ML20096F422

Second Round Interrogatories & Request for Production of Documents to NRC Re Contentions 215 & 224.Certificate of Svc Encl.Related Correspondence

ML20096F422
Person / Time
Site:	Harris
Issue date:	09/05/1984
From:	Eddleman W EDDLEMAN, W.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8409070437
Download: ML20096F422 (5)

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""""_ Z' UNITED STATES OF AMERICA 9/5/8h NUCLEAR REGULATORY COMMISSION BEFORE THE A'K)MIC SAFETY AND LICENSING BOARD Glenn O. Bright occE[kc U

Dr. James H. Carpenter James L. Kelley, Chairman g4 g In the Matter of CAROLINA POWER AND LIGHT CO. et al.

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ikcNk: EL Docket 250300 -

(Shearon Harris Nuclear Power Plant, )

Unit 1) ) ASLBP No. 82-h66-01

_ _ _) OL Wells Eddlenan's Second Round InterroFatories

& Request for Production of Documents to NRC Staff on Contentions 215 and aph On 6/29/8h Wells Eddleman filed a first round of discovery to NRC Staff on contentions 215 and 224 Since Staff's reviewer was unavailable to respond on time, Staff counsel and Eddleman agreed to a second round of discovery on Contentions P15 and P2h after Staff'e recponse was filed. (Staff has not filed any interrogatories to Eddlenan on these contentions. ) On 8/29/84 NRC Staff filed responses to the first round interrogatories. The questions below are the second round of interrogatories on these contentions. The Board anproved this nrocedure en July 31, 198h.

General Interrogatories

28. Is the single page consisting of a checklist "' Evaluation of Evacuation Time Estimate" (Shearon Harris) all the documentation (including handwritten notes, calculations, etc) that exists from Dr. Urbanik's review of the Harris Evacuation Time Estimates IETFs)?

If not, please identify all such documents related to this review.

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29. Please identify authors and.cddresses for all documents 6

identified in response to first or second round interrogatories on 84o907o437 84o905 1 215 and 224 poR Apocx osooo4oo G PDR

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30. Where do the criteria for the evaluation of ETWs used in Dr. Urbanik's review of the Harris ETEs cone frns? Please identify all documents containing such criteria.

Sp;cific Ints. 224-3 Are there any criteria for the kinds of severe weather conditions that should be applied to evacuation time estimates?

If so, please identify all such criteria annlicable to the Harr$ s ETEs and all documents containing such criteria.

224-4. Have you made any deternination of the effect of weather corditions (a) analyzed in the ETEs (b) stated in contention 22h on the Harris ETEs, on any basis other than what the FTEs a say?

If so , what is your basis and what is your determination? Please identify all documents related to such determination.

22k,5 Are there any data sources describing how various kinds of adverse weather, including (a) rain (b) heavy rain (c) fog (d) freezin6 rain (e) snow (f) ice, affects (1) highway capacity (ii) highway canacity for curvinr tun-lane roads such as exist in the Harris EPZ (iii) traffic sneeds (iv) safe traffic sneeds on curving two-lane roads such as are found in the Harris EPZ (v) traffic accident rates? Please identify all such data sources fully. If any were not used in your evaluation of the Harris ETFs then please state, for each such data source, all reasons why you did not use it in evaluating the Harris PTEs.

215-10. Please explain all reasons for each check (X) mark made on the " Evaluation of Evacuation Time Estimate" for Shearon Harris.

Please exnlain the criteria for "adeauate" on each item KfA in the Evaluati

n. 21$-11. Do the evaluation crit'eria for the ETEs ensure that an ETE evaluated as " adequate" is not inaccurate due to conservatisms in the assumptions used in the ETE? If so, how (explain in as a.uch detail as you know, clease)? If not, why not?

215-12. Which assumntions, if any, in the Harris ETEs, do you consider " conservative"? For ench, niense exnlain why you consider it " conservative" and how each such assunntion affects the ETEs.

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. .c Please identify all documents which contain informstion 'which in your opinion tends to show, or shows, that any assumotion in the Harris ETEs is conservative. Please state which assumptions relate to which documents, and for each assumotion, state the gaualitative (or quantitative, if known) effect on evacuation time for the Harris EPZ that results from that . assumption.

21k$-13 Do you believe that every assumption made in the Harris ETEs is accurate? If not, which are inaccurate (plesse list)? Please identify all documents and information which suoports your belief regarding the accuracy (or inaccuracy) of each assumption in the Harris ETEs.

