ML20093B224

Second Set of Emergency Planning Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20093B224
Person / Time
Site:	Harris
Issue date:	10/05/1984
From:	Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	WILSON, R.
References
CON-#484-315 OL, NUDOCS 8410090477
Download: ML20093B224 (12)

Text

X ggL "",;yJ'S Yc October 5, 1984 UNITED STATES OF AMERICA

'84 CCT -9 PJO NUCLEAR REGULATORY COMMISSION f[;.I((,$n . ,p

.M u .'.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ""'

In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant) )

APPLICANTS' EMERGENCY PLANNING INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR WILSON (SECOND SET)

Pursuant to 10 C.F.R. S S 2.740b and 2.741 and to the Atom-ic Safety and Licensing Board's " Final Set of Rulings On Admis-sibility of Offsite Emergency Planning Contentions, Ruling on Petition For Waiver of Need for Power Rule, and Notice of Upcoming Telephone Conference Call" (August 3, 1984), Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Richard Wilson an-swer separately and fully in writing, and under oath or affir-mation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the responses to interrogatories below. Answers or objections to these interrogitories and re-sponses or objections to the request for production of documents must be served no later than October 24, 1984.

8410090477 841005 PDR ADOCK 05000400 6 32 G PDR

These interrogatories are intended to be continuing in na-ture, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. 5 2.740(e),

should Dr. Wilson or any individual acting on his behalf obtain any new or differing information-responsive to these interroga-tories. The request for production of documents is also con-tinuing in nature and Dr. Wilson must produce immediately.any additional documents he, or any individual acting on his be-half, obtains which are responsive to the request, in accor-dance with the provisions of 10 C.F.R. 5 2.740(e).

Where identification of-a document is requested, briefly describe the document (e.g., book, letter, memorandum, tran-script, report, handwritten notes, test data) and provide the following information as applicable: document name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the per-son or persons having possession of the document. Also state the portion or portions of the document (whether section(s),

chapter (s), or page(s)) upon which you rely.

Definitions. As used hereinafter, the following defini-tions shall apply:

" Applicants" is intended to encompass Carolina Power &

Light Company, North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.

t "Offsite emergency plans" refers to the " North Carolina

-Emergency-Response' Plan In Support of The Shearon Harris Nuclear Power Plant," Parts 1-5.

" Document (s)" means all writings and records of every type in ~the possession, . control or custody of Ihr. Wilson or any individual acting on his behalf, including, but not limited to',

memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice record-ings and all other writings or recordings of any kind; "docu-ment (s)"'shall also-mean copies of documents even though the originals thereof are not in the possession, custody, or con-trol of Dr. Wilson; a document shall be deemed to be within the

" control" of Dr. Wilson or any individual acting on his behalf' if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.

General Interrogatories 1(a). State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the facts alleged, and upen which you relied in formulating allegations, in each of your conten-tions which are the subject of this set of interrogatories.

in . .

(b). Identify those facts concerning which each such person ~has first-hand knowledge.

(c). State the specific allegation'in each contention which you-contend such facts support.

2(a). State the name, present or last known address, and present or last employer of'each person, other than affiant, who provided information upon which you relied in answering each interrogatory herein.

(b). Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained.

3(a). State the name, address, title, employer and edcuational and professional qualifications of each person you intend to call as an expert witness or a witness relating to any contention which is the subject of this set of interrogato-ries.

(b). Identify the contention (s) regarding which each such person is expected to testify.

(c). State the subject matter as to which each such per-son is expected to testify.

4(a). Identi5y all documents in your possession, custody or control, including all relevant page citations, pertaining to the subject matter of, and upon which you relied in formu-l lating_ allegations in each contention which is the subject of this set of interrogatories.

l

y L l

(b). ; Identify.the. contention (s) to which each such docu-

. ment relates.

.(c). State the specific. allegation in each contention which you conte'nd each document supports.

5(a). Identify all documents in your possession, custody or' control, including all relevant page citations, upon which you relied in answering each interrogatory herein.

(b). Identify the specific interrogatory response (s)' to which each such document relates.

6(a). Identify any other source of information, not' pre-viously identified in response to Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein.

(b). Identify _the specific interrogatory response (s) to which each such source of information relates.

7(a). Identify all documents which you intend to offer as exhibits during this proceeding to support the contentions

'which are.the subject of this set of interrogatories or which you intend to use during cross-examination of witnesses

. presented by Applicants and/or the NRC Staff and/or the Federal Emergency Management Agency (" FEMA") Staff on each contention Which is the subject of this set of interrogatories.

(b). Identify the contention (s) to which each document relates and the particular page citations applicable to each contention.

f-

r_ _

q l

. Interrogatories on Wilcon 12(b)(2) 12(b)(2)-1. Provide all facts which would support your statement that " Evacuation time study itself is deficient be-

-cause the 1 evacuating car / family assumption is too low -- many families would take two cars."

12(b)(2)-2(a). Describe in detail any and all changes you believe must be made in offsite emergency plans to meet the concerns expressed in Wilson 12(b)(2).

(b). Describe in detail the bases for your be-lief that such changes must be made.

12(b)(2)-3(a). Describe in detail any and all actions or changes (other than those described in your response to Inter-rogatory 12(b)(2)-2(a)) which you believe are necessary to meet the concern expressed in Wilson 12(b)(2).

(b). Describe in d'etail the bases for your be-lief that such actions or changes are necessary.

Interrogatories on Wilson 12(b)(3) 12(b)(3)-1. State whether you are aware that the estimate of 240 familes (at page 3-2 of the evacuation time estimate study for the Harris plume EPZ) is the estimated number of fam-ilies without transportation in the Wake County portion of the plume EPZ, not the entire Harris plume EPZ.

