ML20093D845

General Interrogatories & Request for Production of Documents.Related Correspondence

ML20093D845
Person / Time
Site:	Harris
Issue date:	10/08/1984
From:	Eddleman W EDDLEMAN, W.
To:	Federal Emergency Management Agency, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
CON-#484-429 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8410110427
Download: ML20093D845 (2)

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October 8, 1984 NUCLEAR BEQULATOBY COMMISSION

'84 0CT 11 N1 :28 BEFORE THE A'IVMIC SAFET[ AND LICENSING BOABD Jr.:E n .,.:

Glenn Dr. O. Bri James H.ght h W ""^SU Carpenter James L. Kelley, Chairman In the Matter of CAB 0 LINA POWER AND LIGHT CO. et al.

(Shearon Harris Nuclear Power Plant, Unit 1) ASLBP No. 82-h68-01

) UL Wells Eddleman's General Interrogatories and Interrogatories and Request for Product $on of Documents to FEMA /NRC Staff General Interrogatories: A. Please provide answers to any general interrogatory in the 9/5/84 set for which the answer has now changed.

B. has a copy of the NRC-FEMA Memorandun of Understanding been l- prev $ously provided to Wells Eddleman by the Staff (s)? If not, are you willing to provide a cony?

C. Do either FEMA Staff or NRC Staff have any objection to me or

, persons working on my behalf observing the test of the Harris

! emergency plan when it hanpens? Are you willing to work out arrangements for such observation? If you have objections, what are they? Do you believe any of these objections could be resolved on an informal basis (e.g. without a Board ruling)? If so, which?

Request for Production of Documents l Vells Eddleman hereby requests that the original or best cony or a fully legible cony of any documents identified in resnonse to interrogatories herein, be made availhble to him for insnection and conying at a mutually agreeable time and place, of that such t

document be placed in the NRC8s Public Document Room and its location / identifier or identifying information be made available to him.

240-k(a) is it still true that you can't identify any documents in response to interrogatory 240-3? (b) If you can't identify the l documents, what is the basis (if any) for each answer to each part l of your trevious responses to all parts /subnarts of 2h0-1 and 240-2?

Please give the basis separately for each part and subnart of each

! of 240-1 and 240-2.4)What specific cites to the ERP for Harris can you make in response to 240-2(d)? (d) What information, if any, will you provide as a supplemental answer to 2h0-3?

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2-213,A-h: Please provide actual answers to the parts of interroFatories 213%A-1, 213-A-2, and for 213-A-3 as previously served.

213-A-5(a) Please state exactly what the nature of the review of item P-7 of -NUREG-0654 which was performed by (i) the RAC (ii)

FEMA Staff, was, and when it was done and by whom. (b) Please describe exactly what it is in the ERP dhat meets criterion II.P.7 (c) How do you interpret the term "in the plan"-- to be cited, to be included, or some other interpretation (please specify).

(d) How s do you interpret the term " included in the nian" --

to be referenced, to be cited, or to be actually. included, or some other interpretation (please specify).

213nA-6(a) Has any cony of the RAC or FEMA staff evaluation s of the Harris ERP been served on (i) NRC Staff (ii) NC Emergency Planners (iii) other NC government or county government agencies or personnel (iv) CP&L (v) NCEMPA (vi) Harris licensing proceeding intervenors? (b) Has any cony of the RAC or FEMA staff evaluations been made available to anyone in any of the listed grouns in subparts (i) ... (vi) to (a) above? If so, to whom, when and why???

(c) Are you aware of FEMA counsel Perry's statements in the Harris licensing case prehearing conference of May,1984, regarding availability of the results of these reviews to the parties to that case? (d) Do you believe FEMA is in compliance with such statements? (e) Do you have available to you a cony of the transcript of the Harris OXL case (NRC Docket 50-h00) prehearing conference i

of May 1984 in which FEMA counsel Perry participated or appeared?

57-e-7(4)(a) Is there an arrangement or tynographical error on page 12 of your responses to previous Eddleman/J.I. inte=roga bories concerning contention 57-C-77 (b) If so, what is the correct answer or answers'to 57-c-7-2 and -3??

57-C-7-5(a) Please provide a more comolete answer to 57-C-7-3 ("57-C-3")

answering varts (i) thru (iv) or specifying to whichpart(s) your answer suplies. (b) What requirements, if any, are you aware of for (i) evaluation (ii) canability (iii) listing, of hospitals

. with the capability to treat severe radiation exuosure injuries, are you aware of under NRC or FEMA guidelines, rules or regulations? J Please specify each such rule or regulation or guidance and give i a comulete answer.- l 57-C-7-6(a) Please provide a more comulete answer to 57-C-7-2, l giving answers to each of its parts. (b) Does FEMA have any ulans for listing, evaluating, or otherwise inquiring into the canability of hospitals around the Harris niant to treat severe radiation injury per se? (c) If so, please detail all such plans re items inquired a'o out in thi(b) above. (d) If you have actually done any of the things inquired about in part (b) above, please tell what (

you have done and all results of it. l 57-c-7-87(a) Please identify all sources of information you rely on or use in making your answers to the above and all nrevious interrogatories on 57-C-7 f

8 October 1984 , 14sc - 4 Wells Eddleman l

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