ML20093J305

Response to W Eddleman General Interrogatories to Applicants (Ninth Set).Certificate of Svc Encl.Related Correspondence

ML20093J305
Person / Time
Site:	Harris
Issue date:	07/25/1984
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	EDDLEMAN, W.
References
OL, NUDOCS 8407300026
Download: ML20093J305 (49)

Text

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RELATED CCW.5FCNDENCE, July 25,1984 cm an n W.,4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSid84 Jll 27 m :32 BEFORE THE ATOMIC sal'ETY AND LICENSING BOARD 00 - Mis 1i ff

~B:-:.mO1 In the Matter of )  ;

) -

CAROLINA POWER & LIGHT COMPANY )

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

)

-(Shearon Harris Nuclear Power Plant, )

Units 1 & 2) )

APPLICANTS' RESPONSE TO WELLS EDDLEMAN'S GENER-AL INTERROGATORIES TO APPLICANTS (Ninth 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 " Wells Eddleman's General Interrogatories to Applicants Carolina Power &

Light et al. (Ninth 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 lasues to be heard in this proceeding.

OENERAL INTERROGATORIES l INTERROGATORY NO. Gl(a). Which contentions of Wells Eddleman do Applicants agree are now admitted in this proceeding, NRC Dockets 50-400/4010.L.?

ANSWER: The contentions of Intervenor Eddleman which are admitted to this proceeding are set forth in various memoranda and orders issued by the Atomic Safety and Licensing Board, all of which are available to Mr. Eddleman. I INTERROGATORY NO. Gl(b). [F]or each such contention, provide for any answers to interrogatories by Wells Eddleman which Applicants have previously or presently received (except those suspended by Board order, if any), the following information:

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ANSWER: The answers to General Interrogatories herein are restricted to 7

Eddleman Contentions 30,57-C-3,57-C-10,57-C-13,213,215 and 224.

4 f- INTERROGATORY NO. Gl(c). Please state the name, present or last known address, and present or last known employer of each person whom Applicants believe or  !

know (1) has first-hand knowledge ot* the facts alleged in each such answer; or (2) upon whom Appilcants relied (other than their attorneys)in making such answer.

ANSWER: The following list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Contentions 30,57-C-3, 57-C-10, 57-C-13, 213, 215 and 224 and indicates the particular interrogatory answers  !

for which such perso1 orovided infomation l PERSON INTERROGATORY NO.

Jesse T. Pugh, til 57-C-3-1(a),(b),(e),(f),

Division of Emergency Management 57-C-3-2, 213-1, 213-2, 57-C N. C. Dept. of Crime Control and 4(a)-(d), (f)

Public Safety Rsleigh, N. C. 27611 Charles D. Reed 30-1, 30-2 Adult Health Services rection I Division of Health Services N. C. Dept. of Human desources P. O. Box 2091 Raleigh, N. C. 27602 Dayne H. Brown 57-C-10-1, 57-C-10-2, 57-C-10-3, .

Radiation Protection Section 57-C-10-4(b)-(f), 57-C-13-1(a)-

Division of F,wilit/ Services (e),(g), 57-C-13-2(a) ,

N. C. Dept. c f Human Resources P. O. Box 12200 Raleigh, N. C. 27605 -

Robert D. Klimm 215-1 through 215-9, 224-1, 224-2 HMM Associates,Inc.

336 Baker Avenue Concord, Mass. 01742 Carolyn Anderson 215-1 through 215-3, 215-5(a)-(d)

Carolina Power & Light Co.

Shearon Harris Energy &

Environmental Center Route 1, Box 327 l New Hill, N. C. 27562 <

h i

Dr. William H. Wilkie 57-C-10-1 through 57-C-10-4, 57-C-Carolina Power & Light Co. 13-1, 57-C-13-2 ,

Shearon Harris Energy &

Environmental Center  ;

. Route 1, Box 327  :

New Hill, N. C. 27562 I INTERROGATORY NO. Gl(d). (P] lease identify all facts concerning whleh each such person identified in response to Gl(cXI) above has first-hand knowledge.  ;

I

ANSWER: See answer to Interrogatory No. Gl(c).

INTERROGATORY NO. Gl(e). (P] lease identify all facts and/or documents upon .

which each person identified in response to Gl(cX2) above relied in providing information 1 to respond to the interrogatory, including the parts of such documents relied upon.

l ANSWER: All facts or documents relied upon by those individuals identified above are indicated within each response to the specific interrogatories on Contentions 30,57- ,

r C-3, 57-C-10, 57-C-13, 213, 215 and 224.

INTERROGATORY NO. Gl(f). Please identify any other document (s) used or relied I upon by Applicants in responding to the interrogatory.

ANSWER: See Answer Gl(e).

INTERROGATORY NO. Gl(g). Please state which specific fact each document, identified in response to Gl(e) and Gl(f) above, supports, in the opinion or belief of '

Applicants, or which Applicants allege such document supports. .

1 ANSWER: Applicants have indicated which specific facts are supported by the f

documents identified, within each response to the specific interrogatories on Contentions  ;

30, 57-C-3, 57-C-10, 57-C-13, 213, 215 and 224.

INTERROGATORY NO. Al(h). Please state specifically what information each  !

person identified in response to Gl(cXI) or Gl(cX2) above provided to or for Applicants' l*

affiant in answering the interrogatory. If any of this information is not documented, please identify it as " undocumented" in responding to this section of General  :

Interrogatory Gl.  ;

ANSWER: See Answer Gl(c).

INTERROGATORY NO. 02(a). Please ~ state the name, present or last known address, title (if any), and present or last known employer, and economic interest i (shareholder, bondholder, contractor, employee, etc.) If any (beyond expert or other l witness fees) such person holds in Applicants or any of them, for each person you intend ,

or expect to call as an expert witness or a witness in this proceeding,if such information has not previously been supplied, or has changed since such information was last supplied, to Wells Eddleman. This applies to Eddleman and Joint Contentions as admitted, or stipulated by Applicants.

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r ANSWER: Applicants have not yet identified the expert or other witnesses they expect to callin this proceeding regarding these Eddleman contentions. When and if such witnesses are identified, Applicants w ll supplement this response in a timely manner.

INTERROGATORY NO. G2(b). Please identify each contention regarding which each such person is expected to testify.

ANSWER: See Answer G2(a).

INTERROGATORY NO. G2(c). Please state when you first contacted cach such person with regard to the possibility cf such person's testifying for Applicants, if you have contacted such person.

ANSWER: See Answer 02(a).

INTERROGATORY NO. 02(d). Please state the subject matter, separately for each contention as to which each such person is expected to testify, which each such person is expected to testify to.

ANSWER: See Answer G2(a). .

INTERROGATORY NO. 02(e). Please identify all documents or parts thereof upon which each such witness is expected to, plans to, or will rely, in testifying or in preparing testimony.

ANSWER: See Answer G2(a).

INTERROGATORY NO. G3(a). [P]! case identify any other 1ourec(s) of information which Appilcants have used to respond to any interrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifying where in such source that information is to be found.

ANSWER: Appilcants have identified all other such sources of information,if any, within the answers to the specific interrogatories set forth herein.

INTERROGATORY NO. G3(b). [P]Icase identify any other source (s) of information not previously identified upon which any witness identified under G2 above, or other witness, has used in preparing testimony or exhibits, or expects to use in testimony or exhibits, identifying for each such source the witness who is expected to use it, and the part or part(s) or such source (if applicable) which are expected 'o be used, and, if not previously stated, the fact (s) or subject matter (or both) to which such source relates.

ANSWER: See Answer G2(a).

INTERROGATORY NO. 04(a). [P]! case identify all documents, and which pages or sections thereof Applicants intend or expect to use in cross-examination of any l witness I call in this hearing. For each such witness, please provide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject matter Applicants believe they relate to, and make the document (s) available for inspection and copying as soon as possible after Applicants decide or form intent to use such document in cross-examination.

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P ANSWER: Applicants have not at this time identified which documents, if any, ,

i they intend h use in cross-examination of Mr. Eddleman's witnesses. '

INTERROGATORY NO. 04(b). [P] lease identify any undocumented information Applicants intend to use in cross-examination of each such witness for me.  ;

ANSWER: See Answer 04(a). v

?

INTERROGATORY NO. G5(a). [F]or each contention Applicants state or admit is an admitted Eddleman contention under Gl(a) above, or an admitted joint intervenor-contention, please state whether applicants have available to them experts, and informa-tion, on the subject matter of the contention.

ANSWER: Applicants have available to them experts and information on the subject matter of Contentions 30,57-C-3,57-C-10,57-C-13,213,215 and 224.

INTERROGATORY NO. 05(b). If the answer to (a) above is other than affirmative, I

' state whether Applicants expect to be able to obtain expertise in the subject matter, and information on it, and if not, why not.

ANSWER: Not applicable.

INTERROGATORY NO. G6(a). [11or each document identified in response to any  !

interrogatory herein, or referenced in response to any interrogatory herein, please supply  !

all the following information which has not already been supplied: l l (I) date of the document (ii) title or identification of document (iii) all authors of the document, or the author ,

(iv) all qualifications (professional, technical) of each author of the document r

(v) the specific parts, sections or pages, of the document, if any, upon which Applicants rely (vi) the specific information each part, section or page ider.tified in response to ,

(v) above contains.

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. (vil) identify all documents used in preparing the document, to the extent known ,

(and also to the extent not identified in the document itself) t (vill) state whether Applicants possess a copy of the document I (ix) state all expert opinions contained in the document, upon which Applicants rely, or identify each such opinion.

(x) identify the contention (s) with respect to which Applicants rely upon (a) the expert opinions (b) the facts identified in the document r

I' (xi) state whether Applicants now employ any author (s) of the document, identifying each person for each document.

(mil) state whether Applicants have ever employed any author (s) of the document, identifying each such person for each document.

(xill) identify all sources of data used in the document. Answers to all the above may be tabulated or grouped for efficiency.

ANSWER: All such information available to the Applicants with regard to each document identified in response to an interrogatory herein is contained in the particular document which is being made available to Mr. Eddleman, it would be particularly burdensome for Applicants to research all historical employment records to determine L whether the authors of each document identified herein have ever been employed by l - Applicants. However, Applicants willsupplement this response in a timely manner if and when Mr. Eddleman identifies any such author regarding whom he is particularly interested in determining this Information.

INTERROG ATORY NO. 07(a). Please identify all documents which Applicants plan, expect or intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which (i) is included in your current response to Gl(a), or (ii) is the subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is expected to be offered.

ANSWER: Applicants have not yet identified those documents they intend to offer as exhibits relating to Contentions 30,57-C-3,57-C-10,57-C-13,213,215 or 224.

