ML20094H794
| ML20094H794 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/09/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Federal Emergency Management Agency, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20094H785 | List: |
| References | |
| 82-472-03-OL, 82-472-3-OL, OL, NUDOCS 8408140122 | |
| Download: ML20094H794 (12) | |
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UNITED STATES OF AMERICA NUCIEAR BEGULATORY COMMISSION 909-89
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-BEFORE THE A10MIC SAFETY AND LICENSING BOARD l
Glenn O. Bri Dr. James M.ght Carpenter MO13 (10:5; James L. Kelley, Chairman N5N)h, l
y, anu
~
l In the Matter of
/y Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
)
(Shearon Harris Nuclear Power Plant, J)
ASLBP No. 82-1p)1 03 l.
Unit 1
)
)
OL Wells Eddleg n's Interrogato5ies to NRC Staff and PEMA
~
{'.f 'd
. Set) and FEMA Wells Eddlenan hereby requests the NRC Staff to answer the following A
interrogatories before ',Julyg 1984 or such other date as counsel for the Staff, FEMA These int.errogatories are submitted under 10 CFR 2.720(h)(ii) and I agree on.
and inquire into the studies, information, and knowledge of NRC staff with Sined I cannot read respect to my contentions, on which discovery is now open.
the minds of the staff, and this information is not contained in documents which the staff has provided to ne, I an unable to obtain this inforsation by Were the information is contained in a document I can obtain other means.
from NRC (Public Document Room, etc). I still need the identification of the document in order to obtain the information. The staff has resources and information which exceed what I have, and as a party,' their position and information are necessary to making my case in this proceeding. These interroga.
tories are continuing in nature and should be supplemented when answers change.
GENEP.AL IEERROGATORIES, ~
In all interrogatories heyein, "you" or" Staff" means NRC Staff or' FEMA.
Eddlenan contentions 30' k "'-
For each of contentions
- 57-C-3, 57.c-10',5 574-13,213, please provide 1.no fo1 Towing information by ' answering ead of these questions.
ff'[
eYstandn t
subject matter of this 1.
Wat s CS conterttion?
tafb$
v b i t! n into,(a) this contention (b) 2.
Has C
c) the allegation (s) in this contention the subject matter of this contention (d) the basis of this contention (e), the information relied upon by intervenor(s) in support of this contentionf For all parts of your response to Interrogatory 2 above for which your 3
who made answer is affirmative, please provide the following information:
the analysis, inquiry, study or investigation; what was being considered in such analysis, inquiry, study or investigation ("AISI"); the content of the AISI, the results of the AISI, whether the AISI has been comple6ed, whether a date for completing _the AISI has been established if it is not complete, what that date is, all documents used in the AISI, all persons consulted 8408140122 840809 PDR ADOCK 05000400 G
2-in th3 oours3 of the AISI, c11 docunsnts ccntaining inforr.ation discovsred or cnalysis cr study or infctmation d3valoped during er es a rosult of the AISI (identify each such document and state dat infornation 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 Wether any persons participating in the AISI are to be caned as witnesses fcr the Staff in this osse,and what questions the staff AISI is intended to answer and what information it seeks to develop if it 4.
answer is other than affirmative, please state (a) whether NRC staff cvFc tup plans to perform any AISI on this contention, (b) dether anyone on MRC Staff has stated that AISI of any) kind is warranted for this conten (even though it has not been made) (c on this contention include a date for beginning or for ending)such AISI, what AISI (d) those dates, for all affirmative answers to (c) above, (e
[ip@ orNRC staff win undertake on this contention (f) what AISI NRC staff desir to undertake on this contention (g) all reasons why no AISI is planned on this contention if none is planned (h) an reasons why no AISI has done yet on of NRC staff th respect to this contentior; are.
CL cf Fc/wh p r p;/1 w s te
- 5. Identify an documents theJtaff relied on in opposing the admission of this contention, and av specific facts not stated in the Staff's opposition to admission of such contention (already filed in this case) upon which Staff relied in making such opposition.
