ML20140A996
| ML20140A996 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/22/1986 |
| From: | Federal Emergency Management Agency |
| To: | Eddleman W EDDLEMAN, W. |
| Shared Package | |
| ML20140B002 | List: |
| References | |
| CON-#186-806 OL, NUDOCS 8601230440 | |
| Download: ML20140A996 (29) | |
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??lD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'86 JAN p2 Id0:53 BEFORE THE ATOMIC SAFETY ANC LICENSING BOARD t rr- yn__
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In the Matter of )
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CAROLINA POWER AND LIGHT COMPANY /ND )
NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 OL POWER AGENCY ) 50-401 OL
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(Shearon Harris Nuclear Power P~ ant, )
Units 1 and 2) )
FEMA STAFF RESPONSE TO INTERROGATORIES PROPCUNDED BY INTERVEN0R WELLS EDDLEMAN (8th SET)
General Interrogatories Interrogctory 1 What is FEPA staff's reviewer's understanding of the subject matter of this contention?
Response (EPX-2):
FEMA staff agrees that Harnett County had " insufficient telephones" and that this communication deficiency revealed in the Plant Harris exercise could have some effects in a real emergency. However, the FEMA-identified deficiency in Harnett County's communications system was'not of safficient magnitude to seriously affect the capability of the emergency response organization to protect the health and safety of the public in the event of a radiological emergency at Plant Harris. As stated in the Shearon Harris Nuclear Station Exercise report dated June 28, 1985, ". . . for too few telephones (exist at the Harnett County E0C) for a 'real-world' emergency, . . ." However, the Director of the 8601230440 B601221 PDR ADOCK 05000400 G PDR I)so7
North Carolina Division of Emergency Management, in his response to FEMA Region IV's letter requesting a schedule of corrective actions for deficiencies identified in the Plant Harris exercise, states the following in regard to the Harnett County communications deficiency:
Excessive reliance on a single landline for backup communications with other E0Cs and other facilities will.be eliminated on the move and subsequent l establishment of the County E0C in the County Office Building. Harnett County representatives and this agency are present1v evaluating the total communica-tion need, and through successful negotiations with the utility will ensure installation of additional telephone circuits and instruments to effectively meet the needs of County operations for radiological emergencies. l The Director further states that the above corrective action is projected to be completed by February 15, 1986. i The Harnett County emergency communications deficiency discussed above is the only communications deficiency identified by FEMA in the Plant Harris exercise. The estallishment of the Harnett County E0C in the County Office Building, with the concomitant improvement of the communications system proposed, will obviate the emergency communications deficiency identified in the FEMA Plant Harris Exercise report and in Contention EPX-2. l Response (EPX-8):
FEMA staff agrees with intervenor that the ". . . use of the EBS was incomplete and ineffectively managed."
Among the inadequacies listed in EPX-8 is ". . . inadequate coverage of the emergency area and emergency response area." This inadecuacy, described on page 12 of the FEMA exercise report, does not refer to a
, l geographical area or sector, but refers to a lack of continuing use of l
EBS to provide instructions to the public, according to the Federal 1
evaluator who observed the Media Center facility and its activities.
The following quoted reference in EPX-8: " Numerous problems with EBS activation mentioned on pp.17-18 of the same report also need to be identified ano rectified" bes been reviewed by FEMA staff. The " numerous problems mentioned on pp. 17-18" of the exercise report are, specifically, problems related to (a) telephone conferencing capability and (b) lack of well-delineated procedures for coord)..ation between county EOC's and State government concerning notification of the EBS, according tc the FEMA evaluator at the Wake County E0C.
The FEMA staff, and the exercise report, recommend that rectifica-tion of the identified problems associated with EBS be accomplished through the following actions: (1) installation of a dedicated telephone communication network, (2) improvement of EBS procedures, and (3) training.
Upon request of FEMA, Region IV, the Director of the North Carolina Divisien of Emergency Management has agreed to the following corrective actions regarding the Public Education and Information NUREG-0654 deficiencies discussed above:
Additional training of State and County PI0's will be undertaken to better familiarize them with the types )
and kinds of information that needs to be provided the public in a nuclear emergency. The essentiality for prompt dissemination will also be stressed during these training sessions.
Current EBS procedures will be expanded to provide more definitive information on how to coordinate activation.
. 1 Ongoing Table Top Exercises will integrate EBS procedures whenever possible. At least one Table Top EBS exercise will be conducted prior to each scheduled fixed nuclear facility exercise if EBS
- procedures have not been previously integrated during the past 24 months.
(letter, Myers to Woodard, dated Nov. 26,1985).
The above-cited letter indicates that the " additional training" will be acccmplished " prior to the next exercise," and that the expansion of
" current EBS procedures" is to be completed by March 15, 1986.
