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Category:AFFIDAVITS
MONTHYEARML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc ML18016A8191999-02-12012 February 1999 Affidavit of G Thompson Re Application by CP&L for Amend to FOL NPF-63 & NRC Review of Application & Proposes to Determine That Amend Request Involves No Significant Hazards Consideration ML20209A9071987-01-28028 January 1987 Affidavit of JW Mckay.* Provides Minor Corrections to 861017 Affidavit.Corrections Should Be Made to Allegation on Undercut Tolerances for Holes Drilled to Receive maxi-bolt Anchors.Certificate of Svc Encl ML20214S1271986-09-25025 September 1986 Affidavit of Tw Brombach Re Allegations Raised in Ps Miriello 860728 Affidavit Concerning QA Filed in Support of 860915 Motion to Reopen Record.Allegations W/O Factual Basis.Util s to Jn Grace Re Insp Encl ML20214S1051986-09-25025 September 1986 Affidavit of SA Brown Re 860728 Affidavit of Ps Miriello Concerning Radiation Exposure,Filed in Support of Motion to Reopen Record.Allegations Re Exposure to High Levels of Radiation Unsupported ML20210B6471986-09-13013 September 1986 Affidavit of Ps Miriello Re safety-related Welds That Never Received Preservice Insp ML20205F3771986-08-0606 August 1986 Affidavit of Tw Brombach Re Issues Raised in 860702 Request for Institution of Proceeding Per 10CFR2.206,specifically Allegations on Inservice Insp of Piping Welds.Insp Rept 50-400/85-48 Encl ML20210E0171986-07-28028 July 1986 Affidavit of Ps Miriello Re False Dose & Const Records Constituting Threat to Public Health & Safety ML20210B6961986-07-28028 July 1986 Affidavit of Ps Miriello Stating That QA Quality Check Program Not Used as Intended at Facility ML20210U7691986-05-16016 May 1986 Affidavit of Ps Miriello Re Failure to Act on Issues of False Dose Records,Intimidation & Unsafe Radiation Practices Until After Contention W-4 Produced ML20210U7751986-05-15015 May 1986 Affidavit of Ps Miriello Re Health Physics Supervisors Ordering Author to Agree W/False Radiation Rept & to File NRC Form 4 in Agreement W/False Radiation Rept ML20204A4921986-05-0606 May 1986 Affidavit of SA Browne Re Results of Review of Ps Miriello 860403 Affidavit in Support of Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 ML20210K7041986-04-0303 April 1986 Affidavit of Ps Miriello Re Falsification of Exposure Records.Related Info Encl.W/Certificate of Svc ML20154N2091986-03-10010 March 1986 Suppl to HR Goodwin Affidavit on Timing of Weather Alerts, Per ASLB Request.Info on Precise Times That Weather Alerts Transmitted Unavailable.Certificate of Svc Encl ML20205K6031986-02-24024 February 1986 Affidavit of RW Fell,Supporting NRC Response to Aslab Question Re Conservation Council of North Carolina Contentions 16,17 & 18.Certificate of Svc Encl ML20137P5991986-01-30030 January 1986 Affidavit of Ti Hawkins,Supporting Nrc/Fema Response to Applicant Motions for Disposition of Eddleman Contentions EPX-2 & EPX-8.Certificate of Svc Encl ML20137F4171986-01-13013 January 1986 Affidavit of W Ethridge Re Contention EPX-2.Minor Highway Patrol Radio & Telephone Communications Delays During 850517-18 Exercise Were Due to Priority Assigned to Messages & Emergency Operations Ctr.Difficulties Being Resolved ML20137J0731986-01-13013 January 1986 Affidavit of Ah Joyner in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys.Certificate of Svc Encl ML20137F4101986-01-13013 January 1986 Affidavit of Dh Brown Re Contention EPX-2.Relay Procedure Is Normal Operating Procedure for Radiation Protection Section Communications & Causes No Significant Delays or Addl Inaccuracies ML20137F6491986-01-13013 January 1986 Affidavit of M Scott Re Contention EPX-2.Chatham County Responded Appropriately & Effectively to Experience Gained During 850517-18 Exercise.Addl Dispatchers Will Assure Response to Radio Traffic