ML20093B244
| ML20093B244 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/05/1984 |
| From: | Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | EDDLEMAN, W. |
| References | |
| CON-#484-317 OL, NUDOCS 8410090489 | |
| Download: ML20093B244 (12) | |
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RELATED C0gnETCNDW Og, 7gg October 5, 1984
'84 CCT -9 pio;5g UNITED STATES OF AMERICA ffDCf r e c e% y...
NUCLEAR REGULATORY COMMISSION t Miig( -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD C #' k' In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
AND NORTH CAROLINA EASTERN
)
Docket No. 50-400 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant)
)
APPLICANTS' EMERGENCY PLANNING INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR WELLS EDDLEMAN (SECOND SET)
Pursuant to 10 C.F.R. SS 2.74Cb and 2.741 and to the Atom-ic Safety and Licensing Board's " Final Set of Rulings on Admis-sibility of Offsite Emergency Planning Contentions, Ruling on Petition For Waiver of Need for Power Rule, and Notice of Upcoming Telephone Conference Call" (August 3, 1984), Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Wells Eddleman an-swer separately and fully in writing, and under oath or affir-mation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the responses to interrogatories below.
Answers or objections to these interrogatories and re-sponses or objections to the request for production of documents must be served no later than October 24, 1984.
8410090489 841005 PDR ADOCK 05000400 0
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i-These interrogatories are intended to be continuing in na-
.ture, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. 5 2.740(e),.
should Mr. Eddleman or any individual acting on his behalf ob-tain any_new or differing information responsive to these in-terrogatories.
The' request-for production of documents is also continuing in nature and Mr. Eddleman must produce immediately any additional documents he, or any individual acting on his behalf, obtains which are responsive to the request, in accor-dance with the provisions of 10 C.F.R. 5 2.*/40(e).
Where identification of a document is requested, briefly describe the document (e.g.,
book, letter, memorandum, tran-script, report, handwritten notes, test data) and provide the following information as applicable:
document name, title, number, author, date of publication and publisher, cddressee, date written or approved, and the name and address of the per-son or persons having possession of the document.
Also state the portion or portions of the document (whether section(s),
chapter (s), or page(s)) upon which you rely.
Definitions.
As used hereinafter, the following defini-tions shall apply:
" Applicants" is intended to encompass Carolina Power &
Light Company, North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.
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~ "Offsite emergency plans" refers to the " North Carolina Emergency Response Plan In Support of The Shearon Harris Nuclear Power Plant," Parts 1-5.
" Document (s)" means all writings and records of every type in_the possession, control or custody of Mr. Eddleman or any individual acting on his behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts,. books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice record-ings and all other writings or recordings of any kind; "docu-L ment (s)" shall also mean copies of documents even though the l
originals thereof are not in the possession, custody, or con-l trol of Mr. Eddleman; a document shall be deemed to be within l
l the " control" of Mr. Eddleman or any individual acting on his behalf if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the docu-ment or copy thereof, from any person or public or private en-tity having physical possession thereof.
General Interrogatories 1(a).
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the facts alleged, and upon which you relied in formulating allegations, in each of your conten-tions which are the subject of this set of interrogatories.
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(b).
Identify those facts concerning which each such person has first-hand knowledge.
(c).
State the specific allegation in each contention which you contend such facts support.
2(a).
State the name, present or last known address, and present or last employer of each person, other than affient, who provided information upon which you relied in answering each interrogatory herein.
(b).
Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained.
3(a).
State the name, address, title, employer and l
edeuational and professional qualifications of each person you l
intend to call as an expert witness or a witness relating to i
any contention which is the subject of this set of interrogato-ries.
(b).
Identify the contention (s) regarding which each such person is expected to testify.
(c).
State the subject matter as to which each such per-son is expected to testify.
4(a).
Identify all documents in your possession, custody 1
or control, including all relevant page citations, pertaining to the subject matter of, and upon which you relied in formu-lating allegations in each contention which is the subject of this set of interrogatories.
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(b).
Identify the contention (s) to which each such docu-ment relates.
(c).
State the specific allegation in each contention which you contend each document supports.
5(a).
Identify all documents in your possession, custody or control, including all relevant page citations, upon which you relied in answering each interrogatory herein.
(b).
Identify the specific interrogatory response (s) to which each such document relates.
6(a).
Identify any other source of information, not pre-viously identified in response to Interrogatory 2 or 5, which-was used in answering the interrogatories set forth herein.
(b).
Identify the specific interrogatory response (s) to which each such source of information relates.
7(a).
Identify all documents which you intend to offer as exhibits during this proceeding to support the contentions which are the subject of this set of interrogatories or which you intend to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff and/or the Federal Emergency Management Agency (" FEMA") Staff on each contention which is the subject of this set of interrogatories.
(b).
Identify the contention (s) to which each document relates and the particular page citations applicable to each contention. I e
i
Interrogatories on Eddleman 57-C-7 57-C-7-1(a).
For each of the hospitals listed in Part 1, pages 68 through 70 of the North Carolina Emergency Response Plan-(" State Plan"), please state which ones, if any, you be-lieve or contend are not prepared to treat severe radiation ex-posure.
(b).
For each of those hospitals identified by you in Answer (a) above, please provide.all facts which support i
your belief or contention that the hospital is not prepared to treat severe radiation expocure.
(c).
For each of the hospitals listed in Part 1, pages 68 through 70 of the State Plan, which you have not iden-tified in response to (a) above, please state how your failure i
i to identify those hospitals as ones unprepared to treat severe i
l radiation exposure is consistent with Contention 57-C-7.
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57-C-7-2(a).
Do you consider the " local and regional" I
hospitals to which you refer in the second sentence of Conten-I tion 57-C-7 to be in addition to the hospitals already listed in Part 1, pages 68 through 70 of the State Plan?
