ML20137M003
| ML20137M003 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/26/1985 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | CAROLINA POWER & LIGHT CO., NORTH CAROLINA, STATE OF |
| Shared Package | |
| ML20137L975 | List: |
| References | |
| OL, NUDOCS 8512030580 | |
| Download: ML20137M003 (18) | |
Text
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, ! V DOCKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI&f h9V 29 P2 M9 r cre> : ,: -
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BEFORE THE ATOMIC SAFETY AND LICEN5ING'BdARD Glenn O. Eright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of s CAROLINA POWER AND LIGHT CO. et al. )
(Shearon Harris Nuclear Power Plant, Unit 1 )
)
Wells Eddleman's General Interrogatories -
to Acolicants Carolina Power & Light et al.
_ if48-03-8%ll) 2.7h1 and the Board's 9-22-62 Memorandum (s)
Under 100CFR 2 7h0,f Val M"3 c> h/sy$f and Orderff}+ Wells Eddleman recuestG Applicants V a are n o r s 4arate com v3 and fully in writing, under oath or affirmation, each of the p}
following interrogatories, and to produce a permit inspection and copying of the original' or best copy of all document's identified in resnonse to interrogatories as set forth below. -
These interrogatories are intended to be continuing in nature, and I request each answer to be promptly supplement a en ed.a 7 ancrocriate unden 10 CFR 2 7h0(e), should CPG, NCEMPA, .any other or any contractor or consultant to any, sone or all of those, 3 g Apolicant, Aor any em loyee of any or some or all of them, or any individual acting on behalf of any or some of all of them, obtain f g
$8 or create any new or differing information resconsive to these
- (whMt,4"Them" refeas to the preceding listing (s))
gf general interrogatorie . The rea.uest for production of documentr ,
DO GN1 di dlhe'd MarGh5 %
is also continuing and recuests Applicantsjto produce romet T
not immediately any additional documents the Applicants and others c3 a.c acting on their behalf or employed by them, as lis'ted in the previous
I, sentence, obtain which are responsive to the request (s) for nroduction of documents below.
Where identification of a document is re{uested, nicase briefly describe the document (e.g. book, notebook, letter, memo, report, notes, transcript, minutes, test data, log, etc.) and provide the document name, title, number, following information as a p licable:
author (s), date of writing or of nublication or both, addressee, the date aproved, by whom myyroved, and the name and address of' versens haing V normal custody of tha document, and name and addvess of any yerson other than the preceding having actual possess? nn of the document. When identifying documents in resnonse to these interroEatories and reouests, nisase state the portion or portiens of the document (e.g. sections, chafrs, pages, lines) upon which Applicants rely or which Ap{11 cents swear or affirm is/are responsive to the applicable interrogatory or veouest.
DEFINI"' IONS herein:
" Harris", " Harris Plant", "SENFP", or " plant" where not specified otherwise, all mean the Shearon Harris Muclear Power Plant.
consultants, "A p licants" means all of the persons, emuloyees, 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 *enort.
"ER" means the Harris Environmental Penort.
" Document (s)" means all writings and records of ever7 t yne, including electronic and ccvuter records, inthepossession, control licarts' or custody of Aplicants or any individual (s) acting on A behalf, including, but not linited to: venorts, books, memorande, corresnondence, notes, ninutes, pamphlets, leaflets, magazines, articles, surveys, naps, bulletins,photogranhs, speeches, transcripts,
- voice racordings, com7utsr printouts, information stored !n computers or comnuter peripheral devices such as disks, drums , etc. , voice reco-dings, m*crofilm, microfiche and all otrer writinEs or ncordings of any kind (s); and conies of any of the preceding even though the oriEi nal(s) are not in the possession of Applicants or in their custody or control. Document (s) shall be deened to be within the any control of Applicants or individual's) acting on their behalf if they have ownership, ossession, or custody of the document (s) or a copy thereof, or have the right to secure the document (s) or a coyv thereof, from any person or public or private entit7 having ph7sical possessien thereof.
Each definitton given above a lies within all other definitions above.
G S N E/2.A G ( W & k Oh0 Y G1 (a) Which contentiens of Wells Eddleman do Applicants agree are now admitted in this eroceeding, NoC Dockets 50-1400/l01 0.L.?
