ML20079P915

Responds to NRC First Set of Interrogatories.Related Correspondence

ML20079P915
Person / Time
Site:	Harris
Issue date:	05/06/1983
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
References
82-468-01-OL, 82-468-1-OL, ASLBP-82-468-1, ISSUANCE-OL, ISSUANCES-OL, NUDOCS 8305110222
Download: ML20079P915 (19)

Text

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1 g,.g g,7 w :e  ;..NQt UNITED STATES OP AMERICA

, , May, 6, ,19U3 ,.

NUCLEAR BEGULATOEY COMMISSION '"yg S 993 3 Q O

BEFORE THE ATOMIC SAFETY AND LICENSING BOAPD ' s,, . ,%.

Glenn O. Bright Dr. James H. Carpenter 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 and 2) ) ASLBP No. 82-E66-01

) OL Wells Fddleman's Resnonse to NRC Staff Interrogatories (Firet Round)

This response is being filed under an extension of tine negotiated with NPC Staff attorney C.A. Barth.

It acuears nere officient to ansuar the general interrogetories all together at first, and then give additional specifics along t with answers on each contention.

l l RESPONSE TO GENERAL INTERROGATORIES L. Only 22 A and B, 37B, 80, and 83/8h (and cerhaps 75) allege inadequacy of analysis by Staff or Antlicants (I tresume you mean Anplicants , not Apnlicant). I am not sure if " person" includes grouns which are not cornorations. 22B, 80, and 83/8h denend on the documents referenced (or the non-existence of documents, like

<@@ the DEIS for Harris), not on persons, as evidence of the lack of So' oc analysis or deficient analysis thus far.

en g

o For 22A, I have relied on analysis by the NC Utilities Commission as oo Public Staff, Carolina Power & Light Co. : See resconse to Apelicantei US g interrogatory 22-A-2 at po 13-17 of my response to lat set (hereina'ter no mac R-A-1st); for 37B I rely on the eersons naned in the contention DS03

I and their co-authors, and others for listing of info and for additional infornaticn '(I'm not sure if that is " analysis" or not): See at up

-17,17-2P of my recoonse to Apolicants second set of interrogato-les (hereinaf ter R-A-2d) . Certain omissions re radiciodines are laid out at pp h through 17 of R-A-2d; nersons relied upon are naned in it, except as objected to re Apolicants ' General Interrogatory 2, wh6ch sane objection I nake to this interrogatory insofar as it seeks names or identification or information identifying nonwitnesses.

The Staff has shown no lack of exnertise on any such subject of Eddleman 29 or ary other of ny contentions, nor any conne111nF need for the identities of nonwitnesses. I rely on Seahrook, slin opinion 3-2h-83 Informatien revealed to the stafe uill go te Aonlicants and the nuclear industry (via PLo, etc), with the ram.e results as if the info was revealed to Anplicants or the industry (and government is not blameless in reprisals and intinidation of tnose ouestioning nuclear energy or aspects of nuclear clants' safety and econony). Thus th e sane ob j e ct ion na d e to Apol' c an t s ' interrogatory G-2 (in R-A-1st and R-A-2d) anolies and is incorporated by reference here.

2. Dr. Gofman's qualifications are set forth on the back of the dust cover of Radiation and Hunan Health, which I believe is in the NRC library ; I have no other listing of oualifications for nersons above, except for those given in rate case and other testinony before the NC Utilities Conniss' en, as f ar as I have cresently determined; and those I have not linked to the informat$on relied on, i.e. I'n not sure who prepared various sect'ons of the recorts I rely on.

3 I am not able to produce such sumnaries without substantial research and editing, which I understand is not rec.uired in resnonse to interrogatories. Gofnan's views on rediation health effects,

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for exannle, are summarized in his 853 nage book (w'th annendices, etc ), on cit above. I think the articles identified in R-A-1st and R-A-2d above can serve as summaries; since they are brief, I submit that they are such summaries, insofar as I have any available or in my possession.