Identify an documents not identified in Staff's interrogatories to Wens Eddle,:an or to Joint Intervenors (to present -- a continuing interrogatory )
6.
upon which the Staff relied in making each such interrogatory.
FC M W Identify by name, personel or business address NRC staff position 7
or title (if any), and telephone nur.ber (if known) each^ person on NEC staff or consultant to NRC staff or known to NRC Staff or consulted by NRC staff in the staff's analysis of the subject matter of this contention prior to (a) its filing (b) its ad.ission; state for each such person what analysis was performed by that person.
State all professional qualifications of each person identified in 8.
response to interrogatories 7,.
'L4; Provide a v statements of the analysis made by persons identified in response to interrogatories 3,4, or ?m above, and identify an docunents 9
containing such infornation or statements not previously identified.
Give the identifier samber, date, source,'and title of an documents identified in response to interrogatories above, which are available through 10.
NRC PRIR (Public Document Room).
- n. Win dtC Staff make available copies of documents identified in response to the above interrogatories to Wens Eddleman for inspection and copying, for documents not available through NRC's PIRf Ft m A orNRC staff position if sy, address and telephone
- 12. Identify by name.n number each person dom NRC staff intends to sxa use or can as a witness in this proceeding.
- 13. State funy the professional qualifications of each p..;on identified in response to interrogatory 12 above.
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3 14 Sumariss tha positien (or plann2d testimony) with rsspect to each contention cn which such perscn is expectsd to tastify, for aach person identified in response to interrogatory 12 above.
frM of Nas(nc Staff, any witness identified in response to interrogatory 15 12, or argone acting in behalf of the Staff or such a witness or at their a
direction, made any calculation or analysis (not identified in response to interrogatories 1 through 4 above) with respect to this contention?
n
- 16. If the answer to interrogatory 15 above is yes in any case, provide the name, business or personal address, telephone number and professinnal qualifications of each person who 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 an docunents containing such calculationer analysis and an docunents used in making such calculation or analysis or relied upon in it or supplying infornation used in it.
Provide a sumary of each AISI, calculation or analysis idsr. for 17 which the answer to interrogatory.15. or interrogatory 2 above, is yes.
- 18. Please give the accession nunber, date and originat'or of each i
docunent identified in response to interrogatory 16,' which is available
(
at the NRC P E.
7GMAof WL11 Nhc Staff make available to Wells Eddlenan for inspection and copying all' documents identified in response to interrogatory 16 above which 19 are not available through the pet br address, and field of expertise and qualifications (explete) (phone nun e,
- 20. Identify each person, including teleif any) fa who answered interrogatories with respect to this contention; if nore than one requested above in this interrogatory for each such person, and state what f
l sach such person's contribution to the answer was, for each answer.
f=Et118 W j
Identify an documents dich the Staff proposes or intends to use I
as exhibits with respect to this contention during this proceeding, including j
21.
exhibits of Staff witnesses (identifying the witness for each, if such a witness has been designated), and exhibits to be used during cross-exanination of witnesses of any party (stating for each which witness it is to be used in cross-exanination of), and identifying for each the particular pages or chapters to be used as exhibits.F W ror Identify an documents dich EC staff relied upon in answering interrogatories with respect to this contention, Wich have n
~q 22.
I each which answer (s) re which contention (s) it was used for, and each l
specific fact and page number therein on which EC staff relied or which l
EC staff used in answering such interrogastery.
- 23. Please give the accession nunber, date, and originator of each docum identified in response to interrogatories 21 or 22.: hove which is available l
through the EC PDR.
Win.EC Staff provide Wells Eddlenan with copies of the documents Fct@ or identified'in response to interrogatory 21 or 22 above dich are not available 24.
at the PM, for inspection and copying?
