ML20023A851

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Supplemental Responses to Discovery Requests.Prof Qualifications & Certificate of Svc Encl
ML20023A851
Person / Time
Site: Clinch River
Issue date: 10/18/1982
From: Hibbitts H
JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
To:
National Resources Defense Council, Sierra Club
References
NUDOCS 8210200082
Download: ML20023A851 (27)


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00CMETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '82 Odi18 P2 51 In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

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PROJECT MANAGEMENT CORPORATION )

) Docket No. 50-537 TENNESSEE VALLEY AUTHORITY )

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(Clinch River Breeder Reactor Plant) )

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SUPPLEMENTAL RESPONSES TO NATURAL RESOURCES DEFENSE COUNCIL, INC.

AND THE SIERRA CLUB'S DISCOVERY REQUESTS Pursuant to 10 C.F.R. 5 2. 740(b) , the United States Department of Energy and Project Management Cor-poration, for themselves and on behalf of the Tennessee Valley Authority (the Applicants), hereby provide supple-mental responses to the Natural Resources Defense Council, Inc. and the Sierra Club's discovery requests.

Supplemental Response to Eighteenth Set of Interrogatories IV. Contention 5 INTERROGATORY

1. Provide the information requested below for each of the following facilities:

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a. Oak Ridge National Laboratory;
b. Y-12 Plant; 8210 20 0 ce2, G y33

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c. K-25 Plant (Oak Ridge Gaseous Diffusion Plant; (1) Describe the national security function (s), if any, performed at each. facility.

(2) If an evacuation of such a facility were required, how many people would I

be required to remain at each facility for national security, or other reasons if the dose to such people were likely to reach:

(a) 1 rem;

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i (b) 5 rems;  ;

(c) 25 rems; (d) 100 rems; (e) 250 rems; (f) 500 rems; (3) Identify fully the national security impact, if any, of losing access to each facility; (a) for one week; (b) for one month; (c) for three months; (d) for six months; (e) for one year; (f) indefinitely.

RESPONSE

The Thermal Margin >Beyond Design Basis (TMDDB) base

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case HCDA ~ is being evaluated for impact on national security and national energy supply. Site specific dose calculations have been reviewed by the operators of the Y-12 Plant and the Oak Ridge Gaseous Diffusion Plant (ORGDP). It is likely that bo'th plants would be manned for the duration of the initial release by essential personnel only.

If so, production at the Y-12 Plant would be curtailed for a short time period, e.g., 1-2 weeks. Pro-duction at the ORGDP would probably not be curtailed since the gaseous diffusion cascade can continue to operate with a minimal number of operators and support personnel. Thus production at these plants would be either unaffected, or affected for a very short time period by the TMBDB base case accident.

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See CRBRP-3, Vol. 2; Chapter 4.

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Supplemental Response to Requests For The Identification Of Witnesses r

Except as indicated below, Applicants' witnesses will be those identified in Applicants' Supsilemental Discovery  ;

Responses filed on August 6, 1982.

Contention 2e George Clare i Walter Dietrich Lee Strawbridge Copies of Statements of Professional Qualiffi ations have previously been provided.

l Contentions 4 and 6(b)(4)

Edward Penico Glenn A. Hammond A copy of Mr. Penico's Statement of Qualifi_ cations was previously provided. Mr. Hammond's Statement is attached.

Contentions 7(a) and (b)

Copies of Statements of Messrs. /buderson and ,

1 Kanshal are attached.

Contentions 6(a), 6 (b) (1) , 6 (b) (2) , and 6(b)t(3)

A copy of Mr. Newton's Statement Ers attached.

Contention 8 Copies of Statements of Messrs. DEsney, Murdock,  ;

and Weinstein are attached.

Contentions ll(b) and 11(c)

A copy of Dr. Preston's Statement fis attached.

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STATEMENT OF QUALIFICATIONS Carl A. Anderson, Jr.

Project Manager, Large Plant Projects Westinghouse Advanced Reactors Division ,

Madison, Pennsylvania 15663 Since January 1979, I have beer. Project Manager, Large Plant Pi rj ects ,' Is ith responsibility for reactor design and development of 'the LMFBR plant to follow Clinch River, technical interactions with LMFBR programs in the United Kingdom, France, Germany and Japan, fusion development, and other advanced reactor programs.

