ML20080Q356
| ML20080Q356 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/06/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | CAROLINA POWER & LIGHT CO. |
| References | |
| 82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8310120370 | |
| Download: ML20080Q356 (18) | |
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7 DOCKETED USNRC UNITED STATES OF AMERICA October 6, 1983 .
NUCLEAR REGULATORY COMMISSION *83 OCT 11 A10:20 CFFICE OF SECEO . .
BEFORE THE ATOMIC SAFETY AND LICENSING BOANSN! C Glenn Dr. O. Eri James H.ght 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 i and 2) ) ASLBP No. 82 468-01
} OL Wells Eddleman's Response to Applicants' Interrogatories on Contentions 15AA and 8F1 This response is filed under an extension of time negotiated with Applicants' attorney Hill Carrow who consulted Dale Hollar in doing so.
The General Interrogatories on each contention appear the same, and so consolidated answers are given for them.
RESPONSE TO GENERAL INTERROGATORIES
. 11(a): Documents used in formulating 8F1 have been located; b_O YMf**S66 % Bbl- G & Q As to 15AA, the authors of the NRC Harris DES, the compilers and suppliers of data for the NRC Gray Book (NUREG-0020), the authors of the decision in NCUC Docket E-2 sub 203 (esrtificate of public conveniance and necessity for the Shearon Harris Nuclear Power Plant), and glous CP&L officials including Wilson Morgan, J.A. Jones (now retired),
Bobby L. Montague; NRC I&E Construction officials testifying in the 1979 remand hearing on CP&L's Management Capability for Harris,
, .A. Ronald Jacobstein, Thomas Lam, and myself.
1(b): For 8F1, see above under (a). For 15AA: NRC estimate of Harris capacity factor andynglysis therefor (DES); capacity factor- '
of other nuclear power plants; similarity of Harris to Beaver Valley --
8310120370 831006 gDRADOCK05000 h
2 believe this information came originally from CP&L and I am trying to get the-transcript to find out. CP&L says it doesn't have a
! transcript of the NCUC hearing to license construction of Harris; CP&L's role in constructing the Robinson 2 plant (none- it was a 8 estinghouse turnkey project), Brunstwick plants (more substantial; X
l QA/QC failuGs in constructing Brunswick), and Harris (extensive);
j CP&L role in operating these plants and NRC comments thereons., see e.g. comments of construction inspectors (names listed in remand l hearing on Harris before NRC, 1979, ASLB at Raleigh NC) re CP&L l
l only doing what is required; similar comments by operating insnectors (see same record including Board Exhibit 8 therein) that CP&L put l
production ahead of safety, did only what was required, and tried
- to impeded inspector access to Robinson 2; record and comments and l testimony on large number of defects in the Brunswick plant and l
failure to solve these problems (see testimony of FS Cantrell and documents attached thereto, etc); analysis of Brunswick plant by A. Ronald Jacobstein and Thomas Lam for NCUC Public Staff, Dockets E-2 sub 444 and sub 461 before NC Utilities Commission -- avoidable outages, operating problems; comparison of expected and achieved capacity factors of similar plants: Beaver Valley at under 36%,
McGuire I at 38.5%, etc.
Tkken together, these facts show that (1) dbe more CP&L has nuclear been involved in building a plant, the worse it runs connared to other nuclear plants or original performance estimates; (2) canacity factors for CP&L'a only PWR are declining; (3) Harris is similar to the very worst-performing PWRS with Westinghouse nuclear steam systems; (4) none of this has been analyzed in the DES er taken into account in the cost-benefit analysis for Harris.
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2(a) OBJECTION. I have previously objected to having to identify any nonwitness expert providing such information; Applicants informed l me previously that they do not wish the identity of those who transmit information used in answering interrogatories. I stand on my objections of 8-19-83 (Applicants' Fifth Set of Interrogatories to me) and First and Second Sets, re G-2(a), and to Applicants' Fourth Set ol' Interrogatories re similar interrogatories 4-1(a) and (c), 4-2 and 4-3.
(b) See objection to (a) above; information will be identified by a pseudonym where it comes from a nonwitness expert.
3(a) and (b). No expert witnesses identified so far.
4(a) I have no page list for these documents, as to what I relied on in formulating contention 15AA; the documents and substance of what is relied on in them are identified in response to 0-1(a) above.
