ML20112J864
| ML20112J864 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/14/1985 |
| From: | Gaukler P CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20112J843 | List:
|
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 OL, NUDOCS 8501180400 | |
| Download: ML20112J864 (3) | |
Text
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'85 3*nWYP m 1985 t
FCE 'j L ! Q{t' ' y pr;cE UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
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and NORTH CAROLINA EASTERN
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Docket No. 50-400 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant)
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APPLICANTS' STATEMENT OF MATERIAL PACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON EDDLEMAN 30 Pursuant to 10 C.F.R. Section 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Eddleman 30, that there is no genuine issue to be heard with respect to the following material facts:
1.
Paragraph IV.E.6. of Part 1 of the Emergency Response Plan for the Shearon Harris facility, entitled " Procurement, Storage and Distribution of Radiological Protective Drugs,"
provides in full as follows:
a.
The Division of Health Services, DHR, will establish a monitoring and replacement pro-gram to insure that a sufficient number of po-tassium iodide units are conveniently and stra-tagically located in the vicinity of the Shearon Harris Plant.
The majority of the potassium iodide units will be stored in the Chatham, Harnett, Lee and Wake County Health Departments under the control of officials in those counties.
The Division of Health Services will 8501180400 850114 PDR ADOCK 05000400 G
LT coordinate directly with SERT, the counties in-volved, and Carolina Power and Light Company in order to carry out this program.
SERT will be immediately informed of any significant change in the status of available potassium iodide units.
b.
The Division of Health Services will determine the number of potassium iodide units required for emergency workers and institution-alized persons within the plume exposure pathway and will coordinate the procurement of all po-tassium iodide.
Reed Aff. 1 3.
2.
The State of North Carolina has decided to store 3,000 units of potassium iodide (each unit consisting of one bottle containing 14 tablets) in the vicinity of the Shearon Harris Plant, which will be divided among the county health depart-ments in Chatham, Harnett, Lee and Wake Counties, for immediate distribution to emergency workers and institutionalized persons in the event of an emergency at the Shearon Harris facility involving the actual or potential release of radioactive io-dine.
Reed Aff. 1 4.
3.
The Division of Health Services has established a co-ordinated state-wide plan for the procurement, storage and dis-tribution of. potassium iodide for emergency workers and insti-tutionalized persons in the event of an emergency at any of the nuclear power plants affecting the State of North Carolina.
This is an ongoing process that continues in the event of an emergency and is premised on the ability to ship potassium iodide anywhere, anytime it is needed.
As part of this coordi-nated program, at the time Shearon Harris is operational, the g
State will have 7,000 units of potassium iodide stored in the vicinity of the McGuire facility, 5,000 units in the vicinity of the Brunswick facility and 3,000 units in the vicinity of the Shearon Harris facility.
Reed Aff. 1 5.
4.
The quantities of potassium iodide stored near a nu-clear facility should not be specified in the ERP because such quantities may vary for a variety of reasons.
Reed Aff. 1 6;
" FEMA Staff Response To Interrogatories Propounded by Interve-nor Wells Eddleman," page 1 (August 14, 1984).
5.
As interpreted by FEMA, NUREG-0654 "does not require that specific quantities of KI be listed in the Plan."
" FEMA Staff Response To Interrogatories Propounded by Intervenor Wells Eddleman," page 1 (August 14, 1984).
Respectfully submitted, DJ_
Thomas A. Baxter, P.C.
Paul A. Gaukler SHAW, PITTMAN,'POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 and Richard E. Jones Dale E. Hollar CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated:
January 14, 1985