ML20107F385

Response to Conservation Council of North Carolina Interrogatories & Request for Production of Documents Re First Set of Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence

ML20107F385
Person / Time
Site:	Harris
Issue date:	10/31/1984
From:	Carrow H CAROLINA POWER & LIGHT CO.
To:	CONSERVATION COUNCIL OF NORTH CAROLINA
References
CON-#484-886 OL, NUDOCS 8411050461
Download: ML20107F385 (15)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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'In the Matter of

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CAROLINA POWER & LIGHT COMPANY.

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AND NORTH CAh0 LINA EASTERN

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Docket No. 50-400 OL

MUNICIPAL POWER AGENCY

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~ (Shearon Harris Nuclear Power Plant)

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APPLICANTS' RESPONSE TO CONSERVATION COUNCIL'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO APPLICANTS ON EMERGENCY PLANNING CONTENTIOP'S (FIRST SET)-

. Applicants' Carolina Power & Light Company ("CP&L") and North Carolina Eastern Municipal Power Agency, pursuant to 10. C.F.R. S 2.740b, hereby submit the following responses to " Conservation. Council's Interrogatories and Request for Production of Documents to' Applicants on Emergency Planning Contentions (First Set)". The provision of answers to these interrogatories is not to be deemed a representation that Applicants consider the information sought to be relevant to the issues to be heard in this proceeding.

SPECIFIC INTERROGATORIES 1

~ INTERROGATORY NO. 3-1: For each of the responses below, state who made the response, their position, and business address.

. ' ANSWER: The following list identifies individuals by name, title, address, and

'l

- indicates the particular interrogatories for which each such person provided information.

Jesse T. Pugh, III 3-4, 3-5, 3-6, 3-7, 3-8, Director, Division of Emergency Management 3-22, and 3-23 4

N.C. Department of Crime Control and Public Safety Raleigh, North Carotina 27611~

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~8411050461 841031 PDR ADOCK 05000400 O

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Robert G. Black,'Jr..

3-1, 3-2, 3-3, 3-9, 3-10, i Director, Emergency Preparedness 11, 3-12, 3-13, 3-14, Carolina Power & Light Company 3-15, 3-16, 3-24,'3-25

. P.O. Box 1551 s-

~ Raleigh, North Carolina 27602 -

- Wendell Murray, Jr.

3-21 3-17, 3-18, 3-19, 3-20, P

Associate Superintendent for Administrative Services Wake County Schools 601 Devereux Street Raleigh, North Carolina 27602 Perry Harrison 3-17, 3-18, 3-19, 3-20, Superintendent 3-21 Chatham County Schools P.O. Box 128 Pittsboro, North Carolina 27312 INTERROGATORY NO. 3-2: For each of the responses below, supply all basis for the response, including all material they relied on in responding (cite each fully).

ANSWER: The basis for each response is included in the response as appropriate.

INTERROGATORY NO. 3-3: What witnesses do Applicants expect to present in the -

hearing on this contention? For each,' include name, address, position, and summary of their testimony.

. ANSWER: Applicants have not yet identified the expert or other witnesses they expect to call in tills proceeding regarding this contention. When and if such witnesses are identified, Applicants will supplement this response in a timely manner.

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INTERROGATORY NO 3-4: What is the total number of volunteer workers -

. including volunteer police, rescue, fire departments, and teachers - expected to be utilized during an alert?

. ANSWER: An estimate of the total number of volunteer workers expected to be utilized 'during an emergency is not currently available.

INTERROGATORY NO. 3-5: For each of the workers enumerated in the response to Interrogatory 3-4 above, please answer the following:

a) what is his/her current position? (ex. volunteer fireman, etc.)

b) - what role is he/she expected to play during an alert?

c) how will he/she be alerted as to the emergency?

d). how long will it take him/her to arrive at his/her position during the alert after he/she is notified?

e).how long is he/she expected to be at that position?

f) what duties will he/she be expected to fill during the alert?

g).in what manner will he/she be permitted to communicate with his/her family while at his/her position?

h) is he/she expected to relieve any other workers (paid or volunteer)?

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-1) how will he/she be allowed any time off for food or necessities while on duty?