Levels.W/Certificate of Svc ML20137F6161986-01-13013 January 1986 Affidavit of Ah Joyner Re Contention EPX-2.Corrective Actions Being Taken to Resolve Communications Problems Experienced During 850517-18 Exercise.Resolutions Expected Prior to Full Power Licensing of Plant ML20137J0591986-01-10010 January 1986 Affidavit of R Capps in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys ML20136F6401985-12-31031 December 1985 Affidavit of Dn Keast Re Correction to 851104 & 05 Oral Testimony on Eddleman Contention 57-C-3.Certification of Svc & Notice of Withdrawal Encl ML20137L7951985-11-26026 November 1985 Affidavit of Wj Hindman Re Info on Age Distribution & Gender of Daniel Intl Corp Employees & First Line QA Inspectors at Facility.Certificate of Svc Encl ML20135H8321985-09-23023 September 1985 Affidavit of SL Burch Re Undercover Drug Operation at Facility.Related Correspondence ML20135H8371985-09-19019 September 1985 Second Affidavit of SL Burch Re Drug Investigation at Facility.Related Correspondence ML20137L6741985-09-0606 September 1985 Affidavit of P Miriello Re Drug Abuse Observed at Facility Const Site.Certificate of Svc Encl ML20134H4261985-08-23023 August 1985 Affidavit of Wp Haass Re ASLB Questions Concerning Whether Public Disclosure of Info Voluntarily Submitted to NRC Would Impair NRC Future Ability to Obtain Similar Info.Notice of Appearance of Ga Berry & Certificate of Svc Encl ML20135C0421985-08-23023 August 1985 Affidavit of Wp Haass Addressing Series of Questions Propounded by ASLB Re Whether Public Disclosure of Info Contained in Certain Applicant Documents in ASLB Possession Would Impair Staff Ability to Obtain Info ML20134E7891985-08-14014 August 1985 Affidavit of Wj Hindman Responding to SL Burch 850731 Affidavit Re Undercover Drug Investigation During Fall 1984 ML20134E7761985-08-14014 August 1985 Affidavit of MW King Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7661985-08-14014 August 1985 Affidavit of DG Joyner Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7831985-08-0909 August 1985 Affidavit of ML Plueddemann Re Fall 1984 Undercover Drug Investigation at Site ML20133A1111985-07-31031 July 1985 Affidavit of SL Burch Re Assertions in King Affidavit & Undercover Operation of Facility Concerning Drug Abuse. Intelligence Indicated Drug Dealings & Abuse Widespread. Certificate of Svc Encl ML20129H1061985-07-11011 July 1985 Affidavit of Nj Chiangi Re Allegation in Conservation Council of North Carolina Contention WB-3.QA Program Provides Necessary Steps to Ensure Safe & Reliable Power Plant.Certificate of Svc Encl ML20129H0941985-07-10010 July 1985 Affidavit of Wj Hindman Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const ML20129H0821985-07-10010 July 1985 Affidavit of Pb Bensinger Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const.Biography Encl ML20129H0911985-07-0909 July 1985 Affidavit of Jd Ferguson Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Cp&L Adopted Drug & Alcohol Interdepartmental Procedure.Resume & Procedure Encl ML20129H0991985-07-0909 July 1985 Affidavit of AR Pannill & Gw Flowers Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Employees Subjected to Preemployment Background Verification ML20129H0871985-07-0909 July 1985 Affidavit of MW King Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Use Widespread & That Mgt Failed to Control Drug Use During Const.Resume Encl ML20128M0401985-07-0808 July 1985 Affidavit of TS Elleman Supporting Util 850709 Application for Withholding Final Rept Shnp QA/QC-Const Inspector Review Panel, Per 10CFR2.790.Certificate of Svc Encl. Related Correspondence ML20128M0331985-07-0808 July 1985 Affidavit of HR Banks Supporting Util 850709 Application for Withholding Documents,Including Quality Check Rept,Concern/ Allegation Followup & Quality Check Procedure Investigation Rept,Per 10CFR2.790.Related