As to 8F1, I have . located the documents used to formulate this contention.99(b),(c), MS(k>ase. -h>and see (a) 8G-Ireferen)es
~ G4 therein.
c l 5(a) To the extent such documents can be located without an 4
extensive search, they are identified in response to interrogatories herein. (b) Identification will be in, or referenced in, specific
' responses.
6(a) Such will be identified in response to the interrogatories, excepting identification of persons objected to above re 2(a). (b) see (a) and see 5(b) above.
l i 7(a) None so far. (b) page citations, if known, will be trovided.
RESPONSES ON T 5-AA 15AA-1(a). I allege that assuming Harris will operate at $5%
capacity factor for NEPA purposes is too high a number to use, particularly if DER rating of the plant is used. The capacity factor for NEPA purposes, to which I assume you refer, is a lifetime cavacity factor. Obviously, the capacity factor of Harris could be above 55%
for a given period of time (e.g. a few minutes) whenever it operates l . . _ .
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above 55% power (DER), if ifcandoso. Such a situation would not necessarily make the lifetime CF above 55% DER. Obviously, at this point no one knows what capacity factor the Harris plant, if licensed to operate, would actually achieve over its useful lifetime, nor does anyone know its useful lifetime if it were allowed to operate. These things would have to be determined by what actually hanpens if Harris were licensed to operate. As to estimates, see response toIXa) below.
There is no assurance Harris will operate at 55% CP or above.
(b) See (a) above; see also CP&L's sales contract with NCF7PA, for portion of Harris 1 and 2 (and 3 and 4, etc), wherein no performance guarantee is found.
(c) Not anplicable.
2(a) NRC Staff should have used a conservative estimate, e.g.
the performance of the worst similar plant. Beaver Valley I, identified in Pinding 6, p.18 of the NCUC 2-29-72 Ordsr approving construction of Harris (NCUC Docket E-2 sub 203) I believe is that plant, with 35.8% lifetime capacity ractor os of 12-31-82. Similarities between Harris and non-Westinghouse plants, e.g. B&W units, should also be considered.
(b) CP&L's Robinson 2 unit , as of 5-31-83, had a DER canacity factor of 63 0%; CP&L played no role in constructing this plant, but has been its sole operator; the PWR lifetime average is about 61%;
the NERC (Equipment Availability Report, 1972-81, publ 6/83, of which I do: - not have a copy) ten year average MDC gross (roughly comoarable to l DER net) capacity factor is 62 7%. Thus, Robinson 2 performs better than the PWR average. (The Gray Book PWR lifetime average is about 61%).
Robinson 2 is the best-performing PWR of 700 MWe or higher design rating in the US, in terms of capacity factor over its lifetime so far; larger reactors tend to have lower capacity factors (see Gray Book and analysis by Dt. Lavon Page of NCSU and myself in NCUC Dockets E-100 sub h0
-5 and sub 46; this also owes something to past analyses by David D. Comey and Charles Komanoff, though these are not used directly here).
Robinson 2's capacity factor is higher for 2 reasons (1) the low site stringency (strictness cof NRC license and operating requirements --
the lowest in Region II according to Board Exhibit 8 of 50-400 remand hearing in 1979), and (2) CP&L management's placing production ahead of safety, as commented on by inspectors in the sane Board Exhibit.
Since Robinson 2 is only a bit above the national PWR average in capacity factor, but has less regulatory restrictions on it and arguably a management committed to production first, safety not being decisive. This suma up to the Robinson plant, which CP&L played no part in building, being about average for a PWR in the US. It is about average size (700 Mwe), and is performing just under the best-fit line for Westinghouse PWRs that Dr. Page and I derived. 700 Mwe would correspond to 63.5% CF, all other things being equal, in that analysis. See Table N*CP*83 in Supplemental Testimony of Welle Eddleman in Docket E-100 sub 46 (1983).
Now contrast that with the Brunswick plants, which CP&L played a much greate? role in c onstructing (see 1979 NRC Docket 50-k00 remand, testimony of J.A. Jones of CP&L). The national BWR average capacity factor (MDC Gross, roughly comparable to DER net) from NERC's 1972-81 equipment availability report is 60.0 percent. The Brunswick units are the worst-performing BWRs in America, with lifetime capacity factors (DER) of 45.3 and 41.9 percent respectively (h7.0 and 43.5% MDC net).
