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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20140A9961986-01-22022 January 1986 Responds to Eighth Set of Interrogatories Propounded by W Eddleman Re Communication Deficiency in Harnett County,Nc. Ti Hawkins Affidavit Encl.Related Correspondence ML20138R0961985-12-22022 December 1985 Responses to Applicant 851125 Emergency Planning Interrogatories & Request for Production of Documents (Third Set).Related Correspondence ML20138R1141985-12-20020 December 1985 Response to Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20138R1061985-12-20020 December 1985 Response to General Interrogatories.Related Correspondence ML20137L9851985-11-26026 November 1985 Interrogatories to NRC & FEMA on Studies,Info & Knowledge Re Contentions on Which Discovery Now Open ML20137M0031985-11-26026 November 1985 Interrogatories to Applicant & State of Nc.Certificate of Svc Encl ML20137H6291985-11-25025 November 1985 Third Set of Interrogatories Re Emergency Planning & Request for Production of Certain Documents.Certificate of Svc Encl. Related Correspondence ML20138D2761985-10-18018 October 1985 Supplementary Response to General Interrogatories 2-3 & 12-14 Re Eddleman Contention 57-C-3 Concerning Nighttime Emergency Siren Sys at Facility.Certificate of Svc Encl. Related Correspondence ML20128P8311985-05-29029 May 1985 Correction of Answer to Applicant Discovery Requests Re Interrogatories on Contention WB-3 Concerning Drug Abuse. Certificate of Svc Encl.Related Correspondence ML20128P8001985-05-29029 May 1985 Response to NRC Interrogatories Re Contention WB-3 Concerning Drug Abuse.Related Correspondence ML20128G7151985-05-24024 May 1985 Answers to Discovery Requests Re Contention WB-3 on Drug Abuse.Applicants Have Not Reinspected safety-related Work of Known Drug Abusers ML20127M8941985-05-20020 May 1985 Answers to Conservation Council Discovery Requests Re Contention WB-3, Drug Abuse During Const. Util Employee Assistance Program Provides Aid in Drug Rehabilitation. W/Certificate of Svc.Related Correspondence ML20116L1731985-05-0101 May 1985 Interrogatories & Request for Production of Documents Re Allegations in Contention WB-3,per ASLB 850315 Memorandum & Order Ruling on Contentions Re Diesel Generators,Drug Use & Harassment.Certificate of Svc Encl.Related Correspondence ML20102C3621985-03-0101 March 1985 Responses to Interrogatories & Request for Production of Documents on Contention 41-G.C Van Vo Considered to Be Well Qualified in Experience & Educ for Job.Related Correspondence ML20107D0491985-02-19019 February 1985 Response to W Eddleman 12th Set of General Interrogatories to Applicant Re Contention 41-G.Related Correspondence ML20107D0591985-02-19019 February 1985 Response to W Eddleman Request for Production of Documents Re Contention 41-G.Certificate of Svc Encl.Related Correspondence ML20106D0951985-02-0808 February 1985 Applicant Request That W Eddleman Answer Interrogatories & Produce & Permit Insp of Documents Re Contention 41-G Concerning C Van Vo Allegations.Certificate of Svc Encl. Related Correspondence ML20102A2061985-02-0404 February 1985 General Interrogatories & Request for Production of Documents Re Employment of Cv Vo.Related Correspondence ML20102A0791985-02-0404 February 1985 Seventh Set of Interrogatories & Request for Production of Documents Re Eddleman Contentions.Related Correspondence ML20101E9021984-12-21021 December 1984 Response to W Eddleman Second Round Interrogatories on 213-A to Applicant/Emergency Response Personnel & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20100G5971984-12-0303 December 1984 Second Round Interrogatories on 213-A to Applicants/ Emergency Response Personnel & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20100A5001984-11-30030 November 1984 Response to 841005 Discovery on Contention EPJ-3 (Volunteer Workers).Certificate of Svc Encl.Related Correspondence ML20099K4271984-11-26026 November 1984 Applicant Supplemental Responses to W Eddleman General Interrogatories to Applicant 11th Set.Certificate of Svc Encl.Related Correspondence ML20099D3771984-11-0909 November 1984 Response to