ML20108E952
| ML20108E952 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/29/1984 |
| From: | Carrow H CAROLINA POWER & LIGHT CO. |
| To: | |
| References | |
| CON-#484-851 OL, NUDOCS 8411020061 | |
| Download: ML20108E952 (14) | |
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000ETrn Octoboc129,1984 UNITED STATES OF AMERICA W EV -1 N0 :25 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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AND NORTH CAROLINA EASTERN
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Docket No.
50-400 OL MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power Plant)
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APPLICANTS' RESPONSE TO [CHANGM EMERGENCY PLANNING INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS
[ON CONTENTIONS EPJ-1, EPJ-2 AND EPJ-41 Applicants Carolina Power & Light Company ("CP&L") and North Carolina Eastern Municipal Power Agency, pursuant to 10 C.F.R. S 2.740b, hercoy submit the following responses to (CHANGS " Emergency Planning Interrogatories and Request for Production of Documents" [on Contentions EPJ-1, EPJ-2 and EPJ-4]. The provision of answers to these interrogatories is not to be deemed a representation that Applicants consider the information sought to be relevant to the issues to be heard in this proceeding.
_GENER AL INTERROG ATORIES Responses to these general interrogatories shall be given for each contention, along with the responses to each specific interrogatory.
(1) State the name, present or last known address, and present or last known employer of each person known to Applicants to have first-hand knowledge on which the responses are based, for each of the contentions which are the subject of this set of interrogatories.
ANSWER: The following list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Contentions EPJ-1, EPJ-2, and EPJ-4, and indicates the particular interrogatory answers for which such person provided information:
8411020061 841029 PDR ADOCK 05000400 0
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. Respondent Response Number Robert G. Black, Jr.
EPJ-4-1 through EPJ-4-5 Carolina Power & Light Company Post Office Box 1551 Raleigh,' North Carolina 27602 Bryan D. McFeaters EPJ-1-1(1) to (5); EPJ-1-2; EPJ-1-4 Carolina Power & Light Company Post Office Box 1551
- Raleigh, North Carolina 27602 Robert D. Klimm EPJ-1-1(6) to (8); EPJ-2-1 HMM Associates 336 Baker Avenue Concord, Mass. 01742 Lloyd Hancock EPJ-1-3(a) and (b)
Carolina Power & Light Company SHNPP' Box 165 New Hill, North Carolina 27562 Carolyn Anderson EPJ-2-2 Carolina Power & Light Company -
Harris E&E Center Box 327 New Hill, North Carolina 27562 M.C. Adams EPJ-1-3(c)
North Carolina Department of Transportation Highway Building Raleigh, North Carolina 27601 W.M. Murray EPJ-4-6
' Wake County Schools 601 Devereaux Street Raleigh, North Carolina 27605 P. Harrison EPJ-4-6 Chatham County Schools t
Pittsboro, North Carolina (2)
Identify those facts concerning which each such person has first-hand knowledge.
[i-ANSWER: See Answer to Interrogatory (1).
(3) State the specific basis or facts which support each response. To the extent that Applicants rely solely upon documents for their response (s), please indicate the documents by their title, date, author, and location. Please identify also relevant page citations.
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ANSWER: All facts or documents relied upon by those individuals identified above are as indicated within each response to the specific interrogatories on Contentions EPJ-1, EPJ-2 and EPJ-4.
(4) State the name, present or last known address, and present or last known employer of each person who provided information upon which Applicants relied in answering each interrogatory herein.
ANSWER: See Answer to Interrogatory (1).
(5) Identify all such information which was supplied by each such person and the specific interrogatory response in which such information is contained.
ANSWER: See Answer to Interrogatory (1).
(6) State the name, address, title, employer, and educational and professional qualifications of each person Applicants intend to call as an expert witness or as a witness relating to.any contention which is the subject of this set of interrogatories.
ANSWER: Applicants have not yet identified the expert or other witnesses they expect to callin this proceeding regarding these contentions. When and if such witnesses are identified, Applicants will supplement the response in a timely manner.
(7)
Identify the contention (s) regarding which each person identified in interrogatory (6) is expected to testify, and the subject metter as to which each such witness is expected to testify.
ANSWER: See Answer to Interrogatory (6).
(8) Identify all documents in Applicants' possession, custody or control, including all relevent page citations, pertaining to the subject matter of, and upon which the Applicants relied in formulating responses to, each contention which is the subject of this set of interrogatories.
ANSWER: Such documents, if any, are contained within Ar 2 cants' responses to each contention.
(9)
State the specific response to each contention or interrogatory which Applicants contend each document supports.
ANSWER: The response supported by each document is indicated within Applicants' responses to each contention.
(10) Identify all documents in Applicants' possession, custody, or control, including all relevant page citations, upon which Applicants relied in answering each interrogatory herein.. -.