INTERROGATORY NO. 07(b). Please identify all documents which Applicants plan, expect or intend to use in cross-examination of any other parties' witnesses or joint in-terrenor witness in this proceeding, with respect to (1) Eddleman contentions identified under 07(a)(1)(or 01(a)) above, or any other Eddleman contention which is the subject of interrogatories in this sett (11) each Jo!nt contention now admitted in this proceedings (111) per our agreement of 4-8-83, each contention of each other party to this proceeding whleh is currently admitted. Please identify for each such document the witnesses, or witness, and all contentions with respect to whom (or which) that document is planned, expected, or intended to be offered or used.

ANSWER: Applicants have not yet identified those documents they intend to use for eross-examination of any witness.

U INTERROGATORY NO. 07(c). Please identify which of the documents identified in 8-

response to (b) above (i) will be offered into evidence by Applicants, and (11) which of the same documents Applicants expect to offer into evidence or intend to offer as evidence or exhibits in this proceeding.

ANSWER: See Answer G7(b).

INTERROGATORY NO. GIO(a). Where the above general interrogatories, and/or specific interrogatories below, or any of them, call for identification of documents, (i) and no documents are identified, is that the same as Applicanta stating that there are no documents responsive to this generat interrogatory, in each case where no documents are identified? (ii) and documents are identified, is that the same as Applicants stating that the identified documents are the only ones presently known which are responsivo to the interrogatories? (iii) If your answer to GIO(a)(ii) is other than affirmative, please stato all reasons for your answer. (iv) If your- answer to GIO(n)(i) above is other than affirmative, please stato all reasons for your answer.

ANSWER: (1) Yes.

(11) Yes.

(iii) Not applicable.

(iv) Not applicable.

INTERROGATORY NO. GlO(b). Where any interrogatory, general or specific, herein, calls for factual information (i) and an opinion is stated in response, is that the expert opinion of any person (s) identified as having contributed information to that response? (ii) and facts are given or identified (or a fact is) in responso, but no documents are identified, does that mean Applicants have no documents containing such fact (s)?

(iii) If your answer to (1) above is affirmative, please state for cach such responso all qualifications of each expert upon whom Applicants rely for cach such answer. The qualifications need be stated only onco for each such person if they are clearly referenced in other answers. (iv) If your answer to (1) above is other than affirmativo, please stato which opinions, if any, given in response to interrogatories (general or spc-cific) herein is the opinion of an expert, identify each expert whose opinion you used in response to cach interrogatory, and stato in full the qualifications of cach such expert.

(v) If your answer to (i) abovo is other than affirmativo, pleaso identify all opinions of non-experts used in your responses, and identify each non-expert whose opinion is included in e6ch answer herein. (vi) If your responso to (11) above is other than

, affirmativo, please identify each document which contains a fact not previously documented in your response (s), stating what the fact is, and at what page, place, chapter or other cpecific part the document contcins such fact.

ANSWER: (i) Yes.

(11) Sco Answers 01(c), (f) and (g) and GIO(a)(1) above.

(111) See Attachments A-F attached hereto.

(iv) Not applicable.

(v) Not applicable.

(vi) Not applicable.

INTERROGATORY NO. Gil. For each answer to each interrogatory herein (or any subpart or part thereof), please identify each item of information in possession of Applicants (including facts, opinions of experts, and documents) which (a) contradicts the answer you made, (1) in whole (11) in part (please identify each such part for each item of information identified); (b) easts doubt on your answer (i) in whole (ii) in part (please identify each such part for each item of information identified); (c) Please identify all documents not already identified in response to parts (a) and (b) above (and their subparts) which contains any item of information asked for in (a) or (b) above. Please identify for each such document what information item (s) It contains and what answer (s) each such item is related to.

ANSWER: Gil(a)-(c): Appheants have no such information.

INTERROGATORIES ON EDDLEMAN 57-C-3 INTERROGATORY NO. 57-C-3-l(a): Do you know of any provisions for nighttime notification of residents or transients (i) within the EPZ (ii) who are asleep (iii) who ace in boats or houseboats or other craft on either (lil-a) Jordan Lake, or (!!!-b) the liarris plant lake?

(b) What are these provisions? Please Identify all documents containing such provisions and state which such documents are part of the emergency response plan (offsite) for Shearon liarris. If any such document is part of another emergency response plan, e.g. Ilarris on-site plan or other state or county emergency response plan or contingency plan, please identify that plan also, for each such document.

(c) What provisions, if any, are in the brochure to be sent to EPZ residents, concerning action to take if a nuclear accident occurs at night?

(d) What provisions among these concern sheltering, turning off air conditioners or air-to-air heat exchangers, or closing windows? Please identify each such provision and which of the above items it relates to.

(e) Do you know of any plans for telephone notification of (i) residents of the EPZ (11) transients in motels, hotels or other lodging in the EPZ, for accidents at the liarris nuclear plant? If so, please identify each such plan and all documents concerning it.

(f) llave you ever considered telephone notification of persons within the EPZ in the event of a nuclear accident? If so, please identify all documents concerning your consideration of this matter.

ANSWER: (a) - (b): Current planning does not include any additional or special provisions for nighttime notification of EPZ residents, boaters and others on Jordan or

Harris Plant lakes above those provisions presently incorporated within the North Carolina Emergency Response Plan in Support of the Shearon liarris Nuclear Power Plant. The provisions for_ EPZ residents and Jordan Lake are included in Part 2, Annexes C and G. The provisions for the liarris Reservoir are under development as Annex J and will be similar to those for Jordan Lake.

(c) - (d): A draft copy of the public Information brochuro was served on the parties e

to this proceeding on July 9,1984.

(e) There are no plans in existence, or currently under consideration, for telephone notification of individual residents or transients within the EPZ.

(f) Telephone notification of persons with*n the EPZ was considered in the planning process. Ilowever, there is no formal documentation concerning the details or scope of this consideration.

INTERROGATORY NO. 57-C-3-2(a): Are automatic telephone dialing systems available to (i) CP&L (!!) the State of NC (iii) Wake County (iv) Chatham County (v)

!!arnett County (vi) Lee County (vil) other authoritics who would be involved in ordering sheltering in the ovent of a nuclear accident at liarris?

(b) What are the capabilitics of the automatic telephonc dialing systems available to cach such organization? Please include in your answer (1) number of numbers dialed per hour (ii) ability to dial a preprogrammed set of numbers (111) ability to have input a set of numbers to dial (iv) ability to automatically dial back if the phone is hung up before a message is completed (v) length of message the system can deliver (vi) audio quality of message the system can deliver (vil) capacity of telephone lines (e.g. number of lines) the system requires, (vill) other technical requirements of the system, e.g. for power supply, actuation, reset if errors in dialing occur (ix) whether the system can function with a backup power supply if electrical power to it is lost, and whether such backup power supply is in fact provided for it.

(c) Please detail the capabilitics of any automatic telephone dialing system which you have (i) considered for use (ii) plan to buy (til) know is available for purchase.

ANSWER: (a) - (c): None of the entitics listed have available to them automatic telephone dialing systems for notification of the general public in the event of an accident at the liarris Plant. There are no plans to purchaso any such system, and the specific capabilities of such systems have not been evaluated.

INTERROGATORIES ON EDDLEMAN 213 INTERROGATORY NO. 213-1(a): What is the specific responsibility of (i) CP&L (11) the State of NC (iii) Wake County (iv) any other authority or agency you know of, for notifying boaters, swimmers or others on or in the liarris plant take in the event of a nuclear accident at liarris?

(b) Please list every means by which you will carry out such notification, and state which document (s) detail these means, your authority or ability to use them, and what personnel are required to operate these means (number of persons, where they work, who will notify them, how long they will take to begin operating the means of notification.

(c) Please state how long each means of notification will take to notify all persons on or in the liarris lake, and for each means, what backup means of notification will be used if there is a failure of the first means. Please also describe the provisions for sheltering or evacuation which will be announced to persons on or in the liarris take.

(d) What means, if any, are provided for verifying that persons on the !!arris lake have been notified of an accident at liarris? Who operates each such means? Who is responsible for each such means being used? Who will roccive the reports of such verification? Ilow will cach such person receive cach such report?

ANSWER: (a) Provisions for notification are currently under development as Annex J to the North Carolina Emergency Response Plan for support of the Shearon liarris Nuclear Power Plant. These provisions will be similar to those published for Jordan Lake. The concept of planninJ presently visualizes Wako County as the responsible agency for implementing and controlling notift:ation on liarris Reservoir.

(b) See answer (a) above. The primary system for notification will be fixed sirens.

As a supplement to the primary system, nutification methods will include red flares or smoke which would be released by emergency workers. Boats, fixed wing airplancs and helicopters will >e used for confirmation purposes. Notification methods will be highlighted at strategic points around the lake by signs explaining these notification procedures and including instructions to turn on radios or television sets for emergency information. Details regarding emergency personnel and their reaction times for liarris Reservoir have not been finalized at this time. The ability to utilize these notification methods will be demonstrated and evaluated during the upcoming lleensing exerciso in December 1984.

F' (c) The primary notification system of fixed strens should provide rapid notification once the deelslon has been made to alert the public. Reaction times to employ the means identified in answer (b) above cannot be attested to at this time.

However, these times will be determined before or during the licensing exercise in December 1984 when these provisions will be tested and evaluated.

(d) Verification methods will include the use of boats, fixed wing airplanes and helleopters. Verification reporting is planned to be accomplished by radio directly from emergency personnel in the field to the responsible Wake County Emergency Operations Center.

INTERROGATORY NO. 213-2(a): In what respects do provisions for notification of persons (1) on fil) in (111) on the shores of, the liarris plant lake, differ from provisions for notification of persons in or on corresponding parts or areas near Jordan take? (This means for notification of an accident at the liarris plant.)

(b) for each such difference in provisions, do you have any reason for the differe .ce? If so, please state in what documents your reason, or reasoning, for having this difference in notification provisions for the liarris and Jordan lake areas, is.

(c) Please explain any modifications to be made in notification provisions for the people in, on or around the !!arris take by (1) Wake County (11) CP&L (111) other emergency planners, including the State of NC.

ANSWER: (a) See answer 213-1(a) above. Primary alerting and notification procedures are expected to be similar. Ilowever, notification of liarris Reservoir will be initiated by Wake County while notification for Lake Jordan will be initiated by Chatham County.

(b) The bodies of water fall within different jurisdictional boundaries.

(c) See answer 213-1(a) above.

INTERROGATORIES ON EDDLEMAN 57-C-10 i INTERROGATORY NO. 57-C-10-1(a) What study, if any, have you made of ,

sheltering effectiveness for shelters typical of those available within the liarris EPZ?

l (b) Please identify all documents in which yo'u make such study, or any analysis of sheltering effectiveness for such shelters.