(b).
If the answer to part (a) of this interroga-tory is affirmative, list individually each of the local and regional hospitals cutside of those referred to in Part 1, pages 68 through 70 which you contend Applicants should evalu-ate to determine its capability to provide medical services for those seriously injured by radiation.,
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.(c).
For each of the hospitals listed by you in, response.to (b)_above,-explain why Applicants should perform an
-evaluation of that hospital and why it is necessary to'be in-cluded in the State. Plan.
Your answer should include a desig-nation of which -hospitals you consider " local and which you consider " regional" and an explanation thereof.
57-C-7-3(a).
Please describe in detail any and all changes which you believe must be made in the State Plan to meet the concern expressed in Eddleman 57-C-7.
(b).
Please describe in detail the bases.for your belief'that such changes must be made.
57-C-7-4(a).
Please describe in detail any and all ac-tions or changes (other than those described in your response to Interrogatory 57-C-7-3(a)) which you believe are necessary to meet the concern expressed in Eddleman 57-C-7.
(b).
Please describe in detail the bases for your belief that such actions or changes are necessary.
Interrogatories _on Eddleman 213-a 213-a-1(a).
For er's ar of the offsite emergency re-sponse plan, state which specii;c section or' sections you be-lieve or contend require implementing procedures.
(b).
For each of the sections of the offsite emer-gency response plan identified in your answer to (a) above, please state why you believe implementing procedures are needed.,
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(c)..
For eachLsection of the offsite emergency're-
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-_sponse;planLidentified in (a), please summarize-the substance of.the implementing procedures you believe are needed.
Your answer sh'ould include, but not be limited to, the consideration you gave to the amount of detail already in that section of the plan.
213-a-2(a).
Please describe.in detail any and all changes which you believe must~be made in-the offsite emergency re-sponse plan to meet the concern expressed in Eddleman 213-a.
(b).
Please describe in detail the bases for your belief that such changes must be made.
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213-a-3(a).
Please describe in detail any and all actions or changes (other than those described in your response to Interrogatory 213-a-4(a)) which you believe are necessary to meet the concern expressed in Eddleman 213-a.
(b).
Please describe in detail the bases for your belief that such actions or changes are necessary.
Interrogatories on Eddleman 240 240-1(a).
Describe any and all-changes you believe must be made in the offsite emergency plan to meet the concerns ex-pressed in Eddleman Contention 240.
(b).. Describe in detail the bases for your belief that>such changes must be made.
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i-240-2(a).
Describe any and all' actions you believe must be taken, or changes you believe must be made (other than those identified in the. answer to Interrogatory 240-1 above),-to meet the concerns expressed in Eddleman Contention 240.
-(b).
Describe in detail the bases for your belief that such actions must be taken and such changes made.
Request For Production-Of Documents Applicants request that Intervenor Wells Eddleman respond in writing to this request for production of documents and pro-duce the original or best copy of each of the documents identi-fied or described in the answers to-each of.the above interrog-atories, at a place mutually convenient to the parties.
Respectfully submitted, ThromAs A.
Baxter,'P.O.
1 Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Richard E.
Jones Samantha-Francis Flynn Dale Hollar Hill Carrow CAROLINA POWER & LIGHT COMPANY P.O.
Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated:
October 5, 1984.....
F; UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
-In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
and NORTH CAROLINA EASTERN
)
Docket No. 50-400 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Emergency Planning Interrogatories and Request For Production of Docu-ments To Intervenor Wells Eddleman (Second Set)" were served this 5th day of Octotar, 1984, by deposit in the'U.S. mail, first class, postage prepaid, upon the parties listed on the attached Service List.
JAHIL
- CLhd, Delissa A. Midgkap)
G Dated:
October 5, 1984 i
l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the-Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
and NORTH CAROLINA EASTERN
)
Docket No. 50-400 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant)
)
SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of U.S. Nuclear Regulatory Commission North Carolina Washington, D.C.
20555 307 Granville Road Chapel Hill, North Carolina Mr. Glenn O.
Bright 2758 4
Atomic Safety and Licensing Board M. Travis Payne, Esquire U.S. Nuclear Regulatory Commission Edelstein and Payne Washington, D.C.
20555 Post Office Box 12607 Raleigh, North Carolina 27605 Dr. James H. Carpenter Atomic Safety and Licensing Board Dr. Richard D. Wilson i
U.S. Nuclear Regulatory Commission 729 Hunter Street i
Washington, D.C.
20555 Apex, North Carolina 27502 Charles A.
Barth, Esquire Mr. Wells Eddleman Janice E.
Moore, Esquire 718-A Iredell Street Office of Executive Legal Director Durham, North Carolina 27705 l'
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Richard E.
Jones, Esquire Vice President and Senior Counse8 Docketing and Service Section Carolina Power & Light Company Office of the Secretary Post Office Box 1551 U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Washington, D.C.
20555 Mr. Daniel F. Read, President CHANGE' Post Offic? Box 2151 i
Raleigh, North Carolina 27602 m
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l Dr. Linda W.-Little Governor's Waste Management Board 513 Albemarle Building 325 North Salisbury Street Raleigh,JNorth Carolina' 27611 Bradley W. Jones, Esquire U.S. Nuclear Regulatory Comraiss'in Region II 101 Marietta Street Atlanta, Georgia 30303
. Steven F.
Crockett, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC Post Office Box 991 Raleigh,' North Carolina 27602 Administrative Judge Harry Foreman Box 395 Mayo University of Minnesota Minneapolis, Minnesota 55455 Spence W.
Perry, Esquire Associate General Counsel FEMA 500 C Street, S.W.,
Suite 480 Washington, D.C.
20740 i
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