I received the degree of Mechanial Engineer from Stevens Insti tute of Technology in 1956, and the degrees of Master of Science in Mechanical Engineering in 1957 and Doctor of Philosophy in Nuclear Engineering in 1961 from Mascachusetts Institute of Technology. In 1971, I completed the Program for Management Development at the Harvard Business School.

From 1961 to 1964, I was employed by Sandia Corporation at Sandia National Laboratory, Albuquerque, New Mexico, first as a Section Supervisor and later as a Division Supervisor. I directed design, construction and operation of the Sandia Engineering Reactor and the Sandia Nuclear Assembly for Reactor Experiments. I. supervised a nuclear dosimetry laboratory, a gamma irradiation facility, cryostats, hot laboratories, remotely

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operated machinery, and pulsed neutron experiments. '

From 1964 to 1967, as a Staff Member of the Los Alamos ,

Scientific Laboratory in Los Alamos, New Mexico, I participated in fast reactor research and development. The work centered on the Fast Reactor Core Test Facility and the LMFBR cores planned for operation therein, with associated work on correlation function analysis, fission product yields, beat transfer, mechanical design and plant transient analysis.

I joined the Westinghouse Electric Corporation Advanced Reactors Division in 1967.

From 1967 to 1968, I was Project Manager responsible for the 1000 MWe LMFBR Design Study and the Large Sodium Pump Study.

From 1968 to 1971, I was Manager, LMFBR Reactor Engineering, responsible for conceptual design and analysis of the reactor f or the Westinghouse LMFBR Demonstration Plant. This included the nuclear, thermal-hydraulic and mechanical design' of components within the reactor vessel.

From 1971 to 1974, I was Manager, PFTF Reactor Engineering. I directed the design, procurement and fabrication l of the FFTF reactor, including reactor vessel, head, instrument trees, in-vessel handling machines, shielding, core support structure, core basket, core restraint system, flux. nonitor l

system and control rod systems.

From 1974 to 1975, I was Manager of Technology, responsible for the Division's fuels and materials research and development, sodium loop testing, friction and wear testing, fast

breeder fuel fabrication and testing, and stress analysis methods development.

From 1975-to 1976, I was Reactor Plant Project Manager in the CRBRP Project. I- supervised the analysis, design, procurement and fabrication of those portions of the plant for which Westinghouse was technically responsible, including: fuel, radial blanket, shield, control system, reactor vessel and head, s

core ' support structure, reactor internals, primary piping, intermedie.te [ heat exchanger, check valves, instrumentation and controls.

From 1976= to 1979, I was Proj ect Manager, Prototype Large Brec, der Reactor. In this position I was responsible for all aspects of the effort to design the Prototype Large Breeder Reactor, a near-commercial LMFBR.

I am a member. of the American Society of Mechanical Engineers, the American Nuclear Society, the American Association for the Advancement of Science and the Society of the Sigma Xi.

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STATEMENT OF QUALIFICATIONS Glenn A. Hammond i I

Chief, Technology Development and Implementation Branch Office of Safeguards and Security U.S. Department of Energy Washington, DC '20545 l

I received a Bachelor of Science degree in chemistry with minors in mathematics and physics from East Tennessee State University in 1956.

Following graduation, I joined the Atomic Energy Commission in 1956 as a technical intern. in..th,e Production Division, Oak Ridge Operations Office. From 1956 to 1961, I had responsibilities in the technical analysis of nuclear materials production and on-site quality assurance programs; and for review, evaluation and on-site inspection of methods and procedures f or measurements and saf eguards. I also completed the Nuclear Saf ety Training School at the Oak Ridge School of Reactor Technology and, af ter transferring to AEC Headquarters in Washington in 1961, completed graduate-level courses in nuclear reactors and operations research.

From 1961 to 1973, I served as physical scientist at AEC Headquarters in development and administration of policies, 4

procedures and standards for the U.S. nuclear materials

caf eguards programs; and perf ormed field evaluations of ,

implementation practices.

From 1973 to 1979,-I was Chief of three branches in saf eguards and security during successive reorganizations f rom AEC to the Energy Research and Development Administration to the current Departmenc of Energy. In these positions, I was responsible for research and development programs to improve or establish technology and systems for nuclear materials safeguards. These programs resulted in major advancements in e

conceptual designs, diversion path analysis methods, near-real-time systems and supporting measurements and nondestructive assay technology. For example, a safeguards conceptual design for mixed oxide (MOX) processing was completed during this period and serves as a basis for the designs at the FMEF.