(c) What study, if any, do you plan to make of sheltering effectiveness for shelters typical of those to be available near liarris? When will cach such study be completed?

Who is doing each such study? What are thele qualificatic.w to do it? Whc will receive the results of each such study?

(d) Does any study referred to in your responses to (b) or (c) above establish sheltering effectiveness for (1) houses without basements (11) brick houses without basements (111) cinder block basements (iv) brick-walled basoments (v) basements abovo ground level (vi) basements sunk partly below ground lovel (vil) motels or Individual motel rooms (vill) restaurants (lx) public buildings (x) farm buildings (xi) storm collars (xil) wooden houses (xill) solar or passive solar houses (xiv) any structures,in terms of typical numbers of air changes per hour (xv) any structures,in terms of mensured numbers of air changes per hour (xvi) any structures, by relying on typleal charnetoristics of such structures?

(e) Please identify all documents containing data on the sheltering effectiveness, or measurements of air changes, or characteristles of shelters, which you havo used or will used [ sic] in addressing the offectiveness of sheltering for typical structures around the liarris plant.

(f) Please explain your method of assessing sheltering effectiveness for homes, etc.,in the liarris EPZ.

I ANSWER: (n) - (f) No such study of "typleal" structures has been mndo or is planned at this time. Ilut soo answer 4(a) below.

INTERROGATORY No. 57-C-10-2(n): linvo you mndo any determination of sheltering effectiveness for any (1) school (11) day enre center (111) church or other house of worship (iv) other structure open to the public or used by more than 10 persons (other than homes or apartments)?

1 (b) Was your deturmination of sheltering offectiveness made (I) for a typical such  !

structure (11) for n specific structuro (please identify)(111) by any other method 7 (c) Please explain, Identifying all documents used for data or assumptions, and identifying all calculations and methods used, how you determined the sheltering effectiveness for each type of structuro inquired about in part (n) abovo. .

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Ah8WER: (a) -(c): As explained in answer to Interrogatory No. 57 4(a) to (c) l below, the State of North Carolina has conducted a survey of structuros in throo of the countles within the EPZ. The results of this survey includo information on the protection I factor category of the structures. Documents concerning this survey will bo mndo available for review and copying upon request.

INTERROGATORY NO. 57-C-10-3(a): Plonso identify all documents, ,

methodologies, data, equations, calculations or other Informntion you invo used, or plan l to uno, in calculating or determining sheltering effectiveness for structures within the llarris EPZ.

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(b) Picase identify all documents containing such information.

(c) Please identify all documents you possess which describo methods of figuring, calculating, or assessing sheltering effectiveness.

(d) Please state why you have adopted or used any methods, data or calculations of sheltering effectiveness whleh you have used with respect to structures near liarris or in its EPZ.

1 (e) Please state and describe in as much detail as you know, what kinds of structures you consider " typical" of those available for sheltering in the liarris EPZ.

Please identify all documents or Information and all opinions you rely on in censidering each type or structure typleal. Ilow many types of structures havo you assessed sheltering effectiveness for within the liarrls EPZ7 ANSWER: (a) - (d): Documents will be mado available for review and copying upon request.

(e) A general description of typleal housing availablo for sheltering is contained in section 4.5 of the liarris on-sito emergoney plan. Structures within the EPZ are typicnl of those for a rural agricultural and residential area.

INTERROOATORY NO. 57-C-10-4(a): Do you possess any Information on tho (1) number (11) types (111) number of persons in (iv) times of day persons are in, structures in the liarris EPZ?

(b) Did you consider stores, schools, farm buildings, theaters, medical or dental offices, pubilo buildings, motels, day caro centers, or other building 11n collcoting data on types of shelter available in the llarris EPZ7 (c) If so, what data do you havo on each type of building inquired about in (b) above.

(d) For each type of building listed in (b) nbovo that you have no dati on or did not consider, please tell why you (1) have no datn on or (11) did not consider, that type of building.

(e) among the types of structures inqulrod about in this interrogatory 57-C-10-4, what structural characteristics, air-chango characteristle or other charneteristics do you think are appropriate to consider to determino sheltering offectiveness for each such ty;w?

If) Please identify all documents in which data, dclorminations or information concerning the matters inquired nbout in (a) thru (o) and nll subparts, inclusivo, nbove, are contained.

ANSWER: (a) - (b): Information on the number of persons and domographlo characteristics of the EPZ are contained in the HMM Associates, Inc. study entitled

" Evacuation Time Estimates for the Plume Exposure Pathway Emergency Planning Zone of Shearon Harris Nuclear Power Plant" (Oct.1983) ("ETE"). In addition, the State of North Carolina has surveyed structures within certain counties for the purpose of planning for wartime sheltering. These surveys presently encompass Wake, Harnett and Lee Counties. A similar survey of Chatham County is planned during fiscal year 1985.

The types of structures surveyed include stores (with the exception of foodstores),

schools, theaters, public buildings, motels, and day care centers. It does not include medical and dental offices.

(c) General data include protection factor (PF) category, shelteree space available, sanitary and dining facilities, and special use facilities. Detailed information on specific data is contained in the Federal Emergency Mt rement Agency publication, National Shelter 'lurvey Instructions, TR-84.

(d) The shelter surveys are designed to identify congregate care facilities, i.e.,

faellities which could potentially be used for temporary relocation of groups of persons during an emergency.

(e) The Radiation Protection Section, Division of Facility Services, N. C.

Department of Human Resources would consider the following to be among those characteristics which should be considered in the evaluation of any structure's sheltering effectiveness: (3 thickness and type of building materials; (2) construction techniques related to the air tightness of walls, ceilings, floors, windows and doors; (3) availability of basement areas as well as the number of floors above; (4) ventilation systems [ heating and cooling]; (5) the presence or absence of storm windows and the number of windows and doors.

(f) Documents will be provided for inspection and copying upon request.

INTERROGATORIES ON EDDLEMAN 57-C-13.

INTERROGATORY NO. 57-C-13-1(a): Have you made any determination of the best Protection Factor (PF) available in any (i) hospital (ii) nursing home within the Harris EPZ?

(b) If so, how did you make that determination? Was an on-site survey conducted? How did you get your data about characteristics of the structure? Did you consider any data about air infiltration into the structure? Please identify all documents concerning each determination of PF you have made for any school or hospital within the Harris EPZ and how that PF was determined.

(c) Have the data used in your PF determination been checked by anyone? If so, by t who and when? _ Please identify all documents concerning checking of such data.

(d) How many people can fit into the aree. with the best PF in each (i) hospital (ii) nursing home,in the Harris EPZ?

(e) .What provisions for patient characteristics (e.g. ambulatory, non-ambulatory, need for special medical supplies, need for nursing access, sensitivity to heat, to cold, or to reduced oxygen and/or stuffy conditions in a closed area) were included in your determination or estimate of how may [ sic] people will fit into the area of best PF in each specific (i) hospital (ii) nursing home, in the Harris EPZ?

(f) What is the maximum capacity of each (i) hospital (ii) nursing home within the Harris EPZ?

(g) What food supplies would be available in the area of highest protection factor in each (i) hospital (ii) nursing home, within the Harris EPZ, in the event of long-term sheltering being required? What water supplies would be available in the highest PF area within each such hospital or nursing home?

'(h) If all the people in the hospital or nursing home can't fit into the highest PF area, what is the PF of the next-highest PF area within such hospital or nursing home?

How many people can this next-highest PF area hold? What regard of medical conditions

. or needs of persons to be sheltered in this area was taken in your determination or estimate of how many people would fit into this area?

ANSWER: (a) - (h): No determination of the "best" protection factor available in any hospital or nursing home in EPZ has been made. The capacities of the hospitals and nursing homes in the EPZ are listed in Table 4-5 of the ETE. To the extent that subpart (b) requests information of the protection factor of any school, Applicants object to answering on the basis that the question exceeds the scope of Contention 57-C-13 as admitted.

INTERROG ATORY NO. 57-C-13-2(a): Are there any means of increasing PF for hospital or nursing home aress within the Harris EPZ that you have (i) considered (ii) recommended to the operators or owners of those hospitals or nursing homes?

a

[.  ;

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

(b) Are there any care facilities within the Harris EPZ which care for adults but which you define as being neither a hospital nor a nursing home? Please identify each such facility and state why you believe it is not included within the term " hospital or nursing home."

ANSWER: (a) No specific means of increasing protection factors for hospitals or nursing homes has been considered or recommended.

(b) Applicants are not aware of any care fdeilities other than those listed in Table 4-5 of the ETE, all of which are considered either a hospital or nursing home.

INTERROGATORIES ON EDDLEMAN 30 INTERROGATORY NO. 30-1(a): Has any determination of the quantity of potassium iodide (KI) to be kept at any location (e.g. county health department) for use as a radioprotective drug in an emergency at the Harris plant been made?

(b) How, if at all, does each such determination take into account the " shelf life" of the KI?

(c) Who made each such determination?

(d) How was each such determination made?

(e) Please identify each document concerning each such determination, and also all documents containing information used in making each such determination.

(f) Please state what information, from what specific source (page reference please) was used in making each such determination.

(g) How many persons are to be provided with KI from each location during an emergency? Please state the numbers of emergency workers, the number of persons not mobile (e.g. in nursing homes), and numbers of other persons for whorr. KI is to be provided from each location where KI is stored for use in a radiological emergency at Shearon Harris nuclear plant.

i (h) Are there any reserve supplies of KI available within the Harris EPZ for use in an emergency? If so, who determines where these reserve supplies are and how .nuch is ir. each location?

(i) What dose (s) are provided per person in the KI stored for use in a radiological emergency at Harris? If no KI is now stored for this purpose, what dose (s) are planned to I be provided per person?

ANSWER: (a) No determination of the quantities of potassium iodide tablets to be kept at any location for Harris plant emergencies has been made.

(b) - (i): Not applicable.

INTERROGATORY NO. 30-2(a): If quantities of KI for use during a radiological emergency at Harris have not been determined yet, when is such determination to be made? Please explain how each of the matters asked about in 30-1(b) through (i) above will be addressed in such determination.

(b) Please state who is making the determination of K1 quantities which is going to be made.

(c) Please state who will make each such determination and whether each such ~

determination will be included in the Harris emergency response plan.

, (d) Please identify all points in the Harris emergency response plans where specific quantities of KI or other radioprotective drugs are mentioned.

ANSWER: (a) The determinstion of the quantities of potassium iodide tablets to be used in a radiological emergency will be made prior to the emergency exercise scheduled for December 1984.

With respect to 30-1(b): The shelf life of potassium iodide tablets is approximately three years from date of manufacture, unless otherwise modified by the United States ,

Food and Drug Administration. The need for replacement of outdated stocks of potassium iodide tablets will be taken into account for each determination.

