ML20039E626

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Response to NRC First Request for Production of Documents. Related Correspondence
ML20039E626
Person / Time
Site: Byron  Constellation icon.png
Issue date: 01/01/1980
From: Chavez D
DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8201110097
Download: ML20039E626 (12)
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' 1 Sinnissippi Alliance for tha Environmant oman 326 North Avon Street *~

Rockford, ll!inois 61103 January 1, 1982 i 41AL In the Matter of e - -- ,e -: . '

Docket Nos. 50-454 CQGiONWEALTH EDISON CTPANY 5N455(OL)

(Byron Nuclear Power Station, Units 1 and 2)

DAARE/ SAFE RESPONSE TO NRC FIRST REQUEST j FOR PRODUCTION OF DOCUMBITS l

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DAARE/SAFEprovidestheseresponsestotheNRC'sFirstRequest for Production of Documents in the following categories. Unless otherwise stated, documents which DAARE/ SAFE has provided ere available for inspec-tion and copying by NRC Staff. Specific appointments for inspection may be arranged, with at least one week's notice, by phoning DAARE/

SAFE member Mr. Stanley Campbell, Monday through Friday, 97 10h Jat w],

s'y (815) 962-7373 py jg,,, n !Q y ,

u jay -D ANSRERS TO INTERROGATORIES t #

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> -*gHFp n CATEGORY 1. .

'b! I t $s Dr. Richard E. Webb, author, has granted pemission to DAARE/8AFE to make available the unpublished report, cited in DAARE/ SAFE contention four, entitled "An Analysis of the Three-4 file Island Accident," 1979 DAARE/ SAFE will make this report available to NRC Staff for inspection

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and copying. However, DAARE/ SAFE has not been authorized by Dr. Webb l

l to provide the same for more general distribution.

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8201110097 820101 PDRADOCK05000g G

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CATEORY 2.

The designations below following listed documents indicate sources other than DAARE/ SAFE from which those documents may be obtained or inspected:

(RPL) - Rockford Public Library, 215 N. Wyman Street, 'Rockford IL (ICC) - Illinois Commerce Comission, 527 East Capitol Avenue, Springfield, IL ,

t Contention 1 DAARE/ SAFE is currentlyrequesting Mr. David Stahr, Illinois Public Action Council to testify in support of DAARE/ SAFE contention 1, parts a,_

b, e, and i. Should Mr. Stahr agree to testify, DAARE/ SAFE will make the specifics of his testimony available to NRC Staff.

DAARE/ SAFE intends to place into the record of the proceedings, or use in the cross-examination of NRC Staff or Applicant witnesses, the following documents:

1. May 1979 issue of Chicago Magazine, Pages 38-41. -

G. NRC NEWS ANIKUNCDiH7TS Notice 78-22, March 28,1978

'" 77-59, October 4, 1977

" III/76-39, May 28,1976

" IE:III 75-78, September 18, 1975

3. AEC PRESS RELEASE, No. R0-98, December 16, 1974

[. Board notification published November 14, 1977 CFR, Volume 42, No. 219, pages 58988--58989 5 IURE-Oh83, Nuclear Power Plant Operating Experience-1977 (RPL)

6. WRE-0090, REPORT TO C0lGRESS ON ABNORMAL OCCURRANCES, October-December 1976, pg. 3-4; October-December 1977, pgs. 1-5; October-December 1978, Vol.1, No. 4, pgs. 21-22; July-September 1980, Vol. 3, No. 3, pg. 24 (RPL) 7., Prepared testimony of Robert J. Schultz, "In the Matter of An Invest-igation of the Plant Construction Program of the Commonwealth Edison Company"-Illinois Comerce Commission, Docket No. 80-0546.

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8. Prepared testimony of Byron Lee Jr., ICC Docket No. 80-0546.

t 9 Prepared testimony of Robert J. Schultz, Ralph L. Heumann, Mark D.

Luftig, David A. Sholz, Supplemental Testimony and Schedules Bearing Particularly on the Interim Rate Application"-ICC Docket No. 80-0546.

