ML20004C602

Interrogatories & Requests for Document Production,Set 1 to Joint Intervenors on Contention 2 Re Radioactive Pollutants Released from Facility Into Mo River

ML20004C602
Person / Time
Site:	Callaway
Issue date:	05/26/1981
From:	Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO.
To:	COALITION FOR THE ENVIRONMENT, ST.LOUIS REGION
Shared Package
ML20004C598	List: ML20004C597 ML20004C602 ML20004C605
References
ISSUANCES-OL, NUDOCS 8106040316
Download: ML20004C602 (27)

Text

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L/ May 26, 1981 UNITED STATES OF AMERICA' NUCLEAR REGULATORY-COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL .

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(Callaway Plant, Unit 1) )

APPLICANT'S INTERRCGATORIES AND REQUESTS FOR DOCUMENT PRODUCTION (SET NO. 1) TO {

JOINT INTERVENORS ON THEIR CONTENTICN 2 l

Pursuant to 10 C.F.R. SS 2.740b, and 2.741, Applicant l

requests that the Joint Intervenors answer separately and fully in writing, and under oath or affirmation,.each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents

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I identified in the responses to interrogatories below.

Interrogatory responses are due no later than July 10, 1981.2 ,

i Special Prehearing Conference Order (April 21, 1981), at 17. i; I

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1 The Joint Intervenors consist of the Coalition for the  !

Environment (St. Louis Region), Missourians for Safe Energy, and the Crawdad. Alliance. Special Prehearing Conference  ;

l Order-(April 21, 1981) at 1-4. j 2- Objections to interrogatories or the production of l documents,-inspections, etc. under 10 C.F.R. S 2.741 must i

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Applicant requests-that the name and address of the person-or persons who provide information used in answering each interrogatory be identified,.and that the source of

.information be disclosed where an answer-is based in whole or in part on information other than the personal knowledge of the person or persons answering.

These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, should the Joint Intervenors, their  ;

. counsel, or any individual acting on behalf of the' Joint ,

Intervenors, obtain any new or differing information responsive, to these interrogatories.

Where identification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, transcript, report, hand written 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 person or persons having possession of the document. Also state the portion or portions of the document (whether sec-tion (s), chapter (s), or page(s)) upon which you rely, i

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Y be served within fourteen (14) or thirty (30) days, re-l { spectively. Special Prehearing Conference Order (April 21, 1981), at 18.

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GENERAL INTERROGATORIES

1. Please specify which, if-any, of the following documents'you rely upon in connection with your Contention 2:

(1) FSAR SNUPPS; (2) FSAR Callaway Site Addendum;.

(3) Callaway Environmental Report, Operating License Stage; (4) NCRP Report No. 47, Tritium Measurement Techniques; (5) NCEP' Report No. 62, Tritium in the Environment; (6) NCRP Report No. 63, Tritium and other Radionuclide Labeled Organic Compounds Incorporated in Genetic Material;  ;

(7)' Behavior of Tritium in the Environment, International Atomic Energy Agency, Vienna 1979; (8) _ Tritium Control Technology, WASH 1269, Mound Laboratory, Monsanto 1973; (9) Biological Implications of P-dionuclides Released from Nuclear Industries, International Atomic Energy Agency, 1979; (10) The Cell, John Peiffer, Time-Life Books, rev.

1969; -

(11) LER Output on PWR Events Involving Released i Activity Frcm 1969 to the Present, Nuclear Regulatory Commission, March 10, 1981; -

(12) Fuel Failure Detection in Operating Reactors, ,

NUREG 0401, March 1978;  ;

l i I (13) Fuel Performance, NUREG 0032, January 1976; F

I (14) Biochemical Behavior of Long Lived Radioactive I Waste, Ferruccio Gera, ORNL-TM-4481, ERDA, July 1975; (15) Assessment of 99Tc Releases to the Atmosphere - I A Plea for Applied Research, Till, Hoffman & Dunning, i DOE, June 1978 (ORNL-TM-6260);

-(16) : Proposed Rule Making Action: " Numerical Guides

... As Low As Practicable" ..., WASH-1258, Vols. 1 &

2, July 1973; (17) Radiological Surveillance Studies, EPA: (a)

Yankee Row RD 77-1 (1971); (b) Haddom Neck EPA-520/3-74-007 (1974); and-(c) Oyster Creek EPA-520/5-76-003 (1976).