FEFA Staff expects implementatior of all the above proposed and recommended actions; however, the Public Education and Information deficiencies and inadequacies cited in the Harris Exercise Report were not of sufficient magnitude to seriously affect the capability of the emergency response organization to protect the health and safety of the public in the event of a radiological emergency at Plant Harris.
Interrogatory ?_
Has FEF$ staff made any analysis, hquiry, study or investigation into, (a) this contention (bl the subject matter of this contention (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 contention?
Response
(a) yes (b) yes (c) yes (d) yes (e) yes Interrogatory 3 For all parts of your response to Interrogatory 2 above for which your answer is affirmative, please provide the following information:
(1) who made the analysis, inquiry, study or investigation; (2) what was being considered in such analysis, inquiry, study or investigation
("AISI"); (3) the content of the AISI; (a) the results of the AISI; (5) whether the AISI has been completed; (6) whether a date for
completing the AISI has been established if it is not complete; (7) what that date is; (8) all documents used in the AISI; (9) all persons consulted in the course of the AISI; (10) all documents containing information discovered or analysis or study or information developed i during or.as a result of the AISI (identify each such document and state what information er results it contains); (11) whether staff believes additional analysis is warranted or further AISI needs or may need to be undertaken on this contention; and (12) whether any persons participating in the AISI are to be called as witnesses for the Staff in this case, and (13) what questions the staff AISI is intended to answer and (14) what information it , seeks to develop if it is not complete.
Response
This interrogatory is unnecessarily long, compounded, and wittout definitive demarcation of subparts; therefore, the responder has supplied tha parenthetical insertion of numbers for the purpose of clarification.
Responses pertain to both contenticas, EPX-2 and EPX-8.
(1)(a): John Heard, Thomas Hawkins, Steven Rochlis.
(2)(a): The validity of the contention and the correlation of portions of the FEMA Harris exercise report with the contentun.
(3)(a): The content of the AISI can be seen as expressed in this FEMA Response document.
(d)(a): Same as preceding response.
(5)(a): Not as of this exact moment.
(6)(a): Yes.
(7)(a): January 16, 1986.
(8)(a): Eddleman's Interrogatories to FEMA Staff and NRC Staff, dated 11-26-85.
(9)(a): John Heard, Glenn Woodard, Cheryl Stovall, Steven Rochlis.
(10)(a): None.
(11)(a): No.
(12)(a): Yes.
(13)(a): Those propounded.
(14)(a): N.A.
(1)(b): John Heard, Thomas Hawkins, Cheryl Stovall, Jack Glover, Chris Saricks.
(2)(b): The adequacy of communications and of EBS during the Plant Parris exercise.
(3)(b): All facets of the Harris exercise.
(4)(b): The Shearon Harris Nuclear Station Exercise report, dated June 28, 1985; the Interim Findings Report on the Adequacy of Radielegical Emergency Response Preparedness for Plant Harris, North Carolina, dated August 7, 1985.
(5)(b): Yes.
(6)(b): N.A.
(7)(b): N.A.
(8)(b): Handwritten notes taken during the Harris exercise, the Harris Plan, the Interim Findings Report, the Harris exercise report.
(9)(b): Participants and evaluators in the exercise.
(10)(b): Handwritten notes taken during the Harris exercise, the Harris exercise report, the Interim Findings Report.
(11)(b): No.
(12)(b): Yes.
(13)(b): Questions propounded by intervenor.
(14)(b): N.A.
(1) through (14)(c): The only AISI's made by FEMA staff into the ellegations of these contentions is the Harris Exercise report, and the Interim Findings Report.
(1)-(14)(d)(e): See preceding response.
Interrogatory 4 For all respcnses to parts of (2) above for which NRC staff's or FEMA's answer is other than affirmative, please state (a) whether NRC Staff or FEPA plai.s to perform any AISI on this contention, (b) whether anyone on NRC Staff has stated that AISI of any kind is warranted for this contention (even though it has not been made), (c) whether NRC Staff plans for AISI, or FEMA's, on this contention include a date for beginning or for ending such AISI, (d) those dates, for all affirmative answers to (c) above, (e) what AISI FEMA or NRC Staff will undertake on this contention f f) what AISI NRC staff desires to undertake on this contention (g) all reasons why no AISI is planned on this contention if none is planned (h) all rearons why no AISI has been done yet on this contention if none has been done (1) what the responsibilities of NRC staff and of FEMA with respect to this contention are.
, Response:
All responses are in the affirmative.
Interrogatory 5 Identify all- documents the FEMA or NRC Staff relied on in opposing the admission of this contention, and any specific facts not stated in the Staff's opposition to admission of such contention (already filed in this case) upon which Staff relied in making such opposition.
