ML20078M157

Interrogatories Re Contentions 8F1,8F2 & 15AA (Second Round,Third Set).Related Correspondence

ML20078M157
Person / Time
Site:	Harris
Issue date:	10/21/1983
From:	Eddleman W EDDLEMAN, W.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8310250040
Download: ML20078M157 (6)

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7 UNITED STATES OF AMERICA Octo k k ,0 1983 NUCLEAR REGULATORY COMMISSION

'83 00124 PI2:25 FiCE OF SECA&

BEFORE THE ATOMIC SAFETY AND LICENSING boa CXEf tHG & SEiWh1 Glenn O. Bri BWU Dr. James H.ght Carpenter James L. Kelley, Chairman In the Matter of J Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuciaar Power Plant, )

Units i ani 2) )

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~ Wells Eddleman's Ir.terrogator$es to N9C Staff

- Re 8F1, 8F2 and 16AA (2d round: 3d set overall) 102. With respect to your answers to (i) Interrogatory 3 (ii) Interrogatory 17 (iii) Interrogatory 26 (iv) Interrogatories 61, INTERPOGATODIES 66, and 76 (re 8F1 only) (v)85-89,92,96, and 101 (re 8F2 only)

(vi) Interrogatories 31, 34, h4, 53,54,58 (re 15AA only), filed 12 October 1983, please answer the following: (Note that you answer 3, 17 and 26 four times in the resnonses, once each fo" Contentions 8F1, 8F2,15AA and 132) -

l l (a) Does the person who orenared this answer know of any I

dissenting oninion (oninion differing with the answer given) hdald by anyone on the NRC Staff ?

(b) does the supervisor or person in charge of the reviev l

branch which prepared answers to this interrogatory know of any dissenting oninion (differing with the answer given) held by anyone on the NRC Staff?

i (c) does anyone else who reviewed, revised, or annrovied

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this answer know of any dissenging opinion- (differing with the ,

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. answer given) held by anyone on the NDC Staff?

l 0310250040 831021 h-PDR ADOCK 05000400 G PDR

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~2-(102 continued)

(d) If answer to any of parts (a),(b) or (c) above is affirmative for any interrogatory for any contention umong those listed above under interrogatory 102, pisase:

(i) identify the verson who holds the dissenting opinion (and each verson who holds a dissenting opinion), and (ii) state, for each such person, dae nature, rationale and basis of the dissenting onihion, including a statement of the dissenting ooinion itself.

103 Please state all significant bases, calculations, and lines of reasoning used in your AISI re (i) Contention 8F1 (ii)

Contention 8F2 (iii) Contention 15AA.

105h. Does the Staff know anything about the health effedts of particulate emissions from coal clants?

105 What doncumente contain inf ormati on known to the Staff concerning health effects of particulate emissions from coal-burning power plants? Please list all suhh documents you nossess.

106. Has the Staff performed any specific analysis of the health effects of the particulate emissions given in Table S-3?

107. Please state exactly what, if anydning, was d3ne by NRC Staff in order to assess the health effects of coal particulate emissions given in Table S-3, including but not limited to (i) studies of toxicity of such particulates (ii) studies of interaction of such particulates with gaseous coal emissions ( e . g . th e "ga s -

aerosol complex) which produce health effects (iii) studies of carcinogenicity of such particulates (iv) studies of the nathways by which such coal particulates enter the lung (v) studies of uptake of materials from coal carticulate in the lung (v5 )

other studies of the health effects of coal rarticulates (vii) any studies done in connection with nrenaring Table S-a3

1 l

(107 continued) which concern the health effects of coal particulates (viii) any connavison of the health effects of coal pollution (including particulates) with health effects of nuclear pollution (emissions fron nuclear power plants) 108. Does the Staff or any person on it who --- analyzes or answers this question believe that coal particulates have no health effects?

109. Please state all basis for any belief that coal particulates do not have health effects. (e.g. belief given re 108 above) 110. If you can't answer Interrogatory 76 (see p.18 of Oct 12 1983 response by NRC Staff), how can you say -that the health effects of coal particulates are taken sufficiently into account in the DES for Harris ?

Please state all basis for your answer to the above que stion.

health effects of 111. If you have no analysis ofjcoal narticulates in the DES and FES (see resnonses to Interrogatories 27 and 66, up1h and 16 of 10-12-83 responses), can you truthfully say that the DES or FES considers the health effects of coal particulates?

112. Is there any concentration or amount of coal particulates in air that NRC Staff believes will result in zero health effects if breathed? If so, what is that concentration or amount?

113 Can coal carticulates cause health effects by interacting with other environmental pollutants (e.g. (i) Sulfur oxides (ii) sulfur and nitrogen oxides (iii) nitrogen oxides (iv) acid precipitation), or not?

114 Has Staff analyzed health effects of coal particulates in conjunction with typical levels of (i) sulfur oxides (ii) sulmfur oxides and nitrogen oxides (iii) nitrogen oxides (iv) acida precipitation?