(b) for each such cententicn, provide f or any answers to' interrog-atories by Wells Eddlenan which Acclicants have pre viously or cresently received (except those suspended by Soar ( order, if any), the following information:
(c) Please state the name, present or last known address, and cresent or last known encloyer of each cerson whon Acelicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) ueon whon Applicants relied ( other than their I attorneys) in making such answer.
(d) elease identify all facts concerning which each such cerson isrHfied in resconse to G1(c)(1) above has first-hand knowledge.
(e) elease identify all facts and/ov documentsuponwhicheach nerson identified in response to G1(c)(2) above relied in protiding informationtorescondtotheinterrogatory,includingthe{ arts of such docunents relied ucon.
or (cl(Ed dfod ,
(f) Please identify any other docunent(s) used/by Aj licants in responding to the interrogatory.
(g) Please state which specific fact each docunent, identified in resconse to G1(e) and GL(f) above, sunports, in the ocinion er belief of Anelicants, or which Aenlicants allege such docunent supeorts.
(h) Please state specifically what information each nersen identified in resconse to G1(c)(1) or G1(c)(2) above orovided to or for Anplicants' affiant in answering the interroEatory. If any of this information is rot docunented, clease identify it as "undocunented" in resnonding to this sect".on of General Interregato y G1.
G2.a';Please state the nane, present or last known address, title (if any), and Dresent or last known amployer, and econonic interest (shareholder, bondholder, contractor, e7elo7ee, etc. ) if or other any @eyond exnert witness fees) such nerson holds in Applicants or exnect or an7 of them, for . each nerson you intendgto ce.11 as an. errert witness or a witness in this proceeding, if such informetion has not orevicusly been supnlied, or has changed since such information was l ast su: plied, to Wells Eddlenan. This applies to Eddlenen by Acclicants.
and Joint o= sticulated (b). Contentions as admitted'ntention
? lease identify each co regarding which each such person is expected to testify.
(c) Please state when you first contacted each such nerson with regard to the possibility of such norson's testifying for Apolicants, if you have contacted such person.
(d) Please state the subject matter, separately for each contention as to which each such person is expected to test?.fy, whicheachsuchpersonisexpectedtotertifyto.
(e) Please identify all docunents or carts thereo r ueon which each such witness is expected to, olans to, or will rely, in testifying or in preparing testinony.
-5 G3(a) #1 ease identify any other sou"ce(s) of information which Applicants have used to resnond to any inteprogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifying where in such source that information is to be found.
(b) Please identify any other sourceh)of information not trevicusly identified upon which any witness identified under G2 above, or or exhibits other witness, has used in urenaring testinenp/, or exnects to use in testimony or exhibits, identifying for each such source the witness who is exoected to use it, and the nart or part(s ) of such source (if applicable) which are expected to be used, and, if not (or both) ureviously stated, the f act(s) or subject matter to which such source relates.
and which Gh(a) please identify all documents,gpages or sections thereof Applicants int =nd or expect to use in cross-exaninatien of any witness I call in this hearing. For each such witness, clease crovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Acolicants believe they relate to, and nake the dccument(s) available for insoection form intent i
and corying as scon as cossible after Applicants decide orj Fturd to use such document in cross-examination.
(b) please identify any undocumented information Applicants i
intend to use in cross-exanination of each such witness for me.
G5 (a) for each contention Apolicants state or admit is an I
admitted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether Applicants have available to them experts, and information, on the subject matter of the contention.
l (b) If the answer to (a) above is other daan affirmative, state whether Aeolicants excect to be able to obtain exnertise in the subject matter, and information on it, and if not, why not.
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. (3 G-6(a) for each document identified in resnonse to any interrogatory herein, or referenced in resnonse to any interrogatory herein, please supply all the following infornatien which has not already
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been supolied:
(1) date of the document (ii) title or identification of document (iii) all authors of the document, o- the author (iv) all qualifications (professional, technical) of each author of the docunent of the document, (v) the specific narts, sections or nages, if any, unon which Aunlicants rely (vi) the specific infornation each nart, section or cage identified in resnonse to (v) above contains.