Response
NRC Staff opposed the admission of these contentions, EPX-2 and EPX-8, on behalf of FrMA staff. See "NRC Staff Response for Intervenor Wells Eddleman's Proposed Contentions Based on the Emergency Planning Exercise" dated October '15, 1985.
Interrogatory 6 Identify all documents not identified in Staff's interrogatories to Wells Eddleman or to Joint Intervenors (to present -- a continuing inter-regatory).upon which the Staff relied in making each such interrogatory.
Response
Not Applicable.
Interrogatory 7 Identify by name, personal or business address, FEMA or NRC staff position or title (if any), and telephone number (if known) of each person or 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 admission; state for each such person what analysis was performed by that person.
Response
(a) Jack Glover, FEMA, 1371 Peachtree Street N.E., Atlanta, Georgia 30309, Region IV Public Information Officer, (404) 347-2400; Cheryl Stovall, same as preceding address, Emergency Management Program Specialist, (404) 347-7068; Elliot Levine, Argonne National Laboratory, 9700 S. Cass Avenue, Building 362, Argonne, Illinois 60439, consultant evaluator during the Harris exercise, (312) 972-6719; Chris Saricks, same address and other information as provided immediately above; John Heard, FEMA, 1371 Peachtree Street N.E., Atlanta, Georgia 30309, Technological Hazards Eranch Chief, (404) 347-7079; Thomas Hawkins, same address as immediately above, Emergency Management Program Specialist, (404) 347-7073; Steven Rochlis, same address as immediately above, Regional Counsel, (404) 347-2410.
(b) Same as "(a)"; ar,alvsis performed by each person named above:
Glover -- evaluator at Media Center during Harris exercise; Stovall --
-9 evaluator at Wake County EOC; Levine -- evaluator at Wake County E0C; Sharicks, evaluator at Harnett County E0C; Heard, evaluator at SE0C, J
reviewer af exercise report, and reviewer of these responses to Interrocatories; Hawkins, compiler of Utrris exercise report and respender to these interrogatories; Rochlis, legal counsel to Hawkins in responding to t,hese interrogatories.
Interrogatory 8 State all professional qualifications of each person identified in response to interrogatories 3, 4, 7.
Response
See professional qualifications attachments.
Interrogatory 9 Provide any statements of the analysis made by persons identified in response to interrogatories 3, 4, or 7 above, and identify all documents containing such information or statements not previously identified.
Response
fill statements and documents have teen previously identified.
Interrogatory 10 Give the identifier number, date, source, and title of all documents identified in response to interrogatories above, which are available through NRC PDR (Public Document Room).
Response
Unknown. NRC has this information.
Interrogatory 11
Will FEMA or NRC Staff make available copies of documents identified in response to the above interrogatories to Wells Eddleman for inspection and copying, for documents not available through NRC's PDR?
Response:.
Yes, except for tandwritten individual notes and pre-decisional papers.
Interrogatory 12 Identify by race, FEMA or NRC staff position if any, address and telephone number each person whom NRC staff intends to use or call as a witness in this proceeding.
Response
Unknown at this time.
Interrogatory 13 State fully the professional qualifications of each person identified in response to interrogatory 12 above.
Response
N.A.
Interrogatory 14 Summarize the position (or planned testimony) with respect to each contention on which such person is expected to testify, for each person identified in response to interrogatory 12 above.
Response
Unknown.
Interrogatory 15 l Has FEMA or NRC Staff, any witness identified in response to interrogatory 12, or anyone acting in behalf of the Staff or such witness l
I
_J
4 or at their direction, made any calculation or. analysis (not identified in response to interrogatories 1 through 4 above) with respect to this contention?
Response:-
No.
Interrogatory 16 _
- If the answer to interrogatory 15 is yes in any case, provide the name, business or personal address, telephone number and professional qualifications of each person who has made such calculation or analysis.
- stating for each what contention it relates to, what person (or Staff) it was made for or at the direction of, and identifying all documents containing such calculation or analysis and all documents used in making i such calculation or analysis or relied upon in it or supplying
- information used in it.
Response
2 N.A.
Interrogatory 17 i
Provide a summary of each AISI, calculation or analysis for which the answer to interrogatory 15, or interrogatory 2 above, is yes. i Response: ,
N.A.
t Interrogatory 18 Please give the accession number, date and originator of ear 5
- document identified in response to interrogatory 16, which is available at the NRC PDR.
Response
'N.A.
Interrogatory 19 i
_ ._ _ . . _ _ _ - . _ _ - . . - . ..__. ._ ~ . , _ , , _
Vill FEMA or NRC Staff make available to Wells Eddleman for inspection and copying all documents identified in response to interrogatory 16 above which are not available through the PDR?
Response:-
N.A.
Interrogatory 20 Identify each person, including telephone number, address, and field of expertise and oualifications (complete) (if any) who answered interrogatories with respect to this contention; if more than one person contributed to an answer, identify each such person, providing the information requested above in this interrogatory for each such person, and state what each such person's contribution to the answer was, for each answer.