1 C

1

~

F ,

L~ . j 1

12(b)(3)-2. Identify all bases for your allegation that I "the 240 family (sic] without transportation is too low."

12(b)(3)-3(a). State whether you believe that the esti-mate of 84 households without transportation in the Chatham County portion of the plume EPZ (at page 3-2 of the evacuation time' estimate study for the Harris plume.EPZ) is sufficiently accurate for planning purposes.

(b) If the answer to (a) above is other than affirmative, state the approximate number of families without transportation in the Chatham County portion of the plume EPZ, to the best of your knowledge, and specify the bases for your estimate.

12(b)(3)-4(a). State whether you believe that the esti-mate of 54 households without transportation in the Harnett County portion of the plume EPZ (at page 3-2 of the evacuation time estimate study for the Harris plume EPZ) is sufficiently accurate for planning purposes.

(b) If the answar to (a) above is other than affirmative state the approximate number of families without transportation in the Harnett County portion of the plume EPZ, to the best of your knowledge, and specify the bases for your estimate.

12(b)(3)-5(a). State whether you believe that the esti-mate of 32 households without transportation in the Lee County

port' ion of'the plume EPZ (at page 3-2 of.the evacuation time estimate study-for the Harris' plume EPZ)cis sufficiently accurate-for planning purposes.

(b) If-the answer to (a) above is other than affirmative, state the. approximate number of families without transportation.in~the Lee county portion of the plume EPZ, to the best of your knowledge, and specify the bases for your es-t'imate.

12(b)(3)-6(a). State whether you believe that the esti-mate of 84 households without transportation in the Wake County portion of the plume EPZ (at page 3-2 of the evacuation time estimate study for the Harris plume EPZ) is sufficiently accurate for planning purposes.

(b) If the answer to (a) above is other than affirmative, state the approximate number of families without transportation in the Wake County portion of the plume EPZ, to the best of your knowledge, and specify the bases for your es-timate.

12(b)(3)-7. Identify all bases for your assertion that

"[m]any (families] have cars that are not in' working order."

12(b)(3)-8. Describe any and all changes you believe must be made in the offsite emergency plan to meet the concerns ex-pressed in Wilson 12(b)(3). Describe in detail the bases'for l

your belief that such changes must be made.

c.

C .-

l 12(b)(3)-9. Describe any and all actions you believe must beztaken, or changes you believe must be made (other.than those

-identified in answer'to Interrogatory 12(b)(3)-8 above) to meet the concerns expressed in Wilson 12(b)(3). Describe in detail the bases for your belief that such actions must be taken and such changes made.

Request For Production of Documents Applicants request that Intervenor Wilson respond in writ-ing to'this request for production of documents and produce the original or best copy of each-of the documents identified or described in the answers to each of the above interrogatories, at a place mutually convenient.to the parties.

Respectfully submitted, N

Th6 mas A. Baffer, ~ P ! C L/

W y Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn Dale Hollar Hill Carrow CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated: October 5, 1984

_g_

+

1

~ .

UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) 1

)

CAROLINA POWER & LIGHT' COMPANY )

and NORTH CAROLINA EASTERN- ) Docket No. 50-400 OL' t MUNICIPAL POWER' AGENCY )

)

(Shearon Harris Nuclear Power )

Plant)- )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Emergency Planning-Interrogatories and Request For Production of Docu-rents To.Intervenor Wilson (Second Set)" were. served ~this 5th day of October, 1984, by deposit in the U.S. mail,'first class, postage prepaid, upon the parties listed on the attached Ser-vice List.

14t5f & ll/h Dellsha A. Ri8tgwa~yl () (/

Dated: October 5, 1984 i

r i

4 4

y 1- ) --- . , - , , -,r- y- y - , , -_ - - - , - -- r----,w , - , . - + - - , y y- , --

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant) )

SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of U.S. Nuclear Regulatory Commission North Carolina Washington, D.C. 20555 307 Granville Road Chapel Hill, North Carolina 275R Mr. Glenn O. Bright Atomic Safety and Licensing Board M. Travis Payne, Esquire U.S. Nuclear Regulatory Commission Edelstein and Payne Washington, D.C. 20555 Post Office Box 12607 Raleigh, North Carolina 27605 Dr. James H. Carpenter Atomic Safety and Licensing Board Dr. Richard D. Wilson

. U.S. Nuclear Regulatory Commission 729 Hunter Street Washington, D.C. 20555 Apex, North Carolina 27502 Charles A. Barth, Esquire Mr. Wells Eddleman Janice E. Moore, Esquire 718-A Iredell Street Office of Executive Legal Director Durham, North Carolina 27705 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard E. Jones, Esquire Vice President and Senior Counsel Docketing and Service Section Carolina Power & Light Company Office of the Secr'etary Post Office Box 1551 U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Washington, D.C. 20555 Mr. Daniel F. Read, President CHANGE Post Office Box 2151 i Raleigh, North Carolina 27602 e

I

a. -- - .- . . - _ _ _ - . . ,- --

Dr.= Linda W. Little Governor's Waste Management Board 513 Albemarle Building 325 North Salisbury Street Raleigh, North Carolina 27611 Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commiss'in Region II 101 Marietta Street Atlanta, Georgia 30303 Steven F. Crockett, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Robert P. Gruber Executive Director ,

Public Staff - NCUC Post Office Box 991 Raleigh, North Carolina 27602 Administrative Judge Harry Foreman Box 395 Mayo University of Minnesota Minneapolis, Minnesota 55455 Spence W. Perry, Esquire Associate General Counsel FEMA 500 C Street, S.W., Suite 480 Washington, D.C. 20740 I

i

. . . . , . . , , -, ., . __, ,, . ._