(vii) identify all documents used in overaring the docunent, to the extent known (and also to the extent not identified in the doc unent itself) y ShC' >rfal_ W CAL) ( M rip 6.f (viii) state whether Aunlicants jnossess a co-v of the p74p?fk" doctnent (ix) state all exnert oniniors contained in the document, upon which Acolicants rely, or identify each such opinion.
(x) identify the contention (s) with resnect to which Annif cants rely upon (a) the exnert oeinions (b) the facts identified in the docunent (xi) state whether Apolicants new ennley any author (s) of the document, identifying each such person for each docunent.
(xii) state whether Auplicants have ever emoloyed any authdis) of the docunent, identifying each such person for each document.
(xiii) identify all sources of data used in the docunent.
Answers to all the above may be tabulated or grouced for efficiency.
G-7(a) Please identify all documents which Applicants plan, exDect or a intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which (1) is included in your current resnonse to G1(a), or (ii) is the subject of interrogatories in this set; please state for which centention 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 perties' witnesses or joint intervenor witness in this proceeding, with resoect to (1) Eddlenan contentions identified under G-7(a)(i) (or G1-(e))
above, or any other Eddleman contention which is the subject of inter-rogatories in this set; (ii) each Joint contention now admitted in this proceeding; (iii) per our agreenent of h-8-83, each contention of each other party to this proceeding which is cu-rertly admitted.
Please identify for each such document the witnesses, or witness, and all contentions with resueet to whon (or which) that document is planned, expected, or intended to be offered or used.
(c) Please identify which of the documents identifkd in resnonse (1) to (b) above will be ofrevad into evidence by Anolicants, and (ii) which of the same documents Acolicants expect to offer into evidence or intend to offer as evidence or exhibits in this proceeding.
and/of spe6fic iute<<yalvna.s be[op#
G-10( a ) Where the above general interrogatories, or any of then, call for identification of documents, (1) and no documents sre identified, is that the sane as Apnlicants stating that tnere are no documents resronsive to this general interrogatory, in each case where no documents are identified? (ii) and documents a_re identified, is that the same as Aeolicants stating that the identified
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 affirnative, please state all reasons for your answer.
(iv) If your answer to G-10(a)(1) above is other than affirnative, please state all reasons for your answer.
(b) Where any interrogatory, general or scecific, herein, calls for factual information (1) and an opinion is stated in response, is that the exrert opinion cf any person (s) identified as having contributed information to that resnonse? (ii) and facts are given or identified (cr a fact is) in resnonse, but no documents are identified, does that mean Auplicants have no documents containing such fact (s)?
(iii) If your answer to (1) above is affirnative, please state for each each such resconse all cualifications of _ expert upon whom b
Auplicants rely for each such answer. The analifications need be stated only once for each such cerson if they are clearly referenced in other answers. (iv) if your answer to (1) above is other than affirmative, please state which oninions, if any, El ven in response to interrogatcries (general or snecific) herein is the opinion of an expert, identify each expert whose oninien you used in resnonse te each interrccatory, and s tate in full the qualifications of each such expert. (v) If your answer to (1) above is other than affirnative, please identify all opinions of non-excerts used in your resnonses, and identify each non-exnert whose coinion is included in each answer herein.
(vi) If your response to (ii) above is other than affirmative, please identify each document which contains a fact not previously docunented in your resnonse(s ), statinF what the fact is, and at what nage, niace, chapter or other scecific cart the docunent contains such fact.
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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 nade, (1) in whole (ii) in part (please identify each such part for each iten of infornaticn identified); (b) casts doubt on your answer (1) in whole (ii) in part (please identify each such nart for each iten of information identified). (c) Please identify all docunents not already identified in resnonse to narts (a) and (b) above (and their subparts) which centains any iten of information asked fcr in (a) or (b) above. Please identify fo" each such docunent what infernation iten(s ) it contains and what answer (s) each such iten is related to, G-12(a) In your previo s f nswers VDO.f where you have not identified documents, (i) 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 aninterrogatoryorphgtionthereof,pleaseidentifyeachset 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 identifyinn 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?
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G-13 Is there any merit or information or $ pinion supporting (a) all (b) any part(s) of Contentions referenced in these interrogatories? l (c) If your answer (s) to (a) or (b) are in any way affirmative, niease identify all such part(s), merit, information or oninion and identify all documents containing informatien or oninion which would suonort such contention (s) or part(s), and explain all such nerit(s).
