ML20100A500
| ML20100A500 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/30/1984 |
| From: | Runkle J CONSERVATION COUNCIL OF NORTH CAROLINA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#484-412 OL, NUDOCS 8412030621 | |
| Download: ML20100A500 (7) | |
Text
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November 30, 1984 UNITED STATES OF AMERICA Z 7' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINO BOARD j g 3 l'j ;77 In the Matter of
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Carolina Power &. Light Company
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Docket No. 50-400 OL And North Carolina Eastern Municipal
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Power Agency
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(Shearon liarris Nuclear Power Plant)
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CONSERVATION COUNCIL'S RESPONSE TO DISCOVERY ON EPJ-3 (VOLUNTEER WORKERS)
On October 5,1984, Applicants filed discovery requests to the sponsors of combined energency planning contentions, including Contention EPJ-3 (Volunteer Workers).
In its August 3, 1984, Order and Rulings, the Board designated the Conservation Council as lead intervenor for EPJ-3 and at the same time combined several other contentions by other intervenors into EPJ-3.
Please contact us for any clarification or other assistance regarding these responses.
General Interrogatories 1(a). This will be included in the responses to the specific interrogatories.
(b). See response to 1(a).
(c). See response to 1(c).
2(a). This will be inicude in the responses to the specific interrogatories.
(b). See response to 2(a).
3(a). Unknown at this time.
(b). Any expert called will tastify to EPJ-3.
(c). See response to 3(a).
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S O t h
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Page 2 4(a). This will be included in the responses to the specific interrogatories.
(b). Each document relates to EPJ-3.
(c). See response to 4(a).
5(a). This will be included in the responses to the specific interrogatories.
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(b). See response to 5(a).
d 6(a). This will be included in the response to the specific interrogatories.
(b). See response to 6(a).
7(a). The docunents to be used on direct examination will be provided at the time prefiled testimony is due. Cross-examination documents, unless 1
needed only to impeach witnesses and similar uses, will also be provided when direct testimony is due.
l (b). See response to 7(a).
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Specific Interrogatories i
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EPJ-3-1(a). The contention refers to all volunteer workers needed to respond to an alert, which includes firemen, policemen, rescue squads, hospital workers, i
ambulance drivers, redact teams, teachers, bus and taxi drivers, support services, other county, state, and J
.ivil defense workers, and/CP&L workers expected to work beyond their job
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descriptions.
Your response to our interrogatory 3-5 states that a detailed breakdewn is not available at this time so several groups may need to be added I
l to the above when such a list is available.
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(b). See Further Actions Needed to improve T.mergency Preparedness Around Nuclear Powerplants (CA0/RCED-84-43, August 1, 1984): " Testimony before the 2
j Suffolk County Legislature Regarding Emergency Planning for the Shoreham 1
l Nuclear Power Station" by Kai Erikson, Ph. D, Professor of Sociology, Yale
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l University (January 24, 1983) and testimony given before the Licensing Board
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Page 3 in the Shoreham Nuclear Power Plant. Dr.Erijson'saddressisPOBox1902A Yale Station, New Haven, Connecticut 06520.
I EPJ-3-2. The Board inserted the 507. figure in formulating the combined contention.
In studies conducted by Dr. Erikson (see response to EPJ-3-1(b) above), 687. of firemen and 697 of bus drivers stated that they would make certain that their i
families were safely out of the evacuation zone before they would report for duty in the case of a nuclear accident.
EPJ-3-3. None of the groups in EPJ-3-1 have been called upon to volunteer for 4
an emergency around a nuclear power plant that we are aware of.
Other emergencies of similar size and complexity of evacuation or emergency around a nuclear power plant have not occurred in the EPZ that we are aware of.
See Dr. Erikson for
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responses by similar groups.
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j EPJ-3-4(a). We are not able to do this as a list of each role to be filled l
is not available (see your response to our interrogatory 3-5).
Volunteers may l
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be called on to fill any one of the off-site roles during an emergency. Again, r
see Dr. Erikson for the number which would see to their families and other l
commitments before filling their role.
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(b)(1).See the response to EPJ-3-2 above.
(ii).A reduncancy of between I
4 to 5 times the needed personnel would be adequate to fill roles needed at the beginning.
l EPJ-3-5.
The primary training will occur during the drills and exercises l
l held annually or bisnnually as the case may be.
Only a limited number of the volunteers needed to successfully implement the response will participate in these exercises. The Plan states that "any county or municipal agency, department, or organization nay be tasked with an emergency mission" (Part 2,
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- p. 3; Part 3, p. 3; Part 4, p. 3; Part 5, p. 3) and to provide personnel on a twenty-four hour basis. There night be other training programs available for some of the workers.
i EPJ-3-6(a). Yes, j
(b). Exericises on a periodic basis (annually or biannually) cannot I
adequately train all personnel which are needed (see citation to Plan in response to EPJ-3-5 above). The exercises are also not designed to train j
any one worker for the different he or she may need to fill. Other workers s
which may not have been available for the exercise (such as becoming a volunteer firenan af ter the last exercise) cannot receive training until the next exercise. Likewise not all of the volunteers will participate in other j
i training programs for the same reasons as above.
