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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20140A9961986-01-22022 January 1986 Responds to Eighth Set of Interrogatories Propounded by W Eddleman Re Communication Deficiency in Harnett County,Nc. Ti Hawkins Affidavit Encl.Related Correspondence ML20138R0961985-12-22022 December 1985 Responses to Applicant 851125 Emergency Planning Interrogatories & Request for Production of Documents (Third Set).Related Correspondence ML20138R1141985-12-20020 December 1985 Response to Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20138R1061985-12-20020 December 1985 Response to General Interrogatories.Related Correspondence ML20137L9851985-11-26026 November 1985 Interrogatories to NRC & FEMA on Studies,Info & Knowledge Re Contentions on Which Discovery Now Open ML20137M0031985-11-26026 November 1985 Interrogatories to Applicant & State of Nc.Certificate of Svc Encl ML20137H6291985-11-25025 November 1985 Third Set of Interrogatories Re Emergency Planning & Request for Production of Certain Documents.Certificate of Svc Encl. Related Correspondence ML20138D2761985-10-18018 October 1985 Supplementary Response to General Interrogatories 2-3 & 12-14 Re Eddleman Contention 57-C-3 Concerning Nighttime Emergency Siren Sys at Facility.Certificate of Svc Encl. Related Correspondence ML20128P8311985-05-29029 May 1985 Correction of Answer to Applicant Discovery Requests Re Interrogatories on Contention WB-3 Concerning Drug Abuse. Certificate of Svc Encl.Related Correspondence ML20128P8001985-05-29029 May 1985 Response to NRC Interrogatories Re Contention WB-3 Concerning Drug Abuse.Related Correspondence ML20128G7151985-05-24024 May 1985 Answers to Discovery Requests Re Contention WB-3 on Drug Abuse.Applicants Have Not Reinspected safety-related Work of Known Drug Abusers ML20127M8941985-05-20020 May 1985 Answers to Conservation Council Discovery Requests Re Contention WB-3, Drug Abuse During Const. Util Employee Assistance Program Provides Aid in Drug Rehabilitation. W/Certificate of Svc.Related Correspondence ML20116L1731985-05-0101 May 1985 Interrogatories & Request for Production of Documents Re Allegations in Contention WB-3,per ASLB 850315 Memorandum & Order Ruling on Contentions Re Diesel Generators,Drug Use & Harassment.Certificate of Svc Encl.Related Correspondence ML20102C3621985-03-0101 March 1985 Responses to Interrogatories & Request for Production of Documents on Contention 41-G.C Van Vo Considered to Be Well Qualified in Experience & Educ for Job.Related Correspondence ML20107D0491985-02-19019 February 1985 Response to W Eddleman 12th Set of General Interrogatories to Applicant Re Contention 41-G.Related Correspondence ML20107D0591985-02-19019 February 1985 Response to W Eddleman Request for Production of Documents Re Contention 41-G.Certificate of Svc Encl.Related Correspondence ML20106D0951985-02-0808 February 1985 Applicant Request That W Eddleman Answer Interrogatories & Produce & Permit Insp of Documents Re Contention 41-G Concerning C Van Vo Allegations.Certificate of Svc Encl. Related Correspondence ML20102A2061985-02-0404 February 1985 General Interrogatories & Request for Production of Documents Re Employment of Cv Vo.Related Correspondence ML20102A0791985-02-0404 February 1985 Seventh Set of Interrogatories & Request for Production of Documents Re Eddleman Contentions.Related Correspondence ML20101E9021984-12-21021 December 1984 Response to W Eddleman Second Round Interrogatories on 213-A to Applicant/Emergency Response Personnel & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20100G5971984-12-0303 December 1984 Second Round Interrogatories on 213-A to Applicants/ Emergency Response Personnel & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20100A5001984-11-30030 November 1984 Response to 841005 Discovery on Contention EPJ-3 (Volunteer Workers).Certificate of Svc Encl.Related Correspondence ML20099K4271984-11-26026 November 1984 Applicant Supplemental Responses to W Eddleman General Interrogatories to Applicant 11th Set.Certificate of Svc Encl.Related Correspondence ML20099D3771984-11-0909 November 1984 Response to Applicant 841005 Emergency Planning Interrogatories & Request for Production of Documents to Sponsors of EPJ-1,EPJ-4 & EPJ-5.Certificate of Svc Encl. Related Correspondence ML20107G1011984-10-31031 October 1984 Final Response to Conservation Council of North Carolina First Set of Interrogatories & Request for Production of Documents on Emergency Planning Contentions.Related Correspondence ML20107F3851984-10-31031 October 1984 Response to Conservation Council of North Carolina Interrogatories & Request for Production of Documents Re First Set of Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence 1999-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
Text
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REuTED 0:227CICENCE emne u mac t
1 September 19,198$4 SEP 24 P2:23 _
CFFICE 0 EEORETM T UNITED STATES OF AMERICA MC hhj?c[ !
