AND LICENSING BOARD r Glenn O. Bri Dr. James H.ght Carpenter James L. Kelley, Chairman 1 In the Matter of ~ CAROLINA POWER AND LIGHT CO. et al. Shearon Harr s Nuclear Power Plant, b i it 1 h ASLBP No. 82-h68-01 i h OL j 'and PEMA Wells Eddlongn g' Interrogatories to NRC Staff ~ b' . Set) l and FEMA requests the NRC Staff to answer the following i Wells Eddleman here A 198$orsuchotherdateascounselfortheStaff These int.orrogatories are submitted under 10 CPR 2.720(h)(ii) interrogatories before ', July l and I agree on. and inquire into the studies, information, and knowledge of NRC staff with l Since I cannot read l respect to my contentions, on sich discovery is now open. the minds of the staff, and this information is not contained in documents l Wich the staff has provided to ne, I an unable to obtain this infornation by Were the information is contained in a document I can obtain from NRC (Public Document Room, etc). I still need the identification of the I other means. document in order to obtain the information. The staff has resources and i information dich exceed dat I have, and as a party,' their position and information are necessary to making my case in this proceeding. These interroga. l t tories are continuing in nature and should be supplemented den answers change. GENERAL I!CERROGATORIES (FIRST SET) I In all interrogatories heyein, "you" or" Staff" means NRC Staff.or'9'EMAEddlenan contentions '3, ' ' " E ! P For each of contentione ~ 0 ~ $7. c-3,; 57-9119',i
- 0-13,213,215,224 please provide sne foI owing information tgr answering ead of these questions.
1. Wat s NR S aff' at n n t , subject matter of this r l contentionf 2. Ha C ffma bi n [nto,(a) this contention (b) l the subject matter of this' contention fc) the allegation (s) in this contention (d) the basis of this contention (e). the information relied upon by intervenor(s) in support of this contention?
- 3. For all parts of your response to Interrogatory 2 above for dich your who made l
answer is affirmative, please provide the following information: the analysis, inquiry, study or investigation; d at was being considered in such analysis, inquiry, study or investigation ("AISI"); 1.he content of the AISI, the results of the AISI, whether the AISI has been conple6ed, whether a date for completing _the AISI has been establishoo if it is not complete, what that date is, au documents used in the AISI, all persons consulted i 8407030209 840629 9 509 PDR ADOCK 05000400 C PDR 3 l.
. -. ~ ,e,a w -~ -2 in the courco cf the AISI, on docunsnts c::ntaining informaticn discsv;rsd j or analysis or study or information developed during or as a result of the AISI (identify each such document and state dat information or results it contains), Wether staff believes additional analysis is warranted, or further AISI needs or may need to be undertaken on this contention, and whether any persons participating in the AISI are to be called as witnesses for the Staff in this case,and What questions the staff AISI is intended to answer and dat information it seeks to develop if it is not co_nplete. For au responses to parts of (2) above for which NRC staff's or Vgyy}g if 4. answer is other than affirmative, please state (a) whether NRC staff ory:op plans to perform any AISI on this contention, (b) d ether anyone on EC Staff has stated that AISI of av) kind is warranted for this contentio (even though it has not been made) (c on this contention include a date for beginning or for ending)such AISI, W at AISI (d) those dates, for an affirmative answers to (c) above (e phorMRC staff win undertake on this contention (f) Wat AISI NRC' staff desires to undertake on this contention (g) an reasons why no AISI is planned on this contention if none is planned (h) all reasons why no AISI has i l done yet on of NRC staff th respect to this contention are. w me-a # FEBH I relied on in opposing the admission
- 5. Identify an documents the facts not stated in the Staff's opposition of this contention, and av specif j
to admission of such contention (already filed in this case) upon which Staff relied in making such opposition. I
- 6. Identify an documents not identified in Staff's interrogatories to Wens Eddleman or to Joint Intervenors (to present -- a continuing interrogatory )
upon Wich the Staff relied in making each such interrogatory. FT/h & or f Identify by name, personal or business address, ERC staff position 7 or title (if av), and telephone number (if known) eact0 person on NRC staff j or consultant to MRC staff or known to NRC Staff or consulted by NRC staff l in the staff's ana37-is of the subject matter of this contention prior to (a) its filing (b) 11,s adnission; State for each such person what analysis I was performed tqr that person. I i State au professional qualifications of neh person identified in 8. response to interrogatories 7,, 'R 1 ' 9. Provide av statements of +he analysis made by persons identified I in respor.se to interrogatories 3,4, or 7m above, and identify an documents l containing such information or, statements not previously identified. i ,c' l ~ Give the identifier mmber, date, source, and title of an documents l identified in response to interrogatories above, d ich are available through l 10. MRC PRIR (Public Doessment Boom). j Win NRC Staff make available copies of documents identified in H. response to the above interrogatories to Wens Eddleman for inspection l and oo;qring, for documents not available through MRC's PIE. j ff/Mh of MRC staff position if a g, address and telephone j
- 12. Identify tqr nameq number each person ton NRC staff intends to uxa use or can as a witness
( in this proceeding.