ANSWER: a-b) The workers belonging to volunteer agencies function in current

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positions and roles assigned to them by that agency. Roles for the agencies involved in

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the emergency response are detailed in the ERP. Roles during an emergency at SHNPP would be; assigned in accordance with the agency's established plans and would be

-adjusted to the timing, scope, and extent of the emergency as it develops. Identified roles by individual worker or by individual position other than key positions are not

'available.

c-d)

Workers will be alerted to an emergency and their need to respond in

accordance with plans developed for each agency. In the case of fire departments, rescue squa'ds, and sheriff's departments, the agency's normal procedures for worker notification are based upon the agency's existing emergency response function and have been proven effective in achieving a timely response by individual workers. The response 4

time for individual workers will vary according to their location at the time of

notification and their assigned duty station. Information on the time needed for an individual worker to arrive at his or her position is not available.

e)' Provisions will be made to provide relief for emergency workers on a schedule which is consistent with the development of the emergency, weather conditions, and

.-assoc ated protective actions. The length of time individual workers remain in their i

positions will vary, and it is not possible to identify this duration with accuracy except under actual emergency conditions.

f) See response to a-b.

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. g) Workers will be able to communicate with their families at times and in a manner in which is consistent with the effective conduct of their assigned duties.

b Workers will participate in periodic training programs, drills, and exercises which will

~ give them a thorough familiarity with their assignments and locations during an actual emergency. These training programs, drills, and exercises will afford each worker the

opportunliy and motivation to discuss with his or her family individual arrangements for communication well in advance of any actual emergency. This will both minimize the need for such communication and will also greatly facilitate effective communication between workers and their families.

h) Workets may be requested to relieve other workers.

i) In many cases, the duties of emergency workers will be finished within a few hours, and breaks for meals are not likely to be needed.

IN.TERROGATORY NO. 3-6: What training will each of the workers enumerated in the response to Interrogatory 3-4 above receive in the following areas:

a) the duties he/she is expected to perform during an alert?

b) the hazards of radiation?

c) the proper use of monitoring devices?

d) the proper use of protective gear?

e) how to communicate to others under his/her supervision what is happening during the alert?

ANSWER: a-e) Workers in each agency receive training for the duties they are expected to perform from several sources. In many cases, the duties of workers during an emergency at SHNPP are identical to those undertaken during the normal operations of the specific agency; e.g., traffic control and transport of nonambulatory patients.

Training for these duties is included in the standard programs provided by the agencies.

This training encompasses needed techniques and procedures, and the operation of specialized apparatus, vehicles, protective gear, and communications equipment. In the 1

event of an emergency at SHNPP, additional techniques, concepts, and plans will be utilized by the -workers involved in 'the response that supplement the skills used by the workers during normal agency operations. Training for these additional skills is obtained through training progr&ms at the state, county, and local level including the conduct of drills and exercises of the ERP, The North Carolina Division of Emergency Management offers a " Basic Radiation Emergency Preparedness Course." A copy of the course outline is attached. The course is a 33-hour program, divided into 3 modules, and its lessons include discussion of the __

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hazards of. radiation and the use of radiological monitoring equipment as well as other

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relevant topics.

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INTERROGATORY NO. 3-7:

For any training described in the response to Interrogatory 3-6 above, please answer the following:

a) who will conduct the training?

b) how often will the training be conducted?

c) will any of this training be certified?

d) how will the persons doing the training ascertain whether all of the volunteer workers needing training have been both trained and trained properly?

ANSWER: a-b) Training is conducted by state, county, and local agency staff.

Training in normal agency operations is conducted by agency personnel or outside trainers and varies in frequency and certification procedures from agency to agency.

Evaluation by agency management of the agency's operations and the effectiveness of individual workers measures the need for training and that training programs have been appropriate.

With regard to the " Basic Radiation Emergency Preparedness Course" (BREP) offered by the state, NCDEM normally offers this program to individuals designated as instructors who in turn provide training to individuals within county and local agencies.

In Wake County, 42 instructors have been trained to date and certified for successfully completing the program. In Chatham, Lee, and Harnett Counties, a total of more than 200 workers have taken Module 1 and/or Module 2 of the program.

DEM continues to offer this course on a periodic basis and recommends that trainees take refresher courses annually. Trained instructors, operating at the county and local agency level, follow the attached outline as a guide in presenting their courses. 4 1-

n, The emergency response drills and exercise that will be held in accord with the ERP are an important mechanism for training emergency workers in specific operations needed in event of an emergency at SHNPP.

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The knowledge and skills taught during the BREP program, testing and certification of instructors, the use of the BREP as a guide for training of emergency workers, and the testing of workers through drills and exercises, assure that proper training has occurred.

