ML20072H190
| ML20072H190 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/25/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| NUDOCS 8306290361 | |
| Download: ML20072H190 (10) | |
Text
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/W 718-A Iredell St.
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~b "q ' Durham NC 27705
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phone 919-286-3076 6-(
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25~ June 1983 Q-ce
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cj)- M Tom Baxter, P.C.
\\
M Shaw, Pittman, Potts & Trowbridge 1800 M st, NW "f
Washington DC 20036
Dear Tom Baxter,
In response to your letter dated 16 June, let me first note that your firm has insisted repeatedly on carryin6 on negotiations with me "off the record".
Here you seem to be trying to force this negotiation onto the record.
While I feel it is appropriate to respond on the record here, I fully reserve the right to respond in the future by insisting (as you and others working for CP&L in this case repeatedly 4
have) that my response be off the record and only those portions mutually agreed to be stated on the record can anpear in any 4
certification by counsel (again, the same procedure you've insisted on).
Also, your letter appears to be not timely.
The Board's Order issued May 27, 1983 Adding 5 days for the mail and 10 days to file a motion to compel gives June 11.
Your letter is dated June 16.
Prior to that date, but af ter May 26, I was in contact.with lawyers for CP&L numerous tines, and visited CP&L headquarter /1,egal dept, at least twice.
No one mentioned these issues to me at any of those con tacts.
Your letter makes no reference to any attempts to contact me previously concerning these matters.
I believe a certain flexibility is reasonable with regard to deadlines, and do not intend to make an issue of this untimeliness here.
However, I an not foregoing any right to make objections concerning timeliness in the f uture.
You fail to show any " exceptional circumstances" (Board Order of 5-27-83 at 15) why you need names of any exnerts (ron-witness) who have provided information or assisted me in answering j
interrogatories.
In response to my general interrogatory G-5(a),
your clients CP&L and NCEMPA have repeatedly stated under oath that they have information and expertise available to them on l
each and every one of my contentions upon which discovery has so far been conducted.
You have not shown any ccndition of being unable I
to "obtain facts or opinions on the same subject by other means" (5-27 Order at 15, footnote 11), and show no facts or circumstances that require any such information.
As to which answers reflect assistance, those with information I will identify; those where the advice or counsel of nonwitness experts are involved, I will not, for two reasons (1) you haven't asked for it: (5/27 Order at 11, note 9, next-t0-last sentence), and (2) NRC rule 2.7140(b)(2) provides that (even where a party has shown a substantial need for, and inability to obtain materials by other l
means) "...the presiding officer shall protect against l
disclosure of the mental impressions, conclusions, opinions or legal theories of an attorney or other representative of a party concerning i
the proceeding."
Expert advice clearly includes such impressions, conclusions, opinions and legal theories.
The experts are acting as my representative inasmuch as they advise my attorney (me) (or any other attorney for me).
8306290361 830625
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/
I PDR ADOCK 05000400 O
s Tom Baxtcr June 25,1983 Your vague and unsupported allusions to " specificity and efficiency" in discovery request Mhow no extraordinary need; you will be told (see bolow) which answers I had assistance on.
I am not sure what you mean by " prepared" but I wrote them all and typed them.
Where they include facts provided by others on which I rely, I will so state.
Where they are based on advice, I do not think that is relevant, and I kept no precise records of what advice I used in each specific response.
You address informally consulted exnerts only to the extent of a possible need (you say "may") to depose folks who will assist me in_ cross-examination or who will oppose a motion for sumnary disposition.
This is no extraordinary circumstance -- you're asking for something that hasn't happened yet (and for which I have made no ' arrangements at this time, though I don't think I have to tell you that since you haven't asked it in any interrogatory).
If a person were to make an affidavit against any motion you might file for summary disposition (on behalf of your clients CP&L/NCENTA),
that person would of course have to be named in the affidavit.
A request for the identity of all persons who might make such an affidavit is premature and too broad.
In both these examples, you show no unusual circumstances, substantial need, or exceptional circumstances including inability to obtain information or opinions on the subject of my contentions by other means.
