ML20092N501

General Interrogatories (Ninth Set) & Request for Production of Documents.Related Correspondence

ML20092N501
Person / Time
Site:	Harris
Issue date:	06/29/1984
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
Shared Package
ML20092N499	List: ML20092N498 ML20092N501 ML20092N502 ML20092N507
References
OL, NUDOCS 8407030211
Download: ML20092N501 (16)

Text

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UNITED STATES OF AMERICA i Q=~

i NUCLEAR BEGULATORY COMMISSION Y U L -2 P 3.'n7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L Glenn O. Eright -

Dr. James H. Carpenter ,-

James L. Kelley, Chairman  ;

i In the Matter of l

) Docket 50 400 OL CAB 0 LINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

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Wells Eddleman's General InterroEatories .

to Aeolicants Carolina Power & Light et al.

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Under 10 CFR 2.7h0, 2.7h1 and the Board's 9-22-82 Memorandum (s)

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andOrdehWellsEddlemanreouestsApplicantst V a CitU UC bly ofr CC sh+arate coa y(pe/f6*

and fully in writing, under oath or affirmation, each of the [4tW.5 ;

following interrogatories, and to produce a permit inscection and -

conying of the original' or best copy of all document's ider.tified in resnonse to interrogatories as set forth below. .  ;

l These interrogatories are intended to be continuing in nature,  !

and I request each answer to be promptly supplement ae ed  !

j aunrocriate unde" 10 CFR ?.7h0(e), should CPG, NCEMPA, .any othe" WA l

or any contractor or consultant to any, some or all of those, g l

Apolicant, Aor any emi oyee of any or some or all of them, or any  ;

f individual acting on behalf of any or some of all of them, obtain g i or create any new or differing information resconsive to these ,

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genera ("Them" refe=s.to the nterrogatorie The precedingor reouest list oro$ng(s)) duction of documents-J is also continuing and reouests Applicants to eroduce tromotly if 5 not immediately any additional documents the Applicants and others .

actin 6 on their behalf or employed by them, as lis'ted in the previous  ;

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sentsnco, obtain trhich cro responsive to the raquest(s) for nroduction of doeunents below.  !

Where identification of a document is re{uested, clease briefly describe the document (e.g. book, notebook, letter, memo, report, notes, transcript, minutes, test data, log, etc. ) and provide the  :

document name, title, number, following information as applicable:

author (s), date of writing or of publication or both, addressee, date approved, by whom aproved, and the name and address of' the versens ha'ing normal custody of tha document, and name and addi ess f of any yerson other than the preceding having actual possession of l

the document. When identifying documents in resconse to these '

interroEatories and reguests, please state the portion or portions ofthedocument(e.g. sections,chafrs,pages, lines)up,onwhich Applicants rely or w .ich Ap{licants swear or affirm is/are responsive to the appli, cable interrogatory or veguest.  !

i DEFINITIONS herein: '

" Harris", " Harris Plant", "SENPP", or " plant" where not specified l otherwise, all mean the Shearon Harris wuelear Power flant.

" Applicants" means all of the persons, emoloyees, consultants, contractors and corporations as listed in the first sentence of the j second paragraph on page 1 of this document, above.

"FSAR" means the Harris Final Safety Analysis *enort.

"ER" means the Harris Environmental Fenort.  !

" Document ($" means all writings and records of ever7 yne, j t

f including electronic and ccmuter records, inthepossessien, control f licarts' or custody of A plicants or any individual (s) act$n6 on A behalf, including, but not linited to: t'enort s , books , memoranda , f j

corresnondence, notes, minutes,paghlets, leaflets, magazines, articles, surveys, maps, bulletins, photogranhs, speechen, transcripts, i

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. . - . . 3 voice racordings, com7utar printouts, information storPd in coyutors or comnuter peripheral devices such as disks, drums, etc. , voice recordings, microfilm, microfiche and all other writinEs or scordings of any kind (s); and cocies of any of the preceding even though the j ortEi nal(s) are not in the possession of Applicants or in their custody or control. Document (s) shall be deemed to be within the any control of Applicants or individual's) acting on their behalf if they have ownership, ossession, or custody of the docunert.(s) or a cony thereof, or have the right to secure the docutgent(s)  !

of a cop thereof, from any person or public or private entity having ph7sical possessien thereof.