_g_
25 Identify any other information or source of information not vW identifiedinresponsetothetheaboveinterroEatories1thru2h10lub[1 ygv Dr' upon which any member of NRC staff reliefd, or which any such j
I member of staff used, in answering each interrogatory with respect 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).
v FE01W 26 (a) Does the Staff new 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?
SPECIFI,p Interrogatorios to t...
pRC 6fn(RfEMA Plannars/ Personnel'("you'" in' questions below) 57-C-3-3(a) Is any consideration of temperature given in ni@t-time notification of residents or transients within the EPZ (i) at all (ii) as regards turni g off heating devices on cold nights, if sheltering is recommended (iii) as regards turning off air conditioners on warm or hot nights, if sheltering is recommended?
(b) Have you ti) conducted any tests (ii) collected any information (iii) known any information, concerning the ability of each notification method you will use for Harris accidents at night, especially between 1 am and 6 am, to awaken persons within the EPZ?
(c) If so, please identify all such information and all documents containing such inf orma tion.
(d) Does the emergency planning account for any delay in sleeping persons (asleep at the time of notification) receiving the information that a Harris accident is in progress?
(e) If so, please explain all such sources of delay (e.g. delay due to awakening, delay due to sleepiness, grogginess or drowsiness, delay in preparing to evacuate, delay in travel due to tired or sleepy drivers, etc) and how each or any of them is taken into account in the planning for emergency conditions (nuclear accidents) at the Harris nuclear plant.
(f) Please identify all documents concerning the matters inquired about in parts (a),(d),or (e) (or any subparts) above, which have not been previously identified, stating for each such document what specific interrogatory part(s) or subpart(s) it relates to.
57-0 4(a)
Referring to your answer to 57-c-3-2, do any of the entitions listed (including "other authorities") have any automatic telephone notification or d'aling systems at all?
l (b) If so, please answer 57-c-a-3-2(b) wath respect to the i
capabilit ies of each such system.
l (c) Do you have any opinion as to whether persons awakened by i
sirens in the Harris EFZ might use the telephone (i) to ask authorities what is going on (ii) to notify friends or relatives or others of the accident (iii) for other reasons?
(iv) which, if any, of your opinions expressed re the questions (1),(ii) or (iii) above, would change if the awakening occurs during normal sleeping hours, e.g. from 1 am to 6 am?
Please detail how each such opinion would change if the awakening occurred during people's normal sleeping hours.
(d) Do you have any information concerning the response of pe'rsons t
to S(i) siren (ii) telephone (iii) broadcast (iv) loudspeaker / sound I
truck (v) personal contact (e.g. door-knoncking) notification of severe accidents where evacuation or sheltering may be necessary?
(e) Please identify all information you have cmicerning the matters asked about in (d) above, telling for each what documents if any contain the information, and what subpart(s) the information relates to.
(f) Is it your opinion daat evacuation of the Harris EPZ could occur as rapidaly during normal sleeping hours (e.g. between 1 am and 6 am) as it could during daytime hours, all weather or other conditions being equal?
Please state all reasons and information supporting your opinion.
(g) Is is your opinion daat evacuation of the Harris EPZ could occur as rapidly during normal sleeping hours (1 am to 6 am) as it could under evening conditions, all weather or other conditions being equal?
Please state all reasons and information supporting your opinion.
(h) Is is your opinion that evacuation of the Harris EPZ would be more or less rapid during normal sleeping hours (1 mm to 6 am) as it would be under (i) daytime conditions, similar weather (ii) evening conditions, up to about 10 pm, with similar weather?
Please state all reasons and information supporting your opinion.
Please identify all documents which conta((-partsgation re answers infor to parts (f) (g) and (h) (including all s
57-c-3-5(a) Is there any difference in rapidity)of evacuation during normal sleeping hours (e.g. 1 am to 6 mm as comeared to evacuation at other times?
(b) please explain each such difference (c) are there differences in evacuation conditions during normal sleeping hours, and conditions for evacuation during)other hours, that would tend to offaset or cancel each other?
(d what are these differences, and how ha do they act to offaset each other?
