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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] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20217F7711999-10-17017 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 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 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 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 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 ML20204E8591999-03-17017 March 1999 Notice of Change of Address.* Counsel Gives Notice as of 990329 of Mailing & e-mail Address That Will Change as Listed ML20209A8631987-01-29029 January 1987 Second Suppl to Licensee Response to Cash/Eddleman Show Cause Petition.* Forwards 870128 Affidavit of JW Mckay,Which Amends Previous Affidavit,Filed W/Original Response,To Make Minor Correction ML20207M0501987-01-0606 January 1987 Suppl to Licensee Response to Cash/Eddleman Show Cause Petition.* Certificate of Svc Encl ML20214R6261986-09-19019 September 1986 Notice of Change of Address for Shaw,Pittman,Potts & Trowbridge,Effective 860927.Certificate of Svc & Svc List Encl.Related Correspondence ML20207H8281986-07-21021 July 1986 Notice of Appeal & Request for Review of Aslab 860711 Memorandum & Order Denying 860609 Motion to Stay Immediate Effectiveness & Petition to Intervene & Motion for Extension of Time to File Brief ML20206P7081986-06-23023 June 1986 Resolution by Raleigh Merchants Bureau,Inc Supporting Util Efforts to Obtain License to Operate Plant at Earliest Date Possible.Served on 860630 ML20211D8791986-06-0909 June 1986 Comments on Immediate Effective Review of Final Licensing Board Decision Urging Review of Issues Raised on Appeal of Partial Initial Decisions on Environ,Mgt & Safety Matters & Final Decision on Drug Abuse & Emergency Planning ML20199E7241986-06-0606 June 1986 Discusses Secret Witness Inability to Obtain Ofc of Investigations Rept on Harassment Allegations.Witness Should Be Allowed Copy of Rept to Review.Certificate of Svc Encl ML20211D7601986-06-0606 June 1986 Rept Per ASLB Order on Harassment Allegations Re Secret Witness.Witness Unable to Obtain Ofc of Investigation Rept on Secret Witness Allegations.Served on 860609 ML20197K2041986-05-16016 May 1986 Memorandum for Parties Discussing Runkle Ability to File Timely Reply to Contention WB-4 Responses by 860526.Eddleman Not in Position to Reply for Runkle on Good Cause for Late Filing Issue.Served on 860519 ML20197J9621986-05-13013 May 1986 Response Opposing Reopening of Record to Accept late-filed Contention WB-4 Proferred by W Eddleman & Conservation Council of North Carolina Re Systematic Falsification of Radiation Exposure Records.Certificate of Svc Encl ML20204A4961986-05-0808 May 1986 Notice of Appeal from ASLB Final Decision Served on 860428. Certificate of Svc Encl ML20204A4091986-05-0808 May 1986 Comments Re Immediate Effectiveness Issue.Application of 10CFR2.764(f)(2)(i) Criteria Does Not Warrant Withholding of Immediate Effectiveness of Board Decision.Certificate of Svc Encl ML20197C2641986-05-0808 May 1986 Comments on Immediate Effectiveness Issue.Issue Which Intervenors Placed in Controversy in Proceeding Carefully Examined by Aslb.Requests Opportunity to Be Heard If Commission Entertains Issuance of Stay.W/Certificate of Svc ML20204A4641986-05-0707 May 1986 Notice of Appeal of ASLB 860428 Final Decision LBP-86-11.All Matters in Proceeding Unresolved,Particularly late-filed Contention Alleging Falsification of Dosage Records. Certificate of Svc Encl ML20154L2401986-03-0101 March 1986 Notice of Change of Address for Svc of Documents in Proceeding Effective on 860301 ML20205K5271986-02-24024 February 1986 Supplemental Brief Re Contentions 16,17 & 18 on Adequacy of Water Sampling Procedures at Various Sample Points. Certificate of Svc Encl ML20205K5931986-02-24024 February 1986 Response to Aslab 860205 Question Re Conservation Council of North Carolina Contentions 16,17 & 18 on Util Environ Monitoring Program.Doctrine of Collateral Estoppel Bars Litigation of