ML20098B084

Interrogatories Re EPJ-5 & Wilson 11,12b2 & 12b3.Certificate of Svc Encl.Related Correspondence

ML20098B084
Person / Time
Site:	Harris
Issue date:	09/19/1984
From:	Wilson R WILSON, R.
To:	Federal Emergency Management Agency, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20098B082	List: ML20098B079 ML20098B084
References
OL, NUDOCS 8409250400
Download: ML20098B084 (3)

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'84 SEP 24 P2 :23 i September 19, 19E4 y 0FFICE er m; aging , f 00CKETING & SEPvics~ l-r-

SRANCw UNITED STATES OF AMERICA {

NUCLEAR REGULATORY COMMISSION j 4

i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ) [_

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CAROLINA POWER AND LIGHT COMPANY ) [_

Docket No. 50-400 OL AND NORTH CAROLINA EASTERN )

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. MUNICIPAL POWER AGENCY I

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(Shearon Harris Nuclear Power Plant) ) {.

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I-RICHARD WILSON INTERROGATORIES TO THE NRC  !

STAFF AND FEMA WITH REGARD TO EPJ-5 and k WILSON 11, 12b2, 12b3 1 a) Did the Staff and FEMA support or oppose the admission of l proposed Wilson Contentions 7a, 7d, 7f,11,12b2,12b37  !

b) Please state the basis for your positions on each of these contentions and provide all references you used to support your j positions.,, j t

2 a) Please state your positions on the admitted contentions Wilson 11, 12b2, 12b3, and EPJ-5. ,

b) If different from answers to Ib above, please state the (

basis and relevent references.  ;

c) Please list the documents, including NRC decisions and j cases, that you would present as exhibits at hearing in support of your positions. 't I

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With respect to the FEMA Regional Assistance Committees in-p fo valuation comments on the Off-Site Radiological Emergency Response Plans for the SHNPP done May 1984, a) Please explain in detail the inconsistencies and unreason-abiness referred to in the comment on NUREG item E6 (the relevance of this question to this contention is that if more mergency vehicles and time are required for notification, then fewer vehicles and less time will be available for evacuation and traffic control).

b) Please explain in detail what you believe to be the most accurate way for counties to identify the mobility-impaired to which you referred in NUREG item J10d. Please include your definition of

" mobility-impaired". and the reasons that would cause a resident to be considered " mobility impaired"? Please include as examples any procedures adopted by other counties which achieve this goal in what you believe to be an optunal f ashion.

4. With respect to entrance into the EPZ during the evacuation, a) What groups are usually allowed to enter?

b) What groups do you believe should be allowed to enter?

c) Do you think that pre-arranged criteria should be established for entrance or that the personnel at each traffic control point should make the decisions?

5.a)1s the " vehicle-owning population" as determined by U.S.

/ Census data a reliable estimate of the number of households within the EPZ during a workday that would not have transportation?

b) If not, hov should the estimate be done?

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' c) If so, why shouldn't vehicles driven to work outside the

! EPZ be subtracted from the total number available for

' evacuation?

6. Please identify each person who helped answer these interrogatories.

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UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Cggo y In the Matter of ) _

)

CAROLINA POWER AND LIGHT COMPANY )

~84 SEP 24 P2:21 E AND NORTH CAROLINA EASTERN ) Docket No.

-MUNICIPAL POWER AGENCY ) 50gQ_{0Ltjocgj T y(- g g-

) cF:a m ,

i (Shearon Harris Nuclear Power Plant) )

t-CERTIFICATE OF SERVICE L I hereby certify that copies of Richard Wilson Interrogatories to '

The Applicant on EPJ-5, Wilson 11. Wilson 12b2. Wilson 12b3 and  ;

Richard Wilson Interrogatories to The NRC Staff and FEMA with regard -

to EPJ-5 and Wilson 11,12b2, 12b3 have been served this 19t.h day of September 1984, by deposit in the US Mail, first-class postage pre- ,-

paid, upon all parties whose names are listed below, except those whose names are marked with an asterisk, for whom service was accom-plished by _

. [

Judge James Kelly Phyllis Lotchin, Ph.D. f-Atomic Safety and Licensing Board 108 Bridle Run US Nuclear Regulatory Commission Chapel Hill, N. C. 27514 Washington, D. C. 20555 Dan Read George F. Trowbridge P. O. Box 1551 .

Shaw, Pittman, Pott s & Trowbridge Raleigh, N. C. 27602 1800 M. St. NW Ruthanne G. Miller, Esq.  ;

Washington, D. C. 20036 Atomic Safety & Licensing Board '

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission!

Attn: Dockets 50-400/401 0.L. Washington, D. C. 20555 '

r

" Bradley W. Jones, Esq.  !

Washington, D. C. 20555 U.S. Nuclear Reg. Com., Region II i Office of the Secretary 101 Marrietta Street i Docketing and Service Station Atlanta, Ga. 30303 Attn: Dockets 50-400/401 0.L. Dr. Linda Little Governor's Waste Management Board Washington, D. C. 20555 (3 copies) 513 Albemarle Bldg., 325 N.Salis- i John Runkle, CCNC Raleigh, N. C. 27611 bury 307 Granville Rc,ad Robert P. Gruber, Exec. Director i Chapel Hill, N. C. 27514 Public Staff - NCUC Travis Payne, Edelstein & Payne P. O. Box 991 Box 12607 Raleigh,'N. C. 27602 Raleigh, N. C. 27605 Spence W. Perry, Esq.

Wells Eddleman Assoc. General Counsel, FEMA 718-A Iredell St. 500 C Street, SW, Suite 480 Durham, N. C. 27705 Washington, D. C. 20740  ;

- Certified by- Ih/[Nw ,

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