ML20094H467
| ML20094H467 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/09/1984 |
| From: | Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | WILSON, R. |
| References | |
| OL, NUDOCS 8408140004 | |
| Download: ML20094H467 (11) | |
Text
{{#Wiki_filter:N = c: i gwa c AugusbObETbk84 USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '&4 AGO 13 A10:21 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _, y,p.. !:f; ny ~n, ca .,,u 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 WILSON (FIRST SET) Pursuant to 10 C.F.R. $$ 2.740b and 2.741 and to the Atom-ic Safety and Licensing Board's " Order (Ruling on Various Pro-cedural Questions and Eddleman Contention 15AA)" of May 10, 1984, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Richard Wilson answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories, and pro-duce and permit inspection and copying of the original or best copy of all documents identified in the responses to interroga-tories below. Answers or objections to these interrogatories and responses or objections to the request for production of documents must be served no later than August 30, 1984. \\ (-{([) ) 8408140004 840809 PDR ADDCK 05000400 O PDR
Y 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. S 2.740(e), should Dr. Wilson or any individual acting on his behalf obtain any new or differing information responsive to these interroga-tories. The request for production of documents is also con-tinuing in nature and Dr. Wilson must produce immediately any additional documents he, or any individual acting on his be-half, obtains which are responsive to the request, in accor-dance with the provisions of 10 C.F.R. 5 2.740(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, addressee, .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, tha following defini-tions shall apply: " Applicants" is intended to encompass Carolina Power & ~ Light Company, North Carolina Eastern Municipal Power Agency a n'd their contractors for the Harris Plant.
f!, i "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 an'd records of every type in the possession, control or custody of Dr. Wilson 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 rccord-ings and all other writings or recordings of any kind; "docu-ment (s)" shall also mean_ copies of documents even though the originals thereof are not in the possession, custody, or con-trol of Dr. Wilson; a document shall be deemed to be within the " control" of Dr. Wilson 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 document or copy thereof, from any person or public or private entity 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. _
c i (b). Identify those facts concerning which ea~ch 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 affiant, 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 eacuational and professional qualifications of each person you intend to call as an expert witness or a witness relating to 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 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. l-u_
(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. '
3 Interrogatories on Wilson II II-1(a). List all groups for which you assert there should be criteria defined for entry into the Harris plume EPZ, ^ including " parer.ts of children in day care, pa, rents with such . chi 1dren at home, people with dependents without vehicles, peo- -ple needing to secure their businesses, [and] people needing to remove a few belongings from their homes." (b). As to each group identified in answer to (a) above, state whether you contend that all members of that group should be permitted entry into the plume EPZ in a radiological emergency. (c). As to each group identified in answer to (a) above,Lidentify, to the best of your knowledge, the approximate number of individuals in that group who-might request entry into.the plume EPZ in a radiological emergency. (d). As to each specific group identified in answer to (a) above, state the. bases for your conclusion that the mem-bers of that-group should be permitted entry into the plume EPZ in a radiological emergency. (e). As to each specific group identified in answer to (a) above, describe and explain in detail all possible ad- . verse consequences of the denial of entry into the IPZ by the members of the group. II-2. Describe any and all changes you believe must be made in.offsite emergency plans to meet your concerns about L.
C..',, e defined " criteria for entry into the 10 mile EPZ," as expressed in Wilson II. Describe in detail the bases for your belief that such changes must be made. II-3. 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 II-2 above) to meet your concerns about defined " criteria for entry into the 10 mile EPZ," as expressed in Wilson II. Describe in detail the bases tor your belief that such actions must be taken and such changes made. Request For Production of Documents Applicants request that Intervenor Wilson respond in writ-ing to this request for production of documents and produce the original or best copy of each of the documents identified or I i f i, L
.a p described in the answers to each of the above interrogatories, at a place mutually convenient to the parties. Respectfully submitted, T h o'm ais A. B axtfe r, P. d. [] 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 CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Dated: August 9, 1984 I l t -a-il ~.
a HEL/5nu f. s,., i,,;.gjg 4 00lMETCO US14RC M AGO 13 A10:21 f0CXY $fg f3itI y' b UNITED STATES OF AMERICA pf NUCLEAR REGULATORY COMMISSION BRANCH 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 This is to certify that copies of the foregoing " Applicants' Emergency Planning Interrogatories and Request For Production of Documents To Intervenor Wilson,(First Set)" were served by
- deposit in the United States Mail, first class, postage prepaid, this 9th day of August, 1984, to all those on the attached Service List.
b " "telissa A'. Ritig%y V CATED: August 9, 1984 + s---
a. UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ) CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400'OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY ) 4 ) (Shearon Harris Nuclear Power ) Plant, Units 1 and 2) ) 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 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Commission P.O. Box 12607 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 Charles A. Barth, Esquire Mr. Wells Eddleman Janice E. Moore, Esquire 718-A Iredell Street Office of Executive Legal Director Durham, North Carolina 27705 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Richard E. Jones, Esquire Office of the Secretary Vice President and Senior Counsel U.S. Nuclear Regulatory Commission Carolina Power & Light Company Washington, D.C. 20555 P.O. Box 1551 Raleigh, North Carolina 27602 Mr.' Daniel F. Read, President Dr. Linda W. Little + CHANGE Governor's Waste Management Board P.O. Box 2151 513 Albemarle Building Raleigh, North Carolina 27602 325 North Salisbury Street Raleigh, North Carolina 27611 ~ y s ,--,m--w, -,--,,w-- --w-,,,.,,, r- ,-,,,-,,,,e -,m~ -,,,, -,
+ 1 Bradley W. Jancs, Esquira U.S. Nuclear Regulatory Commission Region II 101 Marrietta 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 P.O. 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 i Washington, D.C. 20740 l l l 1 1 -}}