ML20096C399
| ML20096C399 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/31/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| OL, NUDOCS 8409050264 | |
| Download: ML20096C399 (13) | |
Text
No REUC ::7 ^C 2 DENCE 2.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION UN;9E PEFORE THE ATOMIC SAFETY AND LICENSING BOARD
(
/-%
Glenn O. Bright Dr. James H. Carpenter
'84 SEP -4 P3 :58 James L. Kelley, Chairman
' =lx ; M99 ;
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.O u s.
In the Matter of CAROLINA POWER AND LIGHT CO. et al.
)
(Shearon Harris Nuclear Power Plant,
)
Unit 1
)
)
)
Wells Eddleman's General Interrogatories to Anolicants Carolina Power & Light et al.
[Il y set)
Under 10 CFR 2.7h0, 2.7h1 and the Board's 9-22-62. Memorandum (s) andOrderfWellsEddlemanrecuestsApplicantstcv6 nC bekv"$r ks I+arate cauf
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C s coa and fully in writing, under oath or affirmation, each of the p14 following interrogatories, and to produce a permit insnection and copying of the original' or best copy of all document's ider.tified in resnonse to interrogatories as set forth below.
These interrogatories are intended to be continuing in nature, a en ed as andIreguesteachanswertobepromptlysupplement anorouriate under 10 CFR 2 7h0(e), should CP4T.,, NCEMPA,.any other j
A or any contractor or consultant to any, sone or all of those, g
Apolicant, Aor any em loyee of any or some or all of them, or any individual acting on behalf of any or som'e or all of them, obtain g
or create any new or differing information resnonsive to these listing ( n ) )
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("Them" refe=s to the precedingor prod ction of documentr nterrogatorie The reouest genera is also continuing and reauests Applicants to eroduce crow tly if not immediately any additional documents the Applicants and others acting on their behalf or employed by them, as J is'ted in the previous 8409050264 840831 n
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. sentence, obtain which cra rseponsive to the raquest(s) for nroduction of documents below.
Where identification of a document is reguested, clease briefly describe the document (e.g. book, notebook, letter, memo, report, 4
notes, transcript, minutes, test data, log, etc. ) and provide the document name, title, number, following information as applicable:
author (s), date of writing or of cublication or both, addressee, date aproved, by whom myyroved, and the name and address of the eersens ha'ing normal custody of tha document, and name and addvess of any ysrson other than the preceding having actual possession of the document.
When identifying documents in response to these interroEatories and reguests, please state the portion or portions of the document (e.g. sections, chafrs, pages, lines) upon which Applicants rely or which A licantsswearoraffirmis/areresponsive to the applicable interrogatory or veguest.
DEFINITIONS herein:
" Harris", " Harris Plant", "SENPP", or " plant" where not specified otherwise, all mean the Shearon Harris wuclear Power 71 ant.
" Applicants" means all of the persons, emeloyees, consultants, contractors and corporations as listed in the first sentence of the second paragraph on page 1 of this document, above.
"FSAR" means the Harris Final Safety Analysis *eoort.
"ER" means the Harris Environmental Fenort.
t "Documeni@" means all writinEs and records of ever7
- yne, including electronic and ccmuter records, inthepossessien, control licarts' orcustodyofAyplicantsoranyindividual(s)actingonA behalf, including, but not limited to: venorts, books, memorande, corresnondence, notes, minutes, paghlets, leaflets, magazines, articles, surveys, maps, bulletins,photogranhs, speeches, transcripts, 1
3 voice racordings, com7utor pi'intouts, information stored in computers or comnuter peripheral devices such as disks, drums, etc., voice recordings, microfilm, microfiche and all other writings or scordings of any kind (s); and cocies of any of the preceding even though the original (s) are not in the possession of Applicants or in their custody or control.
Document (s) shall be deemed to be within the any control of Applicants or individual's) acting on their behalf the docunent(s) iftheyhaveownership,nossession,crcustodyof or a co,y thereof, or have the right to secure the document (s) or a cop thereof, from any person or public or private entit7 having ph7sical possensien thereof.
Epch definitton given above a lies within all other definitions above.
