ML20094G371

Supplemental Answer to Eddleman Interrogatory 57-C-10-3(a)-(d) Requesting Identification of All Documents, Methodologies,Data,Equations,Calculations & Info. Certificate of Svc Encl.Related Correspondence

ML20094G371
Person / Time
Site:	Harris
Issue date:	08/08/1984
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	EDDLEMAN, W.
References
OL, NUDOCS 8408130288
Download: ML20094G371 (6)

Text

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~ RELATED CCF.rcs?ONDENC!(

August 8,1984 00:VETED us w

' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .#,

AG010 P10:51 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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-CAROLINA POWER & LIGHT COMPANY )

'AND NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

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-(Shearon Harris Nuclear Power Plart, )

Unit 1) )

4

' APPLICANTS' SUPPLEMENTAL ANSWER TO EDDLEMAN INTERROGATORY NO. 57-C-10-3(a) THROUGH (d)

By agreement with Intervenor -Wells Eddleman, Applicants are supplementing I " Applicants' Response to Wells Eddleman's General Interrogatories to Applicants (Ninth Set)," dated ' July 25, 1984. Accordingly, Applicants' Answer to Interrogatory No. 57-C-3(a) through (d) is revised as follows:

i-INTERROGATORY NO. 57-C-10-3(a): Please identify all documents, methodologies,~ data, equations, calculations or other information you have used, or plan to use, in calculating or determining sheltering effectiveness for structures within the

_ Harris EPZ.

(b) Please identify all documents containing such information.

(c) Please identify all documents you possess which describe methods of 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 with respect to structures near Harris or in its EPZ.

ANSWER: (a) - (c): The following documents, copies of which will be produced for review and copying upon request, contain information relating to these interrogatories:

(1) "Public Protection Strategies for Potential Nuclear Reactor MF Wh0

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~ Accidents: Sheltering Concepts With Existing Public and Private Structures" (SAND 77-1725).

(2) " Protective Action Evaluation Parts I and . II, The Effectiveness of Sheltering as A Protective Action Against Nuclear Accidents Involving Gaseous Releases" (EPA 520/1-78-001 A and B).

(3) " Effects of Man's Residence Inside Building Structures on Radiation Doses from Routine Releases of Radionuclides to the Atmosphere"

' (ORNL/TM-6526).

In addition, the documents provided in response to Interrogatory No. 57-C-10-4 contain information on sheltering effectiveness.

(d) - Methods, calculations and data contained in the first two reports listed in answer (a) - (c) above are referenced in accordance with NUREG-0654 (at 64) which

_ provides that they may be considered in determining the protection afforded in residential units and other shelters. The data and calculations contained in ORNL/TM-6526 are referenced because they provide additional information on sheltering effectiveness of structures.

With respect to the shelter surveys discussed in response to Interrogatory No. 57-C-10-4, the methodology used to determine sheltering effectiveness of the structures s urveyed was in conformity with Federal Emergency Management Agency guidance contained in " National Sheltar Survey Instructions," TR-84 and " Mass Thickne::s Manual for Walls, Floors and Roof," Sept.1980 and Jan.1984, TR-68. Copies of these documents will be made available for review and copying upon request. The data collected on a shelter's location, intended use, adequacy of radiation shielding and other characteristics of - the structure are used for civil defense purposes and are intended to provide emergency planners with a data base in planning for a wartime nuclear emergency.

Dated: August 8,1984.

Submitted by:

b.

Dale E. Hollar, Esq.

Associate General Counsel Carolina Power & Light Corrpany Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 Attorneys for Applicants:

Thomas A. Baxter, P.C.

Delissa A. Ridgway, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones, Esq.

Samantha Francis Flynn, Esq.

Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 F.

s: . . - -

Applicants were not able to attach hereto the Affidavit of B. J. Furr, Vice

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President - Operations Training and Technical Services of Carolina Power & Light Company, because he was out of the office and unavailable due to other conflicts. When the Affidavit is secured, it will be forwarded in a timely manner to the parties for attachment to " Applicants' Supplemental Answer to Eddleman Interrogatory No. 57-C-10-3(a) through (d)."

This 8th day of August 1984.

h .

Dale E. Hollar, Esq.

Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power Plant, )

Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Supplemental Answer to Eddleman Interrogatory No. 57-C-10-3(a) through (d)" were served this 8th day of August,1984 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.

Dale E. Ilollar Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 l

Dated: August 8,1984 r

SERVICE LIST J:mes L. Kelley, Esquire M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 Mr. Glenn O. Bright Dr. Richard D. Wilson Atomic Safety and Licensing Board .

729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D. C. 20555 Mr. Wells Eddleman

- Dr. James H. Carpenter 718-A Iredell Street Atomic Safety and Licensing Board Durham, North Carolina 27705 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Thomas A. Baxter, Esquire John H. O'Neill, Jr., Esquire Charles A. Barth, Esquire Shaw, Pittman, Potts & Trowbridge Myron Karman, Esquire 1800 M Street, NW Office of Executive Legal Director Wachington, D.C. 20036 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Bradley W. Jones, Esquire U. S. Nuclear Regulatory Commission Docketing and Service Section Region II Office of the Secretary 101 Marietta Street i U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303  !

Washington, D. C. 20555 Robert P. Cruber Mr. Daniel F. Read, President Executive Director Chapel Hill Anti-Nuclear Public Staff Group Effort North Carunna Utilities Commission Post Offlec Box 2151 Post Office Box 991 Raleigh, North Carolina 27602 Raleigh, North Carolina 27602 Dr. Linda Little .

Mr. Spence W. Perry Governor's Waste Management Board Federal Emergency Management Agency 513 Albemarle Building 500 C Street, S.W.

325 Salisbury Street Room 840 Raleigh, North Carolina 27611 Washington, D. C. 20740 Mr. Steven Crockett, Esquire Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 J:hn D. Runkle, Esquire Conservation Councilof North Carolina 307 Granville Road Chapel Hill, North Carolina 27514