ML20096H465
| ML20096H465 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/07/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8409110416 | |
| Download: ML20096H465 (19) | |
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RELATEC C1ECM:i;QCE, DOCKE -
USNR UNITED STATES OF AMERICA September 7, 198h NUCLEAR REGULATOBY COMMISSION '84 SEP 11 NO 21 GVTCE C~ 55 '
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BEPORE THE ATOMIC SAFETY AND LICENSING BOARD
~
Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
~ Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al. )
ar Harris Nuclear Power Plant,
) ASLBP No. 82-h66-01
) OL Wells Eddlenan's Response to Apolicants' 8-09-84 Emr gency D1anning Interrogatories RESPONSES TO GENE 9AL INTERROGATORIES G-1(a) Paul Holmbeck,1300 Green St. , Durhan NC 27705 provided analysis of the Harris offsite ERP on which contentions 215 and 224 are based. I do not specifically recall whether Holnbeck contributed any analysis to other contentions filed in 1984 which I composed.
(b) see tne contentions. (c) As stated in the contentions.
2(a) and (b) OBJECTION incornorating nast objections to th$ s intorrogatory, 3-21-83 and following.
3(a) None identified so far. (b)(c) see (a).
h(a) NUREG-0654; Harris offsite energency response olan; other docunents cited in contentions; no other docunents identified, though there may have been some.10 CFR 50 47 and annendix E thereto.
5(a)(b) See snecific responses.
- 6. See objection to 2 above. See snecific resnonses 7(a)(b) none identified yet. t RESPONSFS TO SDECIFIC INTERROGATORIES
- 30-1(n) Not possible to give a fully connlete list -- evaluation Eg is continuing; however: Emergency response personnel, inmobilized
.o persons, the handicanned, the hospitalized, persons under the 7 influence of drugs (including alcohol) which nreclude their being able to drive, or oreclude rational thinking, or keep then asleen (b) nunbers not yet determined; sone grouns, like those under
$ the influence of drugs with effects nentioned in answer to (a) above
.g e may vary in numbers substantially with time.
(c) see (b)
(d) the numboe would have to be (with allowance for shelf life, dam 1ge (e.g. in an earthquake which could cause an accident at the Harris nuclear olant) and losses , sufficient to provide KI at levels adeouate to block absorption of radioiodnines during the longest nossible Harris release (which would orobabl be above 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> (I'm en 1 ofthedocumentonreleasetknessince}.tssourceisnok9sideEihiehy e for all persons for wnonn evacuation may be infeasible or very difficult with an allowance for margin (reserves of KI doses ). _ ,_ _ 3501
-g-addition to (a): pe'rsons trann'ed in wreckage (e.g. of houses or buildings af ter a' tornado which could caqse a nuclear accident (LOOP etc) at tne Harris nuclear plant; Schoolchildren who could not be evacuated.
(e) the number of doses must obviously be enough to Five everybody for whom " evacuation may be infeasible or very difficult". KI.
A reserve margin is just connon-sense nrudence. Allowance fo9 shelf life $s necessary so that anough effective doses will be ava$1able.
Allowance for damage is necessary to assure enough dosec are usable.
Allowance for losses is necessary to assure enough doses are delivered and administered. Analysis of the anount of each such allowance and margin is currently not conolete.
30-2. You have asked what is necessary "to neet your concern".
This would mean (1) providing sufficient KI doses as described in resnonse to 30-1 above with adequate allowances and nargins; (2) assuring enough nersonnel to deliver it (3) obtaining nrior informed consent for the adninistration of KI fron every identifiable nerson who may need it, especially the handicanned, innobilized persons, emergency resnonse personnel, and any others whose evacuation may be infeasible or very difficult,that can be identified in advance, since KI has side effects and risks itself; (4) assuring the means of delivering the KI to each such person whose evacuation may be infeasible or very difficult, in a tinely manner (i.e. before radio-4o I (3) dines storagefronthe of KI Harris olantfron at nlaces can which _ ting be pepts to such nronnt nergons)ly" (i.e. tine as described in (h) above) delivery is assured. The basis for such changes is sinnly that without planning to take care of all these things, effective and timely adninistration of KI to those who cannot be evacuated, or for whom evacuation is very difficult, is not assured. Further info gathering will continue re this.
30-3 Cancellation or not pperating the Harris nlant would take care of the uroblem. Whether the changes listed in resnonse to 30-2 above are made in the clant or not, they need to be made if the Harris nuclear niant is going to onerate, to ensure that KI will be available when needed to those who will need it.
Further info gathering re this will continue.
57-C-3-1(a) lo CF9 50 47(a)(1),(b) (see fn 1, FUBEG-065k),(b)($ 1),
(b)( .6), F"MA h3; there are certainly other "nublications" which apply, but I can't get a connlete list yet. GAO PCED 8h-h3 of 8/1/8h, I believe annlies.
(b) I don't have all the annlicable docunents, but as far as I now know, none makes exulicit reference to tine of day or year.
Since accidents can hannen any tine, I infer that the requirement to assure that adequate protective measures will be taken annlies as much at night as in the daytime, and (since your question misstates the contention, or annears to ) as much when neonle are sleening as when they are all awake.
(c) see (b) above.
57-C-3-2(a) Probably it would fail. You can't tell for sure without testing it. I know of no accounting for time for neonle to awaken, and no tests of the ability of the systen to awaken sleeping neople. You do not specify in your question what the "A16rt and Notification System nuntained described in the offsite emevgency plants"_is. I. presume you refer to (a) pp 3h-36 of Dart 1 of the plan (ner the index) and/or the NUPEG-065h criterion F.6 on oage H-B of annex H thereto, or Annex C.
57-C-3-x2(b). The plcn never really cays cnything about the capabilities of the system other than some bald assertions about the sirenns providing notification within 15 minutes (pt. 1 p.81; Annox c ). No information about the ability of the sirens to wake people un is even referenced, Ebough nart 1 p.81 does mention that special infornation on how the public will be alerted between 12 midnight and 6 an should be made available(when the energency starts at other hours, obviously) once emergency conditions exist. No description of such alerting is in the nlan as f ar as I can see so far. The other primary notification is EBS radio and TV, but peonle who are aisleep are not generally watching radio or TV ;
police car notification, aircraf t, etc. do not have their canabilities to awaken sleening neonle addressed, not are they able to mobilize within 15 ninutes according to anything in the nlan I've located so far.
The amount of roads to be covered by sixam vehicles is not addressed directly, but the plans allow snoeds to be estimated, e.g. average of 30 moh for Wake county (pt. 5 pp 2P-25) 37 mnh average for Chatham County (hgigh variability in sneeds required to connlete routes in times assumed, 15 minutes, etc); average h2 M*1es per houzr in Harnett county, and 24 miles ner hour in Lee county, vs. 15 moh for vehicles stonping every 1/k mile to nake announcements.