(18) Nuclear Power Plant System and Equipment, Kenneth C. Lish, New York, Industrial Press 1972; (19) Guidebook to Nuclear Reactors, Anthony Nero, Jr., Berkeley, University of California Press 1979; (20). NCRP Report No. 22, Maximum Permissible Body Burdens; (21) NCRP Report No. 30, Safe Handling of Radioactive Materials; i (22) NCRP Report No. 60, Radiocerium; (23) NCRP Report No. 9, Basic Radiation Protection Criteria; -

(24) Comprehensive' Standards: The Power Generation Case, Thomas H. Pickford et al., prepared for Office of Research-and Development, EPA ~, TEKNEKRON/EEED-104; (25) Handbook of Chemistry and' Physics, Chemical Rubber Company Press (54th Ed. 1974).

2. For each of the documents specified in the previous interrogatory as a document upon which you rely,  !

identify:

P (a) The subsection or subsections of Contention 2 l l ,

which the document is relied upon to support;  !

L (b) The particular portion or portions (chapter (s), i i

section(s), page(s)) of the docament which are relied o:

upon for each of the subsections c5 :ontention 2 you identified in response to Interrogatory 2(a);

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(c). The purpose for which each portion of the document will be used.

(d) The witness'or witnesses whose testimony, in whole or'in part,-will rely upon the portions of-the

' document (s) you identified in response to Interrogatory 2(b).

3. Identify every other-document which'is not listed.in your response to Interrogatory-1 upon which you rely in asserting Contention 2.

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, 4. For each of the documents identified in your response to Interrogatory 3, identify:

(a) The subsection or subsections of Contention 2 ,

which the document is relied upon to support; (b) The particular portion or portions (chapter (s),

section(s), page(s)) of the document which arc relied  ;

upon for each of the subsections of Contention 2 you identified in response to Interrogatory 4(a);

r (c) The purpose for which each portion of the document will be used; (d) The witness or witnesses whose testimony, in

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whole or in part, will rely upon the portions of the-1 l I ii i

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. document identified in.your response.to Interrogatory.

.4(b).

. CONTENTION 2A A-1. . With respect to each-of the allegations. listed below, t

(a). state the factual basis for the allegation, including the applicable. plant' conditions (routine; type of accident), (b) identify all documents .pon

-which you rely to substantiate this factual basis, v (c) provide the name and present or last known address of each person known to you to have first hand knowledge of the factual basis for this allega-tion, and (d) state the name, address and quali- l fications of each person you intend to call as a i witness-to support the allegation.

1 (1) Applicant has not adequately assessed the amount '

of the radioactive pollutants to be released from i

! - Callaway Plant, Unit 1 into the Missouri River. L i  :

(2) Applicant cannot accurately predict the amount I l t L

of the radioactive pollutants to be released from '

Callaway Plant, Unit 1 into the Missouri River. '

(3) Applicant has not adequately assessed the amount

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of dilution to be afforded by the Missouri River. l I

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(4) Applicant cannot accurately predict the-amount of dilution to be afforded.by'the Missouri. River.

(5) ~ Applicant cannot accurately predict the potential bioconcentration of radionuclides in fish.

A-2.- 'Specify the radioactive pollutants that you contend l

. Applicant has not adequately assessed.

A-3. For each radioactive pollutant identified in the

' previous interrogatory, identify all documents,

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including the portion (s) of tha document, upon which ,

you rely to substantiate your allegation.

A-4. Specify the_ radioactive pollutants for which you-contend Applicant.cannot accurately predict the amount'which will be released frem the Callaway Plant, Unit 1 into the Missouri River.

A-5. For -;ach radioactive pollutant identified in the previous interrogatory, identify all documents, in luding the portion (s) of the document, upon which you rely to substantiate your allegation.

p- _ , - A-6. Describe how you believe an " adequate assessment" of  !

the amount of radioactive pollutants to be released

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from Callaway Plant, Unit 1 into.the Missouri River should be conducted.

A-7. Describe how one'would carry _out an " accurate-prediction" of the amount of radioactive pollutants to be-released from Callaway Plant,-Unit 1 into the Missouri River.

A-8. Describe how you believe an " adequate assessment" of the amount of dilution to be afforded by the Missouri River should be conducted.

t A-9. Describe how one would carry'out an " accurate prediction" of the amount of dilution to be afforded by the Missouri River.