Response
Thomas Hawkins, principal responder; Steven Rochlis, FEMA Region IV attorney, assisted through general review and legal consultation.
Professional qualifications were furnished in the response to previous interrogatories.
Interrogatory 21 Identify all documents which the FEPA or Staff proposes or intends to use as exhibits with respect to this contention during this proceeding, including exhibits of Staff witnesses (identifying the witness for each, if such a witness has been designated), and exhibits to be used during cross-examination of witnesses of any party (stating for each which witness it is to be used in cross-examination of), and
!- identifying for each the particular pages or chapters to be used as exhibits.
Response
The Harris Exercise Report, the Interim Findings Report; remainder of interrogatory unknown.
Interrogatory 22 Identify all documents which FEMA or NRC staff relied upon in answering interrogatories with respect to this contention, which have not been identified in response to interrogatories 1 through 21 above, stating for each which answer (s) re which contention (s) it was used for, and each specific fact and page number therein on which NRC staff relied or which NRC staff used in answering such interrogatory.
Response
None.
Interrcoatory P3 Please give the accession number, date, and originator of each document identified in response to interrogatories 21 or 22 above which is available through the NRC PDR.
Response
Unknown.
Interrogatory 24 Will FEMA or NRC Staff provide Wells Eddleman with copies of the documents identified in response to interrogatory 21 or 22 above which are not available at the PDR, for inspection and copying?
Response
Yes.
Interrogatory 25 Ider.tify any other information or source of information not identified in response to the above interrogatories 1-thru 24 on which, or upon which any member of NRC or FEMA staff relied, or which any such member of staff used, in answering each interrogatory with respect to this contention, naming the contention and response in which each such source was used, and the location of the information used or relied on in such source (e.g. page number, section, chapter, etc).
Response
None.
Interrocatory 26 (a) Does the Staff or FEMA now agree with the contention? (b) Does the NRC or FEMA Staff now agree with any part of the contention?
Response
(a) No.
(b) Yes. ,
Interrogatory 27 If answer to (b) above is affirmative, which part(s) and why?
Response
Please see response to Interrogatory 1 above.
Interrogatory G-EPX Please answer all of Applicants' and Staff's interrogatories to me on EPX-? and EPX-8, including general interrogatories, as if the same questions had been asked to you as if fully set out here. Please answer as if the term "ycur contention" means " Contention EPX-2 and/or Conten-tion EPX-8" in each such question or interrogatory, and that "your contentions" also means " Contention EPX-2 or EPX-8 or both".
Response
The answers to Applicants' and Staff's interrogatories to Wells Eddleman are unknown, have been answered in this response, not applicable or not formulated by Intervenor Eddleman for which FEMA should not be required to respond to pursuant to 10 CFR 9 2.720(h)(2)(ii).
Non-General Interrogatories
l 1
i
)
l Interrogatory EPX-2-1 Please identify all documents related to each and every communica-tiens deficiency referred to or described in any way in Contention EPX-2.
This includes evaluators' and others' handwritten notes, typewritten notes, tape recorded notes, nll documents concerning the admission of contention EPX-2, all docutants concerning actions recommended to be taken to deal with the deficiencies mentioned or referred to in EPX-2, actions that might be taken with respect to any matters referred to in EPX-2, responses to contention EPX-2, and records or information relating to any matter m,entioned in Contention EPX-2.
Response
"Shearor Harris Nuclear Station Exercise Report," dated June 28, 1985; Memorandum, May to Krimm, Sub.iect: Interim Findings Report, Plant Harris, North Carolina, dated August 7, 1985; " Interim Findings Report on the Adecuacy of Padiological Emergency Response Preparedness for Plant Harris," North Carolina, dated August 7, 1985; exercise notes of evaluators Stovall, Glover and Saricks; letter, Myers to Woodard, dated November 26, 1985, containing "the schedule of corrective actions for the summary listing of NUREG-065a deficiencies noted during the Shearon Harris Nuclear Power Plant Exercise on May 17-18, 1985."
Interroaatory EPX-2-2(a)
Please describe, and identify all documents relating to, all
" lack (s) of effective communications" durino the emergency planning exercise. (This refers, here and below, to the exercises held May 17-18, 1985, re the Shearon Harris Fuclear Power Plant.)
Response
See pages 8, 9, 11, 14, 1c, 17, 18, 19, 20, 21, 24, 25, and 30 of the Harris exercise report, dated June 28, 1985. See page 9 of the Interim Findings Report for Plant Harris, dated August 7, 1985.
\
i 4
Interrogatory EPX-2-2(b)
Please describe, and identify all documents relating to, all " lack of radiation monitoring results" during the emergency planning exercise.