(This assunption is at Pt. P p.2, pt. 3 p.20, pt. 4 p.19, pt. 5 p.20).
15 mnh seems reasonable for an average sneed for such work, due to the curting roads in the EPK2, need to accelelyte and decelerate between stops, and need to make an announcement every 1/h mile.
Ability of bu11 horns to wake pbople un is annarently not addressed in the olant -- there's-no data, no reference, not even, so far as I have found, any bald statement that the bu11 horns will be able to awaken sleeping neonle or how long it waill take to get then awake. No information on the effectiveness (in waking pecole up),
or delay time to get airborne for aircraft notification is in the plan so far as I can tell thus f ar. (ref. G. Kats, A Critique of the nronosed emergency preparedness nlan for the Shearon Harris Nuclear Power plant p.21 for vehicle sneeds and assumptions).
There doesn't seem to be anything in Section IV.D of Part 1 of the olan about how it would notify peonle who are sleening.
Obviously, if the plan doesn't assure alerting within the times specified, for neople who are asleep, then it will not work when they are asleen. This is not assurance that effective protective actions "can and will be taken" 50.47(a)$1), that ' notification orovides " provisions ... for uronnt communication . . . to the nublic" because you can't communicate with a nerson who is asleep; no means are provided in the brochure about how sleening people will be notified (50 47(b)(7), cf. Plant part 1 p.81; analysis continues as to other noncomnliances. The basic one is that neonle sleening have to be awakened before communication is nossible, and without communication
~
the nlan cannot be activated in a tinely manner as reouired by the applicable rules and regulations, in such a way that effective protective action can and will be taken.
(c) See (b) above; analysis continues.
(d) see (a)(b) and (c) above. "urobably" is close enough 1 to affirmative that I've just answered as if the answer were affirmative.
57 -c-3-3 see 57-c-3-2(b) above.
57-C-3-4 Although less action is required when awakening persons and telling them to take shelter, there is still the delay of awakening, getting emergency information, and taking shelter.
Sleepy people don't generally react as fast, may be confused or drowsy, and thus will be slower to act. Effective sheltering reouires the
. building to beclosed tightly (even sealed, if possible) before the
-h-radienttivo plums goto thoro. Warnin are estimated at 1.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for *WRs (gsee timso reference for many enclosed seriousfor accidents 30-1(d))
and there is no analysis in the nlan diat I have found, of how long it will . take from warning, at a time when many emergency resnonse personnel are also asleep (the " graveyard shif t" will be awake only) to (1) get -the notification sys tem activated,-and (2) wake neople up and tell them to take shelter, and (3) assure they actually do this, and don't evacuate in a panic, as being awakened with news of a nuclear accident may reasonably produce some nanicky reactions.
Without son.a assurance that this can and will be done on a t"mely basis (and that means are available to prevent the plume from eaualizing radiation levels inside and outside typical structurens within 2 or 3 houras by ordinary air exchange with the outside, even with windows closed and heating / ventilating / air conditioninF systens off (effective sheltering means some urotection from radiation, connared to the Drotectionafforded by evacuation ), the ulan is clearly inadequate.
See also 57-C-3-2(b) above.
57-C-5(a) Possibly, for sirens, depending on the direction of the siren, which windo4(s) are onen, and the location of the sleeping person (s). Sleeping next to an open window is fairly common among folks without air conditioning around here, in my exnerience, and some who are trying to reduce high electric bills bill turn air conditioners off and onen windows on many summer nights, again fron my exnerience ads an energy consultant. However, this 4
doesn't apply at all on winter nights, when nost peonle will keep their windows closed.
(b) see (a) 57-C-3-6(a) Yes. (b) see 57-c-5-(a) above. since it is usually hotter during the day, more peonle without air conditioning will keep their windows closed daen; those with air conditioning will very likely keep their windows closed in the daytime, to keep the cooling inside and avoid even more outrageous electric bills.
57-C-3-8(a) For those who are aisleen, yes. For others, possibly. It deoends on the means used, and how close the peoole are to the. nuclear plant.
(b) The means have to be sufficient to wake peonle un if they are asleep. They have to be awakened in time to take effective protective action or get help in taking it. (50.k7 (a)$1) and (b),
NUREG-065h II.F. 3,h,5,6; 50.47(b)(5) The messages have to get to the public, and sleepers don't get the message. The actions have to be effective and in time. This can be elaborated a good bit, and an& lysis along those lines is continuing). For those not asleep, the ability to receive the messages and get E3S advice is necessary. Folks up fishing in the early norning, e.g. at h a.m.,
may km very well not have radios. Therefore the aircraft or boat notification needs to provide the same messages to then that the EBS provides.to those with radios or TVs.
57-C-3-9(a) There are several varieties of automatic phone-dialing equipment. Information is shhts available fron both manufactureras and suppliers of such equinment. I an checking ny f$les for information concerning sane.. None has been located in writing so far. However, the two basic tynes I understand are available are sequential dialer types which simply dial every possible number in an exchange (e.g. 362-000C thru 362-9999 large-in sequence and multi number o)f numbers sim,ultaneous1hle-dialers hich can call a and store Yby connuter memory)
- the busy numbers to be dialed again in the next cycle.
.-5 (b) Josso Riley informad _me that thoso cro available from Southern Bell; since the breakup of AT&T, I don't. know exactly who is marketinF this equipment.. More inquiry along these lines is needed & will hannen
" when I have more' time.
( c ) I don 't know. Further inquiry will occur. when I have time. .
Right now I'm busy with the start of school and getting ready for the mismanagement and. safety hearings.
57-C-3-10. A connlete list of all changes required isn't available .yet;
-however, see responses to 57-C-2,3, and k above. The plan needs to provids specific, provably effective means' (e.g. tone warning radios, automatic phone dialing) for versons (including transients) within the EPZ to make sure they can be awakened in time to take effective protective action in the event of a nuclear accident at the Harris plant, including very ranidly.develoning accidents. At uresent, the olan does not apnear to effectively address the nroblem of awakening people when an emergency begins during normal sleeping l
hours; it evidently only makes a passing reference to the need to inform the public of measures to alert them between midni l
'(the information and means do not anpear to be snecified)ghtwhen andan 6am ^
accident begins in non-sleeping hours (pt.1 p.81). The olan needs to address awakening persons without telenhones, esnecially in light of rapidly rising telephone rates which may reduce the number of I
persons who have telephones in their homes. Tone alert radios are :
one means to do that. As usual, the reason for the need is to be sure !
peonle are awake to receive information from EBS and/or take needed protective actions promntly (within NUPEG-065h guidelines) in the event of a nuclear accident, including ranidly develoning accidents, at Harris. Further analysis re these matters will continue when I have more time.
