ML20073T255

Affidavit of W Eddleman Certifying Negotiations W/Nrc Re Response to NRC First Set of Interrogatories

ML20073T255
Person / Time
Site:	Harris
Issue date:	05/06/1983
From:	Eddleman W EDDLEMAN, W.
To:
References
ISSUANCES-OL, NUDOCS 8305110145
Download: ML20073T255 (2)

Text

1 1

, co l UNITED STATES OF AMERICAN' '

,Ma,f 1983.

NUCLEAR REGULATORY COMMISSIO'N ,e @.

'A 3 w

BEFORE THE ATOMIC SAFETY AND LICENSING j B IED h Glenn O. Eri 5ht ,y Dr. James H. Carpenter % / d James L. Kelley, Chairman 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 ani 2) ) ASLBP No. 82-h68-01

) OL CERTIFICATE OF NEGOTIATIONS Wells Eddleman hereby certifies that he has negotiated with NRC Staff Attorney Barth as follows re the resnonse to Staff's 1st set o-T interrogatories: 1. We agree that no seearate answer is re-ouired to general interrogatories where the answer is the same for each contention.

2. We reached an imoasse over the objection.to identification of nonwitnesses who suon11ed information in these resnonses, and info identifying them. Barth desires only the identity of folks who agree with me. I believe that the identity of nonwitnesses is protected under Ager regardless of their oninions, because I am dealing with a small pool of notential information sources and experts who are gen.85 subject to, and in many cases fear, harassnent and intimidat' on by gf o the nuclear industry or the NRC or its staff.

Ln n

O 3. "nornal operations" means in connliance with tech suecs; however, I believe the cronosed Harris tech specs have been deleted

• from the FSAR so this does not innrove my sbility to answer Staff interrogatories 1!t through 19. h[/(&j[Qf) d h,g Note: 5-5-83 I also gave CP&L an a . net was 934 DSo3 to enswer my diecovery re Edd1enan upditiona(10

s. Att7 . vnndavs eat jt).14-23 Rhrd ehenged.

e_

/

.s

/

UPDATE RE Eddleman 29 and 37B; Joint 2 Wells Eddlenan has received " Fallout and SAT scores: Fvidence for Cognitive Damage During Early Infancy" by E.J. Sternglass and Steven Bell, Phi Delta Kaupan, Auril 1983 pp 539-5E5. This shows that radiciodines, particularly I-131 which was nonitored, are strongly associated with declines in SAT scores of nersons exuosed It also includes evidence of radiation-caused nn1 formations & nortality, to the radiciodines in infancy, i.e. below two years of age. This is a health effect of radiciodines (Eddleman 29) and shows danage that needs to be taken into account in the environmental cost-benefit analysis of Harris oneration under NEPA; it is a health effect under Joint Contention II and Eddlenan 37B, this document being sunnorting evidence for an effect of radiciodines against normal brain development. So far as I know, neither Staff nor Aoplicants have analyzed or included the effect of radiciodines on brain development in the fetus and infants (e.g. below 2 years of age, as shown in the above article), in the ER or the DEIS.

Exclusion of these effects would, of course, result in an under-estinate of the damage donc in the environnent by radiciodines released from Harris under " normal" operating conditions, in minor and in major accidents. The health effects of accidental releases are a nroper part of Joint II and Eddleman 37B in that

. they result from Harris oneration, are effects under NFPA (whether intended or not, controllcd or not), and have an innact on the environment. The cost of such danaFe, to individuals and society, can be quite substantial: witness prevalent concerns about the cuality of education in Anerica, the achievement of students, the SAT scores, and the availability of highly skilled labor for "high tech" industry which both the US and the State of NC seek to devdbp, and which is considered imnortant for economic  ;

growth in the future.