Each definitton given above a lies within all other definitions above. .

GEMEdeL /*JTE/MD64TD% l G1 (a) Yhich contentions of Wells: Eddleman do Applicants agree  !

are now adnitted in this nroceeding, N*C Dockets 50-1400/401 0.L. ?

, l (b) for each such contentien, provide for any answers to interrog- t stories by Wella Eddleman which Acolicants have previously or [

eresently received (except those suspended by Board order, if any), the  :

I following information: l (c) Please state the name, present or last known address, and cresenW i or last known encloyer of each person whom Aeplicants believe or know l l

(1) has first-hand knowledge of the facts alleged in each such l answer; or (2) unon whom Applicants relied ( other than their attorneys) in making such answer.

(d) elease identify all facts concerning which each such verson 7 ideniified in resconse to 01(c)(1) above has first-hand knowledge.

(e)nienseidentifyallfactsand/ordocumentsuponwhicheach l

nevson identified in response to G1(c)(2) above relied in pro #iding informationtorespondtotheinterrogatory,includingtheparts of such docunents relied ucon. ,

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(f) Please identify any other document (s) used/by A licants in responding to the interrogatory.

l (g) Please state which specific fact each docunent, identified in resnonse to G1(e) and GL(f) above, aunports, in the ouinion er belief of Aunlicants, or which Annlicants allege such docunent supnerts.

(b) Please state specifically what information each nerson ,

i identified in resnonse to G1(c)(1) or G1(c)(2) above orovided to l

I or for Anplicants' affiant in answering the interrogatory. If any [

of this information is rot docunented, nisase identify it as i "undocunented" in resnonding to this sect *.on of General Interrogato7 Gl.

G2.a)*1 ease state the name, present or last known a(dress, title (if any), and nresent or last kno,wn syloyer, and econonic interest (shareholder, bondholder, contractor, ewlo7ee, etc. ) if or other any (beyond expert witness fees) such nerson holds in Applicants f or exnect or an7 of them, for . each nerson you intend jtc ce.11 as an . exeert i witness or a witness in this proceeding, if such information has l

l not vreviously been supnlied, or has changed since such information i l i

! was last sueplied, to Wells Eddlenan. This applies to Eddlenen ,

i and Joint Contentions as admitted,o* stinulated by Apelicants.

l (b). Please identify each contention regarding which each .

I such person is exnected to testify.  ;

(c) Please state when you first contacted each such verson  ;

l with reEard to the possibility of such norson's testifying for ]

Apolicants, if you have contacted such nerson. '

(d) Please state the subject natter, separately for each j 1

i contention as to which each such person is expected to testify, '

! whicheachsuchpersonisexpectedtotestifyto.

(e) Please identify all docunents or narts thereof unen which each such witness is expected to, nlans to, or will rely, in testifying or in preparing testimony.

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03(a) Please identify any other sou"ce(s) of information which Applicants have used to resnond to any interrogatory identified f under G1 above, stating for each such source the interrogatory l to which it relates, and what information it provides, and identifying f where in such source that information is to be found.

(b) Please identify any other source @of information not vrevicusly  ;

identified upon which any witness identified under G2 above, or l or exhibits ,

otherwitness,hasusedinurenaringtestinen[,orexnectstouse in testimony or exhibits, identifying for each such source the l witness who is exnected to use it, and the nart or part(s) of such l so urce (if applicable) which are expected to be used, .a.nd, if not  ;

(or both) f oreviously stated, the f act(s) or subject matter to which such '

f .

s'ource relates, and which i t

, G14(a) please' identify all documents,gpages or sections thereof Aplicants ibtand or eyect to use in cross-examination of any  ;

witness I call in this hearing. For each such witness, please troville on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Aeolicants believe they relate to, and nake the document (s) available for insueetion l forrt intent and coeying as scen as possible after A licants decide orj2mixmd to use such document in cross-examination.  !

(b) please identify any undocumented information Applicants intend to use in cross-exanination of each such witness for ne. ,

5 G5 (a) for each contention Apolicants state or a& nit is an i 1

admitted Eddleman contention under G1(a) above, or an admitted  !

joint intervenor contention, please state whether gplicants have available to them experts, and information, on the subject  !

matter of the contention.

(b) If the answer to (a) above is other than affirmative, j state whether Aeolicants exoect to be able to obtain extertise in  !

the subject matter, and information on it, and if not, why not.