INTERROGATORY NO. 3-8:

Please provide a brict summary of the training described in the response to Interrogatory 3-6 above.

ANSWER: The attached course outline summarizes the BREP discussed above.

INTERROGATORY NO. 3-9: Have the Applicants contacted all organizations and agencies which are expected to supply volunteers during an alert?

ANSWER: The Applicants have not contacted all such orgarizations and agencies.

INTERROGATORY NO. 3-10:

Which agencies and organizations have been contacted?

ANSWER: To date, the Applicants had direct contact with two agencies:

1.

Wake County EMS 2.

Harrket County Volunteer Fire Department In addition, the Applicants have been in contact with state and county emergency preparedness officials who are in frequent communication with individual agencies.

INTERROGATORY NO. 3-11: For each agency listed above in the response to Interrogatory 3-10, please answer the following:

a) who made the contact?

b) which personnel of the agency or organization was contacted?

c) when were these contacts made?

d) what was discussed during each contact?

e) have memoranda of understanding (MOUs) or any other such documents been signed with any of the contacted egencies?

ANSWER: a) Contact was made by staff of CP&L and its contractor, Ebasco Services.'

b) The head of each agency was contacted.

c)

Wake County EMS-10/16/84; Harnet County Volunteer Fire Department-

.09/28/84...

d) Topics relevant to their roles in emergency plan operation.

- 6) No MOU's or other documents have been signed or executed between these agencies and the Applicants. Such agreements are not normally expected between these agencies and an applicant.

INTERROGATORY NO. 3-12: Have Applicants or'any person under their direction studied the potential role conflicts in volunteer workers which might occur around the Shearon Harris site during an emergency?

ANSWER: Applicants know of no such studies of " role conflict." However, the potential for role stress has been generally considered in emergency pir.nning for SHNPP. See response to 3-5g.

~ NTERROGATORY NO. 3-13: Are Applicants aware of any studies made of role I

conflict around any other nuclear plant during an emergency?

ANSWER: The Applicants are aware of none.

INTERROGATORY NO. 3-14: Are Applicants aware of any studies made of role conflict during any other emergencies, i.e. not related to nuclear plant evacuation?

ANSWER: Applicants are not aware of any such formal studies of " role conflict."

However, according to emergency management officials in NCDEM and the counties of Wake, Lee, Harnett, and Chatham, the availability of emergency workers has never impeded the response to other natural and man-made disasters.

INTERROGATORY NO. 3-15: Have Applicants or any person under their direction studied the locations of the families of volunteer workers enummerated [ sic) to the response to Interrogatory 3-4 above?

ANSWER: No.

INTERROGATORY NO. 3-16: If the response to Interrogatories 3-12 through 3-15 above is affirmative, please provide a copy of that study or studies.

ANSWER: Not applicable.

INTERROGATORY NO. 3-17: Do the contracts of teachers who are expected to respond to an alert contain explicit provisions relating to such alerts?

ANSWER: Neither Wake County or Chatham County school systems include special provisions in teacher contracts regarding teachers' duties at the time of a radiological emergency at SHNPP. Both school systems do, however, require the teachers to care for the students' health, welfare, and reasonable safety while students are in their care. )

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. INTERROGATORY NO. '3-18:

If L the response to Interrogatory 3-17 above is affirmative, what provision are in the teacher contracts' ANSWER: See response to Interrogatory 3-17.

7 INTERROGATORY _ NO. 3-19: How many students will each teacher be expected to

- supervise?

ANSWER: '_ The emergency response planning for the Wake County and Chatham County school systems is under development at this time, and specific information on

this topic is not available. Generally, however, it is anticipated that at least one teacher

. or school administrator will accompany each bus load of students.

~ INTERROGATORY NO. 3-20: How many teachers and students will be on each bus?

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' ANSWER:

The numbers of students and teachers on each bus has not been determined as of this date (see response to 3-19). However, it is expected that during an L evacuation, each available bus seat will be filled.

INTERROGATORY NO. 3-21: How many teachers and students will be in each

' shelter? -

ANSWER: To date, it has not been determined how many students and teachers

will be at each shelter. The role of teachers would be generally reduced as students are

. joined with other members of their families.

INTERROGATORY NO. 3-22: How many of the volunteer 'torkers expected to respond to an alert willin fact respond? Please explain the response.