Response
No " lack of radiation monitoring results" was reported by Federal evaluators during the Harris exercise.
Interrogatory EPX-?-2(c)
Plcase describe, and identify all documents relating to, " lack of contact with field and gecund units" during the emergency planning exercise.
Response
One possible reference to a " lack of contact with field and ground units" may be found on page 15 of the Harris exercise report.
4 Interrocatory EPX-2-2(d)
Please describe, and identify all documents relating to, the overloading of the emergency inter-system mutual aid frequency during the t emergency planning exercise, including (1) the bandwidth of such frequency, (ii) the frequency or frecuencies in Hertz (cycles /second)
- (iii) the capacity of such frequency or frequencies in number of simul-i tanecus voice channels (iv) the number of unit (s) having access to such frequercy (v) the number of units not involved in the emergency planning
, exercise having access to use of such frequency or frequencies (vi) the maximum 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 exercise or at other times. Please identify all documents relating to any of the above matters.
Response
i There is no reference to "the overloading of the emergency inter-system mutual aid frequency during the emergency planning exercise" in the FEMA Harris exercise report or related FEMA documents.
t Interrogatory EPX-2-2(e) f
Please describe, and identify all documents relating to, the communication inadequacies of the NC Highway Patrol, particularly those related to insufficient equipment, ability to adequately handle the number of units responding to an emergency of the (nuclear plant) types, during the exercise or otherwise; the number of units of the Highway Patrol that did respond to the Harris emergency planning exercise, and the number of frequencies available to those units and their base stations, relay stations, etc., and the capacity of each frequency for handling communications, in the form of 2-way conversations in voice, or other capability for communication. Please identify all documents giving information asked for above, or relating to any such information.
Respense:
There is no reference to "the communications inadequacies of the NC Highway Patrol" in the FEMA Harris exercise report or related FEMA docurrents .
Interrocatory EPX-2-2(f)
Please describe, and identify all documents relating to, the number of telephones available to the Harnett County emergency personnel during the exercise, what a " sufficient" number of telephones for them would be, or is; and any insufficiencies of the telephones available to Harnett County emergency response personnel during the exercise. Please identify all documents giving such information or relating to any of the above matters.
Response
The number of telephone lines available to the Harnett County E0C energency personnel was "two or three", according to the Federal evaluator present at the E0C during the Harris exercise. The exercise report relates to the number of telephones in the Harnett County E0C in that it describes the number of telephones as " insufficient". A sufficient number of telephone lines would be "four or five", according to the Federal evaluator observing activities at the Harnett County E0C.
Interrogatory EPX-2-2(g) 1 I
Please describe, and identify all documents relating to, the amount of radio traffic in Chatham County during the exercise, the number of radio operators on duty in Chatham County at all times during the exercise, the capacity of such operators / dispatchers to handle radio traffic, the amount of radio traffic that was " extra" during the exercise in Chatham County, and the overloading of personnel on duty in Chatham County due to extra radio traffic, the degree of such overloading, what personnel were overloaded, when, and for how long. Please identify all documents containing(any of the information inquired about above, orrelating to :ny pa orpart{s).
Response
FEMA has no information or documents concerning radio traffic in Chatham County during the exercise.
Interrogatory EPX-2-2(h)
Please describe, and identify all documents relating to, delays in Emergency Medical Services Office receiving messages from SERT (State Emergency Response Team). Please identify and provide a copy of all messages that were delayed, and give the amount of time each was delayed and the content of each such message. Please identify all occuments containing any of the above-recuested information, or relating to it.
Response
FEMA did not evaluate this activity and has no knowledge of the delays alluded to in this interrogatory.
Interrogatory EPX-2-2(I)
Please describe, and identify all documents relating to, comunications paths from the mobile radiation lab to base station (s) that involved any relay or relay (s). Please identify each such communication, its date, time, and contents and all documents relating to it; please also identify the specific relay (s) that were used, by unit, location, relay method, frequencies employed, communications method employed, 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 messages, and all documents containing any of the information inquired about above, or relating to it.
Response
The only information pertaining to this item which FEMA has is found on page 14 of the Harris exercise report in the " Mobile Radiological Laboratory" section which states: "A slight problem with communication between one field team and the mobile laboratory developed during the second day of the exercise. The problem was rectified by relaying messages through the E0F."
Interrogatory EPX-2-2(j)
Please describe the " possibility of delayed and/or incorrect information" in relaying reports from the mobile radiation lab to base and all documents related to this matter and the state Radiation Protection Section evaluator's information about it, opinions about it, and statements about it, including any communications to or from the evaluator concerning this opinion, or the evaluator's evaluation or statements concerning the possibility of delayed or incorrect-information (or both) resulting from relays of information. Please also identify all documents relating to any of the above matters.
Response
FEMA has no information related to this interrogatory.