Applicant 841005 Emergency Planning Interrogatories & Request for Production of Documents to Sponsors of EPJ-1,EPJ-4 & EPJ-5.Certificate of Svc Encl. Related Correspondence ML20107G1011984-10-31031 October 1984 Final Response to Conservation Council of North Carolina First Set of Interrogatories & Request for Production of Documents on Emergency Planning Contentions.Related Correspondence ML20107F3851984-10-31031 October 1984 Response to Conservation Council of North Carolina Interrogatories & Request for Production of Documents Re First Set of Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence 1999-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
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- UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER AND LIGHT COMPANY AND ) Docket N8.456E4@J 0tpg ,.g NORTH CAROLINA EASTERN MUNICIPAL -) 50-401 OL POWER AGENCY ) .y,2 y ecng yh_; -
(Shearon Harris Nuclear Power Plant, ll' ^ Y '
Units 1 and 2)
RESPONSE TO INTERR0GATORIES DATED JUNE 29.-1984 PROPOUNDED BY WELLS EDDLEMAN CONCERNING EDDLEMEN 215 AND 224 The following responses are presented on behalf of the NRC staff for which I serve as a subcontractor through the Battelle Pacific Northwest Laboratories. Battelle is responsible under contract to the Nuclear Regulatory Commission for reviewing evacuation time estimates.
GENERAL INTERR0GATORIES My name is Thomas Urbanik, II. I am an Associate Research Engineer associated with the Texas Transportation Institute of the Texas A&M University System, College Station Texas. I serve as a subcontractor through the Battelle Pacific Northwest Laboratories. Battello is responsible under contract to the Nuclear Regulatory Commission for reviewing evacuation time estimates for nuclear facilities. A statement of my professional qualifications is attached.
I have reviewed the October 1983 Evacuation Time Estimate Study entitled
" Evacuation Time Estimates for the Plume Exposure Pathway Emergency Planning Zone, Shearon Harris Nuclear Power Plant", prepared by HMM Associates of Raleigh, North Carolina. A copy of my review is attached. The documents 1
I i 8409040145 840829 PDR ADOCK 05000400 0 PDR
a
- . . l assisting in my review include NUREG-0654, the Highway Capacity Manual, and l 1
the . Interim ' Materials on Highway Capacity. The last two cited documents are available from the Transportation Research Board, National Academy of Sciences Washington, D.C.
SPECIFIC INTERR0GATORIES In regards to Interrogatory 224-1, I have conducted no independent analysis of meterological data and I do not have any data outside that presented in the October 1983 Evacuation Time Estimate Study.
In regards to Interrogatory 224-2, sensitivity analyses, none were performed at Shearon Harris beyond those contained in the October 1983 Evacuation Time Estimate Study.
In regards to Interrogatory 215-1, 215-2 and 215-3, no data or analyses of transient populations or their characteristics were done beyond those emminating from the October 1983 Evacuation Time Estimate Study; and none are planned.
In regards to Interrogatory 215-4 and 215-5, no such studies have been made.
In regards to Interrogatory 215-6, the Highway Statistics Division,
, Federal Highway Administration U.S. Department of Transportation has pub-lished findings from the 1977 National Personal Transportation Study which contains data concerning vehicle occupancy (see for example Report 6. Vehicle Occupancy). However, no special analyses beyond those contained in the October 1983 Evacuation Time Estimate Study were made.
In regard to Interrogatories 215-7 to 215-9, I know of no analyses beyond those previously stated.
a 1
UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION .l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
In the Matter of )
)
CAROLINA POWER AND LIGHT COMPANY AND ) Docket No. 50-400 OL NORTH CAROLINA EASTERN MUNICIPAL ) 50-401 OL POWER AGENCY )
)
. (Shearon Harris Nuclear Power Plant, )
Units 1 and 2)
AFFIDAVIT OF THOMAS URBANIX II I, Thomas Urbanik II, hereby affirm as follows, subject to the penalty of purjury, that the answers are true and correct to my best knowledge and belief.
