ML20106F540

Response to W Eddleman 841008 General Interrogatories, Interrogatories & Request for Production of Documents. Supporting Documentation & Certificate of Svc Encl.Related Correspondence

ML20106F540
Person / Time
Site:	Harris
Issue date:	10/22/1984
From:	Hawkins T Federal Emergency Management Agency
To:	EDDLEMAN, W.
Shared Package
ML20106F537	List: ML20106F540
References
OL, NUDOCS 8410300295
Download: ML20106F540 (15)

Text

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HELATED CORRESFUNDENCQ

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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g4 DCT 26 P3:40 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER AND LIGHT COVPANY AND )

NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 JL POWER AGEhCY ) 50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

FEMA STAFF RESPONSE TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES, INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS DATED OCTOBER 8, 1984 GENERAL INTERR0GATORY A Please provide answers to any general interrogatory in the 9/5/84 set for which the answer has now changed.

ANSWER No changes.

GENERAL INTERROGATORY 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 happens? Are you willing to work out arrangements for such observations? 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?

ANSWER No. Yes, however, the State government has authority in this '

matter.

8410300295 841025 PDR ADOCK 05000400 G PDR

. Request for Production of Documents Wells Eddleman hereby requests that the original or best copy or a fully legible copy of any documents identified in response to interroga-tories herein, be made available to him for inspection and copying at a mutually agreeable time and place, or that such document be placed in the NRC's Public Document Room and its location / identifier or identifying information be made available to him.

REQUEST 240-4(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 docu-ments, what is the basis (if any) for each answer to each part of your previcus response to all parts / subparts of 240-1 and 240-2? Please give the basis separately for each part and subpart of each of 240-1 and 240-2. (c) 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 240-3?

RESPONSE

240-4(a) FEMA Staff did not state that it could not identify any documents in response to interrogatory 240-3. FEMA Staff responded to all documents concerning responsible agencies where " unknown." One docu-ment which states essentially, the FEMA response to Interrogatory 240-1(a) is the " North Carolina Emergency Response Plant,"

Part 2, Page 35.

(b) See above.

(c) " North Carolina Emergency Response Plan," Part 2, Page 35.

(d) See above.

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REQUESI 213-A-4: Please provide actual answers to the parts of interrogatories 213-A-1, 213-A-2, and for 213-A-3 as previously served.

RESPONSE

Actual answers have been given.

REQUEST 213-A-5(a) Please state exactly what is the nature of the review of item P-7 of NUREG-0654 which was performed by (1) the RAC (ii) FEMA Staff, was, and when it was done and by whom. (b) Please describe exactly what it is in the ERP that meets criterion II.P.7 (c) How do you interpret the term "in the plant"-- to be cited, to be included, or some other interpretation (please specity).

RESPONSE

215-A-5(a): (i) and (ii) The nature of the review by RAC and FEMA of Item F-7 consisted of finding and reading the listing of SOP's in each section of the plan within an " attachment." Since the titles of the SOP's are not indicative of which sections of the plan the S0P's pertained to, FEMA Staff has asked the State Division of Emergency Manage-ment to obtain and submit all available 50P's to the FEMA regional office.

The review was done by the members of the (names attached) RAC and by FEMA Staff on May 15-16, 1984.

(b) The ERP contains a listing of SOP's in each section under an " Attachment" (or Appendix). In the view of the RAC and FEMA Staff, at the time of the review, these listings constituted compliance with Criterion II.P.7. of NUREG-0654. We (FEMA) have now requested copies of the 50P's.

i (c) FEMA Staff interprets the term in the plan to mean "to be cited." -

(d) FEMA Staff interprets the term " included in the plan" to -

mean "to be cited."

-REQUEST 213-A-6(a) Has any copy 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 intervenor?

(b) has any copy of the RAC or FEMA staff evaluations been made avail-able to anyone in any of the listed groups in subparts (i) ... (vi) to (a) above? If so, to whom, 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 ,

review 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 copy of the transcript of the Harris OL case (NRC Docket 50-400) prehearing conference of May 1984 in which FEMA counsel Perry partici-pated or appeared?

RESPONSE

213-A-6(a) (i) One copy of the RAC evaluation has been forwarded to NRC. (ii) Yes. (iii) No. (iv)No. (v) No. (vi) No.

(b) Yes - to NRC Staff member Robert Trojanowski who is also a member of the RAC. He received his copy in May 1984 and to NRC legal staff for their review.

(c) No firsthand knowledge.