(Source is NUREG-0020 Vol 7 #6, June '83, data as of 5-31-83; I do not possess a copy of this). That is, Brunswick performs at only about 2/3 to 3/k of the average BWR capacity factor. (Of course, the average already includes several years' operation of both Brunswick units. If Brunswick were excluded from the average, their performance would be l
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even further below average. The performance of the Brunswick plants other is significantly worse than any BWRs with salt-water cooling or 4
- Brackish water cooling.
Where Robinson is about average for a PWR, Brunswick is the worst for BWRs in capacity factor. The difference can be attributed to CP&L's involvement in constructing Brunswick, and to added NRC require-ments for safety at Brunswick, and to CP&L's mismanagement of the Brunswick plant in construction and operation. The difference puts Brunswick about 15 points below average for a BWR.
CP&L's involvement in constructing Harris is far greater than CP&L's involvement in constructing Brunswick. Ani: . , 1 extrapo1& tion of the variation of CP&L plant capacity factors from national averages as CP&L involvement in construction of the plant changes from zero (Robinson 2) to substantial (Brunswick) to very extensive (Harris) would indicate Harris could fall 30 or more points below the national PWR average (capacity factor of about 30 percent).
Since it is likely NRC will limit backfits of existing nuclear plants (it has proposed rule changes and law changes to this effect), Harris, as an uncompleted plant, will likely be subject to stricter regulatory requirements than existing plants. This will tend j to depress the Harris capacity factor.
Another check, which I have used successfully as a conservative estimator for other plants, is to find a comparable plant and look at l adtual performance. Beaver Valley has a lifetime capacity factor of 37.4% (5-31-83) and is similar in design to Harris (NCUC Docket E-2 sub 203 Order of 2-29-72, p.18, finding 6).
Harris also has unreIolsved steam generator problems that could depress its operating capacity factor. McGuire 1, oro jected by Duke Power Co. to have an early capacity factor of 60% (65% lifetime)
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when put into commercial operation, actua11 achieved 38.5% through the end of 1982.
Taken together, these estimates suggest that a Harris capacity factor in the 30 to 40 percent range is quite nossible. A conservative estimate of Harris operating capacity factor is therefore 30 to 40 nercent on a DER basis.
Another check is to take the "all other things equal" figure of 58.1 percent for a Westinghouse PWR of 900 MWe (Page and Eddleman, E-190 sub 46 NCUC case,1983) and correct for steam generators, added regulation, and CP&L construction involvement. That would suggest a capacity factor in the 25 to 35 percent range, figuring a 30% drop for CP&L involvement (Robinson-Brunswick extrapolated) and a few percent off for later-corrected steam generator problems and for regulation constr. involvement at the low end (58% minue 30% minus 3% is 25%), and a CP&Ljfactor of minus 15% (conservative) with larger impacts from regulation and steam generator problems which might prove intractable or result later in operation (as at Robinson and other PWRs), giving a 20-25%
subtraction from the 58% "other things equal", or 35% as the high range.
(c) Estimation is set forth above. I have conies cf the computer analysis Dr. Page and I did; it's best-fit by least squares to the NUREG-0020 lifetime CF data with minor adjustments (for refueling l and to exclude atypical reactors under 400 MWe) as shown in testimony filed in NCUC Dockets E-100 sub 40 and sub 46. CP&L was served with this testimony.
(d) I have been recognized as an expert in energy systems and energy conservation before the NCUC repeatedly; qualifications are given in testimony and appendices, most of which CP&L has been served with. I have estimated capacity factor in operation, e.g. in NCUC Dockets E-7 sub 289 and sub 314 (Duke Power dropned its 70% claim for McGuire in sub 289 to the 65% I Droposed there; I don't suggest
they did so because of my estimate -- see W.S. Lee direct and supplemental '
testimony in Docket E-7 sub 314 for Duke Power -- but it does show that the power company adjusted its estimates as I'd suggested.
I have also addressed capacity factor in other cases, and am able to estimate it from design, maintenance, repair and performance data. I know of no specific " qualifications to assess capacity factor" which are recognized by any regulatory or other agency, except the qualifications of training, experience and knowledge. The critical benefit factor, I believe, is judgment -- when making NEPA gostimates one should be conservative, and neither CP&L's nor NRC Staff's judgments i
of Harris capacity factor ars sufficiently conservative. Overoptimistic benefit estimates lead to erroneous cost-benefit conclusions.