Interrogatory EPX-2-2(k)
Please identify all documents sent to or from (i) evaluators (ii) other emergency planning personnel (iii) FEMA staff (iv) NRC Staff (v) Applicants or persons working for or with them (vi) other government officials, concerning the matters mentioned or referred to in the above interrogatories and parts and subparts, or concerning any matters related to contention EPX-2 or matters mentioned or referred to in it. Please note especially here that this interrogatory is a continuing one.
Response
The only documents related to contention EPX-2 which FEMA has knowledge of are the two documents already mentioned in these responses
-- the Harris exercise report and the Harris Interim Findings, and their submittal letters or memorandums and subsequent responses.
Interrogatory EPX-2-3(A)
With respect to every matter inquired about in any part of Interrogatory EPX-2-2 above, please provide the following information and identify all accuments relating thereto:
(i) what action (s) have been suggested, thought of, written down, recommended, considered or discussed concerning actions which might or should be taken to remedy any communications deficiency identified or alleged with regard to this matter. (Please provide an answer to this part separately for each matter identified in response tu any part(s) of Interrceatory EPX-2-2(a) through (k) above, and for any matter inquired about in any of those parts.)
Pesponse:
The answer to this interrogatory may be found by carefully reading the Harris exercise report, the Harris Interim Findings and their accompanying submittal letters and remorandums, and the response by the State of North Carolina Division of Energency Management to the Harris exercise report submittal letter in which is contained a " Schedule of Corrective Action" for the summary listing of NUREG-0654 deficiencies identified during the Shearon Harris Nuclecr Power Plant Exercise conducted on May 17-18, 1985.
The documents listed in the preceding paragraph contain or represent the actions suggested, thought of, written down, recommended, considered or discussed concerning actions which might or should be taken to remedy-any communications deficiency identified or alleged with regard to this matter.
Interrogatory EPX-2-3(A)(ii)
What actions have been taken to remedy any of the communication deficiencies alleged in Contention EPX-2? Please identify for each the action, who takes it, the schedule for its completion, any tests of the adecuacy of the remedy or action, the results and any evaluation of such tests, any other evaluations positive, negative or otherwise of the adecuacy of the remedy or action, what equipment changes are involved in the action, the specific equipment (item, make, model, function) involved, the degree to which the action or remedy does in fact solve the communications problem, and please identify all documents relating to the above, particularly recommendations for action, authorizations for action, evaluation or remedies, statements concerning completion of action, etc.
Response
FEMA knows of no remedial actions which have been taken other than the florth Carolina Division of Emergency Management letter, dated ficvember 26, 1985, containing the " Schedule of Corrective Action," and the actions alluded to in that schedule.
Interrogatory EPX-2-3(A)(iii)
What actions were recommended or discussed or thought of, but not taken, to remedy each deficiency alleged in EPX-2 or inquired about in any part(s) of interrogatory EPX-2-2 above? Please describe every such action, ard all reasons why each was not taken, and identify all documents relating to such action, and/or to the decision not to take it, reasons why it was not taken, and other matters relevant to the decision.
Pesponse:
None.
Interrogatory EPX-2-3(A)(iv)
What actions are still under consideration for remedying any communications deficiencies alleged in EPX-2 or inquired about in EPX-2-2 above or any part of EPX-2-2? Please identify each such action, all documents relating to it, all reasons why it is still under consideration and when or if it is to be implemented.
Response
- ?2 -
The document referred to in (ii) above contains the only remedial actions under consideration of which FEMA is aware.
Interrogatory EPX-2-3(A)(v)
What actions are yet to be completed to remedy any communications deficiencies alleged in Contention EPX-2 or inquired about in any part(s) cf interrogatory EPX-2-2 above? Please identify each such action and all documents relating to it, tc why it is to be done, why it was recomended and by whom, why it has not been completed yet, when it is scheduled to be completed, who is in charge of completing it, what their authority and powers to complete it are, and when any portion (s) of it are to be completed. Please identify all documents containing any information inquired about above, or information or opinions relating to any such matters.
Response
See the preceding response.
Interrogatory EPX-2-3(A)(vi)
What barriers, financial, organizational, bureaucratic, or otherwise, exist to the completion in a 100% successful manner of any remedy or remedies (or actions to remedy) any communications deficiency or deficiencies alleged in Contention EPX-2 or inquired about in any part(s) of Interrogatory EPX-2-2 above? Please identify and describe in detail each such barrier and what will be required to overcome 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 or all of those resources will be available. For each barrier or impediment to any remedy for the communications deficiencies in description of the problem (s) the quired about barrier or above, please impediment give aand causes, specific the specific personnel, material resources, financial resources, and other resources to be used to overcome each impediment or barrier. Please give a schedule for the overcoming of each such barrier or impediment and identify all barriers of impediments that have not yet been overcome.