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G-6(a) for each docunent identified in resconse to any interrogaton herein, or referenced in response to and into[rogatory herelif, please supply all the following 'infernat! n tqhich has not alre3dy -

been supplied: .s

' 'N (1) date' of the document '

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(ii) title or identification of document '

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t (iii) all authors of the Accument, on the author (iv) all qualifications (professional, technical) of.each I author of the document '

of the document, (v) the specific parts, sections or pages, if any, unon 0

which Annlicants rely l (vi) the specific information each nart, section.or nage identified in resnonse to (v) above co,ntains g (vii) identify all documents used in renaring the docunent, to the extent known (and also to the extent not identified in the

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docunent itself)  :

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(viii) state whether Anplicantsjpossess e. co-y of the i p  ;

o~ A doc ument ,

(ix) state all expert eniniors contained n the document, upon which Annlicants rely, or identify each sucN opinion.

(x) identify the contention (s) with resnect to which Anniteants':

rely upon (a) the exnert oninions (b) the facts identified g in the docunent (xi) state whether Apolicants now ennloy any author (s) of the document, identifying each such person for each document.

(xii) state whether Applicants have ever emuloyed any auth@ s) of the docunent, identifying each such person for each document.

(xiii) identify all sources of data used in the document.

Answers to all the above may be tabulated or grouned for efficiency.

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- G-7(a)' Please identify all documents which Applicants plan, exoect or a l

\[  !%nntend to offer as exhibits (other than for cross-examination) with i

- Brespl<ect to each Eddleman contention admitted in this proceeding which i y~

(1) is included in your current resnonse to 01(a), or (ii) is the

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sub N ; ' or' contentions ject .of interrogatories each exhibit in will thisbe set; orplease state to is exuected forbe which contention offered.  !

% (b) Please identify all documents which Auplicants nian, expect or j 1

l intend to use in cross-exanination of any other perties' l s

p,. . witnesses or joint intervenor witness in this proceeding, with reseect I

t l'h'# e to (i) Eddleman contentions identified under G-7(a)(1) (or G1-(e))

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• "Y* o above, or any other Eddleman contention which is the subject of inter-

, .h gatories in this set; (ii) each Joint contention now adnitted in >

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this proceeding; (iii) per our agreenent of h-8-83, each contention

\ of each other party to this proceeding which is cu=rentlY adnitted. f h ..Please identify 'for each such document'the witnesses, or witness,

.'and all contentions with resoect to whom (or which) that document  ;

.as '

4 is planned, expected, cn? intended to be offered or used.  ;

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4 J (c) Please identify which of the documents identifhd in response i ls (i) to (b) above will be offered into evidence by Anolicants, and (ii)

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v which of the same documents Apolicants expect to offer into evidence a

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- or intend to offer as evidence or exhibits in this proceeding.

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Mb/bfSPe$$C (hWNESNE Where the above general interrogatories, or any of then, '

I s i g call for identification of documents, (1) and no documents are i s., sq identified, is that the sane as Apnlicants stating that there i

. . are no documents resconsive to this general interrogatory, in each l ss;' '

case where no documents are identifiad? (ii) and documents a_re identified, is that the sane as Auplicants stating that the identified -

documents are the only cnes presently known which are responsive to the interrogatories? (iii) If your answer to G-10(a)(ii) is other than affirmative, please state all reasons for your answer.

(iv) If your answer to G-10(a)(1) above is other than affirmative, please state all reasons for your answer.

(b) Where any interrogatory, general or specific, herein, calls for factual information (i) and an opinion is stated in response, is that the expert opinion of any person (s) identified as having contributed information to that responce? (ii) and facts are given or identified (or a fact is) in resnonse, but no documents are identified, does that mean Applicants have no documents containing such fact (s)?

(iii) If your answer to (i) above is affirmative, please state for each '

each such response all qualifications of expert unon whom

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s E Applicants rely for each such answer. The qualifications need be stated o'nly once for each such person if they are clearly referenced in other answers. (iv) if your answer to (1) above is other than affirmative, please state which oninions, if any, E i ven in response tc interrogatories (general or snecific) herein is the opinion of an expert, identify each expert whose oninion you used in response to each $nterrogatory, and state in full the qualifications of each such expert. (v) If your answer to (1) above is other than affirmative, please 'Jentify all opinions of non-experts used in your resconses, and identify each non-expert whose opinion is included in each answer herein.