4 Much of this data is identified in the footnotes to the reports (e.g. Public Staff of NCUC), articles and books relied on (see R-A-1st and R-A-2d and R-A-3d, my resnonse to the third set of interrogatories from Aunlicants, which is being filed 6 May 1983).

However, I do not nossess the f nformation as to all data, books, texts or other granhic (does this mean written?) material all thesa folks have relied on. Agnin, it would take research on my nart to get it, re I don't peseers the info, and such teardh is not reauired in i

resoonse to interrogatories. If I find other such info as I go through my extensive files (which I've committed to do for Anolicants for certain itens), I'll be glad to identify such info and nake conies available to the Staff for inspection and/or conying as mutually agreeable.

l $. Yes. You have Gofman's book, R-A-1st and R-A-2d. S'ex [A /f 4elad

6. None so far. 7, 8 see 6.

9. Other than as laid out in the original contentions, resnonses to interrogatories (R-A 1st, 2d and 3d), ne'ther I nor anyone on 7qr behalf has made any calculations or analysis to substantiate all or any part of any contention. The analysis in the documents referred to in R-A 1st, 2d and 3d was not nade on ny behalf (nersonally).

10. So far, none, for contentions - - -

.. in this set of interrogatories.11,12 see 10 and 9.

13. I answered them: Wells Eddleman, 718-A Iredell St. , Durham NC , 27705.919 -1Sa6-non-witness Where 3076 contributed information to any answer,

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I mako the sane general objection nade to Apolicants' Genaral Interrogatory 2 in B-A-1st and 2d, for the reasons cited above under Staff General Interrogatory 1, incornorating both those reasons, and those objections from the R-A 's, here by reference.

RESPOKSE TO SDECIPIC INTEPD,0 GAT 047FS l q .- ( 4 r e E :t2 b.nl 2.f

14. I need a definition of " normal full nower overation" to answe= this cuestion. Does " normal" nean that all systens function 100fs , or does it nean that the facility has not been required to derate due to any problems with radiciodines or othe- difficulties in oneration? Deficiencies I think may have this result, regardless cf the " normality" of operation, are discussed and stated at paEe8 E-17 of R-A-2d. I may analyse further and find nore eroblans, based on discovery and cther info I an acquiring or may accuire.

15. I have not asserted that CP&L Co. will intentione12v overate the Harris facility in violation of Anpendix I. They seen to be abic to commit- numerous violat5ons of thei" tech steca, KR,C

regulations, etc, yet I cannot recall a single such e"ror or violation which the company has stated or adnitted was deliberate. I an not able to assess Applicants' intent fully, but, e.g. in the Board Notification (Board Txhibit khI) of the 1979 renand heerinrs on managerent canability, they were fauted for pursuing power production goals so as to override safety and health concerns, for doing enly what is required; and the evidence in that renand (e.g. testimony of F.S. Centre 11 & his exhibits) shows they d'dn't always do what was l required pronptly or efficiently at all, e.g.16 month delay in -

installing door alarms, failure to tag problens , to fix tagged problens; further info is operation of Brunswick with 15% or more failed fuel (vs. 1% design basis), which NRC had to change the Brunswick license to put a stop to, nunerous fines and fa'lu es at Brunswick, radiation release unnonitored offsite, disnosal of

-g-low-levet radioactive wastes to local scrap dealers and sanitary landfills, a'nd so on. CP&L hasn't said any of this was intentional.

16. I don't know; I need discovery to answer. Annlicants admitted in the FSA9 (TMI-60 to 63, pages) that they could not measure radioactive iodine releases from turbine gland seals and vacuum punpas , ' due to high hunidity. High hunidity is a normal condition where the Harris plant is located.

17. See answer to 16, and R-A-2d at h to 17. More info than I have is recuired to answer.

18. I did not make this assertion. The Board did $n re-writing the contention. Again, without a definition of " normal operations" (I assume you mean cuerations) I can't answer.

