ML20138D276

Supplementary Response to General Interrogatories 2-3 & 12-14 Re Eddleman Contention 57-C-3 Concerning Nighttime Emergency Siren Sys at Facility.Certificate of Svc Encl. Related Correspondence

ML20138D276
Person / Time
Site:	Harris
Issue date:	10/18/1985
From:	Johari Moore Federal Emergency Management Agency, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	EDDLEMAN, W.
Shared Package
ML20138D190	List: ML20138D187 ML20138D197 ML20138D220 ML20138D256 ML20138D262 ML20138D276
References
OL, NUDOCS 8510230227
Download: ML20138D276 (8)

Text

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UNITFD STATES OF AMERICA 1 s V 3' J NUCLEAR REGULATORY COMMISSION fj ,

9b BEFORE THE ATOMIC SAFETY AND LICENSING BOARD $

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In the Matter of CAROLINA POWER AND LIGHT COMPANY AND )

NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 OL POWER AGENCY 50-401 OL (Shearon Harris Nuclear Power Plant, )

Units I and 2)- )

FEPA STAFF SUPPLEMENTAL RESPONSE TO EDDLEMAN GENERAL INTERR0GATORIES 2-3 and 12-14 CONCERNING EDDLEMAN CONTENTION 57-C-3 I. INTRODUCTION Pursuant to 10_ C.F.R. 9 2.740(e)(1)(ii) of the Comission's regulations the Staff, on behalf of FEMA, provides the following supplemental response to General Interrogatories 2-3 and 12-14 concerning Eddleman Contention 57-C-3. FEMA initially responded to these interrogatories by a filing dated August 14,~1984. " FEMA STAFF RESPONSE TO INTERROGATORIES PROPOUNDED BY INTERVENOR WELLS EDDLEMAN."

II. SUPPLEMENTAL RESPONSE INTERROGATORY 2 Has FEPA or NRC Staff made any analysis, inquiry, study or investigation into, (a) this contention (b) the subject matter of this contention (c) the allegation (s) in this contention (d) the basis of this contention (e) the information relied upon by intervenor(s) in support of this contention?

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SUPPLEMENTAL RESPONSE FEMA, through its contractor, International Energy Associates Limited, performed an analysis of the capability of the alert and notification system to arouse people from sleep between the hours of midnight and six a.m.. This analysis was completed very recently. The results of the analysis are I

contained in the testimony of Thomas F. Carter, Van M. Lee, Karl D. Kryter, and Jiri Nehnevajsa. The documents reviewed and relied upon in conducting this analysis are identified in the' testimony. All of the above named gentlemen will appear as witnesses.

INTERROGATORY 3 For all parts of your response to Interrogatory 2 above for which your answer is affirmative, please provide the following information: who made the analysis, inquiry, study or investigation; what was being considered in such analysis, inquiry, study or investigation ("AISI");

the content of the AISI, the results of the AISI, whether the AISI has been completed, whether a date for completing the AISI has been established if it is not complete, what that date is, all documents used in the AISI, all persons consulted in the course of the AISI, all documents containing information discovered or analysis or study or information developed during or as a result of the AISI (identif such document and state what information or results it contains)y each whether staff believes additional analysis is warranted and whether any persons participating in the AISI are to be called as witnesses for the Staff in this case, and what questions the staff AISI is intended to answer and what information it seeks to develop if it is not complete.

SUPPLEMENTAL RESPONSE See response to Interrogatory 2 above.

INTERR0GATORY 12 Identify by name, FEMA staff position if any, address and telephone number of each person whom FEMA staff intends to use or call as a witness in this proceeding.

INTERR0GATORY 13 State fully the professional qualifications of each person identified in response to interrogatory 12 above.

INTERROGATORY 14 l Summarize the position (or planned testimony) with respect to each contention on which such person is expected to testify, for each person identified in response to interrogatory 12 above.

SUPPLEMENTAL RESPONSE FEMA currently intends to present the testimony of the following individuals en Eddleman Contention 57-C-3:

Dr. Jiri Nehnevajsa i

Professor of Sociology l Faculty of Arts and Sciences

Department of Sociolcgy i

University of Pittsburgh Pittsburgh, Pennsylvania 15260 '

l Qualifications:

Ph.D. in Sociology, University of Zurich l

l Area of Testimonyt The behavioral response of individuals to alert and notification systems.

Dr. Karl D. Kryter President, Acousis Company l

P.O. Box 750 Bodega Bay, California 94923

4

, Cualifications:

Ph.D, in psychology and physiology, University of Rochester Specialized professional competence in psychological / physiological effects of noise on humans.