Correspondence ML20116N7771985-05-0202 May 1985 Affidavit of Ti Hawkins in Support of Applicant Suppl to Motion for Summary Disposition of Eddleman Contention 213 Re Emergency Planning.Certificate of Svc Encl ML20116D0091985-04-25025 April 1985 Affidavit of Jf Myers Describing Recent Change to Provisions for Official Transportation Assistance for Persons in Emergency Planning Zone Needing Assistance in Event of Plant Emergency.Related Correspondence ML20112K0061985-04-0505 April 1985 Supplemental Affidavit of RG Black on Eddleman Contention 213.Provisions for Alert & Notification of Persons on Harris Lake Obviate Measures Suggested by Contention ML20112K0131985-04-0505 April 1985 Supplemental Affidavit of MR Bassiouni on Eddleman Contention 213.Rept of Proposed Siren Configuration & One Oversize Map Encl.Aperture Card Available in PDR ML20100B1011985-03-22022 March 1985 Supplemental Affidavit of Eh Harris Re Rev of School Evaluation Procedure Which Would Reduce Number of Students Riding Buses & Use of Buses Kept on Property During School Hours.Certificate of Svc Encl.Related Correspondence ML20107M5111985-02-27027 February 1985 Affidavit of Ti Hawkins in Support of Motion for Summary Disposition of Eddleman Contention 30.Emergency Response Plan Provisions Fully Comply w/NUREG-0654 ML20107K0411985-02-26026 February 1985 Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Contention EPJ-4(c).Prof Qualifications Encl.Certificate of Svc Encl 1999-04-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
Text
.9.
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w:.xiw i:0DUur?nsnesco C0CKF.TED UNITED STATES.OF AMERICA USNRC
- NUCLEAR REGULATORY COMMISSION e -
." BEFORE THE ATOMIC SAFETY AND LICENSING 3dAfi9 -6 P1 :26
____ _0EEICE E SE CPE? F1--- --
In the Mattetof )- g.gcgg.imG & SEN!f.!,
) BF./.NCH CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
)
(Shearon Harris Nuclear Power Plant, )
Units 1 & 2) )
AFFIDAVIT OF WILLIAM T. HOGARTH IN SUPPORT OF
SUMMARY
DISPOSITION OF EDDLEM AN CONTENT!ON 83/84 (CHEMICAL DISCHARGES)
STATE OF NORTH CAROLINA )
)
COUNTY OF WAKE )
WILLIAM T. HOGARTH~, being duly sworn according to law, deposes and says as follows:
- 1. I am Manager-Environmental Technology Section of Carolina Power & Light Company, and give this affidavit in support of Applicants' Motion for Summary Disposition of Eddleman Contention 83/84. I have personal knowledge of the matters set forth herein and believe them to be true and correct to the best of my information, knowledge, and belief. A summary of my professional qualifications and experience is attached as Exhibit "A" hereto.
- 2. Eddleman Contention '83/84 (Chemical Discharges) alleges that the Applicants have not adequ<1tely assessed the environmental effects of the SHNPP chemical discharges. The purpose of this affidavit-is to summarize Applicants' environmental assessments of SHNPP chemical discharges in support of Applicants' summary disposition motion.
8309070265 830901 PDR ADOCK 05000400 0 PDR
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- 3. The Applicants have foll' owed applicable guidelines ' and regulations established pursuant to federal and North Carolina law in evaluating the effects of chemical discharges in the Environmental Report - Construction Permit ' Stage and the Environmental Report -
Operating License Stage.
- 4. The NRC established guidelines (Reg. Guide 4.2, Rev. 2, NUREG-0099) for applicants to follow in preparing environmental reports to ensure that adequate environmental assessments are performed. ' As recommended, Applicants' ER measures expected discharges from the Harris plant against federal and state effluent standards - namely, the North Carolina water quality standards for Class C waters and the NPDES permit requirements. See ER Table 3.6.2-2; see also ER SS 3.6, 5.3 and 5.4.
