ML20137L985
| ML20137L985 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/26/1985 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Federal Emergency Management Agency, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20137L975 | List: |
| References | |
| 82-472-03-OL, 82-472-3-OL, OL, NUDOCS 8512030575 | |
| Download: ML20137L985 (14) | |
Text
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, ja' UNITED STATES OF AMERICA -
NUCIZAR REGUIATORY COMMISSION %ff?2b-96
'85 f!DV 29 P2:49 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bri Dr. James H.ghtCarpenter [NIMN g~ '
James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al.
(Shearon Harris Nuclear Power Plant, Unit 1 ) ASLBP No. 82-!/)1-03
,) OL Wells Eddleman's' Interrogatories to NRC Staff and PEMA )
( ., g . Set)
- and FEMA Wells Eddlenan here reonests the NRC StaffA to answer the following interrogatories before h 1955or such other date as counsel for the Staff l and I agree on. 'Ihese lnterrogatories are submitted under 10 Crit 2 720(h)(ii) ,PEMA I
and inquire into the studies, information, and knowledge of NRC staff with respect to my contentions on which discovery is now open. Since I cannot read 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 infornation by other means. Where the information is contcined in a document I can obtain fron NRC (Public Document Roon, etc), I still need the identification of the doc.2nent in order to obtain the information. The staff has resources and in ormation which exceed what I have, and as a party, their position and ir2ormation are necessary to making my case in this proceeding. These interroga-t rios are continuing in nature and should be supplemented when answers change.
GENEF.AL IICERROGATORIES , ' ~ ~
In all interroEatories herein, "you" or," Staff" means NRC Staff or' PEMA
- For each of contentione g?)( @% ' Eddlenan contentions7 g ,
please provide i.no fo11owing information by ' answering ead of these questions.
- 1. What s S ff' eYstan n th subject matter of this contention?
. 2. Ha bfb a the subject' matter of this contention li n into,(a) this contention (b) c) the allegation (s) in this contention (d) the basis of this contention (e), the information relied upon by intervenor(s) in support of this contentiont 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 analysis, 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 comple6ed, whether a date for completi the AISI has been established if it is not complete,
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l' in tha sourse of the AISI, en docun:nts contnining infcrmation discovarod
- or analysis or study or information developed during or es o rosult of ths . l AISI (identify each such document and state what infornation or results it contains), Wether 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 fcr the Staff in this osse,and d at questions the staff AISI is intended 4.
to answer and dat information it seeks to develop if it i answer is other than affirmative, phase state (a) eether NRC staff or-FEW l plans to perform any AISI on this con 1;ention, (b) whether anyone on NRC Staff has stated that AISI of any) 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.
(d) those dates, for an affirmative answers to (c) above. (e) Wat AISI ,
gd orNRC staff will undertake on this contention (f) Wat AISI NRC staff desiresl to undertake on this contention (g) an reasons *y no AISI is planned on '
this contention if none is planned (h) an reasons why no AISI has been l done yet on this contention if none has been done (1) what the responsibilities )
of NRC staff# with respect to this contention gma s, pare. c. \
& ceFene i 5
Identify an documents theJtaff relied on in opposing the admission of this contention, and any specific facts not stated in the Staff's opposition l to admission of such contention (already filed in this case) upon dich Staff ,
relied in making such opposition.
- 6. Identify all docunents not identified in Staff's interrogatories to l Wells Eddle-an or to Joint Intervenors (to present -- a continuing interrogatory ) ;
upon which the Staff relied in making each such interrogatory.
FEhh of !
7 Identify by name, penonal or business address.)IRC staff position l or title (if any), and telop.one nunber (if known) each person on NRC staff or consultant to NRC staff or known to NRC Staff or consulted by NRC staff in the staff's analysis of the subject matter of this contention prior to (a) its filing (b) its ad.ission; state for each such person what analysis was performed by that person.
- 8. State an professional qualifications of each person identified in response to interrogatories 7,, ' gh; .