You cite no contention or interrogatory with respect to which your allegations of need may be true. Your clients' resuonse to G(5)(a) says it's not.
I do rely on the Board's Order of 5/27/83 (see at 15), and hold that it does not require me to demonstrate the expertise of anyone.
In Secbrook, the case on which the Board relied in making this Order, the intervenor was not required to make any showing of specific expertise of those persons co nsulted.
There are good reasons why not:
First, detailing such expertise could be tantamount to identifying such person in a limited group of persons who might assist nuclear intervenors, or narrowing the number of persons who fit the description enogh do that Applicants could obtain the identity of the expert (s).
The Seabrook Board relied on Ager
- v. Jane C. Stormont Hosnital, 622 FPd 496 (loth Circuit 1980), that "once the identities of retained or specially employed experts are disclosed, the protective provisions of the rule concerning facts known or opinions held by such experts are subverted"(Ler at 503, Seabrook A
at p. 10).
In asking to depose such experts, you clearly seek to subvert the protection of the Board's 5-27 order.
Ager also protects information which would tend to disclose the identity of such non-witness experts (e.g. address, employer, phone number).
As noted above, a vita of such a non-witness expert could also be used to identify them.
Neither the Seabrooka Board of this Board has required demonstration of dhe expertise of non-witnesses.
There is another Sood reason for thi s: sinc e the non-witness will not testify, the other parties have no need to examine that non-witnessa's qualifications.
Finall the facts of my position are known, my consultant experts (y,whose identity is requested by you) are not expected to testify, and you have other expertise available (CP&L responses to my interrogatory G-5(a)), so you have no need to prepare cross-examination of them or protect against surprise at hearing (dhe fac$s are disclosed, so they can't surprise you later).
See Hooever v. US, Dept of Interior, 611 F 2d 1132 at 1142' ($th Cir.1980)
. Every person who assisted me in answering interrogatories (except reference librarians whose names I do not know) has technical competence (i.e. knowled e, skill, experience, training 6
or education) in the fields in which they assisted me. (see Board Order of 5 6-17-83 at 6).
You ahow no compelling need or extra-ordinary circumstances that require you to examine the specific qualifications of such experts.
You and your clients have your own experts available, bl CE'"
sd 6tbbd Z reNNY f
I have determined that each such person /has applicable knowledge, skill, experience, training or education; thus they are all exnerts.
(In one case I consulted legal counsel to confirm this. )
The degree of exnertise would only be relevant if each such nerson testif$es.
Obviously, folks who testify or mkke affidavits are identified.
(I can conceive the extraordinary circumstance where only an affidavit from a person who could not be identified was available to me to defend against such a motion.
Then I guess I'd have to move for a protective order, and show the Board compelling reasons to withhold such person's identity.
Tha t situation has not arisen. )
The need to withhold such persons' identities has already been accepted by the Board (5-27-83 Order at 15-16).
The Beard does also say it may make exceptions, but upon a dbowing of exceptional circumstances (or, for informally consulted nonwitness experts, on some possibly less strong showing weighed against the fact that the expert (s) were only informally consulted) that it is " impracticable" to obtain " facts or opinions on the same subject b Exceptions to this, the Board says (fn.11, p.15)y other means".
should turn largely on their own facts.
Without your making such a showing i
of need, there is no need for me to make answers about this.
This is particularly true where the answer might lead to discovery of the identity of a person or persons, wh3ch identity is protected by the Board's 5-27-83 order, It would compromise that protection i
to disclose such information; I would do so only on Board order under an appropriate protective order to prevent the information from being len'ked or used in any way by Applicants except for argunent on the individual case).
You have made no previous interrogatory as to my contractual arrangements with any experts who will not be witnesses, nor have your clients.
I object to the discovery of any such agreements, insofar as they have no bearing on the proceeding.
Since the Board has indicated it will treat non-witness experts informally can sulted somewhat differently (5-27-83 at 15-16), I will point out here that none of the experts you're inquiring about has a written contract, but I understand that in North Carolina law verbal agreements are vilid contracts, and I have such agreements with J persons.