With respect to 30-1(c): The North Carolina Division of Health Services is responsible for determinin'g the quantity and location of ' state-purchased potassium iodide supplies.

With respect to 30-1(d): An assessment of the potential numbers of individuals who v;ould reasonably require potassium iodide tablets will be made based upon past

! experience, professional judgment, comparative information from other states,

-information provided by the utility about the number of individuals who cannot be readily evacuated and who may need to be sheltered within the 10-mile EPZ, and the number of I-emergency workers subject to radioiodine exposure. Each of these factors willinfluence i

, the determination of the quantities of potassium iodide tablets to be provided and the 1

location of each storage site.

l j .- - . - - . . -- - .- .-- ..- - .__ _ .- _ _ - -

With respect to 30-1(e): In making determinations about potassium iodide tablet quantities and locations in the vicinity of the Harris plant, information contained in (1) the ETE; (2) the Final Safety Analysis Report for the Harris plant, and (3) the final draft of the " North Carolina Emergency Response Plan in Support of the Shearon Harris Nuclear Power Plant" will be considered.

With respect to 30-1(f): Information contained on the following pages of the ETE will be considered: pp.1-1 through 1-4 including all maps and tables; pp. 3-1 through 3-6, including fig. 3-1 through 3-4 and tables 3-1 through 3-7; pp. 4-1 through 4-7 including tables 4-1 through 4-5; and pp. 6-4 and 6-5. The Division of Health Services has not reviewed the FSAR yet. The final draft of the ERP has not yet been published.

With respect to 30-1(g): It is impossible to state the number of persons who will be served by each specific location as the conditions of the specific emergency will dictate the actual distribution and use of the potassium iodide inventory.

With respect to 30-1(h): There are no plans to store state-purchased reserve potassium iodide tablets within the 10-mile EPZ. An estimated 5000 bottles of potassium lodide tablets (14 tablets in each bottle) will be stored in at least 4 separate sites around the Harris plant. In addition, an estimated 400 bottles of potassium iodide (14 tablets in a bottle) will be stored at the Harris site. These quantities represent the entire amount of

. potassium lodide available for immediate use. No other inventory of potassium iodide tablets for " reserve" purposes will be stored within the 50-mile EPZ.

With respect to 30-1(i): Fourteen tablets (130 mg. of potassium iodide per tablet) will be made available for each emergency worker and each person who cannot be readily evacuated.

(b) The North Carolina Division of Health Services is responsible for determining the quantities of state-purchased potassium iodide tablets for use in an emergency.

(c) The North Carolina Division of Health Services will make each determination and, if necessary, each determination will be included in the Harris off-site emergency l.

r 7; response plan.

(d) Copies of all emergency plans have been served on the parties to this proceeding.

INTERROGATORIES ON EDDLEMAN 224 INTERROGATORY NO. 224-1(a): What analysis of the frequency of weather events, including fog, ice, snow, rain, heavy rain, hall or other adverse weather, have you made for the Harris EPZ?

(b) What information do you have on the frequency (both (i) typical, and (ii) maximum in any recorded data) of (aa) fog (bb) ice (cc) snow (dd) rain (ee) " heavy rain" (ff) hail (gg) rain above 1 inch per hour (hh) rain above 3 inches per hour, in or around the Harris EPZ in areas believed to be similar in meteorology to the Harris EPZ? Please identify all documents containing such information.

(c) Do you have any other information concerning frequency of adverse weather in the Harris EPZ or in areas of similar meteorology? If so, please identify all such other information and all documents containing it.

ANSWER: (a) An analysis of the frequency of adverse weather evsnts is contained in the Shearon Harris Nuclear Power Plant Environmental Report (ER), section 2.3.1 and in the Final Safety Analysis Report (FSAR), section 2.3.1 for regional information and section 2.3.2 for local (on-site)information.

(b) (aa) See FSAR section 2.3.2.1.5, pages 2.3.2-4 and 2.3.2-5.

(bb) See FSAR section 2.3.1.2.5, page 2.3.1-4.

(cc) See FSAR section 2.3.1.2.8, page 2.3.1-5.

-(dd) See FSAR section 2.3.1.2.8, page 2.3.1-5; FSAR section 2.3.2.1.4, page 2.3.2-3; and ER section 2.3.5, page 2.3-3.

(ee) See sections identified in answer (dd) above.

(ff) See FSAR section 2.3.1.2.4, page 2.3.1-3.

(gg) See sections identified in answer (dd) above.

(hh) See sections identified in answer (dd) above.

(c) Information concerning frequency of adverse weather in the Harris EPZ has been identified in the references to sections 2.3 of the ER and FSAR.

r INTERROGATORY NO. 224-2(a): Please state what sensitivity analysis for frequency of adverse weather was included in the Harris evacuation time estimates.

(b) If you reviewed the Harris evacuation time estimates, what analysis,if any, did you make of the sensitivity of such time estimates to the frequency of adverse weather? Please identify all documents concerning (i) your analysis of the Harris evacuation time estimates (ii) sensitivity of such estimates to adverse weather conditions (iii) sensitivity of evacuation time estimates to the frequency of adverse weather conditions.

(c) Please state what further analysis cf adverse weather frequency and its effect

.on Harris evacuation time estimates you plan to make, and when it will be done.

ANSWER: (a) - (b): Applicants are uncertain what is meant by the phrase

" sensitivity analysis for frequency of adverse weather." NUREG-0654 (at 4-6) provides that the evacuation time estimate analysis should include an adverse weather frequency severe enough to define the sensitivity of the analysis to the adverse conditions. The adverse weather scenario used in the ETE (i.e., heavy rainstorm) was selected from a number of potential adverse weather scenarios based upon a review of weather frequency and severity data presented in the Shearon Harris FSAR and discussions with state and local emergency preparedness officials. The selected scenario represents a condition which is severe enough and occurs often enough to provide a reasonable frame of

- reference for protective action decision-making during adverse weather conditions. The ETE reveals that evacuation times during adverse weather conditions will be greater because the methodology is sensitive to the reductions in roadway capacity and travel speeds associated with the adverse conditions. However, the sensitivity is not great relative to factors which have primary influence on evacuation, i.e., preparation and mobilization time.

(c) No further analysis is planned.

INTERROGATORIES ON EDDLEMAN 215 INTERROGATORY NO. 215-1(a): How do recreational populations at (i) Jordan Lake (ii) the Harris plant lake (iii) other recreation sites with the Harris EPZ, vary with

. _ . . . ,- , , _ - . _ . . m_ .

. 1 (aa) time of day (bb) day of week (ce) season of year? Please provide what data you have on variation of recreational populations in each recreational area in the EPZ, including numbers of overnight users of each.

(b) What data provided in response to (a) is based on actual observation?

(c) What basis do you have for estimates of recreational populations near Harris at various times of the day, week and year, other than observation? How realistic is such basis in your view? Do you know methods to check the realism of suel .:stimates? What are such methods? Are you doing any checking of the realism of such estimates? If so, how? Do you plan to check the realism of estimates of recreational populations in the Harris EPZ before the plant operates? Before the evacuation plan is tested?

(c)[ sic] What data do you have on vehicle occupancy rates in the Harris EPZ (i) at any time or times (ii) in the early morning, e.g. 6-9 am (iii)in the early evening, e.g. 5-7 pm (iv) between 11 am and 1 pm or in that range (v) after 7 pm but before midnight?

(d) Do any of your data on vehicle occupancy rates in the Harris EPZ vary by day of week or season or date in the year? If so, how does each vary?

(e) Please identify all documents concerning actual occupancy rates of vehicles in the Harris EPZ which you (i) possess (ii) know of.

(f) Please identify all documents concerning recreational populations in the Harris EPZ or how these populations vary at varying times.

.(g) Please icentify all documents concerning estimation of (i) vehicle occupancy rates (ii) recreational populations, in the Harris EPZ, or basis for such estimates, or data used in such estimates.

ANSWER: (a) In accordance with guidance in NUREG-0654 (at 4-3), the recreational population estimates used in the ETE represent " peak tourist volumes." As such, variations by time, day of the week and season are not addressed. The peak r.

population estimates were developed from data presented in the CP&L report entitled

" Demographic Data for the Shearon Harris Nuclear Power Plant (SHNPP) Evacuation L

j. Time Estimate Report" (Oct.1983, Rev.1) (" Demographic Data Report") and obtained l

l from a recreational survey (Jordan Lake and Harris Reservoir), the Boy Scouts of o

America (Boy Scout Camp), and CP&L (Visitors Center) during 1982 and 1983. Hunting reports were based on North Carolina Wildlife Resources Commission reports. These data are presented in the ETE and are summarized below:

l - Harris Reservoir: 326 (peak summer weekend population);

l - Jordan Lake: 6,000 (peak summer weekend population);

1 l

- Shearon Harris Visitors Center: 200 visitors (peak fall or spring day population);

- Boy Scout Camp: 500 (peak overnight population on one spring and one fall weekend);

- Hunting: 431 (peak ;opulation during late fall or early winter).

The recreational populations for each local planning zone are summarized in Table 4-3 of the ETE. Overnight camping can also occur at the Boy Scout Camp during " warm

- weather" weekends with an average occupancy of 15-25 scouts and their leaders. No other public camping facilities have been identified in the EPZ.

- (b) Two helicopter surveys of Jordan Lake and Harris Reservoir were conducted on September 5,1982 (Labor Day weekend) and July 3,1983 (Fourth of July weekend).

These surveys were utilized in projecting the maximum recreational populations. The

' hunting population was derived from North Carolina Wildlife Resources Commission data.. Usage of the Shearon Harris Visitors Center and the Boy Scout Camp was estimated from historical usage patterns.

(c) In those areas of Jordan Lake within the EPZ, approximately 2000 persons were counted during each of the helicopter surveys cited in answer (b). These base numbers reflect high usage periods (holiday weekends), but not necessarily the highest usage period. Thus, a " projection factor" was used. The base number was multiplied by 3 to project the maximum recreational population for those parts of Jordan Lake in the EPZ.

These resulting usage estimates are more consistent with those of the U. S. Corps of Engineers. .

The results of the helicopter surveys for Harris Reservoir were quite variable 4

because they were conducted during a time period when the public was just becoming

-aware of the Reservoir. - Therefore, a different method for estimating the maximum recreational population was used. The reservoir size (in acres) was multiplied by the

- maximum population density at Jordan Lake (number of persons per acre), and it was y 't$ 'wey e T?-

• 2 wyr? -**ug -~gyW-- 7N*F-M*-av g -es y y =- < ftYy -9 T-rw ya a v"--W=9v=-*W8V 7ly=yCy'fy - 7 v +'*W-w'Mr-

assumed that the per acre usage of Harris Reservoir would be 10 percent of that of Jordan Lake.

