ML20097J205
| ML20097J205 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/07/1984 |
| From: | Hawkins T Federal Emergency Management Agency |
| To: | EDDLEMAN, W. |
| Shared Package | |
| ML20097J201 | List: |
| References | |
| OL, NUDOCS 8409210152 | |
| Download: ML20097J205 (12) | |
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C UNITED STATES OF AMERICA NUCLEAP REGULATORY CO't'tISSION
,.1 u d 3 3.,o tg i
1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
-In the Matter of
)
)
CAROLINA PONER & LIGHT COMPANY
)
Docket 50-400 OL AND NORTH CAROLIMA EASTERN
)
MUNICIPAL PONER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
)
)
)
FEMA STAFF RESPONSE TO INTERROGATORIES PROPOUNDEO BY INTERVENOR WELLS EDDLEMAN GENERAL INTERROGATORIES s
INTERROGATORY 1.
What is FE!!A Staff's understanding of the subject matter of conten-tions 30, 57-C-3, 57-C-10, 57-C-13, 213, 215, 224?
ANSNER:
FEMA Staff's answer to interrogatory number 1, 213 is supplemented as follows:
ANSMER:
213:
We agree that a plan for Harris Lake, similar to the plan for Jordan Lake (annex G) should be included in the radiological emercency planning for Plant Harris.
SPEC.TFIC INTERROGATORIES 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 regards turning off heating devices on cold nights, if shelterina is recommended (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, con-cerning the ability of each notification method you will use for Harris accidents at nicht, especially between 1 am and 6 am, to awaken persons within the EP"?
(c) If so, please identify all such information and all documents containing such information.
(d) Does the emergency plan-ning 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.
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delay due to awakening, delay due to sleepiness, grogginess or drow-siness, 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 con-cerning 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.
ANSFER:
57-C-3-3 (a) (i), (ii), (iii) unknown (b) (i), (ii), (iii) No (c) not applicable (f) not applicable 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 telechone not.ification or dialing systems at all?
(b) If so, please answer 57-C-2-3-2(b) with respect to the capabilities of each such system.
(c) Do you have any opinion as to whether persons awakened by sirens in the Harris EPZ might use the telephone (i) to ask authorities what is going on (ii) to notify friends or relatives or others of the accident (iii) for other reasons?
(iv) which, if any, of your opinions expressed re the questions (i), (ii) or (iii) above, would change if the awakening occurred 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 infor-mation relates to.
(f) Is it your opinion that evacuation of the Harris EPZ could occur as rapidly during normal sleeping hours (e.g. between 1 am and 6 am) as it could during daytime hours, all weather or other con-ditions being equal?
Please state all reasons 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 during normal sleeping hours (1 am to 6 am) at it would be under (i) daytime conditions, similar weather (ii) evening conditions, up to about 10 pm, with similar weather?
Please state all reasons and information supporting your opinion.
Please identify all documents which contain in-formation re answers to parts (f) (g) and (h) (including all sub-parts).
ANSWER:
57-C-3-4 (a) Unknown (b) not applicable (c) (i), (ii) yes, (iii) no (iv) nate (d) No (e) not applicable (f) yes. Through extrapolation of the ETE study.
(g) No. Through extrapolation of the ETE study. (h) (i) more (ii) less.
We infer this from the ETE study, page 1-4 and Table 7-1.
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) please explain each such difference (c) are there differences in evacuation conditions during normal sleeping hours, and conditions for evacuation during other hours, that would tend to off-set or cancel each other?
(d) what are these differences, and how do they act to offset each other?
(e) Please identify all documents con-cerning differences in (i) evacuation conditions (ii) rapidity of evacuation (iii) evacuation times, for normal sleeping hours compared to other times.
(f) are there any differences in evacuation conditions (see (c) above, e.g.) between sleeping hours (1 am - 6 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 evacuations which indicates differences in evacuation times under sleeping hours con-ditions? (i) 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 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? (1) Does the State of NC, CP&L or any other responsible emergency preparedness agency intend to test (i) comnunications (ii) notification elenents, during normal sleeping hours (1 am to 6 an or any time between these hours, i.e. between 1 am and 6 am)?
(m) If so, what tests will be done by whom, and on about what dates (e.g. before fullscale plan test, dur-ing that test, before Jan. 1, 1985, quarterly, once a year, etc)?
