ML20138R096

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Responses to Applicant 851125 Emergency Planning Interrogatories & Request for Production of Documents (Third Set).Related Correspondence
ML20138R096
Person / Time
Site: Harris Duke energy icon.png
Issue date: 12/22/1985
From: Eddleman W
EDDLEMAN, W.
To:
CAROLINA POWER & LIGHT CO.
References
CON-#485-615 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8512300380
Download: ML20138R096 (14)


Text

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7 aguu t.9 .,e<6nts: orWM igg UNITED STATES OF AMERICA P3 ggcenber 1085 N NUCLEAR REGULATORY COMMISSION

'35 ggg ,, fW BEFORE THE ATOMIC SAFETY AND LICENSING BOA!1D Glenn O. Bright ML,n .

Dr. Jatles H. Carpenter ' yj"c1" m 4" James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Unit 1) ) ASLBP No. 82-1468-01

) OL Wells Eddlenan's Resnonse to Annlicants (EPX)

Energency Planning Interrogatories and Request for Production of Docunents (Third Set)

Wells Eddle, nan hereby responds to Anplicants' Interrogatories dated 11/25/85 as follows:

RESuoNSES TO INT"9'0GATORIES General Interrogatories: 1(a) See answers to snecific interrogato-ries below: (b,c) sane as (a).

2(a) Lisa Finaldi, address at nresent not known, telephone 755-Also (see 0-3) Betsy Levitas, 212 N. 31(lodworth St. 9aleigh P7601 0361 or 832-P971;4see also resnonses to snecific interrogatories.

Last known ennleyer was Sierra Club D.adioactive Waste Campcign, 78 Elnwood Ave , Surfalo , NY, lltP09. (b) see snecific interrocatory a answers below. (c)(i)the evaluators presunably have exnertise or knowledge in the fields or narts of the exercise they evaluated, g although I have not yet independently assassed their eznertise.

gg (11),(111) N/A at this coint. (d) see (a) althouch I do not believe no S$ that resnonse is recuired by the Licensing Board's nenorandun and order n

% of 5/27/83 and other objections could be raised; I do not here waive

$$o an rightlicensing to object to this interrogatory or its nresunntions about the 5/ 7/83 board order, g

-P.

3(a) Although I have not connleted niannine what witnesses to call, it is fair to assume I will call the evaluators whose connents forn nart of the basis for, or relate to , any nart(s ) of Contentions FDX-P or EPX-8 or both. These would include (info. suonlied by B. Levitas and/or L. Finaldi, most of these neoole being identified in the state evaluation renort on the exercise, which Finaldi has; I cannot locate a cony here):

EPX-2: Max Powell, Snecial Assistant to Connissioner, f70 Dert of Insurance, 733-73h3 (statewide designated frecuanev uso cnd nublic information suut off MNK W'dBad +

otherjconnunications nroblems; ) ice Bo N b ey,iN ef of Office of

'mergency Medical Services (State of NC), Raleigh, 733-PP85 (deley in getting nessages back to EMS; information EMS did not receive (e.g.

when controlled release hannened); other connunications difficulties; any relationship of connunications to dicricultf es in c.oving ambulances at 'Anex staging

  • area); Crystal Stowe,  ?'O Dent of Crtne Control and Public Safety, State Public Information Officer, 733-5027:

any connunications difficulties in nublic infornation, etc, and in energency response (attemnts, repeated, to communicate with Ms. Stowe have not been successful. Mr Al Joyner (Joiner?) of NC dont CCPS Office of Fnergency (Managenent), 733-3867, referred Finaldi to Ms. Stowe.)