- 13. State fully the professional qualifications of each person identified l
in response to interrogatory 12 above. f i i i
3_ ~ - 14 Sumarico th3 positien (or plcnned testimony) with respect to each conte.ntion on which such person is expected to testify, for each person identified in response to interrogatory 12 above. hW Ha$ C 5%ff, av witness identified in response to interrogatory 15 12, or a go acting in behalf of the Staff or such a witness or at their direction, made ag calculation or analysis (not identified in response to interrogatories 1 through 4 above) with respect to this contention?
- 16. If.the answer to interrogatory 15 above is yes in any case, provide the nane, business or personal address, telephone number and professional qualifics.tions of each person to has made such calculation or analysis, stating for each dat contention it relates to, what person (or Staff) it was nade for or at the direction of, and identifying all documents j
containing such calculationer analysis and an docunents used in n;aking j such calculation or analysis or relied upon in it or supplying infornation i used in it. j 17 Provide a sumary of each AISI, calculation or analysis idan for which the answer to interrogatory,15, or interrogatory 2 above, is yes. l
- 18. Please give the accession nunber, date and originat'cr of each j
doeur.ent identified in response to interrogatory 16, which is available I at the EC PE. Md of 19 WL C Staff make available to Wens Eddlenan for inspection and copying all ocuments identified in response to interrogatory 16 above which I are not available-through the PET I of expertise and qualifications (c:r.plete) (phone number, address, and
- 20. Identify each person, including teleif any) 2n who answered interrogatories with respect to this contention; if more than one persen l
contributed to an answer, identify each such person, providing the information l requested above in this interrogatory for each such person, and state what each such person's contribution to the answer was, for each answer. k~51fr F i
- 21. Identify an documents W ich th taff proposes or intends to use as exhibits with respect to this content on during this proceeding, including t
exhibits of Staff witnesses (identifying the witness for each, if such a j witness has been designated), and exhibits to be used during cross-examination of witnesses of a g party (stating f.r each which witness it is to be used in cross-exanination of), and identLM for each the particular pages j l or chapters to be used as exhibits.PMk or interrogatories with respect to this^BC staff relied upon in answering 22 Identify an documents Wich contention, W ich have not been identified in response to interrogatories 1 through 21 above, stating for each which answer (s) re which contention (s) it was used for, and each j specific fact and page number therein on dich EC staff relied or which j EC staff used in answering such interrogastory. j
- 23. Please give the accession nunber, date, and originator of each document identified in response to interrogatories 21 or 22 above which is available through the E C P2.
