Proposed Findings of Fact & Conclusions of Law on Reopened Contention 57-C-3 (Alert Notification) Re Distribution of tone-alert Radios to 589 Households within 5 Miles of Facility.Certificate of Svc Encl| ML20199E233 |
| Person / Time |
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| Site: |
Harris  |
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| Issue date: |
03/19/1986 |
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| From: |
Eddleman W
EDDLEMAN, W. |
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| To: |
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| References |
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| CON-#186-521 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8603250439 |
| Download: ML20199E233 (5) |
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Category:FINDINGS OF FACT/CONCLUSIONS OF LAW
MONTHYEARML20140F9881986-03-26026 March 1986
Proposed Findings of Fact & Conclusions of Law Re Reopened Issues Concerning Eddleman Contention 57-C-3.Applicant Proposed Siren Sys Adequate to Awaken Sleeping People within 5 Mile Radius of Plant.W/Certificate of Svc
ML20140E6311986-03-25025 March 1986
Reply to North Carolina Atty General & W Eddelman 860319 Proposed Findings of Fact & Conclusions of Law on Reopened 860319 Hearings on Eddelman Contention 57-C-2.Certificate of Svc Encl
ML20199E2331986-03-19019 March 1986
Proposed Findings of Fact & Conclusions of Law on Reopened Contention 57-C-3 (Alert Notification) Re Distribution of tone-alert Radios to 589 Households within 5 Miles of Facility.Certificate of Svc Encl
ML20138B8531986-03-19019 March 1986
Proposed Findings of Fact & Conclusions of Law Re Eddleman Contention 57-C-3 on Nighttime Notification.Certificate of Svc Encl
ML20154Q2751986-03-18018 March 1986
Proposed Findings of Fact & Conclusions of Law on Reopened Hearings Re Eddleman 57-C-3 Concerning Nighttime Notification.Board Concludes That Harris Alert & Notification Sys Meets NRC Regulations.W/Certificate of Svc
ML20136H3091986-01-0606 January 1986
Reply to Other Parties Proposed Findings of Fact & Conclusions of Law on Eddleman S7-C-3 Re night-time Notification.Certificate of Svc Encl
ML20141F7411986-01-0303 January 1986
Reply to Proposed Findings of Fact & Conclusions of Law on Conservation Council of North Carolina Contention WB-3 Re Drug Abuse During Const Filed by Other Parties.W/Certificate of Svc
ML20138P7141985-12-23023 December 1985
Proposed Findings of Fact & Conclusions of Law on Eddleman Contention 57-C-3 (Nighttime Notification) Re Emergency Planning.Certificate of Svc Encl
ML20138P6771985-12-20020 December 1985
Proposed Findings of Fact & Conclusions of Law on Conservation Council of North Carolina Contention WB-3 (Drug Abuse During Const).Certificate of Svc Encl
ML20138K8961985-12-16016 December 1985
Proposed Findings of Fact & Conclusions of Law on Eddleman Contention 57-C-3 Re night-time Notification.Certificate of Svc Encl
ML20138R2941985-12-16016 December 1985
Proposed Findings & Conclusions Re Contention 57-c-3 Concerning Nighttime Alerting & Notification.Plant Siren Sys Must Be Upgraded W/Addl Sirens or Telephone Sys to Notify Persons within 5 Miles of Facility.W/Certificate of Svc
ML20138R3991985-12-16016 December 1985
Proposed Findings of Fact & Conclusions of Law Re Conservation Council of North Carolina Contention WB-3 Concerning Drug Abuse During Facility Const.Certificate of Svc Encl
ML20138K6381985-12-13013 December 1985
Proposed Findings of Fact on Conservation Council of Nc Contention WB-3 Re Drug Abuse During Facility Const. Certificate of Svc Encl
ML20138B3921985-12-0909 December 1985
Proposed Findings of Fact & Conclusions of Law on Eddleman 57-C-3 (Night Time Notification) Re Collective OL for Facility.Svc List & Certificate of Svc Encl
ML20137W4501985-12-0606 December 1985
Submits Corrections to Applicant 851205 Proposed Findings of Fact & Conclusions of Law on Conservation Council of North Carolina Contention WB-3 (Drug Abuse During Const). Certificate of Svc Encl
ML20137W2851985-12-0505 December 1985
Proposed Findings of Fact & Conclusions of Law on Conservative Council of North Carolina Contention WB-3. Contested Safety Matters Resolved in Favor of Staff & Applicants & Against Intervenors.Certificate of Svc Encl
ML20134H2731985-08-22022 August 1985
Proposed Findings of Fact & Conclusions of Law on Emergency Planning Contentions EPJ-4(b) & Eddleman 57-C-10.Certificate of Svc Encl
