ML20096C347

Interrogatories to NRC & FEMA (6th Set) Re Contentions 240,213a & 57-C-7.Certificate of Svc Encl.Related Correspondence

ML20096C347
Person / Time
Site:	Harris
Issue date:	08/31/1984
From:	Eddleman W EDDLEMAN, W.
To:	Federal Emergency Management Agency, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
82-472-03-OL, 82-472-3-OL, OL, NUDOCS 8409050239
Download: ML20096C347 (8)

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c-UNITED STA'!ES OF AMERICA NUCIEAR REGULATORY COMMISSION 9 31-84 00LMETE!-

BEP0EE THE A'fCMIC SAFETY AND LICENSING BOARD UStac Glenn O. Bright 4

l Dr. James H. Carpenter ag4 gp _4 ;

James L. Kelley, Chairman A'

F secw n.im a sr NH I

In the Matter.of CAROLINA POWER AND LIGHT CO. et al.

(Shearon Harr s Nuclear Power Plant, Unit 1

ASLBP No. 82-1;% -03 OL Wells Eddlenan's" Interrogatories to NRC Staff and PEMA and FEMA J

Wells Eddleman hereby requests the NRC Staff to answer the following i

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//fi,198$ or such other date as counsel for the Staff nr.errogatories are submitted under 10 CFR 2 720(h)(i interrogatories before and I agree on. These and inquire into the studies, information, and knowledge of NRC staff with Sined I cannot read respect to my contentions, on which discovery is now open.

the minds of the staff, and this information is not contained in documents which the staff has provided to ne, I am unable to obtain this inforsation by W ere the information is contained in a document I can obtain other means.

fror. NRC (Public Document Roon, etc). I still need the identification of the The staff has resources and document in order to obtain the information.

information which exceed what I have, and as a party,' their position and information are necessary to making my case in this proceeding. These interroga-tories are continuing in nature and should be supplemented ten answers change.

GENERAL IEERROGA70 RIES, -

In all interrogatories heyein, "you' or" Staff" means NRC Staff or' PEMA

• j' For each of contentione CPT lj,3,Wf-44 Mdlenan contentionsgg y" 2

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please provide we fo1 Tow:ing information tgr answering ead of these questions.

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eYstan n

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. subject matter of this 1.

Wat NR S contention?

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Eli Nn [nto,(a) this contention (b) 2.

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ntion c) the allegation (s) in this contention the subject matter of this con (d) the basis of this contention (e),the information I

in support of this contention?

For all parts of your response to Interrogatory 2 above for which your 3

who made answer is affirmative, please provide the following informations the analysis, inquiry, study or investigation; what was being considered in I

such analysis, inquiry, study or investigation ("AISI"): the content of the the results of the AISI, whether the AISI has been completed, whether AISI adaleforcompleting_theAISIhasbeenestablishedifitisnotcomplete, what that date is, a n documents used in the AISI, all persons consulted 8409050239 840031

$03 DR ADOCK 05000

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in tho oourso cf the AISI, en docun:nts centaining infermation disesvarad Gr cnalysis tr ctudy cr infctmation d:velsped during er cs a rosult of ths AISI (identify each such document and state what informatisn er results it contains), eether staff believes additional analysis is warranted, or further AISI needs or may need to be undertaken on this contention, and tether any persons participating in the AISI are to be caned as witnesses for the Staff in this osse,and what questions the staff AISI is intended to answer and what information it seeks to develop answer is other than affirmative, please state (a) whether EC staff w-pgg 4.

plans to perform any AISI on this santention, (b)

• ether anyone on EC Staff has stated that AISI of av) kind is warranted for this content (even though it has not been made) (c on this contention include a date for beginning or for ending)such AISI, what AISI (d) those dates, for an affirmative answers to (c) above. (e

["G$ orEC staff will undertake on this contention (f) what A to undertake on this contention (g)(an reasons why no AISI is plann h) au reasons why no AISI has been this contention if none is plannedis contention if none has been done (1) what the r done yet on of EC staff th respect to this contention are.

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aff relied on in opposing the admission O

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5. Identify an documents the facts not stated in the Staff's opposition of this contention, and av specifto admission of such contention (alread relied in making such opposition.

6. Identify an doounents not identified in Staff's interrogatories to Wens Eddle.an or to Joint Interwners (to present -- a continuing interrogat upon which the Staff relied in u.aking each such interrogatory.F61% A W Identify by name, personal or business address, BC staff position or title (if av), and telephone nunber (if known) each^ person on EC staff 7

or consultant to EC staff or known to EC Staff or consulted by BC staff in the staff's analysis of the subject matter of this contention prior to (a) its filing (b) its adnission; state for osch such person what analysis was performed hr that person.