These agreenents do not provide for payment unless such persons perform calculations or studies that involve a significant amount of time, i.e. a half day or somewhat less in one case.
All others are l
Informally consulted in the sense that they refuse to accent payment l
for their services and are not under contract with me. (This does not speak to security experts retained by Joint Intervenors, or any experts I may have retained on issues on which Applicants have not yet filed interrogatories or had same answered).
As to the need to withhold such nanes, I think it is established in the Board's order of 5-27-83 and the Seabrook Board's order of 3-24-833.
Disclosure of names would make it harder for me to obtain expert assistance.
It would definitely expose non-witness experts to depositions if I take you at your word (your letter is one of the difficulties (it takes time, interrupfs tke 2),tc) pa sich en, e
Tom Baxter 6-25-83 cited by the Seabrook intervenor NECNP, and b the Harris Board accepted (5-27 b3 at 12,15).y me, and which Since I might well not be able to produce lawyers (or nyself) to defend such experts during such depositions, particularly for persons not located near me, the possibility of such a chilling effect is more real because there would be no restriction on the measonableness of such depositlons except Applicants' own choice.
I have previously detailed the problems which could deter, and have deterred, persons from assisting me, in my answer to.
Applicants' motion to compel on which the Board ruled 5-27//Sd hdWf.
I remain concerned that those who may lose their job if their identity is revealed, are still in sone jeopardy diile Apnlicants continue to pursue their identity or infomation that can lead to it.
I believe this entire matter is a grand waste of paper, in that Applicants haven't shown a need that is legitimate unusual, and compelling under the standard of Federal Rule 26(b)(4)(B) and the Board's 5-27-83 Order.
They have stated under oath that they have infomation and expertise available to them on all my contentions.
(responses to Eddleman interrogatories G-5(a) in all sets so far received).
There simly is no issue here.
In an attachment to this letter, I will list ~ the specific interrogatory responses (to the best of my recollection where there is no written record) on which I received information from nonwitness experts, identifying what information was received.
As noted above, (in accord with Board 5-27-82 p.11 footnote 9)
I am not disclosing which responses I received advice on.
Applicants have not asked that, and if they did,(2) as cited on page 1 the content of the advice is clearly pmtected by NRC rule 2 740(b)
I of this letter.
I finally note your last paragraph "This constitutes negotiation which tolls the time for Applicants to file a motion to compel discovery."
This appears to be a unlilateral declaration on your part.
You definitely did not contact me prior to sending this letter, concerning it. I am willing to have you start negotiations and tb11 the time for notions to compel in this way, but only to the extent that I can do likewise.
I should be able, thus, to toll time and trigger negotiation with a written notice.
/@u 4
Wells Eddleman j
Intervenor pro se cc (with attachment): Service list.
e o
attachment to 6/25/83 letter to Ton Baxter, atty for Applicants p.1 Supplement to Wells Eddleman's interrogatory resconses to Applicants, identifying which information in certain responses was supplied by an expert.
Contentions 22A and 22B excluded since they've been rejected (this is the same procedure used by Applicants' counsel O'Neill re these contentions as soon as he got the order rejecting then, he advised me he'd do no more work on it (i.e. no answers he'd nromised)).
"Al Aloe"yms herein alternate sexes -- do not imnly experts'f act that defic pseudon NOTE:
hl-1(a) supnlied the is shown by CP&L's failure to catch nine hanger defects.
Sunnlement, also sunplied by "A.A."
is that this is a breach of f aith with NRC since CP&L agrees in setting up QA/QC program to nrevent such defects.
Answer and supplement mad 6 here annly to page 22 of resp.
to 1st set of interrogs by Applicants, contention hl, Int h1(1)(b).
Info on page 2h of same, re 41-1(b) and hl-2(b) was supplied by
" Bess Boe".