57-0-3-11. Besides having the right stuff in the nlan (see responses to 57-0-3-10 and referencesa responses in it, above), it has to actually be done, be tested (somewhere, not necessarily here) and uroved to work effectively within the times needed to alert people in the event of a nuclear accident within normal sleening hours. What that means is that telenhone notification (automatic), tone alert radios, and/or other ofrective means must be found, bought, installed, and properly tested, maintained and choohrd, and all this must be in place prior to the Harris nuclear plant's getting a full power license.
Alternatively, scranning the plant would take care of the problem, since if the plant doesn't operate, evacuation planning won't be needed from nuclear nower accidents at the niant. Additional analysis on 1 this question may be done when I get more time.
l t
57-C-10-1(a) List incomniete now. NUREG-0654 (I NRC and FEMA publications ) is one.10 CFR 50.47(a ) presume you mean(1) requires adequate protective measures "can and will be taken in the event of a radiological emergency"; 10 CFR 50 47(b)(9) requires adequate methods, systems 1
l and eculpment "for assessing and monitoring actual or notential offsite consequences of a radiological emergency condition" to be in use.
(b) Since the dose to neonle in shelter is one of the actual .
or notential consequences of a radiological emergency condition, without some evaluation of the urotective value of sheltering for exposure to airborne radionuclides (through inhalation or " shine" or both) must be in place (in use, in the words of 10 CFR 50.h7(b)(9)) lack of evaluation of PFs is inconsistent with dais recuirement. 10 CPR 50.47,ja)(1) requires that adequate urotective measures "can and will be taken -- sheltering effectiveness (nrotection factor) has to be reasonably <
known before' dae' adequacy of dae nrotective action (sheltering) can !
be 'known. 50 47(b)(10) seems anbiguous about whether the protective
f action guidelines have to be based on valid ir. formation, but dose j- assessment cannot properly be done widbout knowing the effect on dose that will result from sheltering (or evacuating) and connaring the two for the ponulation of the E?Z or subzones therein to determine the effective protective action 50.47(a)(1) reouires can and will be taken. NUREG-0654 mataraxin(II.J.10.m,p.64) requires inclusion in the olan of " bases for the cho.'ce of recommended nrotective actions from the plume exnosure pathway during emergency conditions. This shall
' include expected local protection afforded (fn 2. cites documents
,- which "may be considered in determining urotection afforded) in residential units or other shelter for direct and inhalation exposure. .."
, That's about as clear a requirement as I can imagine,. and the determination of " protection" in residential units or other shelter for direct and inhalation exnosure 'isn't done, and obviously needs to be done to allow informed choice of erotective actions.
If sheltering effectiveness is overestimated, or underestimated, it may lead to the wrong actions being chosen for recommec.dation th by(c)esee emergency (b) above. p response authorities.-
I am reluctant to think ddat the emergency
, planners can't read or understand NUREG-065h II.J.10.m even if they might interpret the other cited authorities differently. NU9EG-06S4 criteria are required to be met by 10 CFR 50.47(b)- (see footnote to (b) before section (b)(1)). In an accident it will be too late to determine from scratch the expected protection afforded by all shelters, residential and other. Any sensible planner would have done the determination in advance, updating it as necessary when new information that would change the determination of ikx sheltering effectiveness comes along.
(d) N/A 57-C-10-2(a). An exhaustive list has not been conniled yet.
However,- the bases in the plan have to state the sheltering effectiveness which is to be used in choosing recommended protective actions.
This has to include sheltering effectiveness for direct and inhalation exposure. Since neonle can't ston breathing during nuclear accidents (or if they did it wouldn't be effective protective action after a short time), the inhalation exuosure must be determined over time, so that i if exuosure continues while pecole are sheltered, emergency response
- personnel can estinate Wnen evacuation would result in less total i
dose than continued exnosure in shelter. Since tynical structures exchange air several times an hour (and aiv changes ner hour are
, influenced by wind sneed)with outside air, this needs to be considered in detail in determining sheltering effectiveness. Radiation exposure from nuclides outaside a shelter continues as long as the nuclides are there and peonle are in it, so that dose needs to be considered over time.
That is, shelteriqs effectiveness changes with time, as radionuclides infiltrate the shelter with ait exchanged with the outside under the 4 influ8nce of wind, leaktightness of shelter, air handling equipment (e.g. can outside intake vents be closed? automatically? panually?
how tightly? how fast?) etc. The sheltering effectiveness needs to be reasonably well known as it will develop over time, and that -
needs to be included in the bases for choice of nrotective actions.
i Otherwise, the choice will be based on inaccurate information, l in v?olation of 10 CFR 50.h7(s)(1) (effective nrotective action must be assured; "can and will be taken"). The olan itself need not contain all this analysis; just its results in useful, understandable
. form, provided the analysis is accurate and consistent.
(b) see (a). Basis is hUPEG-0654 II.J.10.m, 50.47(a)(1), and the common sense requirement that the basis of choice of nrotective action'should be accurate.
This l 57-c-10-3(a) k lack of information indicates that the authors of l the plan don't understand the requirements of NU".EG-0654 II.J.10.m.
According to interrogatory responses received to date, the emergency i
planners have some information on direct exuosure sheltering effectiveness available in their files; little if any useful or accurate information on inhalation exuosure sheltering effectiveness; and this information relates solely to buildings evaluated for use as fallout shelters in a nuclear war. It does not relate to homes or other typical structures, and I don't see any z schools in the material nrovided, though there may be sone. The information on sheltering effectiveness of typical structures for direct radiation exnosure is available in very crude form, i.e. just for brick and wood houses, no evaluation of house geometry, high-protection areas, or air infiltration annears to be in it.
Whether this lack of information proves a lack of knowledge by the planners, I'm not certain; I have asked them to tell me what they know in interrogatories to them. The information urovided is surely not sufficient to meet the requirenents of II.J.10.n, and would not be of nuch use in protective action decisionnaking unless the planners also know how many peonle will be in each shelter and its sheltering effectiveness and canacity (typical, for hones) and how the sheltering effectiveness varies with time.
(b) see (a) (c) see (a), N/a 57-C-10-h(a). The bases must be stated, not described, in the plan.
A descriution is not adequate. Whether this requirement does reouire the state planners to document "the entirety of their knowledge of
' sheltering effectiveness ' " in the olans would depend on how much they know. If they know nore than what is required, they need only docunent what is required. If they know less than what is reouired, nutting that in the plan will not meet the requirement. If they know exactly what is required, then nutting in all they know will neet the requirenent. See also end of resnonse to 2(a) above. &(c) elos (b) I think this is a silly ouestion, but see answer to (a) above.
