ML20102A079

Seventh Set of Interrogatories & Request for Production of Documents Re Eddleman Contentions.Related Correspondence

ML20102A079
Person / Time
Site:	Harris
Issue date:	02/04/1985
From:	Eddleman W AFFILIATION NOT ASSIGNED, EDDLEMAN, W.
To:	Federal Emergency Management Agency, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
CON-#185-465 82-472-03-OL, 82-472-3-OL, OL, NUDOCS 8502080119
Download: ML20102A079 (6)

Text

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s.. 1 giATED Cop UNITED STATES 02 AMERICA i

EUCIEAR BEGULATORY COMMISSION 4W .

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BEFORE THE OIenn Dr. ATOMIC James 0..Bri H.ght8AFETY AND LICENSING BOARD Carpenter James L. Kelley, Chairman Q(:lg L -

MANCH

.- In the Matter of Docket 50 400 OL CAROLINA 70 WEB AND LIGHT CO. at al.

gearonBarrgsNuclearPowerPlant, t 1 ASLBF No. 82 1-03

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Wells Eddlenan's" Interrogatories to RC Staff 'and PEMA l

Q% 'g . Set) 4l &

- and FEMA i

Wells Eddleman here re nests the NRC Staff4to answer the following interrogatories before , Q or such other date as counsel for the Staff l t and I agree on. These f.nr. pr 1gatories are subr.itted under 10 CPR 2 720(h)(ii), FEM

- and inquire into the studies, information, and . knowledge of NRC staff with

~ respect to my contentions, on which ' discovery is now open. Since I cannot read F

the minds of the staff, and this information is not contained in documents which the staff has provided to ne, I an unable to obtain this information by

. other means. W ere the information is contained in a document I can obtain i~ from NRC (Public Document Room, etc). I still need the identification of the document in order to obtain the information. The staff has resources and

' information which exceed what I have, and as a party," their position and information are necessary to making my osse in this proceeding. These interroga.

tories are continuing in nature and should be supplemented when answers change.

GENERAL IlCERROGATORIES , ~ ~~'

In all interrogatories herein, "you" or" Staff" means NRC Staff;or'.TEWA:h' 4

e For each of eegte,nti.one .;g , ' ~ y g ' Eddlenan conte,ntions p ( ,~ -

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please pro; vide we fo1 Towing information tqr answering sad of these qu stions. ,

&Q#5 orD *s eVQ Ra,q$

1. , Mat is MRC Staff 8 anding(df the , subject matter of this i: contention? A

2. Bahc fEmNar hb5(igb$nEnto.(a)thiscontention(b) the subject matter of this contention (c) the allegation (s) in this contention

(d) the basis of this contention (e), the information relied upon tqr intervenor(s)

.in support of this contentiont

3. For all parts of your response to Interrogatory 2 above-for d ich your answer is affirmative, please provide the following informations who made g

- the analysis, inquiry, study or investigations what was being considered in

" such analysis, inquiry, study or investigation ("AISI"): the content of the

- 'AISI the results of the AISI, whether the AISI has been oompleted, whether

.. .g or t da is, eti the AISI has been established if it is not complete, documents used in the AISI, all persons consulted B502000119 850204 .

PDR ADOCK 05000400

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in thh oontse cf the;AISI, ou docun:nts contcining information discsvered *

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f or analysis or study or information developed during or os a rosult cf the .

AISI (identify each such doeweent and state what information or results it contair.3), 2 ether staff believes additional analysis is warranted, or further AISI needs or may need to be undertaken on this contention, and tether any persons participating in the AISI are to be called as vitnesses fe; the Staff in this ease,and d at questions the staff AISI is l intended 4.

to (nswer and dat information it seeks to develop if it is

- answer is other than affirmative, please state (a) whether RC staff ee FE@

plans to perform any AISI on this contention, (b) whether anyone on

- EC Staff has stated that AISI of any) kind is warranted for this conten #

(even though it has not been made) (c l on this contention include a date for beginning or for ending such AISI, t

ffM ory(d) those dates, fcr an affirmative answers to to underta'ce on this contention (g)(su why h) all reasons reasons no AISI *y hasnobeen AISI is planned this contention if none is plannedis contention if none has been done (i) Wat the resp done yet tsn j of EC stnfO ofthFeJnn respect to this contention are.

op w 4, W.

aff relied on in opposing the admission

3. Identify an documents the l of this osntention, and any specif e facts not stated in the Staff's opposition j

to admission of such contention (already filed in this case) upon which Statt relied in making such opposition.

6. Identify an doounents not identified in Staff's interrogatories to )

Wens Eddlexan or to Joint Intervenors (to present -- a continuing interrogator upon eith the Staff relied in making each such interrogator {.