A-10. Define "the Missouri River watershed."

r A-11. Specify the particular water diversion projects which you anticipate in the Missouri River watershed which would lower the amount of dilution water available.

A-12. Specify the factual basis, including any previous events which substantiate your allegation an.d any documentation in support thereof (including the applicable portion (s) of the documents), for the

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proposition that conditions of drought and freezing I

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(ice-jams) would lower the amount of-dilution water available in the Missouri River.

A-13. What likelihood do you assign _to your allegation that conditions'of' drought would. lower the amount of dilution water available to a degree sufficient-to raise the' concentrations of radioactive material-in the-Missouri River to levels higher than calculated ,

by Applicant?

A-14. State the factual basis, and any documentation in support there'f o (including the applicable portion (s) of the. documents), for your response to the' previous interrogatory.

A-15. What likelihood do you assign to your allegation that conditions of freezing (ice-jama) would lower the amount of dilution water available to a degree sufficient to raise the concentration of radioactive material in the Missouri River to levels higher than calculated by Applicant?

l A-16. State the factual basis, and-any documentation in support thereof (including the applicable portion (s) of the documents), for your response to the previous d

interrogatory. .

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. ..- J A-17.; Specifylthe particular. radionuclides for which you

contend Applicant cannot accurately predict the bio-concentration in fish.

. A-18. Do-you contest the' validity of the steady-state stream tube model utilized.by Applicant.to evaluate the transport 'sf radionuclides 11n the Missouri River

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A-19. Do'you' contest the applicability.of the steady-state stream tube model utilized by Applicant to evaluate the transport of radionuclides in the Missouri. River (FSAR Site Addendum, S 11.2.3.3)?

A-20. Do you contest the manner in which Applicant applied the steady-state stream tube model to evaluate the transport of radionuclides in the Missouri River (FSAR Site Addendum, 5 11.2.3.3)?

A-21. Do you take issue with the use of the certified computer program, DISPERN, for performing Applicant's routine surface-water effluent-analysis (FSAR Site Addendum, 5 11.2.3.3)?

A-22. Do you take issue with Applicant's selection of surface-water model parameters in its routine effluent analysis sJSAR Site Addendum, 5 11.2.3.3.1)?

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,v 4 Do'you contest the values provided'lyr Applicant for.

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A-23.

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b~ ' ' surface-water _model parameters in its' routine effluent analysis (FSAR Si.te Addendum, S.11.2.3.3.1)?

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- A- 2 4 .' . Do you take issue.with the-results of Applicant's; analysis-for radionuclide transport in the Missouri Ri er from the estimated Callaway Plant annual liquid effluent releases.(FSAR Site Addendum, S 11.2.3.3.2)?

A-25. -Do you disagree with Applicant's. decision to consider po' int radionuclide concentrations less than 0.377 x.

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-10 3 of zero value in Applicant's evaluation Ci/ft of point-radionuclide concentrations at various-cross-stream distances from the near shore-- (FSAR Site Addendum S 11.2.3.3.2)?

A-26. Do you take issue with App.'icant's use of the LADTAP computer code to formulate dose rate-estimates to 4

local biota (FSAR Site' Addendum, S 11.2.3.4.1)?

f A-27. Do you take issue with Applicant's use of Table A-8 f in Regulatory Guide 1.109 to determine bio-accumulation factors used to calculate dos.es to fish (FSAR Site Addendum, 5 11.2.3.4.1)? i I

A-28. Do you take issue with the results which Applicant reached on the basis of its use of Table A-8 of l

l. I Regulatory Guide 1.109 to determine bio-accumulation factors ~used to calculate doses to fish-(FSAR-Site Addendum, S 11.2.3.4.1)?

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-A-29. For each of the previous eleven interrogatories (Interrogatories A-18 through A-28).to which;you.have answered yes, or other.than in the negt. ee, (1) Provide the factual basis for your answer.

(2) Identify all documents upon which-you rely to substantiate your position.

(3) State the name, address and qualifications of each person you-intend to call as witness to support your position.

A-30. Identify any other technical analyses or methods,

' including computer programs, codes, models, Regulatory Guide criteria and tables, which you

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believe Applicant has improperly relied upon in its effluent analysis. >

i A-31. For each technical analysis identified in the

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I previous interrogatory, l e i

(1) Provide the factual basis for your answer.

