ML20082S283

Corrected Page 8 to Response to Intervenor Reply to ASLB Questions Re Health Effects Contentions

ML20082S283
Person / Time
Site:	Harris
Issue date:	12/12/1983
From:	CAROLINA POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20082S271	List: ML20082S268 ML20082S283
References
NUDOCS 8312140091
Download: ML20082S283 (1)

Text

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a,

s proceeding, Dr.> Johnson testified particularly about the Staff and applicant's dose estimates; however, on cross-examination it became clear that Dr.. Johnson was " unconversant with the ,

Commission's regulations on the control of radiation emissions and the methodology for determining dose estimates." Id. at 1090. Applicants refer in their motion for summary disposition on Joint Contention II and Eddleman Contention 37B to the  !

various rejections of Dr. Johnson's work by these well-

. recognized _ scientific and legal reviewers. Without offering any basis, much.less a substantial basis, for their position, the Intervenors now baldly assert that Dr. Johnson is qualified

to testify _to a broad range of subjects, including NRC's standards for radiation exposure and NRC's radionuclide concen-tration models -- the subjects about which his expertise was substantially undermined in the Waterford proceeding.1/

, Finally, Intervenors propose to have a psychiatrist, Dr.

Morris Lipton, and a general practitioner, Dr. Barbara Wynn, i f testify about "the physical and psychic aspects of pain and I

a 1/ Dr. Johnsen also testified before a licensing board on the

- alleged under-estimation of radiological releases from the L Clinch River Breeder Reactor ("CRBR") fuel cycle facilities.

See United States Department of Energy Project Management Corp.

et al. (Clinch River Breeder Reactor Plant), LBP-83-8, 17 N.R.C. 158 (1983), stay request denied, ALAB-721, 17 N.R.C. 539

.(1983). In that proceeding, Dr. Johnson was found to have made an invalid comparison between the CRBR fuel cycle facilities

- and the Rocky Flats plutonium (weapons) production facility.

Id. at 222. The Board also concluded that Dr. Johnson "had no specific training or experience that enabled him to make such '

comparisons." Id. at 222, 265.

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