10. Prepared testimony of Robert R. Nathan," Economic Conditions"-ICC Docket No. 80-0546.
11. Prepared Testimony of Mark D. Luftig," Cost of Capital and Rate of Return."-ICC Docket No. 80-0346.
12. Prepared Testimony of Robert J. Schultz, " Background of Application, Financial Condition and Program of the Company"-ICC Docket No. 80-0546.

13 Prepared testimony of Gerald R. Benson, " Plant Investment Data and .

Working Capital Requirements"-ICC Docket No. 80-0546.

14. FSAR, Byron Units 1 and 2. Summary of 1978 and 1979 Iand E Reports Pertaining to Byron, Table 3.5 :-2.

15 FSAR, Byron Units 1 and 2. " Status of Byron Compliance with Division 1 Regulatory Guides." Appendix A, Table 3 5-I.

16. NRC-0IE, Reports No. 50-254/80-12;50-455/80-11, Docket No. 50-454; 50-455 17 IRC-CIE, 7.eports No.50-454/80-15; 50-455/80-14, Docket No. 50-454; 50.-455
18. NRC,IE Infomation Notice No. 80-43; December 5,1980.

19 IEC, ole Reports No. 50-454/80-22;50-455/80-21, Docket No. 50-454; 50-455, November 25, 1980.

20. NRC Notice of Violation and Inspection Report, Nos. 50-454/8005; 50-455/80-05; 180 Docket Nos. 50-454 and 50-455.
21. NRC, OIC Infomation Notice No. 8015, Axial Oriented Cracking in Pipes, April 21, 1980; NRC Docket Nos. 50-454 and 50-455
22. Byron Station Units 1 and 2 Response to IE Inspection Report Nos.

l 50-454/80-05and50-455/80-05, IRC Docket Nos. 50-454 and 50-455.

23. Byron Station Units 1 and 2, Post-Tensioning Anchorhead Failure, NRC Dacket Nos. 50-454 and 50-455, February 29, 1980.
24. NEC Notice of Violation and Inspection Report, Nos. 50-454/79-18; j 50-455/79-18; IEC Docket Nos. '50-454 and 50-455.

25 NRC Notice of Violation, and OIE Report Nos. 50-454/80-09and 50-455/

80-08, NRC Docket Nos. 50-454 and 50-455 l

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26. NURM/CR-1656 " Utility Management & Technical Resources. Executive l Summary" September 1980. (RPL) l 27 NURE/CR-1263 " Compilation of State Laws and Regulations on Trans- I portation of Radioactive Materials" January 1980. (RPL) )
28. NURE/CR-1481"Finan al Strategies for Nuclear Power Plant Decom-missioning" July 1980 (RPL)

Contention 2

- DAARE/ SAFE is currently requesting Dr. Karl Z. Morgan, Atlanta GA, Should Dr. Morgan agree to testify, testify in sup/ port DAARE SAFEof our second will make thecontention.

specifics of his testimony 'available to NRC Staff.

1 DAARE/ SAFE intends to place into the record of proceedings, or use in the cross-examination of NRC Staff or Applicant witnesses, the following documents:

1. " Nuclear Facilities and Radiation Monitoring in California: Some Implications for Public Healthu-Another Mother Fund for Peace, Interim Report, December,1975
2. IURE-0668, Staff Review of "Radioecological Assessment of the WHIL Nuclear Power Plant"
3. NRC Translation 520, "Radioecological Assessnent of the WHIL Nuclear -

Power Plant" 4 " Radiation Exposures of Hanford Workers Dying from Cancer and Other Causes," Health Physics,1977, Vol. 33, No. 5, pages 369-384.

i 5 NURE-0440, " Liquid Pathway Generic Study," excerpts 2-15, 2-16; A-7, A-8.

6. Tectimony of Roger J. Mattson, NRC-EPA' Hearing on Proposed 40 CFR Part 190, March 8,1976.

7 " Cancer and Low-Level Ionizing Radiation" Bulletin of Atomin Scientists, September 1978, pages 30-41.

3. Letter, dated April 11, 1979 from Irwin D.J. Bross, Ph.D., Director of Biostatistics, Roswell Park Hemorial Institute, addressed to Bruce Von Zellen, Ph.D., Professor of Biology, Nothern Illinois University.