19. Both I and the joint intervenors are nursuing discovery concerning this. I can't answer now in any great detail. The humidity P

problem, cited above, and the lack of detectors at many noints where radiciodines can exixt the Harris niant, are the main nroblev.s I have now identified, in addition to those in R-A-2d at h through 17.

I assume you mean radioiodines when you say " radioactive" being released into the environment. Radioactive material releases other than radiciodines are not a subject of this centention, excent i inaofar as other radioactive snecies (nmuclides ) decay into radio-iodines. On this, too, I need more information to answer, fbE[k2 h CSCug m ca gsjzig,f- T Off'W(20-21 re Eddlenan hl) f!Lin c/ tucM<> yn.Ses (t % ~), Q )

20. I am pursuing discovery of Apolicants and Staff to answer this. ine hanger QA Note that Eddlenan 41 goes to the failure of p/QC orogran and QC as an example of the failure of Applicants' QA -

t at Harris. The fact that the 95% failures in a samule of h00 hangers got aoproved in the first place, prior to NFC staff's finding a ddfective weld, shows a failure of QI/QC and a breach of f aith with

1 NRC and federal law. This ct'ts doubt on Anpi tcants ' fitness for a license to' operate Harris. The fact that Anolicants have taken corrective actions (if any) af ter they were caught in this nassive violation of QA/QC requirements is no nore relevant to this contention than is a thiefis refunding money.which he or she is accused of stealing is relevant to the cuestion of whether the theft took place.

Indeed, the taking of any corrective action, like the refund of stolen money, is an adnission of guilt, an adnission that CP&L's OA/OC was grossly inadeouate.

21. I have not inspected Harris pine hanger welds, and have not yet received discovery naterial that would enable me to answer this cuestion as of 3-18-83 (the data of the Staf e 'nte"roga tories, which is what this interrogatory asks about), except for information in the Anplicants' attachments to their interrogatories of 1-31-83, which indicates a IP'% failure rate after retraining all l their welders, on a sannie of welds taken inmediately af ter retraining, which indicates not all these welds were fixed, does not exrlain the rationale for each field change order or annroval to use a defective I

safety-related nipe hanger (but indicates that a number of such changes and annrovals have been given).

Interrogatories 22 and 23 re Eddlenan 6hF

22. Annlicants assert they will use one 17-300 cask, the design aspects of which (beyond D-A-3 and the contentf on itself in or!ginal and final form) I have not got information on and have not analyzed.

In' addition to design, the use (dry or wet) and license conditions on the cask (IF*300) can affect complianc<: with NSC reFulatory criteria. Other casks have not been identified, but may exist or be used for spent fuel transport to Harris during its onerating life.

(if it operates). I an pursuing discovery on these natters.

23. I am not sure if just part 70 is meant, or narts 70 through 75 inclusive. Assuming the forner, (1) I do not know all spen _t fuel casks to be used at Harris, and haven't got the info on CP&L's own cask yet, nor any guarantee that this (or this type, IF-300) cask will be the only one used at Harris. By "at Harris" I assune you maan "in transnort of spent fuel to or from Harris" .

Part 70 concerns Domestic Licensing of Snecial Nuclear Material, including the U-235 and plutonium present in snent ruel, I believe.

CP&L is not exempt from these regulations (70.2), but a contract carrier of the spent fuel could be (70.12); I know of no exenotion applying to CP&L under 70.1h.

I understand that CP&L, in its Harris plant license apolication, seeks a license to nossess stent fuel from other nients, at Harris (for storage). Section 70.20a provides that a licensee nust conoly with sections 70 32(a0 and (b), 70.k2, 70 52,70.55, 70.61, 70.62 and ,

70.71 as well as the restrictions of narts 30 through 35, h0,50,110 and the rest of "this part" (10 CFR, I believe).

