ML20082P920

Amends to Discovery Responses Re Eddleman Contentions 8F & 37B & Joint Contention II

ML20082P920
Person / Time
Site:	Harris
Issue date:	12/05/1983
From:	Eddleman W EDDLEMAN, W., JOINT INTERVENORS - SHEARON HARRIS
To:	CAROLINA POWER & LIGHT CO.
Shared Package
ML20082P913	List: ML20082P908 ML20082P920 ML20082P929
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8312090236
Download: ML20082P920 (2)

Text

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'9 es s UNITED STATES OF AMERICA ,1983 Decen e NUCLEAR REGULATORY COMMISSION

'83 EC -8 NO:23 1

)

BEFORE THE ATOMIC SAFETY AND LICENSING BOAEDr - i ,

Glenn O. Bright "' " '

" bi' Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of J Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 and 2) ) ASLBP No. 82-b6F-01

) OL Amendnents to Discovery 9esnonses re 8F(2) and 37a (by Wells Eddlenan), and re Joint Contention II (by the Joint Intervenors), re witnesses on said contentions In response to Auplicants' General Interrogatories both Wells Eddleman and the Joint Intervenors hereby supolement their responses as follows (including information 4.rcornxorated by referenc e ):

3(a). Dr. Ernest Sternglass, nosit5cn on n.1 of contennoraneous-ly filed Answere to Board Questions rc 37B and Jofrt II; v"esent address 2925 Ranble Rd. East, B1bonington IN h7h01; ennloyer Univ.

of Pittsburg; oualifications as set out on v.h of Resnonses to Boavd Questions filed by us Dec. 5 1983 and in the book refe==ed to the=e; he is an exnert witness, re 8F2, 37B (for Wells Fddlenan) and Joint II (for Joint Intervenors Kudzu Alliance, Conservat?on Council o' NC, CHANGE /ELP, and Eddleman) .

3(b) sunnary of anticinated testinony, see uni-3 of Dec. 5 Resnonses to Board Questions.

3(c)Qradiationuhysies,radiationhealtheffects,estinating health effects due to radioactive releases fron nuclear plants etc.

(ii) Dr. Stergnglass has been retained (.snecially ennloyed) to testify on these contentions b.v 18itT lt)9f4fMM Of A b., tyq4 N F/w.S 8312090236 831205 PDR ADOCK 05000400

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3(a) Dr. Carl Johnson, a medical doctor who has been necogn17ed as an exne=t in radiation health effects and testified as such befo=e the NRC (re Clinch Fiver Breeder Reactor) and in othen cases; n=esent nosition address h2 Hillside Driver, Denver, CO 80215; uresent encloyergand qualifications data not in hand yet.

3(b) Sunnary of anticinated testinony as now planned, see on h-7 of Joint Intervenors/Eddleman Desnonses to Boawd Questions, 5 Dac. '834 (i) 3(c) Health effects of radiation, including =adioactive nate=ials emitted from nuclear facilities; radioactive natevial in the e nv5 =onne nt .

(ii) Dr. Johnson has been ennloyed and snecially = eta'ned by Joint Intervenors and Wells Eddleman to testicy on Joint Content *on II, and on Eddlenan 37B and 8f(2).

NOTE: Annlicants and Staff are advised that the outlines of testinony of Drs. Sternglass, Johnson refevenced above effectively undated and revise ou" nast (WP and .T.I. ) nesponses as to what we are concevned with, 4 f agjg re the snecific contention (s) referenced in each such outline. Where additional or different concerns and beliefs are stated, each was based on the statement (s) of the witness during trenaration oc the outline; thus, the identified witness helned nrmrare our response, in prenaring the testinony outline given in our Dec 5 verannse to the 90a-d.

Joint Intervenors and Wells Eddlensn adont the outline of test'nony for Joint Intervenors' Contention II, by each witness, as an undated statement of what we believe and are conce-ned with in that content *on, to the extent it may differ fron out ureviousx resnonses. Wells Fdd?enan adonts, =e 37B and 8F(2) resnectively, each outline oc testimony given in the 9esnonse to Board Quest

• ons,of December 5,1983 likewise as an undate of his discovery res{onses on each of those content *ons to which each such outline refers Iod MP4 >WS% ra ,re u a..e .

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