Contentions ML20151Y7991986-02-10010 February 1986 Memorandum Addressing Objections to Chairman 860110 Order Re Ex Parte Communication.Administrative Procedure Act Provision Requires That Miriello Be Treated as Ex Parte Communication.Served on 860212 ML20137P0331986-01-30030 January 1986 Supplemental Brief Responding to Questions Re Ocean Dumping, Per Appeal Board 860109 Order.Intervenor Claims Right to Hearing to Request Prohibition on Ocean Dumping of Facility Radwaste ML20140D1821986-01-21021 January 1986 Exceptions & Objections to 860110 Order Re Ex Parte Communication.P Mirello Expressed Intent to Keep Confidential.Neither Branch of Ex Parte Communication Test Reached.W/Certificate of Svc ML20140C5981986-01-21021 January 1986 Exceptions & Objections to 860110 Order & P Miriello Served on Parties to Proceeding.Svc of Ltr on Applicant Allows Opportunity to Destroy Incriminating Evidence Re Allegations in Ltr.Certificate of Svc Encl ML20141F8551986-01-0606 January 1986 Notice of 860205 Oral Argument on Appeals of Conservation Council of North Carolina & W Eddleman from ASLB 850820 Partial Initial Decision in Bethesda,Md.Served on 860107 ML20136F6251986-01-0202 January 1986 Proposed Corrections to Page 9,650 of Transcript of 851105 Evidentiary Hearing ML20151P2081985-12-30030 December 1985 Response to ASLB 851209 Order Re Arrangements for Medical Svcs for Contaminated,Injured Individuals.Eddleman Contention 57-C-7 Remains Dismissed Due to Lack of Requisite Specificity to Be Litigable.Certificate of Svc Encl ML20138R2521985-12-27027 December 1985 Memorandum Re Denial of Subpoenas for Intervenor Witnesses. ASLB Fails to See How Single Nonexpert Witness Residing in Emergency Planning Zone Can Contribute to Resolution of Issues.Served on 851230 ML20138R0921985-12-23023 December 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20137L9681985-11-26026 November 1985 Identifies Various Exhibits Which Applicant,Nrc & FEMA Have Agreed May Be Admitted to Record & Exhibits Not Agreed to ML20138L3441985-10-25025 October 1985 Certifies Svc of Encl RG Black & CS Wingo & Oversize Drawing Entitled Revised 60 Dbc Coverage within Emergency Plan Zone of Shearon Harris Nuclear Power Plant, on 851025.Related Correspondence ML20138B3901985-10-10010 October 1985 Notice of Evidentiary Hearing on Eddleman Contention 57-C-3 on 851104 in Raleigh,Nc & Second Hearing on Conservation Council of North Carolina Contention WB-3 on 851102.Served on 851011 ML20133B0761985-09-30030 September 1985 Requests Extension of Time to File Brief in Appeal of 850828 Partial Initial Decision on Some Safety Matters. Granted for Aslab on 851001.Certificate of Svc Encl ML20133B2091985-09-30030 September 1985 Request for Extension of Time to File Brief in Appeal of 850828 Partial Initial Decision on Some Safety Matters. Request Based on Stated Facts ML20134M0821985-08-31031 August 1985 Notice of Appeal from 850820 Partial Initial Decisions on Safety Contentions,Including Partial Initial Decision & ASLB Orders Granting Summary Disposition & Excluding Safety Contentions from Litigation.Certificate of Svc Encl ML20134Q2411985-08-30030 August 1985 Notice of Change of Address for Svc of All Documents. W/Certificate of Svc.Related Correspondence ML20134H1961985-08-23023 August 1985 Comments on Board 850805 Request for NRC Views Re Impairment of NRC Ability to Obtain Safety Info If Eddleman 850619 FOIA Request Granted.Certificate of Svc Encl ML20133B4121985-08-0505 August 1985 Request for NRC Views Re Guild 850619 FOIA Request for Documents About Safety Concerns of Employees at Facility & Applicants Objections to Disclosure.Response to Listed Questions Due by 850823.Served on 850805 ML20126K9891985-07-29029 July 1985 Notice of 850828 Oral Argument in Bethesda,Md Re Appeal of Conservation Council of North Carolina & W Eddleman from ASLB 850220 Partial Initial Decision.Served on 850729 ML20127N3251985-05-20020 May 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20108F4081985-03-0505 March 1985 Notice of Appeal of ASLB 850220 Partial