70.20a(c) provides_ that in transport for another or storage incident to such transport, the duties of a general licensee are limited to protection of such naterial against thef t or sabotage.

l I don't think this applies to CP&L transportinE for itself, but it might be read to apply to CP&L transporting fuel co-owned by NCEMPA (spent fuel from Brunswick, e.g. ).

a 70.20(d) requires a_n approved security plan for transnortation of spent fuel. CP&L has not got such on approved plan: counsel for URC Staff stated 2-2h-83 that N9C review of the nlan was not complete.

The plant has not been shown to connly with the recuirements listed in 70.20a(d) which are fron part 73, nor with those of 70.20a(e).

With Joint Intervenors, I an seeking to qualify experts to review Applicants' plant to transport spent fuel to Harris, under part 73

. 70.20b does not apply to Applicants. 70.21(b) requ'"es a snecific anplication for other activities, which Apnlicants have nade for snent fuel at Harris. I have no information verifying that Applicants have conplied with 70.21(g) which they nust. I do not believe the citizenshin of CFhLis and NCEPTA's officers is indicated in its application (70.22(a)(1)). The technical a2alificat'ons of f.pulicants' staff (70.22(a)(6)) and description of facilities and equinnent to protect health and nininize danger to life or uroperty (ibid (a)(7))

are not in the application. The information recuired by 73 22(g) is not included in the license application, i *he requirement of 70.22(k) for scent fuel not being used in the eneration of a power reactor, referencing 73.o7(d)(e)(f) and (g) i does not appear to have been met.

Apn11 cants' application has not been anproved under 70.23 as required.

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the two-detector rule cf 70.2h for accidental criticality l

l does not anpear to be net at all points where scent fue) will be moved or held within Harris facilities. Harris emergency oroceduves do not annear to address 70.2Jh(a)(3) requirenents.

The accounting requirenents of 70 32 (c) apply to Apn1* cants 1

i for spent fuel not used in oneration of the Harris power rea ctors.

There is no information I have located that these requirenents have been met for transport of scent fuel to Harris t or at Harris.

.Section 70 37 disclains any Comnission responsibility for .

injury of danage, and gives no guarantee of safety, of the scent fuel to be shioped to Harris and stored, either in shinning on on site. The full resnonsibility for these thinFs is thus Col L's.

re 70.39, I do not know if check sources or reference sources are in the cask. I need discovery re this.

Re 70.41, CP&L's unauthorized disposal of low-level waste offsite at 3runswick, e.nd unnonitored offsite release there, indicate a cotent,ial of. violation. There is no assurance the routes of svent fuel transnort to Harris would be as licensed.

CP&L has not-6stablished connliance with 70.51 for Harris for 70.F7, 70.56 and 70.50 also fresh fuel or noent fuel; ditto for 70.53 and 70.5h as f ar cs I know.

b 70.55 recuires opportunity for inspect'on at all reasonable tides, but Board Exhibit 8 of the 50-h00 CP remand of 1Q79 (hear!ng; ordered 1978) shows CP&L impeding access to its site at Robinson; CP&L night repeat such action at Harris or re soent fuel shipments to Harris.

Part 70 does n6t renove resconsibilities under part 20 for containinE the spent fuel during and af ter shinnent.

The casks themselves would f all under these licensing reovirements, but I haven' t found requirements on the casks in Part 70 in my review in answering this interrogatory, other than as recuired for licenses 1

j and undeb 70.22, 70.2, and 70.20a which leave a13 other requirenents in effect for licenses under part 70.

Interrogatories 2h thru 27 on Eddleman 65 2h. Such voids have been found. I have not located the documents I

i I used in precaring this contention, and need then to answer in detail.

I l I an advised by NRC that such voids do exist at Harris, and have existed, but that they have been patched.

25. I am conducting discovery of Applicants and Staff to get this information. I do not know if I or consultants or persons working yith or for me will be able to insnect the Harris plant to verify such information.