(d) Unknown.

(e) No.

I REQUEST 57-c-7(4)(a) Is there an arrangement or typographical error on page 12 ,

of your responses to previously Eddleman/J.I. interrogatories concerning

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contention 57-C-7? (b) if so, what is the correct answer or answers to .

57-c-7-2 and -3?? l I

RESPONSE

57-c-7(4)(a) The paragraph at the top of page 10 was inadvertently inserted at the top of page 12. Simply delete this paragraph from page 12.

(b) The correct answer,s to 57-C-7-2 are given on page 11.

A modified answer to 57-C-3(a) is as follows:

(a) (i) No FEMA guidance requires the ability to treat severe radiation exposure per se. NUREG-0654, L.1. , requires that each organi-zation shall arrange for hospital and medical services capable of evalua-ting radiation exposure and uptake, including persons prepared to handle contaminated individuals.

NUREG-0654, L.3., requires that each state develop lists indi-cating the location of hospitals capable of providing medical support for any contaminated injured individual.

REQUEST 57-C-7-5(a) Please provide a more complete answer to 57-C-7-2, giving answers to each of-its parts. (b) Does FEMA have any plans for listing, evaluating, or otherwise inquiring into the capability of hospitals around the Harris plant, to treat severe radiation injury per se?

(c) If so, please detail all such plans re items inquired aT6uTin (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.

RESPONSE

57-c-7-5(a) FEMA Staff is not aware of the identify of any FEMA documents concerning the questions of whether the ability to treat severe radiation exposure per se eis required by FEMA guidance or NRC regulation or rule or any applicable law or requirement. The answer

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previously given by FEMA Staff is accurate and complete. NUREG-0654 is the only guidance we have in this area and it does not address the subject of " severe radiation exposure treatment." -

(b) We are aware of no such requirements.

57-C-7-6(a) Please provide a more' complete answer to 57-C-7-2, giving answers to each of its parts. (b) Does FEMA Have any plans for listing, evaluating, or otherwise inquiring into the capability of hospitals around the Harris plant to treat severe radiation injury per se? (c)If so, please detail all such plans re items inquired about in (bT 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.

RESPONSE

57-C-7-6(a) Refering to 57-C-7-2:

(a) i Unknown ii Unknown (b) Unknown; we don't know; no, we haven't inspected.

i Unknown 11 Unknown, we don't know; (d) i We didn't say this.

(e) NUREG-0654 and the North Carolina ERP. ,

(b) tio (c) Not applicable (d) Not applicable

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REQUEST 57-C-7-7(a) Please identify all sources of information you rely on or

u:e in making your answers to the above and all previous interrogatories on 57-C-7. -

RESPONSE ,

57-C-7-7(a) No outside sources or consultants were used or relied on, only NUREG-0654, the c~ontentions and interrogatories themselves and the North Carolina ERP.

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ATTACHMENT RAC Members and. FEMA Staff who reviewed the Harris Plan on .

May 15-16, 1984.

RAC: H. Richard Payne,. EPA; Bradley D. Eichorst, FDA; Robert E.

Trojanowski, NRC; George E. Bickerton, USDA; Alvin W. Hall, DOT; David Lassiter, DOE.

FEMA Staff: Ray Boyette, Tony Foltman, John Heard, Thomas Hawkins, Doug Hoell, Shana Aucsmith, Cheryll Stovall, Jack Glover.

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Nuclear Regulatory Commlaeion (NRC)

, in todiological emergency reponu ,

, planrnns matters, so that their mutual

- efforts will be directed toward more eflective plans and related preparedness meesures at and in the vicinity of

• nuclear reactors, fuel cycle facihties m hich are subject to 10 CF1 Part 30

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• Appendix E. and certain other fuel cycle '

and materiefs hcenaces which Lave Potential for significant accidental off-site red.ologicalteleasee.no memorandum is responsive to the President's decision of December 7, 1979, that FEMA will take the lead in off site planning and response hia request that NRC assist FEMA in carrying out this role and the NRC's continuma otetutory raponsibility for the radiological health and safety of the pubhc.