Response to k1-h(a) on nage 23 reflects my recollecti6n of opinion of an expert, " Carl Coe", but this person was not consulted in connection with formulating this contention G-1(c) re Eddleman 45 (pp25-26 ibid) beginning "I believe Applicants haven' t shown compliance with or ability to...
and ending on p.26 above 1st paragranh indentat! on (with possible exception of reference to McGuire event of 1981) reflects information supplied by "Della Doe".
G-5, also refle'ei info sunplied by "D.D."
Response to 45-4(b) pp 27-28 ibid 64thiGr*- information supplied laiEr by " Earl Eoe" and "Fran Foe". 4 This information continues to inform the discussion on pp 28-29. 7 Cor]6cm3 TW (ESpW9 Worked 6 Mu%
Response to h5-3 (all parts) based on info sunplied by "D.D."
(page 27)
Response to 45-6 reflects info suppli ed by "D.D." page 29 ibid.
Response to h5-7 reflects info suppli ed by "D.D.",
nage 30 ibid.
Resnonse to 45-8 may include basis of info sunnlied by "D.D.";
I do not exactly recall one way or the other.
Resoonse to h5-9(all parts) is essentially all information supplied by "D.D."
Response to h5-10(all parts) is fnfo sunplied by "D.D."
Resnonse to h5-11 based on infoysunplied by "E.E."
and "F.F." l45fr.
Please note that "E.E. and F.F." may have contributed info to the Skytvdof above listed responses where I prinarily relied on "D.D."; my memory of these noints is not clear; I typed up ' die responses directly af ter referring on sone of these pointsj E+EN " A.P." Wfi cew cM fb d Response to 65-3(a) and (b), page 32 ibid, reflects info supplied by " Bess Boe"; documents on page 33 re 65-h also supplied by "B.B."
Resnonse to 65-5 opinions of experts (but who were not consulted with respect to this response), and that of "B.B."
re, respectively, Brunswick and Danniel, t4rl40rkt M qworJ ES 40 yeosctJS, I do not know the names of the persons who reported bpd concrete at the Harris plant.
They aren't experts to my knowledge, but may have expertise (I <?n n't know). I am unable to identify them.
Response to 65-6 reflects expert oninions, but rJame5 ud KA0W.
(pp3h-35 ibid)
Response to 65-9(a) info sunplied by "B.B."
l
6-25-83 attachm:nt (which intarrogs includo oxport cunplied info)
(balottor to Tom Baxtor, attornsy for CP&L, NCEMPA) nago 2 65-10(a)(b)(C) info was sunplied by "B.B."
(p.36 ibid) 65-11, see 65-9 above.
65-12 info re Diablo Canyon was supplied by NRC Staff; I don't recall who.
75-2, info "another possibility is marine algae above it" supplied by " George Goe".
75-3(b) need for grounding supulied by " Helen HoeZ"; ability of organisms to live on algae:
"G.G.";
safety significance of failures referred to in FOIA 82-261 sunplied by "Ian Ice".
75-h(a) ability to live on dead or living organic matter introduced to condensers, "G. G. " s unpli e d info.
75-5 suread of Corbicula annears inexorable, reflects expert on$nion
. Nw NOV M9-r 75-7 info was sunplied by Aunlicants -- I nresume they're exnerts at least on what Applicants are going to do; ditto for 75-6 above.
(pp 39-ho ibid).
83/8hI do not know the source of the article (p.kk); I haven't found it.
It was delivered to me by a non-expert who was consulting me concerning the article.
(This is a fact I had not recalled in writing response to Baxter's letter of 6-16-83). Under the Board's 5427-63 order, I object to revealing the name of this person, who was consulting me, because this person did not deliver the info to ne in connection with this case at all, but sone years earlier, in connection with an unrelated matter.
This person cannot know anything useful about the article (I've asked) and does not have copy of it (I asked). Revealing the person's nane would only a
expose someone not involved in this case to possible harassnent, waste of time, etc.
I object that the nane is irrelevant to the contention, and to the interrogatory, for the above reasons.
(p.h4 ibid is where this document is referenced).