From 1979 to 1981, I was Chief, International Support Branch in DOE's Office of Safeguards and Security with responsibilities fcr research and development in safeguards approaches and technology to improve the effectiveness of international saf eguards in support of U.S. nonproliferation and national security obj ectives. Major proj ects included technology and systems for uranium enrichment and spent fuel reprocessing plants; and direct technical support to the International Atomic Energy Agency, Vienna, Austria. ,

Since late 1981, I have been in my current position of l

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Chief, Technology Development and Implementaton Branch, DOE's Office of Safeguards and Security with responsibilities for development, test and evaluation of physical security, materials control and accountability components and systems required to ensure protection of DOE nuclear materials and facilities. These DOE-sponsored programs are carried out primarily by the national laboratories such as Los Alamos and Sandia. Projects include identification of deficiencies at DOE production f acilities, development of advanced integrated systems designed to meet site-specific needs and assist field managers in application; and concepts and advanced hardware and systems f or implementation at new facilities such as FFTF, FMEF, CRBRP, and proposed design I options for reprocessing facilities such as the Demonstration Reprocessing Plant (DRP).

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STATEMENT OF QUALIFICATIONS Narinder N. Kaushal Engineering Division Clinch River' Breeder Reactor Plant Project Office P.O. Box 0 Oak Ridge, TN 37830 Dr. Kaushal is the Deputy Assistant Director for Engineering at the Clinch River Breeder Reactor Plant Project.

In this capacity he serves as the principal technical, administrative and operating official of the Engineering Division, coordinating and executing approved programs, policies and decisions of the Assistant Director. He also advises and assists the Assistant Director in the formulation of engineering prog' rams and policies and acts for the Assistant Director with full responsibilities and authorities assigned to that position, except where redelegation by* the Director is expressly prohibited.

Dr. Kaushal also serves as the Chief, Reactor and Plant Systems Branch, a position which he has held since February 1978.

In this capacity, he. directs the day-to-day activities of CRBRP participants involved in the design, development, fabrication,

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test, evalu'ation, installation, checkout, startup test, safety, operation, and plant security of the major systems and components of the reactor and balance-of-plant.

From February 1975 to 1978, Dr. Kaushal served as the Chief, Instrumentation, Control and Electrical Branch with a full range of management responsibilities for the reactor and plant controls, instrument'ation and electrical systems.

. Dr. Kaushal has a broad technical background in Applied Nuclear Physics with expertise in reactor physics, reactor engineering, radiation protection and control, nuclear and digital instrumentation, computer applications and electronic data processing. He holds bachelor's degrees in mathematics and physics, masters degrees in both physics and electronics and doctorate degrees from Rensselaer Polytechnic Institute in nuclear physics and solid-state physics. From 1967, when he received his doctorate degree, until he j oined CRBRP in 1974, he was a Research Associate in Rensselaer Polytechnic Institutes' Linear Acceleration Laboratory, where he had supervisory responsibility for the Fast Nautron Spectrum Analysis Program.

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I STATEMENT OF QUALIFICATIONS James F. Murdock ,

Engineering Division Clinch River Breeder Reactor Plant Project Office

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P.O. Box U Oak Ridge, TN 37830 l l

l Current Position: Reactor Engineer Reactor and Plant Components Branch ,

U.S. DOE - CRBRP Proj ect Office Mr. Murdock received a B.S. degree in Metallurgical Engineering f rom Virginia Polytechnic Institute in 1959 and a M.S. degree f rom the University of Tennessee in 1964.

From 1950 to 1957 he was employed at the Oak Ridge National Laboratory as a cooperative engineering student in the Solid State Division. His work involved assembly and disassembly in hot cells of experiments from test reactors.

From 1959 to 1967 he was employed as a metallurgist in the Metals and Ceramics Divison of the Oak Ridge National Laboratory. He performed research studies of radioisotope tracer diffusion in pure metals and alloys.

From 1967 to the present, he was employed by the United States Atomic Energy Commission (then ERDA and now DOE) . After n

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i an intensive training program in reactor theory and practical operation in the Operations Division of the Oak Ridge National Laboratory, he was assigned to the position of Site Representative for the Division of Reactor Development and Technology (DRDT) at the Boiling Nuclear Superheat Reactor l (BONUS) near Rincon, Puerto Rico. He was liaiaon between the contractors at BONUS and the various AEC Program and contracting organizations during the decommissioning of the BONUS facility.

