ML20024E858

General Interrogatories & Interrogatories on Contentions 8F1 & 8F2,fifth Set.Certificate of Svc Encl

ML20024E858
Person / Time
Site:	Harris
Issue date:	08/31/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
Shared Package
ML20024E830	List: ML20024E829 ML20024E832 ML20024E834 ML20024E840 ML20024E846 ML20024E850 ML20024E853 ML20024E856 ML20024E858 ML20024E862
References
ISSUANCES-OL, NUDOCS 8309070142
Download: ML20024E858 (14)

Text

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2 DOCMETED UNITED STATES OF AMERICA USNRC NUCIEAR REGULATORY COMMISSION g

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BWORE THE A'ICMIC SAFETY AND LICENSINk1bAddfSkN[

i w2M Glenn O. Bright j

Dr. James H. Carper.ter James L. Kelley, Chairman In the Matter of J

Dockets 50 400 OL CAB 0 LINA POWER AND LIGHT CO. et al.

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50.401 OL (Shearon Harris Nuclear Power Plant, l

Units 1 armi 2) i

)

Wells Eddleman's General knterrogatories 6pd 14

%W to Aeolicants Carolina Power & Light et al.

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(Fifth set)

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F}f-U J 3-}0-f34 Under 10 CPR 2.7h0, 2.7k1 and the Board's 9-22 82. Memorandum 6) and OrderIWells Eddleman recuestG Applicants to answer separately and fully in writing, under oath or affirnation, each of the following interrogatories, and to produce a permit insoection and conying of the original" or best copy of all document's ider.tified in resoonse to interrogatories a-set forth below.

These interrogatories are intended to be continuing in nature, l

and I recueet each answer to be cromotly supplemented o* amended as accrocriate unde" 10 CFR 9.714 (e), should CP4L, NCFMPA,.any othe" d

or any contractor or consultant to any, some or all cf those, Apolicant,por any emnleyee of any or some or all of them, or any individual acting on behalf of any or some of all of them, obtain l

or create any new or differing information resoonsive to these (whMt,4"Them" ref eas to the preceding listing (s ))The reauest for Droduct general interrogatorieg.4 is also cont $nuing and reouests Applicants to eroduce'eromotiv if not inmediately any additional documents the Applicants and others acting on their behalf or emoloyed by them, as lis'ted in the previous B309070142 830831 PDR ADOCK 05000400 0

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( ) for nroducticn sentenco, cbtain which ora rcsp:nsivo to tho ranu?ct s of documents below.

Where identification of a document is reouested, clease briefly l

t describe the document (e.g. book, notebook, letter, memo, renor,

ide the notes, transcript, minutes, test data, log, etc. ) and prov document name, title, number, following information as annlicable:

ddressee, author (s), date of writing or of nublication or both, a h

date annroved, by whom annroved, and the name and address o document, and name and addvess versens haing nonmal custody of tha V

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?no of any verson other than the preceding having actual possess o When identifying documents in resnonse to these the document.

tions interroEstories and reouests, please state the nortion or nor

) uron which of the document (e.g. sections, chafrs, tages, lines

/

sive Applicants rely or which Ap{licants swear or affirm is are res to the applicable interrogatory or weouest.

DEFINITIONS herein:

" Harris", " Harris Plant", "SENPP", or " plant" whene not specifie all mean the Shearon Harris Muelear Power Plant.

otherwise,

" Applicants" means all of the persons, emuloyees, co h

contractors and corporations as listed in the first sentence of t e second paraEraph on page 1 of this document, above.

Secort.

"FSAR" means the Harris Final Safety Analysis "ER" menns the Harris Environmental Fenort.

t "Documen$" means all writings and records nf ever7

yee, including electronic and emuter records, in the possessien, co licarts' or custody of Aplicants or any individual (s) act!ng on A vetorts, books, memorande, behalf, including, but not limited to:

hlets, leaflets, magazines,

corresnondence, notes, minutes,pa7 it articles, surveys, maps, bulletins,photogranhs, speeches,transcrps,

1 3

veico recordingo, ccm7ut3r print:uts, infcrmation stcred in coyutcro or connuter peripheral devices such as disks, drums, etc., voice recordinEs, microfilm, microfiche and all other writings or scordings of any kind (s); and cooies of any of the preceding even though the oriE nal(s) are not in the possession of Applicants or in their i

custody or control.