(e) Please identify all documents concerning differences in (i) evacuation conditions (ii) rapidity of evacuation (iii) evacuation times, for normal sleeping hours compared to other times.
(f) are there any differences in evacuation conditions (see (c) above, e.g. ) between sleeping hours (1 am -6 mm) and other hours which would affect or could affect evacuation times?
(g) What are these differences and how does (or could) each affect evacuation times?
(h) Is there any actual experience with night-time evacuations which indicates differences in evacuation times under sleeping hours conditions?
(j) Is there any consideration of increased likelihood of fog or preemipitation during normal sleeping hours (1 am to 6 am) in the emergency planning for the Harris nuclear plant?
(k) If so, what consideration, and how does it affect evacustion ti$a time estimates?
What amount of increase or decrease in the evacuation times due to these conditions is possible?
Why?
Why not more?
Why not less?
(1) Does the State of NC, cP&L or any other responsible emergency preparedness agency intend to test (1) communications (ii) notification (iii) sheltering (iv) evacuation (v) ether emergency response plan elements, during normal sleening hours (1 am to 6 an or any time between these hours, i.e. between 1 am and 6 am)?
(m) If so, what tests will be done, by whom, and on about what dates (e.g. before fullacalk plan test, during that test, before l
Jan.1, in985, quarterly, once a year, etc)?
57-c-3-6(a) Does Nunso-0654, FEMA 43, or othe r applicable guidance (palease identyify all documents contgining other applicable guidance) for the Harris offsite emergency plan require (i) both an alert signal and an informational or instructional message to the population on an arena wide basis throughout the 10 mile EPZ, within 15 minutes?
(ii) initial notification system assuring direct coverage of essentially 100% of the population within 5 miles of the site? (iii) special arrangements to assure 100% coverage within 45 minutes of the population who may not have received the initial notification within the entire plume exposure EPZ?
(b) How does the Harris offsite emergency plan notification prodcedure meet each notification requirement of FEMA 43 (Including (1), (ii) and (iii) of (a) above if applicable) during normal sleeping hours (e.g. 1 am to 6 am)?
Please specify your answer in detail, describing the alterting systems used, the design report on each alerting means to be used, the ability to provide an informational or instructional message to persons who are asleep at the time of the alert / notification beginning; please specify all documents, opinions of experts, or other information you rely on in making your answer.
Please answer separately for each requirement or criterion for notification in EUREG-0654 or FEMA 43,or other applicable guidance (as indicated in your answer to (a) above).
l i
57-c-3-7(a) What in your view, are the merits and /or negative aspects of the us,e of tone alert radios to notify sleeping persons of an accident at the Harris plant?
(b) Isn't is true that PEMA 43
57-c-3-7(b) continund section E.6.2 4 that tone alert radios are one of the methods of alerting not included in "special alerting methods"?
(c) Have you made any investigation as to the cost, effectiveness, i
or other aspects of tone alert radios for the Harris EPZ? (d)
Please provide details of any investigation re tone alert radios that you have made, either for the Harris EPZ, or otherwise, identifying all documents containing information about the scope, plan, authorization, method of inquiry, results, or infomation obtained or developed in such investigation.
(e) Are there any other sources of information re tone alert radios which you are aware of?
Please identify each such.
(f) Do you consider tone alert radios to be an alternative to (i) siren notification (ii) loudspeamker notification (iii) automatic ringdown telephone notification, for notification of Harris plant emergencies and/or providing informational or instructional messages to persons within the Harris plume exposure EPZ, during normal sleeping hours, e.g.
I 1 an to 6 am?
(g) Please give all reasons for your answer (s) to each subpart of (f) above.
57-c-3-8(a) Does PEMA encourage the use or development of special alerting methods such as automatic telechone dialers or swit&hing equipment where it is cost effective?
(b) Please provide all basis for your answer to (a), identifying all d ocuments l
or expert opinions you used in making that answer.