' ANSWER: Such documents, if any, are contained within the responses to specific
- interrogatories.
-(11) --Identify.all other sources of information, not identified in responses to General Interrogatories ' 5, 8, and 11 herain, which were used in answering each interrogatory herein.
ANSWER: Applicants have identified all other such sources of information, if any, within the answers to the specific interrogatories set forth herein.
(12) Identify all documents which Applicants intend to offer as exhibits during this
. proceeding to refute contentions which are the subject of this set of interrogatories.
-ANSWER: Applicants have not at this time identified exhibits, if any, which they
' intend to offer to refute contentions which are the subject of this set of interrogatories.
SPECIFIC INTERROG ATORIES INTERROGATORY NO. EPJ-1-1: Identify all studies or examinations of snow and ice conditions in the area around the Shearon Harris plant Applicants have conducted or considered in assessing the effect of inclement weather on the plant, evacuation times, traffic around the plant, shutdown analyses, or shift changes.
ANSWER EPJ-1-1: The following documents were utilized for analysis in FSAR Section 2.3.1 and include information regarding snow and ice conditions:
Its Meteorology and Climatology, Geographical (1)
- Bennett, I.,
" Glaze Distribution, and Economic Effect," Headquarters Quartermaster Research and Engineering Command, U.S. Army, Natick, Mass. Tech. Rep. EP-105,1959.
(2) '"Climatography of the United States No. 60, Climate of North Carolina," U.S.
Department of Commerce, National Oceanic and Atmospheric Administration, National Climatic Center, Asheville, North Carolina, Reprinted July 1978.
'(3) ~ Cimrlotte, North Carolina,1978, " Local Climatological Data, Annual Summary -
with Comparative Data," National Oceanic and Atmospheric Administration, National Climatic Center, Asheville, North Carolina.-
-(4)
Greensboro, North - Carolina, 1978, " Local ' Climatological Data, Annual Summary. with ' Comparative Data,"
National Oceanic and Atmospheric Administration, National Climatic Center, Asheville, North Carolina.
(5)
Raleigh-Durham, North Carolina,1978, " Local Climatological Data, Annual Summary with Comparative Data," National Climatic Center, Asheville, North
' Carolina.
Development of the evacuation time estimate utilized the following studies, in addition, to examine the effect of adverse weather on evacuation times:
(6)
The Environmental Influence of Rain on Freeway Capacity, E. Roy Jones and Merrell E. Goolsby, Highway Research Record No. 321, Highway Research Board,1970.
(7). Headway Approach to Intersection Capacity, Donald S. Berry and P. K. Gandhi, Highway Research Record No. 453, Highway Research Board,1973.
(8)
Interim Materials on Highway Capacity, Transportation Research Circular No.
212, Transportation Research Board, January 1980.
INTERROGATORY NO. EPJ-1-2: Identify any data compilations Applicants have considered in assessing or predicting the effect of inclement weather on any of the activities / subjects described in EPJ-1-1.
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ANSWER EPJ-1-2: References 1-5 listed in response to EPJ-1-1 are applicable to this question, as well as the following:
' (1)
"Climatography of the United States No. 82-31 Decennial Census of United States Climate - Summary of Hourly Observations,'Raleigh, North Carolina 1951-1960" 1963, U.S. Department of Commerce, Washington, D.C.
(2)
" Local Climatological Data - Annual Summary With Comparative Data,
- Raleigh, North Carolina,"
1983, National Oceanic and Atmospheric Administration, Asheville, North Carolina.
INTERROGATORY NO. EPJ-1-3:
Identify all snow, ice, or other removal equipment (a) at the plant site,(b) within one mile of the plant,(c) upon which Applicants rely to keep roads to the plant open under non-accident conditions.
ANSWER EPJ-1-3(a):
At the SHNPP site, CP&L presently has the following construction equipment which can be utilized for snow removal:
Motor grader-Gallion T500M Front-end loader-rubber tire-International 520B Front-end loader-rubber tire-International 530 2 Crawler loaders-big bucket, Crawler Caterpillar crawler-T14 Caterpillar crawler-T39 Dump trucks ;
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y (b) The only major development within this area is the SHNPP itself; therefore, the equipment noted in (a) above is stored within one mile of the plant.
(c) The North Carolina Department of Transportation maintains twenty-five pieces of equipment which consist of tandem trucks, motor graders, and dump trucks. All dump trucks have plows, while the tandem trucks have both plows and salt spreaders.
INTERROGATORY NO. EPJ-1-4: How do Applicants understand " severe snow and ice conditions" as stated in the contention?
ANSWER EPJ-1-4:
Applicants understand " severe snow and ice conditions" ~as stated in the contention to mean "anything more than 1/2 inch of snow in a 24-hour period" as indicated by Intervenors in their response to Interrogatory EPJ-1-1(a).