Separate memorende wi!! be negotiated covering NRC/ FEMA cooperation and respone'bibties in response to an actual emergency and Public Information activities in addition. en agreement has already been 45 m 5s47 reached between the NRC and FEMA cn NbhsNd U24/00 September 11.1979. that chairmanship of the FederalInterogency Central Coordmating Committee should be Memoesndum of Understandm9 trcnsferred from NRC to n.MA.nie Between NRC and FEM A To agreement woe transmitted to other Accomplish a Prompt improvement in Federal agencies bv e loint letter from Ra$ological Emergency Planning and the Chairman of NitC and the Directot

P8'enness of FEMA. The NRC and FEMA also I he Ntclear Regulatory Commission agreed in principle on September 11,

!\RCs and the Federal Emergency 1979, to the idea of joint participation in Alcagement Agency [ LEMA) hase the review, assessment and concurrence e.tered inn a memorandum of writh regard to State and local emergency response plans. net undr tsund.ca which dehneates each apan6s lead responsibihties m _greement will be implemented by e

udalorca! emergency preparedness FT.MA coordinating s!! Federet planning Th's menorandum responds to e and by FEMA's taking the lead for directae from the President dated developing a program for aseeeems State and local emergency rnponse December 7.1979 which defined areas of responsibihty for emergency plane in all elements of off-site pieparedness for the two agencies radiological emergency plannin6 and Copies of the memorandum are for mahaos Andmge and deteremanone asatlable for pubhc inspection at the as to the adequacy and capabihty of NRC Pi.bhc Document Room.1717 H implementing State end local plans, and Street. N.W Washington. D C. Copies to make those findings and of the memorande may be obtained by determinations available to NRC.He NRC shall review those FEMA findings wntmg to Joseph M.:n. Director. and determinations for the purpose of Daision of Rules and Records. Office of Administration.U.S Nuclear Regulatory making determinations on the overall Commission. Washinginn D C. 20555. state of emergency preparednese for Telephone 3T-492-1211 Included with lesuance of bcenses or shutdowns of the memorandum, but not pubhehed Operating reactors.The NRC proposal to herewith, are two attachments. lA) require concurrence in State and local FEMA /NRC Steering Committee and (B) emergency respmsa plena fe ducnbod Duties of NRC Personnel Detailed to in the proposed emergency pfeoning rule FEMA through June.1960. (44 FR 75167. December 19. as% The The text of the memorandum of arrangement wi!! malie the FEMA staff understandmg to set forth below. responsible for evolustirig the adquacy Background and Purpou that th one e poble of hs memorandum of understandmg implementation on a continuing bule.

establ.shes a framework of cooperation and witl therefore substantially avoid between the Federe1 Emergency duphcotive efforts by NRC staff.

Mensaement Aaency (FT.MA) and the ,

MEMORANDA 0F UNDERSTANDING

' Emergency Response Planning Fixed plans as they are completed.

11 Authonties and Responsibilities Facil;tres and Transportation" (40 FR FTMA routm, e suppor* willinclude FE.NExecut:ve Order 12148 mo4). the Federal Preparedness provid.ng essenments of State sad local chs 8es the Director

• MM with Agency a predecessor of FEMA ~ plans nlated to reactor Construction e tab! hms pobey for and c'oordmatmg Permit and Operating Ucense reviews outimed res)ons!bihties of varioue and continuing anessments of 5 tete and

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Federal agencies in providing assistance ,

ass ne e ans fo xcuve to Seate and local gosernments in their IOC*I plans during the facility lifetime. -

agencies (Section 2-101) It also h support its findings and assessments.

' presides that "The Director sha!g raMcgical emergency response .

t nepon b hties are aI b re t e sion the e a go e m n s and nv e undergoir g rect alushon and that this NRC Advisory Committee on Reactor sector to shmulate vigorous Safeguards. NRC hearing boards and partiupation in civil emergency memorandum of understanding will require reissuance of that Federal administroth e law judges. any court preparedness mitigation. response. and actions. and dunns any related Repster Notice recos e-) probems "(Section 2-104) In Specincally. discovery proceedir,gs. Nothing in this On Decem r 7.10"S. the President. for emergency,the NRC response to the recommendettons of the upandans areresponsibilities f,0C 1.To assus acesu emersecy p!ans d i h C nspm b 1 y for Kerr en) Commission on the accident at for adequacy. protn.tmg the radiological health and Three Mde Island. directed that FEMA safety of the pubhc.

assume lead responsibihty for all off site 2. To verify that licensee emergency nuclear emergency plannir 3 and [Jans are adequately implemented (e.g 8 FEMA Review of State and Local response. adequacy and ma;ntenance of p/ars Specifically the IT.MA {rocedurn. training. resources, staffmg NRC will assist in the development responsibihties with respect to vels and qualifications and equipment and 'eview of State and local plans n preparedness as they relate ec adeq]g through its membenhip on the Regional 3 ew the MM findigs and ^ '