Document (s) shall be deemed to be within the any control of Aplicants or individual's) acting on their behalf the document (s) if they have ownership, ossession, or custody of f

or a co{y thereof, or have the right to secure the document (s) of a cop thereof, from any person or public or private entit7 having ph7sical possessf.on thereof.

Each definiti.on given above a plies within all other definitions 66ME/Ull

/afTEg3R066T$M above.

G1 (a) Vhich contentiens of Wells Eddleman do Applicants agree are now admitted in this croceeding, N*C Dockets 50-h00/h010.L.?

(b) for each such contentien, provide for any answers to interrog-stories by Wells Eddleman which Aeolicants have previously or cresently received (except those suspended by Board order, if any), the following information:

i (c) Please state the name, present or last known address, and oresent

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or last known emoloyer of each person whom Aeolicants believe or know each such (1) has first-hand knowledge of the facts alleged in answer; or. (2) uton whon Applicants relied (

other than their attorneys) in making such answer.

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(d) elease identify all facts concerning which each such cerson idanHfied in resnonso to G1(c)(1) above has first-hand knowledge.

(e) olease identify all facts and/or documentsuponwhicheach nerson identified in response to G1(c)(2) above relied in protiding informationtorespondtotheinterrogatory,includingtheparts i

of such documents relied uoon.

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v fehtA V (f) Please identify any other document (o) es?dh A licants in responding to the interrogatory.

(g) Please state which specific fact each docunent, identified in resnonse to G1(s) and GI,(f) above, aunports, in the oninion er belief of Annlicants, or which Aunlicants allege such document supports.

(b) Please state specifically what information each norson identified in resnonse to G1(c)(1) or G1(c)(2) above trovided to If any or for Anplicants' affiant in answering the intenogatory.

of this information is rot docunented, visase identify it as "undocunented" in resnonding to this sect'.on of General InterreFato7 i

G1.

G2.a)*1 ease state the name, present or last known address, title (if any), and cresent or last known employer, and econonic interest (shareholder, bondholder, contractor, emeloyee, etc. ) if or other any (beyond exnert witness fees) such verson holds in Applicants or exnect or an7 of them, for. esich nerson you intend to cell es an. expert j

witness or a witness in this proceeding, if such informetion has not vrevicusly been supnlied, or has changed since such information wss last sunplied, to Wells Eddlenan.

This applies to Eddlenen by Anvlicants.

t culated and Joint Contentions as admitted (b). Please identify each cdnteEtfon rega i

such person is expected to testify.

Please state when you first contacted each such nerson (c) with regard to the possibility of such verson's testifying for Apolicants, if you have contacted such norson.

Please state the subject Matter, separately for each (d) contention as to which each such person is expected to test?fy, t

whicheachsuchpersonisexpectedtotestifyto.

Please identify all docunents or narts thereof unon (e) which each such witness is expected to, Dlans to, or will rely, in testifying or in preparing testimony.

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5 03(a) Please identify any other sou*ce(s) of information which Applicants have used to resoond to any interrogatory identified under 01 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifying where in such source that information is to be found.

(b) Please identify any other source @of information not orev5cusly identified upon which any witness identified under G2 above, or or exhibits

(

otherwitness,hasusedinurenaringtestinen7',orexnectstouse in testimony or exhibits, identifying for each such source the witness who is er.nected to use it, and the nart or part(s) of st:ch (if applicable) which are expected to be used, etnd, if not so urce (or both) creviously stated, the f act(s) or subject matter to which such l

source relates.

and which I

Gl4(a) please identify all documents,gpages or sections thereof Aplicants intard or expect to use in cross-exanination of any witness I call in this hearing.

For each such witness, clease orovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Aeolicants believe they relate to, and nake the document (s) availabite for insoectionforpt intent and copying as soon as nossible after A licants decide orj niard i

I to use such document in cross-examination.

