ML20098F736
| ML20098F736 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/28/1984 |
| From: | Hawkins T Federal Emergency Management Agency |
| To: | EDDLEMAN, W. |
| Shared Package | |
| ML20098F734 | List: |
| References | |
| OL, NUDOCS 8410030319 | |
| Download: ML20098F736 (14) | |
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RELATED CORRESP0t4DUICE EO UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION 34. g
.BEFORE THE ATOMIC SAFETY AND LICENSING BOARD b, ?? ? %m ~,..
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In the Matter of
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e CAROLINA POWER AND LIGHT COMPANY'AND )
NORTH CAROLINA EASTERN MUNICIPAL.
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Docket Nos. 50-400 OL POWER AGENCY-50-401 OL (Shearon Harris Nuclear Power Plant,
' Units-1-and 2) r FEMA RESPONSE TO INTERROGATORIES DATED AUGUST 31. 1984 PROP 0UNDED BY WELLS EDDLEMAN ANSWERS General Interrogatories INTERROGATORY 1.
What is FEMA's or NRC Staff's reviewers or affiant's understanding of the subject matter of this contention?
ANSWER:
EPJ 1:
Severe snow and ice conditions and their effects on evacuaticn times, and/or local and state capabilities to clear evacuation routes'are the subject matter of this contention but are not necessarily NUREG-0654 requirements.
FEMA Staff infers, from the ETE study, that these conditions are not sufficiently frequent in the Harris plant plume exposure pathway zone to warrant consideration beyond that which. presumably was included in the ETE study.
Regarding Section IV.E.8 of the State plan (page 50), FEMA Staff has no knowledge of_the number of snow plows available in or near the Harris 10-mile EPZ or the amount'of' time required to effectively clear the roads of snow or ice.
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EPJ-2:
NUREG-0654,. Appendix 4, requires that the ETE study include estimates ~of the number of people in the EPZ without transportation. The ETE study does include these estimates; FEMA has no basis for questioning the 240 figure estimate mentioned in this contention. NUREG-0654 does not require that the State plan provide an estimate of the number of people without transportation in the EPZ.
In regard to the portion of this contention which implies that the State plan should suggest the means people without transportation should use to get to pickup point and that the State plan should contain criteria for determining when and where the pick-up points would be
" established as required", FEMA Staff opinion is that the plan statement on page 47 meets FEMA guidelines.
EPJ-3:
FEMA staff has not yet formulated its position on this contention.
EPJ-4:
(a)-(d) FEMA Staff has no knowledge of the demographic characteristics of the school bus drivers, their trustworthiness, whether or not students have parental authorization to drive buses, etc. These types of investigations are not FEMA responsibilities.
EPJ-5:
FEMA guidelines do not require listings of non-ambulatory people in the plan. FEMA does encourage state and local governments to compile such listings, and we understand the state and local governments involved with the Harris plant emergency planning are currently making these compilations.
FEMA Staff will be more kncwledgeable about the number of vehicles available for transportation of non-ambulatory people after the Decem'oer 1984 exercise is conducted.
i y EDDLEMAN 57-C-7 27: According to the State plan, the RPS SOP's contain the-information asked for in this contention. NUREG-0654 does not require the lists to be included in the State plan.
EDDLEMAN 240-33:
See response under specific interrogatorv. An Appendix is unnecessary since an 50P listing is included at the conclusion of each part of ~ the plan. Also see response to specific Interrogato'ry 213-A-1(a) through -(g).
INTERROGATORY 2:
Has FEMA or NRC Staff made any analysis, inquiry, study or investigation into, (a) this contention (b) the subject matterofthiscontention(c)theallegation(s)inthiscontention(d) the basis of this contention (e) the information relied upon by intervenor(s) in this contention?
ANSWER:
FEMA Staff has read these contentions and the State and County plans under discussion. FEMA Staff has made no analysis, inquiry, study or investigation (AISI) into these contentions or their subject matter.
. INTERROGATORY 3:
For all parts of your response to Interrogatory 2 above for which your answer is affirmative, please provide the following information: who made the analysi.;, inquiry, study or investigation; what was being considered in such analysis, inquiry, study or investigation ("AISI"); the content of the AISI, the results of the AISI, whether the AISI has been completed, whether a date for completing the AISI has been established if it is not complete, what that date is, all documents used in the AISI, all persons' consulted in the course of the AISI, all documents containing information discovered or analysis or study or information developed during or as a result of the AISI (identify each such document and state what information or results it contains), whether staff believes additional analysis is warranted, or-further AISI needs or may need to be undertaken on this contention, and i
whether any persons participating in the AISI are to be called as witnesses for the Staff in this case, and what questions the staff AISI
-is' intended to answer and what information it seeks to develop if it is not complete.