9 Provide any statements of the analysis made by persons identified
[ in response to interrogatories 3,4, or 7a above, and identify an docunents i
I containing such information or statements not previously identified. ~
- 10. Give the identifier number, date, source, and title of all documents identified in response to interrogatories above, which are available through NRC PRIR (Public Document Room).
FM W
- 11. WinjiRC Staff make available copies of documents identified in t
response to the above interrogatories to Wens Eddleman for inspection j and copying, for documents not available through NRC's PIR?
I FEM W
- 12. Identify ty namenMRC staff position if any, address and telephone I
nunbar each person dom NRC staff intends to sxs use or call as a witness in this proceeding.
i 13. State fully the professional qualifications of each person identified l
in response to interrogatory 12 above.
. 3 14 Summariza tho positicn (or pisnned tastinony) with respect to each contention on which such person is expected to testify, for each person identified in response to interrogatory 12 above.
[n& W Hasj(EC Staff, any witness identified in response to interrogatory 15 12, or a gone acting in behalf of the Staff or such a 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?
- 16. If the answer to interrogatory 15 above is yes in any case, provide the nane, business or personal address, telephone number and professinnal I
qualifications of each person to has made such calculation or analysis, stating for each what contention it relates to, what person (or Staff) it was nade for or at the direction of, and identifying all docunents containing such calculationer analysis and all docu .ents used in r.aking such calculation or analysis or relied upon in it or supplying infornation used in it.
- 17. Provide a summary of each AISI, calculation or analysis idar. for which the answer to interrogatory.15, or interrogatory 2 above, is yes.
- 18. Please give the accession nunber, date and originat'o r of each ,
doeur.ent identified in response to interrogatory 16, which is available at the KRC PE.
A of C Staff make available to Kells Eddle .an for inspection and 19 all copying all ocuments identified in response to interrogatory 16 above Wich are not available through the P E7 j
- 20. Identify each person, including telephone nu .ber, address, and field f of expertise and qualifications (cor.plete) (if any) fa who answered ,
interrogatories with respect to this contention; if ore than one person I contributed to an answer, identify each such person, providing the inforr.ation requested above in this interrogatory for each such person, and state what each such person's contribution to the answer was, for each answer.
- 21. Identify all documents which th f oposes or intends to use :
as exhibits with respect to this contention during this proceeding, including Tv exhibits of Staff witnesses (identifying the witness fer each, if such a l
witness has been designated), and exhibits to be used during cross-exar.ination l
of witnesses of any party (stating for each which witness it is to be used
' in cross-exanination of), and identifying for each the particular pages or chapters to be used as exhibits.5 EVh o("
- 22. Identify all documents whicgEC staff relied upon in answering interrogatories with respect to this contention, tich have not been identified in response to interrogatories 1 through 21 above, stating for j each which answer (s) re which contention (s) it was used for, and each specific fact and page nu.ber therein on which EC staff relied or which EC staff used in answering such interrogastory.
1 l 23. Please give the accession number, date, and originator of each document identified in response to interrogatories 21 or 22 above which is available l l through the EC PDR. 1 l
24 M11, aNprovideWellsEddlemanwithcopiesofthedocuments identified,in response to interrogatory 21 or 22 above which are not available I at the PM, for inspection and copyingt l
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-h-25 Identify any other information or source of information not ONl identified in response to the aN reliefd, or which i
any 1thru2h1 0ub/1 such gp> Vmember upon ofwhich any inmember staff used, answeringofeach NRC%;he above interrogatory interrogator es 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 relie8 on in such source (e.g. page number, section, chapter, etc).
<FE01V 26 (a) Does the Staff,now agree with the contention? (b) Does thepjRc or Q'gg Staff not agree with iny part of the contention?
J7 If answer to (b) above is affirnative, which part(s) and why?
G-EPX. Please answer all of Aeolicants' and Sta*f's interrogatories to ne on EPX-2 and EPX-8, including gene ~al inter-ocator-fully iess, as if t.e sane questions had been asked to you as ifgasil;j set out here. Please answer as if the term "your contention" means "Contentien EPX-2 and/or Contention EPX-8" in each such question or interrogatory, and d.at "your contentions" also neans " Contention EPX-2 or E?X-8 or both".