Initial Decision on Environ Contentions,All Other Orders & Rulings,Granting of Summary Disposition of Various Contentions & Denial of W Eddleman 10CFR2.758 Petition.Certificate of Svc Encl ML20107G2011985-02-21021 February 1985 Notice of W Eddleman Submittal of Ee Utley,Ma Mcduffie, HR Banks,Jm Johnson,A Fuller & Re Lumsden 850227 Depositions in Raleigh,Nc Re Eddleman Contention 41-G.Certificate of Svc Encl.Related Correspondence ML20101T0121985-02-0101 February 1985 Applicant Notice of Intention to Take Deposition of C Van Vo on 850226 in Raleigh,Nc.Certificate of Svc Encl.Related Correspondence ML20112J8371985-01-14014 January 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20101F0261984-12-21021 December 1984 Comments on Cv Vo/Util Settlement Including Dept of Labor Claim of Inability to Substantiate Cv Vo Allegations. Certificate of Svc Encl ML20093D9361984-10-0808 October 1984 Notice of Intent to Pursue Negotiations & Motion to Compel Discovery Against FEMA on 840928 Responses.Related Correspondence ML20093D6561984-10-0808 October 1984 Memorandum of Law in Support of Motions for Summary Disposition of Eddleman Emergency Planning Contentions 144 & 154 1999-07-16
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1 000KETED UNITED STATES OF AMERICA UE Decembe" 5, 1983 NUCLEAR BEGULATOBY COMMISSION 83 [F,-8 E0 :23 n
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD. '
F=
Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of J Dockets 50 400 OL CAB 0 LINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )
Units 1 and 2) ) ASLBP No. 82-L6F-01
) OL Joint Intervenors'and Wells Eddlenan's Resnonse to Board Questions re Health Effects Contentions By order dated 11-23-83, Docketed 11-25 93 and served 11-28-83 the Board ordered the Joint Interveno-s and Wells Eddlenan to (1) identify excent witnesses we nrorose to call re Joint Contention II and Eddleman Contention 373, describing in detail what issues those witnesses would address; and (2) to state which of the seven "nost critical disputes" listed on page 11 (LIST OF MATTFDS IN DISDU'E L
ON JOINT CONTENTION II) of our 10-28-83 response will be the subject of exnert testinony. We have identified the following exneat i
i witness list and address each ouestion for each such witness.
A.I, JOINT INTEn7EDORS will nresent Jr. Ernest Ste=nglass, Professor Eneritum of Radiological Physics, Dent of Radiology, School of Medicine, Unive=sity of Pittsburg, who will testify concerning itens (a)(3) (need to use a sunralinear resnonse nodel for radiation health effects, including higher health effects when a radiation dose is distributed over a lonF neriod); (b) (internal emitter hazards insufficiently considered, including eefects on the fetus, fetal thyroid, young children, and young children's thyroids 8312090231 831205 PDR ADOCK 05000400
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i and studies and evidence for underestination (by NRC Staff, E?IW et al)
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J of the health and genetic effects of alnha, beta and neutron radiation r
on DNA, cell membranes, and enzyne activity); (c)lthat the tine L
period used by Apolicants and Staff to 6stinate health effects
)
from oueration of the Harris clant'(100-1000 years) is too sho-t, connared to the neriod the enitted radionuclides (e.F. in the cases of C-lh, nlutonium and other transuranics, etc) will be doing damage; (d) his own studies of observed increases in cance" 9ortality rates in the vicinity of nuclear facilities; (e) the natte"s stated on Joint II part (e) for errors in Aunlicants ' radionuclide concentration nodels: rainout of radionuclides, or hot sports; "ad'. onucli d es absorbed in o- attached to fly ash fron coal nlants; inconnlete mixing and dispersion of radionuclides. Dr. Ste nglass will address (or rive"s) the novenent of radionuclides from the air to the ground gand thence into water supulies (by runoff, etc ) fo= cities near the Ha="is nlant, e.g. Lillington, also, under this part of his testinony.(f) Dr.