(c) Have you l
made any study of the cost-effectiveness of any special alerting methods for the Harris EPZ during normal sleeping hours (e.g. 1 am l
to 6 am)?
(d) Please identify all documents concerning, or used I
in, or identified during, any such study as inquired about in part (c) above. (e) H,ve you made any study of simultaneous dialing systems, i
e.g. those mentioned in sectionEL.6.2.4 4 of FEMA 43, for use in the Harris EPZ, for notification during normal sleeping hours or L
for notification or delivery of instructiona*$ or informational l
messages?======Hy (f) Please provide details of any such study as inquired about in part (e) above, including identification of all documents related to such study, particularly any about the capability of aimultaneous-dialing or simultaneous-ringing telephone equipment.
(g) Was the message-delivering canability of simultaneous-ringing or dialing telephone equipment considered in any of han your studies?
In which, and how?
(h) What is your opinion ccncerning the usefulness of (i) simultaneous dialing (ii) automatic ringdown dialing telephone equipment for notification of persons within the Harris EPZ durf ng normal sleeping hours?
Please give all basis for your===h=t opinion, identifying all documents used in war preparing or sunnorting your ouinion.
(j) (there is no part (i) since that is used for subparts, as (1),(11))
l l
What role did provisions for (1) calling back busy lines (ii) preventing subscriber overloading of the telephone system during use of telephone notification to Harris EPZ residents / transients play in your analysis or study of telephone notification within the Harris EPZ? (k) Would telephone system overloading by subscribers be less, more of, or about the same of a paroblem for telenhone notification during normal sleeping hours?
(1) Have you made, or collected, any other studies or reports or inquiries concerning notification systems or methods for l
p ple ska (i) who are asleep at the time of notification (ii) w ose whole households /are asleep at the time of notification, for emergency planni response purposes or other purposes?
(m) Please described n detail any studies /information asked
(
about in (1) above.
L
57-C-3-9(a) Referring to your answer to 57-C-3-1(f), if not previously fully answered, does any documentation or records of any kind concerning the consideration of telephone notification of persons within the EPZ that was made during the Harris emergency planning process exist?
(b) If so,. what documentation?
Please identify it fully; please fully identify any other records of this consideration which you know of.
(c) If answer to (a) is "none" or an answer to that effect, or you believe you have fully answered (a) previously, please explain why no records of this consideration exist.
(d) Do you remember anything about the consideration of telephone notification of persons within the EPZ that was mada during the emergency planning process?
(e) If so, what do you remember?
(i) Do you remember what kinds of telephone notification (aa) methods (bb) systems, were considered? (ii) do you remember any reasons why telephone notification was rejected?
(iii) do you remember whether night-time (normal sleeping hours) notification was part of the consideration of telephone notification 1
for the Harris planning process (emergency response planning)?
(iv) do you remember whether alternatives to telephone notification, e.F. tone alert radios, etc., were considered?
Please explain what you remember, both in general, and for every subpart for which your answer is affirmativo.
I 213-3(a) Refer to your answer to 213-1(d):
Do you agree that i
the job titles or names of versons responsible for verifying (in the field) and/or receiving reports verifying (in the Emergency Operations Center) that persons on the Harris Lake have been notified of an accident at the Harris nuclear plant, should be part of the plan (off-site emergency response plan)?
(b) Please fully explain all reasons for your answer to (a) and identify any documents or authorities you rely on in making that answer.
(c) What is the job title of the person or persons resnonsible for receiving reports that notification of persons on or in the Harris Lake has been accomplished?
(d) what is the job title of the person or persons responsible for notifying i
persons on or in the Harris lake of a nuclear accident at the Harris plant?
If more than one job title is involved, please give all dhe titles, including thos e of back-up personnel.
(e) Who is responsible for ordering the notification of persons on or in the Harris lake of an accident at the Harris nuclear plant? Please give name or job title.
213-4(a) What are the means for giving an instructional message or an informational message to persons on or in the Harris lake in the event of a nuclear accident at the Harris plant?