ANSWER:
57-C-3-5(a) Yes-based on the ETE study. (b) Daytime is probably the slowest since the typical family is dispersed, and evening is probably the most rapid since the typical family is together at home but not asleep; and during the hours 1 am to 6:00 am, evacuation time is pro-babl.y sonewhere between the daytime and evening evacuation times. (c)
There probably are offsetting differences but precisely how much these differences offset one another, we do not know. (d) One obvious difference in conditions is the amount of light available for visual purposes; another is that during the day, most employed people are located at their place of employment; still another difference is that most people of the Harris EPZ probably sleep between the hours of I am and 6 am. -Exactly how these differences in conditions offset one another we do not know.
We are not aware of any studies concerning the sleeping habits of the Harris EPZ inhabitants, their employment or their hone to work travel times.
Without studies such as these, we do not think it possible to determine with any degree of accuracy, how much one factor of the evacuation equation offsets another.
(e) We know of none other than the ETE study which has already been identified.
(f) yes (g) stated above (h) Unknown (j) Unknown
(' ) not applicable (1) Unknown (m) not applicable.
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- 57-C-3-6(a) Does NUREG-0654, FE?iA 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 informational or instructional message to the population on an area wide basis.throughout the 10 mile EPZ, within 15 minutes?
(ii) initial: notification system assuring direct coverage of essentially 100% of'the population within 5 miles of:the site?
(iii) special arrangements to assure 100% coverage within 45 minutes of the. pop--
ulation who may:not have received the initial notification within the (b) How does'the Harris offsite emergency-
. entire plume exposure EPZ?
plan inotifica tion procedure meet each notification requirement of FEMA 43- (Including (i), (ii).and (iii).of (a) above if applicable) during
^
normal'sleecipy hours (e.g. 1 am to 6 am)?
Please specify your. answer
.in detail, describing the alerting systems used, the design report on i
l 9
-each alertingLmeans to be used, the ability to provide an informat ona cut instructional message to persons who are asleep at the time of the i
4-1 alert / notification beginning; please spec-ify all documents, opinions of' experts, or other information you rely on in making your answer.
1Please answer. separately for each requirenent or criterion for notifi-
~ cation in NUREC-0654 or FEMA 43, or other applicable guidance (as indicated in your answer to (a) above),
t
.ANSNER:
57-C-3-6 (a) (i) yes (ii) yes (iii) _ yes (b) Special provisions for noti-
.fication_during normal sleeping hours are not included in the Harris Alerting, warning, planiand;are not required under FEMA guidelines.
and notification of the public will be provided by sounding sirens and j~
supplemente'd by announcements made through EBS radio and television, sound trucks, bullhorns, and knocking.on doors.-
57-C-3-7 (a)~ Nhat, in your view,.are the merits and/or negative aspects of the.use of tone alert radios.to notify sleeping cersons of an accident (b) Isn't it true that FEMA 43 section E.6.2.4 at the1 Harris plant?.
that tone alert radios are one of the methods of alerting not included (c)'Have you made any investigation as
.in "special alerting methods"?
effectiveness, or other aspects of tone alert radios for
~to the cost,
^
the Harris EPZ (d) Please provideLdetails of any investigation re tone alert radios that you have.made, either for the Harris EPZ, or otherwise, j
- identifying all documents containing information about the scope, plan,
' authorization, method of_ inquiry, results, or information obtained or developed in'such investigation.
(e) Are there any other sources of in-h Please identify formation re tone alert radios which you are aware of?
(f)1Do you consider tone alert radios to be an-alternative to each such.
.(i) siren notification (ii) loudspeaker notification (iii) automatic for notification of Harris plant emer-
.ringdown telephone notification, gencies.and/or providing informational or instructional messages to persons within the Harris plumo. exposure EPZ, during normal sleeping t
~
- hours, e.g. 1 am to 6 am?
(g) Please give all reasons for your answer (s)
I to each subpart of (f) above.
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L ANSMER':
Tone alert radios, in our opinion, are not as effective as 57-C-3-7 (a) sirens primarily because control of the systemfis in the hands of the public which,1oftentimes, may unplug the radios in their complacency or^may not see the importance of maintaining them properly.
