ML20112G882

Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard on Emergency Planning Joint Contention 5

ML20112G882
Person / Time
Site:	Harris
Issue date:	01/14/1985
From:	Hollar D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20112G872	List: ML20112G870 ML20112G882 ML20112G888
References
OL, NUDOCS 8501160551
Download: ML20112G882 (4)

Text

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o January 4,1985 UNITED STATES OF AMERICA .-

NUCLEAR REGULATORY COMMISSION O U '5 f40 :13 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.- .

}y ['

uenO In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

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

)

(Shearon Harris Nuclear Power Plant) )

i-

)

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THEREIS NO GENUINE ISSUE TO BE IIEARD ON EPJ-5 Pursuant to 10 C.F.R. S 2.749(a), Applicants' state, in support of their Motion for J

Summary Disposition of EPJ-5, t!'at there is no genuine issue to be heard with respect to the following material facts:

i 1.

The " Safety Information" brochure (for distribution by special malling throughout the Harris plume EPZ prior to commencement of plant operation and annually thereaf'er) will include a special needs response card to elicit information identifying non-ambulatory homebound members of the public. Pugh Affidavit,13.

2. The completed response cards will be analyzed by the State and the four county i

emergency management agencies. This information will serve as the basis for the counties' listing of non-ambulatory homebound persons within the EPZ. The listing will

. be updated to reflect each new special needs card as it is received. Pugh Affidavit,13.

3. The lists compiled from the special needs response cards will be augmented with information identifying homebound non-ambulatory persons provided by rescue squads, l fire departments, social services agencies and health care providers in the four-county area. Carolina Power & Light Company's listing of customers on life support systems i

~ will also be used to augment information from other snurces. Pugh Affidavit,14.

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4. The listing of homebound non-ambulatory persons ire the EPZ will be completed -

' prior to commencement of plant operation, and will be updated annually and with the receipt of each new special needs card. Pugh Affidavit 113,16.

5. The current list of homebound non-ambulatory persons will be maintained in the county EOCs, sheriffs' offices, fire stations, ambulance s(rvice and rescue squad

. headquarters, and will therefore be readily available to resporue personnel in the event of an emergency. Pugh Affidavit,15.

f 6. There will be a telephone number in each county listed in the " Safety Information" brochure and broadcast over the Emergency Broadcast System whereby non-ambulatory persons who are not included on the lists for any reasoa can obtain assistance

- during an evacuation. Pugh Affidavit,16.

7. Based upon discussions with local health care and social services agencies and.

- other organizations, the North Carolina Division of Emergenay Management has estimated the number of homebound non-ambulatory persons in the EPZ who would need to be evacuated by ambulance. Pugh Affidavit,17.

8. Based upon discussions with hospital, nursing homa and rest home administrators, the Division of Emergency Management has also estimated the number of non-ambulatory persons in hospitals, nursing homec and rest homes who would require evacuation by ambulance. Pugh Affidavit,18.

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9. Totalling the estimated number of homebound non-ambulatory persons and non-l ambulatory hospital and nursing home patients requiring evacuation by ambulance, there are an estimated 10 persons in Chatham County,5 persons in Harnett County,'10 persons i

in Lee County,' and 89 persons in Wake County who will need to be evacuated using ambulances. Pugh Affidavit,19.

! 10. Information on the ambulance resources in the fo*ir counties within the plume EPZ and in surrounding counties has been obtained from the Office of Emergency l'

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Medical Services of the North Carolina Department of Human Resources. Pugh --

Affidavit,110 and Attachments E and F. -

11. With the ambulance resources identified, there will be a sufficient number of ambulances available to evacuate all of the non-ambulatory persons in the EPZ for whom ambulance evacuation is necessary even if the entire EPZ is evacuated. There will also be a sufficient number of backup ambulances available to perform other evacuation responsibilities and to respond to routine emergency situations, as necessary. Pugh Affidavit, 1111-12,

12. Under North Carolina law, all ambulances operated in the state must obtain a permit from the North Carolina Department of Human Resources and must meet strict standards established by the North Carolina Medical Care Commission. All of the ambulances that will be used to evacuate non-ambulatory persons have received a permit from the Department of Human Resources and are adequately equipped to transport non-ambulatory persons in the event of an accident at the Harris Plant. Pugh Affidavit,113.

13. In addit.on, all ambulances in Wake County have Advanced Life Savings (ALS) capability. This provides additional assurance that they will be able to safely evacuate patients from the two hospitals within the plume EPZ. Both of these hospitals are located in Wake County. The hospitals have a capacity of 56 persons and Wake County ambulances have a capacity of 86 persons. Pugh Affidavit,118,14 and Attachment G.

14. There will be an adequate number of certified personnel to operate the available ambulances and who are adequately qualified to evacuate non-ambulatory persons in the event of an accident at the Harris Plant. Pugh Affidavit,115.

This 14th day of January,1985.

Respectfully submitted, '

Dale E. Hollar, Esq.

Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 Attceneys 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.

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

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