ML20093D598

Emergency Planning Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20093D598
Person / Time
Site:	Harris
Issue date:	10/08/1984
From:	Read D CHAPEL HILL ANTI-NUCLEAR GROUP EFFORT
To:	CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES
References
CON-#484-407 OL, NUDOCS 8410110305
Download: ML20093D598 (6)

Text

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C00 METER UNITED STATES OF AMERICA :W:

NUCLEAR REGULATORY COMMISSION 84 OCT 10 All:29 ji -

BEFORE THEGlenn ATOMIC SAFETY O. Bright AND LICENSING BMNC BOARD [ok

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Irr. James H. Carpenter James L. Kelley, Chairman In the Matter of

) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 and 2) 8 October 1964 l

EMERGENCY PLAlWING INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS

'IO APPLICANTS Pursuant to 10 C.F.R. 2.740 et sea, and the orders of the Board (particularly that of 3 August 1984), CHANGE hereby requests that Carolina Powcr & Light Company and North Carol-ina Eastern Municipal Power Agency (hereinafter " Applicants")

answer separately, fully, and in writing, and under oath or affir-mation, each of the following interrogatories, and produce and permit inspection and copying of all documents identified in the responses to said interrogatories. Answers or objections, to these interrogatories and responses or objections to the request for production of documents must be served no later

' than 29 October 1984. These interrogatories and the request for

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production of documents 'are intended to be continuing in nature and answers should be promptly supplemented or amended, or additional documents immediately produced, as appropriate, should Applicants or their agents obtain new or differing information or responsive documents, as provided by 10.C.F.R.

2.740.

8410110305 841008 l- PDR ADOCK 05000400

G PDR D

Page GENERAL INTERROGATORIES Responses to these general interrogatories shal'1 be given

-for each contention, along with the responses to each specific interrogatory.

(1) State the name, present or last known address, and present

-or last known employer of each person known to Applicants to have first-hand knowledge on which the responses are based, for each of the contentions which are the subject of this set of in-terrogatories.

(2) Identify those facts concerning which each such person has first-hand knowledge.

(3) State the specific basis or facts which support each respon=e.

To the extent that Applicants rely solely upon documents for their response (s), please indicate the documents by their title, date, author, and location. Please identify also relevant page citations.

(4) State the name, present or last known address, and present

or last known employer of each person who provided information i

upon which Applicants relied in answering each interrogatory ,

herein.

(5) Identify all such information which was supplied by each such person and the specific interrogatory response in which such information is contained.

(6) State the name, address, title, employer, and educational and

. professional qualifications of each person Applicants intend to call as an expert witness or as a witness relating to any conten-tion which is the subject of this set of interrog' atories.

(7) Identify the contention (s) regarding which each person ident-ified in interrogatory (6) is expected to testify, and the subject

page b matter as to which each such witness is expected to testify.

(8) Identify all documents in Applicants' possession, custody

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or control, including all relevent page citations, pertaining to the subject matter of, and upon which the Applicants relied in formulating responses to, each contention which is the subject of this set of. interrogatories.

(9) State the specific response to each contention or interroga-tory which Applicants contend each document supports.

(10) Identify all documents in Applicants' possession, custody, or control, including all relevant page citations, upon which Applicants relied in answering each interrogatory herein.

(11) Identify all other sources of information, not identified in responses to General Interrogatories 5, 8, and 11 herein, which were used in answering each interrogatory herein.

(12) Identify all documents which Applicants intend to offer as exh'ibits during this proceed'ing to refute contentions which are the subject of this set of interrogatories.

, DEFINITIONS As used herein,- the word " study" or " studies" shall not mean only documents titled as such, but it means such documents and other documents or activities involving critical examination ard investigation of a subject, see New World Dictionary of the American Lancuare, 2d College Edition,1974.

" Applicants" means Carolina Power & Light Co. , N.C. Eastern Municipal Power Agency, their contractors, agents, designees, or other persons acting in their behalf.

Page 4 SPECIFIC INTERROGATORIES EPJ-1-1. Identify all studies or examinations of snow and ice conditions in the area around the Shearon Harris plant Appli-cants have conducted or considered in in assessing the effect of inclement weather on the plant, evacuation times, traffic around the plant, shutdown analyses, or shift changes.

EPJ-1-2. Identify any data compilations Applicants have considered in assessing'or predicting the effect of inclement weather on any of the activities / subjects described in EPJ-1-1.