+

The methodology for estimating the peak hunting population is described in documents that will be produced upon request. This methodology has been verified by the Division of Wildlife Management, N. C. Wildlife Resources Commission.

The estimated maximum usage of the Visitors Center was based on historical usage patterns. Estimates of usage of the Boy Scout Camp were supplied by the local Scout Council.

The methods to estimate maximum recreational populations are considered to result in realistic population figures. Applicants are presently checking the validity of the recreational population esimates for Harris Reservoir against 1984 recreation / creel survey data.

(c) [ sic] - (e): Data on vehicle occupancy rates are summarized in Table 3-7 of the ETE. The bases for these rates are explained in sections 3-1 to 3-3 of the ETE.

Applicants have no specific data on the variability of these rates by time of day. Vehicle occupancy rates for the transient population would vary seasonally depending upon what recreational populations are predominant (e.g., hunters or users of the lakes).

(f) - (g): Documents will be produced for inspection and copying upon request.

INTERROGATORY NO. 215-2(a): Please state if you know what numbers or percentage of the Harris EPZ population is at home (i) with transportation at home (ii)

I without trarisportation^ at home, at varying hours of the day or year or at any time (s)

(please specify times for which you have such information).

l (b) Please state what investigation or analysis or data collection you (i) have made (ii) will make (iii) are making concerning numbers of persons in the Harris EPZ who are at home at any time or times of the day or yer.r.

l ANSWER: (a) - (b): Applicants are not aware of any information on the numbers or l

l percentage of the population in the Harris EPZ that is at home at varying times of the i

f day and year. Applicants have not analyzed such variability and have no plans to do so.

l

INTERROGATORY NO. 215-3(a): Do you know how many vehicles are available to each household within the Harris EPZ (i) as owned or rented vehicles (ii) at any time of the day, e.g. during work or school hours (iii) located at or near the home of each household, at any time or times of the day or year?

(b) Please detail all data you have on the numbers of vehicles available to each household in the Harris EPZ at any specific times.

(c) Please detail all data, information or documents as to the number of vehicles each household (or a typical household) in the Harris EPZ will use to evacuate in the event of a nuclear accident at Harris.

ANSWER: (a) - (b): No survey of individual households within the plume EPZ has been conducted to determine the availability of vehicles. However, the CP&L Environmental Technology Section has prepared a Demographic Data Report which was used in connection with the ETE. The Demographic Data Report contains information on the number of registered automobiles and small trucks within the EPZ (Table 3.4-2) and the number of houses within the EPZ (App. A at 16-21). An estimate of the number of vehicles per household could be calculated from these data. Data have not been collected on the number of vehicles available to each household at any specific time.

(c) Consistent with guidance in NUREG-0654 (at 4-3), there are two acceptable methods for estimating the vehicle demand associated with the permanent resident population. First, the number of vehicles to be used by permanent residents can be estimated _ using an appropriate auto occupancy factor (typically 2-3 persons per vehicle). Alternatively, the number of vehicles associated with this population category could be estimated based on the number of households that own vehicles, assuming one vehicle per household would be used in the evacuation. The methodology used for the ETE used documented assumptions on vehicle occupancy and anticipated evacuation characteristics associated with each individual population category (i.e., permanent residents, transients and special facilities). For permanent residents, it was assumed that one vehicle would evacuate from each household after notification and preparation for evacuation.

The one vehicle per household assumption is consistent with federal guidance.

L

NUREG-0654 at 4-3. The assumption is also confirmed by 1) empirical data on past evacuations, indicating the tendency of family units to unite and evacuate as a unit, and

2) previously developed evacuation planning standards indicating the likelihood of evacuees to utilize the "best available" automobile when evacuating.

INTERROGATORY NO. 215-4(a): Have you made any study of how many persons would evacuate from a location other than their home(s) within the EPZ in the event of an accident at the Harris nuclear plant?

(b) Have you studied where people would actually evacuate from under daytime or evening conditions from the Harris EPZ at any date or season of the year?

(c) Please identify all documents concerning such study or studies.

ANSWER: (a) In developing the evacuation time estimates for the Harris EPZ, it was assumed that certain classifications of persons would evacuate from areas other than

. their homes:

(1) Persons visiting major recreational areas will evacuate directly frem those areas to locations outside the EPZ; (2) Persons at major places of employment will evacuate directly - from those places to locations

, outside the EPZ; (3) Persons in special facilities (e.g., hospitals, nursing homes, schools) will evacuate directly from those I

facilities to locations outside the EPZ.

Data on the number of persons in these classifications are summarized in Tables 3-3 to 3-6 of the ETE. The exact origins of vehicles evacuating from the EPZ would i'

depend on the particular evacuation scenario that arises. However, the assumptions in l - the ETE have been reviewed and concurred with by state and local emergency

_ preparedness officials, and attempt to simulate a realistic evacuation scenario.

l (b) - (e): The ETE considered evacuation under a variety of conditions, including l

l t i

\

l different times of day. See ETE at section 1.3 and Table 1-1. See also answer (a) above .

l INTERROGATORY NO. 215-5(a): Have you determined the distance from each (or any of the non-car-owning household (s)in the Harris EPZ to each's nearest neighbor?

(b) Have you determined how many non-car-owning households have telephones over which they might ask neighbors for rides in the event of an accident at Harris?

(c) Do you know how many persons would evacuate from car-owning households near the non-car-owning households?

(d) Do you know how many of such car-owning neighbors of non-car-owning households would have extra space to carry members of the households without transportation?

(e) Why have the evacuation time estimates assumed that one car will be added per family of non-vehicle-owning evacuees in an accident at the Harris plant?

(f) Have you made any analysis of the Harris evacuation time estimates' treatment of the number of vehicles evacuating as it is affected by the numbers of vehicles assumed or estimated to be evacuating persons without transportation?

-(g) Please identify all documents concerning any such analysis.

(h) Please state whether persons without transportation includes those who do not have their own transportation readily available, or only those who do not own cars.

ANSWER: (a) Distances from individual non-car-owning households to their nearest neighbor have not been determined.

(b) The number of non-car-owning households with telephones has not been determined.

(c) The ETE (at section 3.1 and Table 3-2) estimates that there are 7,347

. households in the EPZ and that 410 of those households are non-auto-owning. Thus,6,937 Pauseholds in the EPZ are estimated to own automobiles. Using the data in Table 4-1 of the ETE, it can be determined that there are approximately 2.7 persons per household in the EPZ. Thus, the number of persons who would evacuate from auto-owning households can be calculated. The exact proximity of these persons to non-auto-owning households has not been determined.

(d) A survey has not been conducted to determine the precise number of auto-owning households with extra space to carry members of households without L

~ _ _

However, given the number of households in the EPZ that own

- transportaiic a.

automobiles and the average number of persons per household (see answer (c) above),

there is adequate basis to believe that more than sufficient capacity will be available to accommodate persons in households without transportation.

(e) During an evacuation, transportation for all non-auto-owning households will be furnished through rides with neighbors or through coordinated efforts by state and county emergency preparedness officials. The exact number of vehicles which would be required to evacuate this population category would vary based upon several factors, including the type and number of transportation resources available at the time of the evacuation.

The methodology used in the ETE assumes that vehicle occupancy rates for the non-auto-owning population are similar to those for the auto-owning population; that is, one vehicle per household. This assumption is used since it provides the most realistic representation of evacuation traffic which would be generated from the non-auto-onning households. Although this assumption does result in the maximum number of vehicles for evacuation of the non-auto-owning permanent households, it represents a reasonable traffic flow condition since it provides for one vehicle trip to each such residence to pick up the evacuees.

(f) No specific analysis has been made of the effect of the number of vehicles evacuating from non-auto-owning households on the evacuation time estimates. As explained in answer (c) above, there are an estimated 410 households in the EPZ that do not own automobiles out of a total of 7,347 households.

For the ETE, the vehicles associated with the non-auto-owning population were treated the same, for simulation purposes, as the auto-owning population. That is, one vehicle would evacuate from each household, and vehicle departures from residences would be distributed over a two-hour period. Thus, the number of vehicles to accommodate the non-auto-owning population would be an insubstantial portion of the total number of vehicles used during an evacuation. The 410 vehicles associated with the L

non-auto-owning population would not have a significant effect on the total evacuation time. As an estimate, a reduction in the total evacuation time of 10 minutes is considered reasonable if the number of vehicles to accommodate the non-auto-owning population were eliminated from the analysis.

(g) As indicated in answer (f) above, no specific analysis was conducted to evaluate the effect on evacuation times of the number of vehicles assumed or estimated to be evacuating persons without transportation on evacuation times. However, a discussion of the treatment of the non-auto-owning population for the evacuation time estimate analysis is contained in the ETE at section 3.1.2 and Table 3-7.

(h) The figures in section 3.1 of the ETE reflect permanent resident households that do not own automobiles.

INTERROGATORY NO. 215-6(a): Please identify any information underlying the Harris evacuation time estimates, or any other information available to you, which concerns the number of vehicles per evacuating person or per family which would be required to evacuate the Ilarris EPZ under realistic conditions.

(b) Please identify the realistic conditions and the documents containing all such information.

(c) Have you compared the number of vehicles used in the evacuation time estimates to the number of vehicles considered to be actually e7acuating under realistic conditions for any evacuation condition or scenario? If so, state for which condition or scenario, and please identify the results of your comparison and all documents containing such results or information on which such results were based.

ANSWER: (a) - (b): A summary of vehicle occupancy rates during an evacuation of the Harris EPZ is contained in Table 3-7 of the ETE. The conditions modeled in the ETE are described in section 3.1. These conditions are considered realistic.

(c) The data and assumptions used to estimate the number of vehicles used in the various evacuation conditions modeled in the ETE are detailed in the ETE itself and in the Demographic Data Report. These estimates are considered to reflect the number of vehicles actually evacuating under realistic conditions. No " comparison" per se has been

. made.

o __

INTERROGATORY NO. 215-7(a): Have you performed, or do you know of, any reanalysis of the computer runs made for the liarris evacuation time estimates, incorporating any less conservative assumptions (or more realistic assumptions) concerning numbers of vehicles to be evacuated, population of recreation-area users to be evacuated, or other matters contained in Contention 215 as initially admitted or as revised? Please identify all documents containing such reanalysis, and state the evacuation times given by each such reanalysis.

ANSWER: (a) Applicants have not performed and are not aware of any reanalysis of the computer runs subsequent to completion of the ETE in October 1983.

INTERROGATORY NO. 215-8(a): Do you know of any data showing the actual traffic loadings on each road segment during evacuation from a Harris accident (i) as computed in any evacuation time estimate computer run (ii) as determined in any other computer run (iii) as determined in any other manner?

