ML20116L721

From kanterella
Jump to navigation Jump to search
Petition Requesting Admittance of Contentions 227-CC & DD Re Brochure Additions Served on 850416 Concerning Emergency Plan Evacuation & Shelter for Settlement or Litigation. Certificate of Svc Encl
ML20116L721
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 04/29/1985
From: Eddleman W
EDDLEMAN, W.
To:
Atomic Safety and Licensing Board Panel
References
CON-#285-834 84-468-01, 84-468-1, ASLBP-84-468-1, OL, NUDOCS 8505030702
Download: ML20116L721 (3)


Text

[ g' 7

UNITED STATES OF AMERICA NUCLEAR BEGULATOBY COMMISSION 00CMETED USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOABD Glenn O. Bright E W -3 #1 :18 Dr. James H. Carpenter James L. Kelley, Chairman 0FFICE OF SECRtIAR v 00CKETING & SEf<vict BRANCH In the Matter of CAHOLINA POWER AND LIGHT CO. et al.

)

S ar Harris Nuclear Power Plant,

)

ASLBP No. 82-h68-01

)

OL Eddleman Contentions Concerning Emergency Plan Brochure additions served 4/16/85 227-00 The brochure evacuation vnnte listings do not give connlete directions to the sheltersA Since the plan assumes that evacuees will check in at shelters, and there be checked and decontaminated if necessary, failure to provide directions to the shelters from the evacuation routes could lead to evacuees failing to find the shelters, failing to register, and not being decontaminated.

Lack of decontamination especially would violate the requirement of 10 CFR 50.47(a)(1) that " adequate protective measures can and will be taken" in a radiological emergency.

Specific maps to the shelter8 or clear directions to each, should be in the brochure, to avoid confusion.

227-DD.

The title "How Will You Know Where to Go To Be Safe" is inapparopriate because it fails to make adequate distinction between evacuation and sheltering, and because it falsely implies that radioactive material cannot reach the shelters.

  1. )

W FIVE FACTORS for both contentions above: (i) Good cause: info 7

was not available until brochure amendments were served. CP&

',i could not have been readily anticipated without seeing them.L SiMrs b

8 No other parties or means will represent my interests here.

(v) There S

is little potential for delay since these contentions could be heard in gg June.

They do not broaden the issues significantly and may be amenable La.c to settlement.

The requirements of 10 CFR 50.h7 for effective emergency planning render these issues important enough to be heard regardless L_

\\ \\

~

of the minor dolny potential and slight brondoning of L3 suas involvsd.

Over 20 issues were admitted on emergency planning. (iii) No particular expertise is required to deal with these issues.

As a teacher I am able to provide review and questions concerning the clarity and accuracy of information provided to the public via the brochure.

r Be'cause thess issues are not full of legal connlexity, I can deal with them and conduct settlement negotiations, or cross-examination, as required to provide a sound record on these matters.

These issues are also simple enough as to not be a great burden on my time or resources.

For the above reasons, Contentions 227-CC and -DD should be admitted for settlement or lirtigation if necessary.

??2etn 29 April 1985 Wells Eddleman

UNITED STATES OF AMERICA NUCLTAR REGULATORY C0!C(ISSION In the matter of CAROLHA POWER k LIGliT CO. Et al. )

Docket 50-400 Shearon Harris Nuclear Power Plant. Unit 1-

)

0.L.

CERTIFICATE 0F SERVICE shc EC I hereby certify that copies of Eddleman contentions concerning Emergency Plan Brochure additions served h/16/85

'3 NI IO HAVE been served this 29 day of April 1985,bydeh

!Ag C

the US Wil, first-class postage propid, upon all parties whose names are listed below, except those whose nanes are arked with an asterisk, for when service was accomplished by i

l Judges Ja ws Kelley, G'lenn Bright and Janas Carpenter (1 copy each)

Atonic Safety and Licensirg Board US Nuclear 9egulatory Connission Washin6 ton DC 20555 George F. Trowbridge (atterney for Applicants)

Shaw, Pittr.an, Potts & Trowbridge R.uthanne G. Miller l

1600 M St. NW ASL3 Panel l

WashinEton, DC 20036 USNRC Washington DC 2055 5 Office of the Executive Legal Director

[

Spence W. Perry l

Attn Docke ts 50-400/k010 L.

plaa $ cst.SW

?a$fngtonDC20555 C M Washington DC 20740 l

4 Dan Read 1

Docketing and Service Section (3x)

CEA!!GE /TLP I

Attn Docke ts 50-h00/L01 0.L.

l office of the Secretary Waleigh,y707 Waveross

(

NC 2760'6 USNRC l

Washington DC 20555 Dr. Linda W. Little i

aoy rnori, we3t, yg, sa, g

(E plan only) 513 Albenarle B1dg.

John Runkle Steve Roch1 mis 325 N. sal' abut v St.

CCNC FEI'A-Suite 700 s

307 Granville Rd 137.1 Peachtree St.NE 'taleigh, NC 27611 Chapel Hill Ne 2751k Atlanta GA 30309 Bradley W. Jones Robert Gruber USNRC Region II Travi.J Payne Exec. Director 101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 30303 Biex 12601 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D.

Certified by w

f 729 Eunter St.

Apex NC 27502 n

_ _ _ _ _ _ _ _