- 5. The effluent concentrations the Applicants expect to discharge are below or are equal to the NPDES " average- rather than the " maximum" concentration limitations. For example, the NPDES requirement for free available chlorine (FAC) is an average concentration of 0.2 mg/l and a maximum of 0.5 mg/1. Discharge of total residual chlorine (TRC)- of which only a small fraction will be FAC - is not expected to exceed 0.2 mg/1. The level of TRC which Applicants expect to discharge is that recommended by the NRC Staff in the RFES-CP. FAC in the discharges at Harris is actually expected to be below detectable limits. In order to ensure compliance with their own operational [Slans as well as NPDES permit requirements, the Applicants have made provisions for effluent hold up and sampling prior to release to the blowdown line for all wastes reijuiring treatment to meet EPA effluent guidelines or state water quality standards. ._
- 6. The Applicants also m'odeled the dilution and mixing of discharges, as recommended in Reg. Guide 4.2. The model assumed the mixing zone to be a 120 acre surface area. (E.R.
Section 5.3.2). TRC will be degraded to 0.01 mg/1, well within this mixing zone. The NPDES permit requirements allow a larger mixing zone (200 acres). The expected 0.01 mg/l meets the most restrictive criteria for a fresh warm water fishery (Quality Criteria for Water,1976, EPA-440/9-76-023). Applicants and the NRC Staff have determined that TRC and other discharges
were determined by Applicants to pose a minimal risk to the environment due to rapid mixing and dilution, as well as by the NRC Staff. See DES at 5-3 to 5-9.
~ 7. Based on compliance with EPA effluent limitations and the dilution and mixing effects, the Applicants have concluded that the expected discharges will have no significant overall risk to environment. The NRC staff in its independent assessment of impacts (DES) have concurred with tne Applicants' findings of minimal impact. DES Section 5.3.1.2.2.
- 9. In conclusion, the Applicants have adequately assessed the environmental impacts of its chemical and wastewater discharges from SHNPP, as required by law (NEPA and FWPCA) and under the regulations, guidelines and recommendations of the NRC and the EPA.
This the N/JN day of Mey'M ,1983.
h&W-WILLIAM T. HOGARTH '
Sworn to and Subscribed before me, this the 3/ day of ML^ci ,1983.
u Wil,- Trn My Commission Expires:
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~ Exhibit ~A WILLIAM T.'HOGARTH l
Social Security No.: _ _ _ _ . . . .
Current Position: Manager Environmental Technology Section Carolina Power at Light Company Harris Energy at Environmental Center Route 1, Box 327 New Hill, North Carolina 27562 Telephone: (919) 362-3276 Home Address:
- 1. Personal Data Date of Birth: . . . . ' , . . . , , . .
' Place of Birth: Jarratt, Virginia
- 11. Education B.S.--University of Richmond, Richmond, Virginia--1963 M.S.--University of Richmond, Richmond, Virginia--1965 Ph.D.--North Carolina State University, Raleigh, North Carolina--1976
- Program for Technical Managers--University of North Carolina-1983 111. Experience in Higher Education Coordinator of General Biology Labs--University of Richmond Laboratory Assistant in Comparative Anatomy, Ichthyology, and Ecology--University of Richmond Graduate Research Assistant-Roanoke-Albemarle Striped Bass Project-North CarolinaState University--1966-1972
- Graduate Research Assistant--Chowan River Project--North Carolina State University--1966-1970
- _ Research Assistant--Dolphin Aquadulture Project--North Car.olina State University--1970.1972 J
h r
.9 .
wo IV. Honors Williams Fellowship--University of Richmond
' P esident-Beta Beta Beta-University of Richmond Grant from Virginia Academy of Science for M.S. Research-University of Richmond Treasurer--Phi Sigma Society--North Carolina State University Sport Fishing Institute Grant for Ph.D. Research Grant from North Carolina Wildlife Society V. Field Experience 1963-1965-Sampling of James River tributaries in connection with M.S.research.
1965-Chesapeake Biological Laboratory-seven months-striped bass project.
1966-1972-Graduate student in charge of Roanoke-Albemarle striped bass project.
1966-1970--Periodic sampling of Chowan, Nottoway, and Blackwater Rivers.
1970-1972--Dolphin Aquaculture-Sea Grant Project-Hatteras, Bimini and Key West, Florida.
1966-Project on RV Eastward to determine feasibility of long-line fishing off Jamaica. ,.
1967--Fishing expedition off San Juan to determine species abundance using long-line gear.