- 1. I am an Associate Research Engineer associated with the Texas Transportation Institute of the Texas A&M University System, College Station Texas.
- 2. I hereby certify the answers given to Eddleman 215 and 224 are true to the best of my knowledge.
4 C
Thomas Urbanik II
February 1984 '
BIOGRAPHICAL DATA URBANIK II. THOMAS Program Manager Texas Transportation Institute Lecturer, Civil Engineering Department, Texas A&M University Education Ph.D., Civil Engineering, Texas A&M University, 1982.
M.S., Civil Engineering, Purdue University, 1971.
B.S., Civil Engineering, Syracuse University, 1969.
B.S., Forest Engineering, State University of New York,1968.
Experience Program Manager, Texas Transportation Institute, Texas A&M University System, 1983-Present.
Assistant Research Engineer, Texas Transportation Institute, Texas A&M University System, 1977-1983.
Lecturer. Civil Engineering, Texas A&M University,1982-Present.
Traffic Engineer, City of Ann Arbor, Ann Arbor, Michigan, 1972-1976.
Transportation Planning Engineer, City of Ann Arbor. Ann Arbor, Michigan, 1971-1972.
Research Assistant, Joint Highway Research Project, Purdue University, 1970-1971.
Professional Licenses 1
Registered Professional Engineer, Texas and Michigan Memberships American Society of Civil Engineers '
Institute of Transportation Engineers Sigma Xi Chi Epsilon SIGNIFICANT REPORTS AND PUBLICATIONS Tmffia Engineering Speed / Volume Relationships on Texas Highways, State Department of Highways and Public Transportation, Research Report 327-2F, Austin, Texas, October 1983. ,
Priority Treatment of Buses at Traffic Signals. Transportation Engi-neering November 1977.
Priority Treatment of High-Occupancy Vehicles on Arterial Streets.
State Department of Highways and Public Transportation, Report 205-5, 1977.
Evaluation of Alternative Concepts for Priority Use of Urban Freeways in Texas,1977.
Driver Information Systems for Highway-Railway Grade Crossings. Highway Research Record Number 414, 1972.
1 s _ .
URBANIK II. THOMAS Evacuation Planning An Independent Assessment of Evacuation Times For a Peak Population Scenario in the Emergency Planning Zone of the Seabrook Nuclear Power Station, U.S. Nuclear Regulatory Comission, NUREG/CR-2903, 1982.
CLEAR (Calculates Logical Evacuation And Response). A Generic Transportation Net-work Model for the Calculation of Evacuation Times Estimates, U.S. Nuclear Regulatory Comission, NUREG/CR-2504 October 1981.
Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones, U.S. Nuclear Regulatory Comission, NUREG/CR-1745, 1980.
Analysis of Eiacuation Times Around 52 Nuclear Power Plant Sites. U.S.
Nuclear Regulatory Comission, NUREG/CR-1856 Volume 1,1980.
Hurricane Evacuation Demand and Capacity Estimation. Florida Sea Grant College, Report Number 33, 1980.
Texas Hurricane Evacuation Study. The Texas Coastal and Marine Coun-cil , 1978.
Pubtic Tmneporbation Analysis of Rural Public Transportation in Texas. State Department of Highways and Public Transportation. Technical Report 1069-1F, August 1982.
Intercity Bus Riders in Texas. Transportation Research Record 887, 1982.
The Intercity Bus Industry in the U.S. and Texas. State Department of Highways and Public Transportation. Technical. Report 0965-1F 1981.
Bryan-College Station Energy Contingency Study. Metropolitan Planning Organization of Bryan-College Station,1980.
Bryan-College Station Transit Improvement Plan. Metropolitan Planning Organization, 1979.
Ann Arbor Dial-A-Ride Project Final Report, Ann Arbor Transportation Authority, 1973.
Ann Arbor Dial-A-Ride Operations, Highway Research Board Special Report 136, 1973.
The Greater Lafayette Area Bus Transit Study. Joint Highway Research Project, Purdue University,1971.
EEder!y and Bandimypod Tmneporhation Evaluation of Selected Human Services Transportation Providers. State Department of Highways and Public Transportation,1980.