ML20134C7651985-08-12012 August 1985
Proposed Findings/Conclusions on Contention 57-C-10 & Emergency Planning.License Should Not Be Issued Until Requirements of 10CFR50.47(a)(1) Met.Certificate of Svc Encl
ML20133B8291985-08-0101 August 1985
Proposed Findings of Fact & Conclusions of Law Re Emergency Planning Contentions.Certificate of Svc Encl
ML20104A8101985-01-29029 January 1985
Applicant Reply to Proposed Findings of Fact & Conclusions of Law on Eddleman Contentions 41,116 & 9 Re Pipe Hangers Qa/Qc,Fire Protection & Environ Qualification of Electrical Equipment,Respectively.Certificate of Svc Encl
ML20112D9271985-01-0909 January 1985
Joint Intervenors Proposed Findings on Joint Contention IV Re TLDs
ML20112D9461985-01-0909 January 1985
Joint Intervenors Proposed Findings on Joint Contention I Re Mgt Capability.Certificate of Svc Encl
ML20112C9081985-01-0808 January 1985
Proposed Findings of Fact on Contentions 41,116 & 9 Re Pipe Hangers Qa/Qc,Fire Protection & Environ Qualification of Electrical Equipment,Respectively
ML20112C9211985-01-0808 January 1985
Joint Intervenors Proposed Findings Re Joint Contention 7, Steam Generators Multiple Tube Ruptures. Certificate of Svc Encl
ML20111C0261985-01-0404 January 1985
Reply to Eddleman Proposed Findings on Contention 65 Re Concrete Deficiencies.No Safety Concerns Raised Re Containment Concrete
ML20101F0231984-12-21021 December 1984
Proposed Findings of Fact Re Contention 45 Concerning Matters Raised by C Stokes in Affidavit Opposing Summary Disposition
ML20101E9471984-12-21021 December 1984
Proposed Findings of Fact & Conclusions of Law on Safety Matters
ML20101E8191984-12-21021 December 1984
Proposed Findings of Fact & Conclusions of Law on Joint Contention I Re Mgt Capability
ML20112D9511984-12-21021 December 1984
Errata & Amends to Applicant Proposed Findings of Fact & Conclusions of Law Re Safety Matters,Including Pages 87,102, 104,B-4 & B-9
ML20094D0011984-08-0606 August 1984
Proposed Findings of Fact in Reply to Proposed Findings of Fact & Conclusions of Law Submitted by W Eddleman on Contention 8F(1) & by Joint Intervenors on Joint Contentions Ii(E) & (C).Certificate of Svc Encl
ML20093N2801984-07-24024 July 1984
Joint Intervenors Findings of Fact on Joint Contentions Ii(E) Re Concentration of Radionuclides Through Interaction W/Fine Particles & Ii(C) Re Calculations of Radiological Doses from Normal Releases.Certificate of Svc Encl
ML20093G1211984-07-20020 July 1984
Proposed Findings & Conclusions of Law on Eddlemen Contention 8F1 Re Health Effects of Coal Particulates.Nrc Consideration of Effects in Fes Inadequate
ML20093G1031984-07-20020 July 1984
Proposed Findings of Fact & Conclusions of Law on Environ Matters.Environ Contentions Do Not Constitute Challenge to Fes Adequacy.Certificate of Svc Encl
1986-03-26
[Table view]
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999
NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc
ML20217H9661999-10-20020 October 1999
NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence
ML20217E0881999-10-18018 October 1999
Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018
ML20217F7711999-10-17017 October 1999
Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence
ML20217F7681999-10-17017 October 1999
Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence
ML20217D6181999-10-14014 October 1999
Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence
ML20217E2611999-10-13013 October 1999
Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence
ML20217E2581999-10-13013 October 1999
Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc
ML20217E1461999-10-13013 October 1999
Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence
ML20217D5561999-10-13013 October 1999
Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence
ML20217D5761999-10-13013 October 1999
Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence
ML20217D6201999-10-12012 October 1999
NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence
ML20217D5661999-10-12012 October 1999
NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence
ML20212M0271999-10-0707 October 1999
Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007
ML20212L1441999-10-0505 October 1999
NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence
ML20212J0801999-09-29029 September 1999
Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence
ML20212G0001999-09-24024 September 1999
Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence
ML20212G0081999-09-24024 September 1999
Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence
ML20212D7151999-09-20020 September 1999
Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence
ML20212D8521999-09-20020 September 1999
Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence
ML20212C1231999-09-17017 September 1999
Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence
ML20211N7481999-09-10010 September 1999
NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence
ML20211N5021999-09-0808 September 1999
Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence
ML20211M4201999-09-0707 September 1999
Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence
ML20211M5001999-09-0303 September 1999
Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence
ML20211H4931999-08-30030 August 1999
Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence
ML20211B7951999-08-23023 August 1999
NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence
ML20211B8361999-08-23023 August 1999
Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence
ML20210T3531999-08-16016 August 1999
Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence
ML20210L9571999-08-0606 August 1999
Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence
ML20216E2041999-07-29029 July 1999
Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730
ML20210B2271999-07-21021 July 1999
Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc
ML20209G7371999-07-16016 July 1999
Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716
ML20209D1791999-07-12012 July 1999
Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712
ML20212J5831999-07-0101 July 1999
Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc
ML20196A8751999-06-22022 June 1999
Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622
ML20207D6991999-05-27027 May 1999
Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc
ML20207D6651999-05-27027 May 1999
Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc
ML20207D6891999-05-27027 May 1999
Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc
ML20206R8731999-05-20020 May 1999
Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520
ML20206R2411999-05-13013 May 1999
Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl
ML20206H9331999-05-11011 May 1999
Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511
ML20206G4051999-05-0505 May 1999
Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc
ML20206F9491999-05-0505 May 1999
NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc
ML20206A0851999-04-22022 April 1999
Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc
ML20205Q8121999-04-21021 April 1999
Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421
ML20196K8771999-04-0505 April 1999
Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding
ML20196K8861999-04-0505 April 1999
Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend
ML20205E3101999-04-0101 April 1999
Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203
ML20196K9041999-03-31031 March 1999
Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc
1999-09-08
[Table view] |
Text
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UNITED STATES OF AMERICA l U$skah-19-86 NUCLEAR REGULATORY COMMISSION l g MR 24 P3:12-
- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD7. ,..,
Glenn O. Bri '
Dr. James H.ghtCarpenter {g'chiw A1GV!
BRANCH James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )
(Shearon Harris Nuclear Power Plant, )
Unit 1) ) ASLBP No. 82-h68-01
) OL Wells Eddleman's Proposed Findings of Fact and Conclusions Of Law on Contention 57-C-3 (Alert / Notification) (Reepened)
Pursuant to oral Order of March 5 and an extension of time granted 3-18 with the assent of Applicants and the NRC Staff, Wells Eddleman files proposed findings and conclusions as followi FINDINGS OF PACT (en Re-opening) 589
- 1. CP&L proceses to distribute tone-alert radios to thghouseholds within 5 miles of the Harris plant. These radios have not yet been put in place or tested (Tr. 10776-777, Goodwin). The percentage of 1
i households that seuld be alerted by sirens alone, wi thin 5 miles of the Harris nuclear plant, ranges from 62.8% to 90% depending on which assumptions are used (Keast attachment B, about 5th,pg before Tr.10472).