26.. In addition to the informati on contained $ n R-A-1st at 32-36 and the documents referenced therein, e.g. use of concrete which is not'aoproved for nuclear installations (WoIr Cr., etc), voids (W.C.

]

- and Callaway, etc), defective testing for voids (Callaway etc ),

improper natching of voids (Callaway, etc), ir.oroner tamping, there anpear to be innroper fabrication of trumnlates, embeds at Callaway (and Harris), imnroner lay'hg of rebar, and cover-uns of construction defects (e.g. case of Willian Smart at Callaway, response of the owners and Danniel thereto, NRC press releases denying problens exist when an internal renort existed confirning many of Smart's charges -- 18 of 21 as I recall). These were done with Daniel as the main contractor or supervisor of the activities involved, particularly for the base nats and attachments thereto at Wolf Creek, Callaway, and re Farley I an nursuing discovery.

27. Unapproved concrete, The Ironworker (docunent delivered to Apnlicants for insnect'on h copying); voids, record in Callaway, Joint Intervenors Exhibits and brief and a> neal brief, news articles re Woolf Creek. Improper testing for voids, Joint intervencrs' pronosed findinEs, exhibits, annlicant and board exhibits, anneal a

brief Callway. All this is in one or more folders and I can make it available to N90 briefly (i.e. a week or so) for inspection and conying. Imoroper fabrice tion of trunnlates and e . beds, Cn11away, Joint Inte-venors proposed findirgs and othew docunents f ror. that case ( a folder I have); for Harris, I&E reports, Anolicants' responses, etc. (relying on my memory; these are not currently assembled in a place I've located yet, though I believe I still nossess conies of them or notes on then from the LPDF); Wm Snart i

case, Critical Mass Journal, Callaway record, NRC renorts, info compiled by rep Willian Clay (D-Mo. ), records of Dublic Cit!:er, records of NRC, possibly other info sources.

Interrogatories 28 through 33 on Eddlenan 75

28. In addition to corbicula sp, the barnacles and clans i.-- __ _

= _ _ _ _ _ __ .-- _ _ _ _ _ _ _ - - - _

found in Aoplicants' Brunswick plant condexnsers and RH_R syatem, iron-metabblizing bacteria, coener or nickel-metaboliri ng bacteria, barnacles, oysters, clams etc. ; genus and species not identified by 1

me for most of these.

besides the oaths described in the contention itself, 29: For any, paths may include : transnort on boats, nronellers, in fishing nets or seines or strainers from infested ocean, estuary, river, lake, sound, or reservoir environments, to Harri s lake, thence through makeup into condenser or thence by transnort of eggs, larvae or individuals into condenser water or from parking lot into plant or into cooling system (e.g. on shoes, cuffs of persons), transoort by a saboteur, transport on scientific equiement used for both ocean and Harris lake water flow investigations, being picked up on or in clothing at a beach or source of such bacteria (e.g. a hot spring, a mineral spring, river or lake sediments, a scrap yard, storage of materials at Harris, especially in the onen, and thus carried into the plant or into the Harris lake, e.g. on swimsuits, on fishing gear or eculpment, by hunters of hikers walking by the lake or wading into it or in duck blinds near it; into the auxiliary reservoir by any of the above neans or by transrort by birds or versons walking into the auxiliary reservoir watershed, frcm there to the wervice water system, RH9 and emergency makeue, and thus in the RER or the condenser by water movenent, or by direct transoort to the auxiliary reservoir the RHR or the condenser by a saboteur or a person unwittingly carrying such organisms or their eFgs, larvae, etc.

30. I have not made such a calculation. Infestation could beg!n

'n the water supply even prior to plant startup.