One of the most obvious of these is the determination that l
Harris was cost-effective versus coal. Sherwood Smith, President, Chairman and CEO of CP&L, admitted that if Harris were started over, l
it would be a coal-fired plant (Raleigh News & Observer, pp 1D and 7D, 9 May 1982). I have successfully made consersative estimates of capacity factor and other technical matters related to power production l
I and use (e.g. future peak loads and sales) in the past, and so far have avoided creating billion-dollar (or more) mistakes, in contrast to NRC Staff and CP&L.
l 15-AA-3(a) World survey not complete; for Us, see 2(b) above.
1 (b) see 2(b) above; I have not looked up odder annual capacity factors in detail, but Bsaver Valley's is 36 percent for 1982, while McGuire 1 is about 40 percent for 12 months ending 8-31-83 (c) Bad design, construction problems, onamerating problems, l steam generator design fer McGuire 1, etc. are reasons I understand apply.
I have not determined "all reasons" for such poor performance and l
doubt that anyone can make this determination.
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(d) For Beaver Valley -- cited similarity to Harris. I believe this information came from CP&L originally and am seeking the NCUC E-2 sub 203 transcript to verify this belief. For McGuire, steam generator design problems. For both -- being Westinghouse PWRs.
15 .AA-4(a) thru (d): See 3(a) above. I understaand Krsko and Ringhals3 had some very poor early capacity factors.
15-AA-5(a) McGuire #1 was declared commercial by Duke Power Co.
at 0000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> on December 1,1981.
(b) Thirteen months.
(c) Of necessity, it is partly predictive. Months since the "fix" very have not (per data yet known to me) shownpaignificant improvement above the 40% C.F. level. The performance of the "' fixed" steam generators, and of the plant, is not fully known yet. '
(d) It shows the effect steam generator problems can have on capacity factor. This will be predictive (to some extent) of Harris C.F. as Harris steam generator problems exist. McGuire is the first Westinghouse plant with model D steam generators to go into commercial operation in the US.
(e) The lifetime CF is the average of all performance ofer a unit 's whole life. The average over any time period is eart of that grand average and necessarily partly predictive of it. Performanc e of plants with defemmetive steam generators (e.g. McGuire) can be predictive of performance of plants (e.g. Harris) which also have 1
) defectively designed steam generators. It is obvious that the performance of steam generators, if inadequate or unsafe, affects PWR capacity factor by reducing it. The performance of McGuire before the 1983 steam generator "fix" is indicative of the effect such problems can have on capacity factor. Similarly designed plants (Harris and McGuire and Beaver Valley are all Westi nghouse PWRs )
would be expected to have similar performance, other factors being equal. The performance of McGuire 1 is thus (to 12-31-82 and prior to the SG "fix" of 1983) useful in predicting nerformance of other plants, and thus to that extent "uredictive". It is not determinative of other plants' performance, which cannot be guaranteed.
(a) 15-AA-6 4 The Design Electrical Rating of the Harris units, 900 MWe.
(b) The MDC (" Maximum Denendable Capacity") of the olant will be less than or equal to the DER in virtually all cases. Exnerience with nuclear plants in the Carolinas and Virginia indicates that MDC ranges 3 to about 6 percent (2 to 4 percentage points on CF) below the DER. Since MDC is likely to be under the DEN for Harris, a 55% MDC CF f or Harris would be somewhat more reasonable as a conservative lifetime capacity factor (CF) estimate, than is 55% DER. That is what the quoted words mean. For reasons why this is still too high, observe that if MDC is 6% less than DER (hynothetically)
$$% is the same as 51.5% DER as a measure of capacity factor.
But, as shown under 2( ) above, that's not conservative enough: the c onservative range would be 30 to 40% or perhaps somewhat less, as shown there.
l 15-AA -7. The Design Electrical Rating is the designed tiet
, electrical output of the plant. This will-be less than the generator capability (whether corrected for power factor or not), and less than the thermal rating of the reactor (or steam output of the NSSS) when l
l adjusted for the thermal efficiency of the plant.
This is a commonly accepted definition. See NUREG-0020 definitions.
To my knowledge, CP&L has never disputed this definition or that 900 MWe is the DER of Harris.
15-AA-8. 900 Megawatts electric (MWe). See 7 and 6(a) above.