ANSWER:
'N.A.
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- o INTERROGATORY 4:
From all responses to parts of (2) above for which NRC staff's or FEMA's, answer is other than affirmative, please state (a) whether NRC staff or FEMA plans to perform any AISI on this contention, (b) whether anyone on NRC Staff has stated that AISI of any one is warranted for this contention (even though it has not been made)
(c) whether NRC Staff plans for AISI on this contention include a date affirmative answers to (c)g such AISI, (d) those dates, for all for beginning or for endin above, (e) what AISI FEMA or NRC staff will undertake on this contention (f) what AISI NRC staff desires to undertake on this contention (g) all reasons why no AISI is planned on this contention if none is planned (h) all reasons why no AISI has been done yet on this contention if none has been done (i) what the responsibilities of NRC staff and of FEMA with respect to this contention are.
ANSWER:
(a) No; (b) no; (c) N.A.; (d) N.A.; (e) none; (f) none; (g) unknown; (h) unknown; (i) FEMA staff will respond to these contentions under the provisions of the Memorandum of Understanding between FEMA and NRC.
INTERR0GATORY 5:
Identify all documents the FEMA or the NRC Staff relied on in opposing the admission of this contention, and any specific facts not stated in the Staff's opposition to admission of such contention (already filed in this case) upon which Staff relied in making such opposition.
ANSWER:
N.A.
INTERROGATORY 6:
Identify all documents not identified in Staff's interrogatories to Wells Eddleman or to Joint Intervenors (to present -- a continuing interrogatory) upon which the Staff relied in making each such interrogatory.
ANSWER:
N.A.
INTERR0GATORY 7:
Identify by name, personal or business address, FEMA or NRC staff position or title (if any), and telephone number (if known) each person on NRC staff or consultant to NRC staff or known to hRC Staff or consulted by NRC staff in the staff's analysis of the subject matter of this contention prior to (a) its filing (b) it admission; state for each such person what analysis was performed by that person.
ANSWER:
N.A.
?
INTERROGATORY 8:
State all professional qualifications of each person identified in response to interrogetories 7, 3, 4.
ANSWER:
N.A.
-INTERROGATORY 9:
Provide any statements of the analysis made by persons identified in response to interrogatories 3, 4, or 7 above, and identify all documents containing such information or statements not previously identified.
ANSWER:
N.A.
IhTERR0GATORY 10:
Give the identifier number, date, source, and title of all documents identified in response to interrogatories above, which are available through NRC PDR (Public Document Room).
ANSWER:
N.A.
INTERR0GATORY 11:
Will NRC Staff make available copies of documents identified in response to the above interrogatories to Wells Eddleman for inspection and copying, for documents not available through NRC's PDR?
ANSWER:
N.A.
INTERR0GATORY 12:
Identify by name, FEMA or NRC staff position if
.any, address and telephone number each person whom NRC staff intends to use or call as a witness in this proceeding.
ANSWER:
Unknown.
INTERROGATCRY 13:
State fully the professional qualifications of each person identified in response to interrogatory 12 above.
ANSWER:
N.A.
INTERR0GATORY 14:
Summarize the position (or planned testimony) l with respect to each contention on which such person is expected to 7
testify, for each person identified'in response to interrogatory 12 l
above.
ANSWER:
N.A.
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INTERROGATORY 15:
Has FEMA or NRC Staff, any witness identified in response'to. interrogatory 12, or anyone acting in behalf of-the Staff or such witness or at their direction, made any calculation or analysis (not identified in response to interrogatories 1 through 4 above) with respect
- to this contention?
ANSWER:
N.A.
INTERROGATORY 16:
If the answer to interrogatory 15 above is yes
- in any case, provide the name, business or personal address. telephone number and professional qualifications of each person who has made such calculation or analysis, stating for each what contention it relates to, what person (or Staff) it was made for or at the direction of, and identifying all documents containing such calculation or analysis.and all documents used in making such calculation or analysis or relied upon in it or supplying information used in it.
ANSWER:
N.A.
INTERROGATORY 17:
Provide a summary of each AISI, calculation or analysis for which the answer to interrogatory 15, or interrogatory 2 above, is yes.
' ANSWER:
N.A.
