ML20112K015

Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention EPJ-4(d)

ML20112K015
Person / Time
Site:	Harris
Issue date:	01/14/1985
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
ML20112J843	List: ML20112J839 ML20112J852 ML20112J864 ML20112J867 ML20112J876 ML20112J883 ML20112J890 ML20112J898 ML20112J904 ML20112J913 ML20112J928 ML20112J936 ML20112J952 ML20112J959 ML20112J966 ML20112J976 ML20112J980 ML20112J999 ML20112K015 ML20112K038 ML20112K042 ML20112K046 ML20112K054 ML20112K067 ML20112K077 ML20112K080 ML20112K082 ML20112K094 ML20112K100 ML20112K105 ML20112K116 ML20112K118
References
OL, NUDOCS 8501180450
Download: ML20112K015 (3)

Text

r January'14, 1985 C;. -

wt UNITED STATES OF AMERICA . . , .

NUCLEAR REGULATORY COMMISSION 02 J,j 7 7 p BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f[ 49.,3 1

.y 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) )

)

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

. TO BE HEARD ON EPJ-4(d)

Pursuant to 10 C.F.R. S 2.749(a), Applicants state, in support of their Motion for Summary Disposition of EPJ-4(d),

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

1. The offsite emergency plans for Harris are designed to facilitate the expeditious evacuation of school children, directly from their schools within the EPZ to predesignated i

school evacuation shelters outside the EPZ. In the event of an

emergency at Harris, schools would be notified directly by ap-propriate authorities, so that warning and notification of school officials will precede (to some extent) public notifica-tion via the siren system. Because the resources for use in school evacuation are at or in close proximity to the schools 8501180450 850114 gDRADOCK 05000400 PDR

9 during the school day, school evacuation would be well underway

. -- perhaps even completed -- before parents could receive and react to notification of the emergency and travel to schools.

Pugh Affidavit, 1 3.

2. Both the emergency public information brochure and the EBS announcements for broadcast in the event of an evacua-tion will advise parents of the evacuation of the schools, and of the shelter to which each school's students have been evacu-ated. The brochure and the EBS announcements will emphasize that parents should not attempt to pick up their children at school, but rather should pick them up at the appropriate evac-uation shelter outside the EPZ. Pugh Affidavit, 14.

3. The provision via EBS of information about the relo-cation of school children assures that, in the event of an evacuation due to an emergency at Harris, few -- if any -- par-ents would attempt to pick up their children at their schools within the EPZ. Pugh Affidavit, 1 5; Mileti Affidavit, 1 6.

4. If parents did go to the schools to pick up their children in an emergency, school evacuation would not be seri-ously impeded. Bus traffic (and other school evacuation vehi-cles) would be routed away from school campuses by separate exits not readily accessible to parent drivers. Moreover, of-ficials at each of the schools are prepared to provide traffic control to direct buses and other school evacuation vehicles out of the loading area, if necessary. Any parents who did at-tempt to pick up their children at school would conduct e

themselves in an orderly manner. Pugh Affidavit, 11 6-7; Mileti Affidavit, 11 2, 4.

5. The evacuation of the general population would not be impeded by parents' attempts to pick up their children at school. The evacuation time estimate study ("ETE") incorpo-rated a broad range of preparation / mobilization times, and sim-ulated the traffic friction on the evacuation-roadway network which would be associated with preparation / mobilization activi-ties involving pre-evacuation travel. Thus, if some parents did attempt to pick up their children at their schools in an emergency, that behavior would not significantly affect the evacuation times provided in the ETE. Klimm Affidavit, 11 2-5.

Respectfully submitted, Th'ombs A.

W Ba'xter,M2 CI 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 l Dated: January 14, 1985 1

l