(d) If your answers to (a) or (b) above are in any way negative, please for those answers, give all reasong and identify all docunents containing information relied on in making those answers. (e) Please state, and identify all documents containing any information relied unon or used by you in answering, all reasons not ereviously identified for your axnswers to G-1 thru 12, and to all naats of G-13 above.
G-EPX. Please answer all of Apn11 cants' and Staff's interrogatories to me on EPX-2 and E'X-8, including general inter"ocator-fully less, as if ble sane questions had been asked to you as ifgOs11 .
set out here. Please answer as if the term "your contention" means
" Contention EPX-2 and/or Contention EPX-8" in each such question or interrogatory, and daat "your contentions" also neans " Contention EPX-2 or EPX-8 or both".
Non-General Interroga to ries EPX-2-1. Please identify all documents related to each and every communications deficiency referred to or described in any way in
- nclud e s t e%ws' Contention EPX-2. This4ahanidnimmiada evalua tors } handwritten notes, tynewritten notes, tane recorded notes, all documents concerning the admission of contention EPX-2, all docunen ts concerning actions reconmended to be taken to deal with the deficiencies nentioned or referred to in EPX-2, actions that night be taken with resnect to any matters referred to in EPX-2, resconses to contention EPX-2, and records or information relating to any matter nentioned in Contention EPX-2.
EPX-2-2(a) Please describe, and identify all documents relating to, all " lack (s) of effective communications" during the energency planning exercise. (This refers, here and below, to the exercises held 17-18, 1985, re the Shearon Harris Nuclear Power Plant)
May(b) Please describe, and identify all documents relating to, all " lack of radiation nonitoring results" during the emergency planning exercise.
(c) Please describe, and identify all docunents relating to,
" lack of contact with field and ground units" during the energency planning 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, including (i) the bandwidth of such frequency,(ii) the frequency or frequencies in Hertz (cycles /
sechnd) (iii) the capacity of such frequency or frequencies in nunber of sinultaneous voice channels (iv) the number of unit (s) having access to such frequency (v) the number of units not involved in the energency olanning exercise having access to use of such frequency or frequencies (vi) the naximum number of units or callers trying to use such frequency at the same time (vii) the nature and extent of any misuse of such frequency or frequencies during the enercise or at other times. Please identify all documents relating to any of the above matters.
(e) Please describe, and identify all docunents relating to, the connunication inadequacies of the NC Highway patrol, carticularly those related to insufficient equinnent, ability to adequately handle the number of units resnending to an energency of the (nuclear plant) type, during the exercis e or otherwise ; the number of units of the Highway Batrol that did respond to the Harnis energency plan,ning exercise, and the number of frequencies available to those units and their base stations, relay stations, etc, and the canacity of each frequency for handling connunications, in the form of 2-way conversations in voice, or other capability for connunication.
Please identify all documents Gi ving information asked for above, or relating to any such information.
(f) Please describe, and identify all documents relating to, the number of telenhones available to the Harnett County energency personnel during t'he exercise, what a " sufficient" number of telenhones for then would be, or is; and any insufficiencies of the telephones available to Harnett County emergency response pe=sonnel during the exercise. Please identify all docunents giving such information or relating to any of the above taitters.
(g) Please describe, and identify all documents relating to ,
the amount of radio traffic in Chathan County during the exercise, the number of radio ope =ators on duty in Chathan County at all tines during the exercise, dae caracity of such onerators/disnatchers to handle radio traffic, the amount of radio traffic that was " extra" during the exercise in Chathan County, and the overloading of nersonnel on duty in Chathan County i due to extra radio traffic , the degree of such overloading, what eersonnel were ove-loaded, when, and fo" how lon6 Please identify all documents containing any of the infornation inouired about above, or relating to any part(s ) of such infornation, no natter how a sna11 a part or nart(s).
(h) Please describe, and identify all documents relating to, delays in Energency Medical Services Office receiving messages from SERT (State Emergency Response Tean). Please identify and nrovide 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 documents containing any of the above-recuested infornation, or rela ting to it.