Cant. Teen, HC State nighway Patrol, Raleigh District, Troop C, *lcke Country, 733-3911,( telenhone problems, difficulties with radio systens, lack of infornation from the ninnt to Enn"gency Onorations, capabilities of radio systens, connunications with troopers being called in from across the state during an energency, other connunicat$ ons r133 a f 6 2 difficulties); nossibly Gil Greed of 9adiation Urotection Section

G 3 3- 4 L?3 Johnny James of 993, UC Dent Hunan Pesou"ces , says he did not do the 4

evaluation although his name appears on it; Green did it,and r#nn1{,d>'

will try to reach him Monda'y (12/P3)whileI'moutoftown.}

_3_

possibly Lieutenant (formerly Sgt. ) G.S. Ake, 779-170h, Fighuay Patrol Evaluator, who has not been reached yet; nossibly others as both conversation and meeting with nersons having knowleine of the exercise and nonsures being taken to deal with the problens revealed is ongoing, and af ter discovery other nercons or nroblenc ( e . g . uf th attenpted or nronosed resolutions) or connunications difficulties nay be revealed:

EPX-8:

nossibly the authoF of the connents on E33 at Dn 17-10 and 19 of the FFMA inter!n findings (re, EPX-S and nnoblens with F3s and conference call, problems with EBS activation, verification, etc. );

nossibly, nerson who has custody of the EBS lors at UOD9-Ftt and WPTF-AM, Raleigh, if the validity of copies of these logs cannot be established by affidavit (this may be Charles Stena11, 832 8311), concerning tintne and content of nessages that ran, any indications of difficulties, etc).

again, conversation, inquiries on this contention continue, authors of other comnonts on the rBS's nroblens and nroblems gettinF info thvouFh it to the oublic nay be called, and discovery may reveal (I exnect it should) further information).

(b) cee (a) but note the infornation is inconnlete at nresent; (c) seu resnonse to 2(c)(1) above; I exnect no"e infornation to be revealed on discovery an? becc~e available through talking with nersons name d and with others , interviewr , e tc.

h(a) I relied on ny knouledge of the UCS v NDC decision establishing that energency n1anning exercise deficiencies are litigable; on the reouirenants of 10 CFR $0.47(n)(1) that there must be reasonable assurance that adenunte nrotective neasures can and will be taken in the event of a radioloE i cal energency; on the fact that real emergencies are not usually announced in advance and thun will create diffic ulties thn t do not exist in an exercise, conpounding any nroblens revealed in an exercise which denend on resnonres by norsennel or ecuinnent $n niace

.h-that n16 ht have to be delivered er brought in or used suidenly (e.g.

under emergency communications conditions with heavier loads on nhones and co$nunications equipnent, under heaview loads of real nrassure on personnel during a real emergency, under uncertainty and confusion as the real energency does not have a knowable or predic table scenario or course of events, etc. ; on the fact that 10 099 50.h7(a)(2) says FEMA findings are a rebuttable nresunction; on the recui*ement that actual nerfornance and the fact of nonconnliance is litigable even if there are oronises to correct problens (i.e. nronises to fix things have no legal standing to sunnort a finding as recui*ed by 50.h7(9 )(1));

, on the requirencnts of 10 CRa 50.h7(b), including the recuirenents of (b)(1) and (b)(2) to be able to augnent resnense on a cort'nuous basiss (nresunably to take care of difficulties as they arise, and overcone then)

(nresuning that could be done), (b)(3)'s recuirenent for e#fectively using resources, (b)(5)'s requirenent for notification (nresunably this has to be pronnt and effective and connunicate needed information),

(b)(5)'s recuirenent for early netificatt er and clear instruction connunicated tc norsons in the EPXZ,(this and (b)(6) are ~oet heavily relied on for EPX-8), (b)(6)'s recuirenent of nrovisions for nronnt and effective connunications among unincinal res"onse organizations, to energency nersonnel and to the nublic (obviously, if communicat* on is not working well, these nrovisions ave not effective and nay not be proMot where connunicat'.on is delayed)(this n"ovision is also stroncly relied on re EPX-2); (b)(88's) reouironent for adequate energency facilities and ecuinnent (e.g. for the TBS and conmunications with the field, the nublic and among enargency resnonse organizatione and personnel)(this probision is relied on throughout EPX-2 and -8)

