ML20079R208

Response to Second Request for Production of Documents on Contentions 29 & 37B.Notice of Appearance,Certificate of Svc & Certification of Counsel Encl

ML20079R208
Person / Time
Site:	Harris
Issue date:	06/17/1983
From:	Bauser D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Eddleman W EDDLEMAN, W.
Shared Package
ML20079R205	List: ML20079R203 ML20079R208
References
ISSUANCES-OL, NUDOCS 8306220111
Download: ML20079R208 (10)

Text

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Juno 17, 1983 UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

l Plant, Units 1 and 2) )

APPLICANTS' RESPONSE TO WELLS EDDLEMAN'S REQUEST FOR PRODUCTION OF DOCUMENTS ON CONTENTIONS 29 AND 37B TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et a,1. (SECOND SET)

Applicants Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency, pursuant.to 10 C.F.R.-S 2.740b, hereby respond to Wells Eddleman's Request for Production of Documents (Second Set) on Contentions 29 and 37B to Applicants Carolina Power & Light Company, et al., by stating that the following documents identified in Applicants' Responses to Wells Eddleman's General Inter-rogatories and Interrogatories on Contentions 29C and 37B to Applicants (Second Set) 'will be made available to Mr.

Eddleman for inspection and copying:

INTERROGATORY DESCRIPTION 29-1(j) NUREG 0367, Radioactive Materials Released from Nuclear Power Plants (1976) 29-1(j) NUREG 0521, Radioactive Materials Relea' sed from Nuclear Power Plants (1977) 29-1(j) NUREG 1497, Radioactive Materials Released from Nuclear Power Plants (1978) 8306220111 830617 PDR ADOCK 05000400 G PDR

29-1(j) NUREG 2227, Radioactive Materials Released from Nuclear Power Plants- -

29-1(j) NUREG 2907, Radioactive Materials Released from Nuclear Power Plants 29-1 (p) , (r) NUREG-0017, " Calculation of Releases of 29-3 (f) , (n) Radioactive Materials in Gaseous and Liquid 29-4(o) Effluents for PWRs" 29-1(p) Regulatory Guide 1.42, Revision 1, " Interim Licensing Policy on as Low as Practicable for Gaseous Radiciodine Releases from Light-Water-Cooled Nuclear Power Reactors."

(Withdrawn March 18, 1976) 29-2 (a) , -(e) Regulatory Guide 1.23," Meteorological Programs in Support of Nuclear Power Plants" 29-2 (h) " Persistence of Precipitation at 108 Cities in the Conterminous United States," D. L.,

Jorgensen and William H. Klein, ESSA Technical Memorandum WBTM TDL 31, Systems Development Office, Environmental Science Services Administration, U.S. Department of Commerce, Silver Spring, Maryland, May 1970 29-2 (h) " Effects of Tropical Cyclone Rainfall on the Distribution of Precipitation Over the Eastern and Southern United States," G. W. Cry, ESSA State Climatologist, ESSA Professional Paper 1, Environmental Science Services Administration,-U.S. Department of Commerce, Washington, D.C., June 1967 e i

29-2 (h) " Maximum Recorded United States Point Rainfall for 5 Minutes to 24 Hours at 296 First-Order i

Stations, Technical Paper No. 2," A. H.

l Jennings, Cooperative Studies Section, l . Hydrologic Services Division, Weather Bureau, l U.S. Department of Commerce, Washington, D.C., revised 1963 l 29-2 (h) " Normal Monthly Number of Days with Precipita-

tion of 0.5, 1.0, 2.0, and 4.0 Inches or l More in the Conterminous United States, Technical Paper No. 57," J. F. Miller and R. H. Frederick, Special Studies Branch, Office of Hydrology, Weather Bureau, U.S.

Department of Commerce, Washington, D.C., 1966 l

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29-2 (h) " Maximum Station Precipitation of 1, 2, 3, .

12, and 24 Hours, Part XI: . North Carolina, Technical Paper No. 15," Division of Hydrological Services, Hydrometeorological Section, U.S. Department of Commerce, Washington, D.C., 1955 29-2(h) "Two- to Ten-Day Precipitation for Return Periods of 2 to 100 years in the Contiguious United States, Technical Paper No. 49,"

J. F. Miller, Cooperative Studies Section, Office of Hydrology, U.S. Weather Bureau, U.S. Department of Commerce, Washington, D.C., 1964 29-2(h) " Rainfall Frequency Atlas of the United States for Durations from 30 Minutes to l 24 Hours and Return Periods from 1 to 100 Years, Technical Paper No. 40," D. M.

Hershfield, Cooperative Studies Section,

, Hydrological Services Division, U.S. Weather Bureau ~, U.S. Department of Commerce, Washington, D.C., May 1961 29- 2 (h) " Maximum 24-Hour Precipitation in the United States, Technical Paper No. 16," A. H.

