ML20081H141
| ML20081H141 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/02/1983 |
| From: | Mauro J, Oneill J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Eddleman W EDDLEMAN, W. |
| Shared Package | |
| ML20081H118 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8311070326 | |
| Download: ML20081H141 (18) | |
Text
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'fl0V -$- pH d; UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION rrrerecru"_,_'f i C ; ' P ", ,
. ,, a BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,
In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
APPLICANTS' RESPONSES TO -
WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTION 8F(2) TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et al.
(SIXTH SET)
Applicants Carolina Power & Light Company and North Caro-lina Eastern Municipal Power Agency, pursuant to 10 C.F.R.
S 2.740b, hereby submit the following responses to " Wells Eddleman's General Interrogatories and Interrogatories on Con-tention 8F(2) to Applicants Carolina Power & Light Company, et al. (Sixth Set)." The provision of answers to these interrog-atories is not to be deemed a representation that Applicants consider the information sought to be relevant to the issues to be heard in this proceeding.
9311070326 831102 PDR ADOCK 05000400 0 PDR
RESPONSES TO GENERAL INTERROGATORIES INTERROGATORY NO. G-1(a). Which contentions of Wells Eddleman do Applicants agree are now admitted in this proceed-ing, NRC Dockets 50-400/401 0.L.?
ANSWER: The contentions of Intervenor Eddleman which are admitted to this proceeding are set forth in various memoranda and orders issued by the Atomic Safety and Licensing Board, all of which are available to Mr. Eddleman.
INTERROGATORY NO. G-1(b). For each such contention, provide for any answers to interrogatories by Wells Eddleman which Applicants have previously or presently received (except those suspended by Board order, if any), the following informa-tion.
ANSWER: The answers to General Interrogatories herein are restricted to Eddleman Contention 8F(2).
INTERROGATORY NO. G-1(c). Please state the name, present or last known address, and present or last known employer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) upon whom Applicants relied (other than their attorneys) in making such answer.
ANSWER: The following person provided information upon which Applicants relied in answering the interrogatories on Eddleman Contention 8F(2).
PERSON INTERROGATORY NO(S).
Dr. John J. Mauro 8F(2)-6, 8F(2)-7(a-d)
Samantha Francis Flynn, Esq. 8F(2)-7(e-f)
Dr. Mauro is employed by Envirosphere Company, a division of Ebasco Services, Inc., a contractor to Applicants. Ms. Flynn is Associate General Counsel of Carolina Power & Light Company.
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INTERROGATORY NO. G-1(d). Please identify all facts con-cerning which each such person identified in response to G-1(c)(1) above has first-hand knowledge.
ANSWER: See answer to Interrogatory No. G-3(c).
INTERROGATORY NO. G-1(e). Please identify all facts and/or documents upon which each person identified in response to G-1(c)(2) above relied in providing information to respond to the interrogatory, including the parts of such documents relied upon.
ANSWER: All facts or documents relied upon by those individuals identified in the answer to Interrogatory No.
G-1(c) are indicated within each response to the specific ,
interrogatories on Contention 8F(2).
I INTERROGATORY NO. G-1(f). Please identify any other document (s) used or relied upon by Applicants in responding to the interrogatory.
ANSWER: See answer to Interrogatory No. G-1(e).
INTERROGATORY NO. G-1(g). Please state which specific fact each document, identified in response to G-1(e) and G-1(f) above, supports, in the opinion or belief of Applicants, or which Applicants allege such document supports.
ANSWER: In this instance, Applicants have not relied on any document in responding to interrogatories on Contention t
8F(2) herein.
INTERROGATORY NO. G-1(h). Please state specifically what information each person identified in response to G-1(c)(1) or G-1(c)(2) above provided to or for Applicants' affiant in an-swering the interrogatory. If any of this information is not documented, please identify it as " undocumented" in responding to this section of General Interrogatory G-1.
l ANSWER: See answer to Interrogatory No. G-1(c).
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l INTERROGATORY NO. G-2(a). Please state the name, present or last known address, title (if any), and present or last known employer, and economic interest (shareholder, bondholder, contractor, employee, etc.) if any (beyond expert or other 1 witness fees) such person holds in Applicants or any of them, for each person you intend or expect to call as an expert witness or a witness in this proceeding, if such information
- has not previously been supplied, or has changed since such in-
- , formation was last supplied, to Wells Eddleman. This applies to Eddleman and Joint Contentions as admitted, or stipulated by Applicants.