Sternglass may also address the use of less chenically reactive, rather than more chemically reactive, forns of radionuclides used in NSC nodeling of radiation dose delivered, and the radionuclides ignored in such modeling. On each of the above-cited issues, D".
Sternglass informs us he will testify in sunnort of Joint Intevvenors' nosition, reviewing recent literature, his own studies, and other l data in the process. Due to lack of time to nrenare a nove detailed outline of his cronosed testinony, we submit the above now. Dr.
Sternglass will be able to n= ovide testimony for nrefiling by 10 j January 198h on the above issues excent for any that a"e dronned by agreenent between him and the Joint Intervenors.
2.0f the seven "nost critical discutes", Dr. Sternglass is presently anticinated to cover #'s 1, 2, 3, 4, and 6; possibly 5 and 7 also.
i
B.1.Dr. Sternglass has also agreed to testify for Wells Fddlenan
. contention 37B he will, concerning contentions 37B and 8F(2). On as nresently anxticinated, testify in sunnort of the work of Brose and Berte11 (and review other sunnorting studies) as to the (a ) visk of other diseases, allergies and causes of death besides cance", due to exnosure to low-level radiation; (b) on the basis of his studies and review of the literature on such health effects, suonowt the contention that the estimates of numbe"s of victims of such diseases (besides cancer) are none accurate than those of BEI9, Annlicants, or NRC Staff; (c) testify in sunnort of the contentf on as to pain and suffering of victims of radiation-caused diseases, includine cance",
that such nain and suffering should be taken into account in striking the cost-benefit balance for Harris overation. Due to the snort notice provided in this Order, no more detailed statenent of Dr. Sternglass' uronosed testinony for Wells Eddleman on 37B is available at this tine.
An undate will be filed, if reauested by the Boa"d, when nove information is available. Dr. Sternglass inforns Wells Eddleman that testimony on contention 373 can be available for fil!nr Jan.10,198h.
- 2. Dr. Sternglass is now anticinated to a_dd-ess evitical issues 3,4 and 6 and nossibly #2 also, re Eddlenan 373.
C. For the Board's infornation (and to undate Eddlenan's discovery resnonses on witnesses), Dr. Ste"nglass has also agreed to -testify for Wells Eddleman on Content $on 8F(2) and as can have his testimony available for urefiling January 10, 198h - now antic? pated.
This testinony will sunnort parts (1), (11)&(111), and (iv) of the contention, based on Dr. Stergnglass's work and review of the literatuwe including narticularly NRC Translation 520 re na*ts (ii) and (iii),
as now anticinated. It is exnected that critical Issues 1,2,3,h,5 and 6 will be addressed concerning contentien 8?(2).
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Dr. Sternglass 's pres'ent nosition is stated on naFe 1 above.
Some of his qualifications are given in his book, Secret Fallout, which Wells Eddleman possesses a cony of. Dr. Sternglass has testified as an nert witness be 're the Joint Committee on Atonic Energy (JCAE) of the US Congress, in legal cases including Hoticker V. Hendrie, and benfore Atonic Safety and Licensing Bohads in the Beaver Valley and Davis-Besse cases. The Beaver Vallev plant was one of those cited by the NC Utilities Connission (based on information suunlied by CP&L, the Shearon Ha*ris Annlicants )
as similar to Harris, when CP&L rexceived its Certificate of Public Convenience and Necessity for Harris from the NCUC, 2-29-1972 (si c ) .
See iten 6 of said case's Order granting _ certificate, Docket E-2 sub 203 Other than N90 Translation $20, the Bross and Berte11 nanews, the Mancuso-Stewart-Kneale studies, and the work of Gofnan nreviously identified to Annlicants on discovery, we do not know what documents Dr. Sternglass will rely on in his testinony; when we obtain such a list from him (or W.E. does re 8F2 or 37B), Annlicants and NMC Staff will be mailed a copy.
D. Dr. Caral Johnson has been retained by Joint Intervenons and Wells Eddlenan to testify on Joint Contention II and Fddlenan 37B.
