ML20094H583
| ML20094H583 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/09/1984 |
| From: | Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | JOINT INTERVENORS - SHEARON HARRIS |
| References | |
| OL, NUDOCS 8408140048 | |
| Download: ML20094H583 (16) | |
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nai.1 L L,.. a .:.uahCE August 9, 1984 00CKETED U3'EC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 84 AM 13 Amu 20 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 SPONSORS OF EPJ-1 and EPJ-2 (FIRST SET)
Pursuant to 10 C.F.R. SS 2.740b and 2.741 and to the Atom-ic Safety and Licensing Board's " Order (Ruling on Various Pro-cedural Questions and Eddleman Contention 15AA)" of May 10, 1984, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that the intevenor spon-sors of EPJ-1 and EPJ-2 answer separately and fully in writing, and under oath or affirmation, each of the following interroga-tories, and produce and perniit inspection and copying of the original or best copy of all documents identified in the re-sponses to interrogatories below. Answers or objections to these interrogatories and responses or objections to the re-quest for production of documents must be served no later than August 30, 1984.
8408140048 840809 PDR ADOCK 05000400 '7 O PDR 03
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 any of the intervenor sponsors of EPJ-1 and EPJ-2 or any individual acting on their behalf obtain any new or differing information responsive to these interrogatories. The request for production of documents is also continuing in nature and the intervenor sponsors of EPJ-1 and EPJ-2 must produce immedi-ately any additional documents any of them, or any individual acting on their behalf, obtains which are responsive to the re-quest, in accordance 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 the sponsors of the joint contention rely.
Definitions. As used hereinafter, the following defini-tions shall apply:
I
" Applicants" is intended to encompass Carolina Power &
\
Light Company, North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.
"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 any of the sponsors or any individual acting on their behalf, including, but not lim-ited to, memoranda, correspondence, reports, surveys, tabu-lations, charts, books, pamphlets, photographs, maps, bulle-tins, minutes, notes, speeches, articles, transcripts,. voice recordings and all other writings or recordings of any kind;
" document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, ' cur control of the sponsors a document ahall be deemed to be within
.the " control" of the sponsors or any individual acting on their behalf if any sponsor (or individual acting on his behalf) has ownership, possession or custody of the document or copy.there-of, or has 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 the sponsors to have first-hand knowledge of the facts alleged, and upon which the sponsors relied in formulating allegations, in each of the contentions which are the subject of this set of interrogatories.
(b). Identify those facts concerning which each such person has first-hand knowledge.
(c). State the specific allegation in each contention which the sponsors 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 the sponsors relied in an-swering 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 the sponsors intend to call as an expert witness or a witness relating to any contention which is the subject of this. set of interrogatories.
(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). Identiff all documents in the possession, custody or control of any of the sponsors, including all relevant page citations, pertaining to the subject matter of, and upon which the sponsors relied in formulating allegations in each conten-tion which is the subject of this set of interrogatories.
(b). Identify the contention (s) to which each such docu-ment relates.
(c). State the specific allegation in each contention which the sponsors contend each document supports.
5(a). Identify all documents in the possession, custody or control of any of the sponsors, including all relevant page citations, upon which the sponsors 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 the sponsors intend to offer as exhibits during this proceeding to support the conten-tions which are the subject of this set of interrogatories or which the sponsors 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.
Interrogatories on EPJ-1 EPJ-1-1(a). Describe and quantify (e.g., stato the amount of specified type of precipitation in a specified unit of time) the weather conditions characterized in EPJ-l as " severe snow and ice conditions."
(b). With respect to each weather condition iden-tified in answer to (a) above, specify the approximate number of times per year that condition occurs in the Harris plume PPZ.
EPJ-1-2(a). Identify specifically all effects of severe snow and ice which the offsite emergency plans have allegedly failed to consider.
(b). 'Specify the bases for your belief that the offsite emergency plans have failed to consider the effects of snow and ice listed in answer to (a) above.