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15-AA-9. Maximum Dependable Capacity (MDC) is the outuut that can be indefinitely maintained (or almost indefinitely) Waen the thermal generating unit is limited by warm coolant (thus lowering its mbility to reject heat). MDC is a standard definition (see NUMEG-0020), though the use of MDC capacity factors by NRC appears to be a way to overstate the actual performance of nuclear plants subtly, thus reducing the nuclear industry's embarrassment at the less-than-oredicted nerformance of its nuclear plants. MDC net, as NRC's NUREG-0020 definitions section notes, is obtained by taking the gross dependable outout of the plant under adverso thermal cooling conditions, and subtracting off the normal station service (electrical) loads, giving a net output.
15-AA-10. I understand the MDC of Harris has not been determined.
For comparison, the MDC of Robinson 2 is 665 MW (700 DER), of Brunswick MDC is 790 (821 DER), of Oconee 860 MW (887 DER), of Noath Anna 1 865 MWe (recently uprated to 877) vs 900 MW DER, of North Anna 2, 890 MDC l versus 900 DER. The uprated MDC of North Anna 1 was determined by l
actual unit performance as I understand it.
l 15-AA -11. Obvious from the answers. Harris doesn't have an l
established MDC in performance yet, and MDC is almost always less than DER for PWRs in this part of the country (similar summer weather for l coolant).
15-AA-12(a). It doesn't matter if the Capacity Factor is MDC l
or DER so long as the output of the plant (lifetime or annual average) is conservatively determined. I contend the Staff $5% DER CF is See 2.758 petition of too There high forare no net NEPA benefits ( o ' see use.,4 Harr s) ogeration.
ove. 6.30,83; WE testinony in NCUC Dkt L100 sub 46.
l 15*AA-13 (a ) . Like CP&L (see response to my interrogatory 75 re contention 15, p.8 of 9-16-83 response) (see also response re l 22-B-1(i), pp 15 and 17 of their 4-28-83 response), I have not analyzed ,
the impact of specific future regulations in such detail as this asks.
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NRC has continued to issue new requirements and regulations and it is likely, even if nothing else changes, that such will continue to a issue. Moreover, both proposed changes in the law (HR 2511/ S 893; HR 2512 / S 89h, both of 1983) and rulemakings pronosed, make it possible for existing plants to escape regulation and repairs that would be applied to plants (e.g. Harris ) still under construction.
Of course, a significant nuclear accident could occur any time and would likely lead to further regulatory requirements (as did TMI-2) and possibly to long term plant shutdowns or chase-outs. In my view, rule changes adopted by the Nuclear Regulatory Commission in the last 3 years, and the attitude of NRC officials, tend to increase that possibility. (Such a minset was criticized by the Kemeny and Rogovin inquiries, but it appears to be very much in daarge at NRC these days).
(b) See (a) and cited references; no such detailed analysis was made, but CP&L's 9-16 response to my interrogatory 39 re constention 15 (ibid, p.8) indicates that a 10% CF drop (estimated) resulted from operating experience pluss added regulations. CP&L maintains that operating experience gives no reason for a further drop (dubious
'in my view), but this answer supports the view that something up to 10 reduc tion percentage points on C.F. could be caused by increased regulation.
I have adopted a more conservative view here (see 2(b) above) that the drop will be from a few (2-3) to maybe 4 or 5 points.
PRODUCTION OF DOCUNENTS o fi15-AA k : I believe CP&L nossesses all of the above-referenced documents that I posses 3, with the possible exception of Duke Power case testimony, which I will produce upon request at a mutually convenient time and place. fFl cbcumoAs beQ RESPONSES on 8F1 h
G-2(c) and (d) arc identical to those objected to in my response to Applicants' Fourth Set of interrogatories (8/83).
I adopt and renew the same objections dhere cited, here.
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8F1-1(a ) . I do not " contend" this in that it's not part of my contention. I understand that Applicants have misinterpreted a response to a similar question re Eddleman 83/84. I believe it is true that the standards are inadequate to protect public health and safety, e.g. in that they do not now address fine particulates or l most carcinogens (including carcinogenic coal particulates). But this is not a " contention" and I do not " contend" it.
(b) See (a) above.
(c) Compliance with these standards does not show protection of the public health and safety. Even if it did, it does not show that the health effects of coal pollutants att forth in Table S-sn3 of 10 CPR 51.20 have been adequately assessed by NRC Staff. I need discovery of the staff (which has been pending since 8-31-83) to dstail their analysis (if any) but there appears to be none in the DES.
Since this NEPA analysis is EFh at the contention 8F1 is about, there is no inconsistency.