Non-General Interrogatories EDX-2-1. Please identify all docunents related to each and every connunications deficiency referred to or described in any way in
- neludes t ei v 3' Contention EPX-2. This4xhaubdnixmhnda evalua tors } handwritten notes, tyeewritten notes, tane recorded notes, all documents concerning the adnission of contention EPX-2, all docunen ts concerning act!ons recommended to be taken to deal with the deficiencies mentioned or referred to in EPX-2, actions that night be taken with reseect to any matters referred to in EPX-2, resconses to contention EPX-2, and records or infornation relating to any natter nenticted in Contention EPX-2.
4h-EPX-2-2(a) Please describe, and identify all documents relating to, all " lack (s) of effective connunications" during the energency planning exercise. (This refers, here and below, to the exercises held May 17-18, 1985, re the Shearon Harris Nuclear Power Plant)
Qb) Please describe, and identify all documents relating to, all " lack of radiation nonitoring results" during the energency planning exercise.
(c ) Please desc=ibe, and identify all docunents relatf ng to,
" lack of contact with field and ground units" during the energency ulanning exercise.-
(d) Please describe, and identify all docunents relating to, the overloading of the energency inter-systen nutual aid frequency during the emergency n1anning exercise, includirg (i) the bandwidth of such frequency,(ii) the frequency or frecuencies in Hertz (cycles /
secknd) (iii) the capacity of such frequency or frequencies in number of sinultaneous voice channels (iv) the. nunber of unit (s) having access to such frequency (v) the nunber of units not involved in the energency ulanning exercise having access to use of such frequency or frequencies (vi) the naximun number of units or callers trying to use such frequency at the sane time (vii) the nature and extent of any misuse of such frequency or frequencies during the exercise or at other tines. Please identify all documents relating to any of the above natters.
(e) Please describe, and identify all docunents rela ting to, the connunication inadequacies of the NC Highway patrol, naaticularly those rela ted to insufficient equionent, ability to adequately handle the number of units resurnding te an energency of the (nuclear plant) tyne, during the exercise er otherwise; the number of units of the Highway Patrol that did resnond to the Ha""is energency planning exercise, and the nunber of frequencies available to these units and their base stations, relay stations, e tc , and th e c an ac ity of each frequency for handling connunications, in the form of 2-way conversations in voice , or other capability for connunication.
olease identify all documents giving infornation asked for above, or relating to any such information.
(f) Please describe, and identify all docunents relating to, the number of telechones available to the Harnett County energency versonnel duning the exercise, what a " sufficient" nunber of telenhones for then would be, or is; and any insufficiencies of the telechones available to Harnett County emergency response re=sonnel during the exercise. Please identify all docunents giving such information or relating to any of the above natters.
(g) Please describe, and identify all docunent e rela ting to ,
the amount of radio traffic in Chathan County during the exercise, the nunber of radio oce=ators on duty in Chathan County at all times during the exercise, d1e capacity of such o,erators/disnatchers to handle radio traffic, the amount of radio traffic that was " extra" duri ng the exercise in Chathan County, and the overloading of nerscnnel on duty in Chathan County i due to extra radio traffic, the degree of such overloading, what eersonnel were ove-loaded, when, and for how long.
Please iden'tify all documents contain!ng any of the 'nfornation inouired about above, or relating to any part(s ) of such infornation, no natter how a sna11 a part or part(s).
(h) Please describe, and identify all documents relating to, delnys in Energency Medical Services Office receiving nessages fron SERT (State Emergency Response Tean). Please identify and urovide a cooy of all nessages that were delayed, and give the m anount of time each was delayed and the content of each such message. Please identify all docunents containing any of the above-recuested infornation, or relating to it.
