ML20071E620
| ML20071E620 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/09/1983 |
| From: | Bauser D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | WILSON, R. |
| Shared Package | |
| ML20071E563 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8303140266 | |
| Download: ML20071E620 (10) | |
Text
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March 9, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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AND NORTH CAROLINA EASTERN
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Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY
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50-401 OL
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(Shearon Harris Nuclear Power
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Plant, Units 1 and 2)
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APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR RICHARD D. WILSON (SECOND SET)
Pursuant to 10 C.F.R. 55 2.740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference)" of September 22, 1982, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Richard D.
Wilson 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 identified in the response to interrogatories below.
8303140266 830309 PDR ADOCK 05000400 I
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Under the Commission's Rules of Practice, answers or objections to these interrogatories must be served within 14 days after service of the interrogatories; responses or objections to the request for production of documents must be served within 30 days after service of the request.
These interrogatories are intended to be continuing in nature, and the ar.swers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R.
$ 2.740(e),
should you or any individual acting on your behalf obtain any new or differing information responsive to these interroga-i tories.
The request for production of documents is also continuing in nature and you must produce immediately any j
additional documents you or any individual acting on your behalf obtain which are responsive to the request, in accord-ance 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, J
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-i tion (s), chapter (s), or pages(s)) upon which you rely.
i Definitions:
As used hereinafter, the following defini-I tions shall apply:
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The "ER" is the Environmental Report - Operating License Stage for the Shearon Harris Nuclear Power Plant, as amended.
" Applicants" is intended to encompass Carolina Power &
Light Company, North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.
" Document (s)" means all writings and records of every type in the possession, control or custody of Richard D. Wilson 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 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, or control of Richard D. Wilson; a document shall be deemed to be within the " control" of Richard D. Wilson or any individual acting on his behalf if he has ownership, possession or custody of the document or copy thereof, or has the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
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General Interrogatories 1(a).
State the name, present or last known address, and l
present or last known employer of each person known to you to i
have first-hand knowledge of the facts alleged, and upon which l
you relied in formulating allegations, in the contention which is the subject of this set of interrogatories. ;
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(b).
Identify those facts concerning which each such person has first-hand knowledge.
(c).
State the specific allegation in the 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, employer and educational and professional qualifications of each person you intend to call as an expert witness or a witness relating to the contention which is the subject of this set of interroga-tories.
(b).
State the subject matter to which each such person is expected to testify.
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 formulating allegations in the contention which is the subject of this set of interrogatories.
(b).
State the specific allegation in the 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 interregatory herein.
(b).
Identify the specific interrogatory response (s) to which each such document relates.
6(a).
Identify any other source of information, not previously 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 you intend to offer as exhibits during this proceeding to support the contention which is the subject of this set of interrogatories or which you intend to use during cross-examination of witnesses presented by Applicants and/or the NRC Staff on the contention which is the subject of this set of interrogatories.
(b).
Identify the particular page citations of each document applicable to the contention.
4 Interrogatories on Wilson Contention I(g)
(Health Effects)
I(g)-1.
Describe the phenomenon " bioaccumulation in terrestial ecosystems" with which you are concerned in Contention I(g).
I(g)-2.
What are the "i,ssues" of bioaccumulation in terrestial ecosystems to which you refer in Contention I(g)?
I(g)-3.
Describe how, in your view, Applicants could satisfy your concern about bioaccumulation in terrestial ecosystems.
I(g)-4.
Why is the ER's use of the exposure pathway through grass and milk insufficient?
I(g)-5.
Why are you particularly concerned about the pathway that involves plants, flowers, bees and honey?
I(g)-6.
Describe all of your particular concerns with respect to the plant-flower-bee-honey pathway.
I(g)-7.
Is Contention I(g) concerned about the impact on the environment of the radiation released during normal operaton of the Shearon Harris facility?
I(g)-8.
If the answer to Interrogatory I(g)-7 is yes, explain what you believe the incremental impact of normal plant operation would be on bioaccumulation in terrestral ecosystems.
W.
Request for Production of Documents Applicants request that Richard D. Wilson 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 interroga-tories at a place mutually convenient to the parties.
Respectfully submitted, Wk b.
Thomas A.
- Baxter, P.C.
Deborah B.
Bauser SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Richard E.
Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O.
Box 1551 Raleigh, North Carolina 26602 (919) 836-7707 Dated:
March 9, 1983 l l I
a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
' TU BEFORE THE ATOMIC SAFETY AND LICENSING BOARD D3 fjAp J 7 NO:24 In the Matter of
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ek,1$cbk Or CAROLINA POWER & LIGHT COMPANY
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Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN
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50-401 OL MUNICIPAL POWER AGENCY
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)
(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Interrogatories and Request for Production of Documents to CANP (First Set),"
" Applicants' Interrogatories and Request for Production of Documents to Intervenor Wells Eddleman (Second Set)," " Applicants' Interrogatories and Request for Production of Documents to Joint Intervenors (Second Set) " and " Applicants ' Interrogatories and Request for Production of Documents to Intervenor Richard D.
Wilson (Second Set)" were served this 9th day of March,1983, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
S h /3./ b u 4. a._
Deborah B.
Bauser
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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)
CAROLINA POWER & LIGHT COMPANY
)
Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN
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50-401 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
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SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atmic Safety ard Licensing Board Conservation Council of North Carolira U.S. Nuclear Regulatory Camlission 307 Granville Road Washington, D.C.
20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atmic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Ccmnission P.O. Box 12643 Washington, D.C.
20555 Raleigh, North Carolina 27605 Dr. Janes H. Carpenter Dr. Richard D. Wilson Atmic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Cemnission Apex, North Carolira 27502 Washington, D.C.
20555 Mr. Wells Eddlenan Charles A. Barth, Esquire 718-A Iredell Street Myron Karman, Esquire Durhan, North Carolina 27705 Office of Executive Iagal Director.
U.S. Nuclear Regulatory Ccmnission Ms. Patricia T. Newnan Washington, D.C.
20555 Mr. Slater E. Newman Citizens Against Nuclear Power Docketing and Service Section 2309 Weymouth Court Office of the Secretary Raleigh, North Carolina 27612 U.S. Nuclear Regulatory Ccmnission Washington, D.C.
20555 Richard E. Jones, Esquire Vice President & Senior Counsel Mr. Daniel F. Read, President Carolina Power & Light Cmpany Chapel Hill Anti-Nuclear Group Effort P.O. Box 1551 P.O. Box 524 Raleigh, North Carolina 27602 Chapel Hill, North Carolina 27514 Dr. Phyllis Ictchin 108 Bridle Run Chapel Hill, North Carolina 27514
- Deborah Greenblatt, Esquire 1634 Crest Road Raleigh, North Carolina 27606 Bradley W. Jones, Esquire U.S. Nuclear Regulatory Ccmnission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atanic Safety and Licensing Board Panel U.S. Nuclear Regulatory Ccmnission Washington, D.C.
20555
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