ML20093D955

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

ML20093D955
Person / Time
Site:	Harris
Issue date:	10/08/1984
From:	Runkle J CONSERVATION COUNCIL OF NORTH CAROLINA
To:	CAROLINA POWER & LIGHT CO.
References
CON-#484-427 OL, NUDOCS 8410110483
Download: ML20093D955 (5)

Text

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.q yg RELATED CC:tRESPONDEth Octobar 8,1H'4 [

UNITED STATES OF AMERICA '~

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 24 '; [ l j All :30 In the Matter of ) $u .N,; Af ~ f M;..

) Docket No. 50-400 oil.m '- ~

Carolina Power & Light Company )

And North Carolina Eastern Municipal )

Power Agency ) ,

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(Shearon Harris Nuclear Power Plant) )

s CONSERVATION COUNCIL'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS T0-APPLICANTS ON EMERGENCY PLANNING CONTENTIONS (FIRST SET) ,,!

Per the Board's Memorandum and Order, dated August 3,1984, .'re las t '

day for filing discovery requests en emergency planning contentions is

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October 8, 1984. The last day to respe,nd to these requests is to be ,

October 31,:1984, withthedeadlineformotions.forsummarydispositiktobe Decenber 21, 1984.- The Conservation Council is the lead intervenor on EPJ 3.

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', ,it L L INTERROGATORIES ON EPJ 3 (VOLUNTEER WORKER CONFLICT) 3-1 For each of the responses below, etate who made the response, their position, j s !' t and business address. 4 r

~3-2 For each of the responses below, supply all basis for the response, i

including all material they relied on in responding (cite each fdlly)'.

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3-3 Whatwitnesses do Applicants expect to present in the hearing on this contention? For each, include naie, eddress, position, and summary of their ,

testimony.

3-4What'isthetotalnumberofvolunteerworkersj-includingvolunteerpolice, rescue, fire departments, and teachers--expccted to be utilized during an alert? s

) i 8410110483 841006 .g PDR ADOCK 05000400 PDR G

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Page 2-3-5'For{each of the workers enumerated ia the; response to Interrogatory 3-4

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ab'ove,:please answer the'following:

'a)'what is his/her current position? (ex. volunteer fireman, etc.)

b) what role is he/she expected to play during an alert?

c) how.will he/shh be alerted as to the emergency?

'd) how long will it:t.se him/her to arrive at his/her-position during S 'the alert after he/she is notified?-

se e) how:long is he/she expected to be at: that position?.

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'f) what duties will he/she be expected to fill during the alert?

s g) in'what manner will he/she be permitte'd to communicate with his/her family while at his/her position?

dbh h)'is he/she expected to relieve any other workers (paid or volunteer)?

l, i)'how will he/she be allowed:any time off for food or necessities 8

\ ,, while on duty?

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3-6 What training will each of . the workers enumerated in the response to

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p Interrogatory 3-4 above receive in the following areas:

a) the duties.he/she is expected to perform during an alert?

i-b) the hazards of radiation?

c) the proper use of monitoring devices?

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, d) the proper use of protective gear?

e) how to communicate to others.under his/her supervision what is

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happening during the alert?-

'3-7 For any training described in the response to Interrogato'ry 3-6 above,

. - please answer the following:

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a) who will conduct the training?

(0-40~ b) how often will the training be conducted?

c) will any of this training be certified?

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Page 3 d) how will the persons.doing the training ascertain whether all of the both volunteer workers needing training have been/ trained and trained properly?

3-8 Please provide a brief summary of the training described in the response to Interrogatory 3-6 above.

3-9 Have the Applicants contacted all organizations and agencies which are expected to supply volunteers during an alert?

3-10 Which agencies and organizations have been contacted?

3-11 For each agency listed above in the response to Interrogatory 3-10, please answer the following:

a) who made the contact?

b) which personnel of the agency or organization was contacted?

c) when were these contacts made?

d) what was discussed during each contact?

e) have memoranda of understanding (MOUs) or any other such documents been signed with any of the contacted agencies?

3-12 Have Applicants or any person under their direction studied the potential in volunteer workers role . conflicts /which might occur around the Shearon Harris site during an emergency?

3-13 Are Applicants aware of any studies made of role conflict around any other nuclear plant during an emergency?

3-14 Are Applicants aware of any studies made of role conflict during any other emergencies, i.e. not related to nuclear plant evacuation?

3-15 Have Applicants or any person under their direction studied the locations of the families of volunteer workers enummerated to the response to Interrogatory 3-4 above?

3-16 If the response to Interrogatories 3-12 through 3-15 above is affirmative, please provide a copy of that study or studies.

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Page 4 3-17 Do the contracts of teachers who are expected to respond to an alert contain explicit provisions ' relating to 'such alerts?

3-18 If the response to Interrogatory 3-17 above is affirmative, what provisions are in the teach'er contracts?

3-19 How many students will each teacher be expected to supervise?

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3-20 How many teachers and students will be on each bus?

3-21 H,w many teachers and students will be in each shelter?

3-22 How many of the volunteer workers expected to respond to an alert will

- .in fact respond? Please explain the response.

3-23 What steps have been taken to identify those volunteer workers which might not-respond to an alert?

3-24 For which organizations (volunteer and non-volunteer), have the Applicants paid attention to the composition which would avoid conflict between organizational and family responsibilities?

3-25 For each organization identified in the response to Interrogatory 3-24, what was done?

REQUEST FOR PRODUCTION OF DOCUMENTS For each document referred to above, will Applicants make it available to Counsel for the Conservation Council at a mutally agreed upon location?

Respectfully submitted, ohn Runkle General Counsel Conservation Council of NC 307 Granville Road Chapel Hill, NC 27514 919/942-7935 942-0600 This'istheffthdayofOctober,1984.

CERTIFICATE OF SERVICE IherebycertifythatcopiesoftheConservationCouncil'skhfghrEkatories and Request for Production of Documents to Applicants on Emergency Planning Contentions (First Set) were served upon the following persons by deposit in the U.S. Mail, postage prepaid, or by hand delivery to the fS41o@lhd:} A)) 3 1 James L. Kelley Richard E. Jones ,. ..

Atomic Safety & Licensing Board Vice PresideptykpF&L ,[jf__y' ,g i.

US Nuclear Regulatory Commission PO Box 1551' .;ANCH Washington, D.C. 20555 Raleigh, NC 27602 Glenn O. Bright. Robert Gruber same address Public. Staff, Utilities Commission PO Box 991 Dr. James H. Carpenter Raleigh, NC 27602 same address Thomas Baxter Docketing and Service (3cc) Shaw, Pittman, Potts & Trowbridge Office of the Secretary 1800 M S treet, N.W.

US Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 Dr. Linda Little Charles A. Barth Governor's Waste Management Board Office of the Executive Legal Director 325 N. Salisbury St. , Room 513 US Nuclear Regulatory Commission Raleigh, NC 27611 Washington, D.C. 20555 Daniel F. Read I

PO Box 2151 Raleigh, NC 27602 .

. gehn Runkle Conservation Council of NC M. Travis Payne PO Box 12643' 307 Granville Road Chapel Hill, NC 27514 Raleigh, NC 27605 Dr. Richard D. Wilson This is the th day of October, Ap x NC 2 50 Wells Eddleman 718-A Iredell Street Durham, NC 27705 Bradley W. Jones US NRC--Region II 101 Marrietta Street Atlanta, GA 30303 Spence W. Perry Associate General Counsel FEMA 500 C Street, S.W. Ste. 480 Washington, D.C. 20740 L__