(b) please identify any undocumented information Applicants intend to use in cross-exanination of each such witness for m.

f G5 (a) for each contention Apolicants state or admit is an admitted Eddleman contention under G1(a) above, or an admitted l

joint intervenor contention, clease state whether Auplicants have available to them experts, and information, on the subject matter of the contention.

(b) If the answer to (a) above is other than affirmative, state whether Aeolicants exoect to be able to obtain exoertise in the subject matter, and information on it, and if not, why not.

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G-6(a) for each document identified in resnonse to any interrogatory herein, or referenced in response to any interrogatory herein, please supply all the following information which has not already been.supolied:

(1) date of the document (ii) title or identification of docunent (iii) all authors of the document, o-the author (iv) all qualifications (professional, technical) of each author of the document of the document, (v) the specific parts, sections or pages, if any, unon which Aonlicants rely (vi) the specific information each nart, section or rage identified in resnonse to (v) above contains.

the docunent, (vii) identify all documents used in orecarinF to the extent known (and also to the extent not identified in the docunent itself)

(viii) state whether Aeplicants possess a co y of the doc ument (ix) state all expert oriniors contained in the document, upon which Apolicants rely, or identify each such opinion.

(x) identify the contention (s) with resnect to which An,1? cants rely upon (a) the expert ooinions (b) the facts identified utkh-tax in the docunent (xi) state whether Apnlicants now ennloy any author (s) identifying each such person for each docunent.

of the document, (xii) st' ate whether Auplicants have ever emuloyed any identifying each such nerson for each authdis) of the document, document.

sources of data used in the document.

(xiii) identify all Answers to all the above may be tabulated or grouted for efficiency.

G-7(c) Picoco id:ntify c.t1 d:cumento which Applicents plcn, exoset er o intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which (i) is included in your current resnonse to G1(a), or (ii) is the subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is exnected to be offered.

(b) Please identify all documents which Anplicants nian, expect or intend to use in cross-exanination of any other parties' witnesses or joint intervenor witness in this proceeding, with respect to (i) Eddlenan contentions identified under G-7(a)(i) (or G1-(e ))

above, or any other Eddleman contention which is the subject of 4.nter-rogatories in this set; (ii) each Joint contention now adnitted in this proceeding; (iii) per our agreenent of h-8-83, each contention

(

of each other party to this proceeding which is cu=rently admitted.

Please identify for each such document the witnesses, or witness, and all contentions with resoect to whom (or which) that document is planned, expected, or intended to be offered or used.

(c) Please identify which of the documents identided in resnonse l

(1)

(b) above will be offeved into evidence by Anolicants, and (iil to which of the same documents Aunlicants expect to offer into evidence or intend to offer as evidence or exhibits in this oroceeding.

08 (a) Please identify, for each Eddlenan contention which is l

the subject of this or an earlier set of interrogatories, all inforna-l tion not previously identified which was (i) used or relied on in preparation of Auplicants' resnonses to that contentien and all I

contentions superseded by it (ver transcrint of July 1982 soecial prehearing conference, the Board's Sentember 1982 order adn'tttinF r otWrt0150 contentions, or stipulation by Applicants or W.E ), with respect to

)

any facte alleged therein, identifying for each such fact the specific source (s) of information used or relied upon.

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_ _ fQ[pf 0-8(b) Please identify all persons who supplied infcrmation valiod cn er used in Applicants' response to each contention for which information a

is requested in G -8(a) above. (ii) Please identify for each such person what information was supplied, and with respect to which conten-each iten of tion (s) thma information supplied uns used. (iii) Please state all known qualieications of each such nerson with respect to the subject matter of the maahantina each contention for which that person supolied information.

G-9(a)Please identify all information not identified in resnonse to the above general interrogatories, including all documents, which Applicants rely on or ftend to use in making their case or carrying with respect (i) their burden of proof in this proceeding, to each Eddleman contentien which is the subject of this or an earlier set of Eddleman interrogatories to Annlicants; (ii) with resnect to the Bnard's each joint contention on which discovery is now open unden March 1983 order, or on which discovery has been open under said order establishing a discovery schedule.

