ML20094H475

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

ML20094H475
Person / Time
Site:	Harris
Issue date:	08/09/1984
From:	Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	CONSERVATION COUNCIL OF NORTH CAROLINA
References
OL, NUDOCS 8408140008
Download: ML20094H475 (14)

Text

hfb HELATED CORRgspCNDENCE k[fhhgust9, 1984

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UNITEDSTATESOFAMERIO AGO 13 Alb:19 NUCLEAR REGULATORY COMMISSION c rr rrr . .- - .

BEFORE THE ATOMIC SAFETY AND LICEUSING BOARDi' In the Matter of )

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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 CCNC (FIRST SET)

Pursuant to 10 C.F.R. SS 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 CCNC 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 documen~ts identified in the responses to interrogatories below. Answers or objections to these interrogatories and re-sponses or objections to the request for production of docu-ments must be served no later than August 30, 1984.

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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 CCNC or any individual acting on its behalf obtain any new ' cur differing . information responsive to these interrogato-ries. 'The request for production of documents is also continu-ing in nature'and CCNC must produce immediately any additional documents it, or any individual acting on its behalf, obtains

-which are responsive to the request, in accordance with the provisions of 10 C.F.R. $ 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, the following defini-

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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 CCNC or any individual acting on its behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any kind; " document (s)" shall also mean copies of documents even though the originals thereof are not in the possession,-custody, or control of CCNC; a document shall be deemed to.be within the " control" of CCNC or any indi-vidual acting on its 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 pub-lic 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.

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y a (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 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 edeuational 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.

l 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.

e (b). Identify the contention (s) to which each such docu-ment relates.

(c). State the specific allegation in each contention which youLcontend 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 cther source of information, not pre-viously. identified in response to Interrogatory 2 or 5, which I.

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 proc ~eeding 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.

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Q Interrogatories on CCNC 2 2-1(a). State whether you are aware that 10 C.F.R.

$ 50.47(b)(10) requires not simply the development of plans for evacuation, but rather the development of "[1] range of protec-tive actions" (emphasis supplied) for the public within the plume'EPZ.

(b). State whether you are aware that Applicants will beErequired to demonstrate the compliance of offsite emergency plans with 10 C.F.R. 5 50.47(b)(10).

(c). State whether you believe that 10 C.F.R. 5 50.47(b)(10) requires consideration of sheltering in local housing as a protective action option.

(d). State whether you believe that the offsite emer-gency plans will fail to comply with 10 C.F.R. S'50.47(b)(10) to the extent it requires provision for consideration of shel-

.tering as a protective action.

(e). If the answer to (d) above is affirmative, iden--

tify specifically all provisions of 10 C.F.R. $ 50.47(b)(10) with which you believe the offsite emergency plans will fail to comply. As to each such provision, describe in detail the bases for your conclusion, including the reasons for identi-fying the provision.

(f). If the answer to (d) above is other than affirma-tive, explain in detail how your response is consistent with

.the allegations set forth in CCNC 2.

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2-2(a). Identify all NRC and FEMA rules, regulations, regulatory guides,' publications, and endorsed national stan-dards which you allege pertain to sheltering as a protective action.

(b). Specify each item identified in answer to (a) ,

above with which you believe the offsite emergency plans will fail to comply. As to each such item, describe in detail the bases for your conclusion, including the reasons for identi-fying the item.

(c). Identify specifically all provisions of each item identified in response to (b) above with which you believe the offsite emergency plans will fail to comply. As to each such provision, describe in detail the bases for your conclusion, including the reasons for identifying the provision ~.

2-3(a). State whether you contend that the " typical rural house" in the Harris plume EPZ is different from the typical rural residences found in the plume EPZs of other commercial nuclear plants in the southeast United States.

(b). If the answer to (a) above is affirmative, specify the bases for that answer.

(c). If the answer to (a) above is affirmative, explain in detail the differences-between the " typical rural house" in the Harris plume EPZ and the typical rural residences found in the plume EPZs of.other commercial nuclear p. ants in the southeast United Staten.

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'2-4(a). Describe in detail the " typical rural house found around the plant site," including (but not limited to) fact $rs such as size of structure, type of building materiaA, density of building material, number of stories / floors, presence or ab-sence of basement, roofing material,-number of size of windows and doors on each floor, type of heating, cooling and ventila-tion systems, and air exchange rate for the structure.

(b). As to each factor or characteristic identified in response _to (a) above, specify the bases for-your conclusion, including the reason for identifying the factor or characteris-tic.

2-5(a). Describe in detail the insulation of the " typical rural house found around the plant site."

(b). Specify the bases for your answer to (a) above.

2-6. Identify all bases for your assertion that the air in the " typical rural house found around the plant site" is

" exchanged several times each hour."

2-7. Describe any and all changes you believe must be made in offsite emergency plans to meet the concerns expressed in.CCNC 2. Describe in detail the bases for your belief that such changes must be made.

2-8. 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 2-7 above), to meet

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• j the concerns expressed in CCNC 2. Describe in detail the bases for your belief that such actions must be taken and such changes made.

Interrogatories on CCNC 8 8-1(a). Identify all training which you believe RPS per-sonnel have already received to prepare them to perform func-tions which they may be relied upon to perform in an emergency at the Harris plant. As to each training course listed, iden-tify the bases for your response.

(b). Identify all training (excluding that listed in answer to (a) above) which you believe RPS personnel will re-ceive prior to operation of the Harris plant above low power, to prepare the personnel to perform functions which they may be relied upon to perform in an emergency at the Harris plant.

8-2(a). List individually each function which the Radia-tion Protection Section (RPS) of the North Carolina Department of Human Resourcas may be relied upon to perform in an emergen-cy at.the Harris plant, but which you believe will not be ade-quately performed due to insufficient staffing.

(b). With respect to each function listed in your an-swer to (a) above, indicate (i) the approximato number of RPS personnel available to perform that function and (ii) the num-ber of additional personnel you contend are required to suc-cessfully implement that function.

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8-3(a). List individually each function which RPS may be relied upon to perform in an emergency at the Harris plant, out ,

which you believe its personnel are not adequately trained to perform, and identify any way in which the training RPS person-ncl will receive will be inadequate.

(b). With respect to each function listed in your an-swer to.(a) above, describe in detail'the training which the personnel must receive in order to'successfully perform that

. function.

8-4. Describe any and all changes you believe must be made in offsite emergency plans to meet the concerns expressed in CCNC 8. Describe in detail the bases for your belief that such changes must be made.

, 8-5. Describe any and all actions you believe must be

'taken, or changes you believe must be made (other than those identified in answer to Interrogatory 8-4 above), to meet the concerns exprassed in CCNC 8. Describe in detail the bases for your belief that such actions must be taken and such changes made.

Request For Production of Documents App'licants request that Intervenor CCNC respond in writing to this request for production of documents and produce the original or-best copy of each of the documents identified or

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4 described in the answers to each of the above interrogatories, at a place mutually convenient to the parties.

, Respectfully submitted, Ala A $da.m

.Thomad 'K. Baxfet, P!C.{ ~ (

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

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40,3 UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION . A';

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 CCNC (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.

! / L belissa Ak Ridg4&y V DATED: August 9, 1984

a UNITED STATES OF AMERICA 4 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 )

)

(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 L 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 l Mr. Daniel F. Read, President Dr. Linda W.'Little l 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 t

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$ Br:dicy W. Jancs, Esquiro U.S. Nuclear Regulatory Commission 1 Region II l 101 Marrietta street l 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 Washington, D.C. 20740

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