EPJ-1-3(a). Identify and describe in detail all ways in which the offsite emergency plans have allegedly failed to give sufficient consideration to the effects of severe snow and ice on evacuation times.
(b). Specify the bases for your answer to (a) above.
EPJ-1-4(a). Explain in detail and quantity what you be-lieve to be the effect on evacuation times of the alleged fail-ure to give sufficient consideration to the effects of severe snow and ice.
(b). Specify the bases for your answer to (a) above.
EPJ-1-5(a). Identify and describe in detail all ways in which the offsite emergency plans have allegedly failed to give sufficient consideration to " capabilities to clear evacuation routes."
(b). Specify the bases for your answer to (a) above.
EPJ-1-6(a). List the number and type of vehicles (e.g.,
snow plow) and any other resources you believe are needed to
" effectively clear the roads of snow or ice in a reasonable amount of time."
(b). Specify the bases for your answer to (a) above.
EPJ-1-7(a). Identify all bases for your assertion that "the State does not have enough snow plows in this area to effectively clear the roads of snow or ice in a reasonable amount of time."
(b). Identify specifically the bounds of the georgraphic area referred to as "this area" in EPJ-1.
(c). State the number of snow plows which the State has available within the area described as "th'is area" in EPJ-1.
(d). Specify the bases for your answer to (c) above.
EPJ-1-8(a). State the number of snow plows (if any) which are available from sources other than State within the area de-scribed as "this area" in EPJ-1.
(b). Specify the bases for your answer to (a) above.
EPJ-1-9. State, in hours and minutes, the length of "a reasonable amount of time" as that phrase is used in EPJ-1.
EPJ-1-10. Explain in detail why, in your opinion, the roads must be cleared within the amount of time specified in the answer to Interrogatory EPJ-1-9 above.
EPJ-1-11. Describe any and all changes you believe must be made in the offsite emergency plans to meet the concerns ex-pressed in EPJ-1. Describe in detail the bases for your belief that such changes must be made.
EPJ-1-12. Describe any and all actions you believe must be taken, or changes you believe must be made (other than those identified in answer to Interrogatory EPJ-1-11 above) to meet the concerns expressed in EPJ-1. Describe in detail the bases for your belief that such actions must be taken and such changes made.
Interrogatories on EPJ-2 EPJ-2-1(a). State whether you contend that the offsite emergency plan itself must include an " estimate of the number of people without transportation."
(b). If the answer to (a) above is affirmative, identify specifically the source of the alleged requirement that the offsite plan include an " estimate of the number of people without transportation."
EPJ-2-2. State whether you are aware that the estimate of 240 families (at page 3-2 of the evacuation time estimate study for the Harris plume EPZ) is the estimated number of families l
l without transportation in the Wake County portion of the plume l
EPZ, not the entire Harris plume EPZ.
l
! EPJ-2-3. Identify all bases for your allegation that l
" Applicants' estimate of 240 families in evacuation time study (p. 3-2) seems far too low."
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EPJ-2-4(a). State whether you believe that the estimate 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.
EPJ-2-5(a). State whether you believe that the estimate 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 answer 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.
EPJ-2-6(a). State whether you believe that the estimate of 32 households without transportation in the Lee County por-tion of the plume EPZ (at page 3-2 of the evacuation time esti-mate 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 Lee County portion of the plume EPZ, to the best of your knowledge, and specify the bases for your es-timate.
EPJ-2-7(a). State whether you believe that the estimate of 84 households without transportation in the Wake County por-tion of the plume EPZ (at page 3-2 of the evacuation time esti-mate 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.
EPJ-2-8. Describe how you believe people without trans-portation should "get to pick-up points," and explain in detail the bases for your belief.
r 1
l EPJ-2-9(a). Identify specifically (and quantify, as ap-l l propriate) the " criteria" you believe should be applied to de-l termine where pick-up points should be located.
l l (b). Specify the bases for your answer to (a) above.
/
( l l
EPJ-2-10(a). Identify specifically (and quantify, as ap-propriate) the " criteria" you believe should be applied to de-termine when pick-up points should be " established."