(The phrase "or on which discovery has been open" is intended to keep this interrogatory current and continuing for information and documents which Anplicants rely on or fovm intent to use after the formal close of discovery.

l I interpret Apolicants' continuing interrogatories to annly continuously from their 'date of subnission to me, and I intend these to apply Odblvff 59dCh (IJWf MS he(Ct),

l G-10(a )

Where the above general interrogatories, or any of then, 1

l call for identification of docunents, (i) and no documents are identified, is that the sane as Apnlicants stating that there l

are no Jocuments resnonsive to this general interrogatory, in each l

case where no documents are identified?

(ii) and documents a,re identified, is that the sane as Anplicants stating that the identified gMdi>M m. x% e -

?

. documents are the only ones presently known which are responsive to the interrogatoriest (iii)

If you answer to G-10(a)(ii).is other than affirmative, please state all reasons for your answer.

(iv) If your answer to G-10(a)(1) above is other than affirmative, please state all reasons for your answer.

(b)

Where any interrogatory, general or specific, herein, calls-for factual information (i) and an opinion is stated in response, is that the exnert opinion of any person (s) identified as having

-contributed information to that responce? (ii) and facts are given or identified (or a fact is) in resnonse, but no documents are identified, does that mean Applicants have no documents containing such fact (s)?

i (iii) If your answer to (i) above is affirmative, please state for each each such response all qualifications of

. expert unon whom Applicants rely for each such answer.

The qualifications need be stated only once for each such person if they are clearly referenced in other answers. (iv) if your answer to (i) above is other daan affirmative, please state which oninions, if any, E ven in response to interrogatories (general or snecific) herein l

is the opinion of an expert, identify each expert whose opinion you used in resnonse to each interrogatory, and state in full the qual"rinctions of each such expert.

(v)

If your answer to (1) other than affirmative, please identify all opinions st.to 6f non-experts used in your resnonses, and identify each non-expert whose opinion is included in each answer herein.

(vi) If your response to (ii) above is other than affirmative, please identify each document which conta*ns a fact not previously documented in your resnonse(s), statinF what the fact "is, and at what page, place, chapter or other specific part the docunent contains such fact.

9 G-11 For each answer to each interrogatory herein (cr any subpart or part thereof), please identify each iten of information in possession of Applicants (including facts, opinions of experts, and docunents ) which (a) contradicts the answer you made, (1) t i

l in whole (ii) in part (please identify each such part for each iten of information identified); (b) casts doubt on your answer (1) in whole (ii) in part (please identify each such nart for each iten of information identified). (c) Please identify all docunents not already identified in resnonse to narts (a) and (b) above (and their subparts) which contains any iten of informatf en l

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asked fer in (a) or (b) above.

Please identify fo* each euch document what infcrmation iten(s) it contains and what answer (s) each such iten is related to.

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. mand The first W will include w se INTERROGATTRIES ON EDEJMAN 15AA :

None are here.

agreed to be M from January 198,3 and others to fonow.

INTERROGATORIES ON 8 F 1:

• 8n-1 (a) mat do Applicants believe are h health effects of the coal emissions given in Table S-37 FLEASE state them in detail and explain the basis of your belief, identifying an doctaments, expert op4Mann and other information you rely on.

(b) Have Applicants (i) made any stu# (ii) had made for then av study (iii) participated in av study (iv) received av studies, of the health effects of coal-fired power plant emissions?

(c) For each part of (b) above for which your answer is affirmative, please identify each such stub, its authors, title, date 4nd all documents containir4 it, (d) Are Applicants aware of av other studies of the health effects of coal ponution for Wich they do not possess a copy of the study?

(e) If answer to (d) is affirmative, please identify each such study and give as complete a citation of it as you have (e.g. name, author (s),

title, date, publisher, source, to commissioned it or sponsored it).

(f) Do Applicants have anyone working for them (1) as an employee (ii) as a consultant (iii) in a v other capacity, whom they believe is an sxpert u the health effects of coal-fired power plant emissions (such as given in Table S-3)?

(g) Please identify each such person for which your answer to av part of (f) above is affirmative, giving name, address, phone, title, and professional qualifications if known (h) Have Applicants participated in other proceedings in which the health effects of ooal ponution were at issue, i.e. the health effects I

of emissions from coal-fired power palants?