] F6thh ov~
- 24. W111 EC Staff provide Wells Eddleman with copies of the documents a
identified in response to interrogatory 21 or 22 above dich are not available l at the P M, for inspection and copying? -n --~-,.,,..,,.....m., n
_ -. =.: .g. ON 25 Identify any other information or source of information not identified in response to the the above interrogatories 1 thru 2hyphib[1 g V upon which any member of NRC staff reliefd, or which any such I member of staff used, in answering each interrogatory with respect i to this contention, naming the contention and response in which each such source was used, and the location of the information used or relie8 on in such source (e.g. page number, section, chapter, etc).f rFEV1V 2 (a) Does the Staff,now agree with the contention? (b) Does the Staff not agree with iny part of the contention? 27 If answer to (b) above is affirmative, which part(s) and why? i F I 1 i ~ SBECIFIC I'NTERROGATORIES. "You" means (to Staff / FEMA) NRC Staff or FEMA or any gerson answering these interrogatories for FEMA or NRC Staff. 'You means, to Applicants, Applicants or the State of NC l or the E NC Dept of Crime Control and Public Safety, or appropriate l county or state emergency response planners or personnel, e.E. those supplying answers to these interrogatories or having knowledge l of the matters inquired about. 57-C-3-1(a) Do you know of any provisions for nighttime notification r ( of residents or transients (i) within the EPZ (ii) who are asleep (iii) who are in boats or houseboats or other craft on either (iii-a) J rdan Lake, or (iii-b) the Harris plant lake? o (b) What are these provisions?' Please identify all documents containing such provisions and state which such documents are part of the emergency response plan (offsite) for Shearon Harris. If any such document is part of another energency response plan, e.g. Harris on-site plan or other state our county emergency response plan or contingency plan, please identify that plan also, for each such document. (c) What provisions, if any, are in the brochure to be sent to EPZ residents, concerning action to take if a nuclear accident offurs at night? (d) what provisions among these concern sheltering, turning off amir conditioners or air-to-air heat exchangers, or i ' closing a windows? Please identify each such provision and which of the above items it relates to. (e) Do you know of any plans for telenhone notification of (i) residents of the EPZ (ii) transients in motels, hotels or other lodging in the EPZ, for accidents at the Harris nuclear plants? If so, nlease identify each such plan and all documents concerning it. (f) Have you ever considered telephone notification of persons within the EPZ in the event of a nuclear accident? If so, please identify all documents concerning your consideration of this matter.
-{ i 57-C-3-2(a) Are automatic telephone dialing systems available to (1) CP&L (ii) the State of NC (iii) Wake County (iv) Chathan County i (v) Harnett County (vi) Lee County (vii) other authorities who would be involved in ordering sheltering in the event of an i nuclear accident at-Harris? (b) What are the capabilities of the automatic telephone dialing systems available to each such organization? Please include in your answer (i) number of numbers dialed per hour (ii). ability to dial a preprogrammed set of numbers t (iii)' ability to have inout a set of numbers to dial (iv) ability [ to automatically dial back if the phone is hung up before a message is completed (v) length of message the system can deliver (vi) audio quality of message the system can deliver (vii) capacity i OF Telephone lines (e.g. number of lines) the system requires, (viii) other technical requirements of the system, e. supply, actuation, reset if errors in dialing occur (g. for power ix) whether the system can function with a backup power supply if electrical power to it is lost, and whether such backup power supply is in fact provided for it. (c) Please detail the capabilities of any automatic telephone dialin for use (ii) plan to buy (g system which you have (1) considered iii) know is available for purchase. 213-1(a) What is the specific responsibility of (i) CP&L (ii) I the State of NC (iii) Wake County (iv) any other authority or agency you know of, for notifying boaters, swimmers or others l on or in the Harris plant lake in the' event of a nuclear accident i at Harris? (b) Please list every means by which you will carry out such notification, and state whidh document (s) detail these means, your authority or ability to use them, and what personnel are required to operate these means (number of persons, where they work, who will notify them, how long they will take to begin operating the means of notification. (c) Please state how long each means of notification will take to notify all nersons on or in the Harris lake, and for each means, what backup means of notification will be used if there is a failure of the first means.