(vi) If your response to (ii) obove is other than affirmative, please identify each document which contains a fact not previously documented in your resnonse(s), statinF what the fact !s, and at what page, place, chapter or other specific nart the document contains such fact.

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G-11 For each answer to each interrogatory herein (or any l subpart or part thereof), please identify each item of information j in possession of Applicants (including facts, opinions of experts, and documents) which (a) contradicts the answer you made, (1) l in whole (ii) in part (please identify each such part for each item of information identified); (b) casts doubt on your answer (i) in whole (ii) in part (please identify each auch part for l t

each item of information identified). (c) Please identify all documonts not already identified in response to parts (a) and (b)  !

t above (and their subpa"ts) which contains any item of information  !

I asked for in (a) or (b) above. Please identify for each suen  !

document what information item (s) it contains and what angwerp)  :

i each such item is'related to. '

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SPECIFIC INTERROGATORIES. "You" means (to Staff / FEMA) NRC Staff cr FEMA or any gerson answering these interrogatories for FEMA or NRC i Staff. 'You means, to Applicants, Applicants or the State of NC  :

or the : NC D,pt of Crime Control and Public Safety, or appropriate county or state emergency response planners or personnel, e.g. those  ;

supplying answers to these interrogatories or having knowledge  :

of the matters inquired about.

57-C-3-1(a) Do you know of any provisions for nighttime notification of residents or transients (i) within the EPZ (ii) who are asleep  !

(iii) who are in boats or houseboats or other ' craft on either (iii-a) Jordan Lake, or (iii-b) the Harris plant lake?  !

(b) What are these provisions? Please identify all documents  ;

i containing such provisions and state which such documents are J part of the emergency response plan (offsite) for Shearon Harris. ,

If any such document is part of another emergency response plan,  ;

l e.g. Harris on-site plan or other state our county emergency response plan or contingency plan, please identify that plan also, L for each such document, i l (c) What provisions, if any, are in the brochure to be sent to 1 EPZ vesidents, concerning action to take if a nuclear accident l offurs at night? (d) what provisions among these ccncern sheltering, i turning off amir conditioners or air-to-air heat exchangers, or i

' closing a windows? ea l of the above items itPlease identify to. (e)ch Dosuch you provision andplans which l relates know of any  :

for telschone notification of (i) residents of the EPZ (ii) transients  !

in motels, hotels or other lodging in the EPZ, for accidents at {

the Harris nuclear plants? If so, niease identify each such plan l and all documents concerning it. (f) Have you ever considered  ;

telephone notification of persons within the EPZ in the event of  !

l a nuclear accident? If so, please identify all documents concerning your consideration of this matter.

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57-C-3-2(a) Are automatic telephone dialing systems available to (i) CP&L (ii) the State of NC (iii) Wake County (iv) Chathan County (v) Harnett County (vi) Lee County (vii) other authorities who j would nuclearbeaccident involvedatinHarris?

ordering b) (sheltering What areinthe thecanabilities event of anof i i

the automatic telephone dialing systems available to each such  ;

organization? Please include in your answer (i) number of numbers i dialed per hour (ii) ability to dial a preprogrammed set of numbers  !

(iii) ability to have input a set of numbers to dial (iv) ability  !

to automatically dial back if the phone is hung up before a message '

is completed (v) length of message the system can deliver (vi) i

' audio quality- of message the system can deliver (vii) capacity  ;

. OF Telephone lines (e.g. number of lines) the system requires, (viii) other technical requirements of the system, e. (

supply, actuation, reset if errors in dialing occur (g.ix)for power whether

! the system can function with a backup power supply if electrical l power. to it is lost, and whether such backup power supply is in i fact provided for it.

automatic telephone dialin (c) Please detail the capabilities of any  !

for use (ii) plan to buy (g system iii) knowwhich you have is available for(i) considered purchase. '

i 213-1(a) What is the snecific resnonsibility of (i) CP&L (ii) the State of NC (iii) Wake County (iv) any other authority or I agency you know of, for notifying boaters, swimmers or others (

on or in the Harri,s plant lake in the: event of a nuclear accident l at Harris? (b) Please list every means by which you will ca*ry out such notification, and state which doctment(s) detail these i means, your authority or ability to use daem, and what personnel are required to operate these means (number of persons, where '

they work, who will notify them, how lo g they will take to begin onerating the means of notification. (c) Please state how long  :

each means of notification will take to notify all versons on l or in the Harris lake, and for each means, what backup means  ;

of notification will be used if there is a failure of the first means.  :