. When the crowth of the organisms compromises the integrity of the condenser (or RHR) or clogs flow or wares pintes or breaches the heat exchange boundary

in the RH_R or condenser, or in conjunction with normal vacuun, water or other coolant flow, or test conditions or failures (e.c. of condenser vacuun, RER flow tests and operability tests ) causes any of these conditions, the ability of the clant to safe;1y shut down w!11 be inpaired. This has occurred in other plants in as little as P years, much less than the exuected coerating life of Harris (e.F. Brunswick, Arkansas Nuclear One, etc ) .

31. Other than Brunswick, I don't know. I do not have the information readily available at nresent. ,

32. The cooling water $ntake, as I uhderstand it, was not affected at Brunswick. The condenser had to be reulaced, and the plant had to be kept shut down for extensive repair and renlacenent in the RHR systens. I do not know how long it took this to occur, but Brunswick 2 has only ouerated since 197h and Brunswick 1 since 1477, so less than 6 to 9 years for sure.

By33 I believe the ultinnte heat sink exhausts heat through the auxiliar7 reservoir or main reservcir, thence to atmosnhe~e and outer space. I have not located the place it ties into the condenser, though of course the condenser is located below the turbine. FSAD doesn't say.

9.2.5 (Ultimate Heat Sink) 3 InterroEntories h through 41 on Fddleman 80 3h. In FSAR 15.0A (Appendix), the tern A o is not defined nor a source for it given. The conttants R and L are evidently assumed, but they are not substantiated; no calculation of the lanbda (decay) constant is stated; the thyroid dose for 30 days ignores liquid-and food pathways; the chi /C factors ignore rainout, etc. per Joint Contention II; the TDCF and WDCF factors are unsubstantiated; atmoseheric conditions are unspecified, the WDCF does not include breathed gases, particulates or liquids breathed or eaten, or the food enthway. The Tech specs may linit leakage , per 15.0. A.1.?,

but they a/e no Buarantee and have 'not been substantiated.

The above and the below are all the mixing and disnersion nodels I found by consulting the Anendment 5 index to the FSAD, h-15-83 date.

For 15.7.13, I don't have Reg. Guide 1.2h and cannot answer beyond the deficiency of the chi /Q values as noted above. Here it says 5 percentile values are assumed: are these 5th nercentile from the lowest values, 5th percentile from the highest, or what?

are they 5th percentile of chi /Q or of meteorological conditions?

The analysis itself is not given, no infants o" fetal doses are computed in suite of the greater sensitivity of those to radio-iodines (and radiation in general) connared to adults; 15.7.2, 15.7.3 and 15.7.h incorporate the same assunntions, so all the above deficiencies should be included as my list of deficiencies for each of these sections. In addition, the scurce terns and pevcent release assunptions for noble gases, radio-iodines and other fission oroducts may not be covrect, leading to errors in The use of Q for aiv flow in FSAF dose estinates as modeled per 15.0A. Andt 5, 15.7.h is confusing and the

, airflow model may be inaccurate.

'yg, See above resnonse to 3h The innact of these errors cannot be quantified by me without more information and detailed study which I an not required to make in resnonse to discovery, and which I have not made.

36. It depends on its location, how it is used, and operated.

Joint Intervenors are nursuing discovery on this natter.

37. I assume you nean the limits of Apnendix I: for this to be. true, the dose nodeling must first be accurate. Then, as in response to 36 above, it depends on location, use and oneration; further, lack of radiciodine monitoring of vacuum pump and turbine gland effluents, and lack of radiciodine monitoring at other points at Harris, could allow Apnendix I limits to be exceeded, esnecially in view of rainout and inconolete mixing of releases, without detection.

. co

, -lh-l To be sure that rainout and inconnlete mixing of releases do not  ;

have these effects, nore nonitoring offsite will be recuired, but that is not "at Harris" in.the naarow view of this question. I have answered in a broader view of the ouestion.

38. See above resnonses to 36 and 37. Monitor locations and data are being sought en discovery by J.I. and by me, but have not been received or analyzed. Moreover, even adeouate nonitors would not solve the eroblems noted in 36 and 37 above, and f urther analysis and information may reveal additional difficulties.