(c) The contention is that the vlan provides no useful informatio[n or analysis of sheltering effectiveness, has inadequate discussion of nrotective actions, fails to conoly with NUDEG-065h II.J.10.m.
Having the stuff in reference books to look un aften an accident has started is silly, since that takes time and the reference books can (and k should) be consulted at leisure before dae accident hannens.
The information fob the Harris EPZ on shelterine effectiveness is the basis required by NUREG-0654 II.J.10.m. I know of no reference books containing information on direct and inhalation exposure sheltering effectiveness in the Harris EPZ, and none have been identified unon discovery yet. The basis information needs to be worked out in advance for the Harris EPZ and nut into the rian.
I don't think I have to tell you how to use the information, but since you asked, even daough you should know, the objective is to minimize dose received by versons in the FPZ. If sheltering followed by withdrawal after a cloud of radioactive material has passed will result in less dose than evacuation or other action, sheltering would be a nreferred action unless and until continuing sheltering seems likely to result in higher total dose. You can't make these sorts of determinations, or any decision on sheltering versus evacuation, without knowing"the sheltering effectiveness.
Since the NUPEG-That's what the " lack of knowledge part is about.
0654 standard requires the bases to be in the plan, if they're not in there it's either lack of knowledge or dereliction of duty.
The licensing board in this case rejected contentions that the nlanners were not adequately trained, so it would seen lack of knowledge is it.
. l 8_
> C-10-5 If they have knowledge, dhey haven't put it in the nian ,
where the rules say they have to nut it. I infer they lack knowledge. '
See h(c) above. They have also resnonded to interrogatories, and.nroduced documents, which show that sheltering effectiveness information isn't there for inhalation exnosure, highest nrotectio n factor areas haven't been ioentified, tynical structures of homes in the Harris EPZ aren't identified, and so on. This is certainly a lack of knowledge of sheltering effectiveness; for the hones they haven 't even begun what 's needed (e.g. sannling struc ture tynes, locating the high PF areas, calculating PFs, neacuring infiltrat!cn of air in tynical structures at varying wind sneeds, neasuring infiltration of particulates in typical structures at varying whind speeds, etc) to determine sheltering effectiveress for tynical homes, and for other structures in the Harris MMMMM EPZ. See 57-C-2 resnonses above, 57-C-3 resnonse above, h(a) rosnonse above also.
57-C-10-6. The plan needs to discuss protective actions and their effectiveness in enough detail (and providing enough quantitative information, as well as qualitative infornation where quantitative information cannohat be obtained) to provide useful guidance to emergency response perconnel. A prine exannle is nrotect$on for inhalation. See e.g. contentions 227A and B and suonorting documents filed 10 August 1983 in this nroceeding. Accurate knowledge of the effectiveness of unotefetive actions is recuired in order to assure that effeMetive protective actions can and will be taken (10 CTR 50.47(a)(1). The olan needs to (1) document at least the major effective nrotective actions known to the energency planners and quantitatively (if at all nossible) detail the effectiveness of such actions snecifically for the Harris EPZ, and (2) be accurate in that documentation; (3) other nrotective actions considered shot 1d be listed in the plan if nossible, and they daould be documented as to xn quantitative effectiveness. As used here, quantitative measures of enffectiveness would refera to determinations of protection afforded for direct and for inhalation exnosure.
Another example would be taping un cracks around windows and doors, which would have to include some analysis of how long it takes to do it, and the radiation exuosure incurved in doing it (if not finished by the tine the plume of radioactivity arrives) versus the saving in exposure by doing it, especially if those who are saved fron exposure are more radiosensitive (e.g. young children, nregnant women, the elderly, etc). All these things need to be figured out in advance, and updated as arnropriate, so you don't hafe to figure them out during an accident. That's the basis nuanose of planning anyway, and for nuclear accidents the planning should (and is recuired to) concentrate on reducing public exoosure to radiation.
57-C-7. The information conciled for the plan must be accuwate; the deterninations of quantitative effectiveness nust be made accurate; in order to be effective, the oublic has to be informed of some of these protective actions (e.g. which tynes of breathing nwotection and which methods of attachnent of such nrotection are most effective; being advised to keep masking tape or duct tape to tape un houses
--or car vents and doors and windows ' edges durinF an evacuation, if needed) The oublic needs to be encouraged to take such nessures, especially those which are chean and easy to do.
57-C-13-1. The plan says people should go to the area of hi F hest PF. The average persen has no concept of where that is.
While general guides for finding higher PFs could be given during an accident, it's clearly more effective to determine daem before
1 tho eccidant, when well-trained personnal can do the job and take their time doing it, as onposed to letting untrained people do it (with-nerhaps some expert advice) under time and stress paressure during an accident. By analPEy, would it make sense to locate fire lanes during a major fire, or to have done it earlier? Would
, it make sense to lay.out evacuation routes.before~evascuation is
! . required, or have nlanners find then the day of the evacuation
! during an accident? It's not effective to wait til the last minute
! and let untrained peonle do it.
57-c-13-2(a). The basic criteria, effectiveness of protection for both direct and ibhalation exnosure, are those of NUMFG-065h II.J.10.m. Another obvious criterion is .the canacity of the area.
For ill, injured,1or any other nersons (e.g. nursing home residents) who requiro _ care, snace to allow for the care and naterials ow devices i needed to nrovide it, must be available. Determination of inhalation protection should include air infiltration natterns and rates, narticularly -
at _ bed height for bedridden nersons, or at floor level where neonle may be required to lie on the floor or sit on the floor. The shielding from direct exnosure in high-PP areas has to be evaluated from all outside curfaces of the shelter building. The infiltration of particulates of sizes typical of radioactive releases needs to be
, determined; the effect of wind speed on infiltration of radioactive
! gases and particulates needs to be deternined; the tine after which interior air would be producing roughly the same exnosure as outside air needs to be determined in advance for each high-PF area.
All methodology for making these deterninations needs to be as quantitative and accurate as it nractically can. Eouipment for measuring air infiltration ratos is connercially available.
Access to the high-PP are (ability to get neonle in and out of it in time to be of use) is also inportant as a criterion. Protection isn't any good unless peonle are in the protection.
Since hosnital and nursing home paitents will take longer to move than nany people will (e.g. thos, who have their own transoort and are in vigorous good health), pro;ection factor assessment is nore important in case theae people nrove infeasible or very difficult to evacuate from the uo pital(s) and/or nursing homes.
(b) see (a); further info will be put together when I have more time.
57-c-13-3(a) I don't know. The State doesn't seen to know either, nor-do other emergency planners, according to discovery received so far.