- Please also describe the provisions for sheltering or efacuation which will be announced to persons on or in the Harris lake. ! '(d) What means, if any, are provided for vergifying daat persons l on the Harris lake have been notified of an accident at Harris? Who operates'each such means? Who is responsible for each such l l means being used? Who will receive the reports of such verification? i How will each such person receive each such report? r 213-2(a) In what respects do provisions for notification of i t persons (1) on (ii) in (iii) on the shores of, the Harris platt lake, differ from vrovisions for notification of versons in or on corresponding parts or areas near Jordan lake? (This means for notification of an accident at the Harris plant.) (b) For each f such difference in provisions, do you have any reason for the difference? If so, please state in what documents your reason, { or reasonging, for having this difference in notification provisions i for the Harris and Jordan lake areas, is. (c) Please explain any modifications to be made in notification urovisions for the i people in, on or around the Harris lake by (1) Wake County (ii) CP&L (iii) other emergency planners, including the State of NC. l -, _ _ ~ ~ -. _.. _ _ _ -. _ _ _ _ _ _ _ _ _. _ _ _
-h-l 57-c-10-1(a) What study, if any, have you made of sheltering I effectiveness for shelters typical of those available within the Harris EPE?. (b) Please identify all docunents in which j you make such study, or any analysis of sheltering effectiveness for such shelters. (c) What study, if any, do you plan to make l of sheltering effectiveness for shelters typical of those to k be available near Harris? When will each such study be completed' Who is doing each such study? What are their qualifications to do it? I Who will receive the results of each such study? t (d) Does any study referred to in your respons3s to (b) or (c) above establish sheltering effectiveness for (i) houses without i basements (ii) brick houses without basements (iii) cinder block i basements (iv) brink-walled basements (v) basements above ground level (vi) basements sunk partly below k ground level (vii) motels or individual motel rooms (viii) restaurants (ix) public buildings (x) farm buildings (xi) storm cellars (xii) wooden houses (xiii) solar or passive solar houses (xiv) any structures, in terms of typical numbers of air changes per hour (xv) any structures, f in terms of measured numbers of air changes per hour (xvi) any structures, by relying on typical characteristics of such i structures? (e) Please identify all documents containing data l ~ on the sheltering effectiveness, or measurements of air changes, j or characteristics of shelters, which you have used or.will used in addressing the effectiveness of sheltering for typical structures l around the Harris plant. (f) Please explain yourmethod for assessing l sheltering effectiveness for homes, dtc., in the Harris EPZ'. 57-C-10-2(a) Have you made any determination of sheltering) effectiveness for any (1) school (ii) day care center (iii church or other house of worship (iv) other structuressam open to the public or used by more than 10 persons (other than homes or apartments)? (b) Was your determination of sheltering effectiveness made (i) for a typical such structure (ii) for i a specific structure (please identify) (iii) by any other method? i (c)Please explain, identifying all documents used for data or t assumptions, and identifying all calculations and methods used, how you determinted the sheltering effectiveness for each typh of structure inquired about in part (a) above. 1 57-c-lo-3(a) Please identify all documents, methodologies, data, equations, calculations or other information you have used, l i or plan to use, in calculating or determining sheltering l effectiveness for structures within the Harris EPZ. (b) Please l l identify all documents containing such information. (c) Please identify all documents you possess which describe methods of l figuring, calculating, or assessing sheltering effectiveness. ( (d) Please state why you have adopted or used any methods, data or calculations of sheltering effectiveness which you have used r l with respect to structures near Harris or in its EPZ'. (e) Please l state and describe in as much detail as you know, what kinds of structures you consider " typical" of those mwnstk available for sheltering in the Harris EDZ. Please identify all documents or information and all opinions you rely on in considering each tyne l or structure typical. How many tynes of structures have you l assessed sheltering effectiveness for within the Harrie EPZ? l l 57-c-10-4(a) ho you possess any informaMon on the (i) number (ii) types (iii) number of persons in (iv) times of day persons l are in, structures in the Harris EPKZ? (b) Did you consider