(b)(9)'s recuironent of adequato nethois, systens (includinc ce nnunica-tion to renort results) snd cou'unent for assessing and nonitoring actual on notential offsite consequences of a radiological energency

condition, which must be in use, nore re EPX-2, but velates to EDX-8 in that inadequate info or connunications problens, erroneous connunicata-ions or. delays may delay activation of EBS or cause nisleading info i to be given to the nublic); (b)(10,11,nnd IP insofar a s commun* cat

  • nas i

or EBS nroblens can lead to these requirements not being met); (b)(1b) requiring uroblens to be corrected if detected during the exercises;

.(c)(1) requiring that all the naragranh (b) standards be net before 1

an operatin6 license is issued; 10 CF9 50.57(a)(2)/a)(3) and (a)(1) recuiring connliance with all the NOC's rules and reculat' ons to Fet an operating license; Evaluat'on 9enort, shearon Harris ruclear "ower olant Exercise. (EPX-2) pn. 1h,15,16 ("could have seve e bad e cfects in a real energency" (ennh added), overloading of nutual aid frecuency made connunications with ground units on the nutual aid frecuency incassible, reconnendation to ungrade also sunnoats this and the "real world energency oroblen, see nn 1h-15; SHP system quickly overworked, but was the only reliable source of contact, n.1h), n.5, insufficient Harnett Co. tele 9 hones; extas rnei o t-affte ove-loaded naasonnel 1

in Chathan Co., p.h, also suonorts 1cter remarks about ninuse, overload 4

of connon energency frecuency (n.h, c"nnents "later', n.14); n.6, delay of nossages received both by hard cony and phone in Unke Co.

l ("could have nevere bad effects in a real ena*cency,

  • ncludinc . . . etc ." )

p.8, highway natrol connunicationn nroblems : "equinnent, wh&ch is designed to suonort our statutory nission, is not yet canable of adequately handling the innact of so nany units resnonding to an I emergency of this tyre" (cf. contention, "The Highway Patrol evaluotor found . . .tyne"), n.9 reconnendation 1, sunnorts corld have severe bad effectc and sunnorts statement just ouoted fren contention nnd suonortst statement on n.8 ; p.11 EMS "excessivo delays" of alnost an houP ,"evacuatien nessures ani nensngcP *e"tn'n'r.c te nonir'atentnr

potassiur. iodide (" lodine" in evclunt!cn), etc , cc uld !.t.ve negntive i

consequences if not received ranidly", this last directly sunnorts "could have severe bad effects . . . etc." and sunnorts it even more stron61 y in conjunction with the "alnost an hour" delays, which could nake KI adninistration useless , e.g. , o" easily evoid "acnnt notic* ent'en l of the nublic or energency response personnel. P.1P, connunientions difficulties in iten 6, cf. content *.on "connunientiens from the nobile radiation lab ... State radiation nrotection evaluntor", direct sunnort; lack of trut ning etc. , naocedures, checklist, ite,ns 1-5, indirect l sunnort for this ntrt of content'on s'rce "delnyed and /or inco=~ect l

! infornation" con enure n"oblens. Th?.s all niso surnoats the "could l

have severo bad effec ts". Note that the se are only examples ; their interaction, and the effects of the real world on those parts that don't nention real-world (real accident) effects, would only connound the problens, leading to nore sunnort for the "could have severe had i

effects . . . etc." sec tion of tha contention. I corsider the contention t

l as a whole, dealing with connunientions, and not as a catalocuc.

i l EPX-8: See contentirn; nrocedures for activation and use of TBS before s tate assunes control, PT'A Inta"in Denoat, n.19 botton; n.13,  ;

l f 0 4.b; inadequato coverage, ibid (n.12 botton, n.13 0.h.b); inconnlete r l nessages, n.12, see also n.13 0.h.b. Need to reco1ve neoblen 0 h7 l o(21 0 ,

(b ) (5 ) , ( b X6 ) , (n )(1), (b)(1h ),10 CF9 50 57(a )(P),(n )(3 ),(n)(1) etc.