1973--Consultant to Roanoke-Albemarle project (March-May)--
Collecting data on spawning migration of striped bass and preparing annual report. - '
1972-1980-Carolina Power & Light (CP&L) Company biologist -
Project Manager of Cape Fear Estuary Study--$8 mi!! ion comprehensive study by CP&L, University of North Carolina, North Carolina State University, and outside investigators to determine impact of once-through power,. plant. cooling system on Cape Fear Estuary asuatic piopulations.
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v*
, - . . . . . - - . . , , - . - - - - - , . . . . . - . . . , ~ ., . - -
e ,,
VI. _ Society Memberships' -
An)erican Fisheries Society' . .
American Society of Ichthyologists and Herpetologists North Carolina Academy of Science.-
Society of Power Industry Biologists VII. Current Technical Committees Southeastern Electric. Exchange Environmental Committee-Vice Chairman Electric Power Research Institute Task Force on Environment North Carolina Wildlife Resources Commission--Striped Bass Steering
. Committee '
University of North Carolina--Water Resources Research Institute--
Advisory Committee Vill. Certification Certified Fisheries Scientist--American Fisheries Society
[ IX. Current Responsibilities l As the Manager of the Environmental Technology Section, I am i
responsible for the formulation and implementation of a broad variety
' of biological and scientific programs necessary to identify and quantify actual and potential environmental impacts associated with the construction and operation of fossil, hydro, and nuclear power -
plants. Responsibilities include providing (1) reports to various regi 'a-l tory agencies the environmental impacts related to Company operations andidentifyingtechnical- (2) special expertise to the Company in support of various Company activities. This expertise is provided by a staff of 47 professiona! engineers and scientists and 37 technicians. Working in four laboratories at the Harris Energy &
Environmental Center, this staff provides suppo'rt in materials sciences, analytical chemistry, air quality, and biological areas.
As Manager. - Environmental Technology, I am also responsible annually for the planning any development of the. annual operations and maintenance and construction budgets for the section. I modify the scope of the~ budget as required to ensure that required programs are adequately funded and contingency funds are available for anticipated studies for the ensuing year. The budget for 1982 is over r; $4 million.
_. Regulatory .cequirements- are the basis for most environmental programs and studies. conducted by the section. Satisfactory Company compliance with these requirements, at minimum cost, requires frequent and positive interaction with these regulatory agencies. The Manager -
Environmental Technology maintains close working relationships with the Environmental Protection Agency, the United States Fish & Wildlife Service, the National Marine Fisheries Service, the Nuclear Regulatory Commission, and various divisions of the North Carolina Department of Natural & Economic Resources and the South l _'
i Carolina Department of Health & Environmental Control to achieve satisfactory compliance.
b Ns Manager - Environmental Technology, I am challenged to identify, as early as possible, potential problems and/or opportunities in L Company environmental compliance; to analyze and evaluate 6 compliance alternatives considering net only ecology but also engineering, behavior; and construction, generation, legal opinions, and regulatory to effectively manage the inherent potential for misunderstood communications between biologists and engineers.
E X. 3 Publications and Technical Reports P Hogarth, W. T. and W. S. Woolcott. 1966. The Mountain Stripeback s
Darter, Percina notogramma montuosa, N. sap. from Upper James
- River, Virginia. Chesapeake Science, 7(2):101-109.
Merriner,3. V., W. T. Hogarth and W. A. Foster. 1970. Occurrence of the Common Snook, Centropomus undecimalis (Block) (Pisces-
- Centropomidae)in North Carolina waters. The Journal of the Elisha n
Mitchell Scientific Society. 86(4):194-195.
m
- Hassler, W. W., W. T. Hogarth and L. L. Liner,111. The status and a abundance of the Striped Bass in the Roanoke River, North Carolina, for 1966.
i e
- Hassler, W. W., W.'T. Hogarth, L. L. Liner, !!! and H. S. Millsaps, Jr.
The status and abundance of the Striped Bass in the Roanoke River.
North Carolina, for 1967.
t E
i Hassler, W. W., W. T. Hogarth and C. R. Stroud, Jr. The status and abundance of the Striped Bass in the Roanoke River, North Carolina,
- for 1968.
E Hassler, W. W. and W. T. Hogarth.