EPJ 1-3. Identify all snow, ice, or other removal equipment

, (a) at the plant site, (b) within one mile of the plant, (c) upon which Applicants rely to keep roads to the plant open under

.non-accident conditions.

.EPJ-1 4. How do Applicants understand " severe maow and ice conditions" as stated in the contention?

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reports publications, or EPJ-2-1. Identify all studies or other/ data known to Appli-cants which provide inf6rmation or guidance on problems of identifying, notifying, and providing transportation f or people without cars in accident or disaster situations.

EPJ-2-2. Identify all studies or examinations of the number and location of people without cars Applicants have undertaken or are aware of with respect to evacuation form the area around the Harris plant in an emergency.

EPJ 4-1. Have Applicants undertaken to identify school bus

. drivers 18 years of age or younger? If the answ er is other than "no", please produce results of any such efforts. (For this and all other questions relevent to EPJ 4, the questions refer to the 10-mile EPZ area unless otherwise specified).

EPJ 4-2. Identify all studies or other evaluations Applicants have made concerning the necessity for school buses to make more than one trip during normal and emergency conditions.

Page 5 EPJ 4-3. Identify all provisions Applicants have made, or are aware have been made, for the availability of extra buses 1 - to transport school children in an emergency situation, (a) including accidents at the Harris plant and (b) including other disasters, emergencies, acts of war, or of God.

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-EPJ 4 4. Identify all' provisions, other than the A Emergency Preparedness' Brochure, Applicants have made, or are aware of, to notify parents of school age children that they.should

.not pick up their children at schools in -the event of an evac-uation. Identify all provisions made, by Applicants or others, to ensure that parents of school age children will not pick up their children at school in the event of an evacuation.

EPJ 4-5.-Identify all studies Anplicants ela, a\

have made, used, or are aware of which deal with the problem of parents picking 3

up school children in an evacuation situation or other similar emergency situation, parental EPJ 4 6. Identify any/ authorization currently required for bus drivers under age 18 to operate school buses in the event of an emergency.

Reauest for Documents CHANGE-requests that Applicants produce the original or best available copy of each document identified in the responses the foregoing general and specific interrogatories at a mut-

^ ually convenient location as may be established by subsequent arrangement, in accordance with the time schedule set out at page 1 above.

He ctfully submitted,.

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Daniel F. Rea CHANGE P.O. Box 2151 Raleigh, NC 27602

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' UNITED STATES OF AMERICA NUCLEAR 'BEGULATORY COMMISSION y[

In the Matter of CAROLINA POWER & LIGHT CO. Docke o' et al. , Shearon Barris Nucicar Plant, Units 1 & 2 '8$0.$b M i 50 401 CERTIFICATE OF SERVICE M f fdf F -Egyh l I hereby certify that copies of d XMM'm@@ oed #AN h jhdudi L d Downs t S 4 A h 'fr wereservhlthis 8 ' day f of 00% W , ih 4 , by deposit in the U.S. Mail, first-olpse postage prepaid, upon all parties whose names appear below, except those whose names are marked with an asterisk, for whom service was accomplished by I'-.. u' M '/ .

James Atomic L. Kelley,& Licensing BoarsiEsq./Mr.

Safety Glenn O. Bright(one

/Dr.each)

James Carpent U.S. Nuclear Begulatory Commission Washington, DC 20555 Office of the Executive legal Director U.S. Nuclear Regulatory Commission Washington, DC 205.55 l Docketing and Service Section Thomas Baxter, Esq.

Office of the Secretary Shaw Pittiman U.S. Nuclear Regulatory Commission 1800,.M St. NW, Potts & Trowbdge.

Washington, DC 20555 Washington, DC.20036 _

Mr. John D. Bunkle Robert P. Gruber, Dir.

Conservation Council of North Carolina Public Staff, NCUC 307 Granville Road P.O. Box 991 Chapel Hill, NC 27514 Baleigh, NC 27602 M. Travis Payne, Esq. Mr. Wells Eddleman Edelstein and Payne 718-A Iredell Street' P.O. Box 12463 Durham, NC 27705 Baleigh, NC 27605 nuthanne Miller Dr. Richard D. Wilson ASLB Panel 729 Hunter Street USNBC, Washington, DC 20555 m, 502 Richar11 E. Jones / DO Mdice Bradley.W. Jones Assoc. General Counsel, CP&L Beg. Counsel USNRC Beg II PO Box 1551 1 l

101 Marietta St, NW Suite 2900 Baleigh C 7602 Atlanta, GA 30303 '

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' Daniel F. Read U CHANGE P.O. Box 2151 Baleigh, NC 27602

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