(b) see (a).
57-0-13-h(a). Since knowledge of this ?F is part of the determination of sheltering effectiveness for those hosnitals and nursing hones, yes. NUREG-0654 II.J. 10.m. PFs for other areas of the hospitals and nursing homes should be generally known to guide emergency nlanners if and when patients can't be moved into the highest PP areas, or all of them can't be moved in (or won't fit). This is also basis for decisions on protective acticns, and should be in the nlan. 1 (b) see (a); (c) N/A :
57-c-13-5 t See above resnonses, e.g. 4(a),2(a),1. There may be other changes recuired if it is not feasible to determine the highest PF areas or to move peoole into daem.
57-c-13-6. Hosnital and nuarsing home personnel should be nade familiar with the highest PF areas, alternative high BP areas, and each hospital or nursing home Maould have its own plan or procedure helterim natients in hi h PF areas and nroviding for their nee [s there m %e event of a Enruclear accident a t Ha'rris. The for determination of PFs needs to be made accurately, undated as necessary.
-1G-14h responses based on CP&L SHNPP Emergency Plan, Rev. 2 dated Feburuary 1984 and received by me March 10, 1984 1kh-1 The Harris plant, Table 2.2-1 of the above-cited report, uses columns headed "30-45 min" and "60-75 min" for the columns required in NUREG-0737 Supolment 1 Table 2 to be "30 nin" and # "60 min"
--d respectively. NUREG-0737 requives 3 additions in !&C -
.. In the 30 minute colunn aand CP&L only provides 2 (Repair and corrective actions). NUREG-0737 requires a radwaste operatior in 60 minutes (same task area) but CP&L doesn't identify one at any time. The fire bridgade and security are unspecified and if I omit them it's not saying they are correct.
CP&L hasn't organized its table exactly as NUREG-0737 sunnlenent 1 organizes Table 2, so there may be more deficiencies I haven't caught.
(b) Basis is direct comparison of Tables specified.
144-2 see 1(
144-3 see 1 144-4 Provide the required nersonnel in the required tines.
If you can't do it, the onsite plan should not be cbproved.
144-5 Provide adequate capability among the personnel at all times.
The plan won't work if the eersonnel aren't capable of carrying it out, and this does not seen to be assessed. Seee.g. sections 5.2.1 andx 5.2.2 of onsite plan, 15h-1(a) It certainly describes a procedure, but as best I can tell, the plan does not include the procedures referenced in Annex E although Annex E of the onsite olan shows all those orocedures as " implemented plan section h.a.3". Section 4.k.3 of the olan, in turn, refers to Rigmxm Table 4.5.1 (once) and Annex B (twice) and gives no detailed procedures. Table k.5.1 is the nrotective action guidelaines (per dose, and it says it,'s from the (offsite)
EMP, Figure 10) . Annex B is all thtt's left. Section h.h.3 refers to ER?IS computerized dose nrojections, but it also snecifies that if radiation data is offscale, it's suspect or bad and assessment will have to wait for measurements. That's a prejudgment that would be disastrous if the readings really were offscale because of high radiation release. Moreover it anpears to contradict Annex B which says that if release values are offscale certain assumptions will be used in the absence of data.
(b) see (a) the question is confusingly stated; answer not affirmative (c ) The procedures the operators will carry out, insofar as they are described in the olan, refer to Annex B, which has the souhisticated requirements afor judgment as referred to in Contention 154 154-2(a) Your interpretation (this question is not really a question; it's more of a request for admission) appears to be consistent with the plan provided you define nrocedure narrowly. However, it is clear from contention 15h that the " procedures" it refers to are those "given in Annex B" of the onsite olan. Annex B says, in its first line "When an emergency situation exists at a nuclear plant
.. ." and continues" the methods and equations used to estinate dose projections are based on the docunents in the reference section." and describes how the estinates are made, referring to the references.
I think Annex B does indeed describe a orocedures for making dose assessments; it does say health physics, not onerators, should do it.
It does not say that the ouerators would make estinates in any other way.
The only other thing the plan refers to re this as far as I can see, is operators using the connuter. Still, judgments would have to be made per Annex B, and the connuter ni Eht not be working. (b) See 15h1(a) & abov
154-3 Annex E does list such procedures. It doesn't tell anything about them but thexir titles and a reference to section h.4 3 of the nlan --- see 1454-1(a) resnonse above.
' 154-h. This contention isn't about "stens" as distinct fron
" judgments". If you look at Annex B, there are sone difficult judgments to make, including the composition of the source term (by radionuclides), estimating the source tern, what to do when the indicators are offscale (the 4.4.3 determination that offscale data is " bad" etc can be dangerous, see 154-1(a) response above),
and do en. The list is basically in Annex B.
(b) Probably not. There is no indication the operators can measure the variables required, and no indication they are trained well enough to do the estimating that Annex B says health physics should do.
(c) See (b). You can't do it reliably wi thout knowledge plus experience, and unless the operator involved is also a health physicist trained to deal with reactor releases and dose estination therefrom, they can't be counted on to have that knowledge and exnerience. (Indeed, even if they do have all those qualifications, there's no guarantee they'll do it right; however, the plan itself only goes so far as referring to health physicists being needed to nake the assessments -- Annex B)
I have no information indicating CP&L has any operators who are health w physicists with such training, or that they intend to get any.
154-5fd As I understand it, one can become a nuclear plant operator if one has formal education to the extent of graduating from high school with a "C" average in math. I am not awe.re of information being made available as to d1e level of formal education Havris plant operators have. However, see (b) and (c) in resnonse to 15h-h above.
(b) see (a) Lack of formal education is not the statement of the contention, which says " unqualified".
15h-6(a) Yes (b) see 154-h(b) and (c) resnonses and Annex B of the onsite plan, which is the basis for contention 15h. See also the statement of basis for content $on 154 itself.
(c) See 154-4(b) and (c) and basis for contention 154 as filed.
I'm not sure why you keep putting " plant operators" in quotes, but it means the same thing as plant onerators to me in context of th$ s contention. I believe if such training was made axvailable to operators (as 154-h(b) and (c) resnonses say they Waould have) 1 CP&L would have said so in its training references, but section 5.2.2 3 of the onsite plan says only that Senior Contatrol Operators and Shift Technical Advisors receive training "in the following areas" including " Dose urojection proceduras and protective action reconmendationS i.e. not health physics. Assuming Auplicants define Eprocedure" here as narrowly as their earlyier questions indicate, then the procedures are simnly cookbooks, not trainirc in judgnent, much less the health physics knowledge and experience I believe is required (and Annex B certainly indicates is required) for accurate or reasonable dose assessments and judgments in sceident conditiens.