(I) Please describe, and identify all document s relating to, connunications oaths fron the nobile k radiation lab to base statirr (s)
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-p- p that involved anv relay or relay (s). Please identify each such ,
l connunication, its date, time, and contents and all docunents relating to it; niease also identify the snecific relay (s) that were I used, by unit, location, relay ne thod, frecuencie s encloyed, connuni-cations nethod enulayed, time involved in relaying, an d content of message as relayed as well as content of nessage sent to be relayed.
Please identify all docunents or recoadings of such ne ssaFes, and all documents containing any of the information inouired about above, or relating to it.
(j) Please describe the"cossibility of demlayed ani/or incorrect information" in relaying reports from the nobile radiation lab to base and all documents related to this natter and the state "adiati on Protection Section evaluator's infornation about it, onirions about it, and statenents about it, includ' ng any con .unications to o" fron the evaluator concerning tnis oninion, or the evaluator's evaluation or statenents concerning the nossibility of delayed or incorrect information (or both) resulting from relays of information. Please also identify all documents relat' ng to any of the above matters.
(k) D1 ease identify all docunents sent to or fren (i) evaluatows (ii) other energency planning nersonnel (iii) FF?!A staff (iv) FoC Staff (v) Anplicants or nersons working for or with then (vi) other gove"nnent officials, concerning the natters ment
- ored o= referred to in the above interrogatories and parts and subparts, or concerning any natters rela ted to contention EPX-2 or na tters nentioned or refe= red to in it. Please note esoecially here that dr.is interrogatory is a continuing one.
EPX-2-3(A) With respect to every matter incuired about in any cart of Interrogatory EPX-2-2 above, niease provide the following infor-nation and identify all docunents relating thereto:
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(1) what action (s) have been suggested, Unought of, written down, reconnended, considered or discussed concerning actions which night or should be t& ken to remedy any communications deficiency identified or alleged with regard to this natter. (Please urovide an answer to this part secarately for each natter identified in resnonse to any part(s) of Interrogatory E'X-2-2(a ) thro ugh (k) above, and for any matter inquired about in any of thse carts. )
(ii) what actions have been taken to remedy any of the connunic a tion deficiencies alleged in Contention EPX-2? Please identify for each the action, who takes it, the schedule for its connletion, any tests of the adequacy ,of the renedy or action, the results and any evaluations of such tests, any other evaluations nositive, negative or o therziwise of the adequacy of the renedy or action, what eauienent changes are involved in the a c tion, the seecific equinnent (iten, nake , nodel, function) involved, the degree to which the action or renedy does in fact solve the connunications nroblem, and clease identify all documents relating to the above, partic ularly reconmendations for action, audacrizations for action, evaluation or renedies, statenents concerning conpletion of action, etc.
(iii) 'Jhat actions were recennended or discussed or thought of, but not taken, to renedy each deficiency alleged in E?X-2 or inouired about in any part(s ) of interrogatory FSX-2-2 above" Please desevibe every such action, and all reascns why d, each was no t taken, and identify anbler to all docunents relating to such actioh,jghe descision not to take it, reasons why it was not taken, and other natters relevant to the descision.
(iv) What actions are still under consideration for renedying any connunications deficiencies alleged in EDX-2 or inquired about in EDX-2-2 above or any part of EPX-2-2? Please identify each euch action, all docunents relating to it, all reasons why it is stfl1 under consideration and when or if it is to be inplemented.
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(v) What actions av> yet to be conoleted to renedy any connunications deficiencies alleged in Contention EPX-2 or inquired about in any nart(s) of interbogatory EPX-2-9 above? Please identify each such action and all documents relating to it, to why it is to be done, why it was reconnended and by whon, why it has not been completed yet, when it is scheduled to be concleted, who is in charge of connleting it, what their authority and powers to connlete it are, and when any nortion(s) of it are to be conpleted. Please identify all docunents containing any infornation inouired abcut above, or information or coinions relating to any such matters.
(vi) What barriers, financial, o=ganizational, bureaucratic, or otherwise, exist to the connletion in a 100% successful nanner of any renedy or renedies (or actions to remedy) any connunications deficiency or deficiencies alleged z in Contention EPX-P or inquired about in any cart (s) of Interrogatory EoX-P-2 above?