8F1-2(a). See 8F1-1(a) above: this is not " contended". It is true that as presently administered, this structure is NOT protecting the health and safety of the public. Death rates as high as 1 in 50 for armsenic emissions, and 1 in 1000 (per human lifetime) for radon emissions have reportedly been proposed by EPA Administrator j Ruckelshaus, for example.
(b) Not applicable, see (a) above. At any rate, I don't
, have time to research all these studies or even dig out all the ones I possess, as they aren't filed that way in general.
(c) See '8F1-c, above.
8F1-3(a). Emissions from a hypothetical plant cannot, logically, violate an actual standard. Perhaps you can rephrase your question so that it makes sense. Emissions of particulates in the amount ner h5MWe
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given in Table S-3, from a (say) 720-MW plant (16 times as much), would likely violate ambient air quality standards for particulates if the location of such a plant had typical other particulate loadings in its air. See submissions by Duke Power Co. and CP&L in NC Environmental Management Commission rulemaking on coal particulate emissions of 1982-83 (b) Answer is not affirmative; the question makes no sense.
(c) The question is irrelevant to the contention. Why should a hypothetical plant be able to violate a real air quality standard?
l I know of no air quality standards for hypothetical nower nlants.
l As shown above, the whole question of standards is irrelevant to a factual determination of actual expected health effects from the effluents in Table S-3 from coal-fired power p& ants. See responses to 8F1-1(a) and (c), 8F1-2(a).
8F1-14.. I do not have the materials used to formulateg8F1 located. I believe this statement has been made by, among others,
! the General Electric Comoany (" Energy Facts") and the Atomic
- Industrial Fornum.
l 8F1-5(a)The accuracy of the Table S-3 values is irrelevant to the contention. These values are established by rule, and 10 CPR 2.758 no contention is allowed to challenge an NFC rule (excent via ; 0 netitio l
petition. Therefore I do not " contend" anything about the accuracy l
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of the release values given in Table S-3 re coal pollutants, which is the subject of this contention.
(b),(c) Not Applicable. See 5(a) above.
8F1-6: Cancer, intestinal disorders, increased incidences and severity of respiratory diseases of most types, premature deaths l
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due to respiratory disease and worsened effects or resnirktory diseases (as well as due to cancer and other causes); irritation of eyes, mucous membranes; see documents listed in 8F1; see also the book Resnirable Particles by Perera and Ahmed (Ballinger,1979) e.g. at 31-kh (esp 40-kh),
50-53,55-56,56-57,57-59,59-63,66-69,71,71 -74; see also 84 (food chain effects); see also Health Effects of Air Pollution, report of the American Thoracic Society, Medical Section of American Lung Assn, Carx1,. Shy, ;M.D. , Chair,1978, particularly at 13-22,27-29, and30-h0.
See also references cited in the above-cited or listed works.
The indices of the above-cited works detail what is covered where; the above pages discuss health effects. Intestinal absorption effects are included in EHP Vol 33 (1979); data on existence / transport
, of various harmful substances identified in documents listed / cited above is in the Atmosphere-Bionsphere Interactions (Nat'l Research Council, 1981, David W. Schindler, Chair -- sen author list, p. iii).
t 8F1-7(a): See listing in contention 8F1, 6-20-83; I OBJECT to making an extensive search of what I may possess that isn't filed under coal pollution cases, but from that, the information and sourcers 1
cited above were found.
(b) I have received all of these studies.
8F1-8. OBIECTION. I don't have to identify such person (s) l under the Board's 5-27-83 Order. By Applicants' response to my interrogatory G-5, they have information and expertise available l to them on the subject of this contention and have no need, thus, under 10 CPR 2.740, for the identity of any such expert (s).
8F1-9: AH-AQ-79-1, " Variance" for CP&L and Duke Power boilers coal-fired him*= in North Carolina re particulate emissions:
Intervenor, cross-examined, argued and proposed findings; Rulemaking, NC Environmental Management Comnission, 1982-83, commenter, reviewed data, proposed rules, subnitted health effects data for record.
T
I have not to my present recollection, directly participated in any other proceedings, although organizations I am a member of or contributor to, e.g. Natural Resources Defense Council, Sierra Club Legal Defense Fund, etc, have participated in many I think, It is burdensome, and probably irrelevant, to list these.
