ML20112J883

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Statement of Matl Facts as to Which There Is No Genuine Issue Re Eddleman Contention 213
ML20112J883
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/14/1985
From: Ridgway D
CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20112J843 List:
References
OL, NUDOCS 8501180412
Download: ML20112J883 (4)
v • d • e


Text

.o January 14, 1985 DZ KETED UNITED STATES OF AMERICA L3'? C NUCLEAR REGULATORY COMMISSION 35 JM 17 P1 :57 BEFORE THE ATOMIC SAFETY AND LICENSING iBOARD,933 ;g ma t. .[S

A NC Hou a $5:v;y In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON EDDLEMAN 213 Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Eddleman 213, that there is no genuine issue to be heard with respect to the.following material facts:

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1. Harris Lake is a-recreational area within the Harris EPZ. The lake covers approximately 4000 acres, has an aver-age depth of approximately 18 feet, and is located entirely within Wake and Chatham Counties. Recreational activities on the lake include boating, waterskiing, and swimming.

Black Affidavit, $3.

2. The fixed siren system will be the primary means of alerting boaters, waterskiers and swimners on the lake in the event of an emergency at the Harris plant. j l

Because current plans do not contemplate the use of vehicles as part of the warning system design on Harris 8501180412 850114 i PDR ADOCK 05000400 i G PDR \

T I

8 Lake, no risk of " boat or traffic accidents" will be

associated with the alerting process. Black Affi-davit,-14,
3. Carolina Power & Light' Company (CP&L") is in the process of contracting with Acoustic Technology, Inc.

("ATI") to analyze and evaluate the existing siren sys-tem as a means of alerting boaters, waterskiers and swim-mers on Harris Lake. As a result of this study, ATI will prepare a report which documents the analysis of the warn-ing system for alerting of boaters, waterskiers and swim-mers, to ensure that the siren signal is distinguishable above the projected ambient noise levels aboard a boat.

Black Affidavit, 55; Bassiouni Affidavit, 12.

4. Background noise levels on a recreational lake such as Harris Lake vary largely according to factors such as people's activities and locations, and,according to the time of day, weekday or weekend, and the season of the year. Relatively high background noise levels on the lake may be generated by recreational activities includ-ing swimming, boating and waterskiing. People on board boats will likely perceive more than a 60 dB background noise level. This means a 70 dBC or higher siren signal would be necessary to alert those people. Bassiouni Affidavit, 13.

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-5. ATI has developed a computer model to evaluate and estimate acoustic environments based upon several noise sources. Through the ATI model, the acoustic environ-ment will be determined for swimmers, boaters, and water-i skiers on Harris Lake. The parameters modeled by the com-puter to simulate background noise levels on the lake will include the types of recreational activities on the lake; time of year, day of the week, and time of day; demographic distribution on the lake; types of boats in use; number of boats in each type and possible locations; distribution of boats; characteristics of boats; and loca-tions of access points. Bassiouni Affidavit, 14.

6. For the purpose of siren system design, a conser-i ,

vative. background noise level among the different cases will be utilized. Bassiouni Affidavit, 14.

7. To verify the simulated acoustic environment through the computer model, ATI and CP&L will perform extensive acoustic measurements on the lake. These measurements will include monitoring background noise levels through-out the lake; determining the ambient noise levels for swimmers, boaters and waterskiers; verifying noise char-acteristics of different types of boats; and validating computer model parameters and inputs. Bassiouni Affi-davit, 15.

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8. Using the data obtained from these measurements and surveys, the computer model will be verified and, if necessary, modified. Bassiouni Affidavit, 16.
9. Based upon the simulated background noise levels on the lake developed through the computer model, the existing siren system will be enhanced to ensure that the siren signal is distinguishable above the projected ambient noise levels aboard a boat. Such a signal would also be sufficient to alert swimmers and waterskiers.

Black Affidavit, 16; Bassiouni Affidavit, 17.

Respectfully submitted, W  ! - . 48lt4Q4L t Thomas' A. Baxter,'PIC. Q Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000.

and Richard E. Jones Dale E. Hollar CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated: January 14, 1985

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