(b). Specify the bases for your answer to (a) above.
EPJ-2-11(a). State when you believe pick-up points should be " established."
(b). Specify the bases for your .inswer to (a) above.
EPJ-2-12. Describe any and all changes you believe must be made in the offsite-emergency plan to meet the concerns ex-pressed in EPJ-2. Describe in detail the bases for your belief that such changes must be made.
EPJ-2-13. Describe any and all actions you believe must be taken, or changes you believe must be made (other than those identified in answer to Interrogatory EPJ-2-12 above) to meet the concerns expressed in EPJ-2. 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 sponsors of EPJ-1 and EPJ-2 respond in writing 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,
. LGBL Thorda5' A. Batter, P . C() y1 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 CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Dated: August 9, 1984
S En
'84 gg 9 A10:20 UNITED STATES OF AMERICA khF CE gg NUCLEAR REGULATORY COMMISSION
~
fj.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) )
CERTIFICATE OF SERVICE This is to certify that copies of the-foregoing " Applicants' Emergency Planning Interrogatories and Request for Production of Documents To Sponsors of EPJ-l and EPJ-2 (First Set)",were I
served by deposit in'the United. States Mail, first class, postage prepaid,.this 9th day of August, .1984, to all those on the attached Service List.
P De:.issa A.' Rid'gwhy U (/
DATED: August 9., 1984 L
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400'OL and NORTH CAROLINA EASTERN ) ,
50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
PJant, Units 1 and 2) )
SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire
, Atomic Safety and Licensing Board Conservation Council of j U.S. Nuclear Regulatory Commiss4_on North Carolina
- Washington, D.C. 20555 307 Granville Road Chapel Hill, North Carolina 2751<
Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Commission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C. 20555 Charles A. Barth, Esquire- Mr. Wells Eddleman i 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 Docketing and Service Section Richard E. Jones, Esquire Office of the Secretary Vice President and Senior Counsel U.S. Nuclear Regulatory Commission Carolina Power & Light Company Washington, D.C. 20555 P.O. Box 1551 Raleigh, North Carolina 27602 Mr. Daniel F. Read, President Dr. Linda W. Little CHANGE Governor's Waste Management Board P.O. Box 2151 513 Albemarle Bu.ilding Raleigh, North Carolina 27602 325 North Salisbury Street Raleigh, North Carolina 27611 e
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> Bradicy W. Jcncs, Esquiro U.S. Nuclear Regulatory Commiacicn Region II 101 Marrietta 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 P.O. Box 991 Raleigh, North Carolina 27602 Administrative Judge Harry Foreman Box 395 Mayo University of Minnesota M14c. apolis, Minnesota 55455 Spence W. Perry, Esquire Associate General Counsel FEMA 500 C Street, S.W., Suite 480 Washington, D.C. 20740 i
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request for production of documents must be served no later than August 30, 1984.
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. $ 2.740(e),
should Mr. Eddleman or any individual acting on his behalf ob-tain any new or differing information responsive to these in-terrogatories. The request for production of documents is also continuing in nature and Mr. Eddleman must produce immediately any additional documents he, or any individual acting on his behalf, obtains which are responsive to the request, in accor-dance with the provisions of 10 C.F.R. 6 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.
"Offsite emergency plans" refers to the " North Carolina Emergency Response Plan In Support of The Shearon Harris Nuclear Power Plant," Parts 1-5.
"Onsite emergency plan" refers-to the " Carolina Power &
Light Company, Shearon Harris Nuclear Power Plant Unit 1, Plant Operating Manual, Volume 1, Part 2."
" Document (s)" means all writings and records of every type in the possession, control or custody of Mr. Eddleman 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 Mr. Eddleman; a document shall be deemed to be within the " control" of Mr. Eddleman 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 docu-ment or copy thereof, from any person or public or private en-tity 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 i
s have first-hand knowledge of the facts alleged, and upon which you relied in formulating allegations, in each of your conten-
-tions which are the subject of this set of interrogatories.