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115 (ref respons e to Interrogatory 2, p.20,10-12-83)

Does the Staff believe thaja level of (i) dose commitments (ii) health effects, resulting from radiation, is accentable as long as it is less than daat resulting f rom natural background radiation?

116. What is the natural background level of alnha-emitting elements in (1) air (ii) fresh water (iii) oceans, i.e. the background level not produced by uranium mining or the nuclear fuel cycle?

117A Please identify all documents which give information inquited about in Interrogatory 1156 above, which you possess. ,

118. What is the natural background level of non-alnha-emitting radioisotones (excluding those uroduced by nuclear fission initiated by humans) in (i) a typical American's body (ii) a reference person's body (iii) the air (iv) the fresh water (v) the oceans in the Unit &d States or its territorial limits, to your knowledge?

119. In comouting " natural background" in the analysis cited from DES page C-7 (your resnons e to Interrogatory 22, p.20, 10-12-83) did NRC Staff count (i) nuclear weanons fallout (ii) venting from underground testing of nuclear weapons (iii) emissions from military or weapons production reactors (iv) emissions from uranium mining for weanons (v) emissions from nuclear bombs, nuclear power plants, uranium mining, or c Lht- nuclear activities outside the US, as " background"'  !! , which ones, and how?

i 120 How was " background" radiation measured or assumed )

for the purposes of the analysis quoted at page C-7 in the DES?

Did it include any of the emissions inouired about in interrogatory 119 above?

121. What in the Staff's " general knowledged of canacity factors for PWRs" referred to in your resnonse to interrogatory 3h (p.36 of 10-12-83 respons e ) ?

-4A- (#'s 12x2-128 nra on naga 5)  ;

or anyone on it 129. Is the Staff aware of any other NRC proceeding in which 4

the health effects of (1) coal emissions of any kind (ii) radioactive emissions of any kind, as set forth in Table S-3, are or have been at issue?

130 If answer to 129 is affirmative, niease identify each such proceeding and state or produce a cony of each contention relating to health effects of Table S-3 emissions (i) f ron coal-fired power production (ii) 9hich are radioactive. Please state which proceeding each such contention is from.

131. Has any decision been reached on any of the contentions I identified in resnonse to 130 above? If so , please identify any document (s) containing each such decision for each such troceeding in which the contention was at issue.

132. When, if ever, does NRC idtend to issue a final document (NUPEG-0668 being a draft) concerning NDC translation 520?

133 To what extent do NRC's models of dispersion of radionuclides in the environment and their transfer to humans depend on (i) uptake studies carried out in soil daat had been baked in ovens (or otherziwise) before the experiments were done?

(ii) uptake studies carried out in soil that had been sterilized by exposure to ultraviolet light (or otherstwise) before the experiments were done?

(iii) uptake studies carried out in soild which had been previously shown to take up less, rather daan more, of radioactive materials deposited on them?

(iv) Studies involving plants grown from seed in soild exposed to continmuous doses of radoiactive material or continuous denosition there of?

(v) Studies involving full-grown plants transnlanted into soil exposed to radioactive material?

I soil(vi) Studies were. in which removed andclants analyzedin radioactive-mate-ial-contaminated after being in the soil less than (aa) a week (bb) a month?

122. Is it correct to state that none of the information asked about in' Interrogatory 3k, other than the Staff's " general knowledge cf capacity factors for PWRs',' and " data in NUREG-C '20 with respect to Westinghouse and EBASCO PWRs" was used in making Staff's 55% CF estimate in the DES for Harris?

123 If answer to 122 is other than affirmativg niease state in full all such information you used, oroviding all work paners and documents containing any such in e ormation for insnection and cocying.

1242 What is the average capacity factor of (i) Westinghouse PWRs in the US (lifetime) (ii) Westinghouse PWRS in the US large_r than 690 MWe (DER) (iii) EBASCO-built PWRS in the US (iv) EBASCO-built PWRs in the US larger daan 690 MWe (DER) (v) PW9S built by EBASCO outside the US (vi) PWRS built with Westinghous e equipment (NSSS) outside the US (vii) Westinghouse PW9S over 690 MWe (DER) built outside the US (viii) Westinghouse /EBASCO PW9S in the US over 690 MWe DER 7 125 Has NRC Staff or anyone on it calculated any of the above-asked averages (in interrogatory 124 above) (i) at any time? (ii) since 1/1/837 126. Can NRC Staff guarantee that Harris l's capacity f actor in operation will be at least 55%?

127. Will NRC take any responsibility for Harris l's canacity factor being less than 55% if it is below 55%?

128. Does NRC Staff have any documents giving its CF estimates (i) at the CP stage for Harris (ii) at the OL stage for any PWR2s?

Please identify each such document you possess.

PRODUCTION OF DOCUMENTS:

Wells Eddleman hereby requests NRC Staff to make available documents identified in resnonse to t he above interrogatories, for inspection and c onying at a time and place agreeable to me and them.