9 " Environmental Radiation Protection for Nuclear Power Operators" Proposed Standards (40 CFR 190) EPA, Supplementary Information, January 5, 1976.

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10. " Report of the Work Gmup on Exposure Reduction," Interagency Task Force on Health Effects of Ionizing Radiation, June 1979
11. Correspondence by Mrs. Leo Drey, University City, MO, addressed to Dr. Thomas Mancuso, University of Pittsburgh, dated November 2,1978.
12. FSAb-Byron Station, Units 1 and 2; Chapters 11 and 15. (RPL)
13. Bymn Environmental Report, Operating License, Chapters 5, 6,11, and 15 (RPL)
14. " Low-Level Radiation Effects and Overview of Compensation Problems

.of Radiation Vict h s," Report by Dr. Thomas F. Mancuso, April 12, 1980.

15. "Recent Evidence of Increased Mortality Rates Associated with Nuclear Fallout and Radioactive Waste Discharges from Nuclear Reactors,"

Report by Dr. E.J. Sternglass, March 17, 1975

16. NURE/Chl152, " Recommended Methods for Estimating Atmospheric Concen-trations of Hazardous Vapors after Accidental Release Near Nuclear Reactor S,ites." April 1980.(RPL) 17 NURE/Cb1206, " Critical Pathways of Radionuclides to Man from Agro-Ecosystems." January 1980. (RPL)
18. NURE/Cb1728, "The Feasibility of Epidemiologic Investigations of the Health Effects of Low-Level Ionizing Radiation." Final Report. Novem-ber, 1980. (RPL) 19 NURE/Cbl539, "A Methodology and a Preliminary Data Base for Emining the Health Risks of Electricity Generation From Uranium and Coal Fuels."

, September 1980. (RPL)

20. NURm/Cbl614, " Approaches to Acceptable Risk: A Critical Guide."

December 1980. (RPL)

21. NURB}/ChlO21, PNL-3008, "Models Selected For Calculation of Doses, Health Effects, and Economio Costs Due to Accidental Radionuclide Re-leases from Nuclear Power Plaints." Ma'y 1980.

Contention 3 DAARE/ SAFE does not anticipate obtaining external testimony to support this contenti)n. DAARE/ SAFE will thus rely upon the documents listed below to submit evidence into the record of proceedings and for purposes of cross-examination of witnessess. Should DAARE/ SAFE chose to introduce expert infonnation, DAARE/ SAFE will provide the specifics of such testimony to the

! NRC Staff at the earliest possible moment.

I DAARE/ SAFE intends to place into the reccrd of the proceedings, or use in the cross-examination of NRC Staff or Applicant witnesses, the following documents:

1. " Evacuation Plans, the Achilles heel of the nuclear industry," Ron Lanoue; Public Citizen,1975
2. Commonwealth Edison's Generic Evacuation Plan, (GSEo), Revision 1.,

July 30,1980. (RPL)

. 3 NURE-0654, FMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," January, 1980.