.(b) yes (e) No (f) (i) Yes (ii) Yes (iii) Yes (g) Tone alert
'(c)-No;(d) None radios are alternatives but are not perferred alternatives for the reasons stated above in(a) 57-C-3-8 (a) Does FEMA ~ encourage the use or development of special alerting imethods such as automatic telephone dialers or switching equipment where
.t is cost' effective?-
(b) Please provide all basis for your answer to i.(a)i identifying all documents or experts opinions you used in making that answer.-(c) Have you'made any study of the cost-effectiveness of any special alerting methods for the Harris EPZ during normal sleeping hours (e.g. 1 am to 6 am)?
(d) Please identify all documents concerning, oriused in, or identified during, any such study as inquired about in part.- (c) abov.e.
(e) Have you made any study of simultaneous dialing those mentioned in section E.6.2.4.4 of FEMA 43, for use in systems, e.g.
for notification during normal sleeping hours or for noti-the Harris EPZl (f) fication or. delivery of instructions, or informational messages?
(e)
Please provide details of any such study as inquired about in part including identification of all documents related to such study, par-
- Labove, ticularly aay about the capability of simultaneous-dialing or simultaneous
-ringing telephone equipment.
(g) Was the message-delivering capability of. simultaneous-ringing or dialing telephone equipment considered in any offyour studies?.In'which, and how?
(h) What is your opinion concerning
.the.usefulness of (i) simultaneous dialing (ii) automatic.ringdown dialing
. telephone.equipnent for notification of persons within the Harris EPZ Please give all basis for,your' opinion, during. normal sleeping hours?
identifying all documents used in preparing or supporting your opinion.
-(j) (there-is no part- (i) since that-is used for subparts, as (i), (ii) )
7What role did provisions for (i) calling back busy lines (ii) preventing subscriber overloading of the telephone system during use of telephone notification to Harris EPZ residents / transients play in your analysis or (k) Would telephone study.'ofLtelephone notification within the Harris EPZ?
system 1 overloading by subscribers be less, more of, or about the same of (1) a problem for telephone notification during normal sleeping hours?
.Have-you made, or collected, any other studies or reports or inquiries concerning notification systems or methods for people (i) who are asleep at the time of notification -(ii) whose whole households are asleep at the for emergency planning / response purposes or other time of notification, Please describe in detail any. studies /information asked purposes?
(m) about in (1) above.
ANSWER: C-3-8 (a) No (b) Observation only. (c) No (d) Not applicable (e) No
-(f) Not applicable (g) Not applicable (h) None (i) No opinion (ii) No opinion (j) (i) None (k) Unknown (1) (i) No (ii) No (m) Not applicable.
57-C-3-9(a) Referring to your answer to 57-C-3-1(f), if not previously e
fully answered, does any documentation or records of any kind concerning the consideration of telephone notification of persons within the EPZ that was made during the Harris emergency planning process exist?
(b)
If so, what. documentation?
Please identify it fully; please fully identify any other records of this consideration which you know of.
(c) If answer to (a) is "none" or an answer to that effect, or you believe you have fully answered (a) previously, please explain why no records of this consideration exist.
(d) Do you remember anything about the consideration of telephone notification of persons within the EPZ that was made during the emergency planning process?
(e) If so, what do you remember?
(i)
Do you remember what kinds of telephone notification (aa) methods (bb) systems were considered? (ii) do you remember any reasons why telephone notification was rejected?
(iii) Do you remember whether night-time (normal sleeping hours) notification was part of the consideration of telephone notification for the Harris planning process (emergency response planning)?
(iv) Do you remember whether alternatives to telephone noti-fication, e.g. tone alert radios, etc. we're considered?
Please explain what you remember, both in general, and for every subpart for which your answer is affirmative.
ANSMER:
57-C-3-9(a) Unknown (b) Not applicable (c) Unknown (d) No (e) Not applicable 213-3 (a) Refer to your answer to 213-l(d) :
Do you agree that the job titles or names of perscns responsible for verifying (in the field) and/
(in the Emergency Operations Center) that or received reports verifying persons on the Harris Lake have been notified of an accident at the Harris nuclear plant, should be part of the plan (off-site emergency response (b) Please fully explain all reasons for your answer to (a) and plan)?
identify any documents or authorities you rely on in making that answer.
(c) What is the job title of the person or persons responsible for re-ceiving reports that notification of persons on or in the Harris Lake has (d) What is the job title of the person or persons been accomplished?
responsible for notifying persons on or in the Harris Lake of a nuclear accident at the Harris plant?