I (2) Identify all documents upon which you rely to substantiate your position. ,

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'(3) State lthe name, address and qualifications of each person you intend to call as a witness to

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support.your position, CONTENTION 2B

.B-1. With respect to the allegation listed below, (a) state the' factual basis for the allegation, (b) identify all documents upon which you rely to .

-substantiate this factual basis, (c) provide ~the name and p' resent or last known address of each person known to you to have firs, hand knowledge of the factual basis for this allegation, and (d) state the i

name, address and qualifications of each person'you intend to call as a witness to support the allega-tion.

(1) Applicant completely ignores the potential impact of its radioactive releases on drinking water.

3-2. Do you disagree with Applicant's evaluation of water usage downstream from the Callaway Plant site, which provides that the closest municipal user of the Missouri River water downstream from the Callaway

Plant site is St. Louis City, with its water intake located some 78 miles downstream of the Callaway Plant site (FSAR Site Addendum, S 11.2.3.3.3)?

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'B-3. ~ Do~you disagree with the proposition that crop.

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?[; irrigation-ought not to be considered a potential i

pathway of liquid effluents to man in the vicinity of Callaway Plant Site (FSAR Site Addendum, 5 11.2.3.4.2)?

B-4. Do-you disagree with the proposition that no drin.<ing water is drawn from the Missouri River within 50 miles downstream of the Callaway plant discharge (FSAR Site Addendum, S 11.2.3.4.2)? -

B-5. Do you disagree with Applicant's use of values recommended'by the NRC for-use with the LADTAP program in lieu of site specific fish consumption data for purposes of assessing radionuclide uptake by fish (FSAR Site Addendum, S 11.2.3.4.2)?

B-6. Do you believe that there are pathways, other than fish ingestion, shoreline, and boating exposure pathways, which Applicant should consider in eval-uating population doses downstream of the Callaway Plant on the Missouri River (FSAR Site Addendum, S 11.2.3.4.3)?

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.B-7 Do you believe Applicant's liquid pathway dosage analysis should consider fish caught further than .05 miles downstream from the discharge pipe and shoreline recreation activities?

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B-8.. -For each of the previous 6 interrogatories (Interrogatories'B-2 through B-7) to which you have answered yes, or other than in the negative, 4

(1) Provide the factual basis' for your answer.

(2) ' Identify all documents upon which you rely to substantiate your position.

(3) State the name, address and qualifications of-each person you interd to call as a witness to support your position.-

, B-9. If your answer to Interrogatory B-7 was yes, specify how far downstream from'the discharge pipe and shoreline recreation activities fish should be analyzed by Applicant for radioactive uptake in i-Applicant's liquid dosage analysis, and provide the factual basis for your answer, including all docu-ments upon which you rely.

CONTENTION 2C j C-1. - With respect to each of the allegations listed below, (a) state the factual basis for the allegation, (b) i l identify all documents upon which you rely to i

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substantiate this factual basis, (c) provide the name l and present or last known address of each person j i

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known to you to have first hand knowledge of the factual basis for this allegation, and (d) state the name, address and qualifications of each person you intend to call as a witness to support the allega-tion.

(1) Adsorption of some radionuclides in sediment-could lead to high levels of contamination.

(2) Absorption of some' radionuclides in seditent could lead to high. levels of contamination.

(3) The potential resuspension of some radionuclides in sediment in the event of dredging could lead to high levels of contamination.

(4) The potential resuspension of some radionuclides in sediment in the event of flooding could lead to high levels of contamination.

C-2. With respect to each of the four allegations identified in Interrogatory C-1, identify the ,

specific radionuclides to which you refer.

C-3. Define "high levels of contamination" as it is used in contention 2C.

i C-4. Identify and explain the factual basis for the l probability you assign to the possibility of high  ;

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_o levels of radioactivity from resuspension of some radionuclides in sediment in the event of (a) dredging, or (b) flooding?

C-5. Do you consider-there'to be and, if so, specify a threshold level of probacility below which the potential for high levels of radioactivity from resuspension of some radionuclides from dredging or flooding need not be considered by the Applicant?

C-6. Do you' agree with the. proposition that there are no potential contaminant source areas upstream of the Callaway Plant Site (FSAR Site Addendum, 511.2.3.3.3)?

C-7. If the answer to Interrogatory C-5 or C-6 was no, (1) Provide the factual basis for your answer.

