ML20094H501
| ML20094H501 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/09/1984 |
| From: | Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | CHAPEL HILL ANTI-NUCLEAR GROUP EFFORT |
| References | |
| OL, NUDOCS 8408140022 | |
| Download: ML20094H501 (21) | |
Text
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August 9, 1984 Shc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g4 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)
)
APPLICANTS' EMERGENCY PLANNING INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR CHANGE (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 CHANGE answer separately and fully in writing, and under oath or af-firmation, 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-spenses 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 1are intended to-be' continuing in na-
' ture,f.and the answers lshould promptly be supplemented;or 1
~ amended-as' appropriate,-pursuant toL10 C.F.R.
5 2.740(e),
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should' CHANGE or any individual acting on its behalf.obtain any new or: differing information responsive to these'interrogato-1 ries.
The request for production of documents is also cont'inu-ing in' nature and CHANGE must produce immediately any addition-al: 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).
j 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
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- following information as applicable:
document.name,. title,
. number, author, date of publication and_ publisher, addressee,
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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:
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" Applicants" is intended to encompar-C'ro tna Power &
Light Company, North Carolina Eastern Mutuelp.:
cwer 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 CHANGE or any individ-ual acting cn1 its 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-ment (s)" shall also mean copies of documents even though the originalo thereof are not in the possession, custody, or con-trol of CHANGE; a document shall bd deemed to be within the
" control" of CHANGE or any individual 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 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. e
r (b). -Identify those facts concerning which each such' person has first-hand knowledge.
( c )'.
-State the specific allegation ~in each contention E
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.
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.
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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 i
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..
Interrogatories on CHANGE 17 1(a).
Identify all NRC and FEMA rules, regulations, regulatory. guides, publications, and endorsed national stan-dards which you believe require provision for special notifica-tion (i.e., by means other than sirens) of the hearing-impaired population within the plume EPZ in the event of an emergency at a commercial nuclear power plant.
(b).
Specify each item identified in answer to (a) above with which you believe the offsite plans will fail to
. comply.
As to each such item, describe in detail the bases for your conclusion, including the reasons for identifying the item. 2(a).
Identify, to the best of your knowledge, the ap-proximate number of " hearing-impaired" persons in the portion of Wake County within the Harris plume EPZ.
(b).
Identify, to the best of your knowledge,.the ap-proximate number of " hearing-impaired" persons in the portion of Harnett County within the Harris plume EPZ.
(c).
Identify, to the best of your-knowledge, the ap-proximate number of " hearing-impaired" persons in the portion of Lee County within the Harris plume EPZ.
(d).
Identify, to the best of your knowledge, the ap-proximate number of " hearing-impaired" persons in the portion
'of Chatham County within the Harris plume EPZ.
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t (e).
As to each number identified in answer to (a) through (d) above, specify the bases for your answer.
17-3.
Identify any existing means of notifying " hearing-impaired" persons in the Counties of Wake, Harnett, Lee and Chatham of non-nuclear emergencies.
17.4(a).
State whether you contend that the provisions in the Harris emergency public information brochure (and the spe-cial needs postcard enclosed in the brochure) for the identifi-cation and special notification of the hearing-impaired are in-adequate.
I, b ).
If the answer to (a) above is other than an un-qualified negative, explain in detail why the provisions iden-tified in (a) above are inadequate.
(c).
If the answer to (a) above is other than an un-qualified negative, state the bases for your belief that the-
- provisions identified in (a) above are inadequate.
17-5.
Describe any and all changes you believe must be made in offsite emergency plans to provide adequate notifica-tion to the hearing-impaired population within the plume EPZ in the event of an emergency at the Harris plant.
Describe in de-tail the bases for your belief that such changes must be made.
17-6.
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 17-5 above), to l '
provide adequate notification to the hearing-impaired popula-tion within the plume EPZ in the event of an emergency at the Harris plant.
Describe in detail the bases for your belief that such actions must be taken and such changes made.
Interrogatories on CHANGE 25 25-1.
Identify all NRC and FEMA rules, regulations, reg-ulatory guides, publications, and endorsed national standards which you believe require special provisions for the transpor-i tation of " families with one private vehicle, which private ve-hicle is used to drive the principal wage-earner to work, leaving dependents at home."
25-2(a).
Identify the approximate number of families within the plume EPZ "with one private vehicle, which private vehicle is used to drive the principal wage-earner to work, leaving dependents at home."
(b).
Identify the approximate number of individuals (excluding the " principal wage-earners") who are-members of the families identified in the answer to (a) above.
(c).