If more than onc 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.
ANSMER:
213-3(a) No (b) This information is better placed in SOPS; placing all planning details in the plan could make the document overly cumbersome.
(c)
We have no documents or authorities to cite regarding this answer.
Unknown (d) Unknown (e) Unknown 213-3-4 (a) What are the means for giving an instructional message or an informational message to persons on or in the Harris Lake in the event of a nuclear accident at the Harris plant?
(b) Please describe each such means in detail, explain why it was included (or will be included) in the emergency response plan, and identify all documents concerning these means what personnel are required to your authority or ability to use theM, - -
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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 Earris lake, and the above information for each backup means of notification.
(c)
What is the content of the in-structional message for persons on/in the Harris lake in the event sheltering is ordered?
Does it provide for sheltering at or near the lake?
If not,.what does it provide?
What will persons on/in the Harris lake be told to do, if sheltering is the overall response for-the EPZ that is ordered?
ANSWER:
(a)
Unknown (b) Not Applicable (c) Unknown 57-C-10-5(a)
Please refer to your supplemented answer to 57-C-10-3-d.
Were any metho,ds for assessing sheltering' effectiveness for structures in the Harris EPZ used, which were NOT intended to provide emergency Please planners with a data base for a wartime nuclear emergency?
identify each such method and its results for structures within the and all documents concerning the method and/or its results for
- EPZ, 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?
(v) something else?
-- please specify what it means.
ANSMER:
(a)
Not applicable (b)
The term could mean any or all of these examples.
57-C-10-6(a)
Were any differences between (i) wartime nuclear emer-gency conditions (ii) nuclear weapons fallout conditions, and likely conditions for a serious accident at the Harris nuclear plant, con-sidered in the sheltering effectiveness estimates made for structures at the Harris EPZ?
(b)
Please specify each such di.fference and how it was considered.
Please identify al.1 documents concerning the ef-fect of each difference on the Protection Factor (PF) or sheltering effectiveness for structures or any specific structure (s) within the Harris EPZ.
(c)
What account of infiltration of (i) radioactive gases (ii) radio-active particles, with incoming air, is taken in (aa) the sheltering effectiveness or PF estimates you now possess (bb) sheltering effec-tiveness or PF estimates for use in connection with a nuclear accident at the Harris plan?
If there is no difference, or the estimates are the same, please say so.
(d)
How long is the maximum sheltering time for a nuclear accident at Harris?
(e)
If you don't know a maximum sheltering time that might be required due to a nuclear accident at Harris, either (i) for the EPZ as a whole, (ii) for any part of the EPZ, or (iii) for any structure (s) or areas within the EPZ, please explain all reasons why you don't know.
(f) What is the maximum sheltering time that has been considered (i) for the entire EPZ (ii) for any part(s) of the EPZ -- please specify which parts (iii) for any structure (s) or specific location within the -.
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a e.
4
.EPZ -- plea'se specify which structure (s) cr specific locations.
'(e) Do any PF. estimates forfstructues within the Harris EPZ assume any sealing of air pathways (i) into the structure (ii) into shelter-If so, please describe what sealing-2 ing areas within'the structue?
is assumed, what materials are needed to do this sealing, the avail-ability;of.those materials at the structure, and the additional pro-ltection assumed or calculated or believed to result from such sealing.
l (see (e).
-(f)~How long can occupants of'any sealed area or structure above) stay in shelter without exhausting their air supply?
Have you made;any calculations or estimates for-any structures within the Harris of (1) air L
.EPZ? (g) Do you'know anything about the infiltration rates (ii) particles, including particles of the size and characteristics of
~
radioactive particles that might be released from Harris during.a
-nuclear: accident (iii) radioactive gases, into structures within the Harris EPZ or any such structure or structures?
If so, how do such in-filtration rates affect the radiation doses likely to be received by Please detail all basis, persons sheltering.within those. structures?
-documentary or.otherwise, for your answers.
i ANSWER:
57-C-10-6(a)
Unknown (b) Not applicable (c) Unknown (d) About three days (e) Not applicable (f)(i) two or three days (ii) two or three days
'(iii) approximately three days for any structure generally.. We have 2
no information on specific structures (e) (i) Unknown (ii) Unknown (f)1 Unknown._No (g) (i) No (ii) No (iii) No n
Where are " protection factor categories" as used in your 57-C-10-7 (a) defined or explained?