(b) For each part of (a) above for which your answer is affirmative please identify all documents containing such data, and state what assumptions or data about population and vehicles evacuating, road conditions, or other variables were used in deriving such data or making such computer run.

ANSWER: (a) - (b): The methodology used for the ETE involved the use of a computer-based evacuation simulation model referred to as NETVAC. The NETVAC program uses accepted traffic flow relationships to calculate and record traffic densities, speeds, flows, vehicle queues and other relevant data throughout the evacuation process.- Retorts are prepared at user-specified time intervals, typically at ten minute periods, throughout the course of the simulated evacuation. Data are presented on a link-by-link basis, such that traffic activity can be evaluated at each reporting interval, along each roadway segment, during the course of the evacuation.

Evacuation simulation runs were performed for the evacuation conditions modeled in the ETE. Data summaries and assumptions on population, vehicle demand and roadway conditions for each condition are described in the ETE.

L INTERROGATORY NO. 215-9(a): Do you have any information as to the amount of time required for evacuating the Harris EPZ under conditions less conservative than those specified in the Harris evacuation time estimates? If so, what information do you possess or know of?

1

(. . .

~

(b) Please identify all assumptions that were made in deriving the time required (or effect on time required) to evacuate the Harris EPZ, for any information identified in response to (a) above.

(c) Please identify all documents containing information about less conservative evacuation time estimates for the Hkeris EPZ you are aware of.

(d) Who made estimates of Harris EPZ evacuation time, other than CP&L's contractor?

ANSWER: (a) - (c): Applicants do not have specific information concerning estimated evacuation times under conditions less conservative than those outlined in the ETE. In choosing the assumptions to be used in the evacuation scenarios, HMM Associates attempted to be as realistic as possible. Hypothetically, evacuation for conditions where total vehicle demand would be significantly less than that identified in the ETE would result in lower evacuation times. The magnitude of such time reductions would depend not only on the magnitude of vehicle demand reductions, but also on the specifie locations of the reduced vehicle volumes. It is worth noting, however, that the total evacuation times for many of the evacuation scenarios reported in the ETE are influenced more by the preparation and mobilization times of the various population categories than by roadway capacity restrictions. Therefore, significant reductions in vehicle demand during many of the evacuatio a scenarios would not necessarily have a significant effect on total evacuation times.

(d) Applicants are not aware of any evacuation time estimates other than those provided by HMM Associates,Inc.

Dated: July 25,1984.

Submitted by:

N - /

Dale E. Hollar, Esq.

Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 u

4 Attorneys for Applicants:

Thomas A. Baxter, Esq.

John H. O'Neill, Jr., Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

-Washington, D.C. 20036 (202) 822-1000 Richard E. Jones, Esq.

Samantha Francis Flynn, Esq.

Carolina Power & Light Company Fost Office Box 1551 Raleigh,' North Carolina 27602 (919) 836-0517 S

.a 31 -

L .-

- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION C ^ W ' _"

.m BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'84 JUL 27 All :32 In the Matter of )

CAROLINA POWER & LIGHT COMPANY ) b N' AND NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )

AFFIDAVIT OF D. 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 Eddleman Contentions 30,57-C-3,57-C-10, 57-C-13, 213, 215 and 224 contained in " Applicants' Response to Wells Eddleman's

' GeneralInterrogatories to Applicants (Ninth 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.

. This the Nday of t (.I !V ,1984.

34/V yJ. frurr Sworn to agn subscribed before me this& day of Jul ,1984.

dca .'

pinb/. , Notary Public gf Y, 8 *t d r.S; Myeommission expires: g g*[MM IJd III [ Y t , ,

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Attachment A  !

                                                                                                                         )

JESSE THOMAS PUGH, IH 713A Grove Avenue Raleigh, North Carolina 27606 _ Home (919) 851-3467 Office (919) 733-3867 PERSONAL Date of Birth: November 19, 1947 Place of Birth: Asheboro, North Carolina Age: 36 Height: 5'5" Weight: 150 lbs. Health: Excellent Married: September 1,1973, to Sandra Strader of Caswell County, Nonh Carolina EDUCATION 1%1-l%5 ASHEBORO HIGH SCHOOL Asheboro, Nonh Carolina Degree: College Prep. Clubs and Organizations

            -Business Manager for Annual,1%5
            -Treasurer for Future Teachers,1%5
            -Drama Club, Journalism Club
            -Quill and Scroll Club, Wrestling Team 1/81-present NORTH CAROLINA STATE UNIVERSITY Raleigh, North Carolina Enrolled in Masters of Public Administration Program, School of Political Science and Public Administration Spring 1982  NORTH CAROLINA STATE UNIVERSITY Raleigh, North Carolina Computer Applications Certificate Program MPA, School of Political Science 7/65-5/69    BS in Textile Technology NORTH CAROLINA STATE UNIVERSITY Raleigh, Nonh Carolina Clubs and Organiza. u Sigma Nu Fraternity (House Manager 1966-67)

Honors: Dean's List Student last three semesters Fall 1980 GOVERNMENT EXECUTIVE INSTITUTE University of Nonh Carolina Chapel Hill, North Carolina August 1%7 NORTH CAROLINA OUTWARD BOUND SCHOOL Morganton, Nonh Carolina MILITARY 6/69-4/72 UNITED STATES MARINE CORPS Honorably Discharged Highest Rank: First Lt. Occupations: Supply Officer - responsible for ordering, controlling, stocking, and warehousing all supplies for a Battalion; Fiscal Office - responsible for budgeting and accounting for all Battalion funds. 1

Attachment A EMPLOYMENT - 5/82-present Division Director, North Carolina Department of Crime Control and Public Safety Division of Emergency Management, Raleigh, North Carolina Responsible for the State of North Carolina emergency response and planning. This includes the coordination of all emergency response activities of the 17 State agencies. Serve as State Coordinating Officer and Governor's Authorized Representative in all disaster related matters. i In addition to these duties, when I was promoted to Director the Deputy Director position was abolished, and I retained all the duties and responsibilities of that position. 509-5/82 A==ident Director, for same division, promoted to Deputy Director May 1980.

• Responsible for daily operations of the Division. Supervise 53 employees, administer budget of approximately $2 million, managed grant program to local governments, represent the State in business transactions and in meetings with local and federal government.

7D8-509 Area Coordinator for same division, then called Division of Civil Preparedness. Office located in Asheboro, North Caroiina. Responsible for a 15-county area, working with local coordinators and governmental officials in preparing plans to prevent and/or respond to disasters, both natural and man-made. Also responsible for arranging specialized training for local volunteers and governmental employees. In3-7n8 Funeral Director / Manager of Pugh Funeral Home, Randleman, North Carolina Pugh Funeral Home, Inc., Asheboro, North Carolina Responsible for counseling with families, arrangement of details of Funeral Services, assisting in filing of benefits with Social Security, Veterans Administration, and other agencies. Also responsible for normal office routine, upkeep of building and grounds, and normal maintenance. 10n2-12n2 Shift Supervisor, Textured Fibres, Inc., Liberty, North Carolina Responsible for scheduling job assignments, maintaining production records, achieving consistent acceptable production levels, and maintaining morale. i ! CLUBS AND ORGANIZATIONS Current Member of North Carolina State Alumni Association Member of North Carolina State Wolfpack Club l Member of Wake County Democratic Mens Club i Former Member of Asheboro Jaycees, Treasur6r in 1974 l Member of Randolph Asheboro YMCA, serving on program committee, nominating committee, j Board of Directors, and Secretary in 1978 l Director of Randleman Heart Fund in 1977 l Worker in United Appeal i i i 1 1 2

M q , Attachment B Resume ' Charles Damon Reed Post Office Box 58207 Raleigh, North Carolina 27658 Personal Data Date:of Birth: September 27, 1946 Place of Birth: Long Beach,-California Marital Status: Married with no children Wife: Judy Pittman Reed Health Status: Very good to excellent Diucation s High School diploma awarded May 29, 1964 by Sidney Lanier High School, Montgomery, Alabama. College diploma awarded June 3,1969 by Auburn University, Auburn, Alabama. Degree: Bachelor of Science in Pharmacy (5-year curriculum). Additional coursework at Auburn University-Montgomery 1970-72: Small Business Management Seminars: Business Law Principles of Management. Health Care Facilities Surveyors Basic Training Course at University of California-Los Angeles - 1974 Emergency Medical Technician Basic Training Course at Wake Technical Institute, Raleigh, North Carolina - 1977 Professional Affiliations AmericanPharmaceuticalAssociation(1964-present) Academy of General Section on Long-Term Practice Care of Pharmacy)(1971-present) (1975-present AlabamaPharmaceuticalAssociation(1964-75) AcademyofInstitutionalPractice(1973-75), Vice-Chairman - 1973: Chairman - 1974 Montgomery (Alabama) Pharmaceutical Association (1969-74), Vice-President - 1972: President - 1973-East Central Alabama Emergency Medical Services Council - 1974 North Carolina Pharmaceutical Association (1975-present) Committee on the Delivery of Pharmaceutical Services - 1978-81 Committee on Public Health (1981-present) American Public Health Association (1977-79) North Carolina Public Health Association (1977-present) Legislative Committee - 1978-present Triangle J (North Carolina) Emergency Medical Services Advisory Committee Wako County Public Representative - 1982-present Professional Licensure Licensed by examination in Alabama in November, 1969: Licensed by reciprocity in North Carolina in December,1975 l 1 l L________....__

Pags 2 - Charles Damon Reed

                    ~

Eusiness Affiliations Advisor on Pharmaceutical Services - North Carolina Office of Emergency - Medical Services - 1976-77 Member, _ Health Advisory Committee; North Carolina Department of Human Resources, Division of Youth Services Member, Drug Purchase Advisory Group; North Carolina Department of Administration, Division of Purchase and Contract Member, North Carolina State Emergency Response Team; North Carolina Department of Crime Control and Public Safety, Division of Emergency Management: Primary assignment: Nuclear power plant disasters . Member, Drug Usage Committee; Governor's Advisory Council on Aging Other Certified by the State of North Carolina as an Emergency Medical Technician - 1977-79 Faculty Associate, University of North Carolina at Chapel Hill, School of Public Health, . Department of Health Administration - 1981-82 Employment History 1966-68 Employed by Bellas-Hess Pharmacy, Divisi'on of Parkview-Gem Inc. , in Montgomery, Alabama as a pharmacist extern. Responsibilities included general dispensing duties, inventory control, and peparation of orders to suppliers. 1968-72 Employed by Price Drug Company, Montgomery, Alabama as a pharmacist extern; pharmacist intern; staff pharmacist; and pharmacist manager. Responsibilities included general dispensing duties and related inventory control and management, and later as manager of a pharmacy, general managerial duties. 1972-73 Employed by the Alabama Board of Corrections, Montgomery, Alabama, as chief pharmacist for the Alabama prison system. Responsibilities included the devclopment of a pharmaceutical services system for the prisons in response to a federal court order. At that time, the prison system consisted of six major-units and 15 smaller highway camps. 1972-74~ Employed by St. Margaret's Hospital, Montgomery, Alabama as a part-time staff pharmacist and weekend supervisor. Responsibilities included supervision of a staff of three pharmacy technicians, preparation of hyperalimentation and other intravenous solutions; and specialized supervision of pharmaceutical services in a newly-developed open-heart surgical ward. 1973-74 Employed by Alabama Department of Public Health, Bureau of Licensure and Certification as a consultant pharmacist. Responsibilities included survey, inspection, and consultation activities relating to the licensure of hospitals and nursing homes, and federal certification for-purposes of Medicare and Medicaid reimbursement; teaching pharmacists about the services needed in nursing homes and how to comply with mandated standards; and becoming proficient in the knowledge of the services provided by other health professions.