- 2. CP&L does not propose to provide tene-alert radios to the 1060 633 house lds between 5 and 10 miles from the Harris nuclear plant 7, Eeast attachments A and B show that, under varying assumptions about Y alertability, between 732 and 1570 of these households would g be alerted by. sirens alone. The sirens are the sole primary alerting system between 5 and 10 miles of the plant under plicants' proposal.
8603250439 860319 DR ADOCK O y0 y 3
, 3 Keast attachments F and G show that under the same range of assumptions used in Attachments A and B, between $1 and 142 er the 589 households within 5 miles of the Harris plant would not be alerted by sirens alone.
4 CP&L witness Goodwin testified CP&L does not know the oests of several important aspects of the tone-alert program, including educational programs, and maihtenance. Tr. 10813-14, 10823.
Without knowing the oests, CP&L cannot have done a sost-benefit analysis of use of tone-alert radio systems either in the 4 to 5 mile range, or the 5 to 10 nile range, within the Harris plant EPZ Emergency Planning Zone (EDE).
- 5. The tone-alert system, assuming it is installe d, would be intended to meet the criterion of alerting essentially 100% of the people within the EPZ within 15 minutes. This criterion is the same throughout the 10-mile radius of the EPZ. If there is any grounds for variation from this criterion outside 5 miles, it would have to be en the grounds of cost-effectiveness. However, CP&L has not assessed this oest-effectiveness, and lacks data to de se (Finding 4, above).
6.CP&L has not even done a significant number of measurements of the signal strength available to tene-alert radios more than 5 miles from the Harris plant (witness Overman for CP&L, Tr. 10787-88).
- 7. Tone-alert radios have other weaknesses: Their inoperability is not reaBily diseevered if the tene-alerting feature is not working (Riley, Tr.,10708: accord, Applicants, Tr. 10791-93). In the Georgia Power tene-alert radio tests, the largest percentage not alerted was found in the third annual test (Tr. 10807). The signal band switch could be tripped by an object below it, as it is recessed only obout 3/32 of an inch (less than 1/8": Tr. 10788-89, 10794 for measurements). CP&L has
g . .
not assessed the sleeping leentions of adults in EPZ households to see if they match its assumptions (Tr. 10810-11).
- 8. The issue before the Board is,will the alerting system proposed 4
by Applicants sufficiently alert essentially 100% of the households within the EPZ. It will not, based en the above findings, particularly in the 5-to-10 mile *deughnut" around the plant, where tone-alert rad'os or other additional primary alerting systems will met be used.
The Board finds ne difference between the 75.9% to 89.6% alerting by sirens alone in the 0-to-5 mile ring around the Barris plant (Keast attachments F and G) and the 75.2% to 88.5% alerted by sirens alone in the 5-to-10 mile ring (Keast attachments A and B under the same assumptions as Attachments F and G respectively). If anything, these data indicate slightly more need for additional. primary alerting systems in the 5 to 10 mile zone. So does the 10-fold larger number of households not alerted between 5 and 10 miles: 732to1570,vs.61to142 within 0 to 5 miles. Another way to see this is that the tene-alert systen from 0 to 5 miles would add about 50 to 135 households to the total number alerted, at most. It might be only 2% of the households
- within 5 miles, or about 11 extra households.(Keast, XE by Gamin).
Thus, the tene-alert radies would ado 0.2 te 1.9% to the percentage of households in the 10-mile EPZ that would be alerted within 15 minutes.
