ML20024E850

Interrogatories Redirected to NRC Per ASLB 830824 Order. Certificate of Svc Encl

ML20024E850
Person / Time
Site:	Harris
Issue date:	08/31/1983
From:	Eddleman W EDDLEMAN, W.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20024E830	List: ML20024E829 ML20024E832 ML20024E834 ML20024E840 ML20024E846 ML20024E850 ML20024E853 ML20024E856 ML20024E858 ML20024E862
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8309070135
Download: ML20024E850 (2)

Text

-

Oct.MFJE0 "SN?.;

UNITED STATES OF AMERICA NUCIKAB EEOULATOBY COMMI.3SION83 MEB8MV 1983 0FFICE OF SECRt.iAc -

00CKETING & SERVlf1 BEFORE THE ATOMIC SAFETY AND LICENSING BOEBBCH Glenn O. Bright Dr. James H. Carper.ter James L. Kelley, Chairman l

In the Matter of Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, Units 1 and 2) ASLBP No. 82-MB-01 et

)

Wells Eddleman's Intevrogatories re-Directed to NRC Staff, per Board 8-24-83 Order At page 14 of the Board's 8-Ph-83 Order they allow me to re-direct interrogatories 37B-3(a),(e) and (k) (or h-22 83) to the Staff. I request that the Staff answer each of them You already and produce documents identified in resnonse to then.

i have been served with a copy of these interrogatories; I will supply another and extend resconse tine appropriately if you need one.

At page 13 of the sane Order, the Board allows ne to submit more sharp'ly focused versions of interrogatories 373-1(c) and (d) to the Staff. Here is a refocusing:

Please identify all material and documents in possession of NRC Staff which indicates or says that NRC models of radiation esposure underestinate dose to humans due to (1) considering less reactive chemical forms of radionuclides (ii) reliance in any way on the experiments described in the 11/11/79 Washington Post article (page B1 and jump to Bk) describing (a) stevilization of soils (b) use of soils known to take up lower amounts of radioactive l

material fron the air (c) transplanting fully grown riants into soils instead of growing then there fron seed (d) sacvificing the plants after only 3 days in place (e) ignoring nicrobial and bacterial concentration of radioactive manterial, whether via use of sterilized soils in exneriments or otherwise; (iii) considering radiation exnosure 8309070135 B30831 PDR ADOCK 05000400 0 PDR

from (a) internal emitters (b) external enitters, to be less likely to cause cancer than an authority thinks is likely (e.g. NFC trans.

520, John W. Gofnan, Karl Z. Morgan, I.D.J. Bross, Rosalie Berte11, as exannles of such authorities); (iv) underestinate deposition of radioactive naterials on (a) human food crops (b) crons or plants used to feed animals which hunans either eat or consune products, e.g. milk and nilk products, fron; (v) underestinate incidence of genetic (a) damage (b) diseases caused by exnosure to ionizing radiation from fission products or fron nuclear power plant enissicrs including a ctivation nroducts and transuranics; (vi) undewestinate incidence of diseases other than cancer and genetically caused diseases, which other diseases are (a) caused (b) contributed to, by erresure to ionizing radiation fren nuclear power ulant emissions.

Please identify all docunents containing such information.

If you believe the above would be unduly burdensone to compile, please negotiate -- I an interested in the significant infornation you possess. Please produce all such docunents identified in resuonse to the above for insnection and eq{ying.

6-31-83 Wells Eddlenan CERTIFICATE OF SE"VICE I hereby certify that a cony of the above was se=ved, US na*1 1st c1 with my other 8-31-83 x filings to NP.C unon the entire service list except for Bradley Jones, Ruthanne Miller, and Jud6es Bright and Carpenter, who do not have to be served copies #

interr ateries under Judge Kelley's order thereon.

Wells Eddlenan

.