(I) Please describe, and identify all documents rela ting to, communications oaths from the nobile k radiation lab to base statier(s)
I' that involved any relay or relay (s). Please identify each such connunication, its date, time, and contents and all documents relating to it; niease also identify the specific relay (s) that were used, by unit, location, relay nethod, frecuencies enployed, conmuni-cations method enployed, time involved in relaying, and content of message as relayed as well as content of message sent to be relayed.
Please identify all documents or recordings of such nessages, and all documents containing any of the informat' on inquired about above, or relating to it.
(j) Please describe the" possibility of demlayed and/or incorrect information" in relaying recorts fron the nobile radiation lab to base and all documents related to this natter and the state Padiation Protection Section evaluator's information about it, opinions about it, and statements about it, including any connunications to or from the evaluator concerning this oninion, or the evaluator's evaluation or statenents concerning the uossibility of delayed or incorrect information (or both) resulting from relays of information. Please also identify all documents relat'.ng to any of the above natters.
(k) Please identify all documents sent to or fron (1) evaluators (ii) other energency n1anning nersonnel (iii) FFMA staff (iv) PSC Staff (v) Anplicants or versons working for or with then (vi) other government officials, concerning the matters nentioned on referred to in the abovo interrogatories and parts and subparts, or concerning any matters rela ted to contention EPX-2 or na tters mentioned or referred to in it. Please note especially here that dr.is interrogatory is a continuing one.
EPX-2-3(A) With respect to every matter innuired about in any eart of Interrogatory EPX-2-2 above, niense provide the following infor-nation and identify all documents relating thereto:
(1) what action (s ) have been suggested, d1ought of, written down, recommended, considered or discussed concerning actions which night or should be taken to remedy any connunications deficiency identified or alleged with regard to this natter. (Please provide an answer to this part seoarately for each natter identified in resnonse to any part(s) of Interrogatory E'X-2-2(a) through (k) above, and for any matter inquired about in any of tdfe narts. )
(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 remedy or action, what equipment changes are involved in the action, the soecific equinnent (iten, nake, nodel, function) involved, the degree to which the action or re7edy does in fact solve the connunications nroblem, and please identify 41 documents relating to the above, particularly recommendations for action, authorizations for action, evaluation or remedies, statenents concerning completion of action, etc.
(iii) 'Jhat actions were reconnended or discussed or thought of, but not taken, to remedy each deficiency alleged in EPX-2 or inquired about in any part(s ) of interrogator 7 EPX-2-2 above? Please describe every such action, and all reasons why d each was no t taken, and identify all documents relating to s uch ac io , tg e 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 remedying any connunications deficiencies alleged in EDX-2 or inquired abo ut in E?X-2-2 above or any part of EPX-2-27 Please iden ti fy each such action, all docunonts reinting to it, all reasons why it is st*11 under censideration and when or if it is to be implemented.
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1 (v) *ihat actions are yet to be co7 eted to renedy any communications 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 19 schedulad to be nonpleted, who is in charge of conpleting it, what their authority and powers to complete it are, and when any portion (s) of it are to be conpleted. Please identify all docunents containing any information inouired about above, or information or ooinions relating to any such natters.
(vi) What barriers, financial, onganizational, bureaucratic, or otherwise, exist to the conpletion in a 100% successful nanner of any remedy or renedies (or actions to renedy) any connunications deficiency or deficiencies alleged a in Contention EPX-P or inquired about in any cart (s) of Interrogatory EDX-P-2 above?
Please identify and describe in detail each such carrier and what will be required to overcone it, telling whether it will be overcome, and if so, when, and with what resources and actions, and on what schedule any or all of those actions are being taken, and when and how any on all of those resources will be available . For each barrier or inredinent to any renedy for the connunications deficiencies inquired about above, niease give a specific description of the eroblem(s) the barrier or impedinent causes, and the snecific nersonnel, material resources, financial reqources, and othe" resources to be used to overcone each innedinent or barrier. Please give a schedule for the or innedinent overconing of each such barrier and identify all barriers oft innedinents g
that have not yet been overcone. Please identify all docunents relating to any inuedinent or barrier to innlenenting 100% effective remedies for every communications deficiency menticr.ed or referred to in Contention
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EPX-2 or inquired about in any nart(s) cf Interrogatory EPX-2-2 above.