(b) Please describe each such means in detail, explain why it was included (or will be included) in the emergency response plant, and identify all documents concerning these means, your authority or ability to use them, what personnel are required to operate these means, how many, where they===k work, who their backup versonnel are, where the backup personnel work, how many people are required to operate each means, all backup means of notification for persons on/in dhe Harris lake, and the above information for each backup means of notification.
(c) What is the content of tne instructional message for persons on/in the Harris lake in the event shelterig is ordered? Does it provide for shelter $ng at or near the lake?
If not, what does it provide?
What will persons on/in the Harris lake be told to do, if sheltering is the overall response for the EPZ that is ordered?
57-c-10-5(a) Please refer to your supplemented answer to 57-c-10-3-d.
Were any methods for assessing sheltering effectiveness for structures in the-Harris EPZ used, which were NOT intended to provide emergency planners with a data base for a wartime nuclear emergency?
Please identify each such method and its results for structures within the EPZ, and' all documents concerning the method and/or its results for such structures or other structures.
(b) Does " wartime nuclear emergency" mean (i) Nuclear war? (ii) nuclear weapons attack?ma (iii) explosion of nuclear weapons?
(iv) considtions of fallout af ter a nuclear explosion or explosions?
(v) something else? -- please specify what it means.
57-c-10-6(a) were any(differences between (i) wartime nuclear emergency conditions ii) nuclear weapons fallout conditions, and likely $k$pg conditions for a serious accident at the Harris nuclear plant, considered in the shelterig effectiveness estimates made for structures in the Harris EPZ?
(b) Please specify each such difference and how it was considered.
Please identify all documents concernig the effect of each differences on the Protection Factor (PF) or shelterinF effectiveness for struenstures or any specific structure (s) within the Harris EPZ.
i (c) What account of infiltration of (i) radioactive gases (ii) radioactive particles, with incoming air, is taken in (aa) the sheltering effectiveness or PP estimates you now possess (bb) sheltering effectiveness or PF estimates for use in connection with a nuclear accident at the Harris plant?
If there is no difference, or the estimates are the same, please say so.
(d) How long(e) If you don't know a maximum sheltering time that is the maximum sheltering time for a nuclear accident at Harris?
al@t be required due to a nuclear accident at Harris, either (1) for the EPZ as a whole, (ii) for any part of the EPZ, or (iii) for any structure (s) or areas widain the EPZ, please explain all reasons why you don't know.
(f) What is the maximum sheltering time that has been considered (i) for the entire EPZ (ii) for any part(s) of the EPZ -- please specify Which parts (iii) for any structure (s) or specific location within the EPZ -- please specify which structure (s) or specific locations 6.
(e) Do any PP estimates for structures within the Harris EPZ assume any sealing of air pathways (i) into the structure (ii) into sheltering areas within the structure?
If so, please describe what sealing is assumed, what materials are needed to do this sealing, the availability of those materials at the structure, and the additional protection assumed or calculated or believed to result from such sealing.
(f) How long can occupants of any sealed area or structure (see (e) above) stay in shelter without eihausting their air supply?
Have you made any calculations or estimates for any structures within the Harris EPZ?
(g) Do you know anything about the infiltration rates of (i) air (ii) particles, including particles of the size and characteristics of radioactive particles that might be released from Harris during a nuclear accident (iii) radioactive gases, into structures within the Harris EPZ or any such structure or structures?
If so, how do su6h infiltration rates affect the radiation doses likely to be received by persons sheltering within those structures? Please detail all basis, documentary or otherwise, for your answers.
1
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9 57-C-10-7(a) Where are Sprotection factor categories" as used l
in your assessment of PFs for structures widdin the EPZ, defined or explained?
(b) Do you have any information about the specific PFs within each categoby, for structures within the Harris EPZ?
(c) If so, what is that information? Please identify all documents containing such information.