. assessment of PFs for-structures within the EPZ, Do'you have any.information about the specific PFs within each (b)
(c) If so, what is that category,' for structures within the Harris EPZ?.Please identify all documents cont
- information?-
- ANSWER:
57-C-10-7 (a) Unknown (b) No. (c) Not applicable.
Is this all the infor-57-C-10-8(a) Refernto your answer to 57-c-10-3-e.
(b) Does l _
mation you have about typical housing within the Harris EPZ?
section 4.5.2 of the on-site emergency plan contain some seven lines f(about_4 sentences) concerning housing within the Harris EPZ?
(c) Why l;
'is this information in the on-site plan, but not in the off-site plan?
Are.the PFs reported there based on any typical house shape or (d) characteristics?
(e) Please identify all documents that concern, or ex-l
. plain, how the PFs in section 4.5.2 of the Harris on-site emergency p an-Please answer 57-e-10-3-e again f
were calculated for typical housing.
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 were calculated, including base data used, used, and all assumptions used or made in the cal-calculation method (s)
Please also explain who did the calculation of these PFs and culation.
Do the PFs of Harris on-site plan section 4.5.2
-why it was done.
(g)
-take into account the effects of (i) radioactive gases (ii) radioactive 5: l-
tr 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:
57-C-10-8 (a) - Not applicable (b) Yes (c) Unknown (d) apparently (e) Unknown (f) UnXnown (g) Unknown.
5 7-C 9'(a )
How much space is considered to be space for one shelteree?
Is this amount of space different for small children for babies, for the ill or infirm?
If so, how does it differ for different people?
(b)
How long are persons assumed to be able to, remain in shelteree spaces within the structures in thW Harris EPZ?
Is food provided in buildings within the Har,ris EPZ that'are fallout shelters?
Is that food in edible condition?
Is there drinking water stored in or hear high-PF areas'of structores in the Harris EPZ? ~Has it been verified to be drinkable?
If so, when?
(most recent date or time if known).
How long can shelterees be expected to stay 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?
ANSHER:
57-C-10-9 (a) 40 square feet--adjusted upwards for special cases.
(b) several days.
Unknown.
Unknown.
Unknown. ' Unknown.
Not applicable (i) Unknown (ii) Unknown.
Unknown.
Unknown.
57-c-10-10 (a)
How are ventilation systems, e.g.
(i) heating (ii) cooling (iii) ventilation w/o heating or cooling, considered in assessing the PF of (aa) buildings (bb) houses (cc) apartments (dd) other structures, within the Harris EPZ?
How long can such systems be turned off during sheltering?
(b) How long can heating systems remain off for sheltering on cold nights (e.g. freezing temperatures, within winds of 10 mph or more)1before adverse effects on shelterees (i) occur (ii) may jeopardize people's willingness to stay ins heter?
(c) How long could cooling systems be turned off, with persons packed into shelteree spaces, on a before ad-hot summer day (e.g. temperatures in the 90s, high humidity) verse effects on shelterees () ' occur (ii) jeopardize people's willingness to remain in: shelter?
(d) How long can external ventilation be turned off during sheltering be? ore adverse effects on shelterees occur?
(e) from Please describe any adveIse effects to shelterees that may result turning off of heating, or cooling, or ventilation systems during shelter-inc.
Please also describe how (if at all) such effects are considered with respect to structures in which such effects are considered with re-spect to structures in which persons in the Harris EPZ might be asked to take shelter during a nuclear accident.
Please identify all documents concerning (i)' adverse effects of having heating, or cooling, or venti-lation, systems turned off during sheltering (or, in genral); (ii) con-sideration of heating, cooling or ventilation with respect to structures in the Harris EPZ in which people might shelter: (iii) degree of adverse.
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offects under which people may leave shelter during a nuclear power
. plant. accident,.or-the difference between such conditions and the conditions under which people may leave shelters during a military nuclear emergency or nuclear war or nuclear bomb fallout situation; (iv) degree of adverse effects which would likely cause people to leave a shelter during a nuclear power plant accident. (f) Does shelter offectiveness analysis always assume ventilation is off?
ANSWER:
57-C-10-10(a) through (f) Unknown.