FEthM Of E C staff position i 7. Identify by name, personal or business address,i or title (if ag), and telephone number (if known) each person on EC staff or consultant to EC staff or known to EC Staff or consulted by NRC staff in the staff's analysis of the subject matter of this contention prior to (a) its filing (b) its adnission; state for each such person what analysis was performed tqr that person.

8. State au professional qualitioations of each person identified in response to interrogatories 7,,

• 17 4; .

7. Provide any statements of the analysis made by persons identified in response to interrogatories 3,4, or 7k above, and identify an docunents containing such information or statements not previously identified. -

10. Give the identifier mmber, date, source,'and title of an dociuments identified in response to interrogatories above, t ich are available through RC PMR (Public Document Room).

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n. Win EC Staff nake available oopies of. documents identified in response to the above interrogatories to Wens Eddleman for inspection and copying, for documents not available through E C's PIRT fg /VI /) Of'

12. Identify tqr name,4 EC staff position if sy, address and telephone

' nunber each person som NRC staff intends to sons use or call as a witness in this proceeding.

13. State funy the professional qualitioations of each person identified in response to interrogatory 12 above.

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- . 3 14 Smunarise the position (or planned testimony) with rsspect to a

each contention on which such person is expected to testify, for each l

person identified in response to interrogatory 12 above.

& Of C Staff, any witness identified in response to interrogatory

15. Na 12, or ago acting in behalf of.the Staff or such a witness or at their direction, made av oalculation or analysis (not identified in response to l

interrogatories 1 through 4 above) with respect to this contention?

16. If the answer to interrogatory 15 above is yes in any case, provide the name, business or personal address, telephone number and professional qualifica.tions of each person to has made such calculation or analysis, stating for each dat contention it relates to. Wat person (or Staff) it was nade for~or at the direction of, and identifying an documents containing such omiculationer analysis and an doounents used in y.aking such calculation or analysis or relied upon in it or supplying infornation used in it.

17 Provide a sumary of each AISI, calculation or analysis Adam for d ich the answer to interrogatory,15, or interrogatory 2 above, is yes.

18. Please give the secession number, date and originator of each document identified in response to interrogatory 16, which is available at the RC PE.

M&of C Staff make available to Wens Eddle .an for inspection and i 19. WL l copying all ocu: tents identified in response to interrogatory 16 above which are not available through the PET

20. Identify each person, including tele l of expertise and qualifications (cor.plete) if any) em t o(phone answerednumber, addres l

interrogatories with respect to this contention; if ~. ore than one person t

contributed to an answer, identify each such person, providing the information requested above in this interrogatory for'each such person, and state what each such person's contribution to the answer was, for each answer.

21. Identify a n documents d ich the oposes or intends to use as exhibits with respect to this contention during this proceeding, including I

exhibits of Staff witnesses (identifying the witness for each, if such a witness has been designated), and exhibits to be used'during cross-examination of witnesses of a v party (stating for each d ich witness it is to be used in cross-exanination of), and identifying for each the particular pages or chapters to be used as exhibits.

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22. Identify an documents dich MRC 4 staff relied upon in answering interrogatories with respect to this oontention. Wich have not been identified in response to interrogatories 1 through 21 above, stating for each which answer (s) re which contention (s) it was used for, and each

specific fact and page number therein on dich NRC staff relied or which ERC stait used in answering such interrogastory.

23. Please give the accession number, date, and originator of each document identified in response to interrogatories 21 or 22 above which is available through the NRC PE.

f provide Wsus Eddleman with oopies of the documents

24. Willin response to interrogatory 21 or 22 above d ich are not available 5

identified at the FM , for inspoetion and copying?

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25 Identify any other information or source or information not #

identifiedinresponsetothetheaboveinterrogatories1thru2gplubk q (V upon whichofany member staff member used, inofanswering NRC staff each reliefd, or which any interrogatory withsuch respect

,.T to this contention, naming the contention and response in which each such source was used, and the location of the information used or relied on in such source (e.g. page number, section, chapter, etc).

2 (a) Does the Staff erFelt now agree with the contention? (b) Does the Staff not agree withiny part of the contention?

27 If answer to (b) above is affirmative, which part(s) and why?

41-G-1. Please identify fully all documents which (a) contain any of the followings (i) any information in the ' personnel file of Chan Van Vo (also known as Van Vo Davis,or the same person under any i other name)

(ii) Chan Van Vo's application for employment, work assignments, work record, transfers, applications for transfer, job performance evaluations, probation, disciplinary actions proposed or taken with respect to Chan Van Vo or Van Vo's termination from CP&L, any written or verbal warnings to Chan Van Vo s all records of Van Vo's attendance, hours worked, promotion (s), recommendations for promotion (s),

and any other information concerning Van Vo's employment, work performance, hiring, " counselling", or allegations raised by Chan Van Vo concerning safety (or lack of it) of work related to the Shearon Harris Nuclear Power Plant.