[
57-c-lo-8(a) Refer to your answer to 57-e-to.
Is this all the information you have about typical housing within the Harris EPZ? (b) Does section 4.5.2 of the on-site emergency plan contain some sbven lines (about 4 sentences) concerning housing within the Harris EPZ?
(c) Why is this information in the on-site plan, but not in the off6 site plan?
(d) Are the PPs reported there i
(
based on any typical house shape or characteristics?
(e) Please identify all documents that concern, or explain, how the PFs l
in section 4 5.2 of the Harris on-site emergency plan were calculated l
for typical housing.
Please answer 57-e-lo-3-e again insofar as your answer involves any definition of a " typical" structure l
or structures.
(f) Please explain how the PFs of section 4.5.2.
of the Harris on-site emergency plan were calculated, including base data used, calculation method (s) used, and all assumptions used or made in the calculation.
Please also explain who did the calculation of these PFs and why it was done'.
(g) Do the PFs of Harris on-site plan section 4.5.2 take into account the effects of (i) radioactive gases (ii) radioactive particles, infiltrating into the houses / apartments within the Harris EPZ with normal air infiltration?
If so, exactly how Soi they do so?
l Were any particular wind conditions used in estimating infiltration l
of radioactive gases or particles into structures typical within the Harris EPZ (houses, apartments or other structures)? If so, please specify the assumntion.
57-C-lo-9(a) How much space is considered to be space for one shelteree?
Is this amount of space differenzt for small children, for babies, for the ill or infirm?
If so, how does it differ for different people?
(b) How long are persons assumed to be able to remain in shelteree spaces within structures in the Harris EPZ?
Is food provided in buildings within the Harris EPZ that are fallout shelters?
Is that food in edible condition? Is there drinking water l
stored in or near high-PP areas of structures in the Harris EPZ?
l Has it been verified to be drinkable?
If so, when? (most recent date or time if known)
How long can shelterees be exnected to stay in high-PF areas without (i) food (ii) water?
What toilet facilities are provided in high-PF areas within structures in the Harris EPZ?
Do you think people might leave high PF areas where toilet facilities are not available, e.g. briefly, to use the toilet?
57-e-10-lo(a) How are ventilation systems, e.g.
(i) beating (ii) cooling (iii) ventilation w/o heating or cooling, considered in assessing the PF of (aa) buildings (bb) houses (cc) apartments (dd) other structures, within the Harris EPZ?
How long can such systems be turned off during sheltering?
(b) How long can heating systems remain off for sheltering on cold nights (e.g. freezing temperatures, with winds of 10 mph or more) before adverse -effects on shelterees (i) occur (ii) may jeopardize people's willingness to stay in shelter?
(c) How long could cooling systems be turned off,(with persons packed into shelteree spaces, on a hot summer day e.g. temperatures in the 90 mas, high humidity) before
((-
57-c-lo-lo-c, continued
^
adverse effects on sheltereses (1) occurm (ii) jeopardize people's willingness. to remain in shelter?
(d) How long can external venti 1xation be turned off during.
abeltering before adverse effects on shelterees occur?
(e) Please describe any adverse effects to shelterees that may result from turning off of heating, or cooling, or ventilmation a systems during sheltering.
Please also describe how (if at all) such effects are considered with respect to structures in which persons in the Harris EPZ might be asked to take shelter during a nuclear accident.
Please identify all documents concerning (i) adverse effects of having heabing, or cooling, or ventilization, systems turned off during sheltering (or, in general); (ii) consideration of heating, cooling or ventilation with respect to structures in the Harris EPZ in which people might shelter; (iii) degree of adverse effects under which people may leave shelter during a nuclear power plant accident, or the difference between such conditions and the conditions under which peonle may leave shelters during a military nuclear emergency or nuclear war or nuclear bomb fallout situation; (iv) degree of adverse effects which would likely cause people to leave a shelter durinF a nuclear power plant accident.
ventiliation s
(f) does shelter effectiveness analysis always assumeA 0
$7-c-10-11(a) How are construction techniques relating 'to the air tightness of walls, ceilings, floors, windows and doors considered in determining the sheltering effectiveness of structures within the Harris EPZ?