(Dr. Johnson will also testify on 8F(2) for Eddlenan as now planned.)
1.Concerning 37B, Dr. Johnson will testify that BEIS-I (1972) estinated that a greater uronortion of neonle would su'fer "non-snecific health effects" fron ionizing radiation, e.g. prenature againg, heart disease, and lower resistance to disease (etc), than wnuld Fet cancer. He will sunnort this position by analysis and other studies.2.This testimony will address critical disnutes k and 6, and nossibly 3 E.1. Concerning Joint Contention II, on iten (d) of that contention, Dr. Johnson will testify that recent studies at/around the Windscale plant in England, which includes nuclear reactors and
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plutonium and uranium processing, show an excess of deaths fron leukenia and cancer; that this finding of excess was confirned by Dr. Edward Radford (head of BEIR-III); that the Windscale studies suonort Dr. Johnson's own studies around the Rocky Flats nlant in Colorado over the nast 9 years; that radioactive veleases from the Oyster Creek n-plant in New Jersey nose an unaccentable danger to the nublic health. Dr. Johnson nay also nresent fu*ther analysis and information f rom his own work and that of others in suonoat of these positions; plans for his testinony are cur ently inconnlete.
Concerning Joint Contention II part (b), Dr. Johnson will testify of the Contention in suonort of this section in detail, relying on his own vecent studies and other studies, including the facts that nentunf un emitted fron Harris decays into Plutonium, with a biological clearxing time of 200 years; that alnha particle emission inside a cell gives (Der alrha pa"ticle) 100 rad to the cell nucidus ; and facts sunnortine the higher risks fron internal radiation enitte=s.
1st naragranh and Concerning Joint Contention IIguart (a), Dr. Johnson will testify that the basis of KDC and DOE radiation exnosure estinates around nuclear nlarts urz is inadeauate and wrong; that studies of rddiation in the environment and around the San Onofre nlant are wrong and inadequate; that when the gestational age o c the fetus at the time of the TMI-2 accident qis accounted for, there is an excess of fetal deaths around Three Mile Island (based on Johnson's own published wovk, and the agreement of the head of the inouiry into fetal deaths at TMI); that the current NRC standards for radiation exp_osure to the public are not adeountely protective, and are inconsistent with (higher exnosu*e allowed than) etc EPA standards for radionuclides such as tritiun, ectinides, and uranium, Concerning Joint II part (c ), Dr. Johnson will testify that after transuranic radionuclides enitted from Harris decay,(once),
they produce decay products that are still radioactive; that there ave
I substantial decay chaings cf this tyne, e.F. the one beginning with nrincinally Np-239 released fron Harris, decaying to Pu-239, then by alrha emission to U-235, and from there by various decay cha ns which have radioactive material in them for thousands of yea *s un to the range of hundreds of thousands of yeaws; that anewic$ un isotones released from Harris will begin similar decay chains; that the hazard from such decay chains lasts far longer than the 100 to 1000 years over which NFC Staff considered health effects *or Henvis emisstens.
Concerning Joint Contention II part (e ) Dr. Johnson will testify that half of the usual industrial exhaust niune reaches the gvound ,
and that direct exnosure to the n1ume fron Harris is not an accentable hazard to the nublic; that the ionization of the ainstwean including radionuclides released fron Harris (ionized by the decayinc nuclides themselves) reduces the effniciency of filters used to renove these radionuclides fron the Harris releases to the atmosnhere; that the=e are other reasons why the exhaust filters on Harvis are inefficient.
Dr. Johnson's renort oublished by the Royal Swedish AcadenEy ve filters d'O NC Nebrning Joint Contention II nart (f), Dr. Johnson w?ll testify that a recent Journal of the American Medical Association article detailing exnosure of Marshall Islanders to the same nadionuclides emitted fron Harris showed that they received about 8 tines greater exnosure from Ioidine-133 and -135 than from Iodine-131; that the=e are hundreds (about 500) of radionuclides of concern that are emitted from nuclear n1 ants; that decay nroducts of certain Harris emissions (e.g. Xe-133, NP-239) are even move hazardous than the nuclides originally enitted.