Please also describe the provisions for sheltering or efacuation which will be announced to persons on or in the Harris lake.!i j

' (d) What means, if any, are provided for vergifying that persons  ;

on the Harris lake have been notified Who operates each such means? Who is resnonsible for each such of an accidedt at Harris? i means being used? Who will receive the reports of such verification? l l

How will each suda person receive each such report?  ;

213-2(a) In what respects do provisions for notification of  !

persons (i) on (ii) in (iii) on the shores of, the Harris platt  !

lake, differ from provisions for notification of nersons in or on '

i corresponding parts or areas near Jordan lake? (This means for j l

notification of an accident at the Harris plant.) (b) For each -

l such difference in provisions, do you have any reason for the  !

i difference? If so, please state in what documents your reason, I or reasonging, for having this difference in notification provisioce (

for the Harris and Jordan lake areas, is. (c) Please explain  ?

l any modifications to be made in notification nrovisions for the l people in, on or around the Harris lake by (i) Wake County (ii)

CP&L (iii) other emergency planners, including the State of NC. ,

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57-c-10-1(a) What study, if any, have you made of sheltering l effectiveness for shelters typical of those available within I the Harris EFE7 (b) Please identify all docunents in which l you make such study, or any analysis of sheltering effectivenssa  :

for such shelters. (c) What study, if any, do you plan to make '

of sheltering effectiveness for shelters typical of those to I be available near Harris? When will each such study be completed? l Who is doing each such study? What are the$ r qualifications to do it? l Who will receive the results of each such s v',7 (d) Does any study referred to in your rest ses to (b) or (c) above establish sheltering effectiveness for (1) houses without basements (ii) brick houses without basements (iii) cinder block basaments (iv) brink-walled basements (v) basements above ground level (vi) basements sunk partly below k ground level (vii) motels or individual motel rooms (viii) restaurants (ix) public buildings (x) farm buildings (xi) storm cellars (xii) wooden houses (xiii) solar or pascive solar houses (xiv) any structures, in terms of I typical numbers of air changes per hour (xv) any structures, )'

in terms of measured numbers of air changes per hour (xvi) any structures, by relying on typical characteristics of such '

structures? (e) Please identify all documents containing data on the sheltering effectiveness, or measurements of air changes, or characteristics of shelters, which you have used or will used ,

in addressing the effectiveness of sheltering for typic'al structures i around the Harris plant. (f) Please explain yourmethod for assessing i

sheltering effectiveness for homes, etc. , in the Harris EPZ~.

57-C-10-2(a) effectivenessHave for any you (i) made any determination school (ii) day careofenter sheltering)

(iii church or other house of worship (iv) other strta aremman open to the public or used by more than 10 persons (other than homes i or apartments)? (b) Was your determination of shelterin I

. effectiveness made (i) for a typical such structure (ii)gfor '

a specific structure (please identify) (iii) by any other method?

(c)Please explain, identifying all documents used for data or assumptions, and identifying all calculations and methods used, how you determinted the sheltering effectiveness for each typh  !

of structure inquired about in part (a) above.

57 ':-10-3(a) Please identify all documents, methodologies, data, equations, calculations or other information you have used, or plan to use, in calculating or determining sheltering l effectiveness for structures within the Harris EPZ. (b) Please e identify all documents containing such information. (c) Please identify all documents you possess which describe methods of j figuring, calculating, or assessing sheltering effectiveness. i (d) Please state why you have adopted or used any methods, data j or calculations of sheltering effectiveness which you have used I with respect to structures near Harris or in its EPZ~. (e) Please '

state and describe in as much detail as you know, what kinds of structures you consider " typical" of those avstah available for sheltering in the Harris EDZ. Please identify all documents or information and all opinions you rely on in consider 1r.g eacb type l or structure typical. How many tynes of structures have you '

assessed sheltering effectiveness for within the Harris EPZ? j 57-c-10-4(a) Do you nossess any information on the (1) number I (ii) types (iii) number of persons in (iv) times of day persons  ;

are in, structures in the Harris EPKZ? (b) Did you consider j i

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57-c-10-4(b) continuad medical or dental offices stores, schools, farm buildings, theaters,3 public buildings,) motels ,

day care centers, or other buildings in collecting data on types of shelter available in the Harris EPZ? (c) If so, what data do you have on each type of building inquired about in (b) above. tdi 2Axymaxdidmamtmmmunidamxanaxaxmammaxminthx (di For each type of building listed in fS) above that you haave no data on or did not ama consider, please tell why you (i) have no data on, or (ii) did not consider, that type of building.

