ML20096G866
| ML20096G866 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/07/1984 |
| From: | Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | EDDLEMAN, W. |
| References | |
| OL, NUDOCS 8409110194 | |
| Download: ML20096G866 (62) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
Efg,{~jg In the Matter of-
)
)
CAROLINA POWER & LIGHT COMPANY
)
AND NORTH CAROLINA EASTERN ~
)
Docket No. 50-4"04 QLo 0 MUNICIPAL POWER' AGENCY
)
477 77 9
)-
~
(Shearon Harris Nuclear Power
)
- a.
Plant)
)
APPLICANTS' RESPONSE TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES TO APPLICANTS (Tenth Set)
Applicants Carolina Power & Light Company ("CP&L") and North Carolina Eastern Municipal Power Agency, pursuant to 10 C.F.R. 5 2.740b,- hereby submit the following responses to
" Wells Eddleman's General Interrogatories to Applicants Carolina Power l& Light et al. (10th Set)."
The provision of answers to these interrogatories is not to be deemed'a repre-sentation that-Applicants consider the information sought to be relevant to the issues to be heard in this proceeding.
GENERAL INTERROGATORIES INTERROGATORY NO. Gl(a). "Which contentions of Wells Eddleman do Applicants agree are now admitted in this proceed-ing, NRC. Dockets 50-400/401 0.L.?
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V ANSWER:
The contentions of Intervenor Eddleman which are admitted to this proceeding are set forth in various memoranda and orders issued by the Atomic Safety and Licensing Board, all i
of which are available to Mr. Eddleman.
t INTERROGATORY NO. Gl(b).
[F]or each such conte'ntion,. pro-Lvide for any answers to interrogatories by Wells Eddleman which Applicants have previously or presently received (except those suspended by Board order, if any), the-following information:
ANSWER:
The answers to General Interrogatories herein.are restricted to Eddleman Contentions 30, 57-C-3, 57-C-10, 57-C-13, 213, 215 and 224.
INTERROGATORY NO. G1(c).
Please state the name, present or last known address, and present or last known employer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) upon whom Applicants relied (other than their. attorneys) in making such answer.
ANSWER:
The following list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Contentions 30, 57-C-3, 57-C-10, 57-C-13, 213, 215'and 224 and indicates the particular inter-rogatory answers for which such person provided information:
PERSON INTERROGATORY NO.
Jesne T.
Pugh, III 57-C-3-3(a),
Division of Emergency Management 57-C-3-4(a),(b),(c),
N.C. Dept. of~ Crime Control and 57-C-3-5(1),(m),
- Public Safety 57-C-3-6, 57-C 7(b),(e),
- Raleigh, N.C.
27611 57-C-3-8, 57-C-3-9, 213-3, 213-4, 57-C-10-5, 57-C-10-6, 57-C-10-7, 57-C-10-8(a),(b),(d),
57-C-10-9, 57-C-10-10, 57-C-10-11, 57-C-13-3, L.
57-C-13-4,
.l~
224-3(d)-(e),
215-10 Charles D. Reed-30-3
' Adult Health Services.Section~
30-4 Division of Health Services 30-5
- N.C.1 Dept. of: Human Resources 30-6
~
P.O. Box'2091 Raleigh, N.C.
~27602
' Robert D. Klimm.
57-C-3-3(d),(e),(f),
HMM : Associates, ' Inc.
57-C-3-4(f),(g),(h),
336 Baker Avenue 57-C-3-5(a) through-(k),
Concord, Mass.
01742 224-4, 224-5, 215-10, 215-11,.
215-12, 215-13(a),(b),(c),
215-14(a),(c) through-(l)
Reada~Bassicuri 57-C-3-3(b),(c)
Acoustic Technology, Inc.
=22 Union Wharf
- Boston, Mass. ~02109 Carolyn Anderson 215-13(d), 215-14(b)
Carolina Power & Light Co.
.Shearon Harris Energy-&
Environmental Center.
Route 1, Box 327
-New Hill, N.C.
_ 27562 Robert Black 57-C-3-4(d),(e),
Carolina. Power & Light Company 57-C 7(a),(c),(d),(f),(g),
~
P.' O. Box 1551 '
57-C 8(c),(e),(f),(g),.
- Raleigh, N.C.
27602 224-3(d)-(e)
Brian McFeaters-57-C-5(j)-(k)
' Carolina-' Power & Light Company 224-3(a),(b),(c)
~P.O.
Box 1551 Raleigh, N.C.
27602 INTERROGATORY NO. Gl(d).
[P] lease identify all-facts con-cerning which each such person identified-in response to G1(c)(1) above has first-hand knowledge.
ANSWER:
See answer to Interrogatory No. G1(c).
t.
'l 291
.' INTERROGATORY-NO. G1(e).
'[P] lease identify all facts
'and/oridocuments upon which.each personoidentified in response to G1(c)(2) above relied in providing information to respond to
- the. interrogatory, : including-the parts of cuch documents relied
.upon.
,' ANSWER: -Alls facts or documents relied upon by those indi-viduals identified.above are indicated'within each response to the specific interrogatories on Contentions 30, 57-C-3, C-10,'57-C-13, 213,-215 and.224.
e -.
INTERROGATORY NO. Gl(f).
Please identify any other docu-
' ment (s) used or relied upon by Applicants in. responding to-the-interrogatory.
ANSWER: - See Answer G1(e).
-INTERROPGATORY~G1(g).
Please state which specific fact
.each document,' identified'in response to G1(e) and Gl(f) above, supports, in the opinion or belief of Applicants, or which Applicants allege such' document supports.
' ANSWER:. Applicants have indicated which specific facts-are supported by the' documents identified, within each response to the specific interrogatories on Contentions 30, 57-C-3,.
l57-C-10, 57-C-13,- 213, 215.and 224.
INTERROGATORY Gl(h).
Please state specifically.what
.information each person identified in response to G1(c)(1) or G1(c)(2) above provided to or for Applicants affiant in an-iswering.the interrogatory.
If any of this information is not documented, please identify it as " undocumented" in responding to this~section of General Interrogatory Gl.
ANSWER:
See Answer G1(c).
INTERROGATORY G2(a). -Please state the name, present or last.known address, title. (if. any)', and present or last known employer,,and economic interest-(shareholder, bondholder, con-tractor,; employee, etc.)'if any (beyond-expert or other witness
. fees) such' person holds in_' Applicants or any of them, for each
~
person you intend or.expectLto call as an expert witness'or a witness in this proceeding, if such information has not previ-
'ously been supplied, or has changed since such information was last supplied, to Wells Eddleman.
This applies to Eddleman and 1
Joint Contentions"as admitted,'or stipulated by Applicants.
J.-
E ANSWER:
Applicants have not yet identified the expert or other witnesses they; expect to call in this proceeding regard-ing these Eddleman contentions.
When and if such witnesses are a
-identified,. Applicants.will supplement this response in a time-ly manner.
INTERROGATORY NO. G2(b).
Please identify each contention regarding which.each such person is expected to testify.
ANSWER:
See Answer G2(a).
INTERROGATORY NO. G2(c).
Please state when you first con-tacted each such person with regard to the possibility of such person's testifying for Applicants, if'you have-contacted such person.
ANSWER: 'See Answer G2(a).
' INTERROGATORY NO. G2(d).
Please state the subject matter, separately for each contention as to which each such person is 1 expected to testify, which each such person is expected to tes-tify to.
ANSWER:
See Answer G2(a).
INTERROGATORY NO. G2(e).
Please identify all documents or
. parts thereof upon which each such witness is expected to, plans to, Hor will rely, in testifying or in preparing testi-mony.
ANSWER:
.See Answer G2(a).
' INTERROGATORY NO. G3(a).
Please identify any other source (s) of information which Applicants have used to respond to any interrogatory identified under G1 above, stating for each_such source the interrogatory to which it relates, and what information it provides, and identifying where in such source that information is to be found.
ANSWER:
Applicants have identified all other such sources of information, if any, within the answers to the specific interrogatories set forth herein.
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. INTERROGATORY NO. G3(b). -Please identify'any other.
. source (s).of.information-not previously identified upon which
- any witness-identified under G2 above, or other witness, has usedLin preparing testimony or-exhibits,.or. expects to use in n
' testimony:or exhibits,* identifying for each such source the i
e
. witness who-is expected ~to use it, and the part or part(s) of.
such : source (if applicable) which are. expected to be used, and, if:not'previously stated, the-fact (s) or subject matter (or
'both):to which such source" relates.
ANSWER:
See Answer G2(a).
jINTERROGATORY NO. G4(a).
[P] lease identify all documents,.
and which pages orisections thereof Applicants intend or expect to;use in cross-examination of any-witness I call in this hear-Ting. -For each,such. witness, please provide on a timely basis
- (ASAP'near or during hearings) a list of all such documents,.
the. subject matterLApplicants believe they relate to, and make the document (s) available for inspection and copying as soon as possibleLafter Applicants decide or form intent to use such document'in' cross-examination.-
' ANSWER:
Applicants have not at.this time identified which documents,- if any, they intend to use in cross-examination of Mr.-Eddleman's w'itnesses.
' INTERROGATORY _NO; G4(b).
[P] lease identify any undocumented information Applicants intend to use in cross-examination of each such witness for me.
ANSWER:
See Answer G4(a).
^ INTERROGATORY NO. G5(a).
[F]or each contention Applicants state or admit'is an admitted Eddleman contention under G1(a) above, or an admitted ~ joint intervenor contention, please state whether' applicants have-available to them experts, and informa-
. tion, on the subject matter of the contention.
ANSWER:
' Applicants have available to them experts and
. information on the subject matter of Contentions 30, 57-C-3,
~57-C-10, 57-C-13,.213,,215 and 224.
INTERROGATORY NO. G5(b)..
If the answer to (a) above is
'other-than affirmative, ' state whether Applicants expect to be able to obtain' expertise in the subject matter, and information on it, and if not, why not. ;
7 ANSWER:
Not applica'ble.
INTERROGATORY NO. G6(a).
[F]or each document identified
- in response-to any interrogatory herein, or referenced.in re-sponse to any interrogatory herein, please supply all the fol-11owing information which has not already been supplied:
.(i) date of the document (ii) title or identification of document (iii) all authors of the document, or the author (iv) all qualifications (professional, technical) of each author of the document (v) the specific parts, sections or pages, of_the document, if any, upon which Applicants rely (vi) the specific information each part, section or page identified in response to (v) above contains.
(vii) identify all documents used in preparing the document to the extent known (and also to the extent not. identified in the document itself)
.(viii) state whether Applicants or State of NC or any emergency planner possess a copy of the document (ix) state all expert opinions contained in the docu-ment,.upon which Applicants rely, or identify each such opinion.
(x) identify the contention (s) with respect to which Applicants rely upon (a) the expert opinions (b) the facts identified in the document (xi) state whether Applicants now employ any.
author (s) of the document, identifying each per-son for each document.
(xii) state whether Applicants hcee ever employed any author (s) of the document, identifying each such person for each document.
(xiii) identify all sources of data used in the docu-ment.
Answers to all the above may be tabulated or grouped for efficiency.,
b a
A
' ANSWER:.All-such-information available to the Applicants with regard,to each document identified in-response to an interrogatory herein'is contained in the.particular document
.whichLis being made~available'to Mr'. Eddleman.