1 To take the lead in off. site determinations on the adequacy and ,he esNn 1[ ry Con i s emergency planning and review and capabihty ofimplementation o. State asses: Stste and local emergency plans and local plans- C Evoluchon ofEmercises for adequacy. 4 To make decisions with regard to FEMA and NRC will cooperate in 2 To complete by June 1980. the the oserat: state of eciersency deternuning exercise requiremente for review of State and local emergency preparedness (i e, mtegration of pmt bcensee. State. local and Federal pla is in those States affected by emergency preparedness on site es esercises and will iointly observe and operating reactors. dete mined by the NRC and off-site se evaluate such exercises. NTsC and 3 To ec nplete, as soon as possible. determmed by FEMA and reviewed by FEMA will also jomtly agree upon the the review of State and local energency NRC) and issuance of operstmg hcanses set of exercise scenanos from which the I plans in those Statu affected by plants or shut down of operatmg reactors- scer.ario for a particular exercise will be scheduled for operation in the near m. Ares,e of Cooperation selected.

Future A NfiCLicensirgRenews D Emergency Preparedness Guidance 4 To make f;ndmss and deternunations as to whether State and FEMA will provide support for NRC NRC has lead responsibihty for the local emergency p!sns are adequate and reactor, fuel facihty and material deselopment of emergency capable of unp;ementation(e 3 hcensing nviews. as requested. with preparedness guidance for heensees adequacy and memtenance of regard to the onessment of the FEMA has lead responsibiht) for the proced res,treming nsources. etaffing adequec) of State and local res;>enae duelopment of emergency Inels and quahf cations and equipment plans for accidental radiological preparedness guidance for State and adequacy) releases This will anclude timely local agencies

5. To assume responsibihty for submittal of a letter evaluation suitable NRC and FTMA recognize the need emergency preparedness trammg of for inclusion in NRC safety es aluation for en integrated assessment of the State end local off;cials. reports. degree of emergency preparedness by 3 To de celop and inae en updated IMA wulprovide NRC with an NRC licensees and State and local senes ofinteragene) ass:gnments which independent essessment of evacuation gesernments NRC and FEMA will each, would defineate respective egency therefore, provide opportunit) for the capabihties and ruponsibilmes and times around 12 reactor altes which other agene) to renew and comment on defme procedarn for coordmation and hu e the highest population density emergency preparedness guid.nce pnor withm the to mde emergency plannns d.rection for ec ergenc) planning and none or are mutualls agreed upon by to adoption as formal agency guidance.

e en agru E Mq owe on&@cials C Ihe AtomicEnergy Act of t954 1 discus future arrangements for as amended. regmres that the NRC grant IT.MA will assume lead responsibihty Pe ed by for emergency preparedness tramma of beenses only if the health and safety cf ',*"#, thet i sw op . g State and local otheials. NRC will the pubhc is adequately protected. reacters and at poirva currently under Whde the Atomic Energy Act does not coopuste in suunna exisung NRC construction sponsored training programs are specificaff) require emergency plans Substantially prior to the tirne that a and related properedness measures the Irnpacted to the mirumum extent durms FT.MA paluation is required with the period lanuary to lune.1980. NRC NRC has regared consideradon of fegard to fuel facility and matenal ourall emergenc) preparedness sa a hcense review NRC will supply FEMA 4 Worm an w m mg o hta part of the bcensir;g process. intenhon to pass responsibiLty to FEMA with a heting of all fuel and material to CFR 50 34 and Appenda E to 10 bcensees identify those with potent;st I '"8C""'I*i"8 P' 3* I"'SI'!'

and local othesals durmg FY 1980 and CFR Part 50 include requirements for the for spificant accidental off site hcensee emergency plan r in a Federal wd! support FEMA in requnung N radio.ogical releases and for those NRC to transfer the traming budget to TEMA Reg: ster Notice dated December 24. will submo to IT.MA the emergency 1975 entitled"Radaologicalincident in ) ears after FY 1980.