(j) If answer to (h) is affirmative, please identify each such proceeding t

in dich Applicants or av(of then (E.g. CP&L) presented av (1) sta of positAon (ii) evidence iii) submissions for the record (iv) expert testimog (v) expert witness, on the subject of health effects of coal pollution as def.ned in this contention, or as you define then.

(k) Please identify each document, statement, witness, ite. of evidence and testimov subitted in each proceeding identified in response to (j) above.

88n-2(a) Do Applicants believe the health effects of the coal-fired power phant emissions given in Table S-3 of 10 CFR 51.29 are proper to include in the NEPA cost-benefit balance for the Harris plantf (b)uPEMat giV6 & M1 explanation of your answer to (a)'above and fully cite av authority on dich you rely for it.

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UNITED STATES oF AMERICA NUCLEkR REGULATORY CoMMISSIoM In the matter of GAROLIKA FUWam & LIGHT CD. It al. )

Dockets 50-1600 Shearon Barris Nuclear Power Plant. Units 1 and 2

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and 504:401 o.L.

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/ p,o y[4fj 2 hereby certify that $ es of&2 hsefeinSOM NYE N " N M -

l Se Larshp Experds e 2d W 3, paas.

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p( 6-30-93 3 _,f Me krs re frte E f/eg i b

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p the US Mail, first-class postage prepaid, upon all parties whose y names are listed below, except those whose names are arked with an asterisk, for whom service was acconplished by hN JS O Mcw1 ahserei k CPH-H Q L y o f i f [r-3,

S&MOWk 4 ?IVH GWS on

${d{ SE2rYDW Df5ce**l Judges Ja ies Kelley, Glenn Bright and Jan.s carpenter (1 copy each)M g

Atomic Safety and Licensing Board j ot# y US Nuclear Megulatory Commission r

Washington DC 2o555 k.gGeorge F. Trowbridge (attorney for Applicants)

Shaw, Pittman, Potts & Trowbridge ILuthanne G. Miller 1600 M St. NW ASLB Panel g

Washington, DC 20036 USNRC Washington DC 25 5 5 h

office of the Executive Legal Directo Phyllis Lotchin, Ph.D.

Attn Docke ts 50-400/401 0.L.

los Bridle Run USNRC Chanel Hill Washington DC 20555 NC 2751h O

(pg g/

Docketing and Service Section (3x)

Dan Read CEA?E/FLP Attn Docke ts 50-hoo/hol o.L.

b office of the Secretary Waleigh, fro 7 Waveross NC 27606

1. D ' fa h ngton DC M

2o555 nr. Linda v. Little l

Governor's Waste Mgt. Bd.

NgoND. John RtInkle 511 Albemarle Bldg.

Karen E. Long 325 N. Salisbu W St.

efe Granville Rd NC 27602 Chapel Hill Ne 2751k Bradley W. Jonesfy USNRC Region II Travi.s Payne 101 Marietta St.

Edelstein & Payne Atlanta GA 30303 Blox 12601 Raleigh NC 27605 Richard Wilson, M.D.

Certified by h

i 729 Hunter St.

Apex NC 27502

. *8F2-3(a) Do Applicants have any opinpn as to eat the health effects of the radiological effluents given in Table S-3 are?

(b) If so, please state that op1 Man and given the identification of aqr documents or work papers con +24=4=g it.

(c) Please fully aite all basis, expert opinions, or authorities on dich you rely in holding the opinion inquired about in (a) above.

(d) If you had an opinion (in response to (a)), do you know if EC Staff shares that opidon or nott (e) If answer to (d) is affirmative, dat is your understanding of MRC Staff's position on the health effects of these radiological effluents?

Is it the same as your position? If not, how do the tuo differt (radiological)pplicants agree that the health effects of the effluentsas giv (f) Do A benefit balance for Harris licensing under EPA (operating license state)?

(g) Please state in h11 the basis for your answer to (f) above including any expert opirbns or documents on which you rely, any authority on dich you rely, and any other basis for your answer.

8F2 4(a) Applicants agreed that 8F2 (as admitted in your rewording) was an abissible contention, didn't yout (b) Do you agree with any part of the contentien 8F27 (c) If answer to (b) is affirmative, please state dich pari's) and for each part, explain 27' (d) If answer to (b) is other than affirmative, please state in detail all your disagreements with each part of 8F2, igiving for each part the basis of your disagreements, a list of your disagreements, and citing p 1

any authorities, experts or documents on eich you rely.