154-7(a) comprehensive list would require more knowledge about the onerators answer above,154-1;and -2 resnonses also.see 154-6(a) answer above, 154-h(b) and (c)
(b) see referenced resnonses.
154-8. Either have a senior (exnerienced) health ohysicist trained in dose assessment on shif t at all times, or do as 15h-k(b)(c) suggest. See above for bases. 15h-9. Ungrade eneraton1G'AlWS 688 &#
1 l
154-9 continued see 154-4(c) response.
and more reliable 213-1(a) Quickerg notificatign (has to be 15 minutes since the lake is closer to the nlant (within 5 miles of it). NuRsG-065h Appendix 3 B.2.b requires "The initial notification system will. assure direct coverage of essentially 100% of the population within 5 miles of the site. " It further states (p.3-3, ibid.) The basis for any special requirements exceptions (e.g. for extended water areas with transient boats ...) must be documented." The offsite ERP does not anpear to document any such exception for the Harris lake.
Prompt notification, NUREG-0654 says (Apn.3 B.1)"the system shall provide an alerting signal and notification by commercial broadcast (e.g. EBS ) plus special systems . . ." This means a message has to get to the peonle in boats on the Harris lake, including those without radios (either regular radios or NOAA weather-band radios). The only way to do this is with powerful loudspeakers, e.g. on aircraf t (NUREG-065h Appm 3 c.4.d ), and it is not evident from the plans that such aircraf t could be nobilized in time to deliver the warnings to the Harris lake within 15 minutes. Alternatively, powerful loudspeakers coverirg the lake (and able to be heard in adverse weather, e.g. thru a thunderstorm) could automatically transmit the message, under direct control from the Harris plant or some other rapid means of activation, and reneat the mesange notification continuously to tell boaters and swimmers on the lake what to do. Or boat-mounted loudspeakers could be used, provided the boats can cover the lake thoroughly in 15 minutes.
It would certainly be helpful if prepared leaflets describing the warning systens and apuronrjate actions were distributed at boat access to the Harris lake. I believe this would be required for transients from outside the EPZ who would not have a brochure or other written information regarding nuclear accident emergency procedures.
(NUREG-0654 II.G.1 and 2 require information de made available to transients through means not limited to the brochure)
(b) See (a) above.
213-2(a). Enough boats to, under adverse weather and noise conditions, e.g. a sudden thunderstorm or rain beginning at or soon after the time notification is required, transmit an audible and under-standable notificatiob message (ner NUDEG-065h Anp.3 B) to all points on the Harris lake. I have not calculated how nany this is yet.
(b) See (a) above and 1-a above that.
213-3(a) Sufficient to assure that (allowing for people not showing up, by providing sufficient backun personnel and backuns to the backups in case they don't show un) the types of notification required by NUREG-065h and discussed in responses 1-a and 2-a above ,
can be performed at any time of the day or year, within 15 minutes of activation of the a16ct and notification system.
I have not calculated this number of personanel. It a depends, of course, on the system chosen. If none of these systens is used, it would appear a much larger number of persons would be recuired, l to ind*vidually notify persons on the Harris lake by direct contact (the equivalent of the " knocking on doors" alternative for notification of persons on land).
3 tha t th(b)"
e plan shall includeNUPEG-065h Aupendig Th,e snecific orpp 3-1 and 3-2, include req by title, who shall be resnonsible for notify!.anizations ng . . . the aforfindividuals, ected population and the specific decision chains for rauid innlementation of alert and notification systems" and
213-3(b) continued "A capability for 24-hour per day alerting and notification".
Tnese capabilities cannot exist without having the required personnel, and won' t work without them. If they won't work, they vio'.ated 16.
CFR 50.47(a)(1) which requires assurance tha t anuropriate nrotective actions can and will be taken.
213-4(a) Provisions for boat accidents on water should include the ability to assist victins of boating accidents and remove them from the lake (e.g. by boat or helicopter) whenever evacuation is required. The number of such boats or heliconters required depends on (1) the time in which helicopters with rescue personnel can reach the Harris lake af ter being alerted that they are needed
' there, including time to get rescue personnel to the helico ers, get pilots, bem sure the helicopters are fueled, etc. ; plus e time required for the boating accident (c) to be noticed and heli pters called for. (3) it also depends on the nunber of accidents, which mani would tend to deoend on the number of boats allowed on the lake (see below). If boats are used for rescue, the boats with anpropriate supplies would have to be maintained at the Harris lake (probably by CPOL), and rescue personnel anpropriately trained would have to be available to go out in dhese boats in the event of boat accidents on dae Harris . lake during an smergency caused by a nuclear accident at the Harris nuclear plant. It would be desirable for the rescue boats to Fo with notification / alert boats so that accidents could be found and attended to more ranidly (the alert boat shouldn't be the rescue boat because if it does come on a boating accident and stops to conduct resuce operations, that interferes with alert / notification to other parts of the lake). Again the capability of such rescue boats and crews should be to assist the naxinun number of boat accidents on the lake, and get the neople involved in those accidents out within reouired evacuation times (or get then into shelter with appropriate nedical care if sheltering is ordered instead).
For traffic accidents, e.g. in noving boats or evacuating in vehicles from the Harris lake, sufficient wreckers shorld be available to ensure that promet evacuation is not imoeded by such accidents either near the lake access, or on the evacuation route out of the EDZ.
Special coverage should annly to the nearest State highway or road not controlled by CP&L, and should be available on a 2h-hour basis with the ability to resnond promotly to any such traffic accidents.
Transport and/or shelter as appropriate, and medical care, for victins of such traffic accidents, should also be available in CP&Lucontrolled areas an off state or county roads.
The limitations of numbers of boats or boaters on the lake when the Harris reactor is critical or fuel handling is taking place, should be based on (1) the ability of all such boats to return their occupants to land for sheltering or evacuation promotly in the event of a nuclear accident at Harris, . with due allowances for boats running out of fuel, having engine malfunctions, having accidents, propellers tangled in weeds or plants, fishing line, etc, and nrovision to Fet boaters with such nroblens off the lake -- i.e. the norc rescue and i
assistance provisions there are, the more boats could be allowed on the lake; (2) the number of boat accidents possible as the number of boats on the lake increases; (3) the ability of all such boats each au to5roccupEronriatelanding Ge =ites near the access area so that nt's can reach v'ehicles for evacuation-- if there are two many boats, they will overcrowd this area and inneded evacuation.
,,---.---.,-w, - - . -
213-4(a) continued I have not calculated these linitations. They would also depend l
-on the type of boats. Rowaboats or canoes should not be nermitted on'the lake _unless pickup for their occupants is nrovided on a
' dedicated basis (boat available at the lake at all times with -
sufficient _ capacity and speed to reach and renove all such occunants),_
- since the .occunants of these unnowered boats could not return to
. landing areas rapidly enough in the event of an accimmident.
t I have not calculated the numbers yet -- these are the nrincinles.
