ML20093D833

Second Round Interrogatories & Request for Production of Documents.W/Certificate of Svc.Related Correspondence

ML20093D833
Person / Time
Site:	Harris
Issue date:	10/08/1984
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO., NORTH CAROLINA, STATE OF
References
CON-#484-428 82-468-01-OL, 82-468-1-L, 82-468-1-OL, OL, NUDOCS 8410110421
Download: ML20093D833 (4)

Text

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RELMEC JORhc.SPONDENCE 8 October 1984 UNITED STATES OF AMERICA @%[

NUCLEAR REGULATORY COMMISSION T4 00T 11 A11:28 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '

DO

, Glenn Dr. O. Bri Janes H.ght ~A '

Carpenter James L. Kelley, Chairman 1

In the Matter of h J Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, Unit 1) ASLBP ?b. 82-h68-01 OL Wells Eddleman's Second 9nund Interrogatories and Request for Droduction of Documenta to CP&L and UC/ County energency Planners General Interrogatories A. Please provide answers to the general interroFatories (lith a nd 12th sets) previously provided, with respect to each iten below to which any of then apolies, or to which the answer has changed, as if those general interrogatories were fully set out here.

B. Are all references to the State Energency Plan (in suono*t of the Shearon Harris Nuclear Power Planzt) in your responses of October 1, 198h, to Fevision 1 of that plan? If not, which ones are to another version and which version do they refer to (please identify version for each).

Specific Interrogatories on Contentions 57-C-7 and 2h0 240-h(a) '.fhere in the energency olan does it say which Chatham County Five Denartments are resoonsible for decontamination of evacuees at shelters? (b) Have these deoartments been anecifically trained in decontamination techniques as distinct from radiation nonitoring?

Please give all details of such training, and identify all docunents including texts, notes, course outlines, or other training natorials on decontanination used in training these fire deoartments; please identify which fire departnents have received what training, and for each docunent identified, specify how and form whon (e.g. which fire department) it was used in training re decontanination. (c)

Do any of the fire denartments listed in your answer 240-1(b) have a plan for decontaninating evacueen at a shelter? If so, is the plan written? Please identify all documents containing nuch plan (s) for each fire denartment.

0410110421 041000 PDR ADOCK 05000400 0 PDH v3

o 240-5(a) Which of the fire departments listed in your resnonse to Interro6atory 240-1(b) is a volunteer fire departnent? (b) How Many fulltime personnel are in each fi e denartment listed in your response tc 240-1(b)? (c) How many nersons have you estimated or connuted will be required for decontamination of evacuees at each shelter listed in your response to 2h0-1(b)? How were these estinates made? Are they in writing? Do these estinates depend on a particular nethod of decontamination, or methods? If so, what are these methods? Please identify all documents concerning the decontamiration nethods to be used by the Chatham County fire departnents, ard ectinates or calculations of the numbers of corsons required to decontaminate evacuees at each shelter, snecifying for which shelter the estinate or calculation is nnde.

(d) Do your past answeas, e.g. to 240-1(d)(iii) as nodified by responses to 2h0-2, fully and connletely describe the capabilities of each Chathan County fire department to carry out decontamination of evacuees from a nuclear accident at Shenron Harris? If not, please p(rovide e) which all RPSadditional information and/or CP&L re and personnel, these howcan&bilities which many, are you you have.

counting on to assist ihm each fire department in decoxntanination in Chothan County?

240-6(a) Where can I get a cory of the Chathan County Denartnent of Emergency Oneration Resources Handbook?Q,$Is this a document Co&L possesses? (c) Does the State emergency planninF office have a cony?

2h0-7 (a) Who provides backup for decontanination at each site in Chathsn County? (b) What assurancds or agreenents does Chathan County have that such backup will be available? Picase identify all documents other than tho energency plan re such backuo; please identify any soecific parts of the nian other than eart 2 p.35 which concern this natter (backun for decontanination). (c) Can you Adentify any specific parts of the Energency Plan other than eart 2 , p.35, which give information anecifically asked about in the various narts of interrogatory 2h0-37 If so, clease identify all of then fully.

(d) If above (you don't identify scecific parts in resnonse tn vart (c)and/or cast know what they are? Does it nean you haven't looked then un?

Does it mean you don't know if they're in the nian? What does your lack of identifying specific narts or pages of the olan nean with respect to the questions in interrogatory Ph0-37 57-C-7-h(a) Why did you say 57-C-7-2(e) is "not analicable"?

(b) Lo you know the caembilities necessary to treat persons seriously injured by radiation per se? (c) If so, what are these canabilities?

