ML20107A966

Response to Applicant Second Set of Emergency Planning Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20107A966
Person / Time
Site:	Harris
Issue date:	10/30/1984
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
CON-#484-845 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8411020038
Download: ML20107A966 (3)

Text

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RELATED C0illiES?ONDENCE

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,, y UNITED STATES OF AMERICA ~E df 10-3684 NUCLEAR REGULATORY COMMISSION

'84 NOV -1 N0;59 BEFORE THE A'!OMIC SAFETY AND LICENSING BOARDMM 3 $ i Glenn O. Bright MP Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of l CABOLINA POWER AND LIGHT CO. et al. ) (Shearon Harris Nuclear Power Plant, Unit 1) ASLBP No. 82-h68-01

                                                              )                    OL Wells Eddleman's Hesponse to Applicants ' 2d set of E Planning Interrogatories Resnonses to General Interrogatories: Same as to 1st set.

[ Info requested will be given under snecific resnonses where annlicable. l 57-C-7-1(a) It anpears none are.(based on Plan Revis1cn 1) (b)No determination that they are able to do so is available,

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! so far as I am aware. (c) The contention has to do with what the plan does or does not identify, as I understand it, not what I might list. 57-C-7-2(a)' Includes them and others, e.g. Durham County General Hospital, hospitals in the region e.g. in Burlington, Greensboro, etc.

             .but I have not conniled a list. In my view, the plan has to list the hospitals, and any to which patients might be evacuated by helnicopter or otherwise (e.g. to Ft. Bragg, Pope AFB etc in addition to the above) or which is within about 100-150 miles of the plant should be included as a regional hospital. The contention doesn't say that Applicants should evaluate it necessarily, but the plan should.

(b)(c) see (a). I don't see any reason to distinguish " local" frort " regional" hosnitals when the contention referns to both, i.e. Or " local or regional" but as a practical matter you could say (I'm not 8%$ O saying this to be bound by it ...) local are within, say, 50 miles or 1 hour access time by vehicle, regional beyond that though some

    'y       hospitals prov'. ding regional services may be within 50 miles of the plant.

O Rs 57-c-7-3(a)The contention pretty well sneaks for itself. The gg plan diould include a survey of local or regional hospitals (all of them) no and each's ability to treat persons seriously injured by radiation alone. P They survey should be well done, not cursory or fill-in-the-blanks or pg superficial. The criteria for evaluation should include all things ma.o reasonable necessary (in terms of materials, shielding, supplies,

            - medical equipment, radiation monitoring equinment, waste disnosal for materials personnel training transnort treat vicfims of seve,re radiation exposure,... facilities, list nob needed     to all-inclusive)

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  "cnd daould rsalistically, not optimistically or cursorily, evaluato ths facility in those tarms. Only ho;pitals mseting critoria chould be used.,