39. Rc.inout hanpens. That is historical data, a.g. f"on the 1950s Nevada A-bonb tests. The rest of the infornation and basis above is not historical information or test information to my knowledge, h0. A partial listing is included in Joint Intervenors' Response to Apolicants' First set of interrogatories, which is scheduled to be nailed about the tine this set is due. I have not had time to list each and every deficiency in these regulatovy guides ( I presune you don't mean trivia like tynogranhical errors ),

and don' t know when I'll have enough time to do it. I think listing every such deficiency may be work beyond what is recuired in answer to interrogatories, but I am willing to make sone additional effort in this direction at the request of NRC Staff.

41. I have not laid out a model and parameters to conclude this.. I conclude it fron the f act that enough radioiodine $ s released, even at Apolicants' connutation, fron Harris (or can be) to exceed the Apnendix I linit for an infant (or fetus whose nother is) exposed to the nlume directly, via eating snow contaninated with such radiciodine, breathing or eat'ng or swallowing the spray or air or food contaminated by rainout of radiciodine from such niune, for at least one individual,

Interrogatories 42 through 49 on Eddleman 83/8h h2. No connlete listing is practical: e.g. all hydrocarbons can interact with chlorinated hydrocarbons resulting (due to chborine), chlorinated and aninated hydrocarbons resulting (with ammonia and hydrazine); organic matter of all sorts, conta' ning a host of conpounds (probably numbers never identified by chenists yet) can interact with chlorine, chloramine , etc, to form carcino-gens; heavy metals, etc. in runoff from the ulant are carcinogens and can becone even more carcinogenic in the presente of chlorine or bv interaction with it or reaction with it; amine, chloramine, and water-chlorine complexes (and conplexes including chlorine, amino or amide grouns, and water) can form with metals; chlorine forming chloromethanes front decaying organic matter is another source of carcinogens. See also response (R-A-1st at h5-h7, and h6) to Aunlicants re this, for me h3 That's even more innossiblep t o list. See above, and pages h5-52 of R-A-1st. The classes of chemicals this contentions concerns are listed in the contention, and the above including R-A-1st;

(

I have connitted to Aunlicants to do more research to list carcino-gens which can be formed by such materials (per h2 above ) and other chemicals present in Harris discharges or to be nresent in the main reservoir or reasonably exnected there. I haven't done this yet; when I do, N90 staff will be served with a cony of the $ nfornati on.

hk. These elenents are nonradioactive, so their time duration is infinite in the environment. I have not comnuted their duration in the reservoir, but nost of then will be being discharged or brought into it continually or continuously. Other than Applicants' ER and discovery info which NRC staff got a copy of, I have not quantified these elements and compounds. I have not connuted the

" duration" of compounds because without a relatively conolete nodel of lake chenistry, such a c omputation would be neaningle ss. Data based on sanoling and testing of a contarable lake would be even better, but I do not nossess this $rformatior end am not able to afford having it done, nor do I have time to do it nyself, even if I Sot the equipnent and information necessary at an affordable cost.

h5. By chemical reacti ons. I don't know what Cris cuestion asks, i.e. is it to give a general description of how chemical reactions take place, to describe the uhysics of reactions between chlorine, hydrazine, annonia, and the other chemicals identified in R-A-1s t (or described there) and cont ention 83/8h? The chenical reactions include the f ormation of ions, connounds, release fron chelation, formation of free radicain, etc. See D-A-1st at h5, also 46-h7; res,onse 83/84-h, 83/8h-7 therein.