INTERROGATORY 18:
Please give the accession number, date and originator of each document identified in response to interrogatory 16, which is available at the NRC PDR.
ANSWER:
N.A.
INTERROGATORY 19:
Will FEMA or NRC Staff make available to Wells Eddleman for inspection and copying all documents identified in response to interrogatory 16 above which are not available through the PDR?
ANSWER:
N.A.
INTERROGATORY 20:
Identify each person, including telephone number. address, and field of expertise and qualifications (complete) (if 7
any) who answered interrogatories with respect to this contention; if more than one person contributed to an answer, identify each such person, providing the information requested above in this interrogatory for each 4
such person, and state what each such person's contribution to the answer l
was, for each answer.
ANSWER:
Thomas I. Hawkins, John C. Heard (address, qualifications, etc.' attached to previous set of interrogatories, dated August 14,1984).
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INTERR0GATORY 21:
Identify all documents which the FEMA or Staff proposes or intends to use as exhibits with respect to this contention during this proceeding, including exhibits of Staff witnesses designated)g the witness for each, if such a witness has been (identifyin
, and exhibits to be used during cross-examination of witnesses of any party (stating for each which witness it is to be used in cross-examination of), and identifying for each the particular pages or chapters to be used as exhibits.
ANSWER:
Unknown.
INTERR0GATORY 22:
Identify all documents which FEMA or NRC staff relied upon in answering interrogatories with respect to this contention, which have not been identified in response to interrogatories I through 21above,statingforeachwhichanswer(s)orwhichcontention(s)itwas used for, and each specific fact and page number therein on which NRC staff relied or which NRC staff used in answering such interrogatory.
ANSWER:
None.
INTERROGATORY 23:
Flease give the accession number, date, and originator of each document identified in response to interrogatories 21 or 22 above which is available through the NRC PDR.
ANSWER:
N.A.
INTERROGATORY 24:
Will FEMA or NRC Staff provide Wells Eddleman with copies of the documents identified in response to interrogatory 21 or 22 above which are not available AT THE PDR, for inspection and copying?
ANSWER:
N.A.
INTERROGATORY 25:
Identify any other information or source of information not identified in response to the the above interrogatories 1 thru 24 on which you, or upcn which any member of NRC staff relied, or which any such 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 reliedoninsuchsource(e.g.pagenumber,section, chapter,etc).
ANSWER:
None.
INTERROGATORY 26:
(a) Does the Staff or FEMA now agree with the contention? (b) Does the Staff now agree with any,part of the contention?
1.
ANSWER:
(a)--No;.'(b) No.
INTERROGATORY 27:
.If answer to (b) above is affimative, which spart(s)_and why?
ANSWER:
'Given above.
Specific Interrogatories on Eddleman Contention 240
~ INTERROGATORY-240-1(a): --What agency of Chatham' County government is responsible 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 prepared to provide it)
'Chatham County government is responsible (or to be responsible)gency of
'atJall Chatham County shelters.
(c)
If anyone other than an a for decontamination of evacuees at any shelter in Chatham County, please list
- the responsible persons or. agencies for each such shelter.
(d) For each.
agency or person who has responsibility for decontaminating evacuees at V
- any shelter in Chatham County, what is the capability of each such agency or person to carry out such decontamination? Please address (i) establishment of radiological response teams (ii) training of these teams (iii) directing of these teams, fully in your answer, and fully and completely describe the capabilities of each such team to carry out decontamination 'of evacuees from a nuclear accident at Shearon Harris.
ANSWER:. '(a) Volunteer fire departments, rescue squads and the g
Landfill. Department, with support from Carolina Power and Light Company
.(and ' SERT, if possible) and under the direction of the Chatham County-
/ Department of Emergency Management'(Chatham County Plan, pages 33 s
14(b) unknown; (c) unspecified in plan; (d) unknown; (i)' Refer to Chatham 4
Co'unty PI'n,'pages 32, 35; (ii) See page 45, 46 of the Chatham County a
Plan; (iii) Chatham County Department of Emergency Management; (with k
assistance-from the RPS representative on SERT) unknown.
IThROGATORY240-2(a): Whichorganization(s)areresponsiblefor previding' support for decontamination of evacuees in Chatham County? (b) y s
3, d Tdentify each shelter for which each support agency, identified in
~ response to-(a) above, will or can provide support.
(c)Foreachsuch agency or shelter, what'are the capabilities to provide support for i!'