ANSWER: ~It is expected that the designated number of volunteer workers required

'to fulfill each agency's role in a protective action will respond. This answer is based upon extensive past experience with volunteer worker response to other natural and man-made emergencies. -

. INTERROGATORY NO. 3-23:

What steps have been taken to identify those i;

' volunteer workers which might not respond to an alert?

ANSWER: Because past experience in North Carolina demonstrates that volunteer workers consistently respond in sufficient numbers, no such steps have been taken.

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INTERROGATORY NO. 3-24:

For which organizations (volunteer and non-

' volunteer),' have the Applicants paid attention to the composition which would avoid conflict between organizational and family responsibilities?

ANSWER: The Applicants have not directly evaluated this topic. However, the

- planning, training, and practice drill programs will provide opportunities for agencies and workers to resolve any such conflicts prior to operation of SHNPP.

. INTERROGATORY NO. 3-25: For each organization identified in the response to Interrogatory 3-24, what was done?

ANSWER: Not applicable.

1. ay of October,1984.

This the 31 d

Hill Carrow Attorney Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6839 Attorneys for Appilbants:

Thomas A. Baxter Delissa Ridgway Sh' w, Pittman, Potts & Trowbridge a

1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn Dale E. Hollar Carolina Power & Light Company Post Office Box 1551

' Raleigh, North Carolina 27602 (919) 836-6517 7

ATTACHMENT 1 9

BASIC RADI AT10N DERGENCY PREPAREDNESS COURSE _

tst llodule--8 hours Unit I3 ass Time Lesson Title 1

30-Administrative Detail Radiological Instruments 1:30-

" Radiological Inst."

Radiological Instruments 2

1:00'

' Radiological Inst."

Radiological Instruments

30 Exposure Records Radiological Instruments 1:00 Exercise-

• Instrument Radiological Instruments Familiarization

• 3 1:00

• Protective Peasures*

Protective Measures

• 3o

• Time-Distance-Shielding Protective Measures 1:00 Esercise-

• Radiation Protective Measures Protection"

'4 1:00

• Protective Measures

• Protective Measures Clothing, Decontamination Protective Measures

30

• NC Department of Crime Protective Measures Control & Public Safety and NC Department of Human Resources

• Responsibilities 2nd Hot ule--3 hours 1

30 Administrative Details Transportation Accidents

)1 1:30

• Labels, Placards, Shipping Documents, & Packaging

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Requirements

• 2 2:00

• Types of Radiation Accidents & Procedures

• Transportation Accidents 3

1:00 Proper Response & Notif f cation Transportation Accidents Procedures County Plan or

• Prototype 50P*

Emergency Response Plan for Flaed Nuclear Fact 11 ties

30 Film: " Radiation Accident Patients

• Discuss

30 Film: ' 'Ftrefighting in the Nuclear Age

• Discuss 4

1:30

• Techniques of Personnel &

Vehicular Monitoring

• Transportation Accidents 1:00 Esercise

' Vehicular Monitoring Transportation Accidents 3rd flodule--I7 hours 1

30 Aestnistrative Details 2:30

• Molecular Structure

• Basic Muclear Science 2

2:30

• Blological Ef fects*

Basic Nuclear Science 2:00

• State Emergency Response Plans Emergency Response Plans C

in Support of Fixed Nuclear for Fixed Nuclear Factiftfes Facti t tles*

3 3:00

• Mock Transportation Acetdent*

Mock Transportation Acetdent e

4 3:00

• Effects of Nuclear Weapons

• Nuclear War

• Emposure & Esposure Rate Calculations

• Nuclear War 5

1:00 Course Review 3:00 Exas: Written & Practical I

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'[

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

' In the Matter of

)

)

CAROLINA POWER & LIGHT COMPANY

)

AllD NORTH CAROLINA EASTERN

)

Docket No.

50-400 OL MUN'CIPAL POWER AGENCY

)

)

(Shearon Harris Nuclear Power Plant)

)

AFFIDAVIT OF B. J. FURR County of Wake

)

)

State of North Carolina

)

B. J. Furr, being duly sworn according to law, deposes and says that he is Vice President - Operations Training and Technical Services of Carolina Power & Light Company; that the answers to interrogatories on Contention EPJ-3 contained in

" Applicants' Response to Conservation Council's Interrogatories and Request for.