(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, emp1. oyer 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.
8 4(a). Identify 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-lating allegations in each contention which is the subject of this set of interrogatories.
(b). Identify the contention (s) to which each such docu-ment relates.
(c). State the specific allegation in each contention which you contend 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). Icentify 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.
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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 s
presented by Applicants and/or the NRC Staff and/or the Federal E
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.
Interrogatories on Eddleman 30 30-1(a). Identify specifically all groups of persons in the Harris plume EPZ whose " evacuation may be infeasible or very difficult" for whom you assert Potassium Iodide'(KI) should be available. .
(b). To the best of your knowledge, state the approx-imate number of persons in each of the groups identified in the answer to (a) above.
(c). Specify the bases for your answer to (b) above.
(d). State the total number of doses of KI that you believe should be available for all persons in the Harris plume EPZ whose " evacuation may be infeasible or very difficult."
(e). Specify the bases for your answer to (d) above.
i 30-2. Describe any and all changes you believe must be made in offsite emergency plans to meet your concern expressed in Eddleman 30. Describe in detail the bases for your belief that such changes must be made.
i 30-3. Describe any and all actions believe must be taken, or changes you believe must be made (other than those identi-fied in the answer to Interrogatory 30-2 above) to meet your concern expressed in Eddleman 30. Describe in detail the bases for your belief that such actions must be taken and such changes made.
Interrogatories on Eddleman 57-C-3 57-C-3-1(a). Identify all NRC and FEMA rules, regula-tions, regulatory guides, and publications which you believe pertain to Alert and Notification Systems for emergencies at commercial nuclear power plants.
(b). State whether you contend that the authori-ties identified in answer to (a) above specify requirements for night notification which differ from those for day notifica-tion.
(c). If the answer to (b) above is affirmative, identify which sections of each identified authority are as-serted to specify different requirements for night notification than for day notification.
57-C-3-2(a) State whether you believe the Alert and No-tification System described in the offsite emergency plans will fail to comply with the authorities identified in the answer to Interrogatory 57-C-3-1(a) above.
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(b). If the answer to (a) above is affirmative, specify all sections of all authorities identified in answer to Interrogatory 57-C-3-1(a) with which you believe the Alert and Notification System described in the offsite emergency plans will fail to comply when that system is activated "at night, e.g. :n the hours between 1 a.m. and 6 a.m."
l (c). As to each section of each authority identi-fled in answer to (b) above, described in detail the bases for your conclusion, including the reasons for identifying the requirement.
(d). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Eddleman 57-C-3.
57-C-3-3. Explain in detail the bases for your belief that the Alert and Notification System described in the offsite emergency plans would not provide " notification at night, e.g.
in the hours between 1 a.m. and 6 a.m. when most people living near the plant would normally be asleep."
57-C-3-4. Explain in detail the bases for your belief that the Alert and Notification System described in the offsite emergency plans would not assure that persons "would be timely awakened to take sheltering action."
57-C-3-5(a). State whether you believe that it is more likely that persons indoors will be alerted by the Alert and
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Notification System described in the offsite plans if the win-dows are open than if the windows are closed.
(b). If the answer to (a) above is other than-affirmative, explain in detail the bases for your answer.
57-C-3-6(a). State whether you believe that more persons
{ in the plume EPZ will have their windows open on a summer night than on a summer day.
(b). Specify the bases for your answer to (a)
, above.
57-C-3-7(a). State whether you believe that more persons in the plume EPZ will have air conditioners on, on a summer night than on a summer day.
(b). Specify the bases for your answer to (a) above.
57-C-3-8(a). State whether you contend that special pro-visions are necessary for night notification of persons in boats or houseboats or other craft on Jordan Lake or Harris Reservoir.
(b). If the_ answer to (a) above is affirmative, describe in detail the special provisions you believe are nec-essary.
(c). If the answer to (a) above is affirmative, specify.the bases for your belief that such special provisions are necessary.