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MEMORANDA OF UNDERSTANDING have lead responsibility for licensee Approved for the US Federal Emergency F O psy NSCProg cms _

IL!aragement Agency.

preparedness and the FIMA members Ongoirg NRC prog ams that are will hase lead respons.bihty for State Frank Camm.

re!.ted to State end local emergency endloca! preparedness ne Steering Assocsore amcrerkrMane and pianmng and preparedness that are Conunittee will osersee the evaluation PNPoNd8888-

supported t y FY 80 funds. will continue team resiew activities and develop Dated Ianuary11.teelt wjthout mterruption unless upgraded acceptance critena for Attachments mod f. cations are recommended to the 1. FEMA /NItC Steering Committee licensee. State and local emertrency _

NRC by the FEMA /NRC Steering 2 Dutwo of NRC Pe sonnelDetaded to preparedness. NRC and FIMA will then NA thre isMune in Committee. (See IV 4 below). consider and adopt criteria as p U.S C. sawa))

C A.h leOrmet/on Prog oms apptopriate,in their respective da FEM A will take the lead in developing junsdictions (See Attachment Ib D* '

,, , *[p(gy tys,1 pu%c m'ormation programs NRC will 5. To permit the orderly transfer from Commission cssist FEMA by reuewmg for accuracy NRC to IIMA of the lead responsibihty Ime V. Geesad, sda ational mate *ials concerning for evaluating State and local plans and EWdeA@m preparedness.the NRC staff who had r:d.ation and its haurds for information regard.ng a;propriate actions to be been performing this function will be 4: ken b) the general pubbe m the esent assigned through June 1980 to work cf an accident insolvmg radioactive directly with FEMA Those incidental maten41s. A separate memorandum of activities, such as respondmg to understandmg will be negota.ted for conespondence thai would normally be Pubhc Information activities handled b) the NRC's State Programa

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IV. Near. Term Cooperatis e Measures continue to be handled by these in order to achiese a prompt per sonnel while assigned to FEMA. (See trnpresement m the state of emergency Attachment 2).

preparedness at and around nuclear 6 NRC will ensure contmustion of pewer facahties. and because of the NRC computer and automatic data need for an integrated assessment of tne processing support (includmg TERA d: gree of preparedness.IIMA and NRC record keeping system support) to the esecgn:re the need fur especially clcse NRC staff personnel detailed to FIMA.

working relationship oser the nest sts 7. NRC Program Support funda months To this end. FIMA and NRC specifically dentified m the FY 80 (gree to the following mode of operation budget (includmg supplemental). for the through lune of 1980- emergency preparedness function cf 1 NRC staff willproceed with the NRC's Office of State Programs, and ss aluation team review of emergency NRC FY 80 tras el funds ist the amount of preparedness at each pcwer reactor and 325.000 will be memteined as is. and will rubl.sh Safety Evaluations on each contmue to be managed by the NRC 2 FEMA will provide members to N . detailed to FEMA to ensure that onSomg programs affectmg State and part.upate with NRC steft on the local gos unment emusency ssah.ation teams The FEMA team preparedness are not mterrupted.

members will participate in the prrparat,ori of assessments of the off. V.Worklag Arrangensents site p!ans along with NRC. Team A. De normal point of contract for mernbers will perform according to the implementation of the points in this procedures desenbed in NRC Steems agreement will be the NRC/ FEMA Committee Memorandum dated Steering Committee.

Nos ember 23.1979. subject. Guidance D. The Steenns Corur.ittee will cn Team Reuewt estabhsh the day to day procedurce for

3. FIMA will provide an intenm carrying out the arrangements of this esaluation of the adequacy of State and memorandum.

local preparedness associated with each VI. Tens of Agresament power reactor suitable for attachment to the NRC Safety Esaluation. TIMA will A.His agreement shall be effective report to NRC on the schedules of State as of [anuary 14.1980 and shall contmue cnd local gos ernments to upgrade their in effect through September,1900, unless terminated by either party upon 120 plans and wi!! prepare a f.nal evaluation when the upgraded plans are completed. days

• notice in writmg.

4. The NRC interoffice Steering 8 Amendments or modiScations to this Agrument may be made upon Committer on Emergency Preparedness wntien agreement by both parties to the will be expanded to an NRC/FIMA Steering Committee consisting of equal ^8'""'"'-

Eumber of members to represent each Approved for the US Nuclear Regulatory Commmon.

agency with one vote per agenc) . Where the Steerms Committee cannot agree on L*e V. Gossia.

Execurwe Dncrorfor Opemreons.

the resolutien of an issue. the issue will Dated lanuary it.tes(L be referred to NRC and FIMA management.The NRC members will

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AFFIDAVIT The below subscribed person hereby affirms, subject to penalty of perjury, that he has answered the Interrogatories of Intervenor Wells Eddleman as identified below. The answers are true and correct to the best-of his knowledge and belief as is also the attached statement of professional qualifications.