57-c-lo-4(b) continusd i medical or dental offices l stores, schools, farm baildings, theaters,j public buildings,) motels, day care centers, or other buildings in collecting data on types I of shelter available in the Harris EPZ? (c) If so, what data do you have on each type of building inquired about in (b) above. tdi IAxymaxdidmaatmamanidsunxmmaxmxmacutexmfmthx (d) For each type of building listed in (b) above that you haave no data on' or did not zum consider, please tell why you (i) have no data on, or (ii) did not consider, that type of building. (e) among the types of structures inquired about in this interrogatory l 57-c-lo-54, what structurnal characteristics, air-change characteristics or other characteristics do you think are anpropriate to consider to determine sheltering effectiveness for each such type? (f) Please identify all documents in which data, determinations or information concerning the matters inquired about in (a) ~ thru (e) and all subparts, inclusive, above, are contained. 57-c-13-1(a) Have you made any determination of the best Protection f Factor (PF) available in any (i) hospital (ii) nursing home within the Harris EPKZ? (b) If so, how did you make that determination?! Was an on-site survey conducted? How did you get your data about cnaracteristics of the structure? Did you consider any data about air infiltration into the structure? Please identify all documents concerning each determination of PP you have made for any school l or hospital within the Harris EPZ and how that PF was determined. (c) Have the data used in your PF determination been checked by anyone? If so, by who and when? Please identify all documents concerning checking of such data. (d) How many people can fit l into the area with the best PF in each (i) hospital (ii) nursing j home,.in the Harris EPZ? (e) What provisions for patient characteristics (e.g. ambulatory, non-ambulatory, need for special medical supplies, need for nursing access, sensitivity to heat, to cold, or to reduced oxygen and/or stuffy conditions l in a closed area) were included in your determination or estinate of how may people wil1%itxints fit into the area of best PF in each specifio (1) hospital (ii) nursing home, in the Harris EPZ? (f)What is the maximum capacity of each (i) hospital (ii) nursing home within the Harris EPZ? (g) What food supplies would be available l int the area of highest protection factor in each (i) hospital (ii) nursing home, within the Harris EPES, in the event of a long-term l sheltering being required? What water supplies would be available in the highest PF area within each such hospital or nursing home? (g) If all the peoole in the hospitel or nursing home can't sti fit into the highest PF area, what is the PF of the next-highest PF area within such hospital or nursing home? How many neople can this next-highest PF area hold? What regard of medical conditions oir needs of persons to be sheltered in this area was taken in j your determination or x estimate of how many peoole would fit into this area? t 57-e-13-2(a) Are there any means of increasing PF for hospital or nursing home areas within the Harris EPZ that you have (1) considered (ii) recommended to the operators or owners of those I hospitals or nursing homes? (Mb) are there any care facilities within the Harris EPZ which care for adults but which you define l as being neither a hospital nor a nursing home? Please identify l each such facility and state why you believe it is not included i within the term "hosnital or nursing home." i i
l i 4 30-1(a) Has any determination of the quantity of potassium iodide (KI) to be kept at any location (e.g. county health department) for use as a radioprotective drug in an emergency at the Harris plant been made? (b) How, if at all, does each such determination take into account the " shelf life" of the KI? (c) Who made each such determination? (d) How was each such determination made? (e) Please identify each document concerning each such determination, and also all documents containing information used in making each such determination. (f) Please state what information, from what specific source (page reference please) was used in making each l such determination. (g) How many persons are to be provided with t KI from each location during an emergency? Please state the numbers of emergency wor'kers, the nunber of persons not mobile (e.g. in nursing homes), and numbers of other persons for whom KI is to be provided from each location where KI is stored t for use in am radiological emergency at Shearon Harris nuclear plant. (h) Are there any reserve supolies of KI available within the l Harris EPZ for use in an emergency? If so, who determines where these reserve supplies are and how much is in each location? [ (1) what dose (s) are provided per person in the KI stored for l use in a radiological emergency at Harris? If no KI is now stored t for this purpose, what dosse(s) are planned to be provided per person? ! 