INTERROGATORY NO. EPJ-2-1: Identify all studies or other reports, publications, or data known to Applicants which provide information or guidance on problems of identifying, notifying, and providing transportation for people without cars in accident or disaster situations.
ANSWER EPJ-2-1:
(1)
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654, FEMA-REP-1, Rev.1, November 1980.
(2)
Envirosphere Company, " Detailed Report on the Evacuation of December 11, 1982," November 1983.
(3)
- Perry, R., M. Lindell, and M. Green, " Evacuation Planning in Emergency Management," 1981, Lexington Books.
(4)
Hans, J., and T. Sells, " Evacuation Risks - An Evaluation." EPA-520/6 002, June 1974.
INTERROG ATORY NO. EPJ-2-2:
Identify all studies or examinations of the number and location of people without cars Applicants have undertaken or are aware of with respect to evacuation from the area around the liarris plant in an emergency.
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ANSWER EPJ-2-2:
'Ihe Applicants' tr st recent study relating to the number of s
households / people without vehicles used (1) data from the U.S. Department of the Interior, Bureau of the Census,. Census of Population and Housing,1980 and (2) data published in CP&L's "Demographie Data for the Shearon Harris Nuclear Power Plant (SHNPP) Evacuation Time Estimate Report," Rev.1. The study statistically estimates the distribution and number of households / people without vehicles under the following situations:
(1)
Everyone at home.
(2)
Normal workday with day shif t at work and school children at school.
(3)
Normal workday with day shift at work and school children at home.
INTERROGATORY NO. EPJ-4-1: Have Applicants undertaken to identify school bus drivers 18 years of age or younger? If the answer is other than "no", please produ:e results of any such efforts. (For this and all other questions relevent to EPJ-4, the questions refer to the 10-mile EPZ area unless otherwise specified).
ANSWER EPJ-4-1: Two counties, Wake and Chatham, have school facilities within the 10-mile EPZ, and the Applicants have contacted school officials in these counties.
Bus drivers in Wake County provide their date of birth to school officials. In Chatham County, bus drivers indicate if they are currently high school students. Applicants have no information concerning the identities of individual drivers.
INTERROGATORY NO. EPJ-4-2:
Identify all studies or other evaluations Applicants have made concerning the necessity for school buses to make more than one trip during normal and emergency conditions.
ANSWER EPJ-4-2:
The principal study performed by the Applicants is the Evacuation Time Estimate (ETE). Section 6.2.5 of the ETE describes the assumptica concerning the numbers of school buses needed.
Applicants' subsequent informal discussions with school officials and with emergency planning authorities continue to confirm this assumption that it will not be necessary for school buses to make more than one trip in an evacuation. L
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s INTERROGATORY NO.'EPJ-4-3: _ Identify all provisions Applicants have made, or
- are aware have been made, for the availability of extra buses to transport school children in an emergency situation, (a) including accidents at the Harris plant and (b) including other disasters, emergencies, acts of war, or of God.
ANSWER EPJ-4-3:
(1)
'Ihe Apolicants are aware that emergency preparedness officials in Wake and Chatham Counties have identified a sufficient number of extra buses available
' for use in the event of an emergency at SHNPP.' Detailed plans for provision of the extra buses are now under development.
(2)
'Ihe - Appilcants have not investigated the availability of buses for other disasters, emergencies, acts of war, or of God.
1 INTERROGATORY NO. EPJ-4-4: Identify all provisions, other than those in the Emergency-Preparedness Brochure, Applicants have made, or are aware of, to notify parents of school age children that they should not pick up their ch4dren at schools in the event of an evacuation. Identify all provisions made, by Applicants or others, to ensure that parents of school age children will not pick up their children at school in the event of an evacuation.
ANSWER EPJ-4-4: The Applicants are aware that, in addition to the instructions to parents contained within the Emergency Preparedness Brochure, the EBS
. announcements will also advise parents that school children are being evacuated to identified shelters and that they should not attempt to pick up their children at school.
To further assure that parents are appropriately informed, the Applicants have approached public and private schools within the EPZ offering to provide programs to parent / teacher organizations on emergency planning topics, such as protective action
- plans for school children.
i INTERROGATORY NO. EPJ-4-5: Identify all studies Applicants have made, used, f
or are aware of which deal with the general problem of parents picking up school children in an evacuation situation or other similar emergency situation.
ANSWER EPJ-4-5: Other than the information discussed in response to EPJ-4-4, i
the Applicants are not aware of any studies dealing with general problems, if any, of parents picking up school children in an evacuation situation or other similar emergencies.
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INTERROGATORY NO. EPJ-4-6: Identify any parental authorization currently required for bus drivers under age 18 to operate school buses in the event of an emergency.