(2) Identify all documents upon which you rely to substantiate your position. i (3) State the name, address and qualifications of j each person you intend to call as a witness to i

support your position.

i j C-8. If your answer to Interrogatory C-6 was no, identify j the particular potential contaminant source areas l 1

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e. -e upsteam of the'Callaway Plant-Site.of which you are aware.

CONTENTION 2D D-1. - With' respect to each of the allegations listed below, (a)' state the factual basis for th'e allegation, (b) identify all documents upon which you rely to substantiate-this factual basis, (c) provide the name and present or last known address of each person known to you to have first hand knowledge of the e factual basis for this allegation, and (d) state the name, address and qualifications of each person you latend to call as a witness to support thefallega-tion.

(1) Applicant has not adequately assessed the amount of the radioactive pollutants to be released from Callaway Plant, Unit 1, into the at;nosphere.

(2) Applicant cannot accurstely predict the smount of the radioactive pc11utants to be released from Callaway Plant; Unit 1, into the atmosphere.

(3) Applicant has not adequately assessed the discharge rate of the radioactive pollutants to be .

released from Callaway Plant, Unit 1, into the f

atmosphere.

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L i y (4) Applicant cannot-accuratelyEpredict the discharge rate of:the radioactive pollutants to be released from Callaway Plant, Unit.1, into the a tmosphe r e .

l (5) Due tozmeteorological. considerations, Applicant.

-is unable to predict accurately the dispersion of

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radioactive materials.

(6) Due to meteorological considerations, Applicant is unable to predict accurately the fallout rate of radioactive materials.

D-2. Describe how you believe an " adequate assesament" of the amount of radioactive pollutants to be' released-f rom Callaway Plant,- Unit 1 into the atmosphere should be conducted.

D-3. Describe-how one would carry out an " accurate prediction" of the amount of radioactive pollutants to be released from Callaway Plant, Unit 1 into the a tmosphe r e.

D-4. Describe how you believe an " adequate assessment" of the discharge rate of radioactive pollutants to be released from Callaway Plant, Unit 1 into the atmosphere should be conducted.  ;

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D-5. Describe ~how one would carry out an " accurate predictien" of the discharge rate of radioactive pollutants to be released from callaway Plant, Unit 1 into the atmosphere.

-D-6. Specify the radioactive pollutants to which you refer in Contention 2D.

D-7. State with particularity the " meteorological condi-tions" to which you refer in Contention 2D.

D-8. Identify any and all documents -(including the applicable portion (s) of the document) upon which you rely in ide.itifying or analyzing the meteorological conditions in the vicinity of Callaway Plant, Unit 1.

D-9. Define " fallout rate".

D-10. Do you take issue with Applicant's use of the straight-line method set forth in Regulatory Guide 1.111 to calculate annual average dilution factors utilized in evaluating the releases of gaseous i

i effluents (FSAR Site Addendum S 11.3.3.4.1)?

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'D-11. Do you take issue with Applicant's use of the olimatological data summaries from National Weather i

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Service Stations in-Missouri.to identify regional

climatology (FSAR Site Addendum, S 2.3.1)?

D-12. Do.you disagree with Applicant's description of the climate in~the region ef.the Callaway plant site (FSAR Site Addendum, SS 2.3.1.1, 2.3.1.2)?

D-13. For each of the previous three interrogatories (Interrogatory D-10 through D-12) to which you answered yes, or other than in the negative, (1) Provide the factual basis for your answer.

(2) Identify all documents upon which you rely to substantiate your position.

1 (3) State the name, address and ' qualifications of -

each person you intend to call as a witness to support your position.

D-14. Identify any other technical analyses or methods, including computer programs, codes, models, Regulatory Guide criteria and tables, which you l believe Applicant has improperly relied upon in its l

analyses of gaseous effluents.

D-15. For each technical analysis identified in the previous interrogatory, ,

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(1) Provide.the' factual' basis-for your answer.

(2)- _ Identify all documents upon which you rely to substantiace your position.

(3) ' State the.name, address and qualifications of each person you intend to' call as a witness to support your position.

CONTENTION 2E E-1. With respect to each of the allegations listed below, (a) state the factual basis for the allegation, (b) identify all documents upon which you rely'to substantiate this factual basis, (c) provide the name and present or last known address of each person known to you to have first hand knowledge of the factual basis for this allegation, and (d) state the name, address and qualifications of each person you intend to call as a witness to support the allega-tion.

'l) There will be inadequate monitoring of the release of tritium when in quantities below the level of detection of commercial monitoring equipment.