ANSWER: Applicants have not yet identified the expert or other witnesses they expect to call in this proceeding. When l and if such witnesses are identified, Applicants will supplement this response in a timely manner.
INTERROGATORY NO. G-2(b). Please identify each contention regarding which each such person is expected to testify.
ANSWER: See answer to Interrogatory No. G-2(a).
i l INTERROGATORY NO. G-2(c). Please state when you first contacted each such person with regard to the possibility of l such person's testifying for Applicants, if you have contacted such person.
f ANSWER: See answer to Interrogatory No. G-2(a).
INTERROGATORY NO. G-2(d). Please state the subject mat-ter, separately for each contention as to which each such person is expected to testify, which each such person is ex-pected to testify to.
ANSWER: See answer to Interrogatory No. G-2(a).
f l
INTERROGATORY NO. G-2(e). Please identify all documents or parts thereof upon which each such witness is expected to, plans to, or will rely, in testifying or in preparing testimo-ny.
i ANSWER: See answer to Interrogatory No. G-2(a).
INTERROGATORY NO. G-3(a). Please identify any other source (s) of information which Applicants have used to respond to any interrogatory identified under G-1 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.
ANSWER: Applicants have identified all such other sources of infermation, if any, within the answers to the specific interrogatories set forth herein.
INTERROGATORY NO. G-3(b). Please identify any other source (s) of information not previously identified upon which any witness identified under G-2 above, or other witness, has used in preparing testimony or exhibits, or expects to use in testimony or exhibits, identifying for each such source the witness who is expected to use it, and the part or part(s) of such source (if applicable) which are expected to be used, and, l'
if not previously stated, the fact (s) or subject matter (or both) to which such source relates.
3 ANSWER: See answer to Interrogatory No. G-2(a).
INTERROGATORY NO. G-4(a). Please identify all documents, and which pages or sections thereof Applicants intend or expect to use in cross-examination of any witness I call in this hear-ing. For each such witness, please provide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Applicants believe they relate to, and make i the document (s) available for inspection and copying as soon as possible after Applicants decide or form intent to use such document in cross-examination.
ANSWER: Applicants have not yet identified which documents, if any, they intend to use in cross-examination of Mr. Eddleman's witnesses.
INTERROGATORY NO. G-4(b). Please identify any undocumented information Applicants intend to use in l cross-examination of each such witness for me.
- ANSWER
- See answer to Interrogatory No. G-4(a).
-S-
INTERROGATORY NO. G-5(a). For each contention Applicants state or admit is an admitted Eddleman contention under G-1(a) above, or an admitted joint intervenor contention, please state whether Applicants have available to them experts and informa-tion, on the subject matter of the contention.
ANSWER: Applicants have available to them experts and in-formation on the subject matter of Contention 8F(2).
INTERROGATORY NO. G-5(b). If the answer to (a) above is other than affirmative, state whether Applicants expect to be able to obtain expertise in the subject matter, and informati 3 n on it, and if not, why not.
ANSWER: Not applicable.
INTERROGATORY NO. G-6(a). For each document identified in response to any interrogatory herein, or referenced in response to any interrogatory herein, please supply all the following information which has not already been supplied:
(i) date of the document (ii) title or identification of document (iii) all authors of the document, or the author (iv) all qualifications (professional, technical) of each author of the document (v) the specific parts, sections or pages, of the document, if any, upon which Applicants rely (vi) the specific information each part, section or page identified in response to (v) above contains (vii) identify all documents used in preparing the document, to the extent known (and also to the extent not iden-tified in the document itself)
(viii) state whether Applicants possess a copy of the document (ix) state all expert opinions contained in the document, upon which Applicants rely, or identify each such opinion.
(x) identify the contention (s) with respect to which Ap-plicants rely upon (a) the expert opinions (b) the facts iden-tified in the document
(xi) state whether Applicants now employ any author (s) of the document, identifying each such person for each document (xii) state whether Applicants have ever employed any author (s) of the document, identifying each such person for each document (xiii) identify all sources of data used in the document.
Answers to all the above may be tabulated or grouped for effi-ciency.