Dr. Johnson's testinony outline is currently inconnlete, but the nresent nlant for it is given above. It is subject to nossible revision; if any revision is made the Board will be advised.
- 2. Dr. Johnson's testinony as now nianned will address c*itical discutes #-6,3, and nossibly 4 and 5 F. Dr. Johnson is anticipated to testify in sunnoat of content *en This testinony is anticinated to address 8F(2) of Wells Eddleman.
critical issue 6 and perhans 3, h and 5 also; it is anticipated to include or rely on the test'.nony on Joint II (c) outlined above, re time neriod of concern for health effects. It is also anticinated to address the 11 nlutoniun isotones of concern in the ruclear fuel cycle.
(}( Wells Eddleman and Joint Intervenors are seeking additional witnesses, at least one of whom had not connitted to testify by the deadline for mailing this response. Such witnesses will be named and the Board questions answered for each as soon as uractical, in amendments to this response.
H. Dr. Morris Lipton, a psychiatrist, will testify for Wells Eddlenan on the pain and suffering aspect of 37B. He will . testify that as a psychiatrist, he knows a lot about pain and treats pecole for it; that the pain and suffering undergone by victins of cancer and other diseases is very real; he will deal with the uhysical and psychic aspects of pain and suffering; all this as presently planned.
Dr. Lipton is Professor of Psychiatry and Directow of the Biiogical Sciences Research Center at UNC School of Medicine, Chanel Hill, NC.
(--W.E).
I do I.not now possess a statement of his further cualifications.W. krbara Wynn, Luarinburg, NC, will testify for Wells Eddlenan, also on the pain and suffering issue. Dr. Wynn has experience with people of all ages dying, including persons dying of cancer, and will testify in detail about the pain and suffering to the individuals and their families in the process of dying fron cancer. No more detailed outline of her planned testinony is presently available.; curriculun vitae to follow later.
J. Testinony on pain and suffering from genetic disease, suffering of peonle in genetic counaeling and uregnancy where genetic disease is possible or detected, is being actively sought. END
UNITED STATES OF AMERICA NUCLTAR REGUIATORY C0!! MISSION J Dockets 50-400 '
In the matter of CAROLIEA POWER k LIGtiT CO. Et al. ) and 50kh01 0.L.
Shearon Harris Nuclear Power Plant, Units 1 and 2 CEICIFICATEOF SERVICE 70/ 6
' Ef' I hereby certify that copies l
of G~f k N a p n[ N N4 gny3ysg5 W b c ? 'd ] 'S ft Wwm2rM 4L *D a CCV H2A % I?DEP>iocer m or us Ma., ecy oc )gijg HAVE been served this b day of 34%hber 1983, by deposit in the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose nanes are marked with an asterisk, for whom service was acconplished by Judges James Kelley, Glenn Bright and Janas Carpenter (1 copy each)
Atomic Safety and Licensirt Board US Nuclear Regulatory Comission Washirston DC 20555 George F. Trowbridge. (attorney for Applicants) R uthanne G. Miller Shaw, Pittman, Potts & Trowbridge 1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2C65 5 Office of the Executive Legal Director Phv111s Lotchin, Ph.D.
Attn Docke ts 50-400/k010.L. 103 Bridle Run USNRC Chanel Hill NC 2751h Washington DC 20555 Dan Read Docketing and Service Section (3x) CFA!ET/FLP l
l Attn Docke ts 50-kOO/hC1 0.L. Malaigh,$707 NC Waveross 27606 Office of the Secretary Dr. Linda W. Little a neton DC 20555 Governor's Waste Mgt. Bd.
513 Albenarle B1dg J hn RurAle 325 N. Salisbu W St.
Raleigh, NC 27611. ,
4 Granville Rd Bradley W. Jones Chapel Hill Nc 2751h USNRC Region II Robert Gruber 101 Marietta St.
'Travi s Payne Exec. Director Edelstein & Payne Public Staff Atlanta GA 30303 Blox 12607 Box 991 l
Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D. Certified by w 729 Hunter St.
Apex NC 27502 l-l