I have made comments on health effects of coal emissions in testimony to the Utilities Commission, in debates and public forums, and so on, but I have no listing of these and no ready way to find the information.
OBJECTION: To making an extensive search (burdensome) for the information covered generally in the above two paragraphs.
8F1-10(a) Yes.
> (b) 10 CPR 51.20(e) says they may be included; NEPA requires that costs and benefits be balanced. If radiological health effects of these emissions are litigable, nonradiological henith effects logically must be too. (c) Not Applicabic.
I I BF1-11: Holdren et al, ERG 79-3, Risk of Renewable Energy Sources: A critique of the Inhaber Report; AECB-1119 (Ihhaber Renort) --
discreditedt endorsement withdrawn by Atomic Energy Control Board of Canada; I believe there are many others, including some work by Wolf Hafele et al at the IIASA in Europe.
OBJECTION: To researching what studies on this exist. The above are all I readily recall and/or can lay my hands on. I have a copy only of Holdren et al. Applicants got it with my 2.758 petition.
8F1-12: See 11, 6 and 7 above. OBJECTION: To searching. Burdensome.
8F1-13 OBJECTION: Except for coal emissions health effects of such effluents are irrelevant to contention 8F1. Coal emissions information is listed above, see 8F1-12 and citations therein.
I am not obligated to do research work for ADplicants; it would be burdensome even if not irrelevant.
PRODUCTION OF DOCUMENTS cited above will be done on request; see p.12 END
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l UNITED STATES OF AMERICA NUCLEAR BEGULATORY COMMISSION 6 October 1983 BEFORE THE A'ICMIC SAFETY AND LICD! SING BOARD Glenn Dr. O. Bri James H.ghtCarpenter 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 i and 2) J ASLBP No. 82 MB-01
) OL CERTIFICATE OF NEGOTIATIONS Most of the objections made 20/6 have been made previouslyg re these October 6 responses I discussed my objection to an extensive document search for coal pollution information (including heelth effects) today with Hill Carrow. Ku agreement was reached. Applicants ' counsel Hollar was not available when I called for him, nor at later times the afternoon of 10/6.
l I agreed to either mail these responses tonight or l
hand-serve them on Applicants ' counsel Hollar and Carrow tomorrow (10/7);
1
- this was accepted by Hill Carromw.
I certify the above is true.
6 October 1983 wells Eddleman l
l l
UNITED STATES OF AMERICA NUCLTAR REGULATORY COMMISSION Dockets 50-400 In the Instter of CAROLIKA POWER 4: LIGHT Co. Et al. J) and 50leh01 0.L.
Shearon Harris Nuclear Power Plant. Units 1 and 2 CEBTIFICATEOF SERVICE we I hereby certify that copies of WEE Reseonses to AnnHeants ,
Interrogatories on 15-A^ and 8Fl; 6ertificate of negotiations ,
thereon _
- HAVE been served this 6 day of October 1983 _, by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are parked with t
envvsn, an asterisk, for whom service was acconplitthed by n=* nwal and==
only Judge Ke11ev and CA Barth for Bonvd and Mtaff-
- Judges James Kelley, Glenn bright and Ja$*s Carpenter (1 egy each)
Atomic Safety and Licensing Board US Nuclear Megulatory Commission Washington DC 2o555 George F. Trowbridge (attorney for Applicants)
- E.uthanne G. Miller Shaw, Pittman, Potts & Trowbridge ASLB Panel i 1800 M St. NW USNRC Washington DC 25 5 $
! Washington, DC 20036 ,
!
- Office of the Executive Legal Director Phyllis Lotchin, Ph.D.
Attn Deckets 50-400Ao10.L. 105 Bridle Run USNRC Chanel Hill BC 2751h Washir.ston DC 2o555 Dan Read Docketing and Service Section[3d CEA?XR'/FLP Attn Dockets 50-400/h01 o.L. sox 524 i Office of the Secretary Chapel Hill NC 2751h ,
USNBC elaanington DC 2o555 nohert eruber, axee. Dir.
Public Staff,.4ox 991 John Runkle Raleigh, RC'27602 ,
CCNC ~
307 Granville Rd
- aradley W. Jones Chapel Hill Nc 2751h USNRC Region II Travi a Fayne 101 Marietta St.
Edelstein & Payne Atlanta GA 30303 Mox 12601 Raleigh NC 27605 Certified by h Richard Wilson, M.D.
729 Hunter St.
Apex NC 275o2 I
1
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