ANSWER: There are no documents upon which Applicants rely in responding to the interrogatories herein. As such, Appli-cants are not separately responding to Mr. Eddleman's request for production of documents.
INTERROGATORY NO. G-7(a). Please identify all documents which Applicants plan, expect or 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 response to G-1(a), or (ii) is the subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is expected to be offered.
ANSWER: Applicants have not yet identified those documents they intend to offer as exhibits relating to Eddleman Contention 8F(2).
INTERROGATORY NO. G-7(b). Please identify all documents which Applicants plan, expect or intend to use in cross-l examination of any other parties' witnesses or joint intervenor witness in this proceeding, with respect to (i) Eddleman con-tentions identified under G-7(a)(1) (or G-1(a)) above, or any other Eddleman contention which is the subject of interroga-tories in this set; (ii) each Joint contention now admitted in this proceeding; (iii) per our agreement of 4-8-83, each con-tention of each other party to this proceeding which is cur-rently admitted. Please identify for each such document the
- witnesses, or witness, and all contentions with respect to whom (or which) that document is planned, expected, or intended to be offered or used.
ANSWER: Applicants have not yet identified those documents they intend to use for cross examination of any witnesses.
INTERROGATORY NO. G-7(c). Please identify which of the documents identified in response to (b) above (i) will be offered into evidence by Applicants, and (ii) which of the same documents Applicants expect to offer into evidence or intend to offer as evidence or exhibits in this proceeding.
ANSWER: See answer to Interrogatory No. G-7(b).
INTERROGATORY NO. G-10(a). Where the above general inter-rogatories, and/or specific interrogatories below, or any of them, call for identification of documents, (i) and no documents are identified, is that the same as Applicants stating that there are no documents responsive to this general interrogatory, in each case where no documents are identified?
(ii) and documents are identified, is that the same as Appli-cants stating that the identified documents are the only ones presently known which are responsive to the interrogatories?
(iii) If your 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)(i) 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 expert opinion of any person (s) identified as having contributed information to that response? (ii) and facts are given or identified (or a fact is) in response, but no documents are identified, does that mean Applicants have no documents containing such fact (s)?
(iii) If your answer to (i) above is affirmative, please state for each such response all qualifications of each expert upon 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 than affirmative, please state which opinions, if any, given in response to interrogatories (general or specific) herein is the opinion of an expert, identify each expert whose opinion you used in response to each interrogato-ry, and state in full the qualifications of each such expert.
(v) If your answer to (i) above is other than affirmative, please identify all opinions of non-experts used in your re-sponses, 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 contains a fact not previously documented in your response (s),
stating what the fact is, and at what page, place, chapter or other specific part of the document contains such fact.
9 ANSWER:
(a)(i) Yes.
(ii) Yes.
(iii) Not applicable.
(iv) Not applicable.
((b)(1) Yes.
(ii) See Answers to G-1(e), (b) and (g).
(iii) See Attachment A. Ms. Flynn's notice of appearance is on record in this proceeding.
(iv) Not applicable.
(v) Not applicable.
(vi) Not applicable.
INTERROGATORY NO. G-11. For each answer to each interrog-atory herein (or any subpart or part thereof), please identify each item of information in possession of Applicants (including facts, opinions of experts, and documents) which (a) contradicts the answer you made, (i) in whole (ii) in part (please identify each such part for each item of information identified); (b) casts doubt on your answer (1) in whole (ii) in part (please identify each such part for each item of infor-mation identified). (c) Please identify all documents not al-ready identified in response to parts (a) and (b) above (and their subparts) which contain any item of information asked for in (a) or (b) above. Please identify for each such document what information item (s) it contains and what answer (s) each such item is related to.
ANSWER: Applicants have no such information.
9_
ANSWERS TO INTERROGATORIES ON EDDLEMAN 8F(2)
INTERROGATORY NO. 8F(2)-6(a). Do Applicants agree with NRC Staff that NUREG-0668 is a draft, not a final, position?
(b) If answer to (a) is other than affirmative, please state all reasons for your position or disagreement. (c) Have Ap-plicants or anyone working for them made any study of what the dose estimates would be if NRC Translation 520 were changed to reflect all the different estimates given in NUREG-0668 in (d) Do Applicants know if any-criticism of Translation 520?
one else has calculated or studied what the dose estimates given in NRC Translation 520 would become if (i) any (ii) each (iii) all different estimate (s) in NUREG-0668 were used in place of the ones actually used in Translation 520? (e) If answer to any part of (d) is affirmative, identify each such person or group and all documents containing each such study.