'It would be 2
particularly burdensome for Applicants to.research all histori-cal : employment l records to determine whether the authors of each fdocument identified _herein have ever been employed by Appli-cants.
However,-Applicants will supplement this-response.in a
^
timely manner if'and when Mr. Eddleman identifies any such-author'regarding whom he is particularly interested in de-
'termining.this information.
-INTERROGATORY NO. G7(a).- Please identify all-documents which Applicants. plan,-expect or intend to offer as exhibits
'(other'than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which.(i) is included in your' current response to Gl(a),.or (ii) is the sub-ject of interrogatories in this set; please state-for which contention,or contentions.each exhibit will.be or is expected to be offered.
ANSWER:
Applicants have not yet identified those docu-ments they intend to offer as exhibits relating to Contentions 30, 57-C-3, 57-C-10, 57-C-13, 213, 215 or 224 INTERROGATORY NO.-G7(b)..
Please-identify all documents which Applicants plan, expect or intend to use in cross-examination of-any other parties' witnesses or joint intervenor
' witness in this proceeding, with respect to (i) Eddleman con-tentions identified under G7(a)(i)-(or Gl(a)) above, or any
-other-Eddleman contention which is the subject'of interrogato-ries in this' set; (ii) each' Joint contention now. admitted in this proceeding; (iii) per our agreement of 4-8-83, each con-tantion of each other. party to this proceeding which is-cur--
rently admitted.
Please identify for each such document the witnesses,-or' witness, and all contentions with respect to whom (or which) that document is planned, expected, or intended to Ebe offered or used..
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'/ ? _
e ANSWER:
Applicants have not yet identified those docu-tmentsttheyyintendito'usesfor cross-examination of any witness.
LINTERROGATORY;NO.DG7(c)..Please identify which of the
?documentsfidentified in response to.(b) above (i) will be coffered into evidence,by Applicants, and (ii) which of the same e
. documents Applicants. expect to offer into evidence or~ intend to
'offerr as :evidenes or : exhibits. in: this; proceeding.
ANSWER:s.See Answer G7(b).
INTERROGATORY NO. GlO(a)._'Where the above general ir.ter-
' _rogatoriesfand/or1 specific-interrogatories below,.or any of them,1 call for. identification of documents, (i) rand no docu-
.ments.are, identified > is that the?same as Applicants stating ithat".there are no. documents responsive to this general inter-Jrogatory,--.in.each. case where~no. documents are identified?: (ii)
.and. documents are' identified, is that-the same as Applicants
~ stating that.sthe identified documents are the only.ones
.prsently known which'are responsivento.the interrogatories?
.(iii) If~your~ answer to G10(a)(ii) is other than-affirmative, please-state all' reasons for your' answer.
(iv) If your answer to G10(a)(i),above is other than affirmative, please state.all'
.rasons for-your answer.
9
-ANSWER:
(i)
Yes.
(ii).
Yes.
(iii)
Not applicable.
(iv)
'Not applicable.
. INTERROGATORY NO. GlO(b).. Where:any. interrogatory, gener-al or specific,Lherein, calls for factual information (1) and an" opinion is: stated in response, is'.that the expert opinion of any person (s)~ identified as having^ contributed information to-that response?
(ii) and facts are given or. identified ~(or a.
~ fact is)-in" response, but no documents are identified, does
' -that mean Applicants have no. documents containing'such. fact (s)?
~
'(iii).If1your answer to'(i) above isLaffirmative, please state
-for.each such response all qualifications of each expert upon
-whom.Appli' cants rely for each such' answer.. -The qualifications need.be stated only once'for each such person if they are
-clearly. referenced in other answers.
(iv) if your answer to
.-(i) above is~other than~ affirmative, please state which opin-
'ionsd if.any, given-in response to' interrogatories'(general ~or specific) herein is the' opinion of an expert, identify each ex-pert.whose_ opinion you used in response to each interrogatory, and state in full the qualifications of each such expert, (v)TIf your answer to1(i) above is other than affirmative, o
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{
please~ identify all opinions of non-experts used in your re-sponses, and identify each non-expert.whose opinion is included in each answer-herein.
(vi) If your response to (ii) above is other than affirmative, please identify each document which contains a fact not previously documentd in your response (s),
stating what the fact is, and at what page, place, chapter or other specific part the document contains such fact.
. ANSWER:
(i)
Yes.
'(ii)
See Answers Gl(e), (f) and (g) and GlO(a)(i) above.
(iii)
The professional qualifications of Messrs. Bassiouni, Black and McFeaters are being provided under separate cover.
All others have been previous-ly provided.
(iv)
Not applicable.
(v)
Not applicable.
(vi)
Not applicable.
INTERROGATORY NO. Gl1.
For each answer to each interroga-tory herein (or any subpart or part thereof), please identify each item of information in possession of Applicants (including facto. opinions of experts, and documents) which (a) contra-dicts the answer you made, (i) in whole (ii) in part (please identify each such part for each item of information identi-fled), (b) casts doubt on your answer (i) in whole (ii) in part (please identify each such part for each item of information identified).
(c) Please identify all documents not already identified in response to parts (a) and (b) above (and their subparts) which contains any item.of information asked for in (a) or (b) above.
Please identify for each such document what information item (s) it contains and what answer (s) each such item is'related to.
ANSWER:
G11(a)-(c):
Applicants have no such information.
INTERROGATORY NO. G-12(a):
In your previous answers where you have not identified documents, (i) have all relevant docu-ments been produced in lieu of stating identification of each such document?
(ii) do you rely on the entire document, since you have not identified parts or page numbers?
(iii) if there 7
!are any particular parts or pages of.each document' produced, which you believe are. responsive'to an interrogatory or portion-thereof, please identify _each set of parts.or pages in each-document, together.with the interrogatory or portion-thereof
.(or interrogatories and/or portions thereof) to which it is re-Japonsive.
(iv) where no documents areLidentified and identifi-cation of documents has.been requested,.are you saying no'such
' documents' exist?- Or_that no such documents _are in your posses-sion?' (b) In your.present answers,.are you actually identi-
- fying' documents-where identification of documents is requested?
.(c)"If not,1how are you going _to provide identification of
~
Ldocuments?
Will that: identification include-statements of.rel-evant pages=or parts?
ANSWER:
G12(a)-(c):
All responsive documents have been either identified in or' produced in response to the discovery requests.
Page numbers have been specified-in each case.where fApplicants rely on specific portions of a document _and can
~
-identify those portions-more readily than could'someone.who has-no familiarity with the-document.
Where-identification of 1
L
~ documents has been requested,_and none are identified, Appli-i cants know of no_ responsive documents.
F INTERROGATORIES ON EDDLEMAN 57-C-3' 43 INTERROGATORY NO. 57-C-3-3(a):
Is any consideration'of temperature 'given in night-time notification of residents or
-transients within the EPZ (i) at all (ii) as regard turning off
' heating' devices on cold nights,Eif' sheltering'is recommended i-(iii)'as regards turning off air conditioners on warm or hot
- nights, if sheltering is-recommended?
(b)
Have.you'(i)-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
'with the EPZ?.
l
[
(c).
If so,' please identify all such information and all documents containing such information.
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y
- L (d)
Does1the 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.
ANSWER:
(a)
Temperature is not considered in notifica-tion.
However, if sheltering is determined to be the appropri-tate protective action, instructions for the public are included in Annex D to the North Carolina Emergency Response Plan in support of the Shearon Harris Nuclear Power Plant.
(b)
Applicants have not conducted tests and have not col-lected information specific to the capabilities of different notification methods at night.
NUREG-0654 was utilized as guidance in designing the notification system within the Harris EPZ.
It has been demonstrated that nighttime ambient back-ground noise is substantially lower than daytime, which facil-itates the effectiveness of notification by siren at night.
'(c)
NUREG-0654, " Criteria For Preparation and Evaluation of Rad.4,ological Emergency Response Plans and Preparedness In Support of Nuclear Power Plants" (Rev.
1, Nov. 1980); FEMA-43,
" Standard Guide For Evaluation of Alert and Notification Sys-tems-For Nuclear Power Plants" (Sept. 1983); and Beranek, Leo,
" Noise & Vibration Control" (McGraw-Hill), at 579, Figure 18-8..
m (d)
The same notification procedures will be followed at
. night as-during the day.
However, the evacuation time esti-mates (ETE)Limplicitly provide for delays associated with awak-ening sleeping residents of the EPZ, by assuming a delayed and staggered departure from the EPZ.
The ETE assumes that no one
-leaves'until half an hour after the decision to evacuate has been made and-that the subsequent departures are distributed over'the next two hours.
This is considered to adequately ac-count for'any delays of the type cited.
-(e)
See response to'(d).
(f)
Not applicable.
INTERROGATORY NO. 57-C-3-4(a):
Referring to your answer to 57-C-3-2, do any of the entities listed (including "other authorities") have any automatic telephone notification or di-aling systems at all?
(b)
If so, please answer 57-C-3-2(b) with respect to the capabilities of each such system.
(c)
Do you have-any opinion as to.whether persons awak-ened by sirens in the Harris EPZ might use the telephone (i) to ask authorities what is going on.(ii) to notify friends or rel-atives 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 dur-ing normal sleeping hours, e.g.
from 1 am to 6 am?
Please de-tail how each such opinion would change if the awakening oc-curred during people's normal sleeping hours.
(d)
Do you have any information concerning the response of persons to (i) siren (ii) telephone (iii) broadcast (iv) loudspeaker / sound truck (v) personal contact (e.g. door-knocking) notification of severe accidents where evacuation or sheltering may be necessary?
(e)
Please identify all information you have concerning 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 that evacuation of the Harris EPZ
'could occur-as rapidly during normal sleeping hours (e.g. be-
. tween.1 am-and 6 am) as it could during daytime hours, all weather or other conditions being equal?
Please state all rea-l sons-and information supporting your opinion.
(g)
Is it your opinion that 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 it your opinion that' evacuation of the Harris EPZ would be more or less rapid du' ring normal sleeping hours (1 am to 6 am)~as it would be'under (i) daytime conditions, similar
. weather (ii) evening conditions, up to about 10 pm, with simi-lar weather?
Please-state all reasons and information sup--
porting your opinion.
Please identify all documents which contain information re answers to parts (f) (g) and (h)
(including all sub-parts).
~ ANSWER:
(a)
None of the entities listed have available to them automatic telephone notification or dialing systems for notification of the-general public.
(b)
Not applicable.
(c)
Some people would probably-try to use the telephone for the specified reasons at all times of the day or night.
(d)
Information concerning the response of persons to various means of notification is-available in the public. liter-ature.
(e)
Such information is discussed'in the following docu-
' ments:
Susan Cutter and Kent Barnes.
Evacuation Behavior and Three-Mile Island.
Disasters, Volume 6, No. 2, pp. 116-124 (1982).
E~
. s l
Ronald W. Perry et al.
Evacuation Planning in Emer-gency Management.
Lexington Bcoks, D.C.
Heath and Company,uLexington, Massachusetts (1981).
-Ronald W.
Perry.
Comprehensive Emergency Management:
Evacuating Threatened Populations, JAI Books, Greenwich, Connecticut (1983).