State an professional qualifications of each person identified in 8.

response to interrogatories 7,,

' 1 A, j

9. Provide av statements of the analysis made by persons identified j

in response to interrogatories 3,4, or 7a above, and identify an docunents oontaining such infornation or statements not previously identified.

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Give the identifier snaber, date, source, and title of an ' documents identified in response to interrogatories above, which are available throu f

10.

l EC PRm (Public Document Room).

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n. Win EC Staff make available copies of documents identified in response to the above interrogatories to Wens Eddleman for inspection i

and oopying, for documents not available through EC's PET f*t P1 h WEC staff position if av, address and telephone l

12. Identify hr name,4 nanber each person whom BC staff intends to xxx use or can as a uitness in this proceeding.

13. State fully the professional qualifications of each person identified in response to interrogatory 12 above.

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3 14, Sunnarisa th3 positiin (cr plcnned testimony) with r3spect to each oontention on Wich such person is expected to testify, for each person identified in response to interrogatory 12 above.

15 Mas Staff, a g witness identified in response to interrogatory

12. or agne acting in behalf of the Staff or such a witness or at their direction, made av oalculation or analysis (not identified in response to interrogatories 1 through 4 above) with respect to this contention?

16. If the answer to interrogatory 15 above is yes in any case, provide the name, business or personal address, telephone number and professinnal qualifica.tions of each person to has made such calculation or analysis, stating for each dat contention it relates to, what person (or Staff) it was nade for or at the direction of, and identifying all documents oontaining such omiculationer analysis and all docunents usad in making such calculation or analysis or relied upon in it or supplying infornation used in it.

17 Provide a sumary of each AISI, calculation or analysis Adam for which the answer to interrogatory.15, or interrogatory 2 above, is yes.

18. Please give the sooession nunber, date and originstor of each document identified in response to interrogatory 16, whici is available at the E C PE.M6 of

19. WL C Staff make available to Wells Eddle:.an for inspection and copying all ocuments identified in response to interrogatory 16 above which are not available through the P mt of expertise and qualifications (conplate) (phone number, address

20. Identify each person, including teleif any) as to answered interrogatories with respect to this contentions if more than one person oontributed to an answer, identify each such person, providing the information requested above in this interrogatory for each such person, and state what esob such person's contribution to the answer was, for each answer.

916 W

21. Identify all documents W ich th Staff proposes or intends to use as exhibits with respect to this content on during this proceeding, including exhibits of Staff witnesses (identifying the witness for each, if such a witness has been designated), and exhibits to be used during cross-examination l

of witnesses of ag party (stating for each dich witness it is to be used i

in cross-exa tination of), and identifying for each the particular pages or chapters to be used as exhibits.

22 Identify all documents dich EC staff relied upon in answering j

interrogatories with respect to this contention, Wich have not been 4

identified in response to interrogatories 1 through 21 above, stating for osch Wich answer (s) re which oontention(s) it was used for, and each specific fact and page nunber therein on d ich E C staff relied or which EC staff used in answering such interrogastory.

23. Please give the accession number, date, and originator of each docu:nent 1

i identified in response to interrogatories 21 or 22 above dich is available through the EC PDR.

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f 24.

C Staff provide Wells Eddleman with oopies of the documents l

identified n response to interrogatory 21 or 22 above dich are not available at the P 2, for inspection and copying?

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_4 25.

Identify any other information or source of information not #

identified in response to the the above interroEatories 1 thru 2gdubl1 p (V upon which any member of NRC staff reliefd, or which any such j

member of staff used, in answering each interrogatory with respect to this contention, naming the contention and response in which each such source was used, and the location of the information used or relied on in such source (e.g. page number, section, chapter, etc).

mf F6P1W 26 (a) Does the Staff now agree with the contention? (b) Does the f

Staff not agree with dny part of the contention?

27 If answer to (b) above is affirmative, which part(s) and why?

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Specific Interrogatories on Eddleman 240 240-1(a) What agency of Chatham County government is resnonsible i

for the decontamination of evacuees at the Chatham County shelters?

(b) if different agencies have responsibility for decontamination of evacuees at different shelters, please state which agency is responsible for which shelter, and whether the county agencies provide decontamination for evacuees (or will be urepared to provide it) at all Chatham County shelters.

(c) If anyone other than an agency i

l-of Chatham County government is responsible (or to be responsible)

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for decontamination of evacuees at any shelter in Chatham County, d

please list the responsible persons or agencies for each such shelter.

(d) For each agency or person who has responsibility for decontaminating i

' evacuees at any shelter in Chatham County, what is the capability l

of each such agency or person to carry out such decontamination?

i Please address (i) establishment of radiological resnonse teams j

(ii) training of these teams (iii) directing of these teams, fully in your answer, and fully and comnletely describe the capabilities 1

of each such team to carry out decontamination of evacuees from l

a nuclear accident at Shearon Harris.

l 240-2(a) Which organization (s) are responsible for providing support for dekamm decontamination of evacuees in Chatham County?