(b) have any direct measurements of the air tightness of x construction of such structures been made, e.g. with blower doors or other air-infiltration measuring equipment? (c) Please identify all documents concerning the matters inquired about in (a) and/or (b) above, particularly including e stimates or measurements of the specific air-gtightness of construction of structures within the Harris EPZ.
(d) Why were food stores eliminated from consideration in the surveys of dbeltering effectiveness of strucatures within the Harris EPZ? (e) Are g food stores considered less safe shelters than other structures of similar construction?
57-e-10-12(a) Have any formal shelter location sketches been made for any structures within the Harris EPZ?
(b) Please identify all documents containing shelter location skethches, formal or informal, for any structures within the Harris EPZ. (c) Please identify all documents showing where the highest PFs are located in structures within the Harris EPZ.
Please identify any documett showing such areas within any such structure.
57-c-13-3(a) Is your answer to 57-c-13-1 complete, e.g. with respect to parts (g) and (h)?
If not, please orovide answerms.
(b) what (1) medical supplies (ii) toilet facilities, are unsteh available in high-PF areas within hosoitals or nursing ho$es within the Harris EPZ? (c) Why havent "best" PF determinations for hospitals or nursing homes widhin the Harris EPZ been made?
Please give all reasons.
(d)
What PF determinations have been made, if any, for any (1) hopspital (ii) nursing home, within the Harris EPZ?
57-c-13-4(c)
Ara there any h6 spa tsis, nursing homas, or o.ther care facilitics within the Harris EPZ basides those listed in fHmfbha Table 4-5 of the Evacuation Time Estimates (ETE) which the" state or county emergenvy planners are aware of?
(b) Have any factors, such as increased sensitivity of ill or elderly persons to radiation exposure, been considered in PF determinations for hospitals or huse h nursing homes or other care facilities within the Harris EPZ?
30-3(a) With respect to your answer to 30-2 any places in the Harris energency response (d), are there (off-site) plan where specific quantities of KI or other radioprotective drugs are mentioned?
(b) are you aware of any reports,or recent declarantions of pol?.cy or resolutions of health-profession associations, which adoress the==4%= desirable availability of KI or other radi oprotective drugs during radiological emergencies?
Please identify all documents containing or reporting on such reports, resolutions or policiens.
(c) How, if at all, do the reports, declarations or policies l
you di identify in response to (b) above (or that you were asked to identify in (b) above), affect your answers to 30-2(a) and 30-1 subparts (b) thru (1)?
30-h(a) Have you made any evaluation of the Harris Emergency Response Plan's plans for distribution of KI, as far as its compliance with NUREG-0654 or other applicable guidance is concerned?
(b) Please identify all documents relating to such evaluation (s), the applicable guidance, and the results of each such investigation. (h)(c) Do you plan to make any such investigati&n?
If so, when?
When do you exnect to complete this investigation?
30-5(a) Are there any applicable FEMA or NRC guides for any of the items inquired about in 30-K1(b) thru (i)? If so, please specify the guidance for each item and the document or documents wnich identifies that guidance.
Please identify all documents and page references which g contain each such item of guidance.
30-6(a) Does the State of NC maintain no reserve of KI at any place for use during nuclear plant accidents?
(b) What provisions for KI use are established for (i) the Brunswick nuclear plant (ii) the McGuire nuclear plant, and how do these provisions differ, if at all, from those for KI use in emergency conditions at the Harris plant?
(c) Please identify all documents concerning matters t
inquired about in (a) or (b) above.
Please tell for each the matter (s) it relates to.
PRODUCTION OF DOCUMENTS Wells Eddleman hereby requests that the original ob best copy of each document identified in response to interrogatories above or below be produced for inspection and copying at a mutually agreeable time and place.
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