He provided review and comment on the decommissicning plans and approval of the detailed procedures f or decommiss_oning. Upon completion of the BONUS decommissionin g in 1970 . e was assigned the position of Site Representative f or .DRDT 'at the Lacrosse Boiling Water Reactor, Genoa, Wisconsin. He was liaison between the~ operating and support organizations at LACBWR and the AEC Program and contracting organizations providing on-site monitoring of the operating plant. In 1972 he asst.ned the additional duties of Site Representative f or the decc.ev.e bsioning

, eff orts at the Elk River Reactor, Elk River, Minnesota. His i

responsibilities at Elk River were the same as his responsibilities at BONUS. Upon the sale of LACBWR to the Dairyland Power Cooperative in 1973 ani. subsequently the completion of the Elk River dismantlement in 1974 he was assigned i

the position of Site Representative for the Chicago Operatic;.s

- Office (CH) at the Westinghouse Advanced Reactors Division ,

(E- ARD) , Madison, Pennsylvania. He perf ormed liaison duties between the CH demonstration Project Office and the Division of l l

Reactor Research and Development and the E-ARD f or the CRBRP and the FFTF.

In 1975 he was assigned to the Engineering Div.ision of the CRBRP Proj ect Office. He was responsible for the engineering management of the reactor internals design and the supporting development programs until his assignment to an engineering group responsible for the engineering planning of the Operations, Maintenance and Testing Program of the CRBRP. From 1978 to the present time he has been assic-ed to the Reactor and Plant Components Branch of the Project Office with responsibility for the design and f abrication of the steam generators and for the procurement of reactor internals hardware.

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STATEMENT OF QUALIFICATIONS l' THE S. M. STOLLER CORPORATION ALBERT A. WEINSTEIN N.

r Mr. Weinstein is manager of Engineering at SMSC responsible for the areas of reactor servicing and operations, mechanical systems design, and real-time systems applicatic:.s.

As Manager of Engineering he provides consulting services to nuclear utilities on ref ueling systems analysis, plant operational and maintenance support, design review and quality assurance, and plant arrangement and system design. In this context he is responsible for saf ety analysis and licensing support in special areas, such as cask drop, and fuel handling accidents, and leads SMSC efforts in support of facilities design review, including fuel stcrage pool arrangements and fuel inspection and reconstitution f acilities.

Mr. Weinstein also leads activities at SMSC related to nuclear power plant decommissioning. He served on the AIF task force assigned to monitor and review the preparation of AIF/NESF-009SR, "An Engineering Evaluation of Nuclear Power Reactor Decommissioning Alternatives". He has reviewed LWR plant designs for ease of decommissioning, and has participated in the l

actual decommissioning of the BONUS nuclear plant in Puerto Rico, where he served as the resident engineer, responsible for program }

l definition, planning and scheduling. Mr. Weinstein has directed the preparation of decommissioning cost estimates for both PWR and BWR nuclear power plants.

He is presently also Project Manager for the D.C. Cook NPP combined RE&M/Secureity System and as such, is responsible for system development and installation, client and subcontractor interf ace and other project related activities. Mr. Weinstein has been extensively involved in the design and application of the RE&M System since its beginnings and continues in this .

capacity. He is also responsible for service administration after installations are complete.

Mr. Weinstein entered the nuclear business in 1957 at Combustion Engineering CoWpany, where he participated in the mechanical design and analysis of the SIC reactor core with responsibility for startup and testing procedures relating to mechanical saf ety of the core. He assisted in subsequent reactor disassembly and inspection of radioactive core components. In 1960 he joined the United Nuclear Corporation, and in 1976 Mr.

Weinstein was named Manager of the Engineering Section of the Mechanical Design Departbent.

Mr. Weinstein has directed the design of fuel l

inspection equipment and supervised the on-site inspection of commercial irradiated fuel, utilizing underwater video equipment and measuring devices. While at UNC Mr. Weinstein served on the

I Technical Support Team under contract to the AEC to provide i

technical assistance f or the Elk River, BONUS, and Lacrosse Nuclear Reactor Plants. He was assigned lead responsiblity for the technical support for the BONUS Nuclear Reactor in Puerto Rico.