Please identify all documents relating to any impediment or barrier to implementing 100% effective remedies for every communications deficiency mentioned or referred to in Contention EPX-2 or inquired about in any part(s) of Interrogatory EPX-2-2 above. Please identify all documents '
containing any other information inquired about above, most particularly ,
including the nature of the barriers or impediments, the resources to be 4 ,
used to overcome them, the schedule (s) for overcoming them, and which '
impediments or barriers have not been overcome.
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Response: ,
FEMA staff knows of no barriers or impediments to the completion in a 100% suscessful manner of any remedy or remedies, or actions to remedy, any communications deficiency or deficiencies alleged in Contention EPX-2 or inouired about in any part(s) of Interrogatory EPX-2-2.
1 s Interrogatory EPX-2-3(A)(vii) '
g Please identify any other problem or circumstance that (vii-a) could, or (vii-b) wculd, interfere with achieving 100% remedying of all communications deficiencies mentioned or alleged in Contention EPX-2 or inquired about in Interrogatory EPX-2-2 above. Please identify all documents relatir.g to each such problem or circumstance and any schedule form er mea'ns 'for dealing with or overcoming such problem or circumstance. Please identify an problems or circumstances which vii-c)
(y documents may, or containing information (vii-d) will, not be about overcome, and which can or do interfere with achieving 1007-effective remedies for every communications deficiency mentioned or. alleged in Contention EPX-2 or inquired about in Interrogatory EPX-2-2 above.
Respohse: i
?
FEMA Staff knows of no other problem or circumstance that could, or .
would, interfere with the remedy of communications deficiencies mentionsd or alleged in Contention EPX-2 or inquired about in Interrogatory EPX-2-2 above.
Interrogatory EPX-2-3(b)
Please provide the identification of all documents containing any other information available to you that relates to remedying communica-tions deficiencies, particularly those alleged or mentioned in Contention EPX-2 or inquired about in any part(s) or Interrogatory EPX-2-2 above.
Response
FEMA staff knows of no documents other than those already cited that relate to remedying communications deficiencies. '
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Interrogatory EPX-8-1 Please identify all documents related to each and every inadequacy, incomplete use, problems with activation, inadequate coverage, or ctive management of the Emergency Broadcast System (EBS), including inef@lete incomp messages and/or incomplete instructions to the public, inadequate procedures for activation and use of the EBS before the State assumes control, inadequate coverage of the emergency area and/or the emergency response area, incomplete messages and incomplete instructions to the public, and other problems with EBS activation (e.g. those mentioned on pa,ges 17-18 of FEMA's draft reports on the emergency planning exercise at Shearon Harris.) This includes sound tapes, video tepes, actual content of messages used during the exercise, transcripts of messages used (I don't want the authentication codes, just the messages themselves), reviewers' handwritten or other notes, note of persons observi'ng the exercise or participating in it, logs of EBS stations as to what messages were sent and when, drafts of the FEMA report (s) en the exercise, and any other document (s) or records relating to these matters, whatsoever.
Response
"The Shraron Harris huclear Station Exercise Report," dated June 28, 1985; the " Interim Findings Report on the Adequacy of Radiological Emergency Response Preparedress for Plant Harris," North Carolina, deted August 7, 1985; the submittal letters and memorandums and responses for the two reppts cited immediately above; the handwritten notes of federal evaluators ack Glover, Cheryl Stovall .
Interrogatory EPX-8-2 (a) Please describe, and identify all documents relating to, ineffective management of the EBS during the exercise.
(b) Please describe, and identify all documents relating to, EBS activation inadequacies during the exercise.
(c) Please desdribe in what ways and by what omissions messages to the public were incomplete during the exercise. Please identify all documents relating to such incompletenesses, for each message.
(d) Please describe, and identify all documents relating to, incomplete instrue.tions to the public during the exercise, identifying each incomplete instruction in each message, and telling what information 4
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would be required or is required to complete the instruction in each case. Please identify all documents relating to any such incompleteness or incompletenesses, for one message or all messages or any combination of messages during the exercise.
(e) Please describe, and identify all documents relating to, any problems with EBS activation during the exercise. Please identify each such problem and separately identify all documents relating to it.
(f) Please describe, and identify all documents relating to, inadequate coverage of the emergency area during the exercise. Please state what is adequate coverage of the emergency area according to (i) applicable rules or standards (ii) your opinion, if different.
Please identify all documents relating to your opinion or adequate rules j or standards for adequate coverage of the emergency area.
(g) Please describe, and identify all documents relating to, 4
inadequate coverage of the emergency response area during the exercise.
4 Please also state what is adequate coverage of the emergency response
, area by the EBS (1) according to applicable rules or standards (ii) in your opinion. Please identify all documents relating to your opinion or i to adequate rules or standards for adequate coverage of the emergency response area.