G5NEPAG I*M(406ATDW G1 (a) Yhich contentions of Wells Eddleman do Applicants agree are now adnitted in this croceeding, N*C Dockets 50-400/401 0.L.?
(b) for each such contentien, provide for an: answers -to interrog-stories by Wells Eddleman which Aeolicants have previously or uretantly received (except those suspended by Board orcer, if any), the fo3 lowing intormation:
(c) Please state the name, present or last known address, and cresent or last known anoloyer of each person whom Apolicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) uuon whom Applicants relied (
other than their attorneys) in making such answer.
(d) ulease identify all facts concerning which each such verson idenHfied in resconse to G1(c)(1) above has first-hand knowledge.
(e)pleaseidentifyallfactsand/ordocumentsuponwhicheach nerson identified in response to G1(c)(2) above relied in pro #iding j.
informationtorespondtotheinterrogatory,includingtheparts of such docunents relied uron.
tv rellt Q (f) Please identify any other document (s) used/by A licants in responding to the interrogatory.
(g) Please state which specific fact each document, identified 1
in resnonse to G1(e) and GL(f) above, sunports, in the ouinion er belief of Aeolicants, or which Aunlicants allege such document supnorts.
(h) Please state specifically what information each person identified in resnonse to G1(c)(1) or G1(c)(2) above trovided to or for Anplicants' affiant in answering the int $rrogatory.
If any of this information is not docunented, nisase identify it as i
"undocunented" in resnonding to this sect'.on of General Interrogato7 Gl.
G2.a)? lease state the name, present or last known address, (if any), and uresent or last known syloyer, and econonic title interest (shareholder, bondholder, contractor, emolo7ee, etc. ) if or other any (beyond exnert witness fees) such nerson holds in Applicants or exoect or an7 of them, for. each nerson you intend to ce.11 as an. exnert j
witness or a witness in this proceeding, if such informe. tion has not ureviously been supnlied, or has changed since such information was last suoplied, to Wells Eddlenan.
This applies to Eddlenen o= sticulated by Annlicants.
and Joint Contentions as admitted'ntention regarding which each (b). Please identify each co such person is exnected to testify.
(c)
Please state when you first contacted each such verson with regard to the possibility of such norson's testifying for Apolicants, if you have contacted such norson.
(d)
Please state the subject matter, separately for each contention as to which each such person is expected to testify, whicheachsuchpersoniseyectedtotestifyto.
(e)
Please identify all documents or narts thereof unon which each such witness is expected to, nians to, or will rely, in testifying or in preparing testimony.
t
5 03(a) Please identify any other souvce(s) of information which Applicants have used to rescond to any inteyrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifyinE where in such source that information is to be found.
(b) Please identify any other source (s)of information not urevic.usly identified upon which any witness identified under G2 above, or or exhibits other witness, has used in urenaring testinen /, or exnects to use in testimony or eWhibits, identifying for each such source the witness who is exoected to use it, and the nart or part(s ) of such so urce (if applicable) which are expected to be used, and, if not (or both) ureviously stated, the fact (s) or subject matter to which such source relates.
and which Gh(a) please identify all documents,gpages or sections thereof Applicants intand or expect to use in cross-examination of any witness I call in this hearing.
For each such witness, please trovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Aeolicants believe they relate to, and nake the document (s) availab&e for insoection form intent and cocying as soon as possible after Applicants decide orjiximad to use such document in cross-examination.
(b) please identify any undocumented information Applicants intend to use in cross-exanination of each such witness for me.
135 (a) for each contention Apolicants state or admit is an ad itted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether qpplicants j
have available to them experts, and information, on the subject matter of the contention.
(b) If the answer to (a) above is other U2an affirmative, state whether Aeolicants exoect to be able to obt&in exnertise in
. the subject matter, and information on it, and if not, why not.
_ ()
G-6(a) for each document identified in resnonse to any interrogatory herein, or referenced in response to any interrogatory herein, please supply all the following information which has not already been supplied:
(1) date of the document (ii) title or identification of document (iii) all authors of the document, on the author (iv) all qualifications (professional, technical) of each author of the document of the document, (v) the specific parts, sections or pages, if any, unon which Applicants rely (vi) the specific information each nart, section or nage identified in resnonse to (v) above contains.