(b) 10 CFR 50.47(a)(1) requives assurance that appropriate protective actions can and will be taken. There is no nrotection from radioactive material out on the lake; even enclosed boats would provide little if any nrotection fron airborne radioactivity. There is no shelter on the lake.- Therefore, to take annronriate protective action effectively, the people have to be able to _get off the lake promptly when alert /
notification is declared. This has to be doable in worst-case conditions, 4
and where it can't be done (e.g. rowing or canoeing too far from landing areas to return on human power in time ) that sort of use of the lake has to be forbidden; where limits are required to assure that people can get off the lake in time, those linits should be innosed.
213128-5(a) I don't know. (b) N/A 213-6(a) Persons who have boated to an area far from access and cre swinming would have to return to their boats and then return to the access; water-skiers cannot come through heavy boat-
. traffic safely and would have to return to boats or mswim to reach the shore at access ' points; x any swimners move slower than most boats and would take longer to get outof the lake than a boat at the same distance from shore. (b) see (a) 3 213-7. Swimming should be forbidden excent in designated
, areas close to accress and behicle parking, so that all swimmers can get out of the lake pronptly in an alert situation, and so that all swinners can be alerted and notified promntly (the alerters will know where they are and/or automatic systems can be aimed at the swimming areas , e.g. loudsneakers); All of the requirennnts Wimuram discussed in 213-4(a), 213-1(a), 213-2(a) and 213-3(a) and 6(a) above should be thoroughly covered. The changes must be made to assure that effectivo nrotective action can and will be taken by nersons on or in the Harris Lake (10 CP9 50 47 (a)(1)). 1 i 213-8. The physical facilities (e.g. dedicated rescue boats, wreckers, available helicopters), rescue and alert eersonnel, pilots, wrecker onerators and others must be available with sufficient backuus l l_ to be sure that all rsquired personnel are available during an actual nuclear accident at Harris _ to carry out the tasks covered ini the above responses in a timely and effective manner. If the plan isn't backed up by people and equipment to carry it out, who are l I
available When needed to carry it out, the plan is no good.10 CFR 50 47(a)(1) requires that effective protective actions can and will _ be taken. This includes also providing shelter to nersons on the lake, when sheltering is the indicated action. The shelter needs to be big enough to held all such nersons, and provide useful protection fron radiation. (same authority, 50.h7(a)(1).
. There may be other snecific authorities that supulement this basic requirement that effective actions for protection can and will be
~
taken.-
, , . . , , - - . - - ,v-. .,,r< ,-.----,---.y.-.m., s, --- ,, -,
215-1 Paul Holmbeck's address is 1300 Green St. Durham NC 27705 His present occupation is
-(b) See pp.1-3 of Holmbeck's testimony in Byron; his preparation of daat testimony; extensive familiarity with the requirements of NUREG-0654;and exnerience in analyszing emergency plans including those for the Byron and Harris plants. I don't know what other i qualifications he has. I believe a person is an "exnert" in law l when she or he has greater knowledge of the subject than the average person (e.g. a juror) or the other fact-finder in the case, by reason of education, training or exnerience or a combination of these.
215-2. Do you mean Eddleman 215 as admitted or as revised?
Applicants have moved tb have the entire contention 215 thrown out.
In general, any conservatism is not realistic (if it were realistic it wouldn't be a conservatism to use it) and varies from actual conditions likely to obtain in an evacuation. Thus any conservatism introduces error into the evacuation time estimates. As to the specific effects of cons ervatisms, see the contention as admitted and a: revised.
215-3. Persons who are away from home (e.g. at work, shopning, on errands) and the time of the order to evacuate (or instructions to evacuate), especially those with their daildren or families wihh them ,
who might have to go back into the EPZ to reach home; persons who are at work and leave from there to go home and then evacuate; persons without transportation; persons already outside the EPZ at the time of an evacuation, e.g. at school or work or shopping or on errands or at the doctor's or dentists or on recreation. Because there are many reasons why peonle may be away from home, the listing of reasons for being away from home above should not be viewed as exhaustive. Peonle who for whatever reason aren't home, neonle who for whatever reason are outside the EPZ, etc are the onerative groups in this answer.
215-4 I don't know what poople will do in an accident exactly.
I don't think anyone does know for sure. However, it would be reasonable for persons or families outside the EPZ to stay outside it if evacuation were ordered, unless they thouE h ) they had to go back inside it to see to families, relatives, friends, coworkers etc. In part, how many people would stay outside the EPZ would orobably depend on the availability of telenhone communications whereby they could contact family, relations, coworkers, friends etc inside the EPZ to assure themselves these folks were OK and could get out OK.
As for persons in the EPZ, the assumption that neoole without transportation evacuate from hone and occupy an extra vehicle is not realistic for those who could fit into another evacuating vehicle and got a ride out that way.
As for persons away from home in the EPZ, subjective factors l and the availability of communications would influence whether they went home or evacuated directly. One subjective factor is how seriously they take the instruction to evacuate; another is how seriously thyy take the danger of the raccident; another is the location of the nlume; another is whether the plume is already escaping or not; another is whether the location of the plume is known. Communication to relatives at hone or at work (to arrange evacuation, or just let then know "We're leaving from where we are and will meet you . . . (nlace T), if effective, could lead to fewers neonle going home. Unavailability of such communications (e.g. telephones, or the phone system overloading) could lead to relatively nore folks going hone, but still probably not 100% since for some no one would be home to get.
(b) see (a).
Further basis info research will go on later. l
215-5 One. obvious such situation is when one vehicle is outside
- - - the EPZ; another is large families; another is people with one car at hone and one at work (or who have a vehricle available at hone, e.g. a. pickup or other truck, etc, which can be used for evacuation);
another and very obvious one is neonle who-have 2 vehicles and 2 drivers but don't want their vehicles contaninated by being lef t in the EPZ and would therefore take both vehicles out. See resnonses to -215-2,3, and 4(a) above. People do things based on their own judgnent.
215-6. I don't know. Analysis would have to have the names or addresses of all the drivers to get a reasonably meaningful answer, and since not all neonle in the sane household necessarily use the same suraname, addresses would have to be checked too.
215-7. I don't know. It depends on their nembershin in grouns r identified above. The only reliable way I-know to get an answe" would be to survey them and ask them about various situations such as Bkk discussed in resnonse to 215-2,3,4(a) above.