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD b r
In the Matter of ) !
) I CAROLINA POWER AND LIGHT COMPANY )
) Docket No. 50-400 OL E AND NORTH CAROLINA EASTERN MUNICIPAL POWER AGENCY ) !
) E (Shearon Harris Nuclear Power Plant) ) {
t RICHARD WILSON INTERROGATORIES TO THE APPLICANT ON EPJ-5, WILSON 11, WILSON 12b2, WILSON 12b3.
GENERAL INTERROGATORIES
- 1. Please list the names and affiliations of each person [
responding to these interrogatories and the specific ones they -
respond to.
- 2. Please make each document identified in response to the -
interrogatories below available for inspection and copying. .
SPECIFIC INTERROGATORIES ,
- 1. a) Do you have 9/ nechanism for identifying non-ambulatory homebound people in the EPZ?
b) If so, how many such people are there, and what is the .
mechanism for identifying them?
c) How will new people in this category be identified as they become disabled or move into the EPZ?
d) If you do have a mechanism, how have you tested its effectiveness and accuracy?
0.
8409250398 840919 V
, PDR ADOCK 05000400 0 PDR
e). If you do not have a mechanism, are you preparing or :
planning one? Please present the current status of such a project or plan.
f) If your mechanism for identifying non-ambulatory home-bound people has not been put into effect, how can you be confident ^
that the numbers will'not overwhelm the sources of assistance? If '
you have estimated, please state the basis for your estimates. !
i 25 According to Section III F2b of the Wake Co. Plan (p 5) o
{
the Rescue Squads of Apex, Fuquay-Varina and Holly Springs will be primarily responsible for evacuating non-ambulatory people. How-
~
ever they also have other duties which might conflict with this activity. The following questions are therefore relevant. ;
i 2 Mj%D How many vehicles eads from the rescue squad, the police department, and the fire departments in each community will be re- I quired should secondary notification be necessary? How many workers i per vehicle? l i
I 1EEP) What will be the time interval following the evacuation order during which this notification will be carried out?
I
- 2) 4ew) Have you revised or are you studying the estimates of time and vehicles required for secondary notification presented in the ETE Study? If so, please present the status of your study.
2 a) How many vehicles each from the rescue squad in each community will be required for evacuating hospital and nursing home residencs? How many workers per vehicle.?
2 b) What will be the time interval following the evacuation order during which this evacuation will be carried out?
2 c) How long will one round trip from the following sites to the nearest appropriate designated shelter take? Include loading and unloading time. Include assumptions regarding traffic conditions.
- 1. ESE Sector, 9-10 mile zone
- 2. NNE Sector, 2-3 mile zone
- 3. NE Sector, 8-9 mile zone
- 4. SE Sector, 10 mile zone 2 d) How many round trips from all special facilities does each rescue squad estimate they will have to make?
3 a) What shelters and decontamination stations will, under the direction.of the Emergency Management Agency, will be operated or manned by tim Rescue Squads from Apex, Fuquay-Varina, and Holly Springs?
3 b) How many workers will be required at each of these areas?
3 c) What will be the time interval fc11owing the evacuation order during'which this activity will be performed? g 4 a) How many vehicles, workers, and hours would be required to respond fully to a serious accident with 10 seriously injured
- people and 20 less seriously injured people at the SHNPP site?
b) Which rescue squads would be involved in such assistance?
How many _ vehicles and workers from each? ;,-
s c) Please attach copies of all written agreements between [
r the rescue squads,and the Applicant for emergency service at the SHNPP site. [
V d) Based on these documents, would the Applicant expect the h rescue squads to provide all necessary assistance for an accident {
such as that described in part a above? ;.
i-
- 5. Please prioritize the 5 duties (a-e) assigned primarily '
to the rescue squads in Section III F2 of Wake County Plans (p.5).