4 NURE/CR-1875, " Evaluation of Emergency Operating Procedures."'

5 NURm/CR-1856, PNI,-3662, Vols.1 and 2, " Analysis of Evacuation TLne Estimates Around 52 Nuclear Power Plant Sites."

6. NURE/CR 2005, SAND 81-7074, " Checklist for Evaluating Emergency Procedures Used in Nuclear Power Plants."

7 NURE/CR-1977, PNL-3713, " Guidelines for Preparing Emergency Procedures for Nuclear Power Plants."

8. NURE-0553, "Beyond Defense-In-Depth: Cost and Funding of State and Local Government Radiological Emergency Response Plans and Preparedness in Support of Commercial Nuclear Power Stations."
9. ~ NURE/CR-1620, " Survey of Current State Radiological Energency Response Capabilities for Transportation Related Incidents." (RPL) 10, NURE/CR-1149, SAND-79-2017, "%rgency Response Scenarios for Transportation Accidents invc2.ving Radioactive Materials." (RPL)
11. The Zion Nuclear Station and Bnergency Evacuation Fact Sheet, Catherine Quigg, Pollution and Environmental. Problems, Inc., Draft, January 4, 1979
12. Press Release.--Catherine Quigg, Illinois Safe Energy Alliance, January 14, 1980.
13. NURE/CR-0744, " Identification and Assessment of the Social Impacts of Transportation of Radioactive Materials in Urban Environment," July, 1980. (RPL) .
14. Transcript, " Emergency Preparedness Workshop," held at Ramada Inn, O' Hare, Chicago, Illinois, January 22, 1980. (PSL)
15. NRC, "In the Matter of: Meeting on Implementation of Emergency Planning Requirements for Commercial Power Reactors, King of Prussia, Pennsylvania; August 20, 21, 22, and 24, 1979 (RPL) 1 I

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16. NRC Special Report, "In the Matter of: Public Meeting, Staff Briefing on Emergency Planning," April 25, 1979 (RPL) 17 FEMA, Report to the President, " State Radiological Emergency Planning and Preparedness in Support of Comercial Nuclear Power Plants, June, 1980. (RPL)

Contention 4 Dr. Richard Webb, Toledo, Ohio, has indicated he will testify in behalf ofDAARE/SAFEcontentionfour. Included below are the documents Dr. Webb intends to place into the record of proceedings, or use in the cross.-

cxamhation of NRC Staff or Applicant witnesses:

1. "The 7MI Accident-Was It a Class Nine Accident?" Chapter 12, Report by Dr. Richard Webb, July 23, 1979
2. "A Documentary History of R. E. Webb's Involvement in the 7MI Accident,"

compiled by Dr. Richard Webb.

3. "A Petition Calling for the Full Review of Hazards of Nuclear Power Plants and Radioactive Waste Disposal." Report by Dr. Richard Webb, May 20, 1978.
4. "The Potential Hamful Consequences of Catastrophic Accidents in Nuclear Power Plants." Report by Dr. Richard Webb, February,1980.

5 " Summary Analysis of the Accident Hazards of Nuclear Power Plants and the Problems of Radioactive Waste Disposal, with Commentaries." Report by Dr. Richard Webb, April 20, 1981.

6. Wbbb, Richard. The Accident Hazards of Nuclear Power Plants. University of Massachusetts Press, Amherst, Massachusetts,1976.
7. Human Reliability Analysis, Section 6-1 in Appendix III-Failure Data of WASH-1400 (Draft): " Reactor Safety Study-An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants." U.S. AEC, Washington, D.C. , August, 1974 (RPL)
8. "Prelhinary Human Factors of the Zion Nuclear Power Plant." Alan Swain, Sandia Laboratories, October,1975. (RPL) 9 "The Accident Hazards of Spent Fuel Storage at the Salem Nuclear Power Plant, Salem, New Jersey." Testimony by Dr. Richard Webb.
10. NURED/CR-1132, "Best Esthate LOCA (LOSS-OF-COOLANT ACCIDENT) Radiation l

i Signature." June, 1980. (PSL) l

! 11. NURED/CR-1730, " Data Su maries of Licensee Event of Prhary Containment i Penetrations at U.S. Commercial Nuclear Power Plants." (RPL) t

12. NURED/Cb1363, Vol.1, Vol. 2, Vol. 3, " Data Summaries of Licensee Event Reports of Valves at U.S. Comercial Nuclear Power Plants,"

May, 1980. (RPL)

13. NUREG/Cb1362, " Data Summaries of Licensee Event Reports of Diesel Generators at U.S. Commercial Nuclear Power Plants," March,1980. (RPL) 14., NURED/CR 0940, " Uncertainty Analysis for a PWR Loss of Coolant Accident I Blowdown Phase Dnploying the RELA 4/ MOD 6 Computer Code," April,1980.