(f) Please state or identify any documents known to you which state estimates inquired about in (c) or (d) above, other than NUREG-0668 gnd NRC Translation 520. (g) Please state whether Applicants rely on NUREG-0668 in this proceeding, or any parts of it, stating which pages or parts (if any). (h) Please state whether Applicants rely on the letter from E.K.F. Bautz identified in response to my interrogatory 8F2-4(d), or any parts of it, in this proceeding, identifying any particular parts relied upon. (j) Please state whether Applicants rely on the GRS " Comment" of March 1979, identified in response to my interrogatory 8F2-4(d), identifying any parts of it you rely on in this proceeding. (k) Please state whether (i)
NUREG-0668 (ii) the letter of E.K.F. Bautz (iii) the GRS
" Comment" cited above, has ever been (aa) published in a peer-reviewed scientific journal (bb) published in a peer-reviewed engineering journal (cc) published in the pro-ceedings of any scientific socity or group (dd) submitted for publication by any peer reviewed journal of science or engi-neering or any field of science or engineering. (1) For all parts or subparts of (k) above for which your answer is affir-mative, please identify (i) the document publication date, if any (ii) the date of submittal, if known (iii) the journal or publication which published it, if any (iv) the date, volume, issue and page numbers where it was published, if known (v) the address of the editors of such publication, if known.
ANSWER:
8F(2)-6(a): Yes.
(b): Not applicable.
(c): No, not for the Wyhl Nuclear Power Plant.
(d): Not specifically, although each time the NRC Staff or any applicant for a nuclear operating license properly assesses the dose from radiological releases, the values of parameters as discussed in NUREG-0668, rather than the inappropriate values used in NRC Translation 520, are utilized.
(e): See Answer to (d) above.
(f): Applicants are not aware of any such documents.
(g): Yes, in the context of demonstrating the universal scientific criticism of NRC Translation 520. The entire document establishes the fact of such criticism.
(h): See Answer to (g) above.
(j): See Answer to (g) above.
(k): Not to Applicants' knowledge.
(1): Not applicable.
INTERROGATORY NO. 8F(2)-7(a). Do Applicants know if health effects of uranium fuel cycle emissions (as set forth in Table S-3) have been litigated in any other nuclear plant operating license proceeding? (b) Please identify each license proceeding in which these health effects were liti-gated. (c) Do Applicants know if the models, data, assump-tions, or conclusions (or any of them) of NRC translation 520 have been litigated in any other NRC licensing proceeding? (d)
Please identify each such proceeding known to you and state (if known) what matters relating to NRC translation 520, and what contention (s) relating to NRC translation 520 were litigated or are being litigated in each such proceeding. (e) Have Appli-cants participated in any NRC proceeding (i) related to determining the health effects of radioactive effluents given in Table S-3 (ii) related to the determination of the values for effluent emissions given in Table S-3? (f) for any part of (e) for which your answer is affirmative, please identify each such proceeding and state what position, if any, Appli-cants took in it, whether a decision has been reached in the
1 proceeding, and if so, what that decision was as it related to Table S-3 emissions and their health effects. (g) Are there other ongoing NRC proceeding known to Applicants in which the health effects of radioactive emissions as set forth in Table S-3 are at issue? (h) Please identify each such proceeding and state (if known) the contention (s) relating to health effects of radioactive emissions set forth in Table S-3 that are at issue therein, whose contention each is, and whether you possess any documents relating to that contention in that pro-ceeding. Please list, for each such contention, the documents relating to it which Applicants possess.
ANSWER:
8F(2)-7(a): Yes.
(b): Applicants are aware of the litigation of certain aspects of the health effects of the uranium fuel cycle in Pennsylvania Power and Light Co., et al. (Susquehanna Steam Electric Station, Units 1 and 2), Docket Nos. 50-387-OL, 50-388-OL.
(c): Yes.
(d): See Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit No. 1), Docket No. 50-289-SP.
The matters litigated in the above cited proceeding can be determined from public records regarding that proceeding.
(e): (i) No. (ii) Yes.