83/84 general response, p.45, " chlorine interacts with grganic connounds" reflects oninion of exnerts d(iMEs (A # 6MM -
NW usW Suppliers of renorts were already identified.
Formation of chloromethanes, p.h6 bottom, info supnlied by "G.G."
the above is evidently re 83/8h-1 as well as the general interrogatories.
soo p.45 Please note that there is a sunglement coning re li st of chenicals--
haven't had tine to do it yet.
64?dde# 04pH T M N# d f.4b re (4),
C 5
83/8h-3 Concentration factor of 10 was sunplied by "Jano Joe".
Factor of 10 concentration Der stage, by "J.J." and by " Ken Koe" who was not specifically consulted re this resnonse, but had supplied that fact to ne earlier.
83/84-4: chromatogranhy source is given; I do not recall nane of person transmictting this info to ne.
Carcinogenicity of 2,3,7,8 TCDD sunn11ed by "J.J.";
increase in carcinogenicity of chenicals when chlorine added since that increases solubility -
"G.G."
"G.G."
Ionic interaction, etc.
Types of reactions under (2) on page 48 -- locus at oxygen atons s unn11ed by "G.G. ", "J. J" or bo th.
Carcinogenicity of NHC1, NH C1 2
p and NC1 -- the nissing article is source; increased carcinogenicity, 3
see above.
I an not certain if any expert supplied the info re azo compounds -- do not recall one way or the other.
3d page listing of oxpert sourcos'of info in Eddlenan resnonses addendum to 6-25-83 letter to Tom Baxter.
83/8h-5 AdegaNte testing snecs reflect exnert oninion, panes Ar# Ky0u/M, Detection of dioxins (sensitivity) info supplied by "J.J."
Info on criticality of resolution and sensitivity of chromatogranhy, possible need for other methods: infor fron "J.J." and possibly"G.G"; this corresnonds with my own oninion and I do not recall if G.G. made a contribution here.
83/8h-6:
Info was supplied by Applicants, Corps of Engineers, gggihGd State of NC, and consultants to State.
I do not recall the names sakl f
EPA response, nanes not recalled.
Apolicantshaveconfirmedth!sykpd56 in their responses to my interrogatories (i.e. that my assertion is correct as far as daey know).
83/8h-7(1) phrasing is mine, but info cones fron "G.G." (2) info from "G.G." (p.49) p.50, extraordinary toxicity of osniun is an excert opinion, Narne ud6W/A Reaction rate depends on concentration -
"G.G." (tho everybody knows this fact); higher concentration s in sediments -
"G.G."
and possibly "J.J." plus fron monitoring renorts of Annl$ cants,
State, and Coros of Engineers.
Metal complex formation is expert opinion
. No pans hd"#N' (5) on page 50 wording is mine; opinion is that of " Ken Koe" re which organians are at risk; toxicity of metals is exdert onihion s og f s h u.,q Pe,Q@!C&S *,
carcinogenicity of metals is expert opinion, see e.g. Natusch et al on coal particulatesf refsturcif Supplier of article, "Lil Loe",
pn51-52, documents were borrowed fron library of " Mike Moe' whom did not supply any facts or oninions.
Opinions are those of the authors or cited sources in the reports.
Re second set responses by W.E., h/22/83, page h: GI 1(b), info was suuplied by Bruce Molholt who has already been naned in connection with formulation of contention.
I do not recall who suncl$ed me with the LEAF report -- it might have been then, see address given on p.h ibid.
Similarity of Harris to N. Anna and V.C. Sumner -- Harris FSAR.
pp h-5 71 bid, info supplied by B. Molholt; conclusions those of the paper authors.
p.7 testimony of Smith and Domtnoski from NCUC files (I also was present and heard it in 1979).
UCS document, n.7, I don't know who supnlied, still haven't located it.
Gillen/Clough NUREG was supolied by NRC PDR.
PP 7-8, ditto.
Opinion on p.8 the volume changes precluding use of PVC as a ti ht sealer is mine, F
based on my consulting work with industrial sealing systems, and my work in testing sealing systems.