Pagy 3 - Char 1cs Damon Reed Emplovnent History. Continued 1974-77 Employed by North Carolina Department of Human Resources, Division - of Facility Services, as a pharmacist censultant. Responsibilities included were the same as the previous Alabama position, plus expanded responsibilities for psychiatric hospitals, intermediate care facilities for the mentally retarded, and home health agencies. Additional responsibilities included liaison activities with the North Carolina Board of Pharmacy, the North Carolina Drug Commission, and the Office of Emergency Medical Services. - 1977-84 Employed by North Carolina Department of Human Resources, Division . of Health Services as a pharmacist consultant. Responsibilities include the development of pharmaceutical service programs and systems for county health departments in North Carolina; liaison with regulatory and professional groups; development of contract specifications for the purchase of pharmaceutically-related products and devices; preparing and presenting programs to public and private groups concerning medications, disease, disease prevention, non-drug therapy, health care costs, and nutrition; assisting in the development of clinical records systems for health departments, and general forms management for division programs; disaster planning, particularly with respect to nuclear power plants; legislative activities; and professional consultation to other state agencies concerning drug purchasing, services for youth facilities, and matters concerning medication use in the elderly. 1979-84 Self-employed as a pharmacist consultant to Kinton's Nursing Home, Fuquay-Varina, North Carolina, a 49-bed nursing home. Responsibilities include reviewing patient records and making appropriate recommendations about drug therapy, and providing educational services to the nursing staff. 1983-84 Self-employed as Charles D. Reed Pharmacist, working cooperatively in an evening and weekend medical clinic with an Internist / Nephrologist. Responsibilities include taking drug histories, evaluation of histories, consultation with the physician, consultation / education activities with patients concerning medications, and general dispensing duties. O

Attachment C CURRICULUM VITAE for Dayne !!. Brown Bom August 18, 1940 in Shelby, North Carolina Graduated f rcm Needham B. Broughton liigh School, Raleigh, North Carolina June 1958 Graduated with honors from North Carolina State University with Bachelor of Science degree in Physics, June 1962 Awarded US Public l{ealth Service Radiological llealth and Safety Fellowship to attend North Carolina State University. Graduated f rom North Carolina State University, January 1964, hbster of Science degree in Physics

 ' Enployed as a h'ealth physicist by the National Aeronautics and Space Administration, Lewis Research Center, Cleveland, Ohio f rcm January 1964
 - to February 1966 Enployed as an inst ructor in the Radiological llealth Training Program of US Public Ilealth Services, Cincinnati, Ohio f rem February 19ti6 to June 1967 June 1967 to present : Enployed as Chief of the Radiat ion Prot ect ion Sect ion, Division of Facility Services, North Carolina llepartment of Ilumen Resources 1976 to present : Ex of ficio member of the North Carolina Ra<lta t i on Prot ect ion Ccmniss1on                                              .

Menber of: . NC Chapter of the llealth Physics Society National llealth Physics Society American Public Ilealth Association Conference of Radiation Cont rol Program Directors

        >                                                        Attachment D ROBERT D. KLIMM Education B.S. Civil Engineering, Worcester Polytechnic Institute, 1975 M.S. Civil Engineering (Transportation),

Northeastern University, 1979 Summary of Experience Mr. Klimm specializes in transportation engineering and emergency preparedness / evacuation planning. He has been responsible for most of the evacuation time estimate analyses conducted oy HMM. He also has been responsible for related tasks including the development of: school facility evacuation plans and procedures, evacuation and population data for CRAC2 and CRACIT consequence modeling, and evacuation routings and time estimates for special facilities (hospitals, nursing homes, etc.). Mr. Klimm was involved in the system development of HMM's NETVAC evacuation simulation model, which has been used at over a dozen power plant sites throughout the country. He has provided training to groups that have been licensed to use the NETVAC model. Professional Experience 1980 - HMM Associates. Mr. Klimm serves as Project Present Manager and/or Principal Engineer for projects involving emergency preparedness 31anning and emergency evacuation. Recent experience includes the following: o Project Manager for evacuation analyses at Consumers Power Company Midland Nuclear Power Plant. Responsibilities included: preparation of supplemental evacuation time estimates, development of evacuation time estimates for special facilities, development of an Evacuation Traffic Management Plan, and preparation of school facility emergency evacuation plans and procedures. o Principal Engineer for the preparation of evacuation time estimates for the Shearon Harris Nuclear Power Plant. o Project Manager for the development of an Evacuation Traffic Management Plan for the Boston Edison Company's Pilgrim Station Evacuation Relocation Center. 1 HMM Associates

            .                                                      Attachment D
  ~                      o   Principal Enginaar for the developmant of population and evacu; tion data for CRACIT radiological consequence modeling within the Seabrook Station EPZ.

o Project Manager for the development of an Evacuation Traffic Management Plan for the Seabrook Station, Plume Exposure EPZ. o Project Manager for the preparation of evacuation time estimates for the Grand Gulf Nuclear Station. o Instructor for Public Service Electric and Gas Company's Evacuation Time Estimate Workshop. O Project Manager for the Big Rock Point Evacuation Time Estimate Study. o Project Manager for an evacuation time estimate study and the development of an evacuation plan for the South Texas Project EPZ.  ; 1977-1980 Fay, Spofford & Thorndike, Inc. Transportation Engineer. Responsible for traffic operations analyses; traffic control desien, specifications and cost estimates; transportation environmental impact analyses; highway safety analyses; truck circulation studies, and traffic circulation plans for private and public developments. 1975-1977 Central Massachusetts Regional Planning Commission. Transportation Engineer / Planner. Risponsible for transportation corridor planning studies,

                          *ransportation systems manatement, traffic operations analyses, and coordination of the regional transportation air quality control plan.

Other Professional Data Affiliations: Transportation Research Board: National Academy of Sciences Institute of' Transportation Engineers American Society of Civil' Engineers Boston Society of Civil Engineers Papers / o Klimm, R., " Comparison of Optional Cycle Publi- Lengths for an Urban Arterial Signal System cations: Using Maximum Bandwidth and Minimum Vehicle Delay Criteria," Northeastern University, 1979. o Klimm, R., " Fringe Parking and Intermodal Transportation System--Feasibility Study," CMRPC, 1976. o Klimm, R., Sheffie, Y., Mahnassani, H., [ Powell, W., NETVAC2. USER MANUAL," HMM Associates, 1982. N 7/84 2 HMM Associates

F: , a g.-.. Attachmant E Carolyg,Waller Anderson 1411h Wakh Forest Rd. Raleigh, :: orth ;arolina 27604 4 (919) 821-4454 . Education Thomas Jefferson High School, Richmond, Virginia - college preparatory. Louisburg College, Louisburg, North Carolina - Associate of Science, GPA 2.8. E North Carolina State University, Raleigh, North Carolina - B.S. Science Education-Biology, GPA 3.2. Graduate studies - University 'of North Carolina - Chapel Hill, Chapel Hill, North Carolina (3 hours, Demographic Statistics); North Carolina State University, Raleign, North Catolina (4 hours, Limnology) . Employment

            .                   'I

1961-1970 Miscellaneous part time jobs including laboratory technician, camp

                                      >                                                   counselor, store clerk, bookkeeper, residence hall assistant, and warehouse worker.                         ,

1970-1972 U.S. Department of Agriculture, Raleigh, North Carolina - Lab-oratory Aide promoted to Laboratory Technician. 1972-1973 North Carolina Department of Health, Raleigh, North Carolina - ( Medical Technician. 1973- Carolina Power and Light Company, Raleigh, North Carolina - Junior Scientist, Scientist III, Scientist II, Scientist I, Senior Scientist . Service Activities High school / college - 31 principal extracurricular activities. Community service - Louisburg College Alumni Committee (present) . North Carolina State University Alumni Committee Young Democrats of Wake County Sigma Kappa Sorority Corporation-- President Sigma Kappa Sorority - National Officer Raleigh Ski and Outing Club

     , , . .                                                      Personal
                               ?

Single, good health. I e

        ~

',~ ,

      .                                                                                               I CP&L Experience
            - Reports (10 years' experience)--author or coauthor SHNPP:             OL-ER and FSAR (demographic data)

Preconstruction Monitoring Report Annual Environmental Monitoring Report 1978 Annual Environmental Monitoring Report 197'9 Demographic Dita for the SHNPP Evacuation Time Estimate Study H.B. Robinson: ER and FSAR (demographic data) 316a Study Program . 1976-78 Environmental Monitoring Program Results Vol. II Environmental Monitoring Program 1979 Annual Report

        -                              Investigations of Deformities and Lowered Recruitment of Bluegill in Robinson Impoundment BSEP:              ER and FSAR (demographic data)
                  'Asheville:          Environmental Report 1980 Mayo:              Environmental Report June 1977 Siting:            E-25b Preliminary Site Investigation Report SC-8b Preliminary Site Investigation Report Misc.:             Analytical Chemistry Laboratory QA Manual Analytical Chemistry laboratory Procedures Manual Environmental Technology Section Procedures Manual
            ~ Computers (5 years' experience)
                   -Languages: SAS, Librarian, VSPC Equipment: Telex 278-2, Tektronix 4025 and pen plotter, Northern Telecom Data 100 printer system Projects / Systems: Development of Water Quality data management system
    .                                     and data. programming

.2- a-2- . _ Analytical Chemistry Laboratory data programming SHNPP, BSEP, H.B. Robinson, and FERC demography programming ,

                                        ' Air Quality data validat. ion QA system Specialized Skills Demography (10 years' experience)--demographic studies for SHNPP, BSEP, and  H.B. Robinson, Walters, Tillery, Blewett, Marshall, SC-86, Mayo ,

South River, and E-25b; 3 hours graduate-level studies in demographic statistics. Contracts (6 years' experience)--negotiating, writing, and executing three major. contracts . QA Calibration Programs (3 years experience)--developing, implementing, and managing calibration programs for ETS field equipment , QA/QC (2 years' experience)--developing QA/QC policy for ETS, in compliance with Corporate QA; writing procedures Hearings _ (6 years' experience)- " Expert Witness" for SHNPP; H.B. Robinson 316b Demonstration _ testimony preparation; Mayo licensing testimony preparation; BSEP (data) testimony preparation CP&L Plants (4 years' experience)--coordination of environmental studies at H.B. Robinson for (successful) 316b Demonstration; extensive travel Regulatory Agency Interface (6-10 years' experience)--NRC(AEC), EPA, FERC,- Corps of Engineers, South Carolina' Department of Environmental Health and Control, and U.S. Department of the Interior Teaching (6 months' experience)--NC Teaching Certificate eligible to be renewed EEI (2 years' experience)--EEI Task Force on Cultural Resouces

Attachment F BIOGRAPHICAL DATA DR. WILLIAM H. WILKIE - l EDUCATION AND TRAINING 1967-1970 Georgia Institute of Technology, Atlanta, GA Nuclear Engineering / Biology / Radiological Physics Specialization Ph.D. 1960-1962 Vanderbilt University, Nashville, TN Physics / Mathematics / Health Physics Specialization

                    't.S.

