ML20072M476

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Pages 43 & 44 to Util 830708 Response to W Eddleman Contentions Re Des,Inadvertently Omitted,Svc List Encl
ML20072M476
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 07/11/1983
From:
CAROLINA POWER & LIGHT CO.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20072M459 List:
References
NUDOCS 8307140445
Download: ML20072M476 (4)


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f the LPGS and that the Harris Plant is not unique in its liquid pathway risk contribution.

Id. at 5-72.

Mr. Eddleman does not dispute these findings nor does he allege that the Staff's de-scription and analysis of the site geology is inaccurate.

In sum, then, it is Applicants' position that Mr. Eddleman has failed to provide a basis with the requisite specificity in i

support of his proposed Contention 162 and the proposed conten-tion must be rejected.

Contention 163 i

i Proposed Contention 163 claims that the Staff's analyses of severe accidents fail to take into account the increasing concentration of people and business in the Apex and Cary areas.

Eddleman Response at 32.

While Mr. Eddleman has pro-vided some explanation of the manner in which he contends the DES is incorrect or insufficient, Applicants contend, as discussed below, that Mr. Eddleman has not set forth a suffi-J ciently specific basis for his contention.15/

l i

15/

Applicants would also note that certain of Mr. Eddleman's complaints here are not timely.

For example, Applicants' ER (which forms the basis for the Staff's DES) contains detailed population data and projections through the year 2027.

Simi-larly, the statement at p.

4-1 of the DES that area land use is

" essentially unchanged" from the CP stage is based upon $2.1.2 of the ER, which stated that the area was primarily a rural-type population distribution.

As to the other four

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i factors briefly mentioned by Mr. Eddleman (June 20 Pleading at 32), Applicants note that Mr. Eddleman fails to address how his participation in this issue might assist in developing a sound record.

See 10 C.F.R. 5 2.714(a)(1)(iii).

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Section 4.3.7 of the DES describes generally the popula-tion in the vicinity of the Harris Plant and specifically identifies increased transient populations in the area which were not considered at the CP stage.

Contrary to i

Mr. Eddleman's claims, this section recognizes the increased number of transient workers (approximately 2000) employed in j

the Apex area.

Mr. Eddleman also complains that the ER popula-tion projections show an increased population growth over that j

projected at the time of the CP stage FES and that the Staff l

mischaracterizes these two projections as being alike.

Appli-cants fail to see the significance of this complaint and, in any event, believe that the two projections are indeed " fairly i

consistent", as characterized by the Staff.

Compare RFES Table 2.1 with ER Tables 2.1.2-1 and 2.1.2-3 (1990 projections).

Fi-nally, while proposed Contention 163 may quibble with the popu-3 lation projections underlying the Staff's assessments, j

Mr. Eddleman does not take issue with the actual Staff evalua-tion of the economic impacts on area businesses and agriculture that would be associated with a severe accident at the Harris Plant.

See DES at 5-75, 5-78 through 5-82.

i Proposed Contention 163 is untimely and lacks basis with requisite specificity; as such it must be rejected.

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  • UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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CAROLINA POWER & LIGHT COMPANY

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Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN

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50-401 OL MUNICIPAL POWER AGENCY

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(Shearon Harris Nuclear Power

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Plant, Units 1 and 2)

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SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Commission 307 Granville Road Washington, D.C.

20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright 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 Dr. James H. Carpenter 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 Charles A. Barth, Esquire (4) 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Commission Richard E. Jones, Esquire Washington, D.C.

20555 Vice President and Senior Counsel Docketing and Service Section (3)

Carolina Power & Light Company Office of the Secretary Post Office Box 1551 U.S. Nuclear Regulatory Connission Raleigh, North Carolina 27602 Washington, D.C.

20555 Dr. Phyllis Lotchin Mr. Daniel F. Read, President 108 Bridle Run Chapel Hill Anti-Nuclear Group Effort Chapel Hill, North Carolina 27514 Post Office Box 524 Chapel Hill, North Carolina 27514 Deborah Greenblatt, Esquire 1634 Crest Road Raleigh, North Carolina 27606

Service List Page TVo Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commission Region II 101 Marrietta Street Atlanca, Georgia 30303 Ruthanne G. Miller, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commissica Washington, D.C.

20555 Karen E. Long, Esquire Public Staff - NCUC Post Office Box 991 Raleigh, North Carolina 27602 l

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