If this question asks the mechanism of carcinogenicity of such comnounds, I an even less able to answer. Changes in DNA, enzymes, chenical radicals, catalysis, changes in cell nenbranes or nuclear membranes, changes in 9NA, " fixing" of mutations in cells, i causing nutations in cells, causing chromosomal delections or i

translocations or excisions, interaction with viruses -- there are a host of ideas about how chenical carcinogens " work".

h6. I have not conouted amounts or concentrat5 cns of carcinogens l

(in total or for each) in the Harris lake.

l h7. By eating fish, shellfish, drinking water, swallowing water (e.g. while swinning), eating anything which metabolically concentrates such carcinogens from its own intake of water or food, breathing the nore volatile of such carc'.nogens, absorbing then through cuts exoosed to water in the lake or its discharge or the Cape Fear l

below its discharge; and other such nechanisms. -I have not connuted the quantity of such intake, nor established a safe level of carcinogens.

h6.Chloromethanes, chloramine, and nossibly some other carcinogens formed in the lake can be absorbed through the skin. I an not sure of this risk from NH C1, NEC1 2 and NC1, 3 but know each of these b a hazard to swimmers; in addition, anything in the lake can be swallonwed (as a chemical) in water, inadvertently on deliberately.

Sone such concouhds, e.g. TCDD (dioxin, 2,3,7,8 tetrachloro-d-dioxin) are dangerous at the parts per quintillion level. There is a study of the NC1 , NH ' " " " hazard to swimmers that I relied on 3 2 2 in formulating this contention, but which I appear to have lost my only cony of. Intake through cuts, abrasions is also possible.

As to the accumulation of such carcinogens, basically any which are fat soluble will concentrate in the human body; others may concentrate in the liver, kidneys or blood; any able to cross the blood-brain barrier nay accunulate in the fat in nerve cells in the barain, or otherwise in the brain. I have not yet compiled a list of the authorities for this response. To the extent that such infornation was provided by nonwitness experts, I object to disclosure of the identity of such person, though book and other sources will be identified when I have then available.

49. I don't know. The rainfall, canacity factor of Harris, actual efficiency of the cooling towers (and their consumptive water use), Cape Fear flow patterns, and other information are needed to nake this calculation. The conacentration will vary t with Cape Fear flow and lake discharge patterns. While this variation would be calculable, I do not have all the infornation needed to make such a calculat'on, and believe that doing it is beyond the scope of required answers to interrogatories.

l PRODUCTION OF DOCUMENTS: Those in my possession identified l

in response to the above interrogatories (including in referenced

18 responses, I will nake available to NRC Staff fo" insnection and cooying. The others are mostly (as referenced) found in the NoC

. library, NRC records, the UNC-Chanel Hill' Health Sciences Library, the depository libraries at UNC (Wilson) and NC State Universities (Chapel Hill and Raleigh, UC, respectively). I don't have the publication dates and other info for the documents not in my nonsession, irsofar as they are not in a set of netes I took (which I will give a cocy of to NRC staff on reouest ).

If Staff counsel will contact ne, we can make arrangement for the Staff to borrow the documents I possess; I will nake the Staff a copy of anything I've given the Anplicants a cony of, and of a reasonable amount of other short documents in my possession, on recuest. I am keeping the documents resnonsive to Anulicants '

interrogatories and Staff interrogatories in file folders, so these can be referenced (if I don't nd slay them. So far the folders are complete to my knowledge).

I hereby affirn that the above resnonses are true and corr ct to my present knowledge, except as stated on information and/or belief, and I believe those parts to also be true. , ,

This 5 day of May, 1983 '

" *M" Wells Fddlenan

4 STATE OF NORTH CAROLINA COUNTY OF ORANGE Today Wells Eddleman appeared before me and affirmed that the contents of his responses to Applicants' Second set of interrogatories (4-22-83), Applicants' third set of interrogatories (5-6-83) and NRC Staff 8 s first set of Interrogatories (5-6-83) are true and correct to the bes_t of his current knowledge and are being supplemented as information becomes available, except as to those matters therein stated upon Information or belief and he believes those to be true.

hg Wells Eddleman May 6, 1983 b/W 4 k loNd Y II 55 Jd T . d@ry% NO YYav su Gu J 1h4w, 77o; '

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