(RPL)(M) 15 NURED/Cb1104, Sandia-79-2002, " Preliminary Analysis of the Containment Failure Probability by Steam Explosions Following a Hypothetical Core Meltdown in a LWR." March, 1980. (RPL)(M)

16. Testimony by Dr. Charles Kelber to the ACRS Ad-Hoc Committee on Class Nine Accidents-May 9,1980.

17 NURED/CR-1410, " Report of the Zinn / Indian Point Study," Vol.1 (Sandia),

Vol. 2 (LASL). (RPL)

18. NURED/Ch1409, " Summary of theZ . ion / Indian Point Study." (RPL) 19 RE: Public Service El.ectric and Gas Company (Salem Nuclear Generating Station, Unit 1) NRC Docket No. 50-272, "NRC Staff Response to Board Question No. 4. Regarding the Occurrence of a Class Nine Accident at TMI," B. H. Smith, August 25, 1979 (RPL)
20. NURED/Cb1250, Three Mile Island, A Report to the Commissioners and the Public, NRC Special Inqtury Group (U.S. N.R.C., Washington, D.C. , '

J anuary, 1980). (RPL)

21. The Need for Change: The Legacy of 'IMI, Report of the President's
  • Commission on the Accident at Three Mile Island. (WT,)
22. Letter to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Pennits, "

Subject:

Prelim 2 nary Clarification of TMI Action Plan Requirements," September 5,1980.

23. NUREG-585, "TMI-2 Lessons Learned Task Force Final Report."

Contention 6 DAARE/ SAFE is currently req 2esting Dr. Earl Gulbransen to testify in support of contentions six and seven. Should Dr. Gulbransen agree to testify, DAARE/ SAFE will make the specifics of his testimony available to IEC Staff at the earliest possible moment.

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DAARE/ SAFE intends to place into the record of proceedings, or use in the cross-examination of IEC Staff or Applicant witnesses, the following documents:

1.' Bulletin of Atomic Scientists, June 1975, page 5 Letter from Dr. Gulbransen.

2.

BMI-2020,(ProgressReport, Task 5. July-December,1978) April,1980." (RPL) Evaluating Stren 9

3 "The Zirconium Connection." Report by Dr. Danial M. Pisello, May 14, 1979

4. " Letter from Mrs. Leo Dray to Rep. Joe D. Holt, Missouri House of Representatives.

5 NIJRED/CR-1132, PNL-2787, "A Survey of Potential Light Water Reactor Fuel Rod Failure Mechanisms and Damage Limits." March, 1980. (RPL)

6. FSAR-Byron Units 1 and 2.

7 Evidentary documents previously cited by DAARE/ SAFE to support contention four; identified by numbers 5, 6, 9, 16, 20, 21, 22, and 23, wm also be relied upon to support this contention.

Contention 7 In addition to Dr. Gulbransen's possible testimony, DAARE/ SAFE intends to place into the record of proceedings, or use in cross-examination of NRC Staff or Applicant' witnesses, the following documents:

1.' NURED/CR-1561, SAND-80-1495, "The Behavior of Hydrogen During Accidents in Light Water Reactors," October,1980.

2. NRC NHfS ANNOUNCEMENT'y No. 80-93, October 3,198(b-NRC Proposes Hydrogen Control and Degraded Core Requirements for Nuclear Power Reactors.

3 Evidentary documents previously cited by DAARE/ SAFE to support contention four; identified by numbers 1, 2, 4, 7, 10, 12, 14, 16, 19-23, will also be relied upon to support this contention.

Contention 8 DAARE/ SAFE does not' anticipate obtaining external testimony to support this contention. DAARE/ SAFE will thus rely upon the documents listed below mceedings and for purposes of cross-to submit evidence examination into theShould of witnesses. record of p/ SAFE choose to introduce expert DAARE infomation, DAARE/ SAFE will provide the specifics of such testimony to the NRC Staff at the earliest possible moment.

1. NURE/CR-2082, ORNL HASRD-95, " Monitoring for Compliance with Decommissioning Temination Survey Criteria." June, 1981.
2. NURm-U/07, "A Methodology for Calculating Residual Radioactivity ievels Following Decommissioning." October, 1980. (RPL) 3 Letter from Mrs. Leo Dray, addressed to Mr. Harold Denton, Director, D.L. , N.S. NRC, July 16, 1980.
4. Letter from Mrs. Leo Dray, addressed to Mr. Paul Pettit, Program Manager, D.O.E., January 4,1979
5. NURE-0686, " Draft Environmental Statement for Decontamination of Dresden, Station, Unit 1." (RPL) r
6. "A Plea for an Environmental Impact Statement on a Major Federal Action Proposed for this Spring 1979, in Illinois." Plea by Mrs. Leo Dray addressed to various public officials, March 18, 1979
7. Science Magazine, Vol. 200, June 30,1978. (RPL)
8. NURE-0686, July 16,1980, ittached Comments by Dr. Bruce von Zellen.'