57-C-3-9(a). Describe in detail the " automatic phone-dialing equipment" to which Eddleman 57-C-3 refers.
(b). Identify the entity or entities from which the equipment identified in answer to (a) above is available.
Note specifically which information about equipment availabili-ty has been obtained from Jesse Riley.
(c). Identify all utility companies and govern-mental entities (if any) who have obtained the type of equip-ment described in the answer to (a) above, for use in public alerting and notification in the event of an emergency at a commercial nuclear power plant.
57-C-3-10. Describe any and all changes you believe must be made in the offsite emergency plans to meet your concerns as expressed in Eddleman 57-C-3. Describe in detail the bases for your belief that such changes must be made.
57-C-3-11. Describe any and all actions you believe must be taken, or changes you believe must be made (other than those identified in the answer to Interrogatory 57-C-3-10 above) to meet your concern as expressed in Eddleman 57-C-3. Describe in detail the bases for your belief that such actions must be taken and such changes made.
l Interrogatories on Eddleman 57-C-10 57-C-10-1(a). Identify all NRC and FEMA rules, regula-tions, regulatory guides, publications, and endorsed national standards which you believe pertain to sheltering and its effectiveness in a radiological emergency.
(b). State whether you aaliete the offsite emer-gency plans fail to comply with the authcrities identified in the answer to (a) above.
(c). If the answer to (b) above is affirmative, specify all sections of all authorities identified in answer to (a) above with which you believe the offsite emergency plans fail to comply.
(d). If the answer to (b) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Eddleman 57-C-10.
57-C-10-2(a). Specify and individually describe each and every type of "useful analysis or information on sheltering effectiveness" which you believe should be in:luded in the
- offsite emergency plans, but which is not presently included in those plans.
(b). As to each type of " analysis or information identified in answer to (a) above, specify the bases for your conclusion that it must be included in the offsite emergency plans.
57-C-10-3(a). State whether you contend that the informa-tion presently included in the offsite emergency plans illus-trates a lack of " knowledge of sheltering effectiveness" on the part of offsite emergency response officials charged with pro-tective action decisionmaking.
(b). If the answer to (a) above is affirmative, specify the bases for your conclusion.
(c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Eddleman 57-C-lO.
57-C-10-4(a). State whether you contend that State and local emergency response officials must document the entirety of their knowledge of " sheltering effectiveness" in the offsite emergency plans.
(b). If the answer to (a) above is affirmative, specify the bases for your conclusion, and explain why all such knowledge must be included in the offsite emergency plans them-selves rather than in other reference documents available for reference by emergency response authorities, and specifically how such information would be used for protective action decisionmaking.
(c). If the answer to (a) above is other than affirmative, explain in detail how your response is consistent with the allegations set forth in Eddleman 57-C-lO.
Lm_.
57-C-10-5. Identify all bases for your allegation that offsite emergency response authorities charged with protective action decisionmaking lack " knowledge of sheltering effective-ness."
57-C-10-6. Describe any and all changes you believe must be made in offsite emergency plans (other than those identified in answer to Interrogatory 57-C-10-2(a) above) to meet your concerns expressed in Eddleman 57-C-10. Describe in detail the bases for your belief that such changes must be made.
57-C-10-7. Describe any and all actions you believe must be taken, or changes you believe must be made (other than those identified in the answers to Interrogatories 57-C-10-2(a) and 57-C-lO-6 above) to meet your concerns expressed in Eddleman 57-C-10. Describe in detail the bases for your belief that such actions must be taken and such changes made.
Interrogatories on Eddleman 57-C-13 57-C-13-1. Specify and explain in detail the bases for your assertion that "[t]he highest PF areas [in hospitals and i nursing homes) need to be determined in advance to comply with 10 C.F.R. 50.47(a)(1)'s requirement for assurance of appropri-ate-protective action."
57-C-13-2(a). Specify all " criteria" you believe to be appropriate for " identifying" "the highest PF in hospitals and nursing homes."
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(b). State the bases for your. answer to (a) above.