Describe in detail the bases for your answers to (a) and (b) above.
25-3(a).
Identify the approximate number of " principal wage-earners" within the plume EPZ who drive their family's only vehicle to their place of employment whom you assert (i) l
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would return home to pick up their families before evacuating, (ii) would evacuate directly from their place of employment.
(b).
Describe in detail the bases for your answer to (a) above.
25-4.
Identify specifically the geographic boundaries of all " low income areas" to which CHANGE 25 refers.
25-5(a).
Identify the percentage of the families to which CHANGE 25 refers which you believe would be able to obtain rides with neighbors, family and friends in the event of an evacuation due to an emergency at the Harris plant.
(b).
Describe in detail the bases for your answer to (a) above.
25-6.
Describe any and all changes you believe must be made in offsite emergency plans to " address the problem of fam-ilies with one private vehicle, which private vehicle is used to drive the principal wage-earner to work, leaving dependents at home."
Describe in detail tile bases for your belief that such changes must be made. 7.
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 25-6 above) to " address the problem of families with one private vehicle, which private vehicle is used to drive the principal wage-earner to work, leaving depen-dents at home."
Describe in detail the bases for your belief that such actions must be taken and such changes made.
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b Interrogatories on CHANGE 29 29-1(a).
State whether you are aware that the Harris emergency public information brochure for distribution to the public within the plume EPZ cdvises parents that, in the event-of an evacuation, their children who are in school within the plume EPZ would be evacuated directly from school to specified locations outside the plume EPZ, and directs parents not to drive to the schools to pick up their children.
(b).
State whether you are aware that the EBS an-nouncements for broadcast in the event of an evacuation will advise parents that their children who are in school within the plume EPZ are being evacaated directly from school.to specified locations outside the plume EPZ, and will direct parents not to drive to the schools to pick up their children.
(c).
Identify and explain in detail all bases for your assumption that parents would disregard the instructions of the public information brochure and the EBS announcements not to go to the schools to pick up their children.
29-2.
Identify the approximate percentage of parents whom you believe would go to the schools to pick up their children in the event of an evacuation, despite the instructions to the contrary in the public information brochure and the EBS an-nouncements..
29-3(a).
Identify and explain in detail all ways in which evacuation of the plume EPZ might be hindered if the number of parents you believe may go to school to pick up their children in an evacuation actually do go to the schools to pick up their children.
(b).
Describe in detail the bases for your answer to (a) abeve.
29-4.
Describe any and all changes you believe must be made in offsite emergency' plans to address your concern ex-pressed in CHANGE 29.
Describe in detail the bases for your belief that such changes must be made.
29-5.
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 29-4 above) to address your concern expressed in CHANGE 129.
Describe in de -
tail the bases for your belief that such actions must be taken and-such changes made~.
j-Interrogatories on CHANGE 30 1
30-1(a).
List individually each-function which rescue-
. squads may be relied upon to perform in an emergency at the Harris' plant, but which you believe may not be adequately per-formed in an emergency due to alleged lack of '" sufficient au-thority" of squad leaders "over the members of their squads."
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(b).
With respect to each function listed in your an-swer to (a) above, indicate (1) the approximate number of res-cue squad workers who actually would make themselves available to perform that function in an emergency and (ii) the number of additional personnel you contend are required to successfully implement that function.
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30-2(a).
Identify specifically all rescue squads whose leaders you believe " occupy merely titular posts and do not possess sufficient authority over the members of their squads to assure continuing participation in emergency activities in the event of a radiological emergency."
(b).
Identify the leaders of the rescue squads listed in the answer to (a) above.
30-3(a).
State whether you contend rescue squads respond to the authority of their leaders in other types of emergencies and disasters, but might not do so "in the event of a ra-diological emergency."
(b).
If the answer to (a) above is affirmative, iden-tify and explain in detail all bases for your answer.
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(c).
If the answer to (a) above is other than affir-mative, explain in detail how your answer is consistent with the allegations set forth in CHANGE 30.
30-4.
Identify and describe in detail all past situations (if any) illustrating the alleged lack of " sufficient authority" of rescue squad leaders "over the members of their squads."
30-5.
Identify and describe in detail all measures (including training and equipment) which you understand are being taken or will be taken to assure that rescue squad mem-bers perform their assigned functions in the event of a ra-diological emergency.
30-6(a).
State whether you contend that any of the mea-sures identified in answer to Interrogatory 30-5 above are in-adequate to assure that rescue squad members perform their as-signed functions in the event of a radiological emergency.
(b).