_ (b) Identify each shelter for which each sunnort agency, identified in responae to (a) above, will or can provide supnort.

(c) For each such agency or shelter, what are the capabilities to provide

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suoport for decontamination of envacuees?

(d) Please identify all documents concerning responsibility for providing sunport for decontamination of evacuees in Chatham County, who wi31 nrovide l

this support, and the canabilities of such sunnort agencies, or 1

the shelters where each such agency will (or is intended to) nrovide j

support for decontamination of envecuees.

l 240-3(a) Please identify all documents concerning the resconsible j

agencies or agency of Chatham County which will vrovide decontamination for evacuees from a nuclear accident at Shearon Harris, including (1) which shelters each such agency has primary or backup respgnaibility for (specify the type of resconsibility, i.e. primary, backup);

(ii)the acapabilities of each such agency for decontamination

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(iii) the establishment, training or direction of Radiological Response Teams in Chatham County or to be used in Chatham County in the event of a nuclear accident at Shearon Harris; (iv) any other agency's responsibility or capabilities for providing decontamination for evacuees at shelters in Chatham Sounty, which j

information is used or relied uoon by emergency planners of the State of NC or Chatham County; (v) any agency or verson who is j

expected to provide decontamination for evacuees at any shelter (s) in Chatham County in the event of a nuclear accident at Shearon i

Harris, which identifies that agency oar person, or discusses or

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describes or evalutes that person or agency's capabilities for providing decontamination #

+nig Specific Interrogatories on 213-a:

213-A -1(a )

Does the Harris offsite emergency response olan i

now confors to evaluation critorion II.P.7 of NUREG-06547 j

(b) If so, how?

(c) If not, why not?

(d) What additional information is required to brir;g the plan for the Harris plant

.into como11ance with NUREG-0654 evaluation criterion II.P.7?

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($e) When is this information riow scheduled to be connletely incorporated into the plan?

When will all of the information j

required to cemely with criterion II.P.7 be in the pian?

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213-A-1 continued (f) when will PEMA begin feview of thie information submitted to ensure come11ance with NUMEG-0654 criterion II.P.7 for the i

Shearon Harris off-site emergency response plan?

When is that review shheduled to be comoleted?

(g) Please identify all documents concerning (i) comoliance or noncompliance of the Harris off-site Emergency Resnonse Plan (ERP) with NUREG-0654 criterion II;..P.7;(ii) information required to brin the Harris ERP into compliance with this criterion;(iii) actions required to bring the Harris offsite ERP into connliance with this criterion; (iv) comments by FEMA or any other emergency planning agency, or any person (including consultants and staff of emergency planning organizations ) concerning the compliance (or lack of compliance) of the Harris offsite ERP with NUREG-0654 evaaluation criterion II.P.7;(v) drafts or information to be added to the Harris ERP to meet evaluation criterion II.P.7;(vi) comments on,

those drafts;(vii) evaluation of the Harris E9P (offsite) vs.

NUREG-0654 criterion II.P.7 by FEMA or anyone else.

213-A-2(a) Do you believe that all requirements of evaluation criterion II.P.7 of NUREG-0654 are met by the nresent form of the Harris offsite emergency response plant?

(b) Please give all reasons for your answer to (a) including cites to every as specific part of the plan which you believe detail or contain implekmenting procedures, all parts of the plan which do not in your opinion aantain sufficient innlementing procedures, and all reasons why you believe the plan in its present form does, i

or does not, fully comply with criterion II.P.k7 of NUREG-065k.

Plecse identify all documents containing information used in forming your belief or making your answer to either (a) above or above earts of (b).

(c) If you don't know whether the Harris offsite ERP does or does not fully comoly with evaluation criterion II.P.7 of NUREG-0654, do you plan or are you now doing anything to find out if it does?

If so, what is to be done, and when is it to be completed?

Please identify all documents concerning your l

review of the Harris offsite ERP for NUREG-0654 criterion II.P.7 i

como11ance, including documents containing any results of such l

review (s) or comnents on such reviews or drafts thereof.

(d)

What imolementing procedures are required for an offsite emergency response plan mz in your opinion?

(e) Is there anything about the present form of the Harris i

offsite ERP daat (i) does (ii) does not, comely with l

evaluation criterion II.P.7 of NUREG-065h?

If so, what does comply, and what does not?

Please provide all reasons l

for your answer (s) including any Amt documents or rules or review standards you used in making or af analysis underlying your answer (s) your answer or any review or any of your answers.

213-A-3(a) Where are the implementin procedures in the Harris

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offsite emergency response plan?