1 EPJ-3-7.
See Dr. Erikson (citation in response to EPJ-3-1 above).
a EPJ-3-8.
Applicants need to incorporate into the Plan a systematic assessment of the following (a) compile a list of the roles that volunteers will need to fill l
during an emergency; I
(b) survey all agencies and organizations which will supply the volunteers l
to determine availability of volunteers and training needed; l
(c) compile a list of individuals who may be called on to volunteer during an emergency with addresses, phone numbers, whether they or their families work or go to school or live in the EPZ; (d) survey the individuals in (c) above to determine if they will go promptly to fill their role when called upon.
EPJ-3-9.
The following additional steps should be followed to assure adequate i
r coverage by volunteers of roles they need to fille j
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i' (a) Designate a volunteer coordinator; (b) Hold more frequent exercises, ranging in scope from one agency's role
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i to the full-scale FEMA field exercise;
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(c) Giva individuals the option whether they want to be called upon in l
l a radiological emergency (this would cut into the pool of volunteers but would make response rates higher);
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j (d) Design and conduct training programs for all possible volunteers, to J
be lead by outside experts as well as CP&L employees; I
i (e) Make certain that key roles (which should be so designated) are filled 1
with trained professionals, and others are backed up with redundancy.
EPJ-3-10.
See response to EPJ-3-9 above.
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EPJ-3-11.
See response to EPJ-3-1 through EPJ-3-10.
Teachers were included
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d in the groups of volunteers.
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EPJ-3-12.
To the best of our knowledge, teachers have not been called upon l
this role in emergencies around nuclear power plants in North Carolina. Other I
emergencies do not require teachers to fill this role.
Dr. Erikson (see response I
to EPJ-3-1) discusses evacuation in Ottowa, Canada, over a twenty hour period.
Any listing of individual teachers who have not or would not abandon their i
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l property or families is not relevant at this time; we may at the hearing call I
j teachers who would refuse to full this role during an radiological enerrency.
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I EPJ-3-13. We would look to Dr. Erikson's studies for response rates for similar personnel in other places.
r EPJ-3-14 None.
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I EPJ-3 15(a). See response to EPJ 3-8 and -9 above.
(b). See response to EPJ 3-8 and -9 above.
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Page 6 EPJ-3-16.
See responses to EPJ-3-8 and -9 above.
EPJ-3-17.
See responses to EPJ-3-8 and -9 above. Further, alternatives to using teachers in this role must be considered.
Request for Production of Documents We will produce documents or copies of them to any party, at a place mutually convenient to the parties. Copying naterial of excessive length will be at the requesting party's expense.
t Respectfully submitted, f '[t) Y M John Runkle 1
v General Counsel i
Conservation Council of North Carolina 307 Granville Road Chapel Hill, NC 27514 919/942-7935, 942-0600 i
This is the 30th day of November, 1984.
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CERTIFICATE OF SERVICE I hereby certify that copies of the Conservation Council's Response to Discovery on EPJ-3 (Volunteer Workers) were served on they following persons by deposit in the U. S. Mail, postage prepaid, or by hand-delivery.
James L. Kelley Richard E. Jones Atomic Safety & Licensing Board Dale llollar US Nuclear Regulatory Conmission Legal Department Washington, D.C.
20555 Carolina Power & Light PO Box 1551 Clenn O. Bright Raleigh, NC 27602 same address Robert Gruber Dr. Jancs 11. Carpenter Public Staff, Utilities Commission same address PO Box 991 Docketing and Service (3 cc.)
Office of the Secretary Thomas Baxter US Nuclear Regulatory Commission Delissa A. Ridgway Washington, D.C.
20555 Shaw, Pittnan, Potts A Trowbridge 1800 M Street, N.W.
Charles A. Barth Washington, D.C.
20036 Office of the Executive Legal Director US Nuclear Regulatory Conmission Dr. Linda Little Washington, D.C.
20555 Governor's Waste Management Reard 325 North Salisbury Street, hoom 513 Daniel F. Read Raleigh, NC 27611 PO Box 2151 Raleigh, NC 27602 M. Travis Payne PO Box 12643 Raleigh, NC 27605
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Dr. Richard D. Wilson "c
729 Hunter Street John Runkle Apex, NC 27502 Conservation Council of NC 307 Granville Road Vc,la Eddleman Chapel Hill, NC 27514 718 A Iredell Street Durham, NC 27705 Bradley W. Jones Thisisthe30thdayofNovember, US NRC.-Region 11 1964*
101 Marrietta Street Atlanta, CA 30303 Spence W. Perry Associate Cenoral Counsel FEMA 500 C Street, S.W., Suite 480 Washington, D.C.
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