(f)- Yes.
See response to Interrogatory No. 57-C-3-5(d).
An evacuation of the Harris EPZ can be e: pected to occur as rapidly during normal sleeping hours as during daytime hours 9
alliother conditions being equal.
This is the case since potential delays associated with waking and mobilizing a sleep-
-ing population are offset by other factors.
For instance forming family. units is much simpler.during normal sleeping hours.
This minimizes time required to prepare to evacuate.
Likewise, demands for public emergency vehicles will be reduced
.since permanent resident vehicles sill ime at the residence when notification is received in a greater number of cases during sleeping hours.
In addition, there is likely to be much less cross-traffic during sleeping hours since the highway network will be'nearly empty.
All of these factors will serve to en-hance evacuation capabilities.
(g)
Yes.
See response to Interrogatory No. 57-C-3-5(d),
and the reasons outlined in the previous response.
(h)
There would be no significant difference in the
. amount of' time to evacuate-in sleeping hours versus non-sleeping hours for the reasons previously. cited.
As - -
=
1 indicated in the ETE report, an evacuation during the day is estimated'to take longer.
The longer period of time is re-quired due to. the higher. employment and transient populations
.during the. day.
The ETE explains, in detail, the methodology, data-and assumptions-used in each of the scenarios modelled.
See also the response to Interrogatory No. 57-C-3-5(d).
INTERROGATORY NO. 57-C-3-5(a):
Is there any difference in rapidity of evacuation during normal sleeping hours (e.g. 1 am to-6 am) as compared to evacuation at other times?
-(b)
[P] lease explain each such difference.
(c)
[A]re there differences in evacuation conditions dur-ing normal sleeping hours, and conditions for evacuation during other hours, that would tend to offset or cancel each other?
(d)
[W] hat are these differences, and how do they act to offset each other?
(e)
Please identify all documents concerning differences in (1) evacuation conditions.(ii) rapidity of' evacuation (iii) evacuation times, for normal sleeping hours compared to other times.
(f)
[A]re there'any differences in evacuation conditions (see (c) above, e.g.) between sleeping hours (1 am - 6 am) 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 evacu-ations which indicates differences in evacuation times under sleeping hours conditions?
(j)
Is there any consideration of increased likelihood of fog or precipitation 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 l
evacuation 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? L --
E-c
- o.
.(1)
Does.the State of NC, CP&L or any other responsible emergency preparedness agency intend to test (i) communications (ii) notification (iii) sheltering (iv) evacuation (v) other emergency response-plan elements, during normal sleeping hours
-(1 am to_6 am or any time between these hours, i.e. between 1 am to 61am)?
(m)
If so, what tests will be done, by whom, and on about what dates (e.g. before fullscale plan test, during that test,
'before.Jan.
1, 1985, quarterly, once a year, etc)?
ANSWER:
(a)
There may be a difference, for the reasons outlined in the response to (d) below.
(b)
See the response to (d) below.
(c)
Yes.
-(d)
At night, there is less existing traffic on the roads. : Family members are more likely to be all together and evacuate as units,- thus minimizing the number of evacuating ve-hicles.
These factors would tend to make evacuation more rapid at night than during the day.
On the other hand, driving at night may be more difficult for some people.
See also the re-sponse to 57-C-3-4(f).
A study of past evacuations by the U.S.
Environmental Pro-tection Agency, Joseph M. Hans, Jr..and Thomas C.
Sell, Evacua-tion Risks - -An Evaluation, EPA-520/6-74-OO2 (June 1974), did not reveal any correlation between time of day and the time re-quired to evacuate a population grcup.
(e)
See response to (d) above.
(f)
Yes.
(g)
See response to (d) above. -
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(h)-'Yes.
'See response to-(e) above.
(j) -;(k)
The adverse weather case analyzed in the ETE is a late fall' weekday case..This case combines peak populations with a roadway capacity reduction of 25%.
This adverse case is
.' considered more time consuming _than an adverse weather case during normal sleeping hours.
No_ specific analysis of the frequency of fog or precipita-tion during sleeping hours has been attempted.
However, it should be noted that precipitation in the vicinity of the Harris _ plant site is not more likely during normal sleeping hours.than at other times of the day or night.
'(1)
As required in Part II, Section N, of NUREG-0654, Re-vision 1 (November 1980), periodic exercises will be conducted to evaluate major portions of emergency response capabilities,
'and periodic drills will be conducted to develop and maintain key skills.
The type and frequency of drills and exercises, and the responsibility for their conduct, are described in 44 C.F.R.-Part 350 and Section VII of the North Carolina Emergency Response Plan In Support of SHNPP.
This plan has been served on the parties to.this proceeding.
As indicated there, at least one exercise will begin between midnight and 6 a.m. every six. years.
(m)
See response to (1) above.
INTERROGATORY NO. 57-C-3-6(a):
Does NUREG-0654, FEMA 43, or'other applicable guidance (please identify all documents containing other applicable guidance) for the Harris offsite emergency plan require (i) both an alert signal and an-informa-utional-or' instructional message to the population on an area.
1 wide basis-throughout the 10 mile EPZ, within 15 minutes? (ii) initial notification system assuring direct coverage of essen-tially 100% of the population within 5 miles of the s.te? (iii)'
special arrangements to assure 100% coverage within 45 minutes of the population who may not have received the initial notifi-cation within the entire plume exposure EPZ?
(b)
How does the Harris offsite emergency plan notifica-tion procedure meet each notification requirement of FEMA 43 (Including (i), (ii) and (iii) of (a) above if applicable) dur-ing normal sleeping hours (e.g. 1 am to 6 am)?
Please specify your answer in detail, describing the alerting systems used, the design report on each alerting means to be used, the abili-ty to provide an informational or instructional message to per-sons who are asleep at the time of the alert / notification be-
. ginning; 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 notifi-cation in NUREG-0654 or FEMA 43, or other applicable guidance (as indicated in your answer to (a) above).
ANSWER:
(a)
The minimum acceptable design objectives for an alert and notification system are specified in Appendix 3 of NUREG-0654, Revision 1 (November 1980).
Item (1) is one of the three design objectives for the system.
This design objective is also specified in 10 C.F.R. Part 50, Appendix E, IV, D.3, which indicates that the timing and extent of actuation of the public notification system is a responsibility of State and local officials.
Items (ii) and (iii) above are the two other design objectives specified in NUREG-0654.
These three design objectives are also quoted in FEMA-43 (September 1983).
(b) -The same way it does during daytime.
A study by the Applicants to demonstrate that the Harris alert and notifica-tion system meets the criteria in FEMA-43 is now in progress.
r.
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INTERROGATORY NO. 57-C-3-7(a):
What, in your view, are the merits and/or negative aspects of the use of tone alert ra-dios to notify sleeping persons of an accident at the Harris plant?
-(b)
Isn't it true that FEMA 43 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, or other aspects of tone alert radios for the Harris EPZ?
J.(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, re-sults, or information obtained or developed in such investiga-tion.
(e)
Nro there any other sources of information re tone alert radi'os which you are aware of?
Please identify each such..
(f)
Do you consider tone alert radios to be an alterna-ti've to_(1) siren notification (ii) loudspeaker notification (iii) automatic ringdown telephone notifcation, for notifica-tion 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.
1 am to 6 am?
(g)
Plea'se give all reasons for your answer (s) to each subpart.of (f) above.
ANSWER:..(a)
The merits are (i) it will meet the 15 minute quideline of NUREG-0654, Appendix 3; and (ii) the mes-sage is.given'at the sama time as the alert.
,The principal drawbackisthelackof-physicalcontrolovertheradiospy
,/
emergency response authorities regarding their use, testing, maintenance, and repair.
An additional drawback is that people may not hear the tone alert radios if they are in another part of the house or outside.
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o (b)
As indicated in the first paragraph of Section E.6.2.4 of FEMA-43, the section deals with alerting methods other than sirens, mobile siren vehicles, or tone alert radios.
(c)
No formal ~ study for the Harris EPZ was conducted; however,~CP&L has studied this matter for other plants.' See response to (d) below.
(d) Applicants included analysis of tone alert radio noti-fication systems in the development of emergency notification systems for CP&L's Brunswick and Robinson Nuclear Plants.
The results of this analysis are included in studies prepared by NUTECH Corporation, dated December 1980, which are available
.upon request.
Applicants, in their evaluation of these studies, selected a siren notification system because of'its
. reliability, ease of maintenance and testing, cost effective-ness, regulatory requirements, effectiveness in notification capability, and the capability to physically control the warn-ing devices.
(e)
Federal Emergency Management Agency.
Standard Guide for.the Evaluation of Alert and Notification Systems for Nucle-
-ar Power Plants, FEMA-43 (September 1983).
(f)
Tone alert radios could supplement all of those sys-tems.
(g)
See the response to (a) above as well as the refer-ence listed in the response to (e) above.
INTERROGATORY No. 57-C-3-8(a):
Does FEMA encourage the use or development of special alerting methods such as automat-ic telephone dialers or switching equipment where it is cost effective?.
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-(b)i 'Pleasejprovide all-basis for your answer to (a),
'identifyingiall documentsLor expert opinions you used in making that.ansyer.
- (c)- Have you made
- any study of the cost-effectiveness of
'any'~specialialerting' methods for the Harris EPZ during normal fsleeping' hours (e.g. 1 am to'6'am)?
(d)
Please identify alli. documents concerning, or used in, or sidentified 'during,' any such. study as inquired about'in part (c)gabove.
(e) -Have you made_any.studyLof simultaneous dialing sys-
..n
.tems, e.g'.'tho~se mentioned in section E.'6.2.4.4 of FEMA-43, for
- use in the Harris EPZ,.for notification during normal sleeping
- hours or
- for notification or delivery of. instructional or
" informational messages?
.(f)'
Please' provide details.of any such study as inquired.
about.in part (e) above, including' identification of all docu-
.ments-related to.such study, particularly;any about the'capa-bility.of simultaneous-dialing or simultaneous-ringing tele-u-
> phone equipment.
f(g)-.Was-the message-delivering capability-of ry
- simultaneous-ringing or dialing. telephone equipment considered cin~any.of-your studies?
Innwhich,.and how?-
.,. (h)
Maat is:your. opinion concerning the usefulness of-(i)-
simultaneous dialing (ii) automaticLringdown. dialing telephone-equipment for notification.of persons within the Harris EPZ duringindrmal. sleeping. hours?
Please.give all basis for-your Topinion, identifying all documents used in preparing or.sup-fporting.-your-opinion.
m (j) f(there'i1"s no part (i) since that is used-for:
- subparts, as (i),-(ii)) :What role did provisions for (i) call--
ing'back; busy 111near(ii) preventing subscriber overloading of ithe teleph~one systemsduring'use;of. telephone' notification to HarrisjEPZ residents / transients. play in your^ analysis or study jof. telephone notification,within the Harris EPZ?
Ja.
<"7 M(k) ~.Would telephone system overloading-by subscribers be
,lessD m'oreto'f, or Lab'oGt:the 'same of a problem for telephone no-g
- tifica~tioniduring' normal-sleeping hours?.