57-C-13-3(a). Identify the areas of hospitals and nursing homes generally that you believe would have "the highest PF."
(b). State the bases for your answer to (a) above.
57-C-13-4(a). State whether you contend that State and local emergency response officials must document their knowl-edge of "the highest PF in hospitals and nursing homes" in the offsite emergency plans.
(b). If the answer to (a) above is affirmative, specify the bases for your conclusion, and explain in detail why all such knowledge must be included in the plans them-selves.
(c). If the answer to (a) above is other than affirmative, explain in detail how your response is consiatent with the allegations set,forth in Eddleman 57-C-13.
57-C-13-5. Describe any and all changes you believe must be made in offsite emergency plans to meet your concerns ex-pressed in Eddleman 57-C-13. Describe in detail the bases for your belief that such changes must be made.
l 57-C-13-6. Describe any and all actions you believe must be taken, or changes you believe must be made (other than those l identified in the answer to Interrogatory 57-C-13-5 above) to
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meet your concerns expressed in Eddleman 57-C-13. Describe in detail the bases for your belief that such actions must be taken and such changes made.
Interrogatories on Eddleman 144 144-1(a). Identify specifically (by reference to Major Functional Area, Major Tasks and Position Title or Expertise) each and every case in which "CP&L's emergency personnel lev-els" allegedly do not meet the provisions of Table 2 of NUREG-0737, Supplement 1 for "On-Shift" personnel.
(b). Specify the bases for your answer to (a) above.
144-2(a). Identify specifically (by reference to Major Functional Area, Major Tasks and Position Title or Expertise) each and every case in which "CP&L's emergency personnel lev-els" allegedly do not meet the provisions of Table 2 of NUREG-0737, Supplement 1 for " Capability for Additions" within 30 minutes.
(b). Specify the bases for your answer to (a) above.
144-3(a). Identify specifically (by reference to Major Functional Area, Major Tasks and Position Title or Expertise) each and every case in which "CP&L's emergency personnel lev-els" allegedly do not meet the provisions of Table 2 of NUREG-0737, Supplement 1 for " Capability for Additions" within 60 minutes.
(b). Specify the bases for your answer to (a) above.
144-4. Describe any and all changes you believe must be made:in the onsite emergency plan to meet the concerns ex-pressed in Eddleman 144. Describe in detail the bases for your belief that such changes must be made.
144-5. Describe any and all actions you believe must be taken, or changes you believe must be made (other than those '
identified in answer to Interrogatory 144-4 above) to meet the concerns _ expressed in Eddleman 144. Describe in detail the bases for your belief that such actions must be taken and such changes made.
Interrogatories on Eddleman 154 154-1(a). State whether you contend that Annex B of the onsite emergency plan is the " procedure" for dose projection.to
.be followed by " plant operators" in an emergency. ~
(b). If the answer to (a) above is affirmative, state the bases for your answer.
(c). If the answer to (a) above is other than affir-mative, explain in detail how your response is consistent with the allegations set forth in Eddleman 154.
154-2(a). State whether you are aware that Annex B of the onsite emergency plan provides the technical bases for dose projection, but is not itself the " procedure" for dose projection to be followed by " plant operators" in an emergency.
8 (b). If the answer to (a) above is other than affir-mative, state the bases for your answer.
154-3. State whethar you are aware that Annex E to the onsite emergency plan is a list of plant emergency procedures, which indicates that Plant Emergency Procedures 0-PEP-341, 0-PEP-342, 0-PEP-343, and 0-PEP-344 are entitled, respectively,
" Initial Dose Projections," "Whole Body Dose Projections,"
" Thyroid Dose Projections" and " Automation of Dose Projection Procedures."
154-4(a). List and describe in detail all steps which you believe " plant operators" must take in the performance of a dose projection.
(b). With respect to each step listed in answer to (a) above, state whether you believe " plant operators" are ca-pable of properly implementing that step.
(c).
With respect to each step identified in (b) above as one which " plant operators" are allegedly unable to properly implement, state the bases for your belief as to the alleged incapability of the " plant operators."