(h) Please identify all other respects in which the use of the emergency broadcast system (EBS) was incomplete during the exercise.
Please identify all documents relating to each such respect in which use of the EBS was incomplete.
, (I) Please identify all other aspects of EBS use which were incomplete or ineffectively managed or had problems during the exercise.
Please identify all documents relating to each such problem.
l (J) Please describe and identify all documents relating to standards which the EBS must meet.
Response
Please see the preceding response. The above-cited documents describe the inadequacies associated with the EBS which FEMA evaluators identified during and after the_ Harris exercise. All the information that FEMA staff has concerning Interrogatory EPX-8-2(a) through (J) is contained in those documents.
i Interrogatory EPX-8-3(a) ,
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1 Please identify every step or measure being taken to remedy each of the problems, inadequacies, deficiencies or other defects of EBS use at Shearon Harris described, mentioned or identified in Contention EPX-8 or asked about in any part(s) of interrogatory EPX-8-2 above.
Response
The steps or measures beina taken to remedy the inadequacies of the EBS are contained in the previously-cited " Schedule of Corrective Action" submitted by th'e N.C. Division of Emergency Management to FEMA Region IV, dated November 26, 1985.
Interrogatory EPX-8-3(b)
Please identify all barriers, impediments or problems with each step or measure being taken to remedy each problem, inadequacy, deficiency or other defect in Harris EBS use that (i) could (ii) would prevent such step or measure from being 100% effective.
Response
FEMA staff is aware of none.
Interrocatory EPX-8-3(c)
Please state which measures or steps to remedy any problem, inadequacy, deficiency or other defect in Harris EBS use have been (i) thr9ght of (ii) written dcwn (iii) proposed (iv) accepted (v) rejected (vi) considered (vii) completed (viii) scheduled to be completed, please tell when each is to be completed (ix) kept under consideration at present. Please note that this is a continuing interrogatory, as are all of these.
Response
FEMA staff has stated above that the recommended remedial actions and the measures being taken to remedy the inadequacies of the EBS are contained in the documents listed above. These documents represent the measures thought of, britten down, proposed, accepted, re,iected.
considered, completed, scheduled to be completed, and kept under consideration at present.
Interrogatory EPX-8-3(d)
Please give all reasons.why each step or measure asked about in (c) above was (i) accepted (ii) rejected (iii) kept under consideration (iv) not considered.
Response
FEMA staff has no knowledge of these reasons.
Interrogatory EPX-8-3(e)
Please identify all documents relating to any of the information or matters inquired about above, especially those proposing measures or steps to remedy deficiencies, defects, problems or inadequacies with the EBS, evaluating such measures or steps, deciding which to implement, scheduling implementation, evaluating the completed measures or steps for effectiveness, or rejecting or declining to consider any measures or steps.
Response
Please see the Response to Interrogatory EPX-8-1, above.
Interrogatory EPX-8-3(f)
Can the remedial measures and steps so far completed assure with 100% confidence that all defects, deficiencies, inadequacies and/or problems alleged in Contention EPX-8, mentioned in Contention EPX-8, or inquired about in any part(s) of Interrogatory EPX-8-2 above, will not occur if the EBS must be activated in a real nuclear emergency at Shearon Harris? Please provide all reasons for your answer and identify all documents you use or rely on in making your answer, all opinions you use or rely on in your answer (and whose they are), and all other information or things you used or relied on in making your answer. Please identify all documents containing any of this information or opinion, and please 61so identify any documents containing information or opinions contrary to those you used or relied on, or information or opinions that would undermine or contradict your answer in whole or in part.
Response
No. FEMA staff understands, from the North Carolina Division of Emergency-Management response of November 26, 1985, that the remedial s
l measures are not in place or completed as of this date.
FEMA staff knows of no documents containing contrary or centradictory information that we'!1d undermine its answer either in whole or in part, or, for that matter, which would change staff's opinion.
Interrogatory EPX-8-3(g)
Please provide all other information relating to EPX-8.
Response
FEMA staft has no other information relating to EPX-8.
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UNITED STATES OF AMERICA
, NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
CAROLINA POWER AND LIGHT )
COMPANY AND NORTH CAROLINA ) Docket No. 50-400 OL EASTER'4 MUNICIPAL POWER AGENCY ) 50-401 OL
)
(Shearon Harris Nuclear Power )
Plant Units 1 and 2) )
)
)
AFFIDAVIT OF THOMAS I. HANKINS I, Thomas I. Hawkins, do hereby affirm subject to penalty of perjury that I have answered Wells Eddleman's Interrogatories to NRC Staff and FEMA (8th Set). The answers are true and correct to the best of my knowledge and belief.
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K M .o c~ v. . m Thomas I. Hawkins \-
County of Fulton City of Atlanta Dated this k k day of January 1986.
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