- 9. These is mise reason to q uestion the eredibility of witness Keast, who shanged his percentage awake to 10 from 3 (Tr.10600-01), said he "eeuld not ammaik3gt have said anything like" (Tr. 10579-80) what he said on Tr.10507, and made other errera. Mr. Keast's highest alerting-percentage ' numbers aren't eredible, particularly in light of Dr. Kryter's testimony that the Kra11 man (German) data were likely from a siren reeerdet outside a building. (Tr. 10634-35; 10539-40). Dr. Kryter misled himself (or was misled) briefly between these 2 statements, with an error he later corrected (see Tr. 10543-44, and 10,630-632,3k-5).
4 GONCLUSION OF IAW OP&L's proposed alert-notification system, sensisting of sirens within the 10 mile EPZ, but tene-alert radios added only within 5 miles of the. Harris nuclear plant, is inadequate to alert essentially 100%
of the persons within the EPZ within 15 minutes, given nighttime conditions. Such alertinE is required to assure that adequate protective measures can and will be taken in the event of a nuclear accident at the Harris plant. 10 CPR 50.k7(a).
Therefore, an operating license is denied until such tine as CP&L can install and test an alerting systen capable of alerting essentially 100% of the persons within 10 miles of the Sheaven Harris plant, under nighttime conditions, includ}.ng people sleeping indoors, using fans, air-conditioners er other household appliar.ces,and show it meets this standard of performance in the real world.
Respectfully subnitted, fW-Wells Eddleman Intervenor pro se, 812 Yancey st.
Durhan NC 27701-3152 39 March, 1986
UNITED STATES OF AMERICA NUCLTAR REGULATORY C01ESION In tr.e matter of CAROLnA POWER k LIGHT Cc. It al. ) Docket 50-hCO Shearen Harris Nuclear Power Plant. Unit 1- ) 0.L.
CERIIFICATEOF SERV!C I hereby certify that copies of MP5ddleman'sproosedFindings 2
ofFact/ConclusionsonContentig$7-C-3(Rebdned) (with EPX pleading HAVE been of 3/12 served to this those not day se"FWdh,3f1P)#.
of thchhe 1961 , by' deposit in the US W il, first-class postage prepaid, upen all parties whose names are listed below, except those whose nanes are erked with an asterisk, for whom service was accenplished by hand a.,<,,. -
3/19 ver agreenent tV YO% W^' WI lig /[Cf p;r ow l
- pstf
- cn W ex44 % W n ig Judges James Ke11ev, Glenn Bright and Jae.as Carpenter (1 copy each)
Atomic Safety and Licensing Board
& their Law Clerk, sane US Nuclear Regulatery Con.ission address Washington DC 20555 '* Al Cole , Karen Long or i
- kek to CP&L Shaw, Pittman, Potts & Trowbridge Nike (attorney for Applicants) Jo Anne Sanford tM ittorney General's
< Raleigh 1600 M St. 104 Office by hand Washington, DC 20036 - F.qx.62S
- 4 Spence /aleien Y%rryEC" 27602 l -
g Office of thetsExecutive Attn Docke 50-400A010.L. Legal Director PW FEMA rt u m 81.0 l
USERC 500 C St. SW Washington DC 20555 (// % Washington DC 207h0 Dan Read Docketing and Service Section (3x) C);AMGEMLP 30x 2151 Attn Decke ts 50-h00/hC1 0.L.
Office of the Secretary Waleigh, NC 276062 SEC Dr. Linda W. Little washington Dc 20555 (r Plan only) Governor's Waste Met. Bd.
John Runkle Steve Rochlis 511 Albenarle B3dg.
CCNC FEFA, Suite 700 325 N. Salisburv St.
1371 Peachtree St. NE Rai n5n, NO 27611 307 Granville Rd '
Chapel Hill Nc 2751h / Atlanta GA 30309 Bradley W. Jones Robert Gruber USNRC Region II
~Travi s Payne Exec. Director 101 Marietta St.
Idelstein & Payne Public Staff Atlanta GA 30303 Box 12607 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D. Certified by A%
729 Hunter St.
Apex NC 27502
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