3 The status, abundance, and y exploitation of the Striped Bass in the Tar River, North Caronna,
. for 1969.
b Hassler, W. W., W. T. Hogarth and C- '
F Manocch. The status, abundance, and exploitation of the 50, L 3 ass in the Roanoke River and Albemarle Sound, North Carolin( Le 1970.
Hassler, W. W., W. T. Hogarth and C. S. Manooch.
5 The status, abundance, and exploitation of the Striped Bass in the Roanoke
, River and Albemarle Sound, North Carolina, for 1971.
, -- Hassler, W. - W., W. T. Hogarth" and ' C. S. Manooch.
The status, abundance, and exploitation of the Striped Bass in the Roanoke 4 River and Albemarle Sound, North Carolina, for 1972.
j
' Hassler, W. W. and W. T. Hogarth. 1977. The growth and culture of Dolphin, Coryphaena hipourus, in North Carolina. Acquaculture, 12 (1977).
p
--i- -
6 Hogarth, W. T. Biology of the Wahoo, Acanthocybium solandri, off the North Carolina coast (in preparation).
5,chwartz, Frank 3., W. T. Hogarth and M. L. Weinstein. Marine and
~ freshwater fishes of the Cape Fear Estuary, North Carolina, and their distribution in relation to environmental factors. Brimleyana
' No. 7:17-37. July 1981. s Manooch, Charles S. III, and W. T. Hogarth. Stomach contents and giant Nematodes from wahoo, Acanthocyblum solanderi, collected
- along the South Atlantic and Gulf coasts of the United States.
Bulletin of Marine Science,33(2):197-212,1983.
XI.
Reoorts Responsible for a' t Carolina Power & Light Company Impingement Report--Brunswick Steam Electric Plant. January 1974-January 1975.
Brunswick Steam Electric Piant Borrow Pit Studies.1975.
H. B. Robinson 316 (a) and (b) Demonstration.1976.
H. F. Lee 316 Demonstration.1978.
Cape Fear 316 Demonstration.1977.
Brunswick Steam Electric Plant-Cape Fear Studies. A 20-volume report set on the effects of the operation of the once-through cooling system on the Cape Fear Estuary aquatic populations.
Bioassay Studies--Roxboro Steam Electric Plant.
Trace Element Studies--CP&L System.
Many other reports concerned with site selection studies and biological monitoring programs. t l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION GFF~.._
- C F ncat ::,
BEFORE THE ATOMIC SAFETY AND LICENSING Bb Nd(jffCH In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN MUNICIPAL )
POWER AGENCY )
) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion for Summary Disposition of Eddleman Contention 83/84," " Statement of Facts Material to Eddleman 83/84 As To Which There Is No Genuine Issue To Be Heard," " Affidavit of William T. Hogarth in Support of Summary Disposition of Eddleman Contention 83/84 (Chemical Discharges)'
were served this 1st day of September,1983 by deposit in the United States mail, first class, posta ge prepaid, to the parties off the attached Service List.
Hill Carrow Attorney .
Carolina Power & Light C'ampany l Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6839 Dated: September 1,1983 . -
l I
SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U. S. Nuclear Regulatory Commission 307 Granville Road Washington, D. C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission cost Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U. S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington,'D. C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Thomas A. Baxter, Esquire Washington, D. C. 20555 John H. O'Neill, Jr., Esquire Shaw, Pittman, Potts & Trowbridge Docketing and Service Section 1800 M Street, N.W.
Office of the Secretary Washington, D. C. 20036 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Phyllis Lotchin 108 Bridle Run Mr. Daniel F. Read, President Chapel Hill, North Carolina 27514 Chapel Hill Anti-Nuclear Group Effort Bradley W. Jones, Esquire Post Office Box 524 U. S. Nuclear Regulatory Commission Chapel Hill, North Carolina 27514 Region II i 101 Marietta Street Dr. Linda Little Atlanta, Georgia 30303 Governor's Waste Management Board 513 Albemarle Building Robert P. Gruber 325 Salisbury Street Executive Director Raleigh, North Carolina 27611 Public Staff
. North Carolina Utilities Commission Ruthanne G. Miller, Esquire . Post Office Box 991 Atomic Safety and Licensing Raleigh, North Carolina 27602 Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 e