215-14 Which assumptions in the Harris ETEs have you evaluated (please list)? Of these, which did you evaluate for accuracy (nlease check off on list, or list separately)?

Of what, other than evaluating accuracy, did youn evaluation

of assumptions in the Harris ETEs consist? What did you snecifically do in evaluating the assumptions in the Harris ETEs?

215-15. How much variability - can there be, in your opinion, between each estimate of evacuation time in the Harris ETEs, and the actual time evacuation could take if it were ordered (a) under the same conditions the ETEs estimated the time for?

(b) under other conditions not included in "TE assumntions?

Please give all reasons for your answers and identify all documents of analysis suonorting each part of each answer.

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-(c ) Could evacuation take (i) less (ii) more time than the Harris ETEs say, depending on the accuracy of assumntions in the ETEs?

Please identify all documents which you believe supnort your answers.

215-16. Has there ever been any test of fu11 scale evacuation of a nuclear power plant EPZ of about 10 miles radius? If so, how long did it take? Please identify all documents concerning it, and

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p j khc,w th[$va*cuation time (actual) connared wi th any i estimates of the f , ,, b evacuatipn : time nade before evacus t$on.

/;. 8 215-17 Have models of X'hua evacuation such as NETVAC been

/ applied to non-nuclear evacuation tine estimates? If so, have any actual evacuations occurred for which NETVf.'C-based estimates exist?

,Please identify all documents concerning annlication of NETVAC or other similar evacuation tine estimating models, and all documents concerning t

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[ actual evacuations (and the times they took and/or the estimated evacuation times for them), for such non-nuYlear evacuations.

. 215-18. Have there been'any'other tests of any kind of the 4- /

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accuracy.of the NETVAC model or~ estimates based on it, for (i) nuclear plant-related evacuations from EPZs (ii) other evacuations?

Please identify all documents concerning such evacuations and/or tests or the results of such tests, particularly results concerning the accuracy of the NETVAC nodel. If there were any assumptions introduc6d into the NFTVAC nodel that adversely affected its accuracy for any such evacuation (s') or test (s), please identify each such assumption. ,

215-19. Do you know anything about the accuracy of assumutions in the Harris ETEs wh$ ch you have not stated in resnonse to above interrogatories? If so, what do you know and what assunntions or assumntion does (do) it relate to? Please identify all documents supporting, - related to, or forming the basis or nart of the basis, for your answer for each assumption..

PRODUCTION OF DOCUMENTS l

Wells Eddleman hereby requests NRC Staff to make available l for inspection and conying all docunents identified in resnonse j reeable time and ulace. '

to the above interrogatories, at a ndtually ( ag#6 Tak '

Wells Eddlenan 9-5-6h  ;

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l UNITED STATES OF AMERICA NUCLTAR REGUIATORY COMMISSION In the matter of CAROLHA POWER k LIGHT CO. Et al. ) Docket 50-400 Shearon Harris Nuclear Power Plant. Unit 1* ) 0.L. j CEftTIFICATroF SERVICE I hereby certify that copies of p >a nimEN55EIone.ae-! -

and request for troduction of documents to N*C Staff on contentions  !

214 and 2Ph _ l

'84 FP -7 A 1 :07 l HAVE been served this 5 day of Sentenha, 196k_, by deposit in the US Wil, first-class postage prepaid, ygylf-pagies whose BRANCH names are listed below, except those whose nanes are arked with hand l an asterisk, for whom service was accomplished by Judges Ja-tes Kelley, Glenn Bright and James Carpenter (1 cgy each)

Atomic Safety and Licensing Board US Nuclear Megulatory Comission washin&ton DC 20555

, George F. Trowbridge (attorney for Applicants)

Shaw, Pittman, Potts & Trowbridge R uthanne G. Miller 1600 M St. NW ASLB Panel washinEton, DC 20036 USNRC Washington DC 2055 5 '

Office of the Executive Legal Director h, 840 Attn Docke ts 50-400/h01 0 L. p ied 500 C St. Sw Washington DC 20 $ 0 s ngton DC 20555

" Dan Read Docketing and Service Section (3x) CEA%T/FLP Attn Decke ts 50-h00/hc1 o.L. Waleigh,ftO7 NC waveross Office of the Secretary 2760'6 USNRC Dr. Linda W. Little washington oc 20555 goy,7n,7,s waste Mst. Bd.

513 Albemarle B1dg J hn Runkle -

325 N. Sal' abut v St.

Granville Rd I" ' N ' .

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

• Travi s Payne Exec. Director 101 Marietta St.

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

Apex NC 27502

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