57-C-7-5(a) Hns the State of nC or its nadiation protectinn section l or its energency planners made any investigation into which hosritals (local and regional) near any nuclear olants are canable of nrnviding medical services needed by peonle seriously injured by exposure to radiation alone? (b) Please identify all docunents concerning any such investigation, its results, and/or the capabilities of such hospitals. Please identify the nauclear niants and hospitals involved in each such investigation. (c) Does the State or any county emergency pinnning agency have any information about them ability of local and/or regional hosoitain near the Harris plant site,e.g.

any of those listed on part I pp 60-70 of the energency rennonse plan

' for Harris, to provide medical services for norsons seriously injuaed by e.xposure to radiation? If so, nicane identify all docunonta containing suen information and state what else you know.

b 57

$7-C-7-6(a) In your answer to $7-C-7-3, please identify what portion (s) or pagdhof NUMEG-o654 you believe is annliemble (b) do you believe that persons could be seriously injured by radiation alone in the course of a nuclear accident at the Harris plant? Please state all basis for your belief and identify all documents concerning such belief or its basis. (c) Have workers, e.g. in Czechoslova! cia, been seriously injured by radiation at nuclear power plants? Please identify all documents conearning such injuries which you possess or know of. (d) Do you have any documents concerning the trentment of radiation sickness or other injuries caused by etnosuae to radiation?

Please identify all such documents, and any documenta you nossess which include such information.

57-C-7-7(a) In arranging for treatment of persons injured at shearon Harris, did you evaluate the ability of the dcctors and hosnitals (e.g. Max hosnital, NC Memorial) involved there, to treat persons If so, what were the results?

seriously If not, why injured nott by)

(b radiation alone?(including that of any doctors In your oninion on your staff or consulting for you) mi is there any difference botheen the canabilities needed for a hos61tal or doctor to treat a contaminated injured person (e.g. a person with cuts or a broken bone or other injury, who is also contaninated with radioactive material) and the espabilities needed to trent a person seriously injured by radiction exposure? If there are, what are the differences? Please give all basis for your answer and identify all documents concernf ng i

the differences of which you or your staff or consultant (s) are aware.

1 PRODUCTION OF DOCUENTS Wells Eddleman hereby requests that the original or best copy of all documents identified in response to any of the above

interrogatories be made available for insnection and conying at a mutually agreeable time and niace.

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i 1& W l wells saaleman, lo/e/8h 4

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7 UNITED STATES OF AMERICA NUCLTAR REGULATORY CO2CUSSION In tr.e matter of CAROLIKA POWER k LIGtfI CO. Et al. JI Docket 50-400 Shearon Harris Nuclear Power Plant. Unit 1- 0.L.

CERTIFICATE 0F SERVICE 4

I hereby certify that copies of W.9. Interroen+n=les en vof_ c + o c c hyvA

. and separate W.E. Interrogatories to CPAL7m C. Emergenes planners HAVE been served this 8 day of Octnba. 1981, by deposit in the US Wil, firrtJclass postage prepaid, upon all parties whose names are listed below, extspt those whose nanes are erked with for whom se .vice was accorrplished by hand for an interrogatorasterisk, ies to C"&L State of NC/NC county emergency plcnners

, (Delivered to counsel Dale Hollar's office in Maleich NC)

-h4 6 3 press, tviW O(r 9- F A G federd H41cm JudEes Ja tes Kelley, Glenn Bright and James Carpenter (1 copy each)

Atomic Safety and Licensirg Board US Nuclear Regulatory Comission Washin6 ton DC 20555

• George F. Trowbridge (attorney for Applicants) ,

Shaw, Pittman, Potts & Trowbridge R uthanne G. Miller 1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2055 5 g Office of the Executive Legal Director f ce W. Perry Docke ts 50-!+00/401 0.L. "

P 500 C st. sW Hashington DC 20555 Washington DC'207140 Dan Read Docketing and Service Section (3x)

CEME/FLP Attn Docke ts 50-400/h010.L. .

Raleigh,5707 NC Waveross Office of the Secretary 27606

""' Li"d" ** Litt1*

a n3 ton DC 20555 Governor's Waste Mgt. Bd.

513 Albemarle B1dg l

John Runkle -

325 N. salisbut,r St.

I" *

• Grcnv111e Rd .

Chapel Hill Ne 2751h Bradley W. Jones Robert Gruber VSNRC Region II

'Travi s Payne Exec. Director 101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 30303 Diex 12601 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D. Certified by h 729 Hunter St.

Apex NC 27502 s ,

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