Cost-Effectiveness of Accessible Fixed-Route Buses in Texas. Technical Report 1061-1F, 1979.
Transportation of the Elderly and Handicapped in Texas: A Case Study.
State Department of Highways and Public Transportation. Technical Repcrt 1056-2F,1979.
. UnsANIK II, THOMAS Page 3 .
j 1
Total Accessibility Versus Equivalent Mobility of the Handicapped.
Institute of Transportation Engineers, Compendium of Technical Papers, 49th Annual Meeting,1979. !
Survey of Vehicles and Equipment for Elderly and Handicapped Trans- !
portation. State Department of Highways and Public Transporta-tion, Technical Report 1056-1, 1978.
Corpus Christi Elderly and Handicapped Transportation Study. City of Corpus Christi Texas,1978.
Espart Fitness Presented expert testimony before the Atomic Safety and Licensing Board, U.S. Nuclear Regulatory Commission, concerning evacuation times at several nuclear power plant sites including Three-Mile Island, Diablo Canyon, Indian Point, Seabrook and Shoreham.
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g EVALUATION OF EVACUATION TIME ESTIMATE )
Sh^^ron N"rris e -
Item Adequate ~ Deficient Poor None I. General A. Naps X B. Report Format X II. Demand Estimation A. Permanent Residents X B. Transient Populations X C. Special Facility Population X D. EPZ Sub-areas X III. Traffic Capacity A. Evacuation Roadway Network X B. Roadway Characteristics X C. Adverse Weather Considered X IV. Analysis A. Assumptions '
.X B. Methodology X C. Carless X V. Other Requirements A. Confirmation Time X B. State and Local Review X VI. Overall X Date of Reports October 1,1983
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of CAROLINA POWER AND LIGHT COMPANY AND NORTH CAROLINA EASTERN MUNICIPAL Docket Nos. 50-400 OL POWER AGENCY 50-401 OL (ShearonHarrisNuclearPowerPlant, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO INTERROGATORIES PROPOUNDED BY WELLS EDDLEMAN ON JUNE 29, 1984 ON CONTENTIONS 215 AND 224" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, throu mail system (*)gh , thisdeposit 29th day inofthe Nuclear August, Regulatory Commission's internal 1984.
James L. Kelley, Chairman
Administrative Judge 729 Hunter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn 0. Bright
Administrative Judge 723 W. Johnson Street Atomic Safety and Licensing Board P.O. Box 12643 U.S. Nuclear Regulatory Commission Raleigh, NC 27605 Washington, DC 20555 Dr. James H. Carpenter
- Dr. Linda Little Administrative Judge Governor's Waste Management Building Atomic Safety and Licensing Board 513 Albermarle Building U.S. Nuclear Regulatory Commission 325 North Salisbury Street Washington, DC 20555 Raleigh, NC 27611 Daniel F. Read John Runkle, Executive Coordinator CHANGE Conservation Counsel of North Carolina P.O. Box 2151 307 Granville Rd.
Raleigh, NC 27602 Chapel Hill, NC 27514
Atomic Safety and Licensing Appeal Bradley W. Jones, Esq.*
Board Panel Regional Counsel, USNRC, Region II U.S. Nuclear Regulatory Commission 101 Marietta.St., N.W. Suite 2900 Washington, DC 20555 Atlanta, GA 30323
. Robert P. Gruber George Trowbridge, Esq.
Executive Director Thomas A. Baxter, Esq.
Public Staff - NCUC John H. O'Neill, Jr., Esq.
P.O. Box 991 Shaw, Pittman, Potts & Trowbridge Raleigh, NC 27602 1800 M Street, N.W.
Washington, DC 20036 Wells Eddleman Atomic Safety and Licensing Board 718-A Iredell Street Panel
- Durtam, NC 27701 U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard E. Jones, Esq. Dr. Harry Foreman, Alternate Associate General Counsel Administrative Judge Carolina Power & Light Company- P.O. Box 395 Mayo P.O. Box 1551 University of Minnesota Raleigh, NC 27602 Minneapolis, MN 55455 TELA AD E.M (TEL Janice E. Moore Counsel for NRC Staff 1
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