(e) among the types of structures inquired about in this interrogatory 57-c-lo-A, what structurnal characteristics, air-change characteristic >

or ether characteristics do you think are anpropriate to consider to determine sheltering effectiveness for each such type?

, (f) Please identify all documents in which data, determinations or information concerning the matters inquired about in (a) thru (e) and all subparts, inclusive, above, are contained.

57-c-13-1(a) Have you made any determination of the best Protection Factor-(PF) available in any (i) hospital 'ii) nursing home within the Harris EPEZT (b) If so, how did you make that determinatioi Was an on-site survey conducted? How did you get your data about onaracteristics of the structure? Did you consider any data about air infiltration into the structure? Please identify all documents concerning each determination of PF you have nade for any school or hospital within the Harris EPZ and how that PF was determined.

(c) Have dae ' data ~used in your PF determination been checked by anyone? If so, by who and when? Please identify all documents concerning checking of such data. (d) How many people can fit into the trea with the best PF in each (i) hospital (ii) nursing home, in the Harris EPZ? (e) What provisions for patient characteristics (e.g. ambulatory, non-ambulatory, need for special medical supplies, need for nursing access, sensitivity to heat, to cold, or to reduced oxygen and/or stuffy conditions in a closed area) were included in your determination or estimate of.how uny people wil1%itxinks fit into the area of best PF in each specifio (i) hospital (ii) nursing home, in the Harris EPZ?

i (f)What is the maximum capacity of each (i) hospital (ii) nursing home within the Harris EPZ? (g) What food supplies would be available int the area of highest protection factor in each (i) hospital (ii) nursing home, within the Harris EPES, in the event of a long-term sheltering being required? What water supplies would be available in the highest PF area within each such hospital or nursing home?

(g) If all the people in the hosnital or nursing home can't ri fit into the highest PF area, what is the PF of the next-highest PF area within such hospital or nursing home? How many neople can this next-highest PF area hold? What regard of medical conditions ofr needs of persons to be sheltered in this area was taken in your determination or x estimate of how many psoule would fit into this area?

57-c-13-2(a) Are there any means of increasing PF for hospital or. nursing home areas within the Harris EPZ that you have (i) considered (ii) recommended to the operators or owners of those hospitals or nursing homes? (Mb) are there any care facilities widhin the Harris EPZ which care for adults but which you define as being neither a hospital nor a nursing home? Please identify each such facility and state why you believe it is not included within the term "hosnital or nursing home."

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30-1(s) Has any determination of the quantity of potassium iodide (KI) l

.to be kept at any location (e.g. county health department) for use l as a radioprotective drug in an emergency at the Harris plant i been made? (b) How, if at all, does each such determination take inte account the " shelf life" of the KI? (c) Who made each such determination? (d) How was each such determination made? (e) Please f identify each document concerning each such determination, and also L all documents containing information used in making each such determination. (f) Please state what information, from what r specific source (page reference please) was used in making each such determination. (g) How many persons are to be provided with >

KI from each location during an emergency? Please state the  ;

numbers of emergency workers, the nunbar of persons not mobile  ;

(e.g. in nursing homes), and numbers of other persons for whom l KI is .to be provided from each location where KI is stored 6 for ,

use in an radiological emergency at Shearon Harris nuclear plant. l (h) Are there any reserve supplies of KI available within the i Harris EPZ for use in an emergency? If so, who determines where  ;

these reserve supplies are and how much is in each location?  !

(1) what dose (s) are provided per person in the KI stored for  !

use in a radiological emergency at Harris? If no KI is now stored (

for this purpose, what donse(s) are planned to be provided ner person?  ;

30-2(a) If quantities of KI for use during a radiologichl emergenycy i at Harris have not been determined yet, when is such determinat!on i to be made? Pleas.e ex in 30-1(b) through (i) plain howwill each of the matters asked about above be addressed in such determination.  !