1957-1960 North Carolina State University, Raleigh, NC Nuclear Engineering / Engineering Mathematics B.S. (high honors) Graduate study one semester 1955-1957 Maryville College, Maryville, TN Mathematics / Physics (no degree) 1984 Chem-Huclear Systems, Inc., Columbia, SC

                    " Regulatory Awareness--Radioactive Waste Packaging, Transportation, and Disposal" 1979        Oak Ridge Associated ~ Universities and Department of En e,rgy , Oak Ridge, TN
                    " Health Physics in Radiation Accidents" 1976        Institute for Advanced Technology, Washington, DC
                    " Data Communications Systems" 1967        University of Tennessee, Knoxville, TN Biology
       '1962       Oak Ridge Institute of Nuclear Studies, Oak Ridge, TN
                    " Advanced Radioisotope Technology" 1971-1981 Tennessee Valley Authority, Muscle Shoals, AL Numerous courses in computer training, management, systems develop-ment, etc.

CERTIFICATION American Board of Health Physics PROFESSIONAL ORGANIZATIONS i Health Physics Society International Radiation Protection Association 1 .

e

     ~*

Attachment F BIOGRAPHICAL DATA DR. WILLIAM H. . WILKIE PRWESSIONAL ORGANIZATIONS (cont.) American Nuclear Society Sigma Xi HONORARY SOCIETIES Phi Kappa Phi Sigma Pi Sigma Tau Beta Pi EXPERIENCE (Active in the field of health physics for 23 years) 1983- Carolina Power & Light Company, Raleigh, NC Principal Health Physics Specialist 1981-1983' Electricity Supply Commission, Cape Town, South Africa Regional Senior Health Physicist Consultant 1971-1981 Tennessee Valley Authority, Muscle Shoals, AL Staff Health Physicist 1970-1971 University of Pittsburgh, Pittsburgh, PA Assistant Professor of Health Physics, Graduate School of Public Health Technical Director, Radiation Medicine Department, Presbyterian-Universi ty Hospi tal 1968-1970 Technical Analysis Corporation, Atlanta, GA Systems Development Engineer ~(part time) 1962-1967 Oak Ridge National Laboratory, Oak Ridge, TU Research Associate l PREVIOUS CONSULTING Radiological Assessment Systems for Nuclear Power Technology for Energy Corporation Oak Ridge National Laboratory l Advanced Research Corporation l l 7

, .~ - Attachment F BIOGRAPHICAL DATA DR. WILLIAM H. WILKIE BOOKS AND PUBLICATIONS Wilkie, W. H., W. J. Millsap, and J. Walmsley, " Planning Bases for Radiological Emergency Response Near the Koeberg Nuclear Power Station," Escom Report, April 1983

                 " Operations Manual--Tygerberg Radiation Casualty Facility," Escom/

Tygerberg Hospital Report,1983

                 " Upgrading Environmental       Radiation   Data,"  USEPA  Report  EPA 520/1-80-012, August 1980 Wilkie,    W. H., and M. S. Robinson, " Browns Ferry Nuclear Plant Emergency Dose Assessment Procedures for Atmospheric Releases of Radioactivity," TVA Report 0HS-20-80-03, April 1980 Robinson, M. S.,     and W. H. Wilkie, " Browns Ferry Nuclear flant Emergency Dose Assessment Procedures for Liquid Releases of Radio-activity," TVA Report OHS-20-80-04, April 1980 Wilkie, W. H. , S. M. Nelson, and M. S. Robinson, " Technical Bases for Emergency Dose Assessment Procedures for Liquid Releases of Radioactivity," TVA Report OHS-20-80-06, May 1980 Wilkie, W. H., and M. S. Robinson, " Technical Bases for Emergency Dose Assessment Procedures for Atmospheric Releases of Radio-activity," TVA Report 0HS-20-80-05, May 1980 Wil kie, W. . H. , and M. S. Robinson, "Sequoyah Nuclear Plant Emer-gency Dose Assessment Procedures for Atmospheric Releases of Radio-activity," TVA Report OHS-20-80-01, April 1980 Robinson, M. S., and W. H. Wilkie, "Sequoyah Nuclear Plant Emer-gency Dose Assessment Procedures for Liquid Releases of Radio-activity," TVA Report 0HS-20-80-02, April 1980 "American National Standard for Internal Dosimetry for Mixed Fis-sion and Activation Products," ANSI N343-1978 "The Tennessee Valley Region Study: Potential Year 2000 Radiologi-cal Dose ' to Population Resulting from Nuclear Facility Operations,"

DOE /ET-0064/2, June 1978 Garry, S. M., and W. H. Wilkie, "The Use of Environmental Monitor-ing Data 'in Determining Background Radiation Doses," Pooulation Exposures, USAEC Report CONF-741018 (1974) 3

 . -                                                                           Attachment F BIOGRAPHICAL DATA
                                                                                                 ~

DR. WILLIAM H. WILK(E BOOKS AND PUBLICATIONS (cont.) Wilkie, W. H. , "The Interdisciplinary Nature of the Radiological Impact of Nuclear Plani. Ef flu nts on the Environment," Proceedings of TVA Task Force on Water Resources Research Meeting--The Growing Need for Interdisciplinary Research, 1974 Fish, B. R. and W. H. Wilkie, "The Fluid Dynamics of the Spherical Partici e: (1) Tabulatior of Settiing V91ocity, Reynolds Number, Drag Coefticient, Relaxatien Time, and Acteleration-Distance in Air and Water," USAEC Report ORNL-TM-4100 (1973) Wilkie, W. H., "The Spatial and Temporal Capture Distribution for Neutrons in a Coaxial, Two Medum, Liquid Scintillation Detection System," Advanced Research Corporation, Atlanta, GA, February 1970 "Biohazards of Aerospace Nuclear S Final Report," T. G. Cl ark, B. R. Fi sh, W. H. Wilkie, J.' ystems, L. Thompson, R. H. Boyett, and G. W. Royster, Jr., SC-CR-69-3291 (1969) Wilkie, W. H., and D. S. Harmer, " Theoretical Modulation Transfer Functions and Dosimetry of Fast-Neu&on Radiography," Biomedical Sciences Instrumentation-Volume 6, Irstrument Society of America, Pittsburgh, PA (1969) Wilkie, W. H., and B. R. Fish, "ScintO!:tica Catrapolation Dosim-etry of Small Beta-Emi tti ng Sou rces . " 41M State and Chemical Radiation Oosimetry in Medicw.. una ts ' o l ogy , IAtiA, Vienna, Austria t1907)

                 " Environmental   Studies:     Radiological      Significance of Nuclear Rocket Debris," (A series of reports involving classified research)

USAEC Reports ORNL-TM-1053 (1965), ORNL-TM-1159 (1966), ORNL-TM-1686 (1966) ! Wilkie, W. H., and R. D. Birkhoff, " Measurement of Spectral Distri-bution of Positron Flux in an Infinite Copper tiedium Containing Cu-64," Phys. Rev., 135, A1133 (1964) More extensive report on the positron research published as USAEC Report ORNL-3469 (1963) l l 1 4

                                                                                                   )

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

                                                                               $[h((        -

BEFORE THE ATOMIC SAFETY AND LICENSING B(MRI7127 M G2 In the Matter of )

                                                    )

fglfffBRtM4 [.. CAROLINA POWER & LIGHT COMPANY ) AND NORTH CAROLIN A EASTERN ) Docket Nos. 50-400 OL ,

   - MUNICIPAL POWER AGENCY                         )                   50-401 OL
                                                    )

(Shearon Harris Nuclear Power Plant, ) Units 1 & 2) ) CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to Wells Eddleman's General Interrogetories to Applicants (Ninth Set)" were served this 25th day of July,1984 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.

                                                        -  'd .C.

Dale E. Hollar k Associate General Counsel Carolina Power & Light Company Post Office Box 1551

                               >                          Raleigh, North Carolina . 27602 (919) 836-8161 Dated: July 25,1984 5

e o

SERVICE LIST

James L. Kelley, Esquire M. Travis Payne, Esquire

    ~ 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. Nuclear Regulatory Commission -                         Apex, North Carolina 27502 Washington, D. C. 20555                                                                                           -

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 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 U. S. Nuclear Regulatory Commission
       -Washington, D. C. 20555                                       Bradley W. Jones, Esquire U. S. Nuclear Regulatory Commission Docketing and Service Section                                 Region II
       . Office of the Secretary                                      101 Marietta Street U. S. Nuclear Regulatory Commission                           Atlanta, Georgia 30303
     - Washington, D. C. 20555 Robert P. Gruber Mr. Daniel F. Read, President                                 Executive Director Chapel Hill Anti-Nuclear                                      Public Staff Group Effort                                               North Carolina Utilities Co.nmission Post Office Box 2151                                          Post Office Box 991 Raleigh, North Carolina 27602                                 Raleigh, North Carolina 27602 Dr. Lindu Little                                              Mr. Spence W. Perry
     'G:vernor's Waste Management Board                               Federal Emergency Management Agency 513 Albemarle Building                                        500 C Street, S.W.

325 Salisbury Street Room 840 Raleigh, North Carolina 27611 Washington, D. C. 20740 Mr. Steven Crockett, Esquire Atomic Safety and Licensing

          ' Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 John D. Runkle, Esquire Conservation Council of North Carolina 307 Granville Road Chapel Hill, North Carolina 27514 7
              - . _ - -     ._. - ,   . - - - . _                 - -                - - - . . - _ - . - . - -}}