Please identify all documents containing any other infornation inquired about above, nost particularly including the nature of the barriers or imoediments , the resources to be used to overcome daen, the schedule (s) for overconing then, and which 1 pedinents or barriers have not been overcome. ,, i q -C)
(vii) Please identify any other eroblem or circunstance th 3 could)
(un-b) or4would) interfere with achieving 100% renedying of all communications deficiencies mentioned or alleged in Contention EPX-P or inquired about in Interrogatory EPX-2-2 above. Please identyify all docunents relating to each such problem or circunstance and any schedule for or neans for dealing with or overconing such nroblen or circunstance. Please identify any docunents containing informatien 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 connunicat!.ons deficiency nontioned or alleged in Contention PPX-x2 or inquired about in Interrogatory EPX-2-2 above.
(b) Please provide the identifgication of all documents containing any other information available to you diat relates to renedying comnunications ueficienncies, particularly those alleged or nontioned in Contention FPX-P or inquired about in any nart(s) or Interrogatory EPX-P-2 above.
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EPX-8-1. Please identify all documents related to each and every inadequacy, inconolete use, problems with activation, inadequate coverage, or ineffective nanagenent of the Emergency Broadcast Systen (EBS),
including incomplete nessages and/or incomplete instructions to the public, inadequate procedures for activation and use of the FBS before the State assumes control, inadequate coverage of the energency area and/or the energency response area, inconcleto messages and incomnlete instructions to the nublic, and other oroblens with EBS activation (e.g. thos nentioned on nages 17-18 of FEMA's draf t renorts on the a
energency planning exercise at Sh ,earon Harris. ) This includes sound tapes, video tapes, actual content of nessages used during the exercise, transcripts of nessages used (I don't want the authentication codes, just the nessages themselves), reviewers' handwritten or other notes, i
note of persons observing the exercise or partickpating in it, logs of EBS stations as to what messages were sent and when, draf ts of the FEMA recort(s) on the exercise, and any other document (s) or records rela ting 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 oublic were inconolete during the exercise. Please identify all documents relating to such incompletenesses, for each message.
(d) Please describe, and identify all documents relating to, iSconnlete instructions to the oublic during the exercise, identifying each inconnlete instruction in each nessage, and telling what information would be required or is a required to connlete the instruction in each case. Please identify all docunents relating to any such incon lete ss or inconpletenesses, for one nessage or all messages or any conbinathon of nessages during t' exercise.
(o)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 documents rele 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 oninion, if different.
Please identify all documents relating to your onin'on or adeous te rules or standards for adeounte coverage o c the energency area.
(g) Please describe, and identify all documents relating to, inadequate coverage of the energency resnonse area dur!.ng the exercise.
Please also s tate what is adequate coverage of the energency vesnonse area by the "BS (1) according to annlicable rules or standards (ii) in your opinion. Please identify all doct nents relating to your oninion or to adequate rules or standards for e.deounte coverage of the energency resnonse area.
(h) Please identify all othern resnects in which the use of thne l
emergency broadcast systen (EBS) was inconf ete during the exercis e.
Please identify all documents relating to each such resnect in which use of the EBS we.s inconclete.
(I) Please identify all other asnects of EBS use which were inconclete or ineffectively nanagad or had nroblems duvi ng the exercise.
Please identify all docunents relating to each such nroblen.
, (J) Please describe and identify all docunents relating to standards which the EBS nust meet.
EPX-8-3(a) Please identify every aten er measure being taken to remedy each of the nroblens, inadequacies, deficiencies or other defects of E83 use at dheuron ilarris described, menticned or identified in Contention EDX-8 or asked abou t in any nart(s) of interrogatory EPX-8-2 above.
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(b) Please identify all barriers, imnedimenits or problems with a each sten or measure being taken to remedy each problem, inadequacy, deficiency or other defect in (Harrid EBS use that (1) could (ii) would prevent such sten or neasure fron being 100%
effective.
(c) Please s tate which neasures or stens to venedy any nroblen, inadecuacy, deficiency or other defect in[ harris)EBS use have been (1) thought of (ii) writtu down (iii) n onosed (iv) accented (v) rejected (vi) considered (vii) connleted (viii) scheduled to be concleted, nicase tell when each is to be comnleted (ix) kent under 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 consideration (iv) not considered.