(vii) identify all documents used in nrenaring the docunent, to the extent known (and also to the extent not identified in the docunent itself) av Strde 4 %, W aw 60s9t+&j j
g/gpry (viii) state whether Applicants possess a co-y of the I doc ument (ix) state all exper opinions contained in the document, upon which Annlicants rely, or identify each such opinion.
(x) identify the contention (s) with resnect to which Annif cants rely upon (a) the exnert oninions (b) the facts identified in the docunent (xi) state whether Apolicants now ennloy any author (s) of the document, identifying each such person for each document.
(xii) state whether Applicants have ever emnloyed any authdis) of the docunent, identifying each such person for each document.
(xiii) identify all sources of data used in the document.
Answers to all the above may be tabulated or grouped for efficiency.
G-7(a) Please identify all documents which Applicants plan, exnect or a intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which (i) is ine uded in your current resnonse to 01(a), or (ii) is the subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is exnected to be offered.
(b) Please identify all documents which Auplicants nian, expect or intend to use in cross-exanination of any other parties' witnesses or joint intervenor witness in this proceeding, with resueet to (1) Eddleman contentions identified under G-7(a)(1) (or Gl-(s))
above, or any other Eddleman contention which is the subject of inter-rogatories in this set; (ii) each Joint contention now adnitted in this proceeding; (iii) per our agreenent of h-8-83, each contention of each other party to this proceeding which is cu=rently admitted.
Please identify for each such document the witnesses, or witness, and all contentions with resnect to whom (or which) that document is planned, expected, or intended to be offered or used.
(c) Please identify which of the documents identif5ed in response (i) to (b) above will be offecad into evidence by Anolicants, and (11) which of the same documents Apolicants expect to offer 9.nto evidence or intend to offer as evidence or exhibits in this proceeding.
ada/oy' specific ;Jfeggalanas bda),
G-10(a )
Where the above general interrogatories, or any of then, call for identification of documents, (i) and no documents are identified, is that the sane as Apnlicants stating that there are no documents resnonsive to this general interrogatory, in each case where no documents are identified?
(ii) and documents a_re identified, is that the same as Applicants stating that the identified
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documents are the only ones presently known which are responsive to the interrogatories ?
(iii)
If your answer to G-10(a)(ii) is other than affirmative, please state all reasons for your answer.
(iv) If your answer to G-10(a)(i) above is other than affirmative, please state all reasons for your answer.
(b)
Where any interrogatory, general or specific, horein, calls for factual information (i) and an opinion is stated in response, is that the expert opinion of any person (s) identified as having contributed information to that response? (ii) and facts are given or identified (or a fact is) in resnonse, but no documents are identified, l
does that mean Applicants have no documents containing such fact (s)?
(iii) If your answer to (1) above is affirmative, please state for each each such response all qualifications of _.. expert unon whom b
)
Applicants rely for each such answer.
The qualifications need be stated only once for each such person if they are clearly referenced in other answers. (iv) if your answer to (i) above is other daan affirmative, please state which oninions, if any,
)
given in response to interrogatories (gensral or snecific) herein is the opinion of an expert, identify each expert whose opinion you used in response to each interrogatory, and state in full the qualifications of each such expert.
(v)
If your answer to (i) above is other than affirmative, please identify all opinions of non-experts used in your resnonses, and identify each non-i expert whose opinion is included in er.ch answer herein.
(vi) If your response to (ii) above is other than affirmative, please identify each document which contains a fact not previously documented in your response (s), stating what the fact is, and at what page, place, chapter or other specific part the docunent contains such fact.
9-G-11 For each answer to each interrogatory herein (or any subpart or part thereof), please identify each iten of information in possession of Applicants (including facts, opinions of experts, and documents ) which (a) contradicts the answer you made, (1) in whole (ii) in part (please identify each such part for each item of information identified); (b) casts doubt on your answer (1) in whole (ii) in part (please identify each such part for each iten of information identified). (c) Please identify all documents not already identified in resnonse to parts (a) and (b) above (and their subparts) which contains any item of information asked for in (a) or (b) above.
Please identify for each such document what information iten(s) it contains and what answer $)
each such iten is related to.
fVdblf.?