(e) If you have not formed an opinion with respectb any part of 8F, please 2

so sta e.

nalysis have Applicants made of EC tra,nE5 ate.issb h

s or had made 52 as 8F '-5(a) ma it v 1 erns (i) od chain concentration analy s (ii) radionuclide concentration valu ; (iii) doses from external emitters (iv) doses fron internal emitterst J.) Please state who made each analysis for each part of (a) above for 9,ich your answer is affirmative, state their qualifications to make the analysis, state e ether they did it for Applicants, state d ether it was done as an employee,ar as a consultant, under some other instruction or coistission from Applicants, or otherwise, and identify all documents containing 1

such analysis, for each such analysispesM1-(c) Are Applicants aware of any analysi agrone else of EC translation 520,concerning any of the matters asked a in (a)(1) through (a)(iv) above?

(d) If answer to (c) is affirnative, please identify each such analysis or study, to made it, when, and identify all documents containing each such, stating tether you possess a copy.

PRODUCTION OF DOCRMS I

Wells Eddleman hereby requesta Applicants to produce the original or best copy of all documents identified above in sesponse to the above interrogatories for inspection and copyiy at a time and place mutually agreeable. Docunents i

re Eddleman 15AA are not included in this request and may be produced when documents requested in the rest of the first round questions on 15AA would be due.

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-n-INTERROGATORIES ON SE oontimed Has CP&L supplied av estimates of health effects of emissions

• 8n-3(a) from coal-fired power plants to NRC in the past?

(b) Did CP&L ever do ag conparison of the health effoots of anissions from a coal-fired power plant and the Harris plant (1) for its own studies of d at kind of plant to build d en it was considering h M yhi Nil m g the new power nlant that eventually became H)arris (ii) for its own usefor suinission to the N at av other time or in any connection (iii or AEC in connection with the Harris construction permit (iv) for the use a

S or for distribution to any other entity besides Cr&L and the AEC/NRCf

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2 (c) Please identify all documents in dich any estimates or comparisons inquired about in (a) or (b) above were made, identifying each fully i!

that and stating wnich part of (b) (or, if appropriate, was it (a))

d it was aared about in, 3

)av EPRI studies on health effects of coal ponution?

j (d) Is CP&L aware o demy of Sciences studies on health effects of ooal 2

(ii) of any National A pollution (that term means e-dssions from coal-fired power plants.throughout this set of interrogatories) (iii) of any National Research Council studies health effects j

.on health effects of coal ponution (iv) of av EPA studies on of coal pollution (v) of any studies by scientists on health effects of coal 6

pollution (vi) of any studies by medical personnel or epidemoiologists or

]

statisticians on health effects of coal pollutiont

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O (e) For each part of (d) above for which your answer is affir.ative, g

please identify each study in detail,4nd state whether CP&L possesses a copy.

j If you do not possess a copy do you have the right to obtain a oopy?

(f) Is CP&L aware of any analysis of health effects of coal pollution j

by NRC Staff?(g) If answer to (f) is affirmative, please identify each document contain 4

such analysis tich you are aware of and state tether you possess a copy.

S ij INTERROGATORIES ON BF2 Does CP&L know of any NRC k,khsi EbE i

• • 8F2-1(a) other place, of health effects of radiological effluents of the melear fuel cycle (excepting power reactor operation), (i) as given in Table S-3 j

(ii) otherwiset (b) If answer to (a) above is affirmative, please identify each analysis 2_

or dascription, analysis or information and an docunents containirg it.

j Please state if you possess a copy or not for each such document.

8F2 2(a) Is CP&L in possession of av documents that discuss the health effects of effluents from the - 62 1 nuclear fuel cycle, 4

(1) as given in Table S-3 (ii) for parts of the cycle other than power reactor operations (iii) that document or compute a v such health effects for radiological effluents fron the nuclear fuel cycle?

(b) If answer to av part of (a) above is affirmative, for each such part please identify each such document and ten what it discusses, documents or computes.