Jennings, Hydrometeorological Section, Hydrological Services Division, U.S. Weather

. Bureau, U.S. Department of Commerce, l Washington, D.C., January 1952 29-2(k) " Iodine Species in Reactor Effluents and in the Environment" (EPRI NP-1269) 29-3 (p) Regulatory Guide 1.109, " Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I" 29-3 (p) Regulatory Guide 1.113, " Estimating Aquatic Dispersion of Effluents From Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I" 29-6 (f) Regulatory Guide 1.143 entitled " Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants" l 37B-4 Committee on the Biological Effects of Ionizing Radiations, The Effects on Populations of Exposure to Low Levels of Ionizing Radiation:

1980, National Academy Press, Washington, D.C.,

1980 (the BEIR-III Report)

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'37B-4' Nations Scientific Committee on-the Effects of Atomic Radiation, Ionizing Radiation:

Sources and Biological Effects, 1982 Report to the General Assembly, United Nations,.

New York, 1982 (the UNSCEAR 1982 Report)

. The' requested documents will be made available at the Energy and Environmental Center, Route 1, New Hill, North i.

Carolina 27602, during CP&L business hours (or such other mutually agreeable time). Appointments to inspect the docu-ments may be arranged by telephoning Hill Carrow at 836-6839,.

at'least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the requested. inspection. Applicants

! will maintain the requested documents assembled in Carolina

. Power & Light Company offices and available for inspection by Mr. Eddleman, for a reasonable time- (i.e. , through July 18, ~ 1983), after which they will be returned to their place

! of origin.

I Inspected documents which Mr. Eddleman wishes to have copied will be reproduced by CP&L on a schedule compatible 5

l- with other. demands for duplicating equipment. A CP&L employee will be available during the inspection in order to receive any requests for copying. Copies of such docu-ments will then be furnished to Mr. Eddleman upon payment of 7 cents per page, to meet CP&L's cost of reproduction.

b . h'"t%

Thomas A. Baxter, P.C.

Deborah B. Bauser Jeffrey J. A. Gibbs SHAW, PITTMAN, POTTS & TROWBRIDGE

-- 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1215

\

Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh,. North Carolina 27602 (919) 836-6517 Counsel for Applicants Dated: June 17, 1983 I

s' 1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH' CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY ).

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

CERTIFICATION OF COUNSEL I hereby certify that I have made the following efforts to resolve Applicants' objections to certain of Wells Eddleman's j

Interrogatories (Second Set) and Requests for Production of Documents, dated April 22, 1983, on Contentions 29 and 37B.

Because of the extensive number of interrogatories filed by Mr. Eddleman and Applicants' corresponding work load in responding to these interrogatories, I was not in a position prior to today to discuss with Mr. Eddleman Applicants' objections. I have called Mr. Eddleman repeatedly today 1

and have not been able to locate him either at his home or business (school) phone number.

l l

W /a. /6.me__

Deborah B. Bauser SHAW, PITTMAN, POTTS & .tOWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 l (202) 822-1215 l

Counsel for Applicants Dated: June 17, 1983

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1

EEFORE THE ATOMIC SAFETY AND LICENSING BOARD i In the Matter of )

l )

l CAROLINA POWER & LIGHT COMPANY AND )

! NORTH CAROLINA EASTERN MUNICIPAL ) Docket No. 50-400 OL l POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Units 1 & 2) ')

NOTICE OF APPEARANCE The undersigned, being an attorney at law in good standing admitted _to practice before the courts of the District of Columbia, hereby enters his appearance as counsel on behalf of applicant Carolina Power & Light t

l Company and North Carolina Eastern Municipal Power Agency in proceedings related to the above-captioned matter.

Respectfully submitted, i

i 4 - #

j e . AY-Gib5s '

l SHAW, ITTMAN, POTTS & TROWBRIDGE

' 1800 M Street, N.W.

Washington, D.C. 20036

, (202) 922-1251 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket.Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL

MUNICIPALLPOWER AGENCY )

! )

l (Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

l CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 29 and 37B to Applicants Carolina Power &

Light Company et al. (Second Set) ," " Applicants' Response to Wells Eddleman's Request for Production of Documents on Contentions 29 and 37B to Applicants Carolina Power & Light Company, et al. (Second - Set) , " " Certification of Counsel,"

l and " Notice of Appearance of Jeffrey J. A. Gibbs" were served this 17th day of June, 1983 by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached

( Service List.

h& h. hMUL Deborah B. Bauser l

l i

UNITED STATES OF AMERICA

' NUCLEAR REGULATORY CONMISSION.

i BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400.0L and NORTH CAROLINA EASTERN ) 50-401 OL.

MUNICIPAL POWER AGENCY' )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

SERVICE LIST 4

'- John D. Runkle, Esquire

. James L. Kelley, 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 Post Office Box 12643

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' 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 (4) 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705

, Office of-Executive Legal Director U.S. Nuclear Regulatory Commission Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel

! ' Docketing and Service Section (3) Carolina Power & Light Company Office of the Secretary Post Office Box 1551 U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Washington, D.C. 20555 Dr. Phyllis Lotchin l Mr. Daniel-F. Read,. President 108 Bridle Run

' Chapel Hill Anti-Nuclear Group Effort Chapel Hill, North Carolina 27514 Post Office Box 524

! Deborah Greenblatt, Esquire Chapel Hill, North Carolina 27514

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1634 Crest Road Raleigh, North Carolina 27606

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. Service-List Page:Two Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Karen E. Long, Esquire Public Staff - NCUC Post Office Box 991 Raleigh, North Carolina 27602 i

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