(2) There will be inadequate monitoring of the release of tritium during accidental releases.

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(3) There will'be inadequate monitoring of the e release of noble gases when in quantities below the level.9f detection of commercial monitoring equip-ment. .

-(4) -There will be' inadequate monitoring of the-release of noble gases during accidental releases.

(5) There will be inadequate monitoring of the release of alpha, beta and gamma emitters when in quantities below the level of detection of commercial

-monitoring equipment.

t (6) There will be inadequate monitoring of the release of alpha, beta and gamma emitters during accidental releases.

E-2.- Describe how you believe an adequate monitoring program for the release of radioactive emissions should be conducted.

E-3. Identify the particular noble gases to which you  ;

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refer in your Contention 2E.

1 I. E-4. Define " accidental releases," as the term is used in '

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! Contention 2E.  ;

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~E-5. :Specify'the commercial monitoring equipment to which l

you refer in Contention 2E.

E-6. Define the " level:of detection" for each piece of equipment identified iniyour. response to Interrogatory E-5. -

- E-7. - State the level of detection of' commercial monitoring equipment with which you would be satisfied,'and provide the factual basis for your response and any

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' documentation in support thereef.

CONTENTION 2G G-1. With. respect to each of the. allegations listed below, (a) state the factual basis for the allegation, (b) identify all documents upon which you rely to substantiate this factual basis, (c) provide the name and present or last known address of each person known to you to have first hand knowledge of the factual basis for this allegation, and (d) state the name, address and qualifications of each person you intend to call as a witness to support the allega-tion.

(1) Applicant's estimates of annual emissions do not take into-account releases frt. the spent fuel pool.

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-( 2) : As_a plant'gets: older, it~gets leakiet.

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-(3) Applicant's. estimates;of annual emissions do~not takerinto account increased releases-~as thefplant.

gets older anc. leakier (e.g., from steam; generator;

-0 tube deterioration).

(4)

' Applicant's est'imates of annual. emissions do.not-take into account releases from decontamination-precedures.

G-2. Specify the releases from the spent fuel-pool which

.you contend Applicant has not considered in its estimates.of annual emissions.

Do you_ consider it necessary_for. Applicant's-

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G-3, estimates of annual emissions'to take into account releases from the spent fuel pool?

G-4. Specify all'of*the sources of increased releases which you believe will occur as the plant gets older, and state the factual basis, including all documents upon which you rely, to substantiate your answer.

i G-5. Do you crnsider it necessary for Applicant's estimates of annual emissions to take into account the increased releases which you identified in your response to Interrogatory G-2?

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G-6. SpecifyLthe decontamination procedures to which you-refer in Contention 2G; I

G-7.- Do you consider it necessary for Applicant's estimates of annual emissions to take into account ,

i releases from decontamination procedures?  !

G-8. :If..the answer to Interrogatory G-3, G-5'or G-7 was ,

yes, for each such answer,-

(1) ~ Provida the factual basis for your answer.

(2) Identify all documents upon which you rely to substantiate your position.

(3) State the name, address and qualifications of each person you intend to call as a witness to support your position.

CONTENTION 2I I-1. Do-you intend to identify new data on the health effects of low level radiation prior to the next prehearing conference?

I-2. If the answer to Interrogatory I-l is yes, or other than in the negative, do you intend to request that the Board amend Contention 2 to take account of such data?

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I-3. .If the answer to both Interrogatory I-1 and:I-2 is-Lyes, or other'than in the negative,

-(l)-_ Identify the new data on.the health effects of lowolevel radiation to-which you refer in your-Contention 2I.

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~ (2).--Specify.the new data on-the' health' effects of

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tritium to which you refer-.in Contention =2I..

(3) .Specify the documents (including-thefspecifi'c portions'thereof) upon which you relied in evaluating Applicant's estimates'of radiation' dose.

(4) Provide the name and present or last known i'

address.of each person known to you to have first i

hand knowledge of the factual basis of Contention 2I.

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'(5) Provide the name,. address and qualifications of each person you intend to call as a witness to support Contention 2I.

Respectfully submitted,  ;

SHAW, PITTMAN, POTTS & TROWBRIDGE i r

, >w.,

Thomas A. Baxter Deborah B. Bauser .

!. Counsel for Applicant i

1800 M Street, N.W.  !

Washington, D.C. 20036 '

(202) 822-1000 ,

Dated: May.26, 1981  ;

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