(f): Applicant Carolina Power & Light Company partic-ipated, as a member of a group of utilities, in the Table S-3 rulemaking and litigation. The validity of the Table S-3 rule was finally resolved in Baltimore Gas & Electric Co. v. National Resources Defense Counsel, Inc., 103 S. Ct. 2246, 462 U.S.
(1983). The position of the parties in the litigation is summarized in the above cited Supreme Court decision and in earlier court decisions cited therein.
NOTE: This response does not include information regarding radon, the health effects of which are being treated generically and are outside the scope of Contention 8F(2).
Si m' ted y: ,
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.M Thc mas A. Baxter, P . C[ /
Jo n H. O'Neill, Jr. [
S W, PITTMAN, POTTS
&}.ROWBRIDGE 00 M Street, N.W. U Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants Dated: November 2, 1983
Attachment A g
- 4/83 Page 1 of 4 JOHN ISEPH MAURO Certified Health Physicist
SUMMARY
OF EXPERIENCE (Sirce 1970)
Total Experience - 12 years total experience. Six years experierce in calculating projected exposures of radionuclides in the environment ano i evaluating the biological significance of these exposures. Six years experierce in managing radiological and hazarocus chemical consulting projects.
Professional Affiliations - Health Physics Society ANSI Committee N18 - Guide to Standarc Format and Content of Emergency Plans for Nuclear Power Generating Facilities Education - PhD, New York University,1973 - Biology, Radiological Health MS, New York University, 1970 - Biology, Raciological Health BS, Lorg Island University,1967 - Biology, Bacteriology -
Awards - Alvin Gruder Memorial Award Founders Day Award REFRESENTATI'E ENVIROSP{RE PROICT EXFERIENCE (Since 1973) 1973 to Present Radiological Assessmer.t Scientist / Director Raciological Assessment anc Health Physics Department Regonsible for evaluating the radiological impact of nuclear power plant operation for Ebasco's client utilities. Preparea the requisite sections of the Environmental Reports and Safety Analysis Reports and defended these analyses before the NRC, the Aavisory Committee on Reactor Safeguards, State Site Certification Boards and the Atomic Safety ano Licensing Boards. Providea these services for 10 nuclear power plants.
Re consible for the calculation of projected racionuclice inventories ano liquid and gaseous source terms associated with various aspects of. normal plant operation and hypothetical accidents. Experienceo in the calculation of the pro,)ected environmental transport, distribution ano concentration of radionuclides released in the liquid and gaseous effluent of nuclear power facilities; the calculation of the projecteo exposures to man and organisms other than man oue to racionuclides in the environment; and the evaluation biological effects of, exposure to radiation.
i Page 2 of 4 ,
l JOHN JOSEPH MAURO (Continued)
Experienced in the design of envircrvnental radiological surveillance p;ograms for nuclear power facilities. Has installeo ano calibrateo radiation detection instrumentation at low level radiological laboratories ano participated in the training of laboratory personnel.
Has managed the preparation of several emergency response plans ano implementation proccoures for comercial nuclear power facilities ano for state agencies responsible for emergency response planning.
Has provideo radiological and emergercy response training to health physicists, nuclear engineers and members of state ano local agencies responsible for. emergency plannirg.
Has managed the preparation of the envirorsnental/raciological technical specifications ano of fsite cose calculation manuals for several nuclear power facilities.
Has managed nunerous consulting projects in the area of cecommissioning, envirtnmental monitoring, environmental cosimetry in-plant health physics for the nuclear fuel cycle.
Has performed several toxic chemical stuoies in stoport of nuclear power plant control room design and in the assessment of the raciological ano chemical tcxicity of low level radioactive wastes.
PRIOR EXPERIENCE (2 years)
Private part-time consulting work.
Workeri on the radiclogical effects sections of a nuclear power plant environmental impact report. Draftea answers to interrogatories from an AEC licensing hearing.
New York University Institute of Envirorsnental Medicine Assistant Research Scientist (2 years)
Performed research work on the life history of white perch in the Huoson River. Aided in the cataloging and enuneration of invertebrates in tne Hudson River. Participated in a project to oevelop techniques to determine and ability of various micro-organisms to organify inorganic mercury.
