ML20092N507
| ML20092N507 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/29/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | |
| Shared Package | |
| ML20092N499 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8407030221 | |
| Download: ML20092N507 (2) | |
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RELATED CCi:nEOs20iWENC5 UNITED STATES OF AMERICA
_29 June 1984 NUCLEAR REGULATOBY COMMISSION M & ~2 P3:0 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter
" E" James L. Kelley, Chairman In the Matter of
)
Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
)
(Shearon Harris Nuclear Power Plant,
)
Unit 1)
)
ASLBP No. 82-h66-01
)
OL Wells Eddleman's Response to Board Order Requiring Additional Specification of Contentien #21$
On pp 24, 265, and 30-31 of the Board's June lh, 1984 Order, items which nay be litigated under Contention 215 (conservatisms that nay render evacuation time estxinates unreadstic) are discussed.
The Order requires a listing of conservatisms in such estimates, which I think a should be litigated, to be filed today.
Here goes:
1.
The assumption of evacuation from hone.
For certain times of day, this aussutsption is unrealistic for many persons wno will not be at home, but be at work, school, shopning, doctor's office, etc.
This could also result in double counting of evacuees for persons who both live and work within the EPZ (6/14/(Evac 8h Order at 3
- 2. The assumption of one vehicle per household
,gg-Time Estimates, e.g. at 3-2/3-3).
Households with 2 vehicles cuen.
.$O may evacuate in both vehicles rather than linking up.
8
'O 3
The apparent assumption that those households without vehicles will automati' ally evacuate with neighbors (or can) at no O<
the rate of one vehicle per household.
E Eao 4
The assumption in all of the evacuat$ on scenarios that (see Estimates at 1-3, 1-k) at least one person is at home at all residences.
The number of persons at aschool,the lakes, etc. varies according to more realistic criteria and these should too.
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UNITED STATES OF AMERICA NUCLIAR REGULATORY COMMISSION Shearon Harris Nuclear Power Plant. Unit 1'
~).
Docket 50-h00 In the matter of CAROLIhA POWER k LIGHT CO. Et al. )
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CERTIFICATE 0F SERVICE
'84 & -2 P 3.<3 WE Response on Contention 215' I hereby certify that copies of WE Ma== ~ m a_ " c '
m '
ni
= t' on Eddleman 11, and of separate Interrogatosiliis:to NRCiS'taff/ FEMAnlana nra to Annliennh /NP Unh/
Omm+7 m cci,,yg 7e -amayanev h
HAVE been served this 29 day of June 1981, by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are arked with an asterisk, for whom service was acconplished by Judges James Kelley, Glenn Bright and Janas Carpenter (1 copy each)
Atomic Safety and Licensirg Board US Nuclear Regulatory Commission Washington DC 20555 George F. TrowbridEe (attorney for Applicants)
Shaw, Pittman, Potts & Trowbridge R uthanne G. Miller 1600 M St. NW ASLB Panel
(
WashinEton, DC 20036 USNRC Washington DC 25 5 5 Office of the Executive Legal Director ff Spence W Perry
] pW $c t
Docke ts 50-400/k01 0.L.
st
\\0 9 Washington DC 20740 4
Washington DC 20555 Dan Read Docketing and Service Section (3x)
CF.A!LT /FLP l
Attn Docke ts 50-h00/h01 0.L.
Raleigh,$707 Waveross Office of the Secretary NC 27606
""* Li"d* "* Li'*1*
a ngton DC 20555 Governor's Waste Ngt. Bd.
John Runkle
~
513, Albenarle B1dg.
325 N. Salisbury St.
I" Granville Rd Chapel Hill Ne 2751h Bradley W. Jones Robert Gruber USNRC Region II
'Travi s Payne Exec. Director 101 Marietta St.
i Edelstein & Payne Public Staff Atlanta GA 30303 Blex 12601 Box 991 l
Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D.
Certified by h
729 Eunter St.
Apex NC 27502
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