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decontamination of evacuees? (d) Flease identify all documents concerning responsibility for providing support for decontamination of j evacuees in Chatham County, who will provide.this support, the y capabilities of such support agencies, or the shelters where each such agency will (or is intended to. ) provide support for decontamination of etacuees.
/
'.-ANSWER:
(a).Answergivenaboveunder240-1(a)and(d)(iii);(b)
~ dnspecifiedinplan;(c)unspecifiedinplan;(d)NorthCarolina
~ Emergr.ncy Response Plan; r,erain' dor of known infonaation given above in interrogatory 240-1.
INTERR0GATORY 240-3(a):
Please identify all documents concerning the responsible agencies or agency of Chatham County which will provide
.l decontamination for evacuees from,a nuclear accident at Shearon Harris, including (i) which shelters each such agency has primary or backup responsibility for (specify the type of responsibility, i.e. primary, backup); (ii) the capabilities of each such agency for decontamination; (iii) the establishment, training or direction of Radiological Response Teams in Chatham County er 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 County, which information is used or relied upon 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 identi.fied that agency or person, or discusses or describes or evaluates that person or agency's capabilities for providing decontamination.
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ANSWER:
(a)(1) unknown; (fi. unknown; (iii) unkncwn; (iv) cnknown; (v) unknown.
Specific Interrogatories on Eddleman 213 INTERR0GATORY 213-A-1(a):
Does the Harris offsite emergency response plan now conform to evaluation criterion II.P.7 of huREG-06547 (b) If so, how? (c) If not, why not? (d) What additional information is required to bring the plan for the Harris plant into compliance with
' NUREG-06E! evaluation criterion II.P.77 (el When is this information now scheduled to be completely incorporated into the plan? When will all of the infcrmation required to comply with criterion II.P.7 be in the plan?- (f) when will FEMA begin review of this information submitted to ensure compliance with NUREG-0654 criterion II.P.7 for the Shearon Harris
off-site emergency response plan? When is that review scheduled to be completed? (g) Please identify all documents concerning (1) compliance or noncompliance of the Harris off-site Emergency Response Plan (ERP) with NUREG-0654 criterion II.P.7; (ii) information required to bring the Harris ERP into compliance with this criterion; (iii) actions required to being the Harris offsite ERP into compliance with this criterion; (iv) comments by FEMA or any other emergency planning agency, or any person (including consultants and staff of errergency planning organizations) concerning the compliance (or lack of compliance)(of the Harris offsite ERP with NUREG-0654 evtluation criterion II.P.7; v) drafts or information to be added to the Harris ERP to meet evaluation criterion II.P.7; (vi) ccuents on those drafts; (vii) evaluation of the Harris ERP (offsite) vs. NUREG-06S4 criterion II.P.7 by FEMA or anyone else.
ANSWER:
The Regional Assistance Comittee (RAC) along with the FEMA Staff reviewed the Harris Plan and found Item P-7 of NUREG-0654 to meet requirements. However, we have requested copies of all Standard OperatingProcedures(SOPS)listedintheplanforadditict:a1inforration and clarification.
INTERROGATORY 213-A-2(a) through (e):
Do you believe that all requirements of evaluation criterion II.P.7 of NUREG-0654 are met by the present form of the Harris offsite emergency response plan? (b) Please give all :easons for your answer to (a) including cites to every specific part of the plan which you believe detail or contain implementing prccedures, all parts of the plan which do not in your opinion contain sufficient impleenting procedures, and all reasons why you believe the plan in its present form does, or does not, fully comply with criterion II.P.7 of NUREG-0654. Please identify all documents containing information used in forming your belief or makfrg your answer to either (a) above or or above parts of (b).
(c)
If you don't know whether the Harris offsite ERP does or does not fully comply with evaluation criterion II.P.7 of NUREG-0654, do you plan or are you now doing anything to find out id it does? If so, what is to be done, and when is it to be completed? Please identify all documents containing your review of the Harris offsite ERP for NUREG-0654 criterion II.P.7 compliance, including documents containing any results of such review (s) or comments on such reviews or drafts thereof.
(d) What implementing procedures are required for an offsito emergency response plan in your opinion? (e)
Is there anything about the present form of the Harris of fsite ERP that (1) does (ii) does not, comply with evaluation criterion II.P.7 of NUREG-0654? Tf so, what does comply, and what does not? Please provide all reasons for your answer (s) including any documents or rules or review standards you used in making your answer or any review or :nalysis underlying your answer (s) or any part of your answers.