(b) Savare radiction oxnosura victims can x ba givsn a much greater (e.g. 50$ greater) chage of surviving if properly treated if their doeses are below about 600-800 rem. If the plan fails to assess and assure the provision of medical services for such people, they will more likely die. Listing of medical facilities includes facilities able to treat such i victims, and that ability has to be determined. Further analysis continues when I hr ve more time, as to reasons. These shoul$ be sufficient to motivate the State & counties (I'd hope). mi.e., listed as available to treat severe radiation exnosure. Further i analysis on this answer will c ontinue when I have nore time. 57-C-7-4(a) An obvious one is ' to develop the ability to trett the severe nadiation injury victimas where it does not now exist. At least maamsmalaxmitta;pi C "- , w- axmambummemmmhkysetwo such sites are needed in case one is in the path of the release plume. None annear to exist now. Odher actions may well be required, e.g. transnort for such victims, agreements to treat them, etc, to assure personnel are available to get these people to treatment and get them treated effectively. (b) In order to safe lives and to meet the requirenents of NU9FG-0654, re which see (b)(of answer (3)) above, or subnart must 213-a-1-(a) Any part/where any notion is specified, akan2d have implementing nrocedures. The procedures must either be written out in the plan, at that point, or otherwise set forth in the plan. (b) See (a). NUREG-0654 says the procedures must be in the plan. (c) except for the alerting sequence and nart of the decision to administer radiciodines, it anpears that all procedures are either incomplete or unstated in the plan. As to the others, it is not my job to write the procedures -- it is the State 's and affected agencies ' job. If the procedures are made available for my review, I may be able to contribute analysis of Ebeir adequacy, if sufficient information is provided in the procedures. 213-Aa-2-(a)*ut in the procedures, be sure daey are workable, have step by step directions, are clear and unambiguous, have them reviewed by FEMA, NBC, CP&L, other planning authorities, and others (e.g. intervenors having contentions in this area), correct nroblems and put corrected nrocedures into plan. (b) It's silly to put in procedures for inplementing the olan if they won't work -- so at ninimum taey should heet the requirements above and , be reviewed. NUREG-0654 requires the nrocedures be in the plan. i If there is concern for plan lenghth, it would be better to replacd general discussions or handwaving in the plan, with the actual urocedures to be used, making the plan itself far more useful and reviewable and testable. Again, these qualities are required in the plan so it will work. An unworkable plan cannot meet the requirements of 10 CPR 50.h7, e.g.. (a)(1) and all specific requirements in the nianz sections following i t. r 213-a-3(a) daese is no 4(a). If you mean (2)(a) above, analysis continues and I'm sure it can be fleshed out more. The reassons (b) are esansentially the same as 2(b) above and can be amplified. l 240-1(a) Plan must state what contention requires it to identify. This ID mus t be to a workable action / agency / agencies. (b) read 0654 and 50 47. 2(a) Should assess workability. 0.47(a) 1) and (b). I affirm the above areAny trudocumeM%

                                                                                  . % beW jfwi 1 0(b) b na see v){Cht J he[tf e available xni a mutually agreeable bassis.                                                      #

e is Eddleman 0-29-8h

r - UNITED STATES OF AMERICA NUCLF.AR REGULATORY COMMISSION In the matter of CAROLIKA PCMER k LIGHT CO. Et al. )) Docket 50-h00 0.L. Shearon Harris Nuclear Power P3snt. Unit 1'__ CERTIFICATEoF SERVICE

                                                                     .W.E. Resnonse to InterroF~atories I hereby certify that copies of dated 10-05-84 (received 10-10) (From Appliciints, r!. Planning 2d set)

October HAVE been served this day of 198 , by deposit in i the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are Turked with an asterisk, for whom service was accomplished by hand -- Pls hr extension of time to distribute at hearing A.-)G /Wecas &%/ l6 '19 Judges James Kelley, Glenn Bright and James Carpenter (1 cgy each) jAtomic Safety and Licensing Board US Nuclear Regulatory Commission Washington DC 20555

                           $ George F. Trowbridge (attorney for Applicants)

Shaw, Pittman, Potts & Trowbridge -/ R uthanne G. Miller 1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2(55 5 ce W. P P 4 0ffice of the Executive Attn Docke ts 50-400/401 0.L. Legal Director g /1 or 1500 C St. sw washington DC 20740 Wa ngton DC 20555 Dan Read i  % Docketing and Service Section (3x) CEA?E/FLP ! Attn Docke ts 50-hoo/hol o.L. . Waleigh,r/07 Waveross Office of the Secretary NC 27606 USNRC Dr. Linda W. Little Washington DC 20555 noy rnoris Waste Mst. Bd. 513 Albemarle B1dg ,

                            -](John Runkle                                          325 N. salisbun St.

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• Granville Rd -

Chapel Eill Re 2751h Bradley W. Jones Robert Gruber USNRC Region II

                                 'Travi s Payne           Exec.' Director                101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 303o3 Blox 12601 Box 991 Raleigh NC 27605 Raleish NC 27602 Richard Wilson, M.D. Certified by h 729 Hunter St. Apex NC 27502

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