~Z:,
(1)"fEave-you made; orfcollected, any other studies.orire-EportsLor; inquiries concerning notification systems ~or methods 4
ifor.' people'(.i);wh.o are' asleep.'at the time of notification (ii)
Jwhose:whole households.are asleep at the time of notification, p
ifor.;emerg,ency, planning / response purposes or other purposes?
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(m)
Please describe ~1n detail any studies /information asked about in (1) ebove.
ANSWER:
(a)
Yes..
(b) ' FEMA-43, Section E.6.2.4.
(c)
No.
(d)
Not applicable.
(e)- No; no formal studies have been conducted.
(f)
Not applicable.
(g)
No studies were conducted (see response to (e) above).
(h)
Both-can be useful in~ warning a relatively small pop-ulation or emergency response authorities.
The drawback is that.'they can burden the available telephone network, which may p
, be.needed for other purposes.
N (j)
Not applicable.
(k) l Fewer people would probably be using the phone system during normal sleeping hours than during the day.
(1)
No.
(m), :Not applicable.
INTERROGATORY NO. 57.-C-3,9(a): -Referring to your answer to 57-C-3-1(f), if not previously fully answered, does any doc-umentatic.. -e records of any kind concerning the consideration Lof 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 ef-
'fect, or-you believe you have fully answered (a) previously, please explain-why no records of this consideration exist..
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.(d)I Do'you remember anything about the consideration of telephonernotification of persons within the EPZ that was made during the emergency planning process?
( eI). 'If.so,swhat do youLremember?
(i) Do you remember.
what kinds of telephone notification-(aa). methods (bb) systems,
- were considered?
(ii).do you remember.any reasons why tele-phone notification was. rejected?- :(iii) do you remember whether night-time.(normal sleeping hours). notification was part of the
' consideration'of telephone notification for the Harris 1 planning
.processL(emergency. response planning)?; (iv) do you remember whether. alternatives,toLtelephone notification, e.g.
tone alert radios,_etc., were' considered?
Please. explain what you remem-
.ber, bothiin' general, and-for.every subpart for which your an-swer is affirmative.
LANSWER:
. ( a) - This question was fully answered in the re-spon'se'to 57-C-3-1(f).
No documentation exists.
~(b) LNone.
,(c)
It was'not considered necessary; the consideration l
was' informal.
. (d)' 'N.C.
DEM's'-informal' consideration-reliedLon first
. hand experience.
- ( ei)
Thel merits,of a telephone notification system rela-tive to sh'e. warning systems already in use in the state.were
-considered.
INTERROGATORIES ON EDDLEMAN'213 5
INTERROGATORY NO. 213-3(a):, Refer to~your answer td 213-1(d):
Do.you~ agree that the job: titles'or names'of persons i'
responsible for-veryifyingi(in-the field)-and/or receiving re-
. ports verifying (in.the Emergency Operations Center) that per-sons on the Harris' Lake have been notified of:an accident at
. - -the~ Harris nuclear ~ plant, should be part-of the plan (off-site a
emergency response plan)?
- (td-Please fully explain all reasons for your answer to
~
-(a)Eand identify any documents or authorities you rely.on in
. making'that-answer.
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(c)' What is the job _ title of the person or persons re-sponsible for receiving reports that notification of persons on or_in the Harris Lake has been accomplished?
(d)
[W] hat is the job title of.the person or persons re-sponsible for notifying 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 the titles, including those 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.
ANSWER:
(a) - (b)
Yes.
Annex J of the plan is the basic
' document controlling notification procedures for Harris Lake.
As such, it contains the names and affiliations of persons re-sponsible-for carrying out these functions.
Annex J will be available by the end of September 1984.
However, a printer's copy can be made available sooner, upon request.
(c)
The Wake County Sheriff.
(d)
(e)
This information is in Annex J, as noted in the responses to (a)-and (b) above.
. hat are the means for giving INTERROGATORY N0. 213-4(a):
W 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 re-sponse plan,_and identify all documents concerning these means, your authority or ability to use them, what personnel are re-quired to operate these means, how many, where they work, who their backup personnel are, where the backup personnel work, how many_ people are required to operate each means, all backup
'means of-notification for persons on/in the Harris lake, and the above information for each backup means of notification.
L(c)
What is the content of the instructional message for persons on/in the Harris lake in the event sheltering is or-
.dered?
Does it provide for sheltering at or near the lake?
If
r-
~is L
-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?
ANSWER:
(a)
(b)
This information is_available in Annex J.
(c)
The_ instructional message on signs around the lake will advise that, upon notification, persons are to leave the lake immediately and to turn on radios and televisions for information and instructions.
The instructions provided via' radio and television will, if appropriate, direct people con-cerning sheltering actions.
INTERROGATORIES ON EDDLEMAN 57-C-lO INTERROGATORY NO. 57-C-10-5(a):
Please refer to your sup-plemented answer to 57-C-10-3-d.
Were any methods for as-
.sessing 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 iden-tify each such methodJand 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?
(iii) explosion of nuclear weapons?
(iv)' conditions of fallout after a nuclear explosion or explosions? -- please specify what it means.
ANSWER:
(a)
No.
The state shelter survey was conducted for. purposes related directly to civil defense during a wartime
. nuclear emergency.
Results of the state survey and supporting documents have been provided.
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a (b).-WartimeinuclearJemergency means'a wartime situation
. involving the' actual or potentialfrisk to'the public'from radi-H?atio'n;;i.e.,' fallout after a nuclear: explosion.
t 1
. INTERROGATORY NO. 57-C-10-6(a):
Were.any differences be--
etween (i) wartime' nuclear-emergency' conditions (ii) nuclear
~
Lweap'ons. fallout l conditions, and likely conditions for a serious t accident' at; the. Harris nuclear plant, considered in'the shel-
- tering effectiveness ~ estimates made for structures.in the tHarris EPZ?
- (b)ufPlease specify each such difference and how it was
-considered.
Please. identify-all documents'concerning the ef-
.'fect-of-each difference on the Protection Factor-(PF) or shel-itering. effectiveness;for structures or any specific struc-h
-ture(s) within1the Harris EPZ.
,(c);.~What account of' infiltration.of'(i) radioactive gases (ii) radioactive particles,'.with incoming air,.is taken in (aa) the sheltering effectiven~esslor1PF estimates you now possess (bb)_ sheltering' effectiveness or PF. estimates for use in con-2
~
- :nection with a nuclear accident at the. Harris plant? -If.there 1
- isLno difference,.or the estimates are the same, please say so.
. 04). -How;1ong is the maximum sheltering time for a' nuclear.
accidunt,at: Harris?
i
.(e),If you don't know a maximum sheltering time'that
[
~
'might befrequired due tora nuclear accident ~at Harris, either-(i) for the EPZ as a whole,-(ii)Jfor any part of the EPZ, or
?
' ~
- (iii) for-any structure (s) or. areas within-the EPZ, please
.explainEa11 reasons why.you don't know.
1 (f) 'What'iscthe maximum sheltering-time that has been.
considered:(i)-for-the entire EPZ (ii) for any part(s) of the- ~
'EPZ' -- please: specifyL which. parts (iii) for any. structure (s) or specificJlocation'within.the EPZ -- please specify:which~struc-
- ture(s)Torfspecific1 locations..
(g) /Docany PF 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
~
4 Tdoithis: sealing,uthe: availability oflthose materials at the
- structure? and the additional protection. assumed or calculated 4
for believed to-result from;such sealing.
i '
(f)_(sic; (h)]'
How long can occupants o.f any sealed area
- or structure-(see-(e);above)~ stay in shelter without exhausting
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their. air supply?
Have you made any calculations or estimates for any structures within the Harris EPZ?
_(g) [ sic;-(i)]
Do you know anything about the
- infiltration rates of-(i) air (ii) particles, including parti-cles 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 such infiltration rates affect the radiation doses likely to be re-ceived by persons sheltering within those structures?
Please detail all basis, documentary or otherwise, for your answers.
ANSWER:
(a)
No, the shelters to house evacuees are lo-cated outside the 10-mile EPZ.
If in-place sheltering is se-lected as a protective repsonse within the 10-mile EPZ, the
- public will be. advised to' remain in whatever shelter they are in.
(b)
See (a) above.
(c)
None.
(d)
The maximum time for in-place sheltering within any area of the 10-mile EPZ could be on the order of a few hours depending on the nature of the accident and environmental con-ditions.
(e)
There are many factors which affect sheltering time.
These factors include both plant and environmental conditions.
The numerous combinations of these factors make it difficult to identify one maximum value of sheltering time.
'(f)- See (d) above.
(g)
The shelter survey noted in the responses to Inter-rogatories 57-C-10-2 and 57-C-10-4 is intended for use in war-time.
It did-not assume any sealing of air pathways. m
q i.
(f) -[ sic ~ (h)]
The structures will at no time be com-pletely sealed so as to prevent air exchange with the outside environment.
Consequently, the problem of exhaustion of air supply'will not occur.
.(g) [ sic;(i)]
Yes, only as it pertains to the Manual of
' Protection Action Guides and Protective Actions for Nuclear Incidents (EPA-520/1-75-001), item 1.6.3.2, which indicates l generally that such shelters are effective for a few hours.
INTERROGATORY NO. 57-C-10-7(a):
Where are " protection
-factor categories" as used in your assessment of PFs for struc-tures within the EPZ, defined or explained?
(b)
Do you have any information about the specific PFs within each category, for structures within the Harris EPZ?
(c)
If so, what is that information?
Please identify all documents containing such information.
ANSWER:
(a)
PFs are not taken into consideration for structures used for in-place sheltering or for shelters used to house evacuees outside the 10-mile EPZ.
(b)
No..However, specific PFs were evaluated for iso-lated structures within the Harris EPZ, for wartime planning.
-These PFs were not considered for shelter planning in support of the-Harris plant.
(c)
The information about the specific PFs within each category is contained in the Federal Emergency Management Agen-cy's National Fallout = Shelter Survey Facility Booklets for Lee, Wake, Harnett,- and Chatham Counties.
These documents are stored at the.Home of Rccord, Region IV, Thomasville, Georgia.
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INTERROGATORY NO. 57-C-10-8(a):
Refer to-your answer to 57-C-10-3-e.
Is'this all-the information you have about typi-cal housing within the Hr.rris EPZ?
(b)
Does section 4.5.2 of the on-site emergency plan contain'some seven lines (about 4 sentences) concerning housing within the Harris-EPZ?
(c).Why-is-this information in the on-site plan, but not in the.off-site-plan?
(d)
Are~the PFs reported there based on any typical house shape or characteristics?
(e)
Please identify all documents that concern, or explain,'how the PFs in section 4.5.2 of the Harris on-site emergency plan were calculated for typical housing.
Please an-swer 57-C-10-3-e again insofar as your answer involves any definition'of a " typical" structure or structures.
(f)_ Please explain how the PFs of section 4.5.2.
of the Harris'on-site emergency plan we.re calculated, including base
- data used, calculation method (s) used, and all assumptions used orimade 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 ti) radioactive gases (ii) radioac-
.tive particles, infiltrating into the houses / apartments within the Harris EPZ with normal air infiltration?
If so, exactly how do.they do so?
Were any particular wind conditions used in
' estimating infiltration of radioactive gases or particles into structures typical within the Harris EPZ (houses, apartments or other structures)?
If so, please specify the assumption.