Mr. Weinstein received a B.S. in Civil Engineering from the University of Southern California in 1954, and a M.S. in Applied Mechanics f rom the University of Connecticut in 1959. He has performed additional graduate work in engineering mechanics and is a licensed professional engineer in the State of Connecticut.

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STATEMENT OF PROFESSIONAL QUALIFICATIONS Richard K. Disney Current Position: Manager, Shielding Analysis Nuclear Systems Engineering Engineering Department Westinghouse Electric Corporation Advanced Reactors Division P.O. Box 158 Madison, Pennsylvania 15663 Education: B.S. in Nuclear Engineering, Kansas State University, 1958 Graduate Studies, Washington University of St.

Louis, 1962.

Since 1971, I have been employed at the Westinghouse Advanced Reactors Divsion, Waltz Mill Site at Madison, Pennsylvania, where I have been assigned various management positions.

I have been Manager of the shielding analysis group at ARD since 1974 with primary responsibility for the Clinch River Breeder Reactor Project radiation protection, radiation analysis, and shielding design efforts. In this capacity, I have'been responsible for efforts to define the radi, tion shielding and radiation prctection philosophy of CRBRP. Included in the

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I responsibilities are prediction of radiation environments in CRBRP reactor systems, development of the ALARA review program for CRBRP, review of radiation shielding designs of CRBRP plant component and systems, technical guidance of experimental programs related to LMFBR radiation shielding, review of the refueling system radiation protection and shielding design efforts, and development of radiation source terms for components, systems, and radiological and saf ety analy.ses or studies.

In 1972-1973 I was responsible for the radiation shielding design, radiation environment predictions, and personnel radiation exposure predictions for'the Fast Flux Test Facility sodium-cooled nuclear test reactor. Responsibilities included review of plant shielding, definition and review of radiation sheilding experimental programs, definintion of component radiation environment, definition of radiation source terms, analysis of reactor system shielding systems, prediction of radiation shielding performance, and personnel radiation exposure predictions.

In 1971 I was responsible for the development of advanced radiation transport methods f or use in LMFBR radiation shielding anelysis and the implementation of these methods on large scale mainframe computer systems.

In the period 1968-1971 I was assigned to a management position in the NERVA (Nuclear Engine for Rocket Vehicle Application) Proj ect at the Astronuclear Laboratory of t

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Westinghouse Electric Corporation at Large, Pennsylvania. In

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this capacity, I was responsible for the analysis of nuclear radiation shielding experiments and for the development and evaluation of advanced analytical techniques and data for nuclear, radiation, and shielding design in the NERVA Project.

In the period 1965-1968 I was assigned to a variety of proj ects including the NERVA Proj ect. I was responsible f or the development of advanced computational methods including advanced discrete ordinate transport methods. I was also responsible for predictions of radiation environments in the large-size propulsion reactors f or space vehicle applications. In addition, l I established radioisotope fuel form and radiation shielding l requirements for an implantable circulatory support system (artificial heart).

In the period 1962-1965 I was assigned to the Advanced Projects Department of Astronuclear Laboratory. I was responsible for radiation and shielding analysis of advanced nuclear-electric propulsion systems and nuclear rockets, nuclear design of compact liquid metal reactors, and shielding analyses for the Lunar Base Nuclear Power Plant conceptual design study.

During the period 1961-1962 I was employed by the internuclear company of Clayton, Missouri. In this capacity I was responsible f or the design and specification oi the radiation shielding for two university research reactors, the 5 Mwt Kansal Research Reactor at Kyoto, Japan and the 10 Mwt Missouri University Research Reactor at Columbia, Missouri.

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In the period 1958-1961 I was employed by the Babcock &

Wilcox Company at the Atomic Energy Division, Lynchburg, Virginia. Job responsibilities were in radiation source definition and radiation shielding design on the following Projects: 1) the tonsolidated Edison No. 1 Nuclear Power Plant,

2) the N.S. Savannah Nuclear Propulsion Merchant Ship, and 3) the Advanced Test Reactor materials test in Idaho Falls, Idaho.

STATEMENT OF QUALIFICATIONS R. Julian Preston Senior Research Staff Member Biology Division 9k "

Oak Ridge National Laboratory Oak Ridge, TN 37830 Dr. R. Julian Preston is a Senior Research Staff Member in the Biology Division, Oak Ridge National Laboratory, that is operated by the Union Carbide Corporation for the Department of Energy. His current positon is Group Leader of the Ma lian Cytogenetics Group. He is particularly involved in studies of the estimation of the genetic effects of radiation and. chemical agents for man from human and laboratory animal studies.