(RPL)

Contention 9

. DAARE/ SAFE does not anticipate obtaining external testimony to support -

this contention. DAARE/ SAFE will thus rely upon the documents listed below roceedings and for purposes of cross-to examination of witnesses. Should DAARE SAFE choose to introduce expert submit evidence into the record of p/

information, DAARE/ SAFE will provide the specifics of such testimony to the NRC Staff.at the earliest possible moment.

1. "Research and Development Status Report-Nuclear Powec Division." EPRI Journal, Vol. 3, No. 3, April, 1978. (RPL)
2. " Westinghouse Steam Generator Symposium," April, 1973, page 5. (RPL) 3 License Event Report, "Parie Island Unit 1 Steam Generator Tube Break,"

October 16, 1979 (RPL)

4. " Corrosion of PWR Steam Generators." Nuclear Energy, 1979, Vol. 18, April, No. 2, pages 117-132.
5. Proposed Statement of Policy Concerning Reactor Safety Study and Need for Rulemaking Resulting from the Risk Assescaent Review Group Report--

Union of Concerned Scientists, November 1,1978.

6. O.I.E. Infomation Notice No. 79-37, "CracMng in Low Pressure Turbine Discs." December 28, 1979
7. Appendix B; Byron Station Units 1 and 2, SER, " Report on the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, May 13, 1975 (RPL)
8. IMRB3-0663, " Draft Environmental Statement Related to Steam Generator Repair at the Surry Power Station, Unit No. 1," March, 1980.

9 NURM692, " Final Environmental Statement Related to Steam Generator Repair at the Surry Power Station, Unit No.1," July,1980.

10. NURE/CR-1595, PNL-3454, " Radiological Assessment of Steam Generator Removal and Replacement: Update and Revision," December, 1980.
11. NUREG-0410, "lRC Program for the Resolution of Generic Issues Related to Nuclear Power Plants," Report to Congress, January 1, 1978
12. NRC, PB-243 767, Safety Evaluation Report Related to Construction of Byron Station, Units 1 and 2, Braidwood Station, Units 1 and 2; Docket Nos. STN-50-454, STN-50-455, STN-50-456, STN-50-457; August 1, 1975, Appendix B.
13. IRC Staff letter addressed to Mr. Cordell Reed, Commonwealth Edison, August 1, 1979 14 ACRS Generie Letters. Letter dated November 15, 1977 (RPL)
15. NURED-0578, IMI-2 Iessons Learned Task Force Status Report and Short Term Recommendations. (RPL)
16. ACRS, Report to Congress, January, 1978.

17 ACRS, Report t'o Congress, January, 1979

18. " Evidentary documents previously cited by DAARE/ SAFE to support contention four; identified by numbers 3, 5, 7, 12, 13, 16, 18, and 20-23, will al.9o be relied upon to support this contention.

19 Evidentary documents previously cited by DAARE/ SAFE to support contention eight; identified by numbers 1, 2, 5, and 7, will also be relied upon to support this contention.

20. NURED-0471, " Generic Task Problem Descriptions", June 1978.

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d InsupplementtodocumentscitedinthisResponse,DAARE/SAFEintends to submit into the record, or as evidence, portions of the NRC-issued Byron FSAR, DES, SER, EIS, and the MHB Report commissioned by the Rockford League of Women Voters.

Documents provided to the NRC Staff in this Response will be updated by DAARE/ SAFE's Response to Commonwealth Edison's First Round of Interrogatories, and as more information becomes available.

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The undersigned, a member of DAARE/ SAFE, certifies that on this date-she served a copy of this " Response" on each member of the service list by United States mail, postage prepaid, or by other means as appropriate.

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%, i cblivnL 6A en AR Diane Chavez h l

i Date: January 1, 1982 cc/cervicelist l

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