That is, which activities would be done if there were not enough :
resources for the local squads to do them all? In addition to the p 5 duties in the plan, please include routine responses to illness and i injury in the priority list. ;
I 6.a) How will the Wake County EMS Director receive requests for ;
assistance from local squads?
b) Who will make specific eyacuation assignments to county rescue squads assisting the local squads?
i c) How will county rescue squad workers know the sites of special f acilities and non-ambulatory home-bound people?
d) Which rescue squads would be the first, second, and third areas asked by the EMS Director?
e) How many vehicles and workers from each would be available, considering other routine and special responsibilities they might have?
7.a) How many vehicles capable of transporting non-ambulatory people does the Apex, Fuquay-Varina, and Holly Springs Rescue Squads have? How,many non-ambulatory people can each vehicle carry?
b) How many members does each rescue squad have?
c) How many members from each would be availabic and would respond in case of an evacuation?
d) How many members of each squad are single?
e) How many from each squad live outside the EPZ?
f) How many from each squad work outside the EPZ?
'~
- . . , i ?
T 5
g) Have any of the squads been involved in a major emergency ,;
requiring full mobilization? 4 E
h) In your planning what percentage of the full staff of each 7 rescue squad have you assumed will be available? On what do you base -
this assumption? Please list all documents and case citations you QE-would use to support this assumption. d_
N.%
Cp, 8.a) Homebound non-ambulatory people will be scattered through- 'b out the EPZ. How long will one round trip including loading and un- i@
loading time from the following sites to the nearest designated shelter @_
take? Please include assumptions regarding traffic conditions.
$$)5 a\ _^
a) W Sector 6-7 mile zone 9,-
b) SSW Sector 6-7 mile zone @
c) NNW Sector 6-7 mile zone h$~
- ng 9.a) Who will be allowed to enter the EPZ during the evacuation? , 7.
,d-b) Will parents of children in day care be allowed to enter? ,
5.: _
c) Will parents with children at home be allowed to enter? %y-d) Will people with other f amily members or non-f amily de- ,Jf pendents (which might include mentally, handicapped, physically handi- Qi capped, elderly, or non-English-speaking people) be allowed to enter? g_
me e) Will people needing to secure their businesses be allowed Gi-to enter? 'i
[d.
f) Will emergency workers reporting for duty (still in their f/L private cars) be allowed to enter? k_
y g) Will emergency workers (rescue squad, fire, police) on duty be allowed to enter? h],y_
e.
h) Will maintenance personnel for CP&L electrical transmission Id lines, Dixie Pipelines, Southern Telephone equipment, Allied and Uni- Q O,
versal Polymer Chemical Plants, CP&L Cape Fear Plant be allowed to enter? Are these f acilities aware of this policy and have they consented (
a
- 1) For each answer above to parts b-h which is g, please Q explain why not. Q j) For each answer above which is not unequivocally YES or i@d g please explain the criteria by which decisions would be made. g Q,.
k) What training and written instructions will be given to M people at traffic check points to guide their decisions? $
g
- 1) If an official at a traffic check point wishes to make ,)
an exception, does he/she have the power to do so? If not who must Q he/she' consult?
E m)' On a map showing all traffic control points at entrances i_
to the EPZ, please show how a large number of cars trying to enter E
=
the EPZ would be diverted.
n) For each' answer to parts b-h above, please estimate the number of vehicles which will'try to gain entry. ;_
- 10. Please demonstrate your calculation that there would be 410 households in the EPZ that have no transportation. Please state f-and justify all assumptions. g
- 11. Have you revised this estimate? b 12.a) How many households in the EPZ have one car which is driven out of the EPZ to work each day? b) How many with 2 cars which h are driven out of the EPZ? ?_
O_
c) If these considerations raised the percentage of house- 9 holds without vehicles from 5.57. (410/7347) to 307. or 507., would [
ride-sharing with neighbors be adequate to evacuate the population? !
Please provide an explanation of your answer and document your assump--- L[
tions.
?
d) Were these considerations investigated furing the prepara- !
?
tion of the Evacuation Time Estimates? If not, why not?
I e) If ride-sharing were not adequate, who would decide when and where pick-up points would be established? What criteria would i be used to make the decisions?
13.a) How many households in the EPZ have one car which is driven to work in the EPZ?
b) Does the NETUAC simulation include the " counter-current" flow of traffic of these vehicles trying to reach home?
c) Will traffic control points permit " counter-current" flow t during the evacuation?
i d) The time required for travel from work to home was not explicitly mentioned in the ETE. Was it considered? ;
t e
. . . . ,