(or ETEs) 215-8. There is nothing in the plan indicating that the persons in households without vehicles have been surveyed (as I recall) nor that their neighbots have, nor that the locations of their nearest neighbors have been determined, nor that the canacities of those neighbors' cars or other vehicles have been determinated to be sufficient to carry the neighbors plus those from households without vehicles, nor that the neighbors will give then rides out (nor that the neighbors will, be there to give them rides out),
and not anything I remember about the nunber of drivers and extra vehicles being available or assured from those neighbors to make one extra vehicle per household without transportation. l The assunption annears to be exactly daat, an assumption, and its I basis is not clear. Its basis , if any, should be documented and shown to be either accurate, or inaccurate (revising the ETEs to correct inaccurae 215-9. I don't know. Worse, I d11nk you don't know either.
Tnis would have to be determined through a survey of those households
, and their neighbors. You allege there are onl (based on vehicle registration and/or census) yso a few hundred a survey of them is feasible.
215-10. The ETEs need to be connuted in an accurate nanner without using the conservatism, in each case. Accurate or realistic information rather than the conservatisms abould be used in each case.
22h-1. NUREG-065h Apnendix h requires (I.B) that all assumptions
- used in the (ETE) analysis shall be provided. IV.A. of the same appendix says " Adverse conditions would depend on the characteristics of a specific site and 'could include flooding, snow, ice, fog or rain.
The adverse weather frequency used in this analysis shall be identified and shall be severe enough to define dae sensitivity a of the analysis to the selected events. These conditions will affect both travel times and capacity. More than one adverse condition may need to be considered." it goes on to say that a " northern" site with a high tourist populat$ on in sumner would have to consider rain, flooding i or fog as the (summer) adverse condition along with snow with winter l population estimates. Nothing in NUDEG-065h excludes southern sites 1 with reacreational populations in the sumner and snow or rice in the winter i
from this requirement. NUMEGS-0654 continues "The text accompanying the table shall indicate the critical assudptions which underlieu die time estimates ... The relat$ve significance of alternative assunctions hall be addressed, especially with regard to time dep"endent traffie load-ing of f the segments of the evacuation roadway network.
l l
l
_ - - -- - - - _ _ . . . - + - _ - - -
2P4-1 continued I understand this to mean daat not just the weather gfrequency itself, but the types of adverse weather (and all their frecuenemies) that can be adverse conditions for evacuating the Harris EPZ need to be identified and established to be " severe enough to define the sensitivity of the analysis to the selected (adverse) events".
The text is required to explain the relative significance of alternative assumptions . . . . especially wi th regard to time dependent traffic loading of the segments of the evacuation roadwFy network."
This clearly includes the relative significance of adverso weather conditions (not only those used, but alternative assumntions) since they "will affect both travel times and canacity", which of course affect the loadings and timing of traffic loadings on the segments of the evacuation network.
224-2. You could read it. Or you could read answer 224-1 above.
See also p.h-10 of 065h Appendix 4 (for facilties) weather must be consideYk 224-3(a) Because if the adverse weather isn't the real adverse weather encountered at the time of the evacuation, the tine estinates aren't of any use. Also, NUREG-0654 requires the adverse weather frequencies and the effects of alternative assumptions (including weather) to be included in the ETES. I presume this is so these effects will be k wn to the planners. Also, of course, weather with low frequen rapid rains, floo (e.g. tornados, hurricanes, extreme icing,
, snow, ice, etc) would have to be considered amonF the alternative assumptions for a site like the Harris EPZ where all such things can occur (see 065h App h IV A "Advxerse conditions would depend on the cberacteristics of a snecific sitel).
I understand that this information is in there so that in the event of an emergency under adverse weather conditions, the effect of those weather conditions is known to the emergency resnonse personnel so they can use the information to decide what nrotective action (s) may be appropriate. Obviously, actions based on inaccurate information re adverse weather would not be accurately deternined to be the best actions. The actions without such information are based on unreliable information because the adverse weather cfrequencies NU9EG-0654 aren't mused (both directly and as alternative ensumptions )
requires.
(b) See cites in (a) andin 22h-1 response (s) above.
224-k. The plan's ETE study must be brought into full compliance with both the letter and the intent (as described in answers 224-1,22k-3(a) above, and otherwise) of NUREG-065k as regards the use of adverse putting weather frequencies identified in the plan, and those frequencies as alternative assumptions) (both intoasthe adverse plan. weather conditions and )
All of the adverse weatherm '
j possibilities for the Harris site (as shown in answers above or in the ER or FSAR re meteorology) should be considered as alternative assunntions l in the ETEs.
i PRODUCTION OF DOCI"4ENTS l
- Within 30 days of these responses, above-referenced documents (except NRC documents, per agreement) will be nade available for inspection and conying at a mutually agreeable time and place by cohtact with Wells Eddleman. l present I affirm the above answers are true to the best of my knowledge and belief. Sgav s !
Qf(Nc, s l Wekls Eddlenan 3 Sentember 1984
- _m
UNITED STATES OF AMERICA NUCLTAR REGULATORY COMMISSION In the matter of CAROLHA POWER k LIGHT CO. Et al. )) Docket 50-400 Shearon Harris Nuclear Power Plant. Unit 1' o.L.
CEftTIFICATEoF SERVICE
'.13 Resnonses te Applicants' I hereby certify that copies of _
August 9,198h Interrogatories on Emergency PIanning HAVE been served this 7 day of September 198)A,,, by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are marked with
""d an asterisk, for whom service was accoriplished by JudEes James Kelley, Glenn Bright and Jamas Carpenter (1 copy each)
Atomic Safety and Licensing Board US Nuclear ReEulatory Commission Washin6 ton DC 20555 George F. Trowbridge (attorney for Applicants)
Shaw, Pittman, Potts & Trowbridge Ituthanne G. Miller 1800 M St. NW ASLB Panel WashinEton, DC 20036 USNRC Washington DC 2055 5
- office of the Executive Legal Director 6I b Spence W. Per Attn Docke ta 50-400/401 0.L. g Li FEMA Room o USNRC v4 500 C St. SW Washington DC 20555 Washington Dc 20710 5 d
Docketing and Service Section (3x) *D'n CF%?M*"/FLP E
Attn Dockets 50-hoo/hc1 o.L. Raleigh,$707 NC Waveross office of the Secretary 27606 Dr. Linda W. Little a neton DC 20555 Governor's Waste Mgt. Bd.
- 51 Albemarle B1dg John Runkle -
32 v St.
RaN. e Salisbut
, C2 M1 Granville Rd ,
Chapel Hill Ne 2751h Bradley W. Jones Robert Gruber USNRC Region II
- ' Travi.a Payne Exec. Director 101 Marietta St.
Edelstein & Payne Public staff Atlanta GA 30303 Blex 12601 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D. Certified by h 729 Hunter St.
Apex NC 27502
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