! see above also, annlies to both TSX-8 and E"X-2 down to "Mnx-2", sect &on) i (b),(c), see (a) 5(a) one nono of notes fran netwy Levitas, unanted; two rares of tyned notes from List Finnidi, IP/P0/85; one nace writtnn notes by ne from thone cL11 from Lisa Finaldi, IP/19/85; other documents as cited.

(b) Epx-2 and Epx-8; Levitas document annenrn to be F"X-P only but not ,

certain. See snecific resnonces, to both rene*al nnd snectric '.nts.

6(n) Advice of unidentified exce"t (identlty withheld). I object to revealing this corson's identity beenuce they w rot tent *fy ond would be subject to harassnent, etc. I niro object te revenlinr l ,

l

any docunents, notes or identities re ny legal strategy on these i contentions since these are work naoduct c e ne ned /o" advise =s net'nt-

~

as ny Icgal counsel. (b) Oojection, see (a) 7(a) not identified yet, but you can exnect relevant nortions t

(including those listed above, or othe"s) of enercency ninn evalunt*cns by FEMA (Interin Findings dated 8/21/85) and State of NC "rvaluntion Renort,"ShMPP Exercise), annronrtute regula tions and venutrenents, '

NU9EG-065k, leEa1 cases (eg. UCs v. NRC), and/o*' docunents received r

from nersons contacted about these issues, or received via discovery.

l (b) not yet identified, excent as noted in seccific rosnonses, ,

these are page,s which nay be 'used i F.PX-P-1 (entire) see resnonse to 3(a) above, current l

state of discussions by Finaldi for ne; see niso Finnidi sunnary IP/PO I l EPX 2-P see Finaldi IP/PO sunnary EPX 2-3 Yes, see response to 0-14 above, 0-4, 0-6, (andwers !

both (a ) and (b) i '

EPX 2-14 Connunications equipnent and backun eouinnent, ,

personnel and nystens nust be abic to elmininnte all difficulties  !

identifled. For exanole I (eHa wkt;Am/%,,h W.on t)CDd h the connon energency frequency I sufficient to accommodat'e g all the traffic to be ex"ected 'n a real  ;

energency (nore than in en exercise) nunt be nyn11nble, throuch the use of other frequencies and eculomont thrt enn conteet and connuniente .

l l

on all those frequncies, which nust be known, and with sufficient traininr, of tersonnel tha t they con ofrectivolv use thic equinnent.

Thene are ni. changes in the ninn, really, but are chnnpes in the l equipnint recuired to execute the vlan. The !!ighway entrol equinnent I nust be fully ut cra Jed to neet the denands of n11 unitr, that would resaond to an enorgoney, nrovidinc relinble connuniertf onn to all thane _

i units and extra cunucity for relaying other neanagen nn the litrhway L I

Pr. trol nn: be enlled on or nequiaed to dot rround unita oc n ? 1 t*"a a n ,

l t . >

l l l especially the nobile radiation inbr nni monitoaing ne= ronnel l and nobile monitoring equinnent, nunt be provided w! th redundant,

( reliable connunications eouinnent canable of directly reaching the emergency resnonne organizations without relays; sufficient telenhones ,

t t and other connunicat1ons equinnent must be provided, not only for l{arnett County, but to trevent telochonn overload as c! ted by the j connunient* nna/nublic info ovaluntor for the State, and to nrovide reliable communications whnn telenhones are all tied un, for all energency rennonno organizationn, imC, FF"A, Ct&L ctc; cu"ficient l; personnel nunt be provided, vin the nian or othorwire, to n" event extra radio traffic from overloading then; delnyn in giv!ng info l r

to T.newgency Modien1 Seavicen nunt be nininized (cut te a n*nute or  ;

i two, esspecially for hon 1th and safety reinted infornation) and the I

fax /hard cony machinen must be fully reliable and duni conmunientions  ;

of info nunt not interfore with vaonat net'er -- e;in ev'iently I i

reouires both nanngenent and trnining changer, and reliable conmunications j for qu!.clly chocking nennngen that conn through, to cerfirn dien.  !