Please identify and describe in detail each such barrier and what will be reouired to overcone it, telling whether it will be overcone, and if so, when, and with what resources and actions, and on what schedule any or all of daose actions are being taken, and when end how any on all of those resources will be available . For each barrier or inredinent to any renedy for the connunicat' ens deficiencies inquired about above, niease give a specific description of the eroblen(s) the barrier or incedinent causes, and the snecific personnel, naterial resources, financial regources, and othe* resources to be us ed to overcone each impedinent or barrier. Please give a schedule for the or impedinent overconing of each such barrier and identify all barriers of innedinents that have not yet been overcone. Please identify all docunents relating to any incedinent or barrier to innlenentd.ng 100% effective renedies for every comnunications deficiency nentioned or referred to in Contention
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-EB- l 0 EPX-2 or inquired about in any cart (s) of Interrogatory EPX-2-P above.
Please identify all documents containing any other informat! cn inqui ed about above, most carticularly including the natu=e of the barriers or imnediments , the resources to be used to overcome then, the schedule (s) for overconing then, and which 1 pedinents o* barriers have not been overcone. ,,
I" (vii) Please identify any other eroblem o= circunstance tha ,could (VE -b) or4would) interfere with achieving 100% renedying of all connunications deficiencies mentioned or alleged in Contention EPX-P or inquired about in Interrogatory EPX-2-P above. Please identyify all docunents relating to each such croblem or circunstance and any schedule for or neans for dealing with or overconing such nroblen or circunstance. Please identify any docunents containing infornatier about eroblens or circunstances which (vii-c) nay, or (vii-d) will, not be overcene, and which can or do interfere with achieving 100% effective remedies for every connunications deficiency nentioned or alleged in Contention EPX-x2 or inquired about in Interrogatory EPX-2-2 above.
(b) Please orovide the identifyicatien of all documents containing any other information available to you diat relates to renedying connunications deficiezncies, partic ularly these alleged or mentioned in Contention EPX-2 or inquired about in any naat(s) or Interrogatory EPX-2-2 above.
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EPX-8-1. Please identify all document s related to each and every inadequacy, inconclete use, problems with activation, inadequate coverage, or ineffective managenent of the Emergency Broadesst Systen (EBS),
including inconnlete messages and/or incomplete instructions to the nublic, inadequate nrocedures for activation and use of the EBS before the State assumes control, inadequate coverage of the energency area and/or the energency resnonse area, inconnlete me ssages and inconnlete instructions to the nublic, and other croblens with FBS activation T
(e.g. thosementioned on nages 17-18 of FE"A's draf t renorts on the emergency planning exercise at Sh earcn harnis. ) This includes sound tapes, video tapes, actual content of nessages used during the exercise, transcrints of nessages used (I don't want the authentication codes, just the ne ssages themselves), reviewers ' handwritten or other notes, note of persons observing the exercise or partie nating in it, logs of EBS stations as to what messages were sent and when, draf ts of the FEMA renort(s) on the exercise, and any other docunent(s) or records relating to these natters, whatsoever.
EFX-8-2(alPlease describe, and identify all documents relating to, ineffective management of the EBS during the exercise.
(b) Please describe, and identify all docunents relating to, EBS activation inadequacies during the exercise.
(C) Please describe in what ways and by what omissions nessages to the nublic were inconnlete during the exercise. Please identify all documents relatin6 to such inconcletenesses, for each message.
(d) Please describe, and identify all docunent s relating to, iSconclete instructions to the nublic during the exercise, identifying each inconclete instruct'on in each nessage, and telling what infornation would be required or is a reouired to connlete the instruction in each case. Please identify all documents relating to any such incompleteness or inconnletenesses, for one nessage or all nessages or any conbination of nessages during the exercise.
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(e)Please describe, and identify all documents relating to ,
any problens with EBS activation during the exercise. Please identify each such problem and senarately identify all documents relating to it.
(f) Please describe, and identify all docunents rela ting to, inadequate coverage of the energency area during the exercise.