30-2(a) If quantities of KI for use during a radiological emergenycy at Harris have not been determined yet, when is such determinat1on to be made? Please explain how each*of dae matters asked about i in 30-1(b) through (1) above will be addressed in such determination. (b) Please state who is making the determination of KI quantities i which is going to be made. (c) Please state who will make each such determination and whether each such determination will be r included in the Harris emergency resnonse plan. (d) Please identify l all points int the Harris emergency response plans where specific quantities of KI or other radioprotective drugs are ment!oned. 224-1(a) What analysis of the frequency of weather events, includigng fog, ice, snow, rain, heavy rain, hail or other advmerse weather, have you made for the Harris EPAZ? (b) What information do you have on the frequency (both (i) typical, and (ii) maximum i in any recorded data) of (aa) fog (bb) ice (cc) uma snow (dd) rain (ee) " heavy rain" (ff) hail (gg) rain above 1 inch per hour (hh) rain above 3 inches per hour, in or around the Harris EPZ ofr in areas believed to be similar in meteorology to the Harris EPZ? Please identify all documents containing such information. i (c) Do you have any other a information concerning frequency of l adverse weather in the Harris EPZ or in areas of sim$1ar meteorology? If so, please identify all such other information and all docu$ents [ containing it. i 224-2(a) Please state what sensitivity analysis for frequency I of adverse weather was included in the Harris evacuation time i 2 estimates. (b) If you reviewed the Harris evacuation time estimates, what analysis, if any, did you make of the sensitivity of such time. estimates to the frequency of adverse weather? Please identify all documents concerning (1) your analysis of the Harris evacuation i time estimates (ii) sensitivity of such estimates t. adverse weather { conditions (iii) sensitivitt of evacuation time estimates to i the frequency of adverse weather donditions. (c) Please state what i 'further analysis of adverse weather frequency and its effect on Harris l evacuation time estimates you plan to make, and when it will be done.
215-1(a) How do recre4tional populations at (i) Jordan Lake (ii) the Harris niant lake (iii) other recreation sites within the Harris EPZ, vary with (aa) time of day (bb) day of week (cc) season of year? Please provide what data you have on variation of recreational populations in each recreational area in the EPZ, including numbers of ' overnight users of each.th,m*xmamm (b) What data provided in response to (a) is based on actual observation? (c) What basis do you have a for estimates of recreational populations near Harris at various times of the day, week and year, other than r observation? How realistic is such basis in your view? Do l you know methods to check the realism of such estimates? What l are such methods? Are you doing any checking of the realism l of such estimates? If so, how? Do you plan to check the realism of estimates of recreational populations in the Harris EPZ l before the plant operates? Before the evacuation plan is tested? i (c) What data do you have on vehicle occunancy rates in the Harvis l EPAZ (i) at any time or times (ii) in the early morning, e.g. 6-9 am (iii) in the early evening, e.g. 5-7 pm (iv) between a llam and 1 pm i or in that range (v) after 7pm but before midnight? Ba (d) Do any of your data on vehicle occupancy rates in the Harris EPZ vary by day of week or season or date in the year? If so, how i does each vary? (e) Please identify all documents concern $ng actual occupancy rates of vehicles in the Harris EPZ which you i (i) possess (ii) know of.(f) Please identify all documents l concerning recreational nonulations in the Harris EPZ or how thesen populations vary at varying. times. (g) Please identify all documents concerning estination of (i) vehicle occupancy rates (ii) recrettional ponulations, in the Harris EPZ, or xx basis for such estimates, or data used in such estimates. 215-2(a) Please state if you know what numbers or percentage of I the Harris 5 EPZ population is at home (i) with transnortation l at home (ii) without transportation at home, at varying hours of the day or year or at any time (s) (please specify times for i which you have such information. (b) Please state what investigation j er analysis or data collection you (i) have made (ii) will make (iii) are making concerning numbers of nersons in the Harris EPZ l who are at home at any time or times of the day or year. i l 215-3(a)Do you know how many vehicles are available to each I household within the Harris EPZ (1) as owned or rented vehicles (ii) at any time of the day, e.g. during work or school hours (iii) located at or near the home of each household, at any time or times of the day or year? (b) Please detail all data you have on the numbers of vehicles available to each household in the Harris EPZ at any snecific times. (c) Please detail all l data, information or documents as to the number of vehicles each I hoursehold (or a typical household) in the Harris EPZ will use I to evacuate in the event of a nuclear accident at Harris. l 215-4(a) Have you made any study of how many persons would evacuate from a location other than their home(s) within the EPZ in the event of an accident at the Harris nuclear plant?(MHave you studied where neople would actually evacuate from under daytine or evening condlM ans from the Harris EPZ at any date or season of the year? l l (c) Please identify all documents concerning such study or studies. I