This is nenecially vital for henith and nnrety reinted info, e.g.  !

i i pinnt s tutus, rudint'on rond' rga, rannon9n neannnnal sta tum. t (b) ano renconnon to 0-14 above, the contention, and uno l h little connon onnne for onen, ninnan. To noivo a nanblen, you need to have thn equinnent, nornonnel, traininc, vn11 ability nnd syntena in nince to actually nolyn i t.

l l EPX-5-P-5(n) anview continunn, noan dntailed dancrintionn nny l

l well be reali od and novo info or requirenonta added. The number of  :

! i connunientione nernonnel and the redundancy and tellnbilit* of coulonent .

ito rdnt e be adequatau4hha to n+"real ccmonw sec.%s world" C L,c.rmv tr frovW4 (nctur.1 nccident" iseH ML anergency. hu.hv (c 4 4.e (b) une h(b).

1 - --

EPX-3-1. I don't recall. See resnonne to General Inte"rogatory I-3-(a) above. There will be followup ef ter discovery.

EPX-8-2. See Resuonse to EUX-8-1.

EPX-8-3 Not yet, excent of course for the requirenents of the j j

rules, the need for the systen to work prenntly, and the other factors (including elaboration of these) given in resnonce to vnur gonoval  !

! interrogatory #4 above, and General Interrogatory y above. This i is response to both (a) and (b).  !

EPX-8-4 I oresune you "efer to the Frt% " Inter'.n Findings" a s i the "FE'% Exercise Renort". These indications are not snecified in

! that recort. FE!u has been under a FOIA to nrovide the evalunters' I l

notes and all other documents reinting to this retort since sunner, 1985, but to the best of ny knowledge has not vrovided any. It is possible that FE5% evaluation criteria give nome of this infornation.*

EPX-8-5. Same presunntion as to identity of "Recort" as in

) EPX-8-k above. The snecificat*on is not orovided on that onge.

Again, FD% is under a FOIA request to nrovide the evaluator's notes l

and all other documents relating to this natter (and every natter they evaluated during the exercise). No documents have been received, to j ny knowledge. It is nossible that the FE'% operationc1 or evaluation l

, Euides give sone of this informat'.on but it is not spac!fied.

\

EPX-8-6. As in the answers to EPX 8-14 and -5 above, FEl% has i not nrovided this infernation, in under a FOIA requent to provide it,

and does not snecify at the nage indicated, how this occurred.  !

liowever, the "nublic announcenent of the encain tf on tn General Energency was not nade until alnost an hour af ter it was declared",  !

{ (FEMA Interin Findings, p.12) and this may be related. Also reinted j may be the statenant at nage 18 that " Verifier tion of the rBS was not mannited otractively through the une of entablished rians. .

i I

i

. . _ - . . _ ~ . _ . - - - - _ . . - - . - - . . _ -

l See also resnonses to Feneral interrogatories 3 and h, above.

EPX-8-7. FEMA has not provided this infornation, is under a FOIA to l

nrovide it, and has not orovided the content of a connlete nessage ,

I either; evaluator's notes and related documents have not been

provided under the FOIA request.

1 EPX-8-8. FEMA is under the same FOIA about this information, l

evaluator's notes and related documents. They have not n"ovided it.

It may exist in the evaluation Suide in sone forn but is not snecified.

l l Page 17 clearly gives no detail about these nunerous nroblems. l l

The sane FOIA situation applies to EPX-9-9,9-10,8-11. The FOTA will be ronewed IP/P31* nothing comes in by then. i EPX-6-9. Page 18 nrovides no details on this. See note about FOIA -

and PE% in EPX-8-8 above and other interrogatory resnonses sunra.

l EPX-8-10 FEMA does not exclain on that nage, excent to refer to verification. See FOIA/PEMA note in EDX-8-8 resnonse above, and other l resnonses sunra. Direct connunication with the EBS stations to ver!fy l .

l what they did and when they did it would be another obvious neaning.

l l Having the EBS stations know what needs to be in a nuclear power energenyy nessage, instructing then to call in (to a dedicated nhone line with ,

l non-nublished confidential nunber) or giving then dedicated radios on 1

a cicar frequency to communicated with the F3S activntors (SE9T or CP&L ,

j or both and/or others) wous1d also be an obvious innrovenent. Need to

! promptly send out ESS nessages when they are asked to be sent in somathf ng ,

. everyone involved with the EBS should have had connunicated to then.