Please state what is adequate coverage of the energency area according to (1) annlicable rules or standards (ii) your opinion, if dif#erent.
Please identify all documents relating to your opin'on or adecus te rules or standards for adeouate coverage o* the energency area.
(g) Please describe, and identify all documents relcting to, inadequate coverage of the energency resnonse area during the exercise.
Please also s tate what is adequate coverage of the energency vesnonse area by the FBS (1) according to annlicable rules or standards (ii) in your opinion. Ple a se identify all documents relating to your ouinion or to adequate rules or standards for adeounte coverage of the energency resnonse area.
(h) Please identify all otherz resnects in which the use of thne emergency broadcast systen (E3S) was inconplete during the exercis e.
Please identify all documents relating to each such resnect in which use of the EBS was inconclete.
(I) Please identify all other asnects of EBS use which were inconnlete or ineffectively managed or hcd eroblems du*i ng the exercise.
Please identify all docunents relating to each such naoblen.
(J) Please describe and identify all docunents relating to standards which the EBS nust meet.
EPX-8-3(a) Please identify every sten or nensure being taken to remedy each of the problens , inadequacies, deficiencies or other defects of EBS use at Shearon liarris described, nencicned or identified in Contention EPX-8 or asked about in any nart(s) of interrogatory FPX-8-2 above.
-ar (b) Please identify all barriers, immedimenits or nroblens with x each sten or neasure being taken to remedy each nroblem, inadequacy, deficiency or other defect in(Harrid EBS use that (i) could (ii) would prevent such sten cr neasure from being 100%
effective.
(c) Please state which neasures or stens to venedy any nroblen, inadeo.uacy, deficiency or other defect in Harris EBS use have been (1) thought of (ii) written down (iii) n onosed (iv) accented (v) rejected (vi) considered (vii) connleted (viii) scheduled to be connleted, clease tell when each is to be conoleted (ix) kent unde" consideration at present. Please note that this is a continuing interrogatory, as are all of these.
(d) Please give all reasons why each sten or ncasure asked about in (c) above was (1) accented (ii) rejected (iii) kent under co nsid eration (iv) not co ns idere d .
(e) Please identify all docunents relating to any of the i nformation or matters ing& mind inquired about above, ensnecially those nronosing xmm measures or stens to renedy deficiencies, defects, problems or inadecuacies wi th the EBS, evaluating such neasures or s tens, deci dine which to innlenent, scheduling inplenentation, evaluating the connleted neasures or stens for effectiveness, or rejecting or declining to corsider any neasures or steps.
(f) Can the remedial measures and s tens so far connleted assure with 100% i confidence tha t all defects, deficiencies, inadecuacies and/
or problens alleged in Contention EDX-8, nentioned in Contention T5X-8, or inquired about in any nart(s ) Of Interrogatory EPX-8-2 above, will not occur skan if the PBS nust be activated in a real nuclear energency at Shearon Harris? Please nrovide all reasons for your answer and identify all documents you use or rely on in naking your answer, all ooinions you use or rely on in your answer (and whose they are),
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and all other infornation or things you used or relied on in nakinF your answer. Please identify all docunents containing any of this information or opinion, and clease also identify any docunents centaining information or opinions contrary to those you used or relied on, or information or opinions that wculd undernine or contradict your answer in whole or in part.
(g) Please provide all other information relating to EPX-8.
FE01EST F07 FPOTCTION CF DOCDIENTS Wells Eddleman hereby renuests that Anolicants, and N70 and FEMA Staff, make available the original er best copy of each and every docunent (including tanes and other recordings, e.c. videotanes) identified in resnrnse to the above interroga tor,ies , for insnec tion and conying and a nutually agreeable d ne an d elace.
Tuis is the 26th of I;cvember,1985 Co n Wells Eddlenan N.B. I received a one-day extension 'jo file this set of interrogatories, anproved by counc?) ib Anolicants and for NSC Staff (Dele Hollar, and Charles Barth, sespec:ively. )
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