Publications and Presentations Mauro, J J and M E Wrenn 1972. A review of radiocesium in acpaatic biota. Presented at the Health Physics Society Annual Meeting, Las Vegas, Nevada, June 12-16.
c cc
a PaBe 3 of 4 J0m JOSEPH MAURO (Continueo)
Mauro, J J and M E Wrenn 1973. Reasons for the absence of a trochic level effect for raciocesium in the Hudson River Estuary. Presenteo at the IRPA meeting held in Washington, D.C. in October. Publisheo in the ,
proceedings of that meeting.
Mauro, J J, and J Porrovecchio. Numerical criteria for in-plant as low as is reasonably achievable proceeoings of the 9th Mio-Year Topical Symposium of the Health Physics Society.
Mauro, J J, O Michlewicz and A Letizia 1977. Evaluation of environmental dosimetry mooels for applicability to possible racioactive waste repository oischarges, Y/0Wl/ SUS-77/45705, Septemoer.
Mauro, J J 1978. Cogarison of gaseous effluent stancaros for nuclear ano fossil fuel power proouction facilities. Proceecings of the Decemoer 1976 Annual Meeting of the American Nuclear Society.
Mauro, J J, J Thomas, J Ryniker ano R Fellman 1979. Airoorne uranium, its concentration and toxicity in uranium enrictment facilities, -
K/P0/ SUS-79/31057/1, February .
Mauro, J J, K E Lino, J D Levine, L Yemin, H J Howe, Jr ano C W Pierce 1979. Safety relatea research requireo to stoport future fusion researen reactors. Presented at the Annual Meeting of the American Nuclear Society-San Francisco, November.
Mauro, J J and E P 0'Donnell 1979. A cost-benefit comparison of nuclear ano nonnuclear health and safety protective measures anc regulations.
Nuclear Safety, Vol. 20 No. 5, September-October.
Mauro, J J 1980. A real time computer program for offsite raciological igact assessment. Presented at the 1980 Annual Meeting of the American Nuclear Society. TANSAO 34 1-899.
Mauro, J J, R Bhatia and G Martin 1980. Effects of containment purge on the consequences of a loss of coolant accioent. Presenteo at tne 1960 Annual Meeting of the American Nuclear Society. TANSAO 34 1-899.
Mauro, J J and S Marschke 1980. Radiocesium transport into reservoir bottom sediments - a licensing approach. Presenteo at the 1960 Annual Meeting of the ANS. TANSAO 34 1-899.
Mauro, J J and D Michlewicz 1981 oeployment concepts for Real Time Envirornental Dosimetry Systems. Presented at the 1981 Annual Meeting if the Health Physics Society.
Mauro, J J and E P 0'Donnell 1982. The role of the Architect / Engineer in the Emergency Planning Process. Presenteo at the Annual Meeting of the American Nuclear Society. June 6-10, 1982.
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6
' Pge 4 of 4 JOHN JOSEPH MAURO (Continueo) .
Mauro, J J and W R Rish 1982. Dealing with Uncertainties in Examining Safety Goals for Nuclear Power Plants. In NUREG/CP-0027. Proceeoings of the International Meetirg on Thermal Reactor SP*ety.
Mauro, J J, S Schaffer, J Ryniker, ano J Roetzer. Survey of Chemical ano Radiological Indices Evaluating Toxicity. National Low-Level Raoicactive Waste Management Program. 00E/LLW-17T . March, 1983.
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i UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION f
i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of -)
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 & 2) )
AFFIDAVIT OF JOHN J. MAURO City of New York \ ) ,
) ss State of New York )
John J. Mauro, being duly sworn according to law, deposes and says that he is a consultant to Carolina Power & Light Company in the area of radiological assessment and health physics, and that the answers to Interrogatories 8F(2)-6 and 8F(2)-7, contained in " Applicants' Responses to Wells Eddleman's General Inter-
- rogatories and Interrogatories on Contention 8F(2) tc Applicants' i
Carolina Power & Light Company, et al. (Sixth Set)" are true and correct to the best of his information, knowledge and belief.
l l
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// eh Johnjf. Mauro, Ph.D.
~
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! Sworn to and subscribed to
( before me this & day of November 1983.
^
I Notary Pubt c. S t
/ h [. [ N . OIPE4605003 N yog l Notary Public
- Qualifed in Kings County i
Cert. Filed in New York Coun My commission expires Commrssion Expires Mac 4
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