ANSWER:
(a)
Section 4.5.2, paragraph 3, of the SHNPP EP provides a description of " typical housing within the Harris EPZ.' "
(b). Copies of the reterenced document have been served on
~
all1 parties to the proceeding.
(c)' ~The'offsite^ plan instead references the Manual of Protection Action Guides and Protective Actions for Nuclear In-cidents (EPA-520/1-75-001).
(d)
Yes.
As stated in'Section 4.5.2 of the SHNPP EP, the PFs apply to masonry and wood frame houses with no basements.
('e)
The PFs in Section 4.5.2 of the SHNPP EP were derived
- from the document "Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Concepts with Existing Public and Private Structures," SAND 77-1725.
The previous re-sponse to 57-C-lO-3(e) is accurate.
(f)
See SAND 77-1725.
(g)
No.
The PFs are the reciprocals of the respective shielding: factors specified in Tables 1 and 2 of SAND 77-1725.
These numbers apply to radiation originating from outside the houses.
INTERROGATORY NO. 57-C-lO-9(a):
How much space is consid-ered to_be space for one shelteree?
Is thig amount of space
'different for small children, for babies, for the ill or in-firm?
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
- providedlin buildings within the Harris EPZ that are fallout shelters?
Is that food in' edible condition?
Is there drinking water. stored in or near high-PF areas of structures in the Harris EPZ?
Has it been verified to be drinkable?
If so, when? -(most recent date or time if known) How long can shel-terees be~ expected to stay in high-PF areas without (1) 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?
f-J ANSWER:
(a)
A square footage per person _ criteria was not considered for in-place shelters within the lO-mile EPZ.
For shelters to house evacuees outside the lO-mile EPZ, a 40 square foot per person criteria was used by the counties.
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(b)
Because in~-place sheltering within the 10-mile EPZ is En tulikely.toLexceed-a few hours (see response'to s.
' 57-C-10-6(d)), the in-shelter storage of' food and water and the l presence'of toilet facilities-are not considerations.
Shelters ilocated outside the 10-mile EPZ used to house evacuees include both c~ooking1and! sanitary facilities to support a several day-stayfif necessaryr -Limited food and water are available at
~
(
. each designated shelter,with provisions.tx) resupply as needed.
1 LINTERROGATORY NO.'57-C-10-10(a):
How are ventilation.sys-tems,: e.g..(i): heating.(ii)' cooling (iii) ventilation w/o
~ heating oricooling, considered in assessing the~PF of (aa)
.buildingsL(bb)' houses 1(cc). apartments-(dd).other structures,.
-within the Harris EPZ?
How long can such-systems be turned-off Jduring sheltering?
p
- (b).-How.long can heating systems remain'orf'for shel-E tering 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'sLwillingness to stay;in shel-ter?~'
,(c)" How long-could' cooling systems.be turned off, with Ypersons packed into1shelteree spaces, on a h'ot. summer. day-(e.g.
~
- temperatures-in.the190s,.high humidity) before adverse effects on shelterees--(i) ' occur (ii) jeopardize people's willingness tx)
-remain'in shelter?.
(d) _How long can= external-ventilation be turned off dur-
'ing-sheltering before adverse effects on shelterees occur?:
4.
.. 1(;e)--Please describe any adverse effects to shelterees
~
ithat'mayLresultLfrom turning:off of heating, or cooling, or
- ventilation? systems'during sheltering.
Please also describe L
how;(if:at'all) such effects are considered with respect to structures in which persons in the-HarrisvEPZ might.beiasked-to (takaishelterfduring'a nuclear accident.
Please. identify'all
- documents-concerning-(i) adverse effects of having. heating, Hor' cooling, or ventilation, systems turned off during sheltering J(or,-in general); -(il) consideration of = heating, cooling or Lventilation with respect'.to
- structures in the Harris EPZ in i
~
E (which* people'might shelter; (iii) degree'of adverse effects-Lunder which people may leave shelter during a. nuclear power
- plant' accident, or.the1 difference between such conditions and i.
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the conditions under which people-may leave shelters during a military nuclear emergency or nuclear war or nuclear bomb fall-fout situation; (iv) degree of_ adverse effects which would like-ly-cause people to leave a shelter during a nuclear power plant accident.
(f) -Does shelter effectiveness analysis always assume ventilation is off?
ANSWER:
(a)-(e)
Specific effects and times are unknown.
However,.because the maximum in-place sheltering period is likely to be on the order of a few hours, depending upon condi-tions, any adverse effects should be minimal.
Shelters outside the 10-mile'EPZ will have heating and ventilation systems in operation as appropriate.
(f)
A shelter effectiveness analysis was not conducted.
However, in-place shelterees within the 10-mile EPZ will be advised to close all windows and doors, and to cut off fans and air conditioners.
INTERROGATORY NO. 57-C-10-11(a):
How are construction techniques relating to the air tightness of walls, ceilings, floors, windows and doors considered in determining the shel-L tering effectiveness of structures within the Harris EPZ?
(b)
Have any direct measurements of the air tightness of 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 estimates or measurements of the specific air-tightness of con-struction of structures within the Harris EPZ.
(d)' Why were effectiveness of structures within the food
- stores eliminated from consideration in the surveys of shel-terine effectiveness of structures within the Harris EPZ?
(e)
Are food stores considered less safe shelters than
.other. structures of similar construction?.
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. ANSWER:
'(a) 'No shelter effectiveness analysis was con-a
.ductadLinLsupport of:the-Harris emergency plans.
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-(b)~ENot applicable.
~
c(c) !Not-applicable.
P (d)
For wartime planning purposes, people will not.be
-sheltered Mn foodstores, since they will serve as points for
- ^
2 food distribution'. 'Therefore, they were not surveyed for war-time planning purposes.
.(e)' The. safety of foodstores as shelters depends upon the structure of the individual buildings.
INTERROGATORY <h0. 57-C-10-12(a):
Have any. formal shelter
. location-sketches been made for any structures 1within the Harris EPZ?
-(b)i Please identify allidocuments containing: shelter lo-cation sketches, formal or informal, for any structures within the Harris'EPZ.
.(c).Please: identify all' documents showing.where the high-est,PFs are located in structures within the Harris EPZ.
Please identify any document sh'owing such areas within any such structure.
ANSWER:
(a) 'Yes,.for war-related planning.
i(b): National Fallout Shelter Facility Booklets, stored at
.Home:of Record in Thomasville, Georgia.
~( c ) - See response to (b)'above.
INTERROGATORIES ON EDDLEMAN 57-C-13 INTERROGATORY NO. 57-C-13-3(a):
-Is-your answer t'o 157-C-13-1 complete, e.g..with-. respect to parts (g) and (h)?
If 1not,=please provide answers.
(b)
.[W] hat (i) medical supplies (ii) toilet facilities,
- are-available:in high-PF areas within hospitals or nursing homes'within'the Harris EPZ?
L_'
(c)
Why haven't "best" PF' determinations for hospitals or nursing homes within the Harris EPZ been made?
Please give all reasons.
_- ( d ). What-PF determinations have been made, if any, for
-any (i) hospital-(ii) nursing home, within the Harris EPZ?
-ANSWER:
-(a)
The wartime' shelter survey includes notation of food prep'aration and serving' facilities.
It.also identifies a source of water but does not note storage of food or water.
For each structure surveyed, the capacity of each PF category within'that structure is-calculated.
(b)
The presence of medical supplies and toilet facili-ties.is not~ included in the wartime survey.
'The information has also not been' gathered-for purposes of Harris emergency planning.
(c)
(d)
Based on federal facility survey guidance, one hospital _within the 10-mile EPZ has been surveyed to date.
The second hospital within the 10-mile EPZ will be surveyed prior F
to the opening of the SHNPP.
Nursing homes within the 10-mile
'EPZ have not been surveyed.
t INTERROGATORY NO. 57-C-13-4(a):
Are there any hospitals, nursing homes, or other care facilities within the Harris EPZ besides those listed in Table 4-5 of the Evacuation Time Esti-mates (ETE) which the state or county emergency 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 nursing homes or other care facilities within the Harris EPZ?
ANSWER:
-(a)
The hospitals, nursing homes, and other care facilities listed in. Table 4-5 of-the Evacuation Time Estimate are the only ones of which state or county emergency planners are aware.
(b)
Th'ese factors were not considered in PF determina-tions for wartime related surveys.
PF surveys are related to structural aspects of buildings and do not take into account factors such as increased sensitivity of ill or elderly persons to radiation exposure.
INTERROGATORIES ON EDDLEMAN 30 INTERROGATORY NO. 30-3(a):
With respect to your answer to 30-2(d),.are there any places in the Harris-emergency response (off-site) plan where specific quantities of KI or other ra-dioprotective drugs are mentioned?
(b)
Are you aware of any reports, or recent declarations of policy or resolutions of hea'lth-profession associations, which address the desirable availability of KI or other ra-dioprotective drugs during radiological emergencies?
Please identify all documents containing or reporting on such' reports, resolutions or policies.
(c). How, if at all, do the reports, declarations or policies you identify in response to (b) above (or that you were asked.to i'lentify in (b) above), affect your answers to 30-2(a) and 30-1 subparts (b) thru (1)?
ANSWER:
(a)
The offsite plan presently does not mention specific quantities of any radioprotective drugs.
(b)
Yes.
During the Annual Meeting of the American Phar-maceutical Association in Montreal, Canada (May 5-10, 1984),
the Report of the Policy Committee cn1 Scientific Affairs contained a section, Part D,-entitled " Potassium Iodide for -.
Nuclear Accidents."
The House of Delegates declined to' adopt this section of the report and voted to refer it back to Com-mittee for further consideration.
Documentation of this action can be'found in the May 18, 198411ssue of apharmacy weekly, Volume 23, Number 19, page 75, and in the July 1984 issue of American Pharmacy, Volume NS24, Number 7, pp. 76-77.
-(c)
.The report has had.no effect upon the answers pro-vided to the' interrogatories.
. INTERROGATORY NO. 30-4(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 appli-cable. guidance is concerned?
(b)
Please identify all documents relating to such evalu-ation(s), the applicable guidance, and the results of each such investigation.'
.(c)
Do you plan to make any such investigation?
If so, when? Then do you expect to complete this investigation?
ANSWER:
(a)
Yes.
[(b)
The evaluation was made on the basis of guidance in NUREG-O'654.
The result of the evaluation was that the plans for. distribution of KI are in compliance with this guidance.
(c)
Not applicable.
INTERROGATORY NO. 30-5(a): -Are there any applicable FEMA or NRC guides for any of the items inquired about in 30-1(b) thru (1)?
If so, please specify the guidance for each item and-the document or documents which identifies that guidance.
Please identify all documents and page references which contain each.such. item of guidance. )
ANSWER:
.(a)
Yes.
Such guidance appears in Part II, Sec-tion J of NUREG-0654, Revision 1,-(November 1980) pp. 59-65.
' INTERROGATORY.NO. 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 in-quired about in (a) or-(b) above.
Please tell for each the matter (s) it relates.to.
ANSWER: ~ (a)
As has been stated in the answer to Inter-1rogatory 30-2(a), Ninth Set,;with respect to 30-1(h), an esti-mated 5000 bottles-of state-purchased potassium iodide tablets'
~
~
are being reserved for use during an.. emergency at the Harris Plaht;
-(b) (i)
At present, an estimated 6000-bottles of state-purchased potassium iodide tables are available_for use during an emergency at the Brunswick Plant.
