ML20101E873

Statement of Matl Facts as to Which There Is No Genuine Issue

ML20101E873
Person / Time
Site:	Harris
Issue date:	12/21/1984
From:	Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20101E870	List: ML20101E867 ML20101E873 ML20101E881
References
OL, NUDOCS 8412260430
Download: ML20101E873 (3)

Text

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6 D:ccmbsr 21,, 1984.,

1 UNITED STATES OF AMERICA ,

DONcYO USIIR NUCLEAR REGULhTORY COMMISSION BEFORS THE ATOMIC SAFETY AND LICENSING BOARD ,. BEC 24 '410:3 c

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s. v In the Matter of ) '

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CAROLINA POWER & LIGHT COMPANY

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and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY ) -

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(Shearon Harris Nuclear Power )

Plant) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH TIIERE IS NO GENUINE ISSUE TO BE HEARD ON CHANGE-17 Pursuant to 10 C.F.R. S 2.749(a), Applicants state, in support of their Motion For Summary Disposition of CHANGE-17, that there ie no genuine issue to be heard with respect to the following material facts:

1. The " Safety Information" brochure (for distribu-tion througbout the plume EPZ prior to fuel load, and annu-ally thereafter) will include a special needs response c_ d, to elicit information identifying hearing-impaired members of the public. Pugh Affidavit, 1 3.

2. The completed response cards will be analyzed by the State and the four county emergency management agencies.

The information will serve as the basis for the counties' lists of hearing-impaired persons within the EPZ, which will be updated.to reflect each new special needs card as it is received. Pugh Affidavit, 1 3.

8412260430 841221 PDR ADOCK 05000400 O PDR ,.

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3. The lists compiled from the special needs response 1 cards will be augmented with information identifying hearing-impaired persons provided b'y rescue squads, fire de-partments, social service agencies and health care providers

'in the four-county area. Puga Affidavit, 1 4.

4. The list of hearing-impaired persons in the EPZ will be completed prior to fuel load, and will be updated annually and with the receipt of each new special needs card. Pugh Affidavit, 1 24.

5. The current lists of hearing-impaired persons will be maintained in county EOCs, sheriffs' offices, fire sta-tions, and ambulance service and rescue squad headquarters, and will therefore be readily available to notification per-sonnel in the event of an emergency. Pugh Affidavit, 1 5.

6. The fixed siren system will serve as the primary public alerting system in the event of an emergency at the

!!arris plant. However, in all four counties within the EPZ, vehicles will be immediately dispatched upon the activation of the fixed sirens, to provide special notification for the hearing-impaired within the'EPZ. Pugh Affidavit, 1 6.

7. As the predesignated special notification person-nel drive their assigned routes in an emergency, they will stop at'the addresses on the list of hearing-impaired per-sons, to' provide those persons with special, individual no-tification of the emergency. Pugh Affidavit, 1 6.

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81 Zones within the EPZ already have been divided into subzones within which the road mileage has been mea-sured, and -- within each zone or subzone -- county agencies have been assigned responsibility for notification of the hearing-impaired. When the list of hearing-impaired persons has been completed, each responsible agency will drive its routes to determine the amount of time needed for notifica-tion. Pugh Affidavit, 1 7.

9. Sufficient vehicles and personnel have been iden-tified to complete the notification of the hearing-impaired within 45 minutes, as prescribed in NUREG-0654, Appendix 3.

Pugh Affidavit, 11 6 n.3, 8-20.

10. Each of the four counties has identified addition-al personnel (with vehicles) who would be available to aug-ment the designated special notification personnel, if nec-essary. Pugh Affidavit, 1 21.

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11. In addition to t,se special, individual notifica-tion which would be provided, EBS television broadcasts would include " crawl messages" (lines of text at the bottom of the TV screen) to provide emergency warnings and informa-tion to the hearing-impaired members of the general public.

Pugh Affidavit, 1 23.

Respectfully submitted, Y1 L Mk Thohas A. BaxEer,'P.E. (

Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha F. Flynn Dale E. Hollar Hill Carrow' CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated: December 21, 1984