57-C-10-ll (a ) How are construction techniques relating to the air tightness of walls, ceilings, floors, windows and doors considered in determining the sheltering effectiveness of structures within the Harris EPZ?
(b)
Have any direct measurements of the air tightness of con-struction of such structures been made, e.g. with blower doors or other air-infiltrati.on measuring equipment?
(c)
Please identify all documents concerning the matters inquired about in (a) and/or (b) above, particu-larly including
- estimates or measurements of the specific air-tightness of construction of structures within the Harris EPZ.
(d) Why were food stores eliminated from consideration in the surveys of sheltering ef-fectiveness of structures within the Harris EPZ?
(e) Are food stores considered less safe shelters than other structures of similar con-struction.
ANSWER:
57-C-10-11 (a ) through (e) Unknown.
57-C-10-12(a) Have any formal shelter location sketches been made for any structures within the Harris EPZ?
(b) Please identify all documents containing shelter location sketches, formal or informal, for any structures within the Harris EPZ.
Please identify any document showing such areas within any such structure.
ANSWER:
57-C-10-12(a) through (e) Unk nown 57-C-10-13-3(a) Is your answer to 57-C-13-1 complete, e.g. with respect to parts (g) and (h)?
If not,-please provide answers.
(b) what (i) medical supplies (ii) toilet facilites, are available in high-PF areas within hospitals or nursing homes within the Harris EPZ?
(c) Why haven't "best" PP 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:
57-C-1-13-3(a) Yes (b) through (d) Unknown.
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t 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 Estimates (ETE) which the state or county emer-gency planners are aware of?
(b) Have any factors, such as increased been con-sensitivity of ill or elderly persons to radiation exposure, sidered in'PF determinations for hospitals or nursing homes or other care facilities within the Harris EPZ?
3 ANSWER:
57-C-13-4 (a ) Unknown (b) Unkc,own.
30-3(a) With respect to your answer to 30-2 (d), are there any places in the Harris erergency response (o f f-site) plan where specific quantities of KI or other radioprotective drugs are mentioned?
(b)
Are you aware of any reports, or recent declarations of policy or resolutions of health-profession associations, which address the de-sirable availability of KI or other radioprotective drugs during radiological e'mergencies?
Please identify all documents containing
< reporting on such reporte, resolutions or policies. (c) How, if at all,'do-the reports, declarations or policies you identify in response to (b) above (or what you were asked to identify in (b) above), affect your answers to 30-2(a) and 30-1 cubparts (b) thru (i)?
ANSWER:
30-3 (a) No (b) No (c) Not applicable.
30-4 (a) Have you made any evaluation of the Harris Emergency Response Flan's plans for distribution of KI, as far as its compliance with NUREG-0654 or other applicable guidance is concerned?
(b) Please iden-tify all documents relating to such evaluation (s), the applicable guidance, and the results of each such investigation.
(b) Do you plan to make any such investigation?
If so, when?
When do you expect to complete this investigation?
ANSWER:
30-4 (a): Yes (b) North Carolina Emergency Response Plan, NUREG-0654; We the FEMA /RAC evaluation indicates the plan provisions are adequate.
understand that the actual distribution plan is being prepared at this time by the State Division of Health Services.
(c)
FEMA will further evaluate the iuplementation of this plan during the December exercise.
30-5(a)
Are there any applicable FEMA or NRC guides for any of the items inquired about in 30-1(b) thru (i)?
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:
30-5 (a) There are no specific FEMA guidelines for these items, only the general criteria mentioned in the response to 30-1(a) through (g) and Interrogatory 1. l
- g.
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 inquired about in (a) or (b) above.
Please tell for each the matter (s) it relates to.
ANSWER:
30-6 (a) Unknown (b) (i), (ii) same as for Harris (c) Plans for each of the sites mentioned.
PRODUCTION OF DOCUMENTS Wells Eddleman hereby requests that the original or best copy of each document identified in response to interrogatories above or below be produced ~for. inspection and copying at a mutually agreeable time and place.
The below subscribed persons hereby affirm, subject to penalty of
~
perjury, that they have answered the Interrogatories of Intervenor Nells Eddleman as identified below.
The answers are true and correct to their best knowledge and belief as are also the attached statements of professional qualifications.
r GJ I.. \\
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s _n I.~
Thomas I. Hawkins'9/7/sT Dated at Atlanta, Georgia this day of September, 1984.
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