G-12(a) In your previo s nswers where you have not identified documents, (1) have all relevant documents been produced in lieu of stating identification of each such document? (ii) do you rely on the entire document, since you have not identified parts or page numbers? (iii) if there are any particular parts or pages of each document produced, which you believe are resoonsive to an interrogatory or protion thereof, please identify each set of parts or pages in each document, together with the interrogatory or protion thereof (or interrogatories and/or portions thereof) to which it is responsnive.
(iv) where no documents are identified and identification of documents has been requested, are you saying such no documents exist?
Or that no such documents are in your possession?
(b) In your present answers, are you actually identifying documents where identification of documents is requested? (c) If not, how are you going to provide identification of documents?
Will that identification include statements of relevant pages or parts?
0~
Spscific Intorrogatorios on Eddleman 240 240-1(a) What agency of Chatham County government is resnonsible for the decontamination of evacuees at the Chatham County shelters?
(b) if different agencies have resnonsibility 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 vrepared to provide it) at all Chatham County shelters.
(c) If anyone other than an agency of Chatham County government is responsible (or to be responsible) for decontamination of evacuees at any shelter in Chatham County, please list the responsible nersons or agencies for each such shelter.
(d) For each agency or person who has responsibility for decontaminating evacuees at any shelter in Chatham County, what is the capability of each such agency or person to carry out such decontamination?
Please address (1) establishment of radiological response teams (ii) training of these teams (iii) directing of these teams, fully in your answer, and fully and comnletely describe the capabilities of each such team to carry out decontamination of evacuees from a nuclear accident at Shearon Harris.
240-2(a) Which organization (s) are resnonsible for providing support for dalhama decontamination of evacuees in Chatham County?
(b) Identify _each shelter for which each sunnort agency, identified in response to (a) above, will or can provide supnort.
(c) For each such agency or shelter, what are the capabilities to provide suoport for decontamination of ervacuees?
(d) Please identify all documents concerning resnonsibility for providing sunport for decontamination of evacuees in Chatham County, who will vrovide this support, and the canabilities of such sunnort agencies, or the shelters where each such agency will (or is intended to) urovide support for decontamination of ervacuees.
240-3(a) Please identify all documents concerning the resnonsible agencies or agency of Chatham County which will urovide decontamination for evacuees from a nuclear accident at Shearon Harris, including (i) which shelters each such agency has primary or backup resognsibility for (specify the type of resnonsibility, i.e. primary, backup);
(ii)the scapabilities of each such agency for decontamination (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 canabilities for providing decontamination for evacuees at shelters in Chatham Sounty, which information is used or relied noon by emergency planners of the State of NC or Chatham County; (v) any agency or person who is expected to provide decontamination for evacuees at any shelter (s) in Chatham County in the event of a nuclear accident at Shearon Harris, which identifies that agency car person, or discusses or describes or evalutes that person or agency's capabilities for providing decontamination.'
snig Specific Interrogatories on 213-a:
213-A -1(a )
Does the Harris offsite emergency resnonse olan now conform to evaluation criterion II.P.7 of NUREG-0654?
(b) If so, how?
(c) If not, why not?
(d) What additional information is required to bring the plan for the Harris plant into conoliance with NUREG-0654 evaluation criterion II.P.7?
(3e) When is this information now scheduled to be comnletely incorporated into the clan?
When will all of tha information required to ccmnly with criterion II.P.7 be in the pian?
{.__
213-A-1 continusd (f) when will FEMA begin feview of this information subnitted to ensure comuliance with NU990-0654 criterion II.P.7 for the Shearon Harris off-site emergency response plan?
When is that review shheduled to be comoleted?
(g) Please identify all documents concerning (i) comoliance or noncomoliance of the Harris off-site Emergency Resnonse Plan (E9P) 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) concernine the cono11ance (or lack of compliance) of the Harris offsite ERP with NPREG-0654 evanluation 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 draf ts;(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 plani?