ANSWER:
See above response.
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INTERROGATORY 213-A-3(a): Where are the implementing procedures in the Harris offsite emergency response plan? Please list each one and explain why, in your view, it is an adequate (or inadequate) implementing procedure for compliance with NUREG-0654 criterion II.P.7.
ANSWER:
See abuve response, Specific Interrogatories on Eddleman 57-C-7 INTERROGATORY 57-C-7-1(a):
Do you know if any hospitals (1) listed on section V.B.3 of the Staff (offsite) Harris emergency response plan are not prepared to treat severe radiation exposure per se? (ii) r.ot listed in the Harris ERP section V.B.3, but (ii-a) local ITi-b) regional hospitals around the Harris plant, are not prepared to treat severe radiation exposure cases? (b)
If your answers to any part(s) of (a) or (b) abnve, or to (s) or (b) above, is affirmative, identify the hospital (s) and give all reasons for your answer.
(c) Please state what types or levels of severe radiation exposure (e.g. does up to 400 rem) each hospital 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 irjuries or expcsure.
ANSWER:
(a)No;(b)N.A.;(c) unknown;(d) unknown.
INTERR0GATORY 57-C-7-2(a):
Does the Harrir offsite ERP presently list (i) Iccal hospitals with the necessary capabilities to provide nidical services for those seriously injured by radiation alone? (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 hospital 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 capabilities? How do the capabilities of each such hospital meet or exceed the "necessary capabilities required to provide medical services for persons seriously injured by radiation, for (1) local hospitals (ii) regional hospitals, around 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 inspection or evaluation of the capabilities of hostdtals to provide medical services for persons seriously injured by radiation are (i) irrelevant (ii) objectionable (iii) outside the scope of this coritention, please explain fully how you know that any hospital 14s the "notessary capabilities to provide medical services for those seriously injured by radiation alone"? (e) Please identify all
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documents concerning each matter inquired about in each part of (a) thru (d)above.
ANSWER:
(a) unknown (b) unknown (c) unknown (d)N.A.(e)N.A.
INTERROGATORY 57-C-3(a): Please identify all documents concerning the question of whether the ability to treat severe radiation exposure per 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, consultants and staff of emergency planning organizations) concerning the compilance (or lack of complience) of the Harris offsite ERP with NUREG-0654 evaluation criterion II.P.7; (v) drafts or information to be addec to the Harris ERP to meet evaluation criterion II.P.7; (vi) comments on those drafts; (vii) evaluation of the Harris ERP (offsite) vs. NUREG-0554 criterion II.P.7 by FEMA or anyone else.
ANSWER:
NUREG-0654 does not require the ability to " treat severe radiation exposure per se".
(See NURFG-0654, II, L.1.).
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g-1 AFFIDAVIT.
The below subscribed persons hereby affirm, subject to penalty of perjury, that they have answered the Interrogatories of Intervenor Wells Eddleman as identified below.
The answers are true and correct to their best knowledge and belief as are also the attached statements of professional qualifications.
4 W.
%rd Thomas I. Hawkins 9/25/84
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1 Dated at Atlanta, Georgia this 25 day of September, 1984 I
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Thomas I. Hawkins Professional Oualifications
.My present position-is Emergency Management Program' Specialist for the Federal Emergency Management Agency.
I am assigned to the Radiological Emergency Planning liaison position between FEMA Region IV and the States of North and South Carolina.
In this position, I am' responsible-for the review of radiological emergency plans and preparedness for the State of North Carolina and the State of South Carolina and for the local governments within these States.
I have held'the position of Emergency Management Program Specialist (or its, equivalent) since December 1981.
.I have been employed by
-FEMA since July 1978.
-From April 1964 to. January 1977 I was employed as Planning Director-1
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of Clayton County, Georgia.
4 My formal education is as follows:
AB-Degree, Emory University, Atlanta, GA, 1958
' Master of City Planning Degree, Georgia Tech., Atlanta, GA, 1963 Completed Radiological Emergency Response Course at the U.S.
Department of Energy's Nevada Test Site, April 1982 Completed Radiological Defense Officer and Radiological Defense Instructor Course, Georgia Emergency Management Agency,
' Atlanta, GA,' March 1982 s
~ Completed Basic Management Seminar for Emergency Management Personnel, Valdosta State College, Thomasville, GA, Winter-Quarter, 1980 Completed Radiological Emergency. Planning Seminar, National Emergencp Training Center,' Emmitsburg, Maryland, October,1982 l
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