(b) Please state who is making the determination of KI quantities i which is going to be made. (c) Please state who will make each  !

such determination and whether each such determination will be included in the Harris emergency response plan. (d) Please identify all points int the Harris emergency response plans where specific -

quantities of KI or other radioprotective drugs are mentf oned. j 224-1(a) What analysis of the frequency of weather events, includigng fog, ice, snow, rain, heavy rain, hail or other advaerse weather, have you made for the Harris EPAZ? (b) Whrt information .

do you have on the frequency (both (i) typical, and (ii) maximum  !

in any recorded data) of (an) fog (bb) ice (cc) nam snow (dd) rain  !

(ee) " heavy rain" (ff) hail (gg) rain above 1 inch per hour (hh)  :

rain above 3 inches per hour, in or around the Harris EPZ oir in I sreas believed to be similar in meteorology to the Harris EPZ?  :

Please identify all documents containing such information. l (c) Do you have any other a information concerning frequency of  :

adverse weather in the Harris EPZ or in areas of sim31ar meteorology?

If so , please identify all such other information and all docu$ents containing it. ,

224-2(a) Please state what sensitivity analysis for frequenev  !

of adverse weather was included in the Harris evacuation time estimates. (b) If you reviewed the Harris evacuation time estinates, j what analysis, if any, did you make of the sensitivity of such j time estimates to the frequency of adverse weather? Please identify i all documents concerning (i) 7our analysis of the Harris evacuation i time estimates (ii) sensitivity of such estimates to adverse weather l conditions (iii) sensitivitt of evacuation time estir_stes to  :

the frequency of adverse weather donditions. (c) Please state wha't i further analysis of adverse weather frequency and its effect on Harris l evacuation time estimates you plan to make, and when it will be done.  ;

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..j w f i 215-1(a) How do recre4tional populations at (1) Jordan Lake (ii)

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the Harris niant lake (lii) other recreation sites within the Harris !

EPZ, vary with (aa) time of day (bb) day of week (ce) season of year?

Please provide what data you have on variation of recreational l

. populations in each recreational area in the EPZ, including numbers of; overni@at users of each.*Mstt aram (b) What data provided in  ;

response to (a) is based on actual observation? (c) What basis  ;

do you have a for estimates of recreational populations near i Harris at various times of the day, week and year, other than j observation? How realistic is such basis in your view? Do i you know methods to check the realism of such estimates? What ,

are such methods? Are you doing any checking of the realism ,

of such estimates? If so, how? Do you plan to check the  !

realism of estimates of recreational populations in the Harris EPZ before the plant operates? Before the evacuation plan is tested?

(c) What data do you have on vehicle occupancy rates in the Harris  ;

EPAZ (i) at any time or times (ii) in the early morning, e.g. 6-9 am i (iii) in the early evening, e.g. 5-7 pm (iv) between = 11am and 1 pm l or in that range (v) after 7pm but before midnight? Ba (d) .

Do any of your data 'on vehicle occupancy rates in the Harris EFZ vary by day of week or season or date in the year? If so, how  ;

does each vary? (e) Please identify all documents concern $ng actual occupancy rates of vehicles in the Harris EPZ which you  !

(i) possess (i.1) know of.(f) Please identify all documents j concerning recreational nonulations in the Harris EPZ or how j theses populations' . vary at varying ti'mes. (g) Please identify l I all documents concerning estination of (i) vehicle occupancy [

rates (ii) recre4tional ponulations, in the Harris EPZ, or zu basis  :

for such estimates, or~ data used in such estimates. l 215-2(a) Please state if you know what numbers or percentage of l the Harris 5 EPZ population is at hene (i) with transportation i at home (ii) without transportation at home, at varying hours  !

of the day or year or at any time (s) (please specify times for i which you have sudh information. (b) Please state what investigation I or analysis.or data collection you (1) have made (ii) will make  ;

(iii) are making concerning numbers of nersons in the Harris EP7  !

who are at home at any time or times of the day or year.  ;

215-3(a)Do you know how many vehicles are available to each i household within the Harris EPZ (i) as owned or rented vehicles i (ii) at any time of the day, e.g. during work or school hours

,(iii) located at or near the home of each household, at any -

time or times of the day or year? (b) Please detail all data  ;

y you have on the numbers of vehicles available to each household i L in the Harris EPZ at any snecific times. (c) Please detail all j

' data, information or documents as to the number of vehicles each .

hounsehold (or a typical household) in the Harris EPZ will use i

! to evacuate in the event of a nuclear accident at Harris.