154-5(a). State whether you contend that " plant opera-tors" lack sufficient formal education to make dose assess-ments.
(b). If the answer to (a) above is affirmative, specify the bases for your answer.
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(c). If the answer to (a) above is affirmative, identify specifically the formal education you believe is needed to make dose assessments, but which you believe " plant operators" lack, and explain why you believe such education is necessary, and the bases for your belief that " plant operators" lack such education.
154-6(a). State whether you contend that " plant opera-tors" lack adequate training to make dose assessments.
(b). If the answer to (a) above is affirmative, specify the bases for your answer.
(c). If the answer to (a) above is affirmative, identify specifically the training you believe is needed to make dose assessments, but which you believe " plant operators" lack, and explain why you believe such training is necessary, and the bases for your belief that " plant operators" lack such training.
154-7(a). Identify specifically all ways in which, in your opinion, " plant operators" are " unqualified" to make dose assessments (other than those identified in answer to Interrog-atories 154-1 and 154-2 above). ,
(b). Specify the bases for your answer to (a) above.
154-8. Describe any and all changes you believe must be made in the onsite emergency plan to meet the concerns ex-presse1 in Eddleman 154. Describe in detail the bases for your belief that such changes must be made.
154-9. Describe any and all actions you believe must be taken, or changes you believe must be made (other than those identified in answer to Interrogatory 154-8 above) to meet the concerns expressed in Eddleman 154. Describe in detail the bases for your belief that such actions must be taken and such changes made.
Interrogatories on Eddleman 213 213-1(a). Identify specifically and describe in detail any provisions you believe should be included in the notifica-tion plan for Harris Reservoir which are not included in the
. notification plan for Jordan Lake. l (b). Specify the bases for your answer to (a) above.
213-2(a). Specify the number of boats you believe are necessary to provide notification for Harris Reservoir.
(b). Specify the bases for your answer to (a) above.
213-3(a). Specify the number of personnel you believe are necessary to provide notification for Harris Reservoir.
(b). Specify the bases for your answer to (a) above.-
213-4(a). Identify.specifically and describe in detail all " provisions for boat or traffic accidents" in an evacuation of Harris Reservoir which you believe should be made, including
" limiting the number of boaters on the lake when the Harris re-actor is critical or whenever fuel handling operations are in progress at Harris."
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(b). Specify the bases for your answer to (a) above.
213-5(a). State whether you know of any lake where the number of boaters on the lake is limited to a specified figure during the period when a commercial nuclear power plant within a ten-mile radius of.the plant is " critical" or " fuel handling operations are in progress."
(b). If the answer to (a) above is affirmative, list the name:of each and every such lake, and the name of the com-mercial nuclear power plant within a ten-mile radius of each identified lake.
213-6(a). Explain in detail why you believe that
" swimmers and water-skiers *** will be harder to get out."
(b). Identify all bases for.your allegation that ,
'" swimmers and water-skiers *** will be harder to get out."
213-7. Describe any and all changes you believe must be made in offsite emergency plans to meet your concerns expressed in Eddleman 213. Describe in detail the basas for your belief that such changes must be made.
l 213-8. Describe any and all actions you believe must be taken, or changes you believe must be made (other than those identified in the answer to Interrogatory 213-7 above) to meet your concerns expressed in Eddleman 213. Describe in detail the bases for your belief that such actions must be taken and such changes made.
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Interrogatories on Eddleman 215 215-1(a). State the occupation and business address of
" expert Paul Holmbeck."
(b). Identify the professional and educational qual-ifications and experience of " expert Paul Holmbeck."
215-2. For each individual alleged " conservatism" identi-fled in Eddleman 215, specify the bases for your allegation that the specific alleged conservatism "may force evacuation time estimates upwards and provide inaccurate estimates for de-cisionmakers during an emergency."
215-3. Identify specifically all groups of persons for whom you contend the " assumption of evacuation from home" is unrealistic.