(iii) Any records or documentation concerning, directly or indirectly, any and ell meetings, conversations, inter-views, discussions, or information not to be discussed (in all cases including written or verbal, formal or infor-mal meetings, discussions, etc.) with anyone (including other CP&L and Daniel employees or other persons employed at the Shearon Harris site, supervieors, CP&L quality assurance personnel, M.A. McDuffie, E.E. Utley, NRC personnel, other investigators, news media, or anyone else) which directly or indirectly concerns Chan Van Vo, his work performance, his safety concerns, any others

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concerns raised by him to CP&L supervisional management, .

disciplinary action against Chan Van Vo, " counselling" Chan Van Vo concerning work performance or any other matters, transfers, promotions, hiring, firing, harassing,

. _. ._.m. .

er retalisting aglingt Chan Van Vos or allegations raised by Chan Van Vo with the Nuclear Regulatory Commission (NRC),

Department of Labor (DOL), Department of Justice (DOJ),

Government Accountability Project (GAP), Citizen inte.rvenor groups or individuals, news media, or any government or private investigatory body. -

(iv) .siny~other information directly or indireptly concerning,

~ evaluating, discussing, or in any way mentioning Chan Van I

Vo, any proposed or actual action taken against him, or any other information concerning Chan Van Vo or his safety concerns or other concerns o

(v) any and all internal CP&L or external investigations or t inquiries concerning Chan Van Vo, his work performance, any action against Chan Van Yo, any action proposed to be taken with respect to Chan Van Vo, any allegations made by Chan Van Vo or any contacts between Chan Van Vo and'NRC or DOL' or DOJ or GAP or any citizen intervenor '

i group. or any news media or any other persons h '(vi) any records or evaluations or Chan Van Vo's work performance, ,

, including evalutions made either before, at the time of, Nor.after Chan Van Vo's being placed on probation:

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.(vii)[any evaluations or reports on Chan Van Vo's allegations

- (including the Cobb Report), identifying each document 4 produced or used in preparing, or in connection with such

, evaluation (s) or report (s), and any information which was

!avaliable tc the, preparer (s) of such evaluation (s) or 1

-repor't(s) which was not used or reported in such evaluation (s)

, or,r'e port (s):

(viii) any' internal or external' investigation (s).. evaluation (s),

.or inquiry (ies) into Chan Van Vo's character. employment

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, qualifications, or job performance, including any informa-tionrequestedoEsought,any..questionsasked,andall.

inf6rmation received:.

I(ix) me' dical' or psychological reports, evaluation (s) and/or

. record (s)1concerning Chan Van Yo .

(x)'information concerning the dates or matters discussed in

. meetings between Chan Van Vo and any higher ranking CP&L

. employee, concerning any matters raised as concerns by Chan .Van. .

Yo.

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(b) Refer to any of ths it:ma or mattsra listsd in (a)(i)-(x) above '

1 (c) may have contained or referred to any of the matters inquir'ed about above but which has been (1) destroyed, (2) lost, (3) given

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away, (4) loaned to anyone, (5) mislaid, or (6) otherwise found unavailable ~for inspection any copying. For each such document please provide a summary of the contents of such document, the date when the document was destroyed, lost, loaned, given away, misiald, or otherwise became unav&ilable, and all reasons why and the name and address or any other person (s) who have or may_have said document or a copy of it, or information the docu-

. ment contains or contained.

.41-G-2(a) Please identify all documents used by, reviewed by, or in the possession of Alex Fuller, Ed Willett, E.E. Utley, M.A. McDuffie, A. Parks Cobb, Jr., or any other person who was employed by CP&L and supervised or met with or investigated Chan Van Vo, which concern '

L L- Chan Van Vo or any action or allegation by Van Vo, including notes.

recordings'or any other information, stating who possesses each item

[ of information (including information used by or reviewed by i any y person including _those named above, which is not now in that person's I possession. (b) Please make available all statements, notes, or other

[ information; produced by' or posessed by any of the persons inquired about above.-or any other persons, concerning meeting with Chan Van Vo, ,

_ discussion (s) or conversation (s) with Chan Van Vo, or investigation of, 9

disciplinary action against, or any other action against, Chan Van Vo.

u EEQUEST FOR PRODUCTION OF DOCUMENTS Wells Eddleman hereby requests that any documents identified l' in response to the above interrogatories be produced for inspection and copying. In' light of the short discovery deadline I request that

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any documents or parts of documents found to be available be made avail-

- able as soon~as possible,'regardless of the time it takes to locate or y produce the rest of.such documents or the time it takes to produce g other documents. (This.is not a waiver of production times, but

,a request for rapid production). Chan Van Vo's counsel advises me that Chan Van Vo' is aware of these . requests and has no objection to g

. my receiving or reviewing any do~cuments concerning the matters

' inquired about above.

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4 February 1985 Wells Eddleman .,i I