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" Thomas I. Hawkins 10/22/84 Dated at-Atlanta,-Georgia this 22nd day.of October, 1984

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A Thomas I. Hawkins Professional Qualificaticns My present position is Emergency Management Program Specialist for .

the Federal Emergency Management Agency.- 'I am assigned to the Radiological Emergency Planning liaison position between FEMA Region IV and the States of North and South Carolina. In this position, I am responsible for the review of radiological emergency plans and preparedness for the State of North Carolina and the State of South Carolina and for the local governments within these States.

I have held the position of Emergency Management. Program Specialist (or its equivalent) since December 1981. I have been employed by FEMA since July 1978.

From April 1964 to January 1977 I was employed as Planning Director:

of Clayton County, Georgia.

My formal education is as follows:

AB Degree, Emory University, Atlanta, GA, 1958 Master of City Planning Degree, Georgia Tech., Atlanta, GA, 1963 Completed Radiological Emergency Response Course at the U.S.

Department of Energy's Nevada Test Site, April 1982 Completed Radiological Defense Officer and Radiological Defense Instructor Course, Georgia Emergency Management Agency, Atlantti, GA, March 1982 Completed Basic Management Seminar for Emergency Management Personnel, Valdosta State College, Thomasville, GA, Winter Quarter, 1980 Completed Radiological Emergency Planning Seminar, National Emergency Training Center, Emmitsburg, Maryland, Ocrober 1982

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d UNITED STATES OF AMERICA

- NUCLEAR REGULATORY COPNISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CAROLINA POWER AND LIGHT COMPANY AND, ) Docket Nos. 50-400-OL

) 50-401-OL NORTH CAROLINA EASTERN MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF AND FEMA RESPONSE TO WELLS ED GENERAL INTERR0GATORIES, INTERROGATORIES AND REQUEST FOR PRODUCT DATED OCTOBER 8, 1984" in the above-captioned proceeding have been served on t following by deposit in the United States mail, first class, system, this 25th day of October, 1984:

James L. Kelley, Chairman

• Richard D. Wilson, M.D.

Administrative Judge 729 Hunter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Comission Washington, DC 20555 Travis Payne, Esq.

723 W. Johnson Street Mr. Glenn O. Bright

• P. O. Box 12643 Administrative Judge Raleigh, NC 27605 Atomic Safety and Licensin;: Board

- U.S. Nuclear Regulatory Comission Dr. Linda Little Governor's Waste Management Building Washington, DC 20555 513 Albermarle Building Dr. James H. Carpenter

• 325 North Salisbury Street Administrative Judge Raleigh, NC 27611 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Dr. Harry Foreman, Alternate

• Washington, DC 20555 Administrative Judge P.O. Box 395 Mayo Daniel F. Read University of Minnesota Minneapolis, MN 55455 CHANGE P. O. Box 2151 Raleigh, NC 27602

2-

- Robert P. Gruber John Runkle, Executive Coordinator Executive Director Conservation Counsel of North Public Staff.- NCUC -

. Carolina ~

P.O. Box 991 ~

307 Granville Rd. Raleigh, NC 27602 Chapel Hill, NC 27514 George Trowbridge, Esq.

Bradley W. Jones, Esq. Thomas A. Baxter, Esq.

Regional Counsel John H. O'Neill, Jr., Esq.

USNRC, Region II -

Shaw, Pittman, Potts & Trowbridge 101 Marietta St., N.W. 1800 M Street, N.W.

Suite 2900 Washington, DC 20036 Atlanta, GA 30323 Atomic Safety and Licensing Board Wells Eddleman Panel

• 718-A Iredell Street U.S. Nuclear Regulatory Commission 1

Durham, NC 27701 Washington, DC 20555 Richard E. Jones, Esq. Steven Rochlis Associate General Counsel Regional Counsel Carolina Power & Light Company FEMA 1371 Peachtree Street, N.E.

P. O. Box 1551 Atlanta, GA 30309 Raleigh, NC 27602 Spence W. Perry, Esq.

Atomic Safety and Licensing Appeal Associate General Counsel Board Panel

• Office of General Counsel U.S. Nuclear Regulatory Commission FEMA 500 C Street, S.W., Room 840 Washington, DC 20555 Washington, DC 20472 Docketing and Service Section*

Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 n . . .- . dc,__

Elaine I. Chan Counsel for NRC Staff

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