, t l PPX-9-11. Making the r39 norsaren available to all nenbers of the i E00 Staff (PD% Interin Na Findings, "renort" at 18, and the sunnort for the ntatenent (ibid n.19) that EBS procedures should be innroved relate to this. But again, PEMA has not paovided additionn1 info.

See FEMA /FOIA note in EPX-8-8 and other responses supen.

One obvious problon is getting the nessage out pronptly, i.e.

with delay mininal (at nost a minute or two) once activation of the E3S is decided on by appropriate authority.

EPX-8-12. The execution, not just the plan, needs to be change d.

Obviously they should find out what all the nroblems FEMA refers to were, and take action that assures the problems have been solved and that there is backun that 'rdenendently will function if the

" solution" doesn't work or fails in a real emergency. (b) See resoonse to General Interrogatory h(a) above; also, use connon sense and out a priority on nakinP the systen really work in a real (unannounced,'unscripted) accident. This EBS is not a toy -- it is the prinary neans to neet tne requirenant of getting an instructional message to everybody in the EPZ within 15 ninutes, cs required by 10 CPR 50 Annendix E IV. D. 3 and its innienenting regulations, including NUREG-0654 Thus, it has to be certain to work in a test if it is to be relied on in a real energency, and all the compo..ents of ac tivating it -- nronntness, con,lete infornation, effective coverage of the EPZ, having econle alerted to tune to it, repeating it as necessary within 15 minutes to reach virtually 100%

of those in the EPZ, verifying the nessage has gone out, verifying it can be received and is being received within the FvZ, bef.ng sure the nonsage is on the air within not nore than ? n'nutes afte" activation, mkking sure problems and mismanagement of any sort do not interfere with the activation or ofrectiveness (or any of the other above-mentioned capabilities) of the EBS -- nuct work in a test. If you can't do it right in a test announced in advance, how can you do it right, in a real accident, under pressure, when you don't know it's going to hanpen, when it catches you asleep or on a bad day or night, etc?

t It doesn't make sense to accept anything less than performance with no real f1Ms, in tecting a systen on which neonle's livec can depend.

-1P-Obviously, the E33 is the key to taking nrotective action.

Uhat does the energency infornat! on distributed in tha . EoZ say? Tune to the EBS, it says, and do what the EBS tells you.

A lot of good that will do if the EBS is giving wrong, delayed or inconnlete information, or isn't activated when needed. This heavy denendence on the EBS for communication with the public about i WHAT PROTECTIVE ACTIONS TO TAKE or NOT TAKE is another key veason I

why the EBS has to be flawless in its test nerfornance. In a real

accident, worse nerfornance is to be exnected since no one known the accident is co,ning and they can't get ready for it, repair things to be sure they'll work on-cue, test things right before the official test, and so on. Thus, the E3S in a test nunt be finwless in tes ts to give reasonable assurance that it will work in a real accident. The EBS is key to getting urotective action taken because it alone will tell the vast najority of persons (virtually all of then) in the EP3 what to do in a nuclect accident. (This answer is te both "erts (a) cnd (b) --

more reasons nay be detailed la ter. I'm not through analyzing this issue.) One other reason is the FACT of perfornance is the key here, not a nronise. Ineffective use cannot give assurance of effective use especially when the real use will be under surprise, nove demandfng

conditions of a real accident.