(ii)
At present, an estimat'ed 9000_ bottles of state-purchase'd potassium iodide tablets are available for use during an emergency at the McGuire. Plant.
The plans for the' storage, distribution, and use of potas-
- sium-iodide tablets for the Harris, Brunswick, _and McGuire Plants are essentially the same.
_(c)
The plans for the storage, distribution, and _ use lif potassium iodide are refle.cted in the offsite plans for the -
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~
- 1. c Brunswick and McGuire plants.
Working documentation of the North Carolina Division of Health Services contains specific information about the locations.and quantities of KI supplies, and the names and phone numbers of people with access to those supplies,' pertaining to the Brunswick and McGuire nuclear plants.
INTERROGATORIES ON EDDLEMAN 224 INTERROGATORY NO. 224-3(a):
Were the analyses in ER_sec-tion 2.3.1 (or FSAR sections 2.3.1 or 2.3.2) made specifically for adverse weather in the Harris EPZ?
-(b)
Which of the items in your response to 224-1-b(aa) thru-(hh) were made for the Harris EPZ?
(c)
What information do you' possess that indicates that the FSAR adverse weather frequencies-(i) are (ii) may not be
-(iii):are not representative of the frequencies of such weather in the Harris EPZ?
Please identify all documents and all rea-
. sons concerning your answers to (i), (ii) or (iii) or un-derlying such answers.
(d)
Does the State or the County emergency planners pos-sess any information on the frequency of adverse weather condi-tions in the Harris EPZ (i) different from (ii) in addition'to, that in the Harris FSAR and ER as shown in the responses to interrogatory 224-1(a), (b) and.(c)?
(e)
If so, please' identify all information, and all docu-ments containing information, responsive to (d)(1) or (d)(ii) above.
ANSWER:
(a)
The analyses in ER'Section 2.3.1 (or FSAR Sections 2.3.1 or 2.3.2)- were made specifically for the SENPP
' Plant, which is within the Harris EPZ, and were based upon me-teorological information from the closest available source of data required to complete that particular analysis.
Although
-some of the input data used in the various analyses was based _.
a upon' sources offinformation which are outside of the 10-mile Harris EPZ, it is representative of Harris plant site condi-~
tions and is'the best available information.
-(b)
See' response to (a) above.
(c)
Carolina Power & Light has included within ER Sec-tions 2.'3.3, 2.3.4, 2.3.5, and 2.3.6 and FSAR Section 2.3.3 the on-site meterological-data collected from the site.
The shorter period of record from the on-site data when compared to surrounding longer term sources of meteorological data shows no
-climactically significant variations.
Thus the adverse weather frequencies presente'd in the ER and FSAR are judged to be rep-
-resentative of-the frequencies of such weather in the Harris EPZ.
(d)
(e) -Respondents are not aware of any information which state or county emergency planners possess concerning the frequency of adverse weather specifically in the Shearun Harris EPZ, other than that previously i 'entified in the response to Interrogatory No. 224-1.
INTERROGATORY NO. 224-4(a):
Is it true (compare your an-swers to 224-2) that the Harris evacuation time estimates only consider adverse weather with respect to heavy rains?
(b)
. hat other adverse weather scenarios were considered, W
when heavy rains was selected as the adverse weather scenario for the evacuation time estimates (ETEs)?
Please identify all documents concerning these scenarios, who prepared them, how the selection was made, who made it, and why.
(c)
Who were the state,- and the local, emergency pre-paredness officials who had discussions on which adverse weath-er scenario (s) to use in the Harris ETE?
. 1 l
l
(d) -What does each such official recall concerning those discussions?
(e)
What does.each CP&L or HMM participant recall con-cerning.those discussions?
(Your-answers to (d) and (e) should include, if known, the date(s), length of time, and nature of the discussions, the information reviewed or referenced in the discussions, what positions if any were taken by the persons _
involved in the discussions, and any documents concerning such discussions should be~ identified, be it notes, handwritten notes,' minutes, memoranda, tape recordings, or other records of any kind).
ANSWER:
(a).The adverse weather evacuation time esti-mates presented in the ETE represent a heavy or severe rain-storm condition, resulting in a 25 percent reduction in roadway capacity and travel speeds.
This is the only adverse weather condition evaluated in the evacuation time estimate report.
However, this adverse weather scenario is generally representa-tive of conditions wh'ere visibility is impaired, roadway capacities reduced, and normal traffic operations impeded, com-pared.to the fair weather conditions.
(b)
Consideration was given to all adverse weather condi-tions which-occur within the Shearon Harris EPZ.
This included rain, fog, flooding and high winds.
Informal discussions be-tween HMM Associates, CP&L and state and county emergency pre-paredness officials and a review of weather frequency and se-verity data presented in the Shearon Harris FSAR led to the selection of a heavy rain' storm condition as that most appro-priate for the evacuation time estimate study.
~(c)
Mr. James Self, North Carolina Division of Emergency Management; e __
t;--
Mr. Mark Scott, Chatham County. Civil Preparedness Agency; Mr.. Carl.Lucas, Harnett County Emergency Management Agen-
[
~
cy; Mr. Billy' Ray-Cameron, Sanford-Lee County Department of Emergency Management; and Mr. J.-Russell'Capps, Wake" County Emergency Management Agency.
(d)
The identified individuals have reviewed and con-l,
. curred with the ETE study.
Applicants do not know what these officials recall _concerning discussions held during the course
~
of the evacuation time estimate study.
(e)
The. discussions with the state and~ county emergency
~
preparedness officials were informal in nature and no minutes were kept.
The discussions focused on identifying an adverse weather condition-which, in the opinion of the' emergency pre-
- paredness officials, would provide a useful frame of-reference
-for' emergency preparedness decision-making.
~ INTERROGATORY NO. 224-S(a):
Is it possible, in your view, that evacuation times under adverse weather conditions other than heavy rain could be (i) greater (ii) lesser, than those for the heavy rain. scenario?
(b)'.Please identify _all adverse weather
- scenarios for which you believe the Harris evacuation times would be (i) greater-(ii) lesser'(iii) about the same as (give range of un-certainty, e.g. Within 5 minutes),
.s the evacuation time esti-a mates for heavy-rains.
(c)
Please identify all'information you possess concern-ing (i) roadway capacity-(ii) travel speeds (iii) accident fre-quency (iv) weather-related complications, due to adverse weather conditions including (aa) thru.(hh) of interrogatory 224-1(b).. Note.that item (ee) of that list is " heavy rain" as used.in the ETE.-,
(d).
Please identify any information you have concerning the effect of fog, ice, snow, rain, heavy rain, hail, tornados, freezing rain, ice storms, or other adverse weather on (i) vis-ibility (ii) travel speeds.(iii) ability of people to control vehicles or avoid accidents, under conditions such as docu-mented for the Harris EPZ as having occurred or being possible (e.g. as documented in the FSAR or ER), particularly on winding, two-lane roads with slopes and/or curves like those in
'the Harris EPZ.
Please identify all documents containi'ng such information, and all. documents re this in possession, e.g.
of the state Dept of Transportation, Highway Patrol, etc. also.
ANSWER:
(a)
It is.certainly possible that evacuation times under adverse weather conditions other than heavy rain could be greater or lesser than those develope'd for the ETE heavy rain adverse weather scenario.
As a worst case, evacua-tion during a severe hurricane or tornado condition could take substantially longer than the scenarios modelled in the ETE.
On the other hand, a light " misty" rain would likely result in conditions not significantly different than those during fair-weather.
The-ETE study presented representative evacuation times for fair:and adverse weather conditions which could be used as a guide and as input in the emergency response decision-making process.
Obviously, evacuation times were not developed for every conceivable fair and adverse weather scenario, nor is such required by Appendix 4 of NUREG-0654, Rev.
1.
The se-lected adverse weather scenario represents a condition which is severe enough and occurs often enough to provide a reasonable frame of reference for protective action decision-making during adverse weather conditions.
e.
w
-(b)
See response to (a) above.
Applicants have no rea-
~
.sonable means of identifying all adverse weather scenarios which are (i) greater or (ii) lesser than the heavy rainstorm condition used in~the ETE, since the ETE adverse weather condi-tion is representative in terms: of its effect on roadway capacities and speeds-during the course of the evacuation.
Due to thefnumerous variables involved in adverse weather condi-
-tions (such as wind speed,. rate ~of precipitation, visibility, and-temperature) it is only reasonable to assess adverse weath-er in.such'a representative nature.
(c)
(d)
Empirical data on the effects of adverse weath-er on roadway capacities and travel speeds is limited, and a survey of state agencies has not been undertaken.
- However, 1,iterature searches conducted by HMM Associates have resulted in the identification of:three references presenting data on the impact of rain on roadway operations.
These sources are:
The Environmental Influence of Rain on Freeway
- Capacity, E. Roy Jones and Merrell.E. Goolsby,
-Highway Research Record, No. 321, Highway Re-search Board, 1970.
Headway Approach to Intersection Capacity, Donald.S. Berry and P.K. Gandhi, Highway Re-search Record No. 453, Highway Research Board, 1973.
Interim Materials on Highway Capacity, Transpor-tation'Research Circular-No. 212, Transportation Research Board,-January 1980. i
4 l
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-These references ~ cite empirical. data which focus on the frdiationship between~ adverse weather (rain)nand roadway capacitiesLandfassociated operations.
Specifically, the avail--
able data deal-with the effects which impaired operations-and
- visibility?due'to rain conditions have on traffic flow.
Appli-icants are.notxaware of specific empirical data which present
- similarHeffects due-to hail, tornadoes, freezing rain, ice storms-or snow storms.
One additional reference presents data on an actual evacu-ation near a nuclear power. plant facility, which was conducted during heavy rains'and fog.
The study Detailed Report on the o
~ Evacuation of December 11, 1982'(prepared by Envirosphere Com-
-pany for Louisiana Power and Light Company, December 1983) in-dicates, at page 43, that despite the adverse weather ~condi-e
-tions:present'at the time of the evacuation, traffic moved smoothly with very-few' traffic back-ups or accidents.
INTERROGATORIES ON EDDLEMnN 215
. INTERROGATORY'NO. 215-10(a):
Do the State,.or County
-emergency planners,_have or have access to any information con-cerningo the number of : persons.(or percent of population) in the Harris:EPZ-that'is at-home at various times of the day or year-
- (i) with'. transportation (ii) without transportation (iii) with--
out regard'tolwhether they have transportation, just that they
- are : home?.
l
.(b) -Does-the State, or county emergency planning person-neli have any-plans to analyze either the questionc asked in 1215-10(a),above, or that asked _in 215-2(a)?
u ANSWER:
(a)
(b)
Respondents presently have no such
~
y
-e information concerning the. percentage of the population with or
_ )
Without. transportation that is home at various times of the day
.and year.
Respondents are-not aware of any present plans to analyze such variability.
INTERROGATORY NO. 215-11(a):
In concurring wit.h the evac-uation time estimates made for CP&L by HMM associates, what did the state and county. emergency planners do to analyze (i) the accuracy-(ii).the degree of conservatism, of those estimates?