Info re degradation of seals, NUREGs cited above.
ti Tight-seal problems, ny bninion, basis same l
as cited above. (pp8-9) including also energy consulting work for the effects nentioned in air-conditia:ing systens, n.9 ibid.
29-3, p.10, B. Molholt and the FSAR; seal failune nossibility l
1s not from them.
29-4/5 Pisiello data -- do not recall who sunplied.
Occurrence of radioiodines, scientific paners cited above, sunnlied by Molholt.
29-10 Regulatory Guide was sunplied by NRC Staff; not sure who.
It cane with interrogatories. (p.12 )
29 12 11/11/79 Wash. Post, do not recall who sunnlied.
Reg Guide, fron NBC staff as above (p.13 )
interroEatories; attached to renly to Tom Baxtpage 4 n o in resnonses to F.14, 29-12, NRC translation er, Atty, 6/25/83 See p.15, 29-12(b) for answer $20, do not recall who sunnlied.
that covers all of the above re analysis.
29-17, op 16-17, do not recall if exnert facts 37-B.
are included. May<be.
bility, Inc., Main P.O. Box 11207, San FranciI got Gofma uclear Resnonsi-at the UNC-Chapel Hill Health Sciences Library sco.
The rest I found these documents are all experts.
The authors of He 3d set W.E. Resnonses, 5-6-83
& Joint II (on back of Certif.
, and undate re Eddleman 29 and 37B Phi Delta Kannan article in undate was suppli d bof Negotiations, 5/6/83 I don't know who mails it to me.I subscribe to the " Waste Pape y " Helen Hoe".
e ow I receive it.
Pyronhoricity of zirconium is exnert oninion who.
Heating of cask in contact with electrical linPossibly "Nell is an expert re this resnonse.
objects, but not the cask specifically -- that waopinion with resnect es inference.
s ny logical Rupture disk failure at time of resnonse wa expert-supplied fact has supplied the same, information. (the latterbut since this "Priscilla s not an phoricity is on p.4) are on n.11; nyro-pp5-6 ibid, penetration of cask by missile or shav p.6' lied by "Og Ge", and also by " Quick Qoe" and "Roz Roe" supo n object: fact
, object falling onto cask, "Og Oe",
suggested by others in li p.6 and p.5 cask warpage,ne inmediately above (CQ or RP).such could have be "Og ce" p.7 "Og Oe" supplied the list of references 67-2, incineration dangers, " Sam' volume reduction and in landfills and scar /or pulverization.Soe" sunnlied info.
Ditto re CP&L disuosal of LLPW an yards, news renorts and NRC are source 67-5(a) failure to accept hot parts, That such have been shipped as LLRW," Bess Boe", ditto for
" Tina Toe" and "B.B."; probes.
67-5(b)(c)(d) p.9 ibid, restrictions -- some of thi ecall who sunplied.
bP&L violati6n of shipning/disnosal require" tents:" Tina Toe o.
67-7(a) leaking landfills, "Og ce",
NPC, " Tina Toe" Noncompliance shutdowns,
" Tina Toe" Waste Paner, "Og Oe", NC Radiation Prot"Og Oe,",
Was te Paner;, lack of s ta tenossibly others.
resou 9.10,rces thaE alulculties apply to all connact states,t$nn Sect'gn.
ec Tina Toe.
page 5 of attachnent to 6.2 5. 83 letter to Tom Baxter, CP&L/NCEMPA Atty, 2
giving which interrogatory recnonses contain informati on sunn11ed by experts 67-8(a) NC efforts-- NC Radiation Protection Section.
Waste Mgt. Bd, public information,
" Val Voe", ibid o.10 67-9(a) Ocean Disnosal ban -
"Ulm ye"; CP&L jeonardy, see above.
General info re comact, ratification by SC, next state, my words, but info also sunplied by " Tina Toe".
67-11, not knowing whether such technology exists, " San. Soe" Storage is not disnosal, my words, but also the info from "Og Oe" and possibly others.