(e) Please identify all docunents relating to any of the information or natters ing& mind inquired about above, enspecially those proposing man neasures or steps to remedy deficiencies, defects, problems or inadeq,uacies with the EBS, evaluating such neasures or s tens, decidine which to implenent, scheduling inplementation, evaluating the connleted neasures or stens for effectiveness, or rejecting or declining to consider any neasures or steps.
(f) Can the remedial measures and s tens so far connleted assure with 100% W confidence tha t all defects, deficiencies, inadecuacies and/
or problems alleged in Contention E"X-8, mentioned in Contention FPX-8, or inquired about in any nart(s ) Of Interrogatory EPX-8-2 above, will not occur mkam if the FBS nust be activated in a real nuclear emergency at Shenron Harris? Please nrovide til reasons for your answer and identify all docunents you use or rely on in naking your answer, all ouintons 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 naking your answer. Please identify all documents containing any of this information or opinion, and please also identify any documents containing information or opinions contrary to those you used or relied on, or Lnformation or opinions that would undernine or cor.tradict vour answer in whole or in nart.
(g) Please urovide all other information relating to EPX-8.
9E0 TEST F07 Po0 DUCTION CF DOCUMENTS Wells Eddlenan hereby reouests that Anolicants, and N90 and FEMA Staff, nake available the original or best cory of each and every ,
document (including tanes and other recordings, e.g. videotanes) identified in resnrnse to the above interroga tor,ies , for insnec tion and conying and a nutually agreeable e na and clace.
L T461s is the 26th of Govember,1985 # G) v,.__
.k l Wells Eddlena'n' N.B. I received a one-day extension to file this set of interrogatories, anproved by counsel for Anolicants and for N90 Staff (Dele Hollar, and Charles Barth, resnectively. )
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UNITED STATES OF AMERICA NUCLIAR REGULATORY C0! MISSION
- ' , i-In the matter of CAROLHAu POWER k LIGHT CO. Et al. )) Docket 50-400 Shearon Harris Nuclear Power Plant, Unit 1* 0.L.
'85C5fdifICMEOF SERVICE J
'felle "ddlennp 's 7nte-ror n torien I hereby certify?that copies of 00cx f , m; i vc, -
to Applicants, and WE Ittteirrogatorie s to FDC/FF?% Staff, on EPX-P and EPX-8 ;
and 4.E. Letter on 57-C-3 Exhibit numbers, HAVE been served this P6 day of r n ,. -% . 1985 , by deposit in the US Mail, first-class postage prepaid, upon all parties whose nanes are listed below, except tho se whose nane s are arked with an asterisk, for whom service was acconplished by I
$W9W CD(PH 0h /A/W%C] L, hodi'd, jQg,- Orgf wy, Judges James Kelley, Glenn Bright and Janas Carpenten (1 copy each)
Atenic Safety and Licensing Board
- Dale Hollar, Legal Dept.
US Nuclear 9egulatory Connission CP&L, Box 1551 Washington DC 20555 Raleigh, NC 27602 Geo?Ee F. Trowbridge (attorney for Applicants)
Shaw, Fittman, Potts & Trowbridge ]Luthanne G. Miller 1600 li St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2055 5 office af the Executive Legal Director (1 Spence W. Per g, NA 8 om 8 0 Attn Docke ts 50-400/h01 0.L.
USSRC flw g N.500 C St. SW Washington DC 20555 Washington DC 207h0 D*" d Docketing and Service Section (3x) CEA!ER'"/FLP Attn Docke ts 50-h00/hC1 0.L. Raleigh,7707 NC Waveross Office of the Secretary 27606 USNRC Dr. Linda W. Little Washington DC 20555 Governor's Waste Mst. Bd.
John Munkle (E Plan on1vi 51 Albenarle B3dg.
Steve 90ch'11s 32 N. Salisbu St.
CCNC Raleigh, NC 2 611 FEMA- Suite 700 P achtre NE Bradley W. Jones hp c 751h 132an Hokert Gr6ber USNRC Region II Travi s Payne Exec. Director 101 Marietta St.
Edelstein & Payne Public Staff Atlanta GA 30303 mex 12607 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D. Certified by .8t h 729 Hunter St* Al Cole Apex NC 27502 Attorney General'n Office Box 629 9aleigh, NC 27602