'Please answer.specifically what you did to review those time estimates and exactly how you determined-that you concurred with them.
If you do not now concur.with the estimates, please give.all reasons for your non-concurrence.
.(b)
Have you made any analysis of how accurate the one-family-per-vehicle assumption is for the Harris EPZ (i) under any--conditions (ii) under the specific condition that people are asked to help evacuate persons without transportation (iii) at-night,'e.g. during normal sleeping-hours (iv) in conditions e
of. snow, ice, or ice storms or freezing rain?
Please identify all documents concerning each such analysis and succinctly state -your. - analysis.
ANSWER:
(a)
State and county emergency preparedness of-ficials were involved with, and provided key input to the evac-uation time estimate study.
Many of the variables which must be^ considered in such a study (such as reasonable preparation and mobilization. times and evacuation procedures)'are' site-s specific or area-specific, and were in this case appropriately.
2identified by local personnel who are responsible on a day-to-
' day basis for planning for such activities.
In addition tp providing key input to the study and re-viewing the assumptions.to be used,- the state and county emer-gency preparedness officials also~ reviewed a draft of the evac-uation study.
In concurring with the evacuation time estimate
. report,'these officials have indicated that based upon their..
[:sf _ 3 i:
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! knowledge-of the area,Jfederal-guidance (i.e., NUREG-0654, Rev.
1)'.and the evacuation process in general',.the ETE provides.a
' reasonable basisifor protective action decision-making for a spotential incident at the Shearon. Harris plant.
L
.(b);: Applicants haveLnot made any: specific analysis to
-test,the? accuracy-of the assumption that one_ vehicle would evacuate-from each permanent resident household.
The ETE meth-Lodology;used. documented assumptions or vehicle occupancy and anticipated evacuati~on characteristics associated with each
^
11ndividual' population c'ategory1(i.e., permanent residents, tran'ients and special facilities).
For permanent residents, a
it was assumed that1one vehicle would evacuate from each house-hold after notification and preparation for evacuation.
This assumption was used and is considered valid for all conditions inclAding evacuation during day or night periods, and;evacua-ition during fair or-adverse weather conditions.
INTERROGATORY NO. 215-12(a):
Is all'the documentation
.concerning.the assumptions of the ETE're (1): vehicle-occupancy
- (ii)_ anticipated. evacuation characteristics.(compare your an-swer--to 215-3(c)) fully referenced or documented.'in the ETE re-Eport'byLHMM associates?. For any that are_not, please give full references and identify all' documents in which these assump-
.tions_are= documented.
- (b). Are;you; aware of any1information' disputing the valid-Lity:of theselassumptions, or/any of them?
Please identify.all documents you are aware of in which any'of these assumptions
_(please specify:which)_.is-disputed or. questioned.
("these as-
- sumptions" are the onesLin the HMM ETE report concerning vehi-
- cle occupancy and evacuation characteristics associated with each invididual population category)
(c). What " federal. guidance" do you say is consistent with your one: vehicle per household' assumption?
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.(d)' Are.y$u saying the federal guidance requires such an assumption?
If,so, please -identify what guidance you maintain
. requires lit.
kN) LAre;other assumptions about the numbers of vehicles percevacuating household also consistent, in your. view, with
' federal ~ guidance applicable.to ETEs?
i ANSWER:
. ( a)' Thefdocumentation on assumptions'used in the
)
. evacuation time estimate study concerning (i) veh'icle occupancy
.and'(ii) anticipated evacuation characteristics are presented in Section 3 and 6 (refer to;the vehicle.. occupancy summary
~
presented in Table 3-7, and discussions presented in sub-sections 3.1, 3.2, 3.3, and 6.2 of the ETE study) of the evacuation time estimate study.
(b) l Applicants are not aware of any empirical data or other related info,rmation disputing the validity of the assump-tions on vehicle occupancy and evacuation characteristics asso-
.ciated with eadh population category presented in the HMM ETE
-report.
,(c).NUREG-0654, Rev.
1, at 4-3 states:
/
-The number of vehicles used by perma-j nentMresidents is estimated using an appro-priate' auto occupancy factor.
A range of two to three persons per vehicle would probably be reasonable in most cases.
An alternative approach is to calculate the number of vehicles based on the number of households that own vehicles assuming one vehicle per household is used in evacua-tion.
i
.I In addition,' NUREG/CR-1745 (Analysis of Techniques for f
Estimating Evacuation Times ~for Emergency Planning Zones, U.S.
URC, November 1980),'at 21, indicates'that:
/
~
This population data [ permanent resi-dents] would then be translated into a projected number of' vehicles using an appropriate auto occupancy factor.
A range of 2 to 3 persons per vehicle would probably be reasonable in most cases, however, any_ rational basis would be' appropriate.
For example, one vehicle per household might be a reasonable assumption.
(d)
Federal guidance does not, in fact, require such an as sumption'.
It does, however, present this methodology as a reasonable basis for estimating vehicle demand associated with the permanent resident population category.
(e)
Yes, use of a vehicle occupancy in the range of 2-3 persons-per vehicle would also~be consistent with federal guid-
=ance.
It is worth noting that the average household size with-in the EPZ is 2.7 persons per household.
Accordingly, one ve-hicle per household translates to approximately 2.7 persons per
~
vehicle, which is in the range of that considered reasonable in NUREG-0654, Rev. 1 and NUREG/CR-1745.
INTERROGATORY NO. 215-13 (refer to your answers to 215-4):
(a)'Do you have any information or studies which support your assumptions concerning evacuation behavior of persons as stated in your answer to 215-4(a)?
Please identify all documents containing such information or studies.
(b)' Is there any inconsistency between your answer to 215-4(a) and your response to 215-3(c) appearing immediately above the answer to 215-4(a), which refers to " empirical data on past-evacuations, indicating the tendency of family units to unite and evacuate as a unit", particularly as regards evacua-tion from recreational facilities, workplaces, or special fa-cilities?
Please explain how or why these answers are (1) con-sistent1(ii) inconsistent.
(P] lease also identify all
. documents concerning empirical data from past evacuations, specifying which were evacuations from around nuclear plants due to nuclear accidents.
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(c)
.P, lease detail the -review of the assumptions in re-sponses to interrogatories of the past (215-1 thru 9, all parts
.and subparts)Lwhich were made (or was made) by state and local
. emergency preparedness officials (.=ee response to 215-4(a)).
Specifically, which officials reviewed these assumptions, when
.did they do it, are there any documents related to their review (including-hotes-or recordingr _ etc) (please identify all such
' documentation), and what was the specific result of their re-
- view as~to each assumption, most particularly re (i) one vehi-cle per household (ii) evacuation directly from work, school, care facilfties, and workplaces (iii) evacuation from recre-ation' facilities (e.g. would these people go home to check their
- families first if their families live in the EPZ) (iv) vehicle occupancy rates, (v) mudoer of persons to be evacuated who.do not own cars (vi) furnishing of rides by neighbors dur-ing an evacuation (vii) furnishing of rides to persons without transportation due to coordinated efforts by state and county
-emergency preparedness' officials; (viii) one vehicle per house-
-hold for the non-auto-owning population; (ix) that vehicle de-partures from households would be distributed over a two-hour period.
(d)
Was any evaluation made by state or county emergency preparedness officials of CP&L's'" demographic data report"s
[ sic]? -If so, who made it, when, and with what results?
Did the State rely on these reports in evacuation planning?
Have the reports.been check by anyone?
If so, with what results?
Did the counties rely-on these reports in evacuation planning?
ANSWER:
(a)
Applicants are not aware of empirical data or-studies which indicate exactly where all persons evacuating would begin the evacuation.
The evacuation assumptions of the various population components used in the ETELrepresent the basis for simulation of realistic evacuation traffic flow con-ditions.
The methodology used to develop the total population and vehicle demand estimates within the Shearon Harris EPZ does incorporate some double-counting.
For example, it is reason-able to assume that a portion of the identified employees with-in the area and visitors to recreational areas are also perma-nent residents of the EPZ.
In addition, school children, +
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. treated as an independent special facility category, are also included in-the permanent population estimates.
This
' double-counting of population, however, is done intentionally bo implicitly simulate. realistic traffic flows on the roadway network.
That is, the method 61ogy.does over-estimate total population'somewhat, but more accurately reflects realistic ve-hicleEactivity on.the evacuation roadway network (e.g., vehi-cles'will be evacuating major recreation areas, whether they are destined to home's within the EPZ, or directly outside of-the EPZ; and during-work periods employees will be departing from their place of employment, destined either home within the EPZ, or directly outside of the EPZ).
(b),From the standpoint of traffic flow, the assumption that-the permanent population will evacuate-from their place of residence is not inconsistent with additional assumptions in
~
the ETE that:
Persons visiting major recreation areas will evacuate
~
from:those areas; Persons at major places of employment will evacuate from those places; and Persons in special facilities will evacuate from those facilities.
.The methodology used for the ETE study results in the most realistic-representation of anticipated' traffic flows from
~
places of-residences, work places and major recreation areas. -
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~
. Applicants are aware'of empirical data from past evacua-tions, documented'inithe following sources:
Reference 1:
Evacuation Planning in the TMI Accident, Federal Emergency Management Agency, RS~
2-8-34,. January 1980.
Reference 2:
Mississauga Evacuates: A Report on the Closing of Canada's Ninth Largest City, NUS Corpora-tion,-[ Proprietary) 1980'.
Reference 3: ' Texas Hurricane Evacuation Study, Texas Transportation Institute, September 1978.
Reference 4:
Evacuation Risks - An Evaluation, U.S.
-EPA,.Hans and Sell, EPA-520/6-74-002, June 1974.
Reference 5:
Evacuation Planning in Emergency
= Management, Perry, Lindell, Greene, 1981.
~
Reference'6:
Detailed Report on the Evacuation of a
December 11, 1982, Envirosphere Company, December
.1983.
Only one-of these, Reference 1, concerned evacuation from around. nuclear. plants due to a nuclear-accident.
(c) -The various assumptions used to develop'the evacua-tion time estimates presented in the ETE were developed based uponf(1) informal discussions held with state-and. county.emer-gency preparedness officials-(refer to response to-Interroga-
- 1. tory 224-4(c)),throughout the course of the study;-(2) reviews, by HMM Associates, of empirical data on past evacuations; (3) knowle'dge and experience obtained by HMM Associates in 5
?
4
.v..
m' Econducting ~similar. evacuation time ~estimateLstudies:for 22 nu--
clear. power. plan't sites throughout the country, and (4) federal'
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qu'idance.(NUREG-0654, Rev. 1).
~
.Theidiscussions~ held with the state.and county emergency preparednesscofficials'were informal in nature.
No. minutes or 1 transcripts were-kept.
-Assumptions used in'the study,
' including' vehicle occupancy,: evacuation procedures, and prepa-
. ration and mobili~zation.~ times,.were reviewed with the officials cited infre'sponse to Interrogatory 224-4 and are presented in
~the ETE.
TheLofficials concurred in.the assumptions.
(d) LState and county emergency preparedness officials.did1 enos specifically~ review " Demographic Data for the Shearon
. Harris: Nuclear Power: Plant (SHNPP): Evacuation Time Estimate Re-port" ~(R$ visions;O or_'1)'.