67-12, answer reflects info sunplied by " San Soe", "Og Oe", and perhaps "T.T" re lack of analysis.
re 6h-3 and 6h-2, answers reflect info sunnlied by "Og ee".
The above answers were made by reviewing the questions and answers and all information I have which identifies the exnerts in ouestion.
I believe it is comnlete, as is the resnonse to Staff cuestions below.
I object to release of any infornation which tends to identify the persons listed above, sirce that would undernine or renove the protection the Board gave 5-27-83 to their nanes.
It a pears that all the informat".on sources for the first 33 staff
(
interrogatories is set forth above.
Iten 2h, do not wecall name l
of NRC sunn11er of the info.
l Re 3h, information sunnlied by Apulicants indicates models to not l
accurately give chi /Q (this is an undate).
Re 37 (Fddleman res3onse to NPC Staff at 13, 5/6/63) need for accurate i
modeling: Bruce Molholt (he was not censulted further re this resnonse).
I re 45, p.16 ibid, methods of carcinogenesis -- some are "G.G." and some are from Gofman's book Radiation and Human Health (1981).
Re h8, chloronethanes can be absorbed thru skin -- I think source is
" or "J.J."
A ccumuxlation of fat-soluble carci nogens -
"J.J."
"G.G.W k
- V,.
Some of the above-listed persons also provided advice on answering interrogatories; some persons not listed above provided advice but no facts -- disclosure of their nanes, I object to, because it cannot lead to di scoverable informat!cn--
the content of their advice is privilbged under 2.7h0(b)(2).
Some persons consulted in connection with this case, e.F.
"Og Oe",
haveprovidedinformationbutonlybeforetheinpwhoprovidedinfo" rogatories were made or answered.
Since the literal cuestion is these persons are listed by pseudonyn above where they provided info.
Others may be relied on but didn't provide the info --e.g.
authors letter as requesting tfiese so they are not gisgeeEl{ don'.treadBaxter's of documents, articles nakers of statement e
ove
~
.o UNITED
'. ERICA NUCLEAR RE%.
Ja 204ISSION In the matter of CAROLINA POWED. & LIG HT CO. Et al. )
Dockets 50-k00 Shearon Harris Nuclear Power Plant, Units 1 and 2
)
and 50leh01 0.L.
CERTIFICATE 0F ST3VICE 6/25/83 lettar to Tom Baxter, Atty I hereby certify that copies of for Applicants,0re his 6/16/83 letter re identity of experts, etc.
von 0 f o&. ce xte n stop of ri m e p gD _ op.
26 June HAVE been served this _
day of _
1981, by deposit in the US Mail, first-class posta5e prepaid, upon all parties whose names are listed below, except those whose names are arked with an asterisk, for whom service was accomplished by Judges James Kelley, Glenn Bright and James Carpenter (1 copy each)
Atomic Safety and Licenairg Board US Nuclear Regulatory Commission Washington DC 20555 GeorEe F. Trowbridge (attorney for Aoplicants)
Shaw, Pittman, Potts & Trowbridge FLuthanne G. Miller 1800 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2055 5 Office of the Executive Legal Director Phyllis Lotchin, Ph.D.
Attn Docke ts 50-400/401 0.L.
100 Bridle Run USNRC Chanel Hill NC 2751h Washington DC 20555 Dan Read l
Docketing and Service Section[3Q CEAUGE/ELP l
l Attn Dockets 50-400/401 0.L.
Box 52h Office of the Secretary Chapel Hill NC 27514 USNRC
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Wasnington DC 20555 L ot) C 2.'
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John Runkle CCNC
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307 Granville Rd (Y WI Chapel Hill Ne 2751k
'yq[gth4 Bradley W. Jones USNRC Region II
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101 Marietta St.
'Travi s Payne Edelstein & Payne 4W Atlanta GA 30303 Box 1260$
Raleigh NC 27605 i
Richard Wilson, M.D.
Certified by 729 Hunter St.
Apex NC 27502
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