ANSWER EPJ-4-6: The written authorization of the parents of the student drivers is neither required by State law nor requested by Wake and Chatham County school officials.
This the 27 day of October,1984.
Hill Carrow Attorney Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6839 Attorneys for Applicants:
Thomas A. Ba:tter Delissa Ridgway Shaw, Pittman, Potts & Trowbrjdge 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn Dale E. Hollar Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517
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C0CKEFF USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *84 NOV -1 A10 :25 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD- -
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BRANCH In the Matter of.
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CAROLINA POWER & LIGHT COMPANY
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AND NORTH CAROLINA EASTERN
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Docket No.
50-400 OL MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power Plant)
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AFFIDAVIT OF B. J. FURR County of Wake-
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~ State of North Carolina
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B. J. Furr, being duly sworn according to law, depues and says that he is Vice President - Operations Training and Technical Services of Carolina Power & Light Company; that the answers to CHANGE Interrogatories on Contentions EPJ-1, EPJ-2 and EPJ-4 contained in " Applicants' Response to [CHANGld - Emergency. Planning Interrogatories and Request for Production of Documents [on Contentions EPJ-1, EPJ-2 and EPJ-41" are true and correct to the best of his information, knowledge and belief; and that the sources of his information are officers, employees, agents and contractors of Carolina Power & Light Company, and employees and agents of the State of North Carolina.
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Notary Public My commission expires:
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COM!nISSION'84 NOV -1 A10 :25 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD q,
()C"XO m 4 SEP BfMCh In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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AND NORTH CAROLINA EASTERN
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Docket No.
50-400 OL MUNICIPAL POWER AGENCY
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- (Shearon Harris Nuclear Power Plant)
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AFFIDAVIT OF B. J. FURR County of Wake
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State of North Carolina
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B. J. Furr, being duly sworn according to law, deposes and says that he is Vice President - Operations Training and Technical Services of Carolina Power & Light Company; that the answers to Interrogatories on EPJ-5, Wilson 11, Wilson 12b2, Wilson 12b3 contained in " Applicants' Response to Richard Wilson Interrogatories on EPJ-5, Wilson 11, Wilson 12b2, Wilson 12b3" are true and correct to the best of his information, knowledge and belief; and 1:iat the sources of his information are officers, employees, agents and contractors of Carolina Power & Light Company, and employees and agents of the State of Nort Carouna.
This f day of October,1984, t
- y. Fiirr Sworn tojnpubscribed before me this d(6___May October 1984.
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' ' ' 1' My commission expires:
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UShn; UNITED STATES OF AMERICA '84 NOV -1 A10 :25 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSikdBCIA'RDgjh BRANC" In the Matter of-
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CAROLINA POWER & LIGHT COMPANY
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AND NORTH CAROLINA EASTERN
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Docket No.
50-400 OL MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power Plant)
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I hereby certify that copies of " Applicants' Response to [CHANGIG Emergency Planning Interrogatories and Request for Production of Documents [on Contentions EPJ-4 1, EPJ-2 and EPJ-41" and the Affidavit of B. J. Furr, unavailable at the time of filing
" Applicants' Response to Richard Wilson Interrogatories on EPJ-5, Wilson 11, Wilson 12b2, Wilson 12b3" were served tilis 29nd day of October,1984 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.
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Hill Carrow Attorney Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6839 Dated: October 29,1984 0
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k SERVICE LIST James L. Kelley, Esquire M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 Mr. Glenn O.' Bright :
Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U. S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D. C. 20555 Mr. Wells Eddleman Dr. James H. Carpenter 718-A Iredell Street Atomic Safety and Licensing Board Durham, North Carolina 27705 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Thomas A. Baxter, Esquire John H. O'Neill, Jr., Esquire Charles A. Barth, Esquire Shaw, Pittman, Potts & Trowbridge Myron Karman, Esquire 1800 M Street, NW Office of Executive Legal Director Washington, D.C. 20036
. U. S. Nuclear Regulatory Commission
-Washington, D. C. 20555 Bradley W. Jones, Esquire U. S. Nuclear Regulatory Commission
~ Docketing and Service Section Region II Office of the Secretary
- 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555 Robert P. Gruber Mr. Daniel F. Read, President Executive Director Chapel Hill Anti-Nuclear Public Staff Group Effort North Carolina Utilities Commission Post Office Box 2151 Post Office Box 991
- Raleigh, North Carolina 27602 Raleigh, North Carolina 27002 Dr. Linda Little Governor's Waste Management Board 513 Albemarle Building 325 Salisbury Street Raleigh, North Carolina 27611 Mr. Steven Crockett, Esquire Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission
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Washington, D. C. 20555 John D. Runkle, Esquire
- Conservation Council of North Carolina 307 Granville Road Chapel Hill, North Carolina 27514
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