However, CP&L demographic' data,'rel-
~
the= preparation of the evacuation time' estimates, were-1evant tx) copied from Revision'1-and incorporated in the:ETE. _The ETE,.
. including some of CP&L's demographicLdata, was reviewed:by
' state.and: county eme'rgency_ preparedness officials.
Concurrence
' statements-are found in-Section llof.the'ETE.
The; State used the'ETE, which included CF&L demographic
' data:from Revision 1.
.?.
The CP&L demographic report, Revision 0, was reviewed by.
OHMM - Associates and CPrL personnel 1and resultc ' 'in.the revisions
' $ indicated by :',' revision -bars" in the right hand margin of Revi-y r3. ',
- sion 1.
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.g.
Review'of; Revision 1 by CP&L indicates that data on page 21for hunting are' incorrect.
Correct data are indicated on page 68lof Appendix A.
Additionally, recreational activity at
. Harris Reservoir appears to be higher than originally estimat-ed.
A creel' survey is being' conducted during 1984 and will en-able refinement of the numbers.
INTERROGATORY NO. 215-14(a):
Do you have any vehicle oc-cupancy rate data for' evacuations (i) that actually occurred (ii) that were estimated for other nuclear plants in NC?
Please identify all-documents containing such data.
(b)
Do you have any data'on how many vehicles are regis-tered to each household in the Harris EPZ?
On the capacity of vehicles registered in the EPZ (e.g. pickup trucks, 4-person, 5-person or 6-person cars)?
Please identify all documents containing such data.
~
l(c)
Do you have any data on the number of persons in households w/o transportation within the Harris EPZ?
Please identify'all documents containing such data.
(d)
Do you have any documentation of the basis for previ-ously developed ' evacuation plan standards' estimates of likeli-hood that evacuees will use the "best available" automobile when evacuating? _Do you have'any information on use of more than one vehicle by evacuating ~ families or groups?
Please identify-all documents containing such information.
-(e)
What is your exact basis for believing that "more than sufficient capacity.will be available to accomodate per-sons'in households without transportation?
Please identify all documents, analysis or calculations-you believe show this is true~.
(f) -How long will it take to get the non-auto-owning pop-ulation into vehicles for evacuation?
Please identify all documents and information concerning how long this would take.
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(g)
Precisely who " accepts" the traffic flow relation-ships used in NETVAC?
Has METVAC been independently evaluated re these_ relationships?
Please' identify all documents concern-ing these matters.
5 (h)
Are the traffic activities on each roadway segment, for each reporting interval, available in the ETEs?
If not,
-please identify all documents containing this information. -.
1(j)
Please explain how the number of persons beginning to evacuate in_each time interval is evaluated in NETVAC, or how it01s determined.
(k) ~Please explain whether any counterflow traffic (e.g.
families uniting)Lis assumed in the Harris ETEs?
If not, why
.not?
(1)
[W] hat is the sensitivity of the Harris ETEs to (i) preparation times (ii) mobilization times?
Please identify any documents re these matters.
. ANSWER:
(a)
Applicants are aware of only one source indicating ~ vehicle occupancy data for actual past evacuations.
The Manual of-Protection Action Guides and Protective Actions for Nuclear Incidents (U.S. EPA, EPA-520/1-75-001, Revised February 1980) indicates that " surveys during evacuation found (4/ persons / car on the avarage"'(at 1.33).
(b)
Applicants' information on vehicle registration by vehicle type-within the Shearon Harris EPZ is limited to calcu-
' lated estimates by subzone and standard nuclear display unit for "1982 registered automobiles and small trucks."
(See CP&L Demographic Data Report, revision 1, pages 28-29; and Appendix A pages 35-40, page 42.)
Corresponding estimates of the number of~ houses by.subzone and standard nuclear display unit are in-cluded in the.same report.
(See Appendix A, pages 16-21.)
Av-erage number of 1982 registered automobiles and small trucks for each house (residence).can be estimateu from these data.
Applicants are not aware of'any other data available on numbers of vehicles registered to each household in the EPZ or of data on the capacity of such vehicles.
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-(c)) See?section 3.1.2 of the ETE.
This section describes
- the number of non-auto-owning residents in the EPZ.
Sources of
. data are' included.
-(db.The' planning standard that. evacuees are likely to utilize ~the 'ibest ava'ilable" automobile when evacuating is out-111ned~1n2the following documents:
-=
Impacts of the' Crisis Relocation Strategy on
- Transportation (Systems, Volume II, Planning I
~ Guidelines, Department of Defense, Defense Civil Pre-paredness Agency, Doc. No. CPG-2-8-13, March 1977, at II-11.
Post Attack Impacts of the Crisis Relocation-Strategy on Transportation Systems, Volume =II, Revised Plan-ning Guidelines, Department of Defense, Defense Civil Preparedness' Agency, Doc..No. RS-2-8-24, March 1979, at II-11.
Applicants.are not aware of any information on the use of more than one vehicle by. evacuating families or groups.
(e)
Given the number of households within the EPZ that own vehicles (an estimated 6,937 households out of a total of.
-7,347 households within the EPZ, refer to previous response to
" Interrogatory No. 215-5(c)) and the average number of persons Lper household-(2.7 persons per household - refer to previous
. response to Interrogatory'No. 215-5(c)), there is adequate basis-to believe the.more than sufficient capacity (i.e., car-ryingLeapacity) would be available to accommodate persons in
~~
1 households without transportation (an estimated 410 households in the EPZ that'do not own automobiles) through ride-sharing in vehicles with_ unoccupied seating.
(f)
It is: reasonable to= assume that it would take varying amounts of time to " pick-up" the non-auto-owning population in vehicles for evacuation.
The assumptions documented in the ETE provide'for a period of-up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following notification for these activities.
(g)
The traffic-flow relationship and algorithms used in the NETVAC:model are. based upon empirical data, criteria and standards presented _in the publications:
Highway Capacity' Manual, Highway Research Board, Spe-cial Report 87,,
1965.
Interim Materials.on Highway Capacity, Transportation Research-Circular 212, Transportation Research Board, January 1980.
The-NETVAC model has been evaluated independently by NRC/ FEMA in its use at 19 nuclear power plant sites throughout the country.
All.of these evaluations conducted to date have been accepted by the NRC/ FEMA reviewers.
.(h)
The traffic activities along each roadway section of the. evacuation netwcrk for each reporting interval are not presented in the ETE since, (1) such decumentation is not re-quired, and (2) the significant amcunt of print-out material is not easily reproduced..
~
-(j)
The number of' persons beginning to evacuate at dif-
-ferent time intervals is based, to a large degree, on the as-sumed, preparation and mobilization times associated with the Evarious population. components.
Section 6 of the ETE documents these preparation and mobilization departure distributions.
(k). The methodology used in the Shearon Harris ETE study did not specifically consider counter flow traffic.
Such in-teraction, which would be' expected, was however taken into ac-count by evaluating vehicle origins.at (1) places of resi-dences, (2) major work places, (3) major recreation areas, and L(4r) at special facilities.
Such an analysis provides a realis-tic assessment of the effects and consequences of such counter
- flow interaction.
See response to 215-13(a) above.
(1)
The methodology used in the Shearon Harris ETE study
-ccmbines the times associated with preparation and mobilization events into a singular time distribution for eachlof the 9,.
'p~opulation categories.
The estimated evacuation times presented-in the ETE indicate that, for most evacuation scenar-ios considered, the evacuation times are very sensitive to the preparation'and~ mobilization times.
Dated:
September 7, 1984.
Respectfully submitted, ebt
- 4k Thoma!s A. Baiter, FR C. (
3 Delissa A. Ridgway Shaw, Pittman, Fotts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Richard E.
Jones Samantha Francis Flynn Dale E. Hollar Carolina Power & Light Company Post Office Box 1551 Raleigh,' North Carolina 27602 (916) 836-6517 Attorneys for Applicants A
UNITED STATES OF AMERICA 4
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)
)
CERTIFICATE OF SERVICE I-hereby certify that copies of " Applicants' Response To Wells Eddleman's General Interrogatories To Applicants (10th Set)" were served this 7th day of September, 1984, by deposit "in'the U.S. mail, first class, postage prepaid, upon the par-t'es listed on the attached Service List.
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n'EA.
>l 812 DAlissa A. RiBgway'
()
J Date:
September 7, 1984 h
l
r M
l i
UNITED STATES OF AMERICA;
- NUCLEAR REGULATORY COMMISSION TBEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
"In--the. Matter of
)
)
cCAROLINA POWER & LIGHT COMPANY ~
)-
andLNORTH. CAROLINA EASTERN-
)
Docket No. 50-400 OL
.MUNICIPALLPOWER AGENCY.
.)
)
(Shearon' Harris Nuclear Power
)-
Plant) '
)
SERVICE LIST James ~L'.;Kelley, Esquire John D. Runkle, Esquire
-Atomic Safety land Licensing Board Conservation Council of
-U.S.
Nuclear' Regulatory Commission North Carolina Washington, D.C.
20555 307 Granville Road Mr. Glenn O. Bright ~
Chapel Hill, North. Carolina 27514 Atomic Safety and Licensing Board M. Travis Payne, Esquire U. S. - N u c l e a r R e g u-l a t o r y C o m m i s s i o n Edelstein and Payne Washington, D.C.
20555 Post Office Box 12607 Raleigh, North Carolina '27605 Dr. James H. Carpenter
=
LAtomic Safety and Licensing Board Dr. Richard D. Wilson U.S. Nuclear ~RegulatoryLCommission.
729 Hunter Street
. Washington,.D.C.
20555 Apex, North Carolina 27502~
Charles A.nBarth,JEsquire-Mr.. Wells Eddleman Janice E. Moore, Esquire Durham, North Carolina 27705 718-A Iredell Street Office of Executive Legal Director-LU.S. Nuclear Regulatory Commission Washington, D.C.
20555
. Richard E. Jones, Esquire Vice President and Senior Counsel Docketing'and Service Section Carolina Power & Light Company
- Office of the' Secretary' Post Office Box 1551 U.S.' Nuclear Regulatory Commission Raleigh, North. Carolina 27602 Washington,.D.C.
2055S Mr. Daniel F.~ Read, President
< CHANGE
' Post, Office-Box 2151 Raleigh,. North ~ Carolina 27602
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.Dr. Linda'W. Littile Governor's Waste Management Board
-513 Albemarle-Building
'L325 North: Salisbury Street 1
Raleigh,1NorthrCarolina' 27611' Bradley W. Jones,.-Esquire LU.S. Nuclear. Regulatory Commissin
, Region II' x10lLMarietta-Street
-Atlanta'1 Georgia L30303 Steven FW Crockett, Esquire iAtomicfSafety and.
Licensing Board Panel U.S.' Nuclear Regulatory Commission
~ Washington, D.C.
20555 Mr. Robert'P. Gruber Executive Director
'Public Staff'- NCUC LPost Office Box 991 Raleigh, North Carolina -27602
+
Administrative Judge. Harry Foreman
? Box -395 Mayo
- University of Minnesota Minneapolis, Minnesota 55455 Spence W. Perry, Esquire Associate General Counsel FEMA
.500 C: Street, S.W.,. Suite 480 LWashington, D.C.
20740 l