ML20112J996

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Supplemental Statement of Matl Facts as to Which There Is No Genuine Issue Re Eddleman Contention 213
ML20112J996
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 04/05/1985
From: Ridgway D
CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20112J975 List:
References
OL, NUDOCS 8504090291
Download: ML20112J996 (3)


Text

April 5:, 1985 c:ym

,:c UNITED STATES OF AMERICA 1

NUCLEAR REGULATORY COMMISSION

'85 APR -8 A11 :47 I

BEFORETHEATOMICSAFETYANDLICENSINGBOhi{G

^

Vt BRANQi In the Matter of

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)

CAROLINA POWER & LIGHT COMPANY

)

and NORTH CAROLINA EASTERN

)

-Docket"No. 50-400 OL"~

MUNICIPAL POWER AGENCY

)

)

(Shearon Harris Nuclear Power

)

Plant)

)

APPLICANTS' SUPPLEMENTAL STATEMENT OF MATERIAL PACTS AS TO WHICH THERE IS NO GENJINE ISSUE TO BE HEARD ON EDDLEMAN 213 Pursuant to 10 C.F.R. 5 2.749(a), Applicants further state, in support of their Motion for Summary Disposition of l

Eddleman 213, that there is no genuine issue to be heard with respect to the following material facts:

10.

Carolina Power & Light Company contracted with ATI to analyze and evaluate the alerting of swimmers, boaters, and wa-terskiers on 11arris Lake, and to prepare a report, " Analysis and Evaluation of Siren Notification for Boaters, Waterskiers, and Swimmers On Harris Lake" (March 1985), which documents the analysis of the warning system design for alerting such popula-tions.

Bassiouni Supplemental Affidavit, 1 2; Black Supplemen-tal Affidavit, 1 2.

8504090291 850405 ADOCK O 4j0 gDR

1 l

11.

Based on the methodology described in great detail in

-the March 1985. report, ATI developed a proposal to enhance the i

existing system of sirens installed throughout the Harris plume Emergency Planning Zone, to assure siren notification of swimmers, boaters, and waterskiers on Harris Lake.

Bassiouni Supplemental Affidavit, 1 3; Black Supplemental Affidavit, 1 3.

12.

ATI's proposed siren configuration of ten additional l

sirens (activated for a total of 10 minutes) would provide es-sentially 100 percent notification to people on Harris Lake within 15 minutes.

Bassiouni Supplemental Affidavit, 1 3; i

Black Supplemental _ Affidavit, 1 3.

13.

CP&L has' committed to install these ten additional sirens.

Black Supplemental Affidavit, 1 3.

l 14.

Fifteen billboards are being erected in prominent lo-cations around Harris Lake prior to fuel load.

The instruc-tional message on the billboards will advise that, upon emer-gency notification, persons are to leave the lake immediately and to turn on radios or televisions for information and in-structions.

Black Supplemental Affidavit, 1 4.

i 15.

These provisions for the alert and notification of persons on Harris Lake obviate the need for restrictive mea-sures such as those suggested in Eddleman 213, e.g.,

limiting u

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e

,n

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the number of boaters, swimmers, and waterskiers on the lake.

Black Supplemental Affidavit, 1 5.

Respectfully submitted, YehldoA.

'Thbmds A. Baxter,'P.@.

9 Delissa A. Ridgway 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:

April 5, 1985 1

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