~ t g-215-5(a) Have you determined Ehe distance from each (or any of the) non-car-ownig household (s) in the Harris EPZ to each's nearest neighbor?~ (b) Have you determined how many non-car-nowning households i have telephones over which they might ask neighbors for rides in the event of an accident at Harris? (c)Do you know how many persons would evacuate from car-owning households near the non-car-owning households? (d) Do you know how many of such car-owning neighbors of non-car-owning housdholds would have extra space j te carry members of the households without transnortation? (e) Why have the evacuation time estinates assumed that one car will be added per family of namon-vehi,c,le-owning evacuees in cn accident at the Harris plant? (f) Heve you made any analysis of the Harris evacuation time estinates' treatment of the number of vehicles evacuating as it is affected by the numbers of vehicles l assumed or estimated to be evacuating persons without transcortation? (g) Please identify all documents concerning any such analysis. (h) Please state whether persons without transportation includes those who do not have their own transnortation readily available, or only those who do not own cars, t 2165-6(a) Please identify any information underlying the Harris evacuation time estimates, or any other information available to you, which concerns the number of vehicles per evacuating person or per family which would be required to evacuate the Harris EPZ under realistic conditions. (b) Please identify thIe realistic i ccnditions and tne documents containing all such information. (c) Have you compared the number of vehicles used in the evacuation l time estisaates to the number of vehicles pas considered to be i actually evacuating under realistic conditions for any evacuation condition or scenario? If so, state for which condition or scenario, and please identify the results of your comnarison and all documents containing such results or information on which such results were based. 215-7(a) Have you performed, or do you know of, any reanalysis of the computer runs makde for the Harris evacuation time estimates, incorporating any less conservative assumptions (or more realistic assumptions) concerning numbers of vehicles j to be evacuated, population of recreation-area users to be evacuated, l or other matters contained in Contention P15 as initially admitted l l or as revissed? Please identify all documents containing such reanalysis, and state the evacuation times given by each such reanalysis. 1 215-8(a) Do you know of any data showing the actual traffic loadings sn each road segment during evacuation from a Harris accident (i) as computed in any evacuation time i estimate computer run (ii) as determined in any odner computer run (iii) as determined in any other manner?(9For each d part of (a) above for which your answer is affirmative please identify all documents containing such data, and state what assumptions or data about ponulation and vehicles evacuating, road conditi ons, or other variables were used in deriving such data or naking such computer run. 215-9(a)De you have any information as to the amount of time required for evacuating the Harris EPMZ under conditions less conservative than those specified in the Harris evacuation time estimates? If so, what information do you possess or know of 9 l
f 4 215-9 continued (b) Please identify all assumptions that were mado in deriving the time required (or effect on time required) to evacuate the Harris EPZ, for any 'information identified in response to (a) above. (c) Please identify all documents cohtaining information about less conservative evacuation time estimates for the Harris EEPZ you are aware of. (d) Who made estinates of Harris EPZ evacuation time, other than CP&L's -contractor? PROIXICTION OF DOCUMENTS Wells Fddleman hereby renuests the persons these interrogatories are addressed to, whether FEMA /NRC Staff, or CP&L and NC State and County government emergency response personnel or planners, to make available for inspection and conying the original or best copy of each document identified in response to any of the above interrogatories. 29 June 1984 I MP&O Wells Eddleman f k}}