! 215-4(a) Have you made any study of how many persons would evacuate  :

from a location other than their home(s) within the EPZ in the i event of an accident at the Harris nuclear plant?(MHave you studied i l where people would actually avacuate from under daytine or evening l l conditions from the Harris MPZ at any date or season of the year?  !

(c) Please identify all documents concerning such study or studies. l l

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-[- j 215-5(a) Have you determined dae distance from each (or any of the)  !

non-car-ownig household (s) in the Harris ETZ to each's nearest i neighbor? (b) Have you determined how many non-car-sowning households  :

have telephones over which they might ask neighbors for rides in the event of an accident at Harris? (c)Do you know how many i persons would evacuate from car-owning households near the non-car-owning households? (d) Do you know how many of such car-owning l

neighbors of non-car-owning households would have extra space r to carry members of the households without transnortation? (e) l Why have the evacuation time estimates assumed that one car  !

will be added per family of nason-vehi, ele-owning evacuees in

, an accident at the Harris plant? (f) Have you made any analysis .

of the Harris evacuation time estimates' treatment of the number I of vehicles evacuating as it is affected by the numbers of vehicles (

assumed or estimated to be evacuating persons without transnortation? l

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(g) Please identify all documents concerning any such analysia.  !

(h) Please state whether persons without transportation includes L those who do not have their own transnortation readily available, or only those who do not own cars.  ;

i 2165-6(a) Please identify any information underlying the Harris [

evacuation time estimates, or any other information available to you,  !

which concerns the number of vehicles per evacuating person  !

or per family which would be required to evacuate the Harris EPZ under realistic conditions. (b) Please identify th'e realistic l conditions and the documents containing all such information.

(c) Have you compared the number of vehicles used in the evacuation  !

, time estimates to the number of vehicles pas considered to be l actually evacuating under realistic co.nditions for any evacuation condition or scenario? If so, state for which condition or scenario, and please -identity the results of your comnarison and all documents  ;

containing such results or information on which such results were  !

based, i c .

215-7(a) Have you performed, or do you know of, any reanalysis [

of the computer runs makde for the Harris evacuation time  ;

estimates, incorporating any less conservative assumptions l (or more realistic assumptions) concerning numbers of vehicles  ;

to be evacuated, population of recreation-area users to be evacuated, or other matters contained in Contention ?15 as initially admitted .

or as revissed? Please identify all documents containing such  ;

reanalysis, and state the evacuation times given by each such  ;

reanalysis. .

215-8(a) Do you know of any data showing the actual traffic loadings on each road segment during evacuation from a Harris accident  ;

(1) as computed in any evacuation time i estimate comeuter run  !

(ii) as determined in any odner conputer run (iii) as determined i in any other manner?(hPor each d part of (a) above for which your l

- answer is affirmative niease identify all documents containing j such data, and state what assumptions or data about ponulation ,

.and vehicles evacnating, road conditions, or other variables j l were used in deriving such data or naking such computer run. l 215-9(a)De you have any information as to the amount of time l required for evacuating the Harris EPMZ under conditions less conservative daan those snecified in the Harris evacuation time estimates? If so, what information do you possess or know of 9  !

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215-9 continued (b) Please identify all assumptions that were made in deriving the time required (or effect on time required) to evacuate the  !

Harris EPZ, for any information identified in response to (a)  :

above. (c) Please identify all documents cohtaining information about less conservative evacuation tine estimates for the Harris EEPZ you are aware of. (d) Who made estinates of Harris EDZ

! evacuation time, other than CP&L's contractor?

Pit 0 DUCTION OF DOCUMENTS Wells Fddleman hereby requests the persons these interrogatories are addressed to, whether FEMA /NRC Staff, or CP&L and NC State and County government emergency response versonnel or planners, to make available for inspection and copying the original or best copy of each docament identified in response to any of the above interrogatories.

29 June 1984 8 @lfst Wells Eddleman e

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