EPX-8-13(a)(b) See rosnonse to E?X-8-1P a and b above. Other changes that would be helpful would be CP&L nutting as nuch ene*gy into solving the nroblens as it evidently does into fighting off 3 contentions. Incrovements by the state and innrovements in the PBS systen and training of norsonnel who actually nut out the TBS nessnres, and connunicatinrs with the EBS na exnin tned in resnnnse te EnX-8-10 abovo, and solving all EB3 nroblens vefevred to nbove, on naked about in your interrogatories _, are all necessary. Why? See TPX-8-1P

' above, but the basic ruoson is tht.t the TBS hns to werk or eneagency resnonse will not have n aubite "esacrea when ona te vacassnav.

Update resnonse to reneral interrogatories h, F and 6.

I an not sure if I relied o.n recennendation 1 at onge 16 of the state " Evaluation Renort / SHNPP Exercise ~."' in formulating EVX-P.

I think I did. It certainly supports contention EPX-2, and thus is rosnonsnive to EPX-2-3(a), EPX-2-4(a) and EPX-5(a).

Update response to F'X-8--k, 9-5. R-7(?), 9-10, A o,8-11 PEMA, page 16, says "The manager sought clarification fren the lant,"

but clairification was never received: he " received no vesponse to

, his calls for clarification." The nanager "sho 16 have followed SDP describinE siren and EBS coordination during a Site Area "mer6ency.

Undate EPX-8-1P

' Likewise, p.17, "the mechanies of activating the T.33" was what l necessistated terminating a conference call, causing "nunerous nroblens" (FEMA Interin Findings) so those nechanice need to be redone or given an alternative so that they will not cause those problems or other problens. FEMA also says (p.19) that TBS urocedures sho':1d be innroved. Presunably these rocedures, whether in the plan, in ERP inplementing procedures, or in other procedures, need to be 6

incroved to avoid the problena found in the test while not causing or tending to cause other problems for real energencies or future tests.

RESPONRE OM P90DUCTIOP OU DOCU!MTS CP&L possesses nost of the documents referred to herein, but I will gladly produce the others for insnection and/or conying at at mutually agreed-on time and niace, nrefernbly within nornal buainess hours. St F MUMM MWkb@NMP I affirn that my tynewriter ribbon is about worn out and that b $P the above responses are true to the best of ny nresent knowledge and belief. k Wella Eddlenan, IP/P2/85 b"Vh

FOIA REQUEST Federal Energency Managenent Agency Attn: FOIA Requests 500 C St. SW Washington DC 207h0

Dear FEMA:

I an the sane Wells Eddlenan on whose behalf FOIA requests were filed concerning the May 17-18, 1985, energency n1anning exercise at the Shearon Harris Nuclear Power Disnt in Fo*th Carolina.

hdQr.3 GLLC. 35A I hereby renew the FOIA requests j for the notes (handwritten and otherwise) and docunentation for the deficiency G.h.b, and f or all doc umentat* on relating to any statements concerning the EBS at Harris en pages IP,13,15, lh, 16,17,18 and 19 of FEMA's Interin Findings re the Shenron Harris Plant exercise. Jack Galover of FEMA was the evaluator resnonsibic Cheryl Stovall, for pp 1P-13; Wake County evaluators were inkKxMuxxt, FE!%; Elliott Levine , FE'% , and Phil Kier, FE"A . These are shown on the " Federal Evaluator Assi Fnnents (SHNPP) May 17-18, 1985, a ttached to the interin findings. Wake County section beings on un 15 and runs beyond p.19. It is not clear who evaluated the natters on pp 1h-15 I request that all docunents, notes and other info-nation relating to the Harris Emergency Broadcast systen activation, nexasages, evaluation, use, deficiencies in use, nanagenent of use, on any other docunents related to the EBS during that May 17-18 exercise, or since, be provided. I request a waiver of fees since M11s information is being used to attennt to nrotect the health and safety of the nublic ,

and not for any private gain, hv h M4e Wells Eddlenan 806 Parker St.

Durhan NC P7705 919/688-0076 919/383-6602 23 Decenber 1985

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