(b) Please give all reasons for your answer to (a) including cites to every am specific part of the plan which you believe detail or contain impletmenting urocedures, all parts of the nian which do not in your opinion arntain sufficient innlementing procedures, and all reasons why you believe the plan in its present form does, or does not, fully comply with criterion II.P.k? of NUREG-0654 Please identify all documents containing information used in forming your belief or making your answer to either (a) above or above narts 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 NU9EG-0654 criterion II.P.7 como11ance, including documents containing any results of such t
review (s) or comnents on such reviews or drafts thereof.
i (d)
What imolementing procedures are required for an offsite emergency response plan xx in your ouinion?
l (e) Is there anything about the present form of the Harris offsite ERP that (1) does (ii) does not, conoly with evaluation criterion II.P.7 of NUREG-0654?
If so, what does comply, and what does not?
Please provide all reasons for your answer (s) including any Ami 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 offsite emergency response nlan?
Please list each one and exxplain 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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HZ' Interrogat:rios on 57-C-7 57-C-7-1(a) no 7-u know if any hospitals (i) listed on section V.B.3 of the Stsia (offsite) Harris emergency response clan are now prepared to treat severe radiation exposure Ler se?
(ii) not listed in the Harris ERP section V.B.3, but (iiCa) local (ii-b) regional hospitals kaum 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 (a) 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 hosoital 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-x2(a)
Eces the Harris offsite ERP presently list (i) local hospitals with the necessary capabilities to provide medical services for those seriously injured by radiation alone ?
(ii) regional hospitals with the necessary canabilities to l-provide medical services for those seriously injured by radiation alone?
(b) what capabilities do you maintain each such hosoital i
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 i
those capabilities?
How do the canabilities of each such hospital meet or exceed the "necessary capabilities" 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 radiat? on, for (i) local hosnitals (ii) regional hosnitals, awound 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 versons 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 medical services for persons seriously (iii) outside the scope insjured by radiation 1
are (i) irrelevant (ii) objectiohable of. this contention, please a explain fully how you know that l
any hospital has the "necessary capabilities to provide medical i
services for those seriously injured by r adiation alone2"?
l (e)Please identify all documents concerning each matter inquired
)
about in each part of (a) thru (d) above.
I 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 1
(iii) any NRC rule (iv any applicable law or requirement, includinE the Atomic Energy Act.
PRODUCTION OF DOCUMENTS Wells Eddleman hereby requests that the original or best copy of each document identified $n response to the above interrogatories be vroduced for inspection and copying at a mutually agreeable time and place.
Wells Eddleman 8-31-8k
.o UNITED STATES OF AMERICA NUCLEAR REGUIATORY C0!CCSSION In the matter of CAROL!hA POWER k LIGHT CO. Et al. )
Docket 50-400 Shearon Harris Nuclear Power Plant. Unit 1*
)
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CE!!TIFICATEOF SERVICE W.E. Interrogatories to Applicants /NC I hereby certify that copies of Emergency Planners on contentions 240, 215-a and 57-0-7, and of W.E. Interrogatories to NRC Staff / FEMA Staff on the same contentions HAVE been served this 31 day of August 198L, by deposit in the US W il, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are parked with an asterisk, for whom service was acconplished by enission fvnn sefvice per oral order of March 1983 Jud es Jales Kelley, Glenn Brigh and James Carpenter (1 e gy each)
E Atomic Safety and Licensing Board US Nuclear Megulatory Comission Washington DC 20555 George F. Trowbridge (attorney for Applicants)
Shaw, Pittman, Potts & Trowbridge
- (R uthanne G. Miller 1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 255 5 Office of the Executive Legal Director h
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Attn Docke ts 50-400/401 0 L.
O %d 500 c St USERC Orl$ Washington DC 207h0 Washington DC 20555 Dan Read Docketing and Service Section (3x)
CEA!LT/FLP Attn Dockets 50-ko0/hc1 o.L.
Waleigh,$707 Waveross
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Office of the Secretary NC 27606 USNRC Dr. Linda W. Little afashington DC 20555 Governor's wast. Mst. Bd.
513 Albenarle Bids-John Runkle 325 N. salisbutw St.
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- Granville Rd Chapel Hill Re 2751h
- Bra diey W. Jone s Robert Gruber USFRC Region II
'Travi s Payne Exec. Director 101 Marietta St.
Edelstein & Payne Public Staff Atlanta GA 30303 Rex 12601 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D.
Certified by 4t h 729 Hunter St.
l Apex NC 27$02 l
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