Dr. Preston has worked at the Oak Ridge National Laboratory since 1970. Prior to this, he was *a Staf f Scientist at the Medical Research Council Radiobiology Unit, Harwell, England. He was a member of the Biophysics Group with emphasis on the genetic effects of radiations of different qualities.

Dr. Preston received a Bachelor of Arts (Genetics) and

, Master of Arts degrees f rom Cambridge University, England, and a l

Doctor of Philosophy degree in Radiation Biology from Reading University, En nd. He was born in London, England, on June 5, 1942, and presently resides in Oak Ridge, Tennessee.

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UNITED STATES OF AMER ~ICA NUCLEAR REGULATORY COMMISSION

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In the Matter of UNITED STATES DEPARTMENT OF ENERGY ,

PROJECT MANAGEMENT CORPORATION )

Docket No. 5C1-537 TENNESSEE VALLEY AUTHORITY

)

(Clinch River Breeder Reactor' Plant)

)

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AFFIDAVIT OF H. W AYNE HIBBITTS , being duly sworn , dieposes and says as follows:

1. That'he is employed as Chief Safety and Environymental Branch, Public Sa fety Division, CRBRP Project Of fic,e , Box U, C0ak Ridge ,

Tennessee 37830.

2. That he is duly authorized to answer the Interrwgatory numbered IV in NRDC's 18th Set of In te rro gatori e s .

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3. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

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SUBSCRIBED and SWORN to before me this 10th day of October, 1982. ,

..y Commission.ExpigsJpril.23,1se4 '

ry b My Commission expires , 198 . MI?eV"J"* /

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of '

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UNITED STATES DEPARTMENT OF ENERGY )

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PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

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CERTIFICATE OF SERVICE Service has been effected on this date by personal delivery or first-class mail to the following:

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~* Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board Nuclear Regulatory Commission Washington, D.C. 20545 (2 copies)

Dr. Cadet H. Hand, Jr.

Director Bodega Marine Laboratory University of California P.O. Box 247 Bodega Bay, California 94923

  • Mr. Gustave A. Linenberger Atomic Safety & Licensing Board Nuclear Regulatory Commission Washington, D.C. 20545
  • Daniel Swanson, Esquire Stuart Treby, Esq re.

Office of Executi Legal Director Nuclear Regulatory Commission Washington, D.C. 20545 (2 copies)

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  • Atomic Safety & Licensing Appeal Board Nuclear Regulatory Commission Washington, D.C. 20545 l i
  • Atomic Safety & Licensing Board Panel Nuclear Regulatory Commission Washington, D.C. 20545
  • Docketing & Service Section Office of the Secretary Nuclear Regulatory Commission Washington, D.C. 20545 (3 copies)

William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Michael D. Pearigen, Assistant Attorney General State of Tennessee l Office of the Attorney General l 450 James Robertson Parkway Nashville, Tennessee 37820 Oak Ridge Public Library l Civic Center l

, Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace , Esquire W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)

( 1725 Eye Street, N.W.

Suite 600 Washington, D.C. 20006 (2 copies)

. Mr. Joe Walker f 401.Roane Street Harriman, Tennessee 37748 Ellyn R. Weiss, Esquire Harmon & Weiss 1725 Eye Street, N.W.

Suite 506 Washington, D.C. 20006

Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 William E. Lantrip, Esquire Attorney for the City of Oak Ridge P.O. Box 1 I

Oak Ridge, Tennessee 37830

    • Leon Silverstrom, Esquire Warren E. Bergholz, Jr. , Esquire Department of Energy 1000 Independence Avenue, S.W.

Room 6B-256 Washington, D.C. 20585 (2 copies)

    • Eldon V. C. Greenberg, Esquire Tuttle & Taylor 1901 L Street, N.W.

Suite 805 Washington, D.C. 20036 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building Suite 1007 Nashville, Tennessee 37219 Ueorge

$. Edga yf Atto . y for V.oj ect Management Corporation DATED: October 18, 1982

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Denotes hand delivery to 1717 H Street, N.W, Washington, D.C.

    • / Denotes hand delivery to indicated address.

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