Please list each one and exaplain why, in your view, it is an adequate (or inadequate) implementing procedure for compliance with NUREG-0654 criterion II.P.7.

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Inttrragsterios on 57-C-7 57-C-7-1(a) Do you know if any hospitals (i) listed on section V.B.3 of the State (offsite) Harris emergency response vlan are now prepared to treat severe radiation exposure Ler se?

(ii) not listed in the Harris ERP section V.B.3, but (ii!a) local (ii-b) regional hospitals hamm around the Harris plant, are now prepared to treat severe radiation exposure cases?

(b) If you answerk to any part(s) of (a) or (b) above, or to (s) or (b) above, is affirmative, identify the y hospital (s) and give all reasons for your answer.

(c) Please state what tpes or levels of severe radiation exposure (e.g. dose up to 400 rem) each hosuital is prepared to treat, i.e. what are the severe radiation injuries or exposure levels each is prepared to treat.

(d) please identify all documents concerning the ability of each such hospital to treat severe radiation injauries or exposure.

57-C-7-m2(a)

Does the Harris offsite ERP presently list (i) local hospitals with the necessary capabilities to provide medical services for those seriously injured by radiation alone ?

4 (ii) regional hospitals with the necessary capabilities to provide medical services for those seriously injured by radiation alone?

(b) what capabilities do you maintain each such hosnital has for providing medical services to persons seriously injured by radiation?

How do you know each has those capabilities?

Have you inspected each hospital to evaluate the existence of those canabilities?

How do the canabilities of each such hospital meet or exceed the "necessary canabilities" required to provide medical services for those seriously injured by radiation alone?

(c) what are the necessary capabilities required to provide medical services for persons seriously injured by radiation, for (1) local hosnitals (ii) regional hosnitals, avound the Harris nuclear plant?

How do you know these capabilities are necessary?

How do you know that other capabilities are not necessary for providing medical services to persons seriously injured by radiation?

(d) If you or your attorney (s) say that knowledge or insnection or evaluation of the capabilities of hospitals to nrovide f

medical services for persons seriously (iii) outside the scope insjured by radiation are (i) irrelevant (ii) objectiohable j

of this contention, please a explain fully how you know that any hospital has the "necessary capabilities to provide medical services for those seriously injured by r adiation alone2"?

(e)Please identify all documents concerning each matter inquired about in each part of (a) thru (d) above.

57-C-3(a) Please identify all documents concerning the question of whetsher the ability to treat severe radiation exposure ner se is required by (i) any) FEMA guidance (ii) any NRC regulation (iii) any NRC rule (iv any applicable law or requirement, including the Atomic Energy Act.

PRODUCTION OF DOCUMENTS Wells Eddleman hereby requests that the original or best copy of each document identified $n response to the above interrogatories be produced for inspection and copying at a mutually agreeable time and place.

ells Eddleman 8-31-84

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of CAROLIhA POWER k LIGHT CO. Et al. )

Docket 50-400 Shearon Harris Nuclear Power Plant. Unit 1-

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CEBTIFICATEOF SERVICE W.E. Interrogatories to Applicants /NC I hereby certify that copies of

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Emergency Planners on contentions 240, 215-a and 57-C-7, and of W.E. Interrogatories to NRC Staff / FEMA Staff on the same contentions I

HAVE been served this 31 day of August 198L, by deposit in 4

the US W il, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are marked with i

I an asterisk, for whom service was accomplished by onission evnm sefvice per oral order of March 1983 JudEes James Kelley, Glenn Brigh and Janas Carpenter (1 copy each)

Atomic Safety and Licensing Board US Nuclear Megulatory Commission Washin6 on DC 20555 t

George F. Trowbridge (attorney for Applicants)

Shaw, Pittman, Potts & Trowbridge

-jfR uthanne G. Miller 1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2C$$ $

I Office of the Executive Legal Director h

• f'##7 Attn Docke ts 50-400/401 0.L.

O W 500 c St $" N USNRC Or/9 Washinston DC 207h0 Washington DC 20555 Dan Read Docketing and Service Section (3x)

CF3?E /FLP Attn Docke ts 50-h00/h01 0.L.

Raleigh,r/07 Waveross Office of the Secretary NC 27606 USNRC Dr. Linda W. Little Washington DG, 20555 Governor's Waste Ngt. Bd.

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J hn R d le I"

• b 8 Granville Rd Chapel Hill Nc 2751h

• Bradley W. Jones Robert Gruber USNRC Region 11

'Travi s Payne Exec. Director 101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 30303 Blex 12601 Box 991 Naleigh NC 27605 Raleish NC 27602 Richard Wilson, M.D.

Certified by h

729 Hunter St.

Apex NC 27502

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