Production of Documents to Applicants on Emergency Planning Contentions (First Set)"

are true and correct to the best of his information, knowledge and belief; and that the sources of his information are officers, employees, agents and contractors of Carolina Power & Light Company, and employees and agents of the State of North Carolina.

Bis 3 15I day of October,1984.

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to:and subscribed before

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~ My commission expires:

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' UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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CAROLINA POWER & LIGHT COMPANY

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AND NORTH CAROLINA EASTERN

)

Docket No.

50-400 OL

' MUNICIPAL POWER AGENCY

)

)

(Shearon Harris Nuclear Power Plant)

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to Conservation Council's Interrogatories and Request for Production of Documents to Applicants on Emergency Planning Contentions (First Set)" were served this 31st day of October,1984 by deposit in the United States mail, first class, postar;e prepaid, to the parties on the attached

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Service List.

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Hill Carrow Attorney Carolina Power & Light Company Post Office Box 1551 Raleigh,' North Carolina 27602 (919) 836-6839 Dated: October 31,1984 P

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~l SERVICE LIST

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James L. Kelley, Esquire '.

M. Travis Payne, Esquire Y

' Atomic Safety and Licensing Board.

Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643

. Washington, D. C.: 20555 -

Raleigh, North Carolina 27605 Mr. Glenn O. Bright.

Dr. Richard D. Wilson Atomic Safety and Licensing Board. -

729 Hunter Street "U. S Nuclehr Regulatory Commission Apex, North Carolina 27502

. Washington, D. C. 205551 Mr. Wells Eddleman Dr. James H. Carpenter 718-A Iredell Street '

Atomic Safety and Licensing Board Durham, North Carolina 27705

. U. S. Nuclear Regulatory Commission e

Washington, D. C. 20555 Thomas A. Baxter, Esquire John H. O'Neill, Jr., Esquire -

Charles A. Barth, Esquire

'Shaw, Pittman, Potts & Trowbridge

Myron Karman, Esquire ~

1800 M Street, NW -

Office of Executive Legal Director Washington, D.C. 20036 r

' U. S. Nuclear. Regulatory Commission 1 Washington, D. C. 20555 Bradley W. Jones, Esquire U. S. Nuclear. Regulatory Commission

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Docketing and Service Section Region 11 Office of the Secretary 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 4

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. Washington, D. C. 20555

. Robert P. Gruber Mr. Daniel F. Read, President Executive Director Chapel Hill Anti-Nuclear.

Public Staff i

Group Effort North Carolina Utilities Commission LPost Office Box 2151 Post Office Box 991 4

Raleigh,' North Carolina 27602

. Raleigh, North Carolina 27602 Dr. Linda Little

~ Governor's Waste Management Board 513 Albemarle Building 325 Salisbury Street e

iRaleigh, North Carolina 27611

'Mr. Steven Crockett, Esquire

' Atomic Safety and Licensing Board Panel' j.

U. S. Nuclear Regulatory Commission

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Washington, D. C. 20555 John D. Runkle, Esquire Conservation Council of North Carolina 307 Granville Road l-Chapel Hill, North Carolina 27514 l

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Hitt CARROW October 31,'1984 The attached cover letter was inadvertently omitted from the-Applicants' filing to answers to CHANGE Interrogatories on 10/29/84.

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P. O. Box 1551, Haleigh, N. C. 27602

Carolina Power & Light Company Post OFFICE box 1551 Raleigh, North Carolina 27602 LEGAL DEPARTMENT.

Writer's Direct Dial Number ^

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October 29,1984 T,

(919) 8 % -7678 Mr. Daniel F. Read, President Chapel Hill Anti-Nuclear Group Effort Post Office Box 2151 Raleigh, North Carolina 27602

Dear Mr. Read:

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Please find enclosed " Applicants' Response to (CHANGE] Emergency Planning Interrogatories and Request for Production of Documents [on Contention EPJ-1, EPJ-2 and EPJ-41".

It should be noted that the last day for filing discovery requests on Contentions EPJ-l and EPJ-2 was August 9,1984. Your interrogatories on those two issues were filed on October 8,1984 - two months late. Despite the very late nature of this filing, Applicants have proceeded to answer the EPJ-1 and EPJ-2 interrogatories.

However, in no event should this be deemed a waiver of Applicants' right to object to the interrogatories as untimely. Applicants here specifically reserve the right to object to interrogatories on Contentions EPJ-l and EPJ-2 on this basis.

Sincerely, Hill Carrow Attorney C/c Enclosure u __