If the answer to (a) above is affirmative, specify each of the measures identified in answer to Interroga-tory 30-5 above which you believe to be inadequate to assure that rescue squad members perform their assigned functions in a radiological emergency.
Describe in detail the bases for your belief that the specified measures are inadequate.
30-7.
Describe any and all changes you believe must be made in offsite emergency plans to assure that rescue squad members perform their assigned functions in the event of a ra-diological emergency.
Describe in detail the bases for your belief that such changes must be made.
30-2.
Describe any and all actions you believe must be 1
taken, or changes you believe must be made (other than those identified in the answer to Interrogatory 30-7 above) to assure that rescue squad members perform their assigned functions in the event of a radiological emergency.
Describe in detail the bases for your belief that such actions must be taken and such changes made.
Interrogatories on CHANGE 31 31-1(a).
State whether you are aware that the Harris emergency public information brochure for distribution to the public within the plume EPZ instructs members of the public not to use their telephones in the event of a radiological emergen-cy (unless they need special assistance), so that all telephone lines can be used for official emergency business.
(b).
State whether you are aware that the EBS an-nouncements for broadcast in the event of a radiological emer-gency will direct members of the public not to use their tele-phones in the event of a radiological emergency (unless they need special assistance), so that all telephone lines can be used for official emergency business.
(c).
State whether you believe that, in a ra-diological emergency, a significant percentage of the public would disregard the instructions of the public information bro-chure and the EBS announcements not to use their telephones in the event of a radiological emergency (unless they need special assistance). l
(d).
If the answer to (c) above is affirmative, iden-tify and explain in detail all bases for your answer.
(e).
If the answer to (c) above is affirmative, iden-tify the percentage of the general public whom you believe would use their telephones, despite the instructions to the contrary of the public information brochure and the EBS an-nouncements.
(f).
If the answer to (c) above is other than affir-mative, explain in detail how your answer is consistent with the allegations set forth in CHANGE 31.
31-2(a).
Describe in detail all types of calls which you i
assert would be made "during the early stages of an emergency,"
including (but not limited to) -- with respect to each type of call -- the general type of caller, the general type of recipi-ent, the purpose of the call, the probable duration of the call and whether the call would be long distance.
(b).
Explain in detail how the calls identified in the answer to (a) above "will tend to delay evacuation of the general public in the EPZ."
Describe in detail the bases for your conclusions.
31-3.
Identify all bases for your allegation that "[tll,
recent tornado disaster in North Carolina showed an increase of approximately 25% in telephone traffic." -
_c.
31-4.
Identify all bases for your suggestion that "a more dramatic increase" than that alleged to have occured in the re-cent tornado would occur in the event of a radiological emer-gency at Harris.
31-5.
Identify all bases for your allegation that "a more dramatic increase in the shorter time immediately following a sudden' emergency would result in serious communication prob-lems."
31-6.
Describe in detail the " serious communication prob-lems" to which CHANGE 31 refers.
31-7.
Specify in detail the load capacities for all tele-phone systems servicing the Harris plume EPZ.
31-8(a).
Identify all telephone systems (if any) which you believe shut down temporarily due solely to the alleged in-crease in telephone traffic at the time of "[t]he recent torna-do disaster in North Carolina."
(b).
Specify the bases for your answer to (a) above.
(c).
With respect to each telephone system identified in answer to (a) above, state the duration of the shutdown, and specify the bases for your answer.
(d).
With respect to each telephone system identified in answer to (a) above, identify the time at which the shutdown occurred.. - - _.. - -,.
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31-9.
Describe any and all changes you believe must be made in offsite emergency plans to address your concern ex-pressed in CHANGE 31.
Describe in detail the bases for your belief that such changes must be made.
31-10. 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 31-9 above) to address your concern expressed in CHANGE 31.
Describe in de-tail the bases for your belief that such actions must be taken and such changes made.
Request For Production of Documents Applicants request that Intervenor CHANGE respond in writ-ing to this request for production of documents and produce the original or best copy of each of the documents identiied or a
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' described in the answers to each of the above interrogatories, at a-place mutually convenient to the parties.
Respectfully submitted,-
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Thom(s h. Baxt % E C.{
y1 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 _, -
HELAlto cU'U '1"C AcC T44p A@ 13 No:17 UNITED STATES OF AMERICA CF 00 NUCLEAR REGULATORY COMMISSION 1
4 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 CHANGE (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.
VW Delissa'A. Rid? way' DATED: August 9, 1984 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
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 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 t
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. Road, 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
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BradlGy W. JcnOs, Esquiro U.S. NuclO3r R gulotcry Commissicn 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 Washington, D.C.
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