215-4(a). With respect to each group identified in answer to Interrogatory 215-3 above, state whether you centend that the members of that group would not return to their homes be-fore evacuation.
(b). With respect to each individual group identi-fled in answer to Interrogatory 215-3 above, specify the bases for your conclusion as to whether the members of that group would return to their homes before evacuating.
215-5. Identify all bases for your allegation that
"[h]ouseholds with 2 vehicles may evacuate in both vehicles rather than linking up."
215-6. Identify the approximate percentage of households in the Harris plume EPZ which own two vehicles.
215-7. Identify the approximate percentage of households in the plume EPZ with two vehicles which you believe "may evac-uate in both vehicles rather than linking up."
215-8. Identify all bases for your allegations challenging the " apparent assumption that those households without vehicles will automatically evacuate with neighbors (or can) at the rate of one vehicle per household." '
215-9. Identify the approximate percentage of " households without vehicles" which you believe might be unable to obtain evacuation transportation through neighbors, friends or rela-tives.
215-10. With respect to each individual " conservatism" alleged in Eddleman 215, describe in detail the changes you be-lieve must be made in "CP&L's evacuation time study" to meet your concern with respect to that specific " conservatism."
Interrogatories on Eddleman 224 224-1. Explain in detail what type of information you understand must be included in an evacuation time estimate study to comply with the NUREG-0654 provision that "[t]he ad-verse weather frequency used in [the) analysis shall be identified"
. . . _ . - _ _ _ _ _ _ ________J
,Ae _ 4._ + - - - A 224-2. Explain in detail why you believe NUREG-0654 pro-vides for the identification in an evacuation time estimate study of "[t]he adverse weather frequency used."
224-3(a). Explain in detail why you believe a failure to 4
" identify the adverse weather frequency used" would make an evacuation time estimate study " unreliable for guiding emergen-cy response personnel in decision making."
(b). Specify the bases for your conclusions in an-j swer to (a) above.
224-4. Describe specifically any and all changes you be-lieve must be made in the evacuation time estimate study for the Harris plume EPZ to meet your concerns expressed in Eddleman 224.
Request For Production Of Documents 4
Applicants request that Intervenor Wells Eddleman respond in writing to this request for production of documents and pro-duce the original or best copy of each of the documents l
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m identified or described in the answers to each of the above in-terrogatories, at a place mutually convenient to the parties.
Respectfully submitted, r
A 1 lt AsiY16 Thomah A. Ba'x Eef', I P $. G Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Gtreet, N.W.
Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn Dale Hollar CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Dated: August 9, 1984 1
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Of r CE cr - -
BEFORE THE ATOMIC SAFETY AND LICENSING BOAR [fC 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) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Emergency Planning Interrogatories and Request for Production of Documents To Intervenor Wells Eddleman (First Set) " were served by deposit in the United States Mail, first class, postage l_ prepaid, this 9th day of August, 1984, to all those on the attached Service List.
nb1 NJA (f'
Delissa'AY Ri8gwtPy DATED: August 9, 1984 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400'OL and NORTH CAROLINA EASTERN ) .
50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
SERVICE LIST i
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 2751<
Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Commission
- P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C. 20555 Charles A. Barth, Esquire Mr. Wells Eddleman i
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 Docketing and Service Section Richard E. Jones, Esquire Office of the Secretary Vice President and Senior Counsel U.S. Nuclear Regulatory Commission Carolina Power & Light Company Washington, D.C. 20555 P.O. Box 1551 Raleigh, North Carolina 27602 Mr. Daniel F. Read, President Dr. Linda W. Little CHANGE Governor's Waste Management Board P.O. Box 2151 513 Albemarle Building Raleigh, North Carolina 27602 325 North Salisbury Street Raleigh, North Carolina 27611 i
'- - Brcdicy W. Jcncs, Esquiro U.S. NuclCar R gulatCry Connicsicn Region II 101 Marrietta Street Atlanta, Georgia 30303 Steven F. Crockett, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washinguen, D.C. 20555 .
Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. 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 4
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