Area of Testimony:

Psychoacoustical aspects of alert and warning systems (i.e., awakening people from sleep).

'Dr. Van Lee -

President 4

Analysis and Computing _ Company 26 Laura Drive Westbury, New York 11590 s

Qualifications:

Ph.D. in Applied Mathematics, Applied Mechanics, and Acoustics, New l- York University Area of Testimony:

Siren sound propagation.

4 f

t-i Thomas F. Carter, Jr.

Vice President, Consulting Services f International Energy' Associates Limited f 2600 Virginia Avenue, N.W. i i

Suite 1000 l j

Washington, D.C. 20037 i

Qualifications:  !

6 B.S. in Civil Engineering, Mississippi State University, i

Area of Testimony: ,

i If i

NUREG-0654 and FEMA-43 criteria overview, and application of criteria to l alert and notification system evaluations. f i

Respectfully submitted, l 1

TuAjDDR.M i undL ;

Janice E. Moore Counsel for NRC Staff  :

e Dated at Bethesda, Maryland this 18th day of October, 1985 i

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )  !

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CAROLINA POWER AND LIGHT COMPANY AND )

NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 OL POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF THOMAS F. CARTER I, Thomas F. Carter, being first duly sworn, do depose and state:

1. I am the Vice President, Consulting Services Group, International Energy Associates Limited.

2. I have provided the response to General Interrogatory 2. The response is true and correct to the best of my knowledge, information and belief.

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"Trorhts F.' Carter /F Sworn to and subscribed before me this 18th day of October,-1985 Me 2Pael N6tary Public My Commission Expires' July 1, 1986 l

l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER AND LIGHT COMPANY AND )

NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 OL POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

I hereby certify that copies of " FEMA ' STAFF SUPPLEMENTAL RESPONSE TO EDDLEMAN GENEPAL INTERR0GATORIES 2-3 and 12-14 CONCERNING EDDLEMAN CONTENTION 57-C-3" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or deposit in the Nuclear Regulatory Commission's internal mail system (*),

this 18th day of October,1985:

James L. Kelley, Chairman

• Richard D. Wilson, M.D.

Administrative Judge 729 Hunter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Comission Washington, DC 20555 2 Mr. Glenn 0. Bright

• Travis Payne, Esq.

Administrative Judge 723 W. Johnson Street Atomic Safety and Licensing Board P.O. Box 12643 U.S. Nuclear Regulatory Commission Raleigh, NC 27605 l Washington, DC 20555 Dr. James H. Carpenter

• Dr. Linda Little Administrative Judge Governor's Waste Management Building Atomic Safety and Licensing Board 513 Albermarle Building U.S. Nuclear Regulatory Commission 325 North Salisbury Street Washington, DC 20555 Raleigh, NC 27611

! Daniel F. Read John Runkle, Esq. Executive Coordinator -

! CHANGE Conservation Counsel of North Carolina P.O. Box 2151 307 Granville Rd.

Raleigh, NC 27602 Chapel Hill, NC 27514 Steven Rochlis Spence W. Perry, Esq.

Regional Counsel Associate General Counsel FEMA Office of General Counsel 1371 Peachtree Street, N.E. FEMA Atlanta, GA 30309 500 C Street, SW Rm 840 Washington, DC 20472 i

. - . - ._.. .- ,., - _ - . - - ~ - - - . - - - - ,

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Atomic Safety and Licensing Appeal Bradley W. Jones, Esq.

Board Panel

• Regional Counsel, USNRC, Region II U.S. Nuclear Regulatory Commission 101 Marietta St., N.W. Suite 2900 Washington, DC 20555 Atlanta, GA 30323 Robert P. Gruber George Trowbridge, Esq.

Executive Director Thomas A. Baxter, Esq.

Public Staff - NCUC John H. O'Neill, Jr., Esq.

P.O. Box 991 Shaw, Pittman, Potts & Trowbridge Raleigh, NC 27602 1800 M Street, N.W.

Washington, DC 20036 Wells Eddleman Atomic Safety and Licensing Board

• 806 Parker Street U.S. Nuclear Regulatory Commission Durham, NC 27701 Washington, DC 20555 Richard E. Jones, Esq. Dr. Harry Foreman, Alternate Associate General Counsel Administrative Judge Carolina Power & Light Company P.O. Box 395 Mayo P.O. Box 1551 University of Minnesota Raleigh, NC 27602 Minneapolis, MN 55455 H. A. Cole, Jr. , Esq.

Special Deputy Attorney General Antitrust Division Office of Attorney General eg, [ h_

Janice E. Moore Counsel for.NRC~ Staff