ML20101N474

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

ML20101N474
Person / Time
Site:	Harris
Issue date:	12/31/1984
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20101N466	List: ML20101N464 ML20101N474 ML20101N486
References
OL, NUDOCS 8501040044
Download: ML20101N474 (3)

Text

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[Deceinber 31,1984 uan%

UNITED STATES OF AMERICA 85 Ja -3 N0 :16 NUCLEAR REGULATORY COMMISSION OFFICE F SEUN BEFORE THE ATOMIC SAFETY AND LICENSINGBo&RDi & SERVICf.

ansNCH In the Matter of )

i )

CAROLINA POWER & LIGHT COMPANY )

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

)

(Shearon Harris Nuclear Power Plant) )

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)

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO i

GENUINE ISSUE TO BE HEARD ON EDDLEMAN 224 Pursuant to 10 C.F.R. S 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Eddleman Contention 224, that there is no genuine 1.wue to be heard with respect to the following material facts:

l 1. Eddleman Contention 224 claims that the evacuation time estimate study

("ETE") prepared for the Shearon Harris plant by HMM Associates, .Inc. violates

, provisions of the Nuclear Regulatory Commission's emergency planning rule because it does not comply with criteria in Appendix 4 to NUREG-0654 by identifying the adverse

{ _ weather frequency used.

l 2. The intent of the relevant language in Appendix 4 to NUREG-0634 is that the adverse weather condition used in the ETE occur often enough and be severe enough to

. warrant the assessment of its effect on evacuation times. Klimm Affidavit,15.

3. The adverse weather condition modeled in the Harris ETE is a heavy rainstorm l 'which results in a 25 percent reduction in roadway capacity and travel speeds within the Harris EPZ. ETE at 1-3,1-4,2-3; K11mm Affidavit,16.

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4. This adverse weather condition was selected from a number of potential adverse weather scenarios based upon a review of weather frequency and severity data presented in the Shearon Harris Final Safety Analysis Report and on discussions with state and local emergency preparedness officials. Based on information from these sources, it was concluded that the selected scenario represents a condition which is severe enough and occurs often enough to provide a reasonable frame of reference for protective action decisionmaking during adverse weather conditions. Klimm Affidavit,16.

5. Quantitative information on the historical frequency of rainfall and precipitation in the area of the Harris Plant has been collected. This information confirms that the choice of the adverse weather condition used in the ETE is appropriate from the standpoint of frequency. Klimm Affidavit,17.

6. The Harris ETE will be amended to add a new subsection and a table that will contain quantitative information on the adverse weather frequency used. With this amendment, the ETE will identify the frequency of the adverse weather condition used and thus conform with Appendix 4 of NUREG-0654. Klimm Affidavit,18.

Submitted by:

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Dale E. liollar, Esq.

Associate General Counsel i

Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 Attorneys for Applicants:

Thomas A. Baxter, P.C. -